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Dairy Facts 2016

Reimbursable School Lunches Can’t Replace Milk with Water

Aug 06, 2015

When IDFA learned last spring that schools in several Midwestern states and New England were offering bottled water as a substitute for milk as part of the National School Lunch Program, we alerted officials at the U.S. Department of Agriculture and shared photos to document the practice. With a new school year approaching, IDFA wrote last week to state directors for USDA child nutrition programs across the country to clarify that the program does not allow bottled water instead of milk with reimbursable meals.

“The Final Rule updating the current nutrition standards for the National School Lunch and School Breakfast programs specifically states that “water may not be offered in place of fluid milk as part of the reimbursable meal…” (77 Fed. Reg.  at 4096), IDFA told the directors. “Furthermore, USDA Memo SP 28-2011 also specifies that ‘while potable water is required to be made available to students, it is not considered part of the reimbursable meal and students are not required to take water.’”

Schools have implemented the potable water requirements in many ways, including offering access to a water fountain or a water pitcher. Bottled water, like milk and other beverages that comply with USDA regulations, may be sold in the cafeteria as an a la carte beverage. 

For more information, contact Cary Frye, IDFA vice president of regulatory and scientific affairs, at or Ruth Saunders, IDFA vice president of policy and legislative affairs, at

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