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The United States Department of Agriculture (USDA) has released SP 01-2026: Whole Milk for Healthy Kids Act of 2025 – Implementation Requirements for the National School Lunch Program. The law immediately expands the types of milk schools may offer through the National School Lunch Program (NSLP). Flexibilities do NOT apply to the School Breakfast Program (SBP), the Afterschool Snack Program, the Child and Adult Care Food Program (CACFP), or the Summer Food Service Program (SFSP).
What’s New for Schools
Under the NSLP, milk requirements have been expanded to specify:
- Schools may offer whole, 2%, 1%, non-fat, and lactose free milk options, including cultured and UHT varieties at lunch. Milk may be flavored or unflavored, provided flavored options meet added‑sugars limits.
- Flavored milk must contain no more than 10g added sugars per 8 ounces.
- Schools must still offer at least two milk choices daily, one of which must be unflavored.
Nutrition Standard Changes
The Act allows schools to exclude saturated fat from milk when calculating the weekly saturated fat average for lunch. Requirements for calories, sodium, and (starting July 1, 2027) added sugars remain unchanged for all meal components, including milk.
Milk Substitute Updates
Schools may now choose to offer non-dairy, nutritionally equivalent milk substitutes (such as fortified soy milk) to all students—not only those with disability related dietary needs. If a school chooses this option:
- The school no longer needs to notify the Office of Superintendent of Public Instruction (OSPI).
- Students with non‑disability preferences no longer need a written request if the milk substitute is offered to all students.
If non-dairy beverages are not offered universally, OSPI must be notified of the LEA’s plan to offer milk substitutes. Milk substitutes offered to all students or for non-disability preferences must meet USDA nutritional standards and FDA fortification guidelines. Review the list of Approved Milk Substitutes for options confirmed to meet nutritional standards. Additional information can also be found on the Milk and Milk Substitutes Reference Sheet.
New Allowances for Disability Related Substitutions
Previously, only a state licensed healthcare professional or Registered Dietitian could provide the required documentation for a disability related milk substitute that did not meet the USDA nutritional standards. Effective immediately, parents and guardians may also submit this written request for a disability related milk substitute during lunch.
Operational Considerations
- When selecting the type of milk to offer, consider the preferences and needs of the students you serve.
- Contact your dairy distributor to discuss product availability and any changes you are considering.
- Review existing contracts to determine whether they need to be rebid or amended.
- Coordinate with your nutrient analysis software provider to ensure updates to saturated fat calculations are accurately incorporated.
Please note that milk requirements are unchanged for breakfast and snack. LEAs must continue to offer two types of 1%, non-fat, lactose free, or lactose reduced milk, flavored or unflavored, at meal service. At least one type of unflavored milk must always be available.
Questions? Please contact your School Meal Programs Specialist or email SchoolMeals@k12.wa.us.
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