Grain Requirements in the CACFP: Questions and Answers

DATE:	December 19, 2024
MEMO CODE:	CACFP 05-2025
SUBJECT:	Grain Requirements in the Child and Adult Care Food Program; Questions and Answers
TO:	Regional Directors Child Nutrition Programs All Regions	State Directors Child Nutrition Programs All States

This memorandum explains the grain requirements for the Child and Adult Care Food Program (CACFP) and includes questions and answers. This memorandum supersedes CACFP 09-2018, Grain Requirements in the Child and Adult Care Food Program; Questions and Answers, published April 4, 2018.

Background

On April 25, 2024, the USDA Food and Nutrition Service (FNS) published the final rule, "Child Nutrition Programs: Meal Patterns Consistent With the 2020-2025 Dietary Guidelines for Americans" (89 FR 31962). The majority of the 2024 final rule focused on gradual updates to the school nutrition requirements, however the rule also included updates to the CACFP to better align child nutrition program (CNP) requirements. The purpose of this memorandum is to provide updated guidance on the provisions of the 2024 final rule that apply to the grains requirements in the CACFP, which included adding a definition for whole grain-rich into CACFP regulations; changing product-based limits for breakfast cereals and yogurts from total sugars to added sugars; and updating guidance on substituting vegetables to meet the grains requirements for eligible program operators. In addition to the information included in previous memoranda, this memorandum specifically:

1. Provides updated guidance on added sugars;
2. Provides updated guidance on substituting vegetables for grains in eligible settings;
3. Adds two Q&As related to substituting vegetables for grains and using non-grain pasta products, respectively;
4. Adopts standardized terminology such as "institutions and facilities;" and
5. Reorganizes information throughout the memorandum for clarity.

Although FNS' goal is to streamline guidance and align CNPs to the greatest extent possible, the agency recognizes that CACFP operates differently than the National School Lunch Program (NSLP) and School Breakfast Program (SBP) and serves distinct populations. Therefore, there are some instances when CACFP guidance differs from school meal programs guidance. For more information on the preschool meal pattern requirements for NSLP and SBP, see SP 01-2018, Updated Infant and Preschool Meal Patterns in the National School Lunch Program and School Breakfast Program; Questions and Answers, Oct. 19, 2017.

Requirements

Grains are a required component at breakfast, lunch, and supper meals in the CACFP. Grains are not required at snack (with the exception of the snack requirements for 6-11 month old infants) but may be served as one of the two meal components. At breakfast, CACFP institutions and facilities may serve meats/meat alternates in place of the entire grains component, up to three times per week. Creditable grains include whole grains, enriched grains, fortified ready-to-eat cereals, bran, and germ. The CACFP meal patterns require that at least one serving of grains per day must be whole grain-rich for children and adults (7 CFR 226.20(a)(4)(i)(A)). A whole grain-rich product has a grain content that is between 50 and 100 percent whole grain with any remaining grains being enriched (7 CFR 226.2). While there is no minimum whole grain-rich requirement for grains served to infants, CACFP institutions and facilities are encouraged to serve whole grain-rich grains to infants developmentally ready to accept them.

There are several ways that state agencies, institutions, and facilities may determine how grain items credit toward the meal pattern requirements. The grains component is measured in ounce equivalents (oz eq). One quarter (0.25) of an oz eq is the smallest creditable grain amount. If the minimum daily requirement for grains is 1.0 oz eq, for example, this minimum could be met by offering one food item or multiple food items, such as offering two separate 0.5 oz eq grain items. This 0.25 minimum creditable requirement does not apply to the CACFP infant meal pattern.

The ounce equivalents for grains may be determined by using the weights or volumes listed in the chart titled 'Exhibit A: Grain Requirements For Child Nutrition Programs,' part of the Food Buying Guide for Child Nutrition Programs (FBG). Institutions and facilities may also use the Grains section of the FBG, as well as Appendix A of the FBG; the latter features the Recipe Analysis Workbook (RAW), which is a tool used to determine the expected meal pattern contribution and crediting statement for a standardized recipe. Institutions and facilities may also use the Crediting Handbook for CACFP, to determine ounce equivalents crediting. Additionally, institutions and facilities may use a Child Nutrition (CN) label or a manufacturer's Product Formulation Statement (PFS) to obtain information on how a product contributes toward meal pattern requirements.

Enriched Grains and Fortified Breakfast Cereals

Enriched grains are refined grains that have been processed to remove the nutrient-rich bran and germ, and then have thiamin, riboflavin, niacin, folic acid, and iron added after processing. Similarly, a food that is fortified has certain vitamins and minerals added to increase the nutritional quality. Foods made from refined grains that meet at least one of the following are considered creditable:

1. The food is labeled as "enriched." For example, long grain rice that is enriched will have the product name "enriched long grain rice."
2. An enriched grain is listed as the first ingredient on the food's ingredient list or second after water. The ingredient list will usually say "enriched flour" or "enriched wheat flour," or there is a sub-listing of nutrients used to enrich the flour, for example, "yellow corn flour {iron, folic acid, riboflavin, niacin, and thiamine}."
3. For breakfast cereals, the product is labeled as "fortified" or the ingredient list names the vitamins and minerals that have been added to the product. If a breakfast cereal is fortified, it does not need to be enriched. For example, the ingredient list of a fortified breakfast cereal may read, "Ingredients: Wheat flour, sugar, contains 2% or less of salt, baking soda, caramel color, BHT for freshness. Vitamins and Minerals: Vitamin C (sodium ascorbate, ascorbic acid), niacin, vitamin B6 (pyridoxine hydrochloride), reduced iron, zinc oxide, folic acid, vitamin B2 (riboflavin), vitamin B1 (thiamin hydrochloride), vitamin A palmitate, vitamin D, vitamin B12."
   
   NOTE: The ingredient list of a non-fortified cereal would not name any added vitamins and minerals. For example, the ingredient list of a non-fortified breakfast cereal may read, "Ingredients: rice flour, corn flour, evaporated cane juice, pomegranate juice concentrate, sea salt." This cereal would not be considered a creditable grain because it is not made from whole or enriched grains and is not fortified.

Whole Grain-Rich

A whole grain contains all parts of the grain kernel (bran, germ, and endosperm), and therefore does not need enrichment. For a grain product to be considered whole grain-rich, the grain content of a product must be between 50 and 100 percent whole grain with any remaining grains being enriched. For meals served to children and adult participants, at least one serving of grains per day must be whole grain-rich. Although whole grain-rich grains may be served to infants, the daily whole grain-rich minimum does not apply to infant meals.

Any one of the following six options may be used to determine if a grain product meets the whole grain-rich criteria. Use of these methods is intended to be flexible so that individual operators, who may use different methods to purchase food (such as wholesale or retail), can easily identify creditable whole grain-rich foods. The operator must only ensure that a food meets at least one of the following to be considered whole grain-rich:

1. The product is found on any state agency's current Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)-approved whole grain food list.

   Except for some cereals, whole grain bread and other whole grain options found on any state agency's WIC-approved food list meet the whole grain-rich criteria for all CNPs. This may include but is not limited to tortillas, pastas, rice, and breads on a state WIC list. Not all cereals on a WIC list are required to be whole grain-rich. When using the WIC list to choose a whole grain-rich cereal, the operator should be sure to choose one that is marked as whole grain on the WIC list. Program operators can obtain a copy of a state agency's WIC-approved food list by contacting WIC at the relevant state agency.

2. The product is labeled as "whole wheat" and has a Standard of Identity issued by the U.S. Food and Drug Administration (FDA).

   An FDA Standard of Identity is a set of rules for what a certain product (like whole wheat bread) must contain or may contain to legally be labeled with that product name. FDA provides Standards of Identity for certain whole wheat bread products (21 CFR 136.180) and certain whole wheat pasta products (21 CFR 139.138).

   Only breads with these exact product names conform to an FDA Standard of Identity and can be considered whole grain-rich using this method:

   • Whole wheat bread
   • Entire wheat bread
   • Graham bread

   • Whole wheat rolls
   • Entire wheat rolls
   • Graham rolls

   • Whole wheat buns
   • Entire wheat buns
   • Graham buns

   
   Only pastas with these exact product names conform to an FDA Standard of Identity and can be considered whole grain-rich using this method:

   • Whole wheat macaroni product
   • Whole wheat macaroni

   • Whole wheat spaghetti
   • Whole wheat vermicelli

   
   Other grain products labeled as "whole wheat" that do not have an FDA Standard of Identity, such as crackers, tortillas, bagels, and biscuits, must be evaluated for whole grain-rich creditability for CACFP using one of the other methods on this list.

   Please be aware that manufacturers may label their products with terms that are similar to, but slightly different from, FDA Standard of Identity terms defined above. Some frequently encountered terms include "whole grain," "made with whole grains," "made with whole wheat," or "contains whole grains" for example. These terms do not indicate an FDA Standard of Identity for whole wheat products. Foods labeled with these terms must be evaluated for whole grain-rich creditability for CACFP using one of the other methods on this list.

3. The product includes one of the following FDA approved whole-grain health claims on its packaging, exactly as written:

   "Diets rich in whole grain foods and other plant foods and low in total fat, saturated fat, and cholesterol may reduce the risk of heart disease and some cancers."
   
   OR
   
   "Diets rich in whole grain foods and other plant foods, and low in saturated fat and cholesterol, may help reduce the risk of heart disease."

4. The product meets the whole grain-rich criteria under the NSLP.

   Use of the NSLP whole grain-rich criteria may ease menu planning and purchasing for schools that operate CACFP, as they can use the same whole grain-rich criteria for both programs. The NSLP whole grain-rich criteria apply for all grain products with the exception of grain-based desserts, which are not creditable under CACFP.

5. The product meets FNS' Rule of Three, a three-step process for identifying whole grain-rich products in the CACFP.

   FNS developed the Rule of Three in recognition that CACFP operators purchase food differently than school meal program operators, particularly smaller sized CACFP operators who often shop in retail environments and may not have access to a manufacturers' PFS' or products specially formulated for school meal programs.

   To meet the Rule of Three, the first grain ingredient must be whole grain, and the next two grain ingredients (if any) must be whole grains, enriched grains, bran, or germ. Any grain derivatives (by-products of grains) may be disregarded. Any non-creditable grain ingredients (e.g., flours that are not enriched or whole) that are labeled as two percent or less of product weight are considered insignificant and may also be disregarded. The Rule of Three applies to the grain portion of mixed dishes, as well. See Attachment 1: Rule of Three Supplementary Information for more detail on implementing the Rule of Three.

   When applying the Rule of Three for ready-to-eat breakfast cereals, if the first grain ingredient is a whole grain and the cereal is fortified, the product meets the whole grain-rich criteria. In this situation, the second and third grain ingredients, if any, do not need to be considered.

6. The product has proper documentation from a manufacturer or a standardized recipe demonstrating that whole grains are the primary grain ingredient by weight.

   Documentation from a manufacturer or a standardized recipe is particularly helpful when determining whole grain-rich creditability for grain products that do not have a whole grain as the first ingredient and for mixed dishes. When a grain product (such as bread) has a first grain ingredient that is not whole grain, the primary ingredient by weight may still be whole grain if there are multiple whole grain ingredients and the combined weight of those whole grains is more than the weight of the other grain ingredients. When the grain portion of a mixed dish (like a beef enchilada) is not entirely whole grain, it may be whole grain-rich depending upon the proportion of whole grains to other grain ingredients. See Attachment 2: Whole Grain-Rich: Examples of Proper Documentation for more information on implementing this option.

Child Nutrition Labels and Product Formulation Statements

Some commercially purchased food items containing a combination of meats and meat alternates and grains, such as pizza, burritos, corn dogs, and chicken nuggets, may not be listed in the Food Buying Guide; however, they still may be creditable with proper documentation, such as a CN label or a manufacturer's PFS. The CN Labeling program is a voluntary federal labeling program for CNPs. A CN label identifies the contribution of a product toward the meal pattern requirements. Main dishes that contribute at least 0.50 oz eq meats/meat alternates per serving are eligible for a CN label. If the product also contributes to the grains component, the CN label will indicate the ounce equivalent of grains provided. When grains on the CN label are expressed as "oz. equivalent grains," they credit as whole grain-rich. When grains on the CN label are expressed as "oz. equivalent grains (enriched)," they credit as enriched grains. When food items with a CN label are served according to directions, the label is sufficient documentation for monitoring purposes.

When a CN label is not available, institutions and facilities may request that the manufacturer provide a PFS to show how the creditable ingredients in the product contribute toward the meal pattern requirements. A manufacturer's PFS is a signed certified document that provides a way for a manufacturer to demonstrate how a product may contribute to the meal pattern requirements. Institutions and facilities are ultimately responsible for ensuring menu items meet meal pattern requirements; therefore, it is the program operator's responsibility to request and verify that the supporting documentation for the PFS is accurate. For more information on the CN label and a manufacturer's PFS, please refer to the Manufacturer Documentation information page.

Grain-Based Desserts

Grain-based desserts cannot credit toward the grains requirement at any meal or snack in the CACFP (7 CFR 226.20(a)(4)(iii)). Grain-based desserts for CACFP are identified as items that have a superscript 3 or 4 in Exhibit A: Grain Requirements for CNPs, which is part of the Food Buying Guide. Under Exhibit A, the following foods are considered grain-based desserts in CACFP: cookies, sweet pie crusts, cobblers, fruit turnovers, doughnuts, cereal bars, breakfast bars, granola bars, sweet rolls, toaster pastries, cake, coffee cake, and brownies. Other grain-based desserts in CACFP include, but are not limited to: sweet bread puddings, sweet biscotti, sweet croissants, sweet pita chips, sweet rice puddings, sweet scones, gingerbread, marshmallow cereal treats, and ice cream cones.

It is important to note that cookies do not have an FDA Standard of Identity, so a food manufacturer may use clever names that could mislead the menu planner into serving a product that may not be allowed. When determining whether a food is a grain-based dessert, the menu planner should consider whether the food is commonly thought of as a dessert or treat.

Menu planners should also be aware that even if a product is not labeled as a traditional dessert item, it may contain high levels of added sugars. Menu planners should use their discretion when serving these foods. State agencies and sponsoring organizations can provide guidance when a menu planner is unsure whether a product could be considered a grain-based dessert.

FNS recognizes that institutions and facilities may want to occasionally serve grain-based desserts for celebrations or other special occasions. As a reminder, institutions and facilities continue to have the flexibility to serve grain-based desserts as an additional food item that does not contribute to the meal components required for reimbursement. However, non-creditable food items are not allowable costs and must be purchased using non-program funds.

Breakfast Cereals

The 2024 final rule updated CACFP total sugars limits for breakfast cereals and yogurt to added sugars limits that align with the NSLP/SBP product-based limits for breakfast cereals and yogurt.

Through Sept. 30, 2025, breakfast cereals must contain no more than 6 grams of total sugars per dry ounce. By Oct. 1, 2025, breakfast cereals served to infants, children, and adults must contain no more than 6 grams of added sugars per dry ounce (21.2 grams of added sugars per 100 grams of dry cereal) (7 CFR 226.20(a)(4)(ii)). However, with state agency approval, CACFP operators may choose to implement the added sugars limits for breakfast cereals (including ready-to-eat cereals for infants) early. Breakfast cereals include ready-to-eat cereals and instant and hot/cooked cereals (e.g., oatmeal). As a reminder, both infant cereals and ready-to-eat cereals must be iron-fortified to be reimbursable in the infant meal pattern. By Oct. 1, 2025, breakfast cereals must meet the added sugars limit and must be made from enriched or whole grain meal or flour, or be fortified, to be creditable in the CACFP.

There are multiple ways for institutions and facilities to determine if a breakfast cereal is within the added sugars limit, including:

• Use any state agency's WIC approved breakfast cereal list. Consistent with CACFP, all WIC approved breakfast cereals must contain no more than 6 grams of added sugars per dry ounce (21.2 grams of added sugars per 100 grams).
• Use either the standard method or rounding method to calculate the added sugars amount per dry ounce.

Standard Method

1. First, find the serving size in grams at the top of the Nutrition Facts label, and then find the added sugars amount listed toward the middle.
2. Next, divide the added sugars amount by the serving size in grams.
3. If the answer is equal to or less than 0.212, then the cereal is within the required added sugars limit and may be creditable in CACFP.

Rounding Method

1. First, find the serving size in grams at the top of the Nutrition Facts label.
2. Multiply the serving size in grams by 0.212.
3. If the answer in step 2 ends in 0.5 or more, round the number up to the next whole number. If the answer in step 2 ends in 0.49 or less, round the number down to the next whole number. For example, if the answer in step 2 is 4.24, it is rounded down to 4; however, if the answer in step 2 is 4.59, it is rounded up to 5.
4. Next, find the added sugars amount listed toward the middle of the Nutrition Facts label.
5. Compare the number from Step 4 with the number in Step 3. If the number from Step 4 is equal to, or less than, the number in Step 3, the cereal meets the added sugars limit and may be creditable in the CACFP.

Both of these calculation methods may be used to determine whether a breakfast cereal meets the added sugars limit; however, there may be times when a breakfast cereal is within the added sugars limit when using one of these methods, but not the other. As long as a breakfast cereal meets the added sugars limit using at least one of the methods described above, it is considered within the added sugars limit.

Substituting Vegetables for Grains in American Samoa, Guam, Hawaii, Puerto Rico, the U.S. Virgin Islands, and Tribal Communities

To support cultural food preferences of program participants as well as address product availability and cost concerns in outlying areas, the 2024 final rule allows certain institutions and facilities to serve any vegetable to meet the grains requirement. Specifically, all institutions and facilities in American Samoa, Guam, Hawaii, Puerto Rico, and the U.S. Virgin Islands, as well as institutions or facilities that serve primarily American Indian or Alaska Native participants in any state may exercise this flexibility. The flexibility to substitute vegetables for the grains requirement extends to the infant meal pattern. Additional information, including documentation requirements, can be found in CACFP 03-2025, Substituting Vegetables for Grains in American Samoa, Guam, Hawaii, Puerto Rico, the U.S. Virgin Islands, and Tribal Communities, Oct. 30, 2024.

Compliance

Institutions and facilities must demonstrate they are serving meals that meet the meal pattern requirements, including the grain requirements outlined in this memorandum. State agencies have the authority to determine what constitutes acceptable recordkeeping documentation to demonstrate compliance, including requesting product labels and ingredient lists.

Demonstrating compliance with the whole grain-rich requirement can be accomplished in a number of ways. As an example, institutions and facilities can indicate on the menu which grain items are whole grain-rich. This could be as simple as writing "whole wheat" or "WW" in front of "bread" so that the menu item reads "whole wheat bread" or "WW bread," writing "whole grain-rich" or "WGR" in front of a food item, such as "whole grain-rich English muffins," or including a check box signifying the food is whole grain-rich. It is the state agency and sponsor's responsibility, as applicable, to verify that the grains served are creditable and the whole grain-rich items being served meet the whole grain-rich criteria presented in this memorandum. This may include reviewing grain products' labels and other product information.

State agencies are reminded to distribute this information to program operators immediately. Program operators should direct any questions regarding this memorandum to the appropriate state agency. State agencies with questions should contact the appropriate FNS regional office.

J. Kevin Maskornick
Director
Community Meals Policy Division
Child Nutrition Programs

Attachments

• Attachment 1 - Rule of Three Supplementary Information
• Attachment 2 - Whole Grain-Rich: Examples of Proper Documentation
• Attachment 3 - Questions and Answers

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