Food and Nutrition Programs

National School Lunch Program and School Breakfast Program — Final Rule

To:School Food Authority Sponsors of the National School Lunch Program
From:Robert M. Leshin, Director
Date:September 17, 2025

On April 25, 2024, the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) published the final rule, Child Nutrition Programs: Meal Patterns Consistent with the 2020-2025 Dietary Guidelines for Americans . This rulemaking finalizes long-term school nutrition requirements based on the goals of the 2020-2025 Dietary Guidelines for Americans . The Final Rule supports the nutritional quality of school meals, and advances USDA's commitment to nutrition security. Updates include changes to the National School Lunch Program (NSLP), School Breakfast Program (SBP), and Afterschool Snack Program (ASP) meal patterns, the Buy American Provision, professional standards, geographic preference, and the Smart Snacks nutrition standards. This memo serves to outline the updated meal pattern requirements for the NSLP and SBP.

New to school meal programs is the first ever limit on added sugars. The final rule also implements a single achievable reduction in sodium levels at school lunch and breakfast. This rulemaking maintains the current whole grain and fluid milk requirements and continues to allow schools to offer fat-free and low-fat flavored milk.

The most notable change includes product-based sugars restrictions for milk, cereal, yogurt and some grain-based items. It is important to note that FNS did not propose restricting the offering of grain-based desserts at school breakfast, only at Afterschool snack. This was partly due to potential negative impacts the proposed change would have to the SBP, especially to alternative breakfast service models that often include grab-and-go friendly items. As a reminder, while many items with sugar restrictions are allowable under the NSLP and SBP, not all products are allowed to be served under the Afterschool snack program and as A la carte.

This memorandum includes only the NSLP and SBP meal pattern changes. For additional guidance on all final rule requirements, refer to USDA Memo SP 19-2024, CACFP 07-2024, and SFSP 12-2024 the Updates to the Nutrition Standards Webpage .

Updates to NSLP and SBP Meal Patterns

The chart below summarizes the final rule changes that apply to the NSLP and SBP meal patterns.

NSLP and SBP Meal Pattern RequirementsSY 2024-25
(effective July 1, 2024)
SY 2025-26
(effective July 1, 2025)
Milk component

Allowable types of milk:
Continues to allow school food authorities (SFAs) to offer fat-free and low-fat milk (flavored and unflavored).

Nutrition standard for fluid milk substitutes:
Updates the units for vitamin A and vitamin D requirements for fluid milk substitutes to align with the Food and Drug Administration (FDA) labeling requirements.

  • For vitamin A, instead of 500 IUs, the unit requirement is now 150 mcg retinol activity equivalents (RAE) per 8 fluid ounces.
  • For vitamin D, instead of 100 IUs, the unit requirement is now 2.5 mcg per 8 fluid ounces.

The amount of vitamin A and vitamin D required in fluid milk substitutes does not change; only the unit of measurement has changed to conform to FDA labeling requirements.

Flavored milk:
Establishes a new sugars limit for flavored milk: no more than 10 grams of added sugars per 8 fluid ounces.

Flavored milk sold as a competitive food in middle and high schools:
Establishes a new sugars limit for flavored milk sold as a competitive food in middle and high schools: no more than 15 grams of added sugars per 12 fluid ounces.

Vegetables component

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 subgroups.

Resource: On Demand USDA Webinar

Beans, peas, and lentils at lunch:
Allows schools to count beans, peas, and lentils offered as a meat alternate at lunch to also count toward the weekly beans, peas, and lentils vegetable subgroup requirement. As with the current requirement, menu planners determine whether peas, and lentils count toward the vegetable component or the MMA component. Beans, peas, and lentils offered as either vegetables or meat alternates can count toward the weekly vegetable subgroup requirement to offer ½ cup of beans, peas, and lentils over the course of a week.

Resource: On Demand USDA Webinar

None
Meats/meat alternate (M/MA) component

MMA at breakfast:
Establishes a combined grains and MMA meal component in the SBP and removes the requirement for schools to offer 1 ounce equivalent of grains each day at breakfast.

Schools may offer grains, MMA, or a combination of both, to meet the minimum daily and weekly ounce equivalents in this combined meal component requirement.

Resource: On Demand USDA Webinar

Nuts and seeds:
Allows nuts and seeds to credit for the full MMA component in all meals and afterschool snacks, removing the previous 50 percent crediting limit for nuts and seeds at lunch.

Resource: On Demand USDA Webinar

Yogurt:
Establishes new sugars limit for yogurt. Yogurt cannot exceed 12 grams of added sugar per 6 ounces (2 grams of added sugars per ounce).
Grains component

Whole grain-rich (WGR) requirement:
Maintains the current requirement that at least 80 percent of the weekly grains offered in the NSLP and SBP for grades K-12 must be whole grain-rich, based on ounce equivalents.

WGR definition:
Adds the following WGR definition in NSLP and SBP regulations: "Whole grain-rich is the term designated by FNS to indicate that the grain content of a product is between 50 and 100 percent whole grain with any remaining grains being enriched." This definition does not change the meaning of WGR. SFAs can continue to identify WGR products as described in current USDA guidance.

Breakfast cereals:
Establishes new sugar limit for breakfast cereals: no more than 6 grams of added sugars per dry ounce.

Reminder: Grain-based desserts—sometimes referred to as sweet grains—are not creditable in the NSLP Afterschool Snack Program, even if the same product is creditable at breakfast, lunch or are on the Smart Snack A-List.

Dietary specifications

Synthetic trans fat:
Removes the dietary specification prohibiting synthetic trans fat in the NSLP and SBP and the Smart Snacks nutrition standards for foods sold to children on campus during the school day. This change eliminates a requirement that the USDA determined is no longer necessary due to the Food and Drug Administration's (FDA) actions that eliminated synthetic trans fat from the U.S. food supply by 2021.

Sodium:
Maintains the current sodium limits for the NSLP and SBP through the end of school year 2026-27 and codifies a single sodium reduction for both programs.

Sodium for the NSLP:
By school year 2027-28, schools must implement a reduction of about 15 percent from current sodium levels.

Sodium for the SBP:
By school year 2027-28, schools must implement a reduction of about 10 percent from current sodium levels.

Added sugars:
By school year 2027-28, added sugars will be part of the dietary specifications and must be less than 10 percent of calories per week. This weekly limit is in addition to the product-based limits for breakfast cereals, yogurt, and flavored milk.

Meal modifications

Terminology update:
Changes the previous references in the regulations for Child Nutrition Programs from "medical authority" to "state licensed healthcare professional or registered dietitian."

Definition of state licensed healthcare professional:
Defines a state licensed healthcare professional as an individual authorized to write medical prescriptions under state law. In Connecticut, this includes licensed physicians (MD), physician assistants (PA) and certified physician assistants (PAC), doctors of osteopathy (DO), and advanced practice registered nurses (APRN).

NSLP and SBP regulations:
Updates and reorganizes the regulatory text to distinguish between disability and non-disability requests more clearly, and encourages schools, institutions, and facilities to meet children's non-disability dietary preferences when planning and preparing school meals and afterschool snacks.

Medical statements from registered dietitians:
Outlines in regulation that state licensed healthcare professionals and registered dietitians may write medical statements to request meal modifications on behalf of participants with disabilities.

Requires SFAs to accept medical statements from registered dietitians by July 1, 2025.

Massachusetts Department of Elementary and Secondary's Office for Food and Nutrition Programs offer support to school districts as they implement these changes. Refer to Nuts and Bolts of School Nutrition On Demand and participate in the most current Communication Plan to ask questions and learn more about updates to federal and state regulations.

This institution is an equal opportunity provider.





Last Updated: September 25, 2025



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