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Nutrition Requirements for Fluid Milk in the CACFP

Nutrition Services Division Management 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 management bulletin (MB) notifies Child and Adult Care Food Program (CACFP) Operators that the California Department of Education (CDE) Nutrition Services Division (NSD) has updated MB CACFP-09-2017. This MB supercedes CDE MB CACFP-09-2017. Updates to this MB include changes to the Nutrient Requirements chart.

Due to recent changes to the Nutrition Facts label, some manufacturers have updated their Nutrition Facts labels to include amounts of vitamins A and D in micrograms (mcg) instead of international units (IU). Current federal nutrient requirements for a fluid milk substitution list the amounts of vitamins A and D in IU. Due to this difference in how the nutrient values are documented on the new label, some program operators have found it difficult to determine whether a fluid milk substitution meets the requirements for vitamins A and D. In an effort to assist program operators, the CDE NSD revised the Fluid Milk Substitutions Nutrient Requirements chart to include vitamins A and D in both IU and mcg. In addition, the Fluid Milk Substitution Nutrient Requirements chart was updated to only include the amounts of each required nutrient and not the percentage Reference Daily Intake. This is consistent with the U.S. Department of Agriculture (USDA) federal regulations.

Please note that there are no new requirements for fluid milk or fluid milk substitutions.

A policy memo detailing the nutrition requirements for fluid milk and fluid milk substitutions is available on the USDA Nutrition Requirements for Fluid Milk Substitutions in the CACFP, Questions and Answers (Q&A) web page at .


The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296, amended section 17 of the Richard B. Russell National School Lunch Act (NSLA) 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, USDA published the final rule Child and Adult Care Food Program: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act. This final rule added the fluid milk requirements and allowance of nondairy beverages outlined in memorandum CACFP 21-2011 Revised Child Nutrition Reauthorization 2010: Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP, Questions and Answers to the CACFP regulations under Title 7, Code of Federal Regulations (7 CFR ), 226.20(a)(1) and 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 or fat-free. Whole milk and reduced-fat (2 percent) milk may not be served to participants two years of age and older or to adults. This has been in effect since September 15, 2011.

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 new requirements for flavored milk:

  • Children one through five years old: Flavored milk or flavored nondairy beverages served to children one through five years old cannot be claimed for reimbursement.

  • Children six years old and to older adults: If flavored milk is served to children six years old and older (unlicensed child care centers only) or adults it must be fat-free or low-fat (1 percent). This is consistent with the National School Lunch and School Breakfast Programs.

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

Nondairy Beverages as Fluid Milk Substitutes

In the case of children who cannot consume fluid milk due to special dietary needs, such as personal preference or religious reasons (in instances where it is not a disability), the caregiver may serve nondairy beverages in lieu of fluid milk. Nondairy beverages must be nutritionally equivalent to milk and meet the nutritional standards for fortification of calcium, protein, vitamin A, vitamin D, and other nutrients to levels found in milk, as outlined in the CACFP regulations 7 CFR , Section 226.20(g)(3). As mentioned above, nondairy beverages served to children one through five years old must be unflavored.

Parents, guardians, adult participants, or a person on behalf of the adult participant, must provide a written request for the nondairy milk substitution that is nutritionally equivalent to fluid milk. As an example, if a parent has a child who follows a vegan diet, the parent can submit a written request to the child’s caregiver asking that soy beverage be served in lieu of milk. Such substitutions are at the option and the expense of the center or day care home. The CDE developed a sample form, Parental Request for Fluid Milk Substitution, Form ID CACFP 49, which is in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS).

A medical statement is required for nondairy substitutions due to a disability that does not meet the nutritional standards of milk. The medical statement must be completed and signed by a licensed physician, nurse practitioner, or physician’s assistant. The Medical Statement to Request Special Meals and/or Accommodations, Form ID CNP 925, is located in the Download Forms section of the CNIPS.

Yogurt (Adults Only)

Yogurt (six ounces by weight or ¾ cup by volume) may be served to meet the fluid milk requirement once per day for adults only.

Allowing yogurt to substitute 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.


To ensure compliance with the 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.

Additional Information

To assist you with implementation, the nutrient requirements for fluid milk substitutions, as outlined in 7 CFR , Section 210.10(m)(3), is listed in the chart below:

Nutrient Requirements as Stated in Federal Regulations (per cup)
Calcium 276 milligrams (mg)
Protein 8 grams
Vitamin A 500 IU, 150 mcg
Vitamin D 100 IU, 2.5 mcg
Magnesium 24 mg
Phosphorus 222 mg
Potassium 349 mg
Riboflavin 0.44 mg
Vitamin B-12 1.1 mcg
Contact Information

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

Questions:  Nutrition Services Division | 800-952-5609

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Esta institución es un proveedor que ofrece igualdad de oportunidades.