Implementation Timeline for Updated Nutrition Requirements in CACFP & SFSP

Requirements Applicable to CACFP and/or SFSP

The provisions summarized below are required for program operators as specified by date and applicable program below.

Added Sugars (Section 2)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	Implementation Date	CACFP	SFSP
Changes product-based limits for breakfast cereals and yogurt from total sugars to added sugars. CACFP total sugars limits remain in place until Oct. 1, 2025, when the added sugar limits must be implemented. With state agency approval, CACFP operators may choose to implement the added sugars limits for breakfast cereals and yogurt early. Current Requirements: Breakfast Cereals: Must contain no more than 6 grams of total sugars per dry ounce. Yogurt: Must contain no more than 23 grams of total sugars per 6 ounces. Updated Requirements: Breakfast Cereals: Must contain no more than 6 grams of added sugars per dry ounce. Yogurt: Must contain no more than 12 grams of added sugars per 6 ounces2. Regulations affected: 7 CFR 226.20(B)(ii) and 7 CFR 226.20(a)(5)(iii)(B)	Oct. 1, 2025

Flavored Milk (Section 3)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	Implementation Date	CACFP	SFSP
No change. Maintains the current requirement to allow CACFP operators to offer flavored and unflavored, fat-free and low-fat milk to participants ages 6 and older.	N/A

Meal Modifications (Section 14)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	Implementation Date	CACFP	SFSP
Clarifies that both state licensed healthcare professionals and registered dietitians may write medical statements to request meal modifications on behalf of participants with disabilities. Regulations affected: 7 CFR 226.20(g)	Oct. 1, 20253
Defines a state licensed healthcare professional as an individual authorized to write medical prescriptions under state law. Regarding non-disability requests, makes clear in regulation that USDA encourages institutions and facilities to meet participants’ non-disability dietary preferences when planning and preparing CACFP meals. Regulations affected: 7 CFR 226.20(g)	July 1, 20244

Menu Planning and Operational Flexibilities

Implementation Date: July 1, 2024³

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

Substituting Vegetables for Grains (Section 7)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	CACFP	SFSP
Tribal Communities Allows sponsors, institutions, and facilities serving primarily American Indian or Alaska Native participants to substitute vegetables to meet the grains requirement. Regulations affected: 7 CFR 225.16(f)(3) and 7 CFR 226.20(f)
Guam and Hawaii Allows all sponsors, institutions, and facilities in Guam and Hawaii to substitute vegetables to meet the grains requirement. Regulations affected: 7 CFR 225.16(f)(3) and 7 CFR 226.20(f)

Nuts and Seeds (Section 11)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	CACFP	SFSP
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. Regulations affected: 7 CFR 225.16(e)(5) and 7 CFR 226.20(a)(5)(ii)

Geographic Preference Expansion (Section 19)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	CACFP	SFSP
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. Regulations affected: 7 CFR 225.17(e) and 7 CFR 226.22(c)

Technical Changes (Non-Substantive Provisions)

Implementation Date: July 1, 2024³

The changes summarized below are technical; CACFP and SFSP program operators are not required to change menus or operations as a result of these provisions.

Fluid Milk Substitutes: Nutrient Requirements (Section 3C)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	CACFP	SFSP
Updates Vitamin A and Vitamin D units of measurement for fluid milk substitutes. 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. Current Requirements: Per 8 fluid ounces: Vitamin A – 500 IUs Vitamin D – 100 IUs Updated Requirements: Per 8 fluid ounces: Vitamin A – 150 mcg retinol activity equivalents (RAE) Vitamin D – 2.5 mcg Regulations affected: 7 CFR 226.20(g)(3)(ii)

Whole Grains (Section 4)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	CACFP	SFSP
Adds in regulation the current definition of whole grain-rich: “the grain content of a product is between 50 and 100 percent whole grain with any remaining grains being enriched.” Regulations affected: 7 CFR 226.2

Miscellaneous Changes (Section 20)

Provisions in the Final Rule that Impact CACFP and/or SFSP1	CACFP	SFSP
Changes references to “dry beans and peas (legumes)” to “beans, peas, and lentils.”5
Changes references from “food components” to “meal components.”5 Regulations affected: 7 CFR 225.16 and 7 CFR 226.20
Updates CACFP definitions: Removes outdated language in the definition of “Functionally impaired adult.” Adds definition for “meal component.” Meal component means one of the food groups which comprise reimbursable meals. The meal components are: fruits, vegetables, grains, meats/meat alternates, and fluid milk. Regulations affected: 7 CFR 226.2
Updates requirements for CACFP meals as follows: Revises certain endnotes for clarity and combines related footnotes to improve readability in meal pattern tables. Updates the meats/meat alternates row at 7 CFR 226.20(c), in meal pattern tables for children age 1 through 18 and adult participants, to use ounce equivalents and refer to meats/meat alternates sources generally, instead of listing specific foods within the category. Regulations affected: 7 CFR 226.20

¹ Meal pattern tables at 7 CFR 225.16(d)(1), 7 CFR 225.16(d)(2), 7 CFR 225.16(d)(3), 7 CFR 226.20(b)(5), 7 CFR 226.20(c)(1), 7 CFR 226.20(c)(2), and 7 CFR 226.20(c)(3) will be updated accordingly.
² Most products that previously credited under total sugar requirements are expected to credit under added sugar requirements.
³ The requirement to accept medical statements from registered dietitians must be implemented by Oct. 1, 2025, for CACFP. Institutions and facilities have the option, but are not required, to implement the change prior to the implementation date.
⁴ Certain provisions of this rule address requirements that are already in effect; others offer new optional flexibilities. This rulemaking provides an implementation date for these provisions to account for minor corrections and reorganization of the regulatory text. Child nutrition program operators are not required to make menu or operational changes to comply with requirements already in effect or with provisions that provide optional administrative or operational flexibilities.
⁵ State and local operators may continue to use materials with previous terminology but are encouraged to use current terminology as materials are developed or updated.