USDA Issues Implementation Requirements for Use of Plant Milks in the National School Lunch Program
photo from Freepik
by Reed Mangels, PhD, RD
The Whole Milk for Healthy Kids Act of 2025 was signed into law on January 14, 2026. Of interest to vegans, this act permits schools to offer all children “nondairy beverages that are nutritionally equivalent to fluid milk and meet the nutritional standards established by the Secretary (which shall, among other requirements to be determined by the Secretary, include fortification of calcium, protein, vitamin A, and vitamin D to levels found in cow’s milk).” Schools are not required to offer all children nondairy beverages but are permitted to do this. In the past, a request from a parent, legal guardian, or physician was required for a school to provide a plant milk to a child without a disability.
USDA, the department of the U.S. government that administers the National School Lunch Program issued a document detailing the requirements for implementing this act. With regard to plant milks, if a school food authority chooses to offer fortified plant milks to all students, a cup of the plant milk must contain at least 276 mg of calcium, 8 grams of protein, 500 IU of vitamin A, 100 IU of vitamin D, 24 mg of magnesium, 222 mg of phosphorus, 349 mg of potassium, 0.44 mg of riboflavin, and 1.1 mcg of vitamin B12. The milk can be flavored or unflavored. The document goes on to say, “offering nondairy beverages to all students to meet the fluid milk requirements at lunch [note that no mention is made of school breakfast programs] is an option, not a requirement.”
Schools that choose to offer plant milks to all students are no longer required to notify the State agency that plant milks are being served.
Schools that do not choose to offer plant milks to all students must follow the earlier process of a requiring a request from a student’s parent or guardian, a State licensed healthcare professional, or a registered dietitian that identifies the reason for the substitute for students without disabilities. The school is then allowed (but not required) to provide that student a plant milk that meets the nutritional requirements described earlier. A school food authority must inform the State agency if any schools choose to offer fluid milk substitutes for non-disability reasons.
Schools are required to provide a substitute for cow’s milk for students whose disability restricts their diet. Previously, a statement from a State licensed healthcare professional or a registered dietitian was required. Now, a parent or legal guardian may provide a written statement requesting a fluid milk substitute (such as a plant milk) for a child whose disability restricts their diet.
It will be interesting to see how many schools will offer all children “nondairy beverages that are nutritionally equivalent to fluid milk” especially since these products are often more expensive and the act does not provide additional funds to cover the costs of offering plant milks to all children.
For more information about plant milks in school lunch programs see:
What are Some of the Brands of Plant Milk that Can Be Used in the National School Lunch Program?
