USDA’s Food and Nutrition Service (FNS) today released a memo clarifying how foods can qualify as “whole grain rich” for the new U.S. school lunch and breakfast requirements. Any companies providing whole grain foods for schools will want to read the full memo, as well as reviewing our commentary of the most important points below.

What is Whole Grain-Rich?

It’s simple: At least 50% of the grain in a food must be whole grain for the food to qualify as “whole grain-rich.”

If a school is not sure what percent of the grain is whole grain, FNS offers three criteria, any one of which can potentially qualify the food:

  1. The food contains 8g of whole grain per ounce equivalent. This applies to most foods; the amount is more for some, although how much more isn’t specifed. See table below.
  2. The food bears the FDA-approved whole grain health claim saying “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.”  (We’d still like to know if the modified moderate-fat version of this claim, which FDA approved in 2003, counts. The memo doesn’t say.)

  3. The ingredients list declares whole grains first (as the first ingredient for non-mixed dishes, and as the first grain ingredient for mixed dishes).

We’re very pleased to see some sensible clarifications in that last point about ingredient lists. FNS says water can be ignored in determining what’s “first” and that all whole grain ingredients can be aggregated to determine if whole grains are the principal ingredient.

Serving Size moves from 14.75g to 16g

We’re touching on serving size next, since this is the question food companies have been asking us the most in recent weeks. Previously, FNS used its own unique serving size for school foods. For everything except pasta, grains like rice and barley, and breakfast cereals (hot or cold), a grain serving used to be defined as “the amount of food that contains 14.75g of grain.”

Going forward, FNS will use the same standards used in the Dietary Guidelines for Americans and MyPlate – 16g of grain content — for these categories of foods. Because July 1, 2012 is just two months away, however, the new serving sizes won’t be mandatory until July of 2013.

FNS wisely realizes that there’s no easy way for buyers to know how much grain went into a slice of bread or a waffle or a cookie, so they’ve published a chart that explains how big an actual serving of food would be. Some examples from the chart:

Foods Minimum whole grain content for “whole grain-rich” Grain content that counts as one ounce equivalent Amount of food that counts as one ounce equivalent
Crackers, breadsticks 8 grams 16 grams 22 g or 0.8 oz
Bread, bagels, pizza crust, tortillas, biscuits 8 grams 16 grams 28 g or 1.0 oz
Pancakes, waffles, cornbread, plain cookies 8 grams 16 grams 34 g or 1.2 oz
Bars (plain), most muffins, sweet rolls (unfrosted) 8 grams 16 grams 55 g or 2.0 oz
Bars & cookies with raisins, nuts etc; French toast 8 grams 16 grams 69 g or 2.4 oz
Unfrosted cakes 8 grams 16 grams 82 g or 2.9 oz
Brownies, frosted cakes 8 grams 16 grams 125 g or 4.4 oz
Grains (barley, rice, quinoa, etc.), Cooked cereals (oatmeal etc.), Pasta 14 grams 28 grams 28 g or 1.0 oz dry
RTE cereal (cold, dry) 14 grams 28 grams 1 cup or 1 oz for flakes, rings (O’s)
1.25 cups or 1 oz for puffed
¼ cup or 1 oz for granola


We have a few comments on the information above, including:

  • Note that FNS is using our least-favorite term, the ounce equivalent, which confounds most consumers (and health professionals and school lunch managers…).

  • FNS doesn’t actually come out and say that a minimum of 14g of whole grain content is necessary in the last two groups, to count as whole grain-rich. But they do say an ounce (28g) of product counts, and that 50% of the grain must be whole grain. We did the math to come up with a minimum that should cover all cases.

  • Only whole grain and enriched grain count as creditable grain ingredients; bran and germ do not count. (Personally, we’d rather see bran and germ count as an option on the enriched side, though not in place of whole grain.) 

  • Before you say, “Why do brownies and cookies count?” – note that only two desserts per week can be counted toward whole grain requirements.

  • One other important question has been clarified here: fractions do count. You could serve ¼ cup of cooked brown rice to the kids and have it count as half of a whole grain-rich serving, for instance.

Timing for Implementation

The timetable FNS laid out previously still holds, with an addition on serving sizes to recognize the short time available for transition. Here’s the timetable at a glance.

When What
Starting July 1, 2012
For SY 2012-2013
a. At least half of grain foods in school lunches must be whole grain-rich.
b. It’s okay to use EITHER the new 16g serving size or the old 14.75g one.
Starting July 1, 2013
For SY 2013-2014
a. At least half of grain foods in school breakfasts must be whole grain-rich.
b. New serving sizes must be used.
Starting July 1, 2014
For SY 2014-2015
a. All grain foods in school breakfasts and school lunches must be whole grain-rich.

All right, all right. Enough. We won’t rewrite the whole document in this blog – and in any event, the FNS memo is the final authority, not us. Take a look at the memo yourself, and start ramping up to serve more good whole grains to our kids! USDA also announced last Friday that they’re increasing funding for school meals to help pay for better quality. It’s only a six cent increase, but every bit helps.(Cynthia)



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