Smart Snacks in School: Federal Standards for Competitive Foods

Smart Snacks in School is the USDA’s set of nutrition standards for any food or beverage sold to students on school grounds during the school day, outside the reimbursable lunch and breakfast lines. The rules cover vending machines, school stores, snack bars, and a la carte cafeteria sales. A final rule effective July 1, 2024, updated several standards, and those changes are fully in effect for the 2025–2026 school year.¹

What Counts as a Competitive Food

A competitive food is any food or beverage sold to students on the school campus during the school day that falls outside the federally reimbursed meal programs. “School campus” covers every part of the property under the school’s jurisdiction that students can access. “School day” runs from the midnight before classes start to 30 minutes after the official school day ends.² That window is wider than most people expect. A student buying a snack from a hallway vending machine well after the final bell is still inside the regulated period.

What the Rules Do Not Cover

Smart Snacks applies only to items sold to students. Lunches packed at home, birthday treats a parent brings to a classroom, and food donated for a class event are not covered, because no sale takes place.³ Concession stands at evening football games and weekend events fall outside the rules because those sales happen after the defined school day. Some districts apply nutrition guidelines to those settings through their own wellness policies, but the federal mandate does not require it.

The Composition Test

Before a food is measured against calorie or sodium limits, it has to clear a composition check. The item must fit at least one of these categories:²

A grain product containing 50 percent or more whole grains by weight, or listing a whole grain as the first ingredient.
A food listing a fruit, vegetable, dairy, or protein as the first ingredient.
A combination food containing at least a quarter cup of fruit or vegetable.

This filters out items where a healthy-sounding component sits behind sugar or refined flour on the label. A fruit snack listing corn syrup before any actual fruit would not qualify, regardless of what the front of the package says.

Nutrient Limits for Snacks and Entrees

Every competitive food that clears the composition test must also stay within specific nutrient ceilings, and the caps differ by whether the item is sold as a snack or an entree.²

Calories: snacks and side dishes are capped at 200 per item as packaged or served; entrees at 350.
Sodium: 200 milligrams for snacks, 480 milligrams for entrees.
Total fat: no more than 35 percent of total calories.
Saturated fat: less than 10 percent of total calories.
Sugar: no more than 35 percent of the product’s weight.

These measurements include any accompaniments sold with the item. If a school sells popcorn with butter or vegetables with ranch dressing, the nutrition information for the condiment counts toward the totals.³ A compliant snack can become non-compliant the moment a dipping sauce is added.

Foods With Partial or Full Exemptions

Several whole foods get exemptions from the fat and sugar limits, reflecting that a handful of almonds is not nutritionally equivalent to a bag of cheese puffs even if both are high in fat.²

Fresh and frozen fruits and vegetables with no added ingredients except water are exempt from all nutrient standards.³
Nuts, seeds, and nut or seed butters are exempt from total fat and saturated fat limits, but still face calorie, sodium, and sugar caps.
Reduced-fat cheese and part-skim mozzarella are exempt from fat limits.
Seafood with no added fat is exempt from total fat limits.
Whole eggs with no added fat are exempt from both fat standards.
Dried fruit with nuts or seeds and no added sweeteners or fat is exempt from fat and sugar standards.
Bean dip and hummus are exempt from the total fat standard, an addition from the April 2024 rule that covers dips made from any variety of beans, peas, or lentils.⁴

A recurring theme runs through these exemptions: the moment a whole food is paired with another ingredient in a package, the exemption disappears and the combination product must meet all standard limits. Trail mix, peanut butter crackers, and hummus with crackers are all subject to the full nutrient tests.

Beverage Rules by Grade Level

Beverage rules are tiered by age. Younger students face tighter restrictions and high schoolers get more options. Every grade level can buy plain water with no size limit.²

Elementary Schools

Beyond water, elementary students may purchase low-fat (1 percent) or fat-free milk, flavored or unflavored, and 100 percent fruit or vegetable juice. Both milk and juice are capped at 8-ounce servings. Nothing else is permitted.

Middle Schools

Middle schoolers have the same beverage options as elementary students, but portion sizes for milk and juice increase to 12 ounces.²

High Schools

High schoolers get everything available in middle school plus two additional categories. No-calorie beverages (fewer than 5 calories per 8 ounces) may be sold in containers up to 20 ounces. Lower-calorie beverages (up to 40 calories per 8 ounces) are limited to 12-ounce containers.³ These categories cover items like flavored waters and certain diet drinks.

Flavored Milk and Added Sugars

Starting with the 2025–2026 school year, flavored milk must meet a new added-sugars cap of no more than 10 grams per 8 fluid ounces. For flavored milk sold as a competitive beverage in middle and high schools, the limit is 15 grams per 12 fluid ounces.⁵ Many popular chocolate milk products exceed these thresholds and will need to be reformulated or replaced.

Other Changes From the 2024 Final Rule

Beyond flavored milk, the rule effective July 1, 2024, made two other adjustments worth flagging:¹

The trans fat requirement was removed. Previously, nutrition labels had to show zero grams of trans fat per serving. The FDA’s separate ban on partially hydrogenated oils had already stripped most artificial trans fats from the food supply, making the school-specific rule redundant.⁴
The bean dip and hummus exemption from the total fat standard was added.

Marketing Restrictions on Campus

The rules go beyond what can be sold and reach what can be advertised. Schools may only allow on-campus marketing during the school day for foods and beverages that meet Smart Snacks standards.² The restriction applies to brand names, logos, and characters on vending machine exteriors, scoreboards, cups, coolers, trash cans, educational materials, school websites, and public address announcements.

Coverage extends to any property the district owns or leases, including athletic fields, parking lots, and school buses. A scoreboard sponsored by a soda brand whose products do not meet Smart Snacks standards violates the rule even if the school does not actually sell that brand’s drinks. The regulation targets the marketing itself, not just the point of sale.

Fundraiser Exemptions

Federal law allows a limited number of fundraisers each year where the food sold does not have to meet Smart Snacks standards. The state agency sets the count, and it varies widely: some states allow none, others permit up to roughly ten per year.⁶

Even during an exempt fundraiser, non-compliant items cannot be sold in the food service area while breakfast or lunch is being served.⁶ The whole purpose of these standards is to avoid undercutting the meal programs. Sales on non-school days, weekends, and off-campus events are not subject to any of these restrictions.

Recordkeeping and Enforcement

Schools must keep documentation proving every competitive food item meets the standards. That means retaining nutrition facts labels, ingredient lists, and procurement records for each item sold on campus, plus records of any exempt fundraisers and the items sold during them.⁷ For scratch-made items without a manufacturer’s label, the USDA directs schools to use approved nutrient analysis software to calculate the values themselves.

State agencies verify compliance through administrative reviews, generally on a three-year cycle. Competitive food compliance is a “general area” of review rather than a “critical area,” so a first-time violation does not automatically trigger financial penalties. The state agency issues corrective action requirements with a deadline. If a school fails to complete corrective action on time or ignores it altogether, the state agency may withhold federal meal reimbursement payments until the issue is resolved.⁸ In some cases the withheld amount may be reduced by up to 60 percent if a full withholding would not serve the program’s interests.

Local Wellness Policies Can Go Further

Every district participating in the federal meal programs must adopt a Local School Wellness Policy, developed with input from parents, students, teachers, school health professionals, food authority representatives, administrators, and the school board.⁹ These policies can address topics the federal standards leave open, like nutrition guidelines for classroom parties, food rewards, and after-hours concession sales.

The federal standards are a floor, not a ceiling. State agencies and districts can adopt stricter requirements.³ A district might ban all sugar-sweetened beverages at high school level even though the federal rule allows lower-calorie options, or extend Smart Snacks-style limits to evening events. Districts must assess their wellness policies at least every three years and share the results with stakeholders.¹⁰ Check your district’s wellness policy before assuming the federal minimums are the only rules that apply.

1
Federal Register. Child Nutrition Programs – Meal Patterns Consistent With the 2020-2025 Dietary Guidelines for Americans
2
eCFR. 7 CFR 210.11 – Competitive Food Service and Standards
3
USDA Food and Nutrition Service. A Guide to Smart Snacks in School
4
USDA Food and Nutrition Service. DGA Final Rule Summary
5
Food and Nutrition Service. Milk – School Nutrition Standards Updates
6
eCFR. 7 CFR 210.11 – Competitive Food Service and Standards
7
Food and Nutrition Service. A Guide to Smart Snacks in School
8
eCFR. 7 CFR 210.18 – Administrative Reviews
9
Food and Nutrition Service. Local School Wellness Policies
10
Food and Nutrition Service. Local School Wellness Policy Implementation Tools and Resources