The School Food Industry Roundtable

Suggested Comment: Eliminate the watermark requirement for CN Labeling

USDA policy requires companies presenting CN labels statements on product information sheets
to include a water mark saying the document cannot be used for meal pattern compliance. This
creates great confusion as that is precisely what the CN label statement is for. The result has been
a persistent requirement for product formulation statements, for CN labeled products, despite
USDA instructions to the contrary. To provide equal assurance the product purchased matches
the CN statement on the product information sheet, the State Auditor should spot check what is
in the freezer and what schools have on their menus.

Suggested Comment: Reduce Requests for Product formulation Statements

Proactively train state auditors and school foodservices to only request or require product
formulation statements for combination products/multi ingredients for which for meal pattern
contribution cannot be calculated based on the Food Buying Guide alone. Eliminate the sample
product formulation statement for grain items that are calculated based on the bread grain
grouping In the Food Buying Guide as this creates an expectation that a Product formulation
statement is needed.

Suggested Comment: Eliminate the Product formulation statement for grains calculated based
on bread grain groupings. It is not necessary.

Suggested Comment: Eliminate the definition and calculation of “uncreditable grains”.

Since “uncreditable grains” are simply not creditable and have since been allowed in exceed the
one time limit of 3.99 g. or less per serving, there is no benefit from calculating the precise
quantity. Eliminate uncreditable grains calculation form the Product Formulation Statements.
Items that are snot defined as creditable, are not creditable, if oat bran is not on the list of Whole
or enriched grains, then it is not creditable – but its presence doesn’t need to be specifically
identified, calculated or limited.

Suggested Comment: Update and Revise the Whole Grain Resource Guide

1) The flow chart should be changed to shows CN Labeled as the first step of identify whole
grain rich compliance, not a last step.
2) Correct examples that show product formulation statements (Based on bread /grain groupings)
They can be credited toward the meal pattern based on the Food Buying Guide alone.
3) Define only creditable whole grains and enriched grains that contribute toward the whole
grain rich requirements with the understanding that anything that is not defined as creditable, is
not creditable, and does not require definition or to be calculated.

Submit comments to USDA:

In response to Request for Information on Credit Policies: