Nutrition Requirements for Fluid Milk in the CACFP

CACFP Bulletin

Purpose : Policy, Beneficial Information

To : Child and Adult Care Food Program
All Child Care Agencies

Attention : Child and Adult Care Food Program Operators

Number : CACFP-02-2020

Date : July 2020


Reference:  U.S. Department of Agriculture Policy Memorandum CACFP 17-2016: Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the Child and Adult Care Food Program, Questions and Answers

Supersedes:  Management Bulletin USDA-CACFP-09-2017 Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the Child and Adult Care Food Program

Subject:  Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the Child and Adult Care Food Program

This Child and Adult Care Food Program (CACFP) Bulletin provides the CACFP nutrition requirements for fluid milk and fluid milk substitutes.

The U.S. Department of Agriculture (USDA) policy memo CACFP 17-2016, Nutrition Requirements for Fluid Milk Substitutions in the CACFP, Questions and Answers (Q&A), provides guidance on the nutrition requirements for fluid milk and fluid milk substitutions in the CACFP.


The Healthy, Hunger-Free Kids Act (HHFKA) of 2010, Public Law 111-296, amended section 17 of the Richard B. Russell National School Lunch Act to require the USDA to update the CACFP meal pattern requirements to make them consistent with the most recent version of the Dietary Guidelines for Americans, the most recent relevant nutrition science, and appropriate authoritative scientific agency and organization recommendations.  On April 25, 2016, the USDA published the final rule CACFP: Meal Pattern Revisions Related to the HHFKA.  This final rule added the CACFP fluid milk requirements and the allowance of creditable fluid milk substitutions for non-disability reasons outlined in the USDA policy memo the USDA policy memo CACFP 21-2011 Revised, Child Nutrition Reauthorization 2010: Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP Q&A, to the CACFP regulations under Title 7, Code of Federal Regulations (7 CFR ), Section 226.20(a)(1) Section 226.20(a)(1) and Section 226.20(g)(3), respectively.  The final rule also established additional nutrition requirements and flexibilities for fluid milk served in the CACFP. 

One Year Old Children

One year old children must be served unflavored whole milk.  This is consistent with recommendations from the National Academy of Medicine.  Additionally, breastmilk is considered an allowable fluid milk substitute for children of any age if a mother chooses to breastfeed her child past one year of age.

Children Two Years Old and Older and Adults

Milk served to children two years old and older and adults must be low-fat(1 percent fat) or fat-free(skim).  Whole milk and reduced-fat(2 percent fat) milk may not be served to participants two years of age and older or to adults.

Switching immediately from whole milk to low-fat or fat-free milk when a child turns two years old may be challenging.  Therefore, the USDA allows a one-month transition period.  During this one-month period, meals served to children 24 to 25 months old that contain whole milk or reduced-fat milk (2 percent) may be claimed for reimbursement.

Flavored Milk

Flavored milk contains added sugars and the Dietary Guidelines recommends that all Americans reduce their consumption of added sugars.  To better align with the Dietary Guidelines’ recommendation and help children develop healthy eating practices early, the USDA established the following requirements for flavored milk:

  • Children one through five years:  Flavored milk or flavored nondairy beverages served to children one through five years old cannot be served or claimed for reimbursement.
  • Children six through 18 years and adults:  Flavored milk must be low-fat (1 percent fat) or fat-free (skim) and may only be served to adults and children ages 6 through 18 in unlicensed child care centers and day care homes only.

Please note:  The California Healthy Beverages in Child Care Act does not allow flavored milk to be served to children of any age in licensed child care centers and day care homes in California.

Nondairy Beverages as Fluid Milk Substitutes

For information on nondairy beverages as fluid milk substitutes for participants with and without a disability visit the California Department of Social Services Menu Modifications in the CACFP web page.

Fluid Milk Requirements for Adults Only

Yogurt (6 ounces [oz] by weight or ¾ cup by volume) may be served to meet the 8 oz fluid milk requirement at once per day (either breakfast or lunch) for adults only.  

Allowing yogurt to substitute for fluid milk once per day for adults offers greater flexibility to the menu planner and will help encourage consumption of a calcium-rich food among adult participants.  Yogurt may not be substituted for fluid milk for children of any age. 

Fluid milk is an optional component for adults at supper.  Fluid milk is never optional at any meal for children.


To ensure compliance with the CACFP meal pattern milk requirements, centers and day care homes must document the type of milk served on their menu.  This includes listing the fat content and if the milk is flavored or unflavored. 

Contact Information

If you have any questions regarding this subject, contact the CACFP Nutrition Team by email at


This institution is an equal opportunity provider.
Esta institución es un proveedor que ofrece igualdad de oportunidades.

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CDSS Child and Adult Care Food Program
744 P Street, MS 9-13-290
Sacramento, CA 95814