January 2026
USDA has released new guidance explaining how schools should carry out the Whole Milk for Healthy Kids Act of 2025. The law was signed on January 14, 2026, and it changes the types of milk that may be offered in the National School Lunch Program (NSLP). The memo states that these updates apply only to the NSLP at this time. Other Child Nutrition Programs, including SFSP and CACFP At‑Risk After School, must continue following their current milk requirements.
Under the new law, schools in the NSLP may now offer whole, reduced‑fat (2%), low‑fat (1%), and fat‑free milk. These options may be flavored or unflavored, and schools may also offer lactose‑free milk. USDA explains that schools must continue offering at least two milk choices each day, and unflavored milk must be available at every meal service. Flavored milk must meet the added sugars limit set in regulation.
The guidance also explains changes for nondairy milk substitutes. Schools may choose to offer nondairy beverages, such as soy milk, to all students. If they do, the beverages must meet USDA’s nutrition standards for milk substitutes. When nondairy beverages are offered to all students, schools no longer need to notify the state agency, and students no longer need to provide a written request for a non‑disability reason. If a school chooses not to offer nondairy beverages to all students, the previous request process remains in place.
USDA also outlines a change to how saturated fat is calculated. Schools may now exclude the saturated fat from fluid milk when calculating the weekly average saturated fat requirement for NSLP lunches. All other dietary rules—such as calories, sodium, and added sugars—still apply to the full meal, including milk. USDA notes that flavored milk must meet product‑based added sugar limits beginning July 1, 2025.
The memo includes an update on disability accommodations. Schools must continue providing a fluid milk substitute when a student’s disability restricts their diet. However, USDA now allows the written statement to come from a parent or guardian, in addition to a licensed health care professional or registered dietitian. Again, this change applies only to fluid milk substitutions in the NSLP.
USDA states that more updates will come through the rulemaking process as the agency works to align regulations with the Dietary Guidelines for Americans, 2025–2030. Missouri program operators should review the memo and follow any additional instructions from the Missouri Department of Elementary and Secondary Education (DESE). SFSP and CACFP At‑Risk After School operators should continue using current milk rules until USDA issues further guidance.
