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Administrative Review Process Regarding the CN Label, Watermarked CN Label and Manufacturer’s Product Formulation Statement

EO Guidance Document #
FNS Document #
SP27 CACFP09 SFSP12-2015
Resource type
Policy Memos
Guidance Documents
Resource Materials
PDF Icon Policy Memo (319.29 KB)
DATE:March 11, 2015
SUBJECT:Administrative Review Process Regarding the Child Nutrition (CN) Label, Watermarked CN Label and Manufacturer’s Product Formulation Statement
TO:Regional Directors
Special Nutrition Programs
All Regions
State Directors
Child Nutrition Programs
All States

The purpose of this memorandum is to provide state agencies and child nutrition program operators, including the National School Lunch Program, School Breakfast Program, Child and Adult Care Food Program, and Summer Food Service Program, with additional information and clarification on the administrative review (AR) process regarding the: 1) Child Nutrition (CN) Label, 2) Watermarked CN Label, and 3) Manufacturer’s Product Formulation Statement (PFS).

Documenting CN Labeled Products Requirements

The CN Label is the gold standard for verifying the crediting of menu items and provides a warranty against audit claims when the product is used according to the manufacturer’s instructions. Valid and acceptable documentation for the CN Label is:

  1. the original CN Label from the product carton; or
  2. a photocopy of the CN Label shown attached to the original product carton; or
  3. a photograph of the CN Label shown attached to the original product carton. (CN Labels that are photocopied or photographed must be visible and legible.)
Documenting Watermarked CN Label Requirements

During an AR, if the original CN Label, or the valid photograph or photocopy of the original CN Label is not available, program operators may provide the Bill of Lading (invoice) containing the product name and:

  1. a hard copy of the CN Label copied with a watermark displaying the product name and CN number provided by the vendor; or
  2. an electronic copy of the CN Label with a watermark displaying the product name and CN number provided by the vendor.
Product Formulation Statement

Reviewers must not request a PFS or additional crediting information when a valid CN Label or watermarked CN Label is provided by program operators. The PFS should only be requested when reviewing a processed product without a CN Label (see attached flowchart - Verifying Acceptable Documentation of CN Labels During an Administrative Review).

CN Label Verification System

FNS is currently working with the Agricultural Marketing Service to develop a CN Label verification system. This system will assist State reviewers during the AR, to verify the status of a CN Label as well as the crediting information. The expected completion date for this verification system is Fall 2015. Once the CN Label verification system is fully operational, state reviewers are encouraged to use this system to verify crediting information and the validity of the CN number on a CN Label.

Regional offices are to ensure all state personnel are aware of the process for verifying acceptable documentation and proper procedures for handling products with a valid CN Label. State agencies should distribute this memorandum to program operators as soon as possible. State agencies may direct any questions concerning this memorandum to the appropriate FNS regional office.

Cheryl Jackson Lewis
Nutrition Promotion and Technical Assistance Division
Sarah Smith-Holmes
Program Monitoring and Operational Support Division


Page updated: February 28, 2024

The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.