Classifying Smoothies-Revised

This management bulletin provides additions and changes to SNP-37-2014 from the California Department of Education (CDE) Nutrition Services Division about classifying and determining compliance for smoothies. The updates include:

• Juice is considered a food group when considering a smoothie as a food
• Examples of a smoothie as a food when juice is the first ingredient

Background

Prior to the U.S. Department of Agriculture (USDA) issuing Policy Memorandum
SP 23-2014 (v.3): Revised Questions and Answers Related to the Smart Snacks in School (SSIS) Interim Final Rule (https://www.fns.usda.gov/q-and-related-smart-snacks-interim-final-rule), California presumed that a smoothie of any type or composition was considered a beverage under the competitive food and beverage rules. The Policy Memo provides written guidance that a smoothie can be considered a food or beverage, based on the composition of ingredients. California will follow the guidance provided in the USDA Policy Memo when classifying a smoothie sold as a competitive item.

It is important to note that this management bulletin refers to requirements for a smoothie as a competitive item (i.e., an item sold to a student, on school campus, during the school day, outside of the National School Lunch Program [NSLP] or School Breakfast Program [SBP]) and not requirements for smoothies served within the NSLP or SBP. For smoothie requirements served in the NSLP or SBP, please reference the U.S. Department of Agriculture Policy Memo SP 40-2019 available at https://www.fns.usda.gov/cn/smoothies-offered-child-nutrition-programs.

Determining Compliance for a Smoothie

• A smoothie is a food if the first ingredient is a main food group category (e.g., fruit, vegetable, dairy, etc.). Under this definition, a fruit and/or vegetable juice is considered a main food group. If the first ingredient is water (or ice), then the second ingredient is used to determine if the smoothie is considered a food group. A smoothie deemed a food is further categorized as either a snack or an entrée based on additional ingredients. If the smoothie is a food and contains a meat alternate such as yogurt (Note: frozen yogurt is not considered a meat alternate) or peanut butter, it is considered an entrée and measured against the entrée requirements. A smoothie deemed a food that does not contain a meat alternate is considered a snack and must meet the competitive snack requirements. For example, a smoothie with the following ingredients is considered a snack food: apple juice, ice, frozen bananas, frozen strawberries, milk. If a meat alternate is also added, it is considered a competitive entrée. The apple juice is deemed a food group, which meets the definition of a smoothie as a food.
  
  
• A smoothie is considered a beverage if it is comprised entirely of allowable competitive beverages. In this instance, the rules for compliant competitive beverages apply. For example, a smoothie with the following ingredients is considered a beverage: ice, apple juice, pear juice, nonfat milk.

For more information, please review SNP-08-2019 on the CDE Competitive Foods And Beverages—Determining Compliant Beverages web page at http://www.cde.ca.gov/ls/nu/sn/mbsnp082019.asp. [Note: SNP-08-2019 supersedes SNP-27-2014].

Resources

For additional information, including trainings, updated Quick Reference Cards, management bulletins, and other competitive food and beverage resources, please visit the CDE Competitive Foods Web page at http://www.cde.ca.gov/ls/nu/he/compfoods.asp.

Contact Information

If you have any questions regarding this management bulletin, please contact the Competitive Foods and Beverages team by email at COMPETITIVEFOODS@cde.ca.gov.