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USDA Upholds Milk as the Beverage of Choice In the School Meals Program After IDFA’s Engagement

Oct 24, 2019

Carlin By David Carlin, Senior Vice President of Legislative Affairs and Economic Policy

Earlier this fall, the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) instructed schools that bottled water may not be offered as a substitute for fluid milk in the school meals programs. 

By way of background, low-fat and fat-free milks are required to be offered to students as part of the National School Lunch Program and the School Breakfast Program administered by FNS. The program also requires schools to make water available to students during the meal service, most likely by having a drinking fountain near the cafeteria or by offering pitchers and cups on lunch tables.  Unfortunately, some schools have been placing commercially bottled water on the serving line and telling students that they may choose water OR milk to accompany their meal.

This issue is important to dairy companies who produce fluid milk because bottled water is the number-one competitor for milk sales. In fact, the decline in fluid milk consumption is correlated with the rise in popularity of a wide variety of beverages led by bottled water, which takes more than 50% of milk’s market share, according the Dairy Management Inc.

kid lunch

The new FNS memorandum to the state directors of child nutrition programs affirmatively states that “[w]hile water must be made available, schools must not directly or indirectly restrict the sale or marketing of fluid milk.”  The memorandum further notes that water is not part of the reimbursable meal and that commercially packaged water “should not be made available on the serving line in any manner that interferes with or appears to substitute for the selection of components of the reimbursable meal, including low-fat or fat-free milk.” A copy of the FNS memorandum is here.

IDFA’s members had raised the water substitution issue with FNS officials over several meetings, including most recently during a strategic fly-in in Washington, D.C. earlier this year.  Dave Carlin, senior vice president for Legislative Affairs and Economic Policy, commended IDFA’s members for bringing this issue to FNS’s attention.  “Working together, we were able to convince FNS to take action to address a growing problem that was negatively affecting children’s access to nutritious milk products.” 

Cow’s milk provides numerous health benefits, including better bone health, lower risk of type 2 diabetes and cardiovascular disease, and is the leading food source of calcium, vitamin D, and potassium in the diet of American children. According to USDA and the U.S. Department of Health and Human Services, American children and adolescents over four years old are not consuming enough dairy to meet the Dietary Guidelines for Americans recommendations. As the American Academy of Pediatrics states, “Dairy products play an important role in the diet of children. … In fact, milk is the leading food source of three of the four nutrients of public health concern in the diet of American children 2-18 years.”

Members with questions regarding water and milk in the school meals program may contact Carlin ( or Cary Frye ( for more information.

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