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On February 6, 2023, the U.S. Department of Agriculture (USDA) released revised nutritional guidelines for K – 12 school systems. These guidelines will have significant impact on the K-12 food providers—and the IFMA foodservice manufacturers and distributors that supply them, to the tune of $38 billion annually. 


That represents a sodium reduction of 52% across the board for school lunches. There is a smaller reduction for school breakfasts, around 23%.


According to USDA, the proposed updates support the growth, health, and well-being of kids. By law, USDA is required to develop school nutrition standards that reflect the goals of the most recent edition of the Dietary Guidelines for Americans, which found that most kids are consuming too much sugar, sodium, and saturated fat, and not enough fruits, vegetables, and whole grains.


Many who run school breakfast, lunch and after-school meal programs believe that the changes will make it nearly impossible to provide meals that students will eat. As Betti Wiggins of the Houston Public School System says, “We cannot make meals that taste good within these guidelines. Students will either skip meals or buy lunch from nearby fast food restaurants.” The most problematic issues involve sodium, added sugars, and whole grains.


Dan Ellnor of the Jefferson County School System, Louisville, KY, adds, “School meals under the current guidelines continue to be the most healthy meals available to students. We applaud USDA for continuing to tackle challenges within school nutrition and working with school food authorities around such items as expanding geographic preference to increase the use of local ingredients and clarifications around Buy American requirements. However, we are still far away from being able to further address nutrition standards from an operational perspective.”  


Public comment on the proposed changes is open until April 10, 2023.


Reductions in Sodium

The rule proposes a multi-year approach including two sodium reductions for breakfast (10% each in fall 2025 and fall 2027) and three for lunch (10% each in fall 2025, fall 2027, and fall 2029). This would reduce current levels as follows for lunch:

  • Current: K-5, <1,230 mg; 6-8, <1,360 mg; 9-12<1,420 mg
  • Fall 2029: K-15, ,810 mg; 6-8, <895 mg; 9-12, <935 mg



That represents a sodium reduction of 52% across the board for school lunches. There is a smaller reduction for school breakfasts, around 23%.


The reduced sodium levels would be problematic for many breakfast and lunch staples, such as pizza, grilled cheese, potato chips and so on. It would be even more of an issue for school systems that are attempting to appeal to local ethnic tastes, such as Mexican or Asian food.


Ellnor explains, “Sodium limits impact culturally relevant menu options such as hot sauce, and other spicy foods preferred by students. Maintaining palatability of offerings is critical to ensure the most at risk and food insecure students continue to eat healthy meals.”


Addressing Added Sugar

To limit added sugars, USDA is proposing a phased approach:  

  • First, the rule proposes limiting added sugars in certain products beginning in fall 2025, targeting the most common sources of added sugars in school meals: breakfast cereals, flavored milks, grain-based desserts, and yogurt.  
  • In fall 2027, the rule proposes limiting overall added sugars across the weekly menu to less than 10% of calories per meal, on average, to better align meals with the dietary guidelines.  


The K-12 school system professionals believe this will have a significant impact, especially on breakfast offerings. Cereals will need to be reformulated for their segment and quick-and-easy breakfast items, such a nut and fruit bars, will no longer be served. Most yogurt will also be unavailable.


“Foodservice manufacturers, especially the cereal companies, will need to redo their products for the K-12 market,” observes Jessica Shelly of the Cincinnati school system. “This will result in foods at school tasting different than the foods they eat at home. Students may not like these less sweet products and encourage their parents not to purchase the products in the supermarket, decreasing sales for many food manufacturers.” 


Manufacturers will need to spend significant money on R&D and may need to retool their production process to provide foods for schools. “Companies will pull out of our segment,” says Kevin Frank of the Detroit Public Schools.


Ellnor adds, “Manufacturers such as JTM have had to already slash K-12 items from 179 to 53 and some vendors, such as Simplot, have chosen to pull out of commodity processing already. Further tightening of standards will exacerbate these supply issues.”


The Challenge with Whole Grains

The proposed rule prioritizes whole grains. USDA proposes two options and requests public feedback on which will work best for students, schools, and partners.

  • One option would maintain the current requirement under the transitional standards rule, which requires 80% of all grains offered in a school week (based on ounce equivalents) to be whole grain-rich (defined as containing at least 50% whole grains).
  • An alternative option would allow schools to serve non-whole, enriched grain foods – like refined, enriched pasta or flour tortillas – one day per school week. 



While challenging for all school districts, this guideline is particularly problematic for schools in the South and Southwest, where grain-based products such as biscuits and tortillas are part of the food culture. As Wiggins says, “We will lose the ability to offer foods with which the students can culturally identify and this will make it more likely that the food we do serve will end up in the garbage.”


An Equity Issue

K-12 foodservice operators believe that the new nutritional guideline will create more disparity in the system, dividing students into the “have’s” and “have not’s.” Students who cannot afford meal alternatives may not eat, or just consume empty calories. This will make it challenging for them to learn.


Those concerned about the new guidelines can file a written statement at regulations.gov. The document ID is FNS-2022-0043-001 and the deadline is April 10. More than 40,000 comments have already been filed.