Smart Snacks in School: the numbers behind the rule

What counts as a competitive food

Section 210.11 uses the term competitive food for everything sold to students on the school campus during the school day other than meals reimbursed under the National School Lunch Act and Child Nutrition Act programs. That covers a la carte lines, vending machines, school stores and fundraiser sales. The school day runs from the midnight before to 30 minutes after the official end of the school day, and the campus is all property under the school’s jurisdiction that students can access during that time.

The standards apply to items as packaged and served. State agencies and districts may add restrictions that do not conflict with the federal rule, and the district is responsible for keeping records showing that food sold in areas outside the school food authority’s control complies.

The numeric limits

A snack or side dish may have no more than 200 calories and 200 mg of sodium per item, counting any added accompaniments such as butter, cream cheese or dressing. An entree sold as a competitive food may have no more than 350 calories and 480 mg of sodium. Total fat must be no more than 35 percent of calories. Saturated fat must be under 10 percent of calories. Total sugar must be no more than 35 percent of the item’s weight. The calculator on this page converts fat grams to calories at nine calories per gram, the standard conversion, which is our arithmetic and not a printed rule.

Example: a 28 g bar with 140 calories, 100 mg sodium, 5 g fat, 1 g saturated fat and 8 g sugar has fat at 32 percent of calories, saturated fat at 6 percent and sugar at 29 percent of weight, so it passes each numeric test.

The food-group requirement

Numbers alone are not enough. An allowable item must also be a grain product with at least 50 percent whole grains by weight or whole grain as the first ingredient, or have fruit, vegetable, dairy or a protein food as the first ingredient, or be a combination food containing at least a quarter cup of fruit or vegetable. If water is the first ingredient, the second ingredient must be one of those items. The calculator cannot see an ingredient list, so a pass on the numbers is not a pass on the standard.

Exemptions that change the test

Several foods are exempt from parts of the rules. Fresh, frozen and canned fruit with no added ingredients except water, juice or light syrup is exempt from the nutrient standards, as are plain fresh and frozen vegetables and canned vegetables that are low sodium or no salt added with no added fat. Seafood with no added fat, bean dip, reduced-fat cheese, part-skim mozzarella, nuts, seeds, nut butters, whole eggs with no added fat and dried fruit with nuts and seeds each skip some fat or sugar limits while still meeting others. Combination products usually do not get the exemption. Sugar-free chewing gum is exempt from all of the standards, at the district’s discretion.

An entree that was served in the lunch or breakfast program that day or the day before is exempt from the competitive standards if sold in the same or a smaller portion.

Caffeine and beverages

Foods and beverages offered to elementary and middle school students must be caffeine-free apart from trace amounts that occur naturally; high school students may be offered caffeine. Beverage options are limited by grade. At every level plain water or plain carbonated water has no size limit. Milk and fluid milk substitutes that meet the school meal milk rules are limited to 8 fluid ounces in elementary schools and 12 in middle and high schools. The same sizes apply to 100 percent fruit or vegetable juice, with or without water or carbonation and with no added sweeteners.

High school lists add calorie-free flavored water up to 20 fluid ounces, other beverages under 5 calories per 8 ounces or 10 calories per 20 ounces up to 20 ounces, and beverages of no more than 40 calories per 8 ounces or 60 per 12 ounces up to 12 ounces.

Fundraisers

A fundraiser selling items that do not meet the standards is allowed only as a specially exempted, infrequent school-sponsored fundraiser. How often is set by the State agency. Everything else sold during the school day must comply.

What this page does not decide

Only your State agency or district can say whether a particular item is on its approved list, whether a fundraiser exemption applies, or whether stricter local limits apply. Use the result as a screen before you check the label against the full regulation.

Sources

• 7 CFR 210.11, Competitive food service and standards: eCFR text current through the October 29, 2026 issue date. Read November 2, 2026.

Edition read: 7 CFR 210.11 (eCFR, current through the October 29, 2026 issue date). This page summarizes the rule and does not replace it.