Implementation Timeline for Updated Nutrition Requirements in School Meals

USDA's Food and Nutrition Service (FNS) published the final rule titled, Child Nutrition Programs: Meal Patterns Consistent With the 2020-2025 Dietary Guidelines for Americans, which is the next step in continuing the science-based improvement of school meals and advancing USDA’s commitment to nutrition security. The changes are based on a comprehensive review of the Dietary Guidelines for Americans, 2020-2025 (Dietary Guidelines), robust stakeholder input on the school meal patterns, including the nearly 136,000 public comments on the proposed rule, and lessons learned from prior rulemakings. While this rulemaking is effective July 1, 2024, USDA is gradually phasing in required changes over time.

The table below summarizes when changes in the rule will be implemented. The final rule does not require program operators to make changes to current meal patterns right away. Required changes to the school meal patterns will not begin until school year (SY) 2025-26 and will be phased in through SY 2027-28.

This table only addresses impacts to the National School Lunch Program (NSLP) and School Breakfast Program (SBP); other child nutrition program (CNP) impacts are outlined on the Implementation Timeline for Updated Nutrition Requirements in CACFP and SFSP.

Implementation Dates for School Meal Programs

Added Sugars

indicates implementation date. Blank cells indicate no changes/no new requirements.

Requirements	SY 2024-25	SY 2025-26	SY 2026-27	SY 2027-28
Product-based limits for breakfast cereals, yogurt, and flavored milk
Weekly limit (<10% weekly calories from added sugars for both lunch and breakfast programs)

Milk

Whole Grains

Sodium

indicates implementation date.

Requirements	SY 2024-25	SY 2025-26	SY 2026-27	SY 2027-28
Lunch - 15% reduction from current sodium limits: Grades K-5: < 935 mg Grades 6-8: < 1,035 mg Grades 9-12: < 1,080 mg	Continue sodium target 1A from transitional final rule while working toward meeting future requirement.
Breakfast - 10% reduction from current sodium limits: Grades K-5: < 485 mg Grades 6-8: < 535 mg Grades 9-12: < 570 mg	Continue sodium target 1A from transitional final rule while working toward meeting future requirement.

Afterschool Snacks

indicates implementation date. Blank cells indicate no changes/no new requirements.

Requirements	SY 2024-25	SY 2025-26	SY 2026-27	SY 2027-28
Revises the definition of “child” to clarify that children aged 18 and under at the start of the school year may receive reimbursable NSLP afterschool snacks throughout that school year.1
Aligns NSLP afterschool snack meal pattern requirements for K-12 children with the CACFP snack meal pattern requirements.

Meal Modifications

indicates implementation date. Blank cells indicate no changes/no new requirements.

Requirements	SY 2024-25	SY 2025-26	SY 2026-27	SY 2027-28
Clarifies existing policy guidance by including in regulation that state licensed healthcare professionals may write medical statements to request meal modifications on behalf of students with disabilities in the school meal programs.1
Defines a state licensed healthcare professional as an individual authorized to write medical prescriptions under state law, consistent with current policy guidance.1
In addition to state licensed healthcare professionals, also permits registered dietitians to write medical statements to request meal modifications on behalf of students with disabilities in the school meal programs.
Regarding non-disability requests, makes clear in regulation that USDA encourages schools to meet participants’ non-disability dietary preferences when planning and preparing school meals.

Buy American

indicates implementation date. Blank cells indicate no changes/no new requirements.

Requirements	SY 2024-25	SY 2025-26	SY 2026-27	SY 2027-28
Maintains the two current limited exceptions for the Buy American provision, which is consistent with current policy guidance, and includes them in regulation. Also provides the use of an exceptions list when items are determined to not be available in the U.S.	Schools will continue to be able to use the limited exceptions to the Buy American requirement and can use the provided exceptions list beginning July 1, 2024.
Institutes a phased-in cap on total non-domestic food purchases. For school food authorities unable to meet the phased-in cap, a temporary accommodation will be available.	In SY 2025-26, non-domestic food purchases are capped at 10 percent. In SY 2028-29, non-domestic food purchases are capped at 8 percent. In SY 2031-32, non-domestic food purchases are capped at 5 percent.
Requires school food authorities to maintain documentation to demonstrate use of one of the two limited exceptions, except when items are listed on the exceptions list.1
Requires school food authorities to include the Buy American requirements in documented procurement procedures, solicitations, and contracts for foods and food products procured for NSLP and SBP using informal and formal procurement methods, and in awarded contracts. This is consistent with current policy guidance.1
Adds in regulation the following definition of “substantially” for the Buy American provision, which is consistent with current policy guidance: “Substantially using agriculture commodities that are produced in the United States means over 51 percent of a food product must consist of agricultural commodities that were grown domestically.”1
Adds in regulation language explaining how the Buy American requirements apply to fish and fish products offered in NSLP and SBP, consistent with current policy guidance.1

Menu Planning and Operational Flexibilities

Implementation Date: July 1, 2024

The menu planning and operational flexibilities summarized below are available to school meal program operators on July 1, 2024; however, NSLP and SBP operators are not required to change menus or operations as a result of these provisions.

Meat/Meat Alternates at Breakfast

Establishes a combined grains and meats/meat alternates meal component in the SBP and removes the requirement for schools to offer 1.0 ounce equivalent of grains each day at breakfast. Schools may offer grains, meats/meat alternates, or a combination of both, to meet the minimum ounce equivalent requirements in this combined meal component.

Substituting Vegetables for Grains in Tribal Communities

Allows school food authorities and schools that are tribally operated, operated by the Bureau of Indian Education, and that serve primarily American Indian or Alaska Native children to serve vegetables to meet the grains requirement in NSLP and SBP.

Substituting Vegetables for Grains in Guam and Hawaii

Allows all schools in Guam and Hawaii to serve vegetables to meet the grains requirement.

Traditional Indigenous Foods

• Continues to allow and clarifies in the regulation that traditional indigenous foods may be served in reimbursable school meals.
• Regulations will include the definition of traditional foods from the Agriculture Improvement Act of 2014, which defines traditional food as “food that has traditionally been prepared and consumed by an [American] Indian tribe,” including wild game meat, fish, seafood, marine mammals, plants, and berries.

Substituting Vegetables for Fruits at Breakfast

• Continues to allow schools to substitute vegetables for fruits in the SBP and simplifies the vegetable variety requirement:
  • Schools choosing to offer vegetables at breakfast one day per school week have the option to offer any vegetable, including a starchy vegetable.
  • Schools choosing to substitute vegetables for fruits at breakfast on two or more days per school week are required to offer vegetables from at least two different vegetable subgroups.²

Nuts and Seeds

• Allows nuts and seeds to credit for the full meats/meat alternates component, removing the 50 percent crediting limit for nuts and seeds at breakfast, lunch, and supper.
• This provision also streamlines CNP requirements by aligning nut and seed crediting across all programs and meals.

Beans, Peas, and Lentils at Lunch

• Changes the name of the “legumes (beans and peas)” vegetable subgroup and all references to “legumes (beans and peas)” and “dry beans and peas (legumes)” to “beans, peas, and lentils,” consistent with the terminology used in the Dietary Guidelines and to implement consistent terminology across CNPs.
• Allows schools the option to count beans, peas, and lentils offered as a meat alternate at school lunch toward the weekly beans, peas, and lentils vegetable subgroup requirement.
• Under this option, menu planners would determine which overall meal component beans, peas, and lentils would count toward, either vegetables or meats/meat alternates. Beans, peas, and lentils offered to students as either vegetables or meat alternates can count toward the weekly requirement to offer ½ cup of beans, peas, and lentils vegetable subgroup in the NSLP.

Competitive Foods/Smart Snacks in Schools

• Adds bean dip to the list of foods exempt from the total fat standard in the Smart Snacks regulations:
  • This exemption applies to products marketed as hummus, as well as bean dips made from any variety of beans, peas, or lentils.
  • Bean dip will continue to be subject to the saturated fat standard for Smart Snacks, as well as all other Smart Snacks requirements.

Whole Grains (Entrée Definition)

Updates the definition of “entrée item” in competitive food standards regulations to clarify that entrées containing either whole grain-rich and/or enriched grains offered as part of a reimbursable school meal may qualify as an entrée item when sold à la carte as a Smart Snack.

Professional Standards

Allows state agency discretion to approve the hiring of an individual to serve as a school nutrition program director in a medium or large local educational agency, for individuals who have 10 years or more of school nutrition program experience but do not hold a bachelor's or an associate's degree. Directors hired under this exception must have a high school diploma or GED.

Geographic Preference

• Expands the geographic preference option to allow “locally grown,” “locally raised,” or “locally caught” as procurement specifications (e.g., a written description of the product or service that the vendor must meet to be considered responsive and responsible) for unprocessed or minimally processed food items.
• Continues to allow state agencies and program operators to adopt their own definition of “local” and does not prescribe a federal definition of “local” for the purpose of procuring local foods.

Synthetic Trans Fat

Removes the dietary specification prohibiting synthetic trans fat in the school lunch and breakfast programs. Schools will no longer need to include the synthetic trans fat prohibition in their procurement documentation, and state agencies will no longer need to review product labels or manufacturers specifications with the synthetic trans fat dietary specification. The U.S. Food and Drug Administration (FDA)’s actions to eliminate synthetic trans fat from the U.S. food supply effectively banned trans fats from being added to foods made or sold in the U.S. USDA used this opportunity to reduce burden on program operators by eliminating a requirement that USDA determined is no longer necessary.

¹ Note: These provisions, which must begin to be implemented in school year 2024-25, do not make changes to the meal patterns. Several of these changes include in regulation requirements that are already in place through policy guidance.
² Note: For school year 2024-25, Congress has provided schools the option to offer any vegetables in place of fruits at breakfast (no subgroup requirements).