SNA Submits Comments on Restoring Flexibilities


On Friday, December 18, 2020, SNA submitted comments in response to USDA's proposed rule, Restoration of Milk, Whole Grains, and Sodium Flexibilities, published in the Federal Register on November 25, 2020. We urge all SNA members to submit comments in support of the proposed rule prior to the December 28th submission deadline.

To assist in drafting comments, we have included below some suggested key points, and we encourage you to share SNA’s comments as part of your letter as well. Thank you for your efforts to support this proposed rule.

  • Under the proposed rule, school meals are still healthy meals that meet calorie, fat and sodium limits and offer students fruits, vegetables and whole grains.
  • This proposed rule ensures schools continue to offer whole grains and lower sodium meals. By setting achievable targets, this rule will result in more students eating healthy school meals, which meet calorie limits and offer a wide range of fruits, vegetables and milk.
  • School meal flexibility does not compromise the progress we’ve made for our students.
    • Provide examples of menu improvements (eg locally grown choices) and nutrition education initiatives in your program/state.
  • The proposed rule will help us prepare nutritious meals that appeal to diverse student tastes.
  • Whole grains: A majority of the grains schools serve are whole grain rich. The flexibility simply gives us a little leeway on specific foods that students just weren’t eating, often due to regional and cultural preferences.
    • Provide examples from your program/state (e.g. preferences for flour tortillas/ biscuits/white rice, challenges with whole grain pastas, etc.)
  • Sodium: Schools significantly reduced the sodium content of school meals to meet Target 1 and are working toward Target 2 reductions. Provide examples from your program/state (eg reformulating recipes, increasing scratch preparation, limiting condiments and reducing portion sizes)
    • Even the Institute of Medicine warned that meeting later targets may not be possible given naturally occurring sodium in foods and other challenges.
      • Naturally occurring sodium in meat, milk and other low-fat dairy foods would force schools to take nutritious choices off the menu.
      • Many schools have already limited soups, entree salads and low-fat deli sandwiches due to sodium limits.
  • Milk: Schools continue to meet calorie, fat and sodium limits for school meals, so any nutrient changes resulting from the addition of flavored 1% milk are offset in other parts of the menu.

Contact Us

2900 S. Quincy Street, Suite 700
Arlington, VA 22206  

Tel (703) 824-3000
Fax (703) 824-3015

> For The Media
> Work With US

Sign Up for Our Newsletters

Read the latest news and developments facing the school nutrition industry, as well as stay on top of important trends and resources.


> Read the Latest Newsletters

SNA State Associations

The School Nutrition Association has a presence in every state across the country. View links to many of the state associations to find out more about what SNA is doing nationwide. 

> Learn More