University of Illinois Urbana-Champaign

Sorting through the USDA Final Rule: What stays the same, what’s different, what’s new?


The USDA recently released its Final Rule, “Child Nutrition Programs: Meal Patterns Consistent with the 2020-2025 DGAs.” It can be a lot to read through, so we’re sharing some of the most important aspects that will impact school nutrition programs.  

Whole Grains

Prior to the release of the USDA Final Rule, at least 80% of weekly grains were to be whole grain-rich, with any remaining grain items being enriched. The Final Rule maintains this requirement. However, two proposed definitions are finalized with an implementation date of July 1, 2024.

1. The definition of whole grain-rich is being added to 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. Note that this definition is the same as previously communicated by USDA, but it is now being codified.

2. The definition of entrée item in the competitive food standards will be clarified so that whole grain-rich and enriched grain entrees may qualify as entrée items sold under Smart Snacks.


Prior to the release of the USDA Final Rule, schools have been allowed to offer flavored and unflavored milks (fat-free and low-fat) for all grades K-12. The Final Rule maintains this requirement.

There is one difference, which is that added sugar limits were included as part of the Final Rule. Flavored milks will need to meet product-based added sugar limits. We will review this further in an upcoming post!


Prior to the release of the USDA Final Rule, there were three 10% sodium reductions proposed for NSLP, for a total reduction of 30% to be achieved by SY29-30. For SBP, there were two 10% reductions proposed for a total reduction of 20% to be achieved by SY27-28.

The Final Rule diverges significantly from these proposals by allowing schools much more flexibility.

For breakfast, schools can continue to meet current limits through SY26-27. As of SY27-28, schools will need to implement a reduction of 10%.

Through SY26-27

  • K-5: 540 mg or less
  • 6-8: 600 mg or less
  • 9-12: 640 mg or less

By SY27-28

  • K-5: 485 mg or less
  • 6-8: 535 mg or less
  • 9-12: 570 mg or less

For lunch, schools can continue to meet Sodium Target 1A through SY26-27. As of SY 27-28, schools will need to implement a reduction of 15%.

Through SY26-27

  • K-5: < 1,110 mg
  • 6-8: <1,225 mg
  • 9-12 <1,280 mg

By SY27-28

  • K-5: 935 mg or less
  • 6-8: 1,035 mg or less
  • 9-12: 1,080 mg or less

As always, if you have questions or need clarification, contact ISBE at!

In our next post, we will take a look at other notable updates to the Final Rule, including added sugar limits, and substituting M/MA for grains and vegetables for fruits at breakfast!