University of Illinois Urbana-Champaign

Sorting through the USDA Final Rule: What stays the same, what’s different, what’s new? (Part 2!)


The USDA recently released its Final Rule, “Child Nutrition Programs: Meal Patterns Consistent with the 2020-2025 DGAs.” In Part 2 of this series, we’re sharing more important updates that will impact Illinois school nutrition programs.  

Added Sugars

As of SY25-26, schools will need to follow product-based added sugar limits for specific items – breakfast cereals, yogurt, and flavored milk.

  • Breakfast cereals: Limited to 6 grams of added sugars per dry ounce.
  • Yogurt: Limited to 12 grams of added sugars per 6 ounces (2 grams of added sugars per ounce).
  • Flavored milk: Limited to 10 grams of added sugars per 8 fluid ounces when offered under SBP and NSLP. Flavored milk sold as a competitive food under Smart Snacks will be limited to 10 grams of added sugars per 8 fluid ounces at the elementary school level. At the middle school and high school levels, flavored milks sold as a competitive food will be limited to 15 grams of added sugars per 12 fluid ounces. Note that all of these come out to a limit of 1.25 grams of added sugars per fluid ounce.

Starting in SY27-28, added sugars will be subject to a weekly limit of less than 10% of calories. This will apply to both SBP and NSLP. This requirement aligns with the Dietary Guidelines for Americans recommendation that no more than 10% of calories should come from added sugars.

Grain and M/MA Component in SBP

Until now, grains have been a required component in SBP. Schools have been required to offer a daily minimum of 1 ounce-equivalent of grains and weekly minimum of 7-9 ounce-equivalents (depending on grade level). Schools could substitute a 1 ounce-equivalent of M/MA for 1 ounce-equivalent of grains, after the daily minimum grain requirement had been met.

As of SY24-25, the grain component will be a combined grain and M/MA component. Schools will have the option to serve M/MA, grains, or a combination of both to count toward this requirement. This will give schools more flexibility in menu planning and make it easier to offer options that are higher in protein and lower in added sugars.

Substituting Vegetables for Fruits in SBP

Options for substituting vegetables for fruits in SBP have been in flux for some time. Under USDA regulations, schools have been allowed to offer starchy vegetables in place of fruit after vegetables from other subgroups had been offered on the breakfast menu. Flexibilities given by Congress in recent years have waived this requirement, allowing schools to substitute starchy vegetables for fruit without having to meet other subgroup requirements.

Under the Final Rule, there will be two options:

1. Schools can substitute a vegetable at breakfast one day per school week, and can offer any vegetable (including starchy) in place of fruit.

2. Schools can substitute vegetables for fruit on two or more days, but will need to offer vegetables from at least two different subgroups.  Consider this example from the Final Rule: “… a school can substitute a starchy vegetable for fruit at breakfast on Monday, then substitute a dark green vegetable for fruit at breakfast on Tuesday. The rest of the week the school may choose to substitute any vegetables, including a dark green or a starchy vegetable, for fruit at breakfast, since it would have met the variety requirement by Tuesday.”

In our next post, we will address several more Final Rule updates of note. Until then (and as always), reach out to ISBE at if you have questions!