Whole grains are coming to a school cafeteria near you! The USDA released new Final Rules for school nutrition on January 26, 2012. These rules decreed that at least half of grain foods must be “whole grain rich” starting with the new 2012-2013 school year – and that two years later, all grain foods served in schools must be “whole grain rich.”

Definition of Whole Grain Rich

But what does “whole grain rich” mean? According to the new regulations, foods qualify as whole grain rich if they meet qualifications for both elements below:

Element 1: A serving of the food item must meet portion size requirements for the Grains/Bread component as defined in FNS guidance. (A bread serving has been defined in the past as the amount that contains at least 14.75g of grains – but it’s unclear whether this will change to 16g of grain content under the new rules.)

Element 2: The food must meet at least one of the following:

a. The whole grains per serving (based on FNS serving sizes above) must be ≥ 8 grams.

b. The product includes the FDA-approved whole grain health claim on its packaging, which says “Diets rich in whole grain foods and other plant foods and low in total fat, saturated fat and cholesterol may reduce the risk of heart disease and some cancers.”

c. Product ingredient listing lists whole grain first, specifically:

I. Non-mixed dishes (e.g., breads, cereals): Whole grains must be the primary ingredint by weight (a whole grain is the first ingredient in the list)

II Mixed dishes (e.g. pizza, corn dogs): Whole grains must be the primary grain ingredient by weight (a whole grain is the first grain ingredient in the list)

Questions Not Yet Answered

As of February 2012, USDA/FNS is still working on creating guidance and a new Food Buying Guide to clarify several questions, including these:

Element 1: What is a grain/bread serving size? Is it still the amount of food that contains at least 14.75g of grain, or has it been increased to 16g as recommended in the IOM report?

Element 2a: What proportion of whole grain is needed? This one depends on the previous answer. Will foods need to have 8g of whole grain per 14.75g (54.2% of the grain must be whole grain) or will 8g per 16g (50% of the grain is whole grain) suffice?

Element 2b: Will the moderate fat FDA Whole Grain Health Claim also qualify? This one allows a moderate level of total fat, as long as “bad fats” – saturated fats and trans fats – are minimal. It’s worded something like “Diets rich in whole grain foods and other plant foods, and low in saturated fat and cholesterol, may help reduce the risk of heart disease.”

Element 2c: Will foods qualify if whole grains in the aggregate come first? Whole grains can sometimes be the primary ingredient by weight, and yet not be the first ingredient. Take, for example, a bread whose grain comes from three ingredients: enriched wheat flour (40% of grain), whole wheat (30% of grain) and whole oats (30% of grain). Together the whole grains make up 60% of the grain, yet the enriched (refined) grain is listed first.

USDA informed us on January 30, when we asked for answers to questions like these, that “We are currently working on guidance to answer all of these issues and will be sure to incorporate your questions into the guidance.  As soon as it has cleared, we will send the information forward to you.” As soon as we hear from USDA, we will share more information with our website visitors.

Interim WGC Advice to Manufacturers and School Districts

In the meantime, WGC advises both manufacturers and schools that would like to move forward to follow a path that doesn’t depend on these answers. This might include:

Element 1: Assume a 16g serving just in case. If you do, you’ll qualify at 14.75g too.

Element 2: If at least 55% of the grain in your food is whole grain, it will qualify for Element 2a no matter what the final guidance turns out to say.

Stay tuned. We’ll tell you more when we know more.