Variations in Meals for Religious Reasons

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

Date: January 2014; Updated December 2025

Number: CNP-04-2014

To: Child Nutrition Program Sponsors

Attention: Food Program/Service Directors

Reference: Title 7, Code of Federal Regulations, sections 210.10(m)(2), 220.8(m), and 225.16(f)(5); U.S. Department of Agriculture Food and Nutrition Service Instruction Number 783-13, Revision 3, March 27, 2013

Subject: Variations in Meal Requirements for Religious Reasons: Jewish Schools, Institutions, and Sponsors

This Management Bulletin (MB) clarifies allowable variations to Child Nutrition Program (CNP) food components in order to meet religious needs among Jewish schools, institutions, and sponsors.

Background

The U.S. Department of Agriculture Food and Nutrition Service (FNS) released instructions (FNS 783-13 Revision) regarding allowable variations in food components to meet religious needs among Jewish schools, institutions, and sponsors participating in the National School Lunch Program (NSLP), School Breakfast Program, NSLP Afterschool Snack, and sponsors and sites in the Summer Food Service Program (SFSP). Sponsors may use these variations on an experimental or continuing basis where such variations are nutritionally sound.

Allowable Variations in Meal Components

1. Whole Grains
   
   During the religious observance of Passover, Jewish agencies may be exempted from the enrichment and whole grain portions of the CNP grain requirements. They may substitute unenriched matzo for the grain requirement during that period of time only.
   
   At all other times during the year, sponsors must ensure that matzo served as the grain component is whole grain rich, whole grain, or enriched in accordance with the specific regulatory meal pattern requirements that apply under the particular CNP.
   
   
2. Fluid Milk
   
   Jewish agencies may be granted flexibilities with the meal pattern requirement that fluid milk be offered with all meals. They may choose from four alternative options. These options apply only to meals containing meat or poultry when participants do not have the opportunity to refuse the fluid milk or meat/poultry through Offer Versus Serve. Jewish agencies may opt to do the following:
   
   
   1. Serve an equal amount of non-dairy fluid milk substitute (for medical or special dietary needs) that is nutritionally equivalent to fluid milk per Title 7, Code of Federal Regulations, Section 210.10(d)(2)(ii).
      
      
   2. Serve an equal amount of full-strength juice in place of fluid milk with lunch or supper. When substituting juice for fluid milk, the juice may not contribute to the vegetable or fruit requirement. Entities operating five days per week may substitute juice for fluid milk twice per week for lunches and twice for suppers, but not more than once each day. Sponsors operating seven days a week may make three substitutions per week for lunches and three for suppers, but may not make more than one substitution each day.
      
      
   3. Serve fluid milk at an appropriate time before or after the meal service period, in accordance with applicable Jewish Dietary Law.
      
      
   4. Serve the snack’s juice component at breakfast, lunch, or supper, and serve the corresponding meal’s fluid milk component as part of the snack.
   
   Sponsors must offer fluid milk or serve it at other meals according to regulations, since Jewish Dietary Laws allow other meat alternatives (e.g., fish, egg, beans, peas, and lentils, nuts and seeds, and their butters) to be consumed with fluid milk at the same meal.
   
   Individual agencies have the discretion to select one of the above fluid milk options as an alternative to standard regulatory meal requirements. The agencies must notify the Nutrition Services Division (NSD) if they employ any of the alternative options for fluid milk.
   
   In addition, a sponsor that chooses to offer a fluid milk substitute to participants without medical or special dietary needs must meet the minimal nutrient standards of milk. The NSD requires that school food authorities complete, sign, and submit the Notification of Decision to Offer Fluid Milk Substitutes (SNP 05) form to the NSD. This form can be downloaded from the Download Forms section of the Child Nutrition Information and Payment System (CNIPS). For non-school food authorities, the NSD requests that agencies submit a written request to their Program Specialist.
   
   
3. Dark Green Vegetables
   
   The Jewish Dietary Law poses challenges to serving the dark green vegetable subgroup, as required in the NSLP. Jewish agencies facing this challenge may be exempt from the requirement to serve the dark green vegetable subgroups. They can make the following adjustments:
   
   
   1. Serve the same total amount of vegetables.
      
      
   2. Serve vegetables in place of dark green vegetables that come from the red and orange vegetables or beans, peas, and lentils subgroups. These subgroups are underrepresented in the average American diet, and the 2020 Dietary Guidelines for Americans states that “throughout youth, starchy vegetables (e.g., white potatoes, corn)—often in forms that are fried or prepared with additions such as butter and salt—are more frequently consumed than the red and orange; dark green; or beans, peas, and lentils vegetable subgroups.”
      

Policy Reminder

The decision to exercise any of the options discussed in this MB will be made at the individual agency level. For review and audit purposes, agencies electing to use one of the three options described above must inform the NSD. They must also maintain a record of which option they have chosen.

Contact Information

If you have any questions regarding this MB, please contact the appropriate NSD Specialist for your agency listed below.

School Nutrition Programs

If you have any questions regarding this subject, please contact the School Nutrition Programs Unit by email at SNPInfo@cde.ca.gov.

Summer Food Service Program

If you have any questions regarding this subject, please contact the SFSP by email at SFSP@cde.ca.gov.