Skip to main content

Substitution of Vegetables for Fruit

Publication Date
EO Guidance Document #
FNS Document #
Resource type
Policy Memos
Guidance Documents
Resource Materials
PDF Icon Policy Memo (65.64 KB)
DATE: March 18, 2019
MEMO CODE: SP 16-2019
SUBJECT: School Breakfast Program: Substitution of Vegetables for Fruit
TO: Regional Directors
Special Nutrition Programs
All Regions
State Directors
Child Nutrition Programs
All States

This memo has been superseded by SP 06-2020: School Breakfast Program: Continuation of the Substitution of Vegetables for Fruit Flexibility.

Effective immediately, school food authorities (SFAs) participating in the School Breakfast Program may credit any vegetable offered, including potatoes and other starchy vegetables, in place of fruit without including vegetables from other subgroups in the weekly menus. This flexibility is based on Section 768 of the Consolidated Appropriations Act 2019 (PL 116-6) (the Appropriations Act), enacted on Feb. 15, 2019, and effective through Sept. 30, 2019. This provision provides additional flexibility in planning breakfast menus but does not require SFAs to make any menu changes.

SFAs participating in the SBP are required to offer 1 cup of fruit daily to children in all age/grade groups (7 CFR 220.8(c)). To meet this requirement, SFAs may offer a vegetable in place of a fruit. Under current regulations, SFAs choosing to offer a vegetable in place of a fruit at breakfast must ensure that at least two cups per week are from the dark green, red/orange, beans and peas (legumes), or “other vegetables” subgroups (7 CFR 220.8(c), footnote (c)). However, under the Appropriations Act, through Sept. 30, 2019, no federal funds may be used to enforce the requirement that at least two cups of vegetables per week come from the vegetable subgroups listed above. Therefore, SFAs that offer 1 cup of fruit or vegetable at breakfast each day will be considered compliant during the administrative review through Sept. 30, 2019.

State agencies are reminded to distribute this memorandum to program operators. Program operators should direct any questions concerning this guidance to their state agency. State agencies with questions should contact the appropriate FNS regional office.

Angela M. Kline
Policy and Program Development Division
Child Nutrition Programs
Sarah E. Smith-Holmes
Program Monitoring and Operational Support Division
Child Nutrition Programs
Page updated: January 26, 2023

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.