National Editor Tom Karst
National Editor Tom Karst

With comments due April 9, more than 20,000 comments (and counting) have been received on website for the “National School Lunch and School Breakfast Programs: Nutrition Standards for All Foods Sold in School, as Required by the Healthy, Hunger-Free Kids Act of 2010.” Check out the docket here.

Find the United Fresh comment here

An excerpt:

United Fresh supports the following:

• USDA’s definitions for “competitive food,” “school day,” and “school campus”. The standards should apply to all snacks and beverages sold in schools, across the school campus, and throughout the school day.

• All foods sold in schools should provide students with a positive nutritional benefit, such as be a fruit, vegetable or whole grain, or naturally contain 10 percent of the Daily Value of a nutrient of public health concern and meet strong standards for calories, fats, sugars, and salt.

• The standards should apply to foods and beverages as they are packaged and sold to children.

• Calorie limits should be tiered to elementary schools, middle schools and high schools to reflect that elementary students require fewer calories per day than high school students.

• All foods sold in school cafeterias should meet the standards.

• State agencies and school districts have the authority to establish additional or stronger standards for competitive foods, as long as such standards are consistent with the minimum federal standards.

• State agencies can specify the frequency of fundraisers as long as they are infrequent and not allowed on school campus during school meal service.


From PMA’s comment


USDA stated in its proposal that implementation of nutrition standards for competitive foods will result in “potentially more expensive” mix of foods offered. We disagree with USDA’s position on this issue, at least as it relates to fruits and vegetables. PMA’s produce pricing research from October 2010, albeit conducted from a retail market basket perspective, showed that the DGA’s daily recommended nine servings of fresh fruits and vegetables can be attained through prices ranging from 88 cents to $2.18. Though schools are not responsible for ensuring children get nine servings each day, the research shows that the idea that healthful eating has to be expensive is a myth.


 Also see the 49 pages of comments from the Center for Science in the Public Interest.


The Center for Food Safety writes that the USDA proposed rule on competitive food doesn’t go far enough.

 USDA should help schools eliminate competitive foods altogether for the following reasons.

  • Competitive foods financially undermine the school meal program.
  • Competitive foods at school meals creates stigma for low-income children.
  • Slightly healthier junk food is still unhealthy, sends the wrong message.
  • Competitive food allows junk food companies to market to children.
  • Challenge of enforcing nutrition guidelines for competitive foods.


 Thus, to maximize the economic benefit to schools, USDA should provide resources to help schools that want to eliminate competitive foods completely, as opposed to placing a healthy halo and government seal of approval upon highly-processed and nutritionally-void products from companies seeking only to target children with their brands. At the very least, USDA should be clear that schools are not required to offer competitive foods and are free to remove them any time they wish, as some districts and states have already done.

In conclusion, to ensure children’s health, USDA should provide guidance and resources to assist schools in successfully eliminating all competitive foods from schools.


Beyond the technical comments about tweaks to the proposed rule, the passion on this issue comes from the local level:

Brenda Thompson from Texas writes:

As a food blogger, chairperson of the wellness committee at our local elementary school and nutrition sub-committee chair on our school district’s School Health Advisory Council, I support the proposed changes being made by the USDA. I have witnessed first-hand students purchasing items such as ice cream and chips and then eating those items first and letting the plate lunches go to waste. If healthier options were available, at least they would not be filling up on junk so much.

Changing the food offered in schools is only one piece of the puzzle to address obesity in school. While the proposed change will not eliminate the sale of a la carte items in schools, a significant income source for many schools, by offering healthier choices it can be a win-win. There is much evidence to support the fact that healthier a la carte items CAN continue to be a valuable income stream so why not offer that?

Thank you for the opportunity to provide feedback for consideration.


Kelly Hornish from Wisconsin is not happy with the whole grain standard:

 The food program is too regulated and kids are eating less food at school and over eating when they get home as they are so hungry. My kids use to take hot lunch 95% of the time, now they take it about 1%. My son, who is 10 is tired of cold lunch because he wants hot food, but will not eat all the whole grain BS they feed him. He is an excellent, fruit and vegetable eater, meats, and other items, but the whole grain is not appealing to his palate.

Thus I spend a lot more on packing cold lunch, and find it is less nutritious than what use to be served. I understand there are many kids who are overweight or unhealthy, but this is not the way to fix that problem. When I visit my son's lunch time at school, I see more food going into the trash than into the mouths of these children. My older kids, in high school, have resorted to packing lunches now too. You know it has to be bad when a teenager will pack a lunch! All this regulation has gone overboard. Feed the kids what they will eat. Keep the fruits and vegetables, great choices, but this whole grain business has to go. Please feed our children!


TK:  USDA will have plenty to sort through with the many thousands of comments on the competitive foods rule, but in my view the final product should not look a lot different than the proposed regulation.