Smart Snacks in School

1. Competitive food standards enacted under the Healthy Hunger-Free Kids Act of 2010.
2. Implementation began July 1, 2014 under Interim Final Rule.
3. Regulations found at 7 CFR 210.11

1. Competitive Foods: All foods and beverages sold to students outside of the reimbursable meal, on the school campus, and at any time during the school day.
   1. Sold means the exchange of money, tokens, or the use of some type of prepaid account to purchase an item.
   2. Includes: Items sold a la carte, in vending machines, at school stores, during fundraisers, or at any other venue that sells food/beverages to students during the school day.
   3. School Campus: All areas of the property under the jurisdiction of the school that are accessible to students during the school day, including school buses.
   4. School Day: Period from midnight before school starts to 30 minutes after the end of the official school day.

1. Apply the same to all grade levels.
2. Must meet two sets of standards:
   1. General Standard - must meet ONE of the following:
      1. Be a whole grain-rich product (i.e., contains 50% or more whole grains by weight or have whole grains as the first ingredient); or
      2. Contain one of the other major food groups (fruits, vegetables, dairy product, or protein food) as the first ingredient; or
      3. Be a “combination food” with at least ¼ cup fruit and/or vegetable.
   2. Nutrient Standards - must meet ALL the following and each is assessed “as packaged/served” and including all accompaniments:
      1. Total Fat: < 35% of total calories per item.
      2. Saturated Fat: < 10% of total calories per item.
      3. Trans Fat: Zero grams per portion.
      4. Sodium:
         1. Snack and side items: < 200 mg sodium per item.
         2. Entrée items: < 480 mg sodium per item.
      5. Calories:
         1. Snack or side items: < 200 calories per item. Rev. July 2024 Page 2 of 4
         2. Entrées items: < 350 calories per item.
      6. Sugar: < 35% of weight from total sugar per item.
3. Broad exemptions to Smart Snacks standards include:
   1. Fruits and Vegetables:
      1. Fresh and frozen fruit with no added ingredients except water, and canned fruit packed in 100% juice, light syrup, or extra light syrup.
      2. Fresh and frozen vegetables with no added ingredients except water, and low sodium or “no salt added” canned vegetables that contain no added fats. (Note: Canned corn or peas with a small amount of sugar for processing are included.)
      3. Combinations of fresh, frozen, or canned fruits and vegetables are exempt if there are no other added ingredients except for water.
   2. SLP/SBP Entrée Items Sold a la Carte: Entrée items offered as part of the reimbursable breakfast or lunch are exempt from all competitive food standards when sold a la carte on the day of service or on the following school day.
   3. Sugar-Free Chewing Gum
4. Specific exemptions to Nutrient Standards (must meet all other nutrient standards):
   1. Exempt from total fat and saturated fat standards:
      1. Reduced fat cheese (including part-skim mozzarella)
      2. Nuts, seeds, and nut/seed butters
      3. Whole eggs with no added fat
      4. Celery with peanut butter and unsweetened raisins
      5. Apples with reduced-fat cheese
   2. Exempt from total fat standard:
      1. Seafood with no added fat (i.e., canned tuna packed in water)
      2. Bean dip
         1. Defined as a spread made from ground pulses (beans, peas, and/or lentils) along with one or more optional ingredients in regulation.
         2. Bean dip exemption does not apply to combination products that contain bean dip with other ingredients such as crackers, pretzels, pita, and manufactured snack-type vegetable and/or fruit sticks.
   3. Exempt from sugar standard:
      1. Dried fruits or vegetables with no added sugars
      2. Dried cranberries, tart cherries, or blueberries sweetened only for processing and/or palatability, with no added fats
   4. Exempt from total fat, saturated fat, and sugar standards:
      1. Trail mix consisting of only dried fruit with nuts and/or seeds with no added sugar or fats

1. Standards vary by grade level:
   1. Plain water or plain carbonated water with no added ingredients may be sold to all students with no limits on portion size.
   2. Unflavored or flavored low-fat (1%) milk, and unflavored or flavored fat-free milk (including nutritionally equivalent milk alternatives as permitted in the school meal programs)
      1. Elementary schools (K-5): < 8 fluid ounces
      2. Middle and high schools (6-12): < 12 fluid ounces
   3. 100% fruit and/or vegetable juice, with or without carbonation
      1. Elementary schools (K-5): < 8 fluid ounces
      2. Middle and high schools (6-12): < 12 fluid ounces
   4. 100% fruit and/or vegetable juice diluted with water, with or without carbonation, and with no added sweeteners
      1. Elementary schools (K-5): < 8 fluid ounces
      2. Middle and high schools (6-12): < 12 fluid ounces
2. Additional beverages for high school students (9-12):
   1. Calorie-Free Beverages (up to 0.5 calories per fluid ounce): Maximum serving size 20 fluid ounces
      1. Calorie-free flavored water, with or without carbonation
      2. Other “calorie-free” beverages with less than 5 calories per 8 fluid ounce container, or up to 10 calories per 20 fluid ounce container.
   2. Lower Calorie Beverages (up to 5 calories per fluid ounce): Maximum serving size 12 fluid ounces
      1. Up to 60 calories per 12 fluid ounce container
      2. Up to 40 calories per 8 fluid ounce container
3. Caffeine:
   1. Only caffeine-free beverages are allowed for elementary and middle school students, except for trace amounts of naturally occurring caffeine substances, such as in chocolate milk.
   2. Caffeine-containing products are not prohibited in high schools.

1. All foods/beverages that meet the Smart Snacks standards may be sold for fundraising purposes on the school campus during the school day without a federal or state limit on frequency or location of sale.
2. Smart Snacks standards do not apply to items sold during non-school hours, on weekends, or at off-campus fundraising events.
3. PDE permits a maximum of five exempt fundraisers to occur in each elementary school and middle school building, and a maximum of ten exempt fundraisers to occur in each high school building per school year.
   1. Exempt fundraisers: Fundraisers that do not meet the Smart Snacks standards.
   2. Each exempt fundraiser may last up to one school week, or five consecutive school days.
   3. Items sold for exempt fundraisers may not be sold in the meal service area during meals.
   4. See Fundraiser Exemptions Guidance on PEARS, Download Forms in the Smart Snacks in School section for more information.

1. Recordkeeping Rev. July 2024 Page 4 of 4
   1. School food authorities (SFAs) are responsible for maintaining records documenting compliance with the competitive food standards for items sold in the meal service area during meal service periods.
   2. Local education agencies (LEAs) are responsible for maintaining records documenting compliance with the competitive food standards for items sold in areas outside of the school food service operation.
   3. LEAs are responsible for ensuring that any organizations selling competitive foods at the various venues in the school are maintaining records documenting compliance with the competitive food standards.
   4. Required records include receipts, nutrition labels, and/or product specifications for items available for sale. In addition, a record that substantiates that each item offered for sale meets Smart Snacks standards is required and includes evaluating the Nutrition Facts label and/or using the Alliance for a Healthier Generation Calculator and retaining copies in the files.
2. Monitoring and Compliance
   1. State agencies are responsible for monitoring compliance with the requirements of the competitive food nutrition standards through periodic reviews of LEA records and operations.

1. PEARS, Download Forms, Smart Snacks in School section
2. Alliance for a Healthier Generation’s Smart Snacks Calculator
3. USDA/FNS Tools for Schools: Focusing on Smart Snacks
4. Alliance for a Healthier Generation’s Smart Foods Planner

RA-NSLP@pa.gov