The federal school meals landscape is undergoing significant updates that will present stakeholders participating in these programs with new challenges and opportunities. A forthcoming proposed rule by the U.S. Department of Agriculture (USDA) is expected to redefine which foods qualify for inclusion in the National School Lunch Program (NSLP), School Breakfast Program (SBP), and potentially Smart Snacks in School — the standards governing competitive foods sold in a la carte lines and vending machines — along with the Child and Adult Care Food Program (CACFP).
The anticipated changes are primarily driven by two factors: the 2025–2030 Dietary Guidelines for Americans (DGA), which updated federal nutrition recommendations in unprecedented ways, and the Make America Healthy Again (MAHA) initiative, which has increased scrutiny on food quality and nutrition content, particularly related to sugar, food additives, and food processing.
Keep reading for our thoughts on what the proposed regulation may entail and how food businesses and other interested stakeholders can prepare.
One Strong Signal: The 2026 Fluid Milk Final Rule
Ahead of the broader update to school meals standards, the USDA issued a final rule on May 8, 2026, implementing the Whole Milk for Healthy Kids Act, signed into law by President Trump in January. Effective June 8, the rule allows schools to offer whole and reduced-fat (2%) milk – along with lower fat versions – for the first time since 2012. Specifically, the rule states:
- Fluid milk served to children 1 year old must be unflavored whole milk;
- Fluid milk served to children 2 through 5 years old may be unflavored whole, reduced-fat, low-fat, or fat-free milk; and
- Fluid milk served to children 6 years and older and adult participants may be unflavored or flavored, whole, reduced-fat, low-fat, or fat-free milk.
Prior standards as codified by the Healthy, Hunger-Free Kids Act limited school milk options to low-fat and fat-free versions due to evidence suggesting higher saturated fat intakes may increase risk of cardiovascular disease. The new rule, which applies to the NSLP, SBP, CACFP, and Smart Snacks, removes this restriction and aligns with updated DGA recommendations and MAHA priorities to downplay saturated fat concerns. (We recently wrote about how saturated fat science is evolving.)
According to the final rule, expanded milk options will now qualify by excluding milk saturated fat from having to meet NSLP and SBP weekly average calculations and limits. However, the rule did not adjust weekly calorie or added sugars limits for these programs, raising questions about whether and how higher fat and flavored milks will fit within overall meal pattern requirements.
Bottom line: The fluid milk rule will be integrated into broader school meals standards updates among other program changes. For dairy companies, these changes offer sales and communications opportunities for a wider variety of milk products, as well as potential new flexibilities for cheese and yogurt if proposed regulations apply a similar approach to the larger dairy category.
Predictions for Broader School Meals Program Updates
In addition to dairy fat flexibilities, we anticipate proposed changes in four key areas:
Added sugars:
- NSLP: Current standards cap added sugars at less than 10% of calories per day. We expect these limits to be maintained or tightened further – the 2025-2030 DGA state that no amount of added sugars is recommended as part of a healthy diet (zero grams is recommended for children under 10), and that one meal should contain no more than 10 grams of added sugars. In addition, the number of foods subject to product-specific added sugars limits may increase.
- Smart Snacks: The competitive foods program still includes limits for total sugar rather than added sugars. Most U.S. nutrition policy has already changed its focus to added sugars, and we expect updated Smart Snacks requirements to do the same. Companies participating in this program should expect to need to further reduce added sugars across categories.
Sodium: Under current regulations, school meal sodium limits will continue to gradually decrease through school year 2027-2028. Smart Snacks sodium requirements are outdated and will likely decrease accordingly. Manufacturers should note that higher sodium levels are commonly associated with ultraprocessed foods (UPF), suggesting sodium reduction should remain a reformulation and regulatory priority.
Grains: The 2025–2030 DGA strongly emphasize whole grains and call for Americans to “significantly reduce the consumption of highly processed, refined carbohydrates.” They also notably omit enriched grains from recommended food groups. Current school meals standards allow up to 20% of weekly grains to be enriched, a flexibility included to accommodate regional preferences and culturally relevant foods like white rice and flour tortillas, as well as to ensure schools can access affordable products that deliver key nutrients like folate, iron, and B vitamins through enrichment. It’s possible the proposed rule will follow the DGA’s lead by completely removing or restricting enriched grains.
UPF: No programs currently include requirements to limit UPF. However, USDA may seek opportunities to change this in schools, consistent with the DGA recommendation to “significantly reduce the consumption of highly processed foods” and recent legislative action by numerous U.S. states. Since 2023, more than 30 states have introduced or enacted bills targeting food additives and dyes in school meals – most commonly Red 40, Yellow 5, Yellow 6, Blue 1, Blue 2, and Green 3, along with potassium bromate and propylparaben. USDA also has established grants to help schools do more scratch cooking.
Bottom line: If forthcoming regulations fully reflect the 2025-2030 DGA and MAHA priorities, school meals program updates could be substantive and challenging to implement, for both school foodservice operators and their partners. A March 2026 letter signed by over 900 school districts and nutrition directors urged USDA to consider the financial realities of implementation — schools currently receive just $4.70 per meal in federal reimbursement. The School Nutrition Association has highlighted needs for additional funding, staffing, equipment, and culinary training.
What to Do Now
Companies participating in school meals programs can act now to support effective advocacy and engagement. Consider the following.
- Audit current Smart Snacks participation. Expect significant changes to fat, sugar, and sodium requirements and start thinking about how to reformulate and innovate compliant products.
- Prepare evidence and communications on enriched grains. If the proposed rule suggests dropping or removing these products from school meals, arguments and evidence supporting their role in child health and development will be needed. Consider reformulation options that use whole grains instead, where feasible.
- Evaluate and potentially expand dairy school food offerings. The broader program updates should allow for including whole and 2% milk – and possibly higher fat yogurt and cheese products – however, schools may need help assessing and managing costs and implementation realities. Reach out to partners and school foodservice agencies now to facilitate the transition.
- Prepare for more UPF scrutiny: Analyze your portfolio against common UPF definitions to determine high-risk ingredients that may be targeted for avoidance or reduction. Prepare communications and stakeholder engagement strategies accordingly.
The Bigger Picture
This regulatory moment doesn’t exist in isolation. FDA is actively working on front-of-pack nutrition labeling, potential further changes to the “healthy” claim definition, and a formal UPF definition — all of which could intersect with school channel compliance in meaningful ways. Ensuring your nutrition strategy holistically addresses pressures on added sugars, ingredient quality, and food processing, while maximizing opportunities for healthy, nutrient-dense foods, is critical.
Contact Global Food IQ to discuss how we can help.
Written by Tova Burton, MPH. Tova is a dietetic intern at Global Food IQ and a recent graduate of the University of North Carolina at Chapel Hill, with a concentration in nutrition and dietetics and interests in food policy, regulatory affairs, and food labeling. Connect with her on LinkedIn
