Guidance for Accepting Processed Product Documentation for Meal Pattern Requirements

This memorandum is being reissued with updated references to clarify common issues related to inaccurate or misleading product literature, product labels, and factsheets; provide guidance about how product literature can be used to make purchasing decisions; and share sample product formulation statements that can be used to document a product’s contribution to meal pattern requirements.

Factsheets and product labels provide a way for food manufacturers to communicate with program operators about how their products may contribute to the meal pattern requirements for meals served under the Department of Agriculture’s (USDA) Child Nutrition (CN) Programs. The USDA Food and Nutrition Service (FNS) frequently receives inquiries about inaccurate or misleading product literature, product labels, and factsheets.

CN Labeled Products

Schools and other program operators are not required to offer processed products with CN labels. However, it is important to recognize that CN labeled products provide an assurance that foods provide the stated contributions toward CN meal pattern requirements. CN labeled products are processed under a quality control plan administered by USDA’s Agricultural Marketing Service or Department of Commerce (USDC) National Marine Fisheries Service using guidelines provided by FNS. CN labels are only available for items that contribute toward the meat/meat alternates component of the meal pattern.

Program operators must keep records of the original CN label from the product carton. If the actual CN label is laser printed on the product carton or cannot be easily removed, then a photocopy of the valid CN label may be provided during an administrative review, as acceptable documentation. A photograph of the CN Label while it is attached to the product carton is also acceptable documentation. CN labels that are photocopied or photographed must be visible and legible.

Since CN Labeled products provide program operators with a warranty against audit claims when the product is used according to the manufacturer’s instructions, state reviewers must not request a product formulation statement when a valid CN label logo and crediting statement is provided during an Administrative Review.

FNS is currently working with the Agricultural Marketing Service to develop a CN label verification system. This system will assist state reviewers during the administrative review, to verify the status of a CN label as well as the corresponding contribution statement. The expected completion date for this verification system is Fall 2015.

Product Formulation Statements/Other Documentation

When purchasing a processed product without a CN label, a program operator may request a signed product formulation statement on manufacturers’ letterhead that demonstrates how the processed product contributes to the meal pattern requirements. Program operators must maintain files on nutrient information to meet the requirements of program regulations in 7 CFR 210 and 220. If there is no nutrition facts panel on the processed product, nutrient information must be obtained from the manufacturer.

Program operators are ultimately responsible if a menu does not fulfill meal pattern requirements; therefore they must keep records of supporting documentation. It is the program operator’s responsibility to request and verify that the supporting documentation is accurate.

General Guidance for Reviewing Product Formulation Statements

An appropriate product formulation statement will provide specific information about the product and show how the food credits toward the CN meal pattern citing CN program resources and/or regulations. Specific policies for alternate protein products and food-based menu planning are available.

When reviewing Product Formulation Statements prior to purchasing processed products, refer to:

• A Reviewer’s Checklist for Evaluating a Manufacturer Product Formulation Statement for Meat/Meat Alternate Products
• Product formulation statement templates for documenting the meat/meat alternates (M/MA), grains and fruits/vegetables components

These documents may be used to determine how a product credits toward the meat/meat alternates, grains, fruits and vegetables component(s) of the meal pattern requirements.

The product formulation statement may need to be modified for various types of products available in the market place. For example, cheese pizza could have crediting information about the red/orange vegetable subgroup in addition to the meat/meat alternates and grain components. The crediting information for each meal component may be documented on the same product formulation statement. The manufacturer must clearly identify how each component contributes to meal pattern requirements. To verify the accuracy of a product formulation statement:

• Determine that creditable ingredients listed in the Product Formulation Statement match a description in the Food Buying Guide for School Meal Programs (FBG). If a product formulation statement claims to provide a higher meal component credit than what is listed in the FBG, then the statement must clarify all credited ingredients and demonstrate how the product provides that credit according to FNS regulations, guidance, or policy.
• Verify that the credit a product contributes to meal pattern requirements is not greater than the serving size of the product. For example, a 2.20 oz beef patty may not credit for more than 2.00 oz of meat/meat alternates.
• Assure that the creditable components are visible in the finished product. For example, fruit-filled pancakes may not credit toward the meat/meat alternates component because a meat/meat alternate component is not visible. In order for a product to claim a meat/meat alternates contribution, the product must have a visible meat or meat alternate present such as a sausage link, beans, cheese, or peanut butter and the method for crediting these items must be specified.

FNS encourages program operators to review product literature carefully, since they are responsible if meals they serve do not meet meal pattern requirements. Any crediting information received from a manufacturer other than a valid CN label should be checked by the school food authority or other program operator for accuracy prior to the item being included in the reimbursable meal. Questions on product compliance with meal pattern requirements should be directed to the state agency.

Regional offices are asked to ensure that state agencies are aware of the process for verifying acceptable documentation and proper procedures for handling products with a valid CN label. State agencies should direct any questions concerning this guidance to the appropriate FNS regional office. Regional offices with questions or concerns should contact the national office, child nutrition programs.

Cheryl Jackson Lewis
Director
Nutrition Promotion and Technical Assistance Division