If your company is supplying whole grain foods to schools in the United States, you’ll be happy to know that USDA’s Food and Nutrition Service (FNS) has issued a new guide to answer all your questions about foods that qualify as “whole grain-rich.”

Two years ago, in the summer of 2012, new rules went into effect mandating that half the grains served in school lunches must qualify as “whole grain-rich.”  This summer, the rules ratchet up another level: all grains served in schools at breakfast and lunch must be “whole grain-rich.”

While we highly recommend that anyone offering whole grain foods to schools read this entire resource cover to cover – click here to download it now – this blog will outline some of the key points we found most worthy of bringing to your attention, in no particular order.

Don’t Put Whole Grain-Rich on Labels. Once you determine your product qualifies as whole grain-rich you may think, “Great, I’ll state that on my label, so that the schools will know.” Not so fast. While USDA/FNS determines what goes into school foods, FDA determines what can go on the label. Because “rich” is synonymous with “excellent source” in FDA’s dictionary, FDA doesn’t permit the use of the term “whole grain-rich” on labels. Another option? Apply for a Child Nutrition (CN) Label to indicate your product is whole grain-rich.

Bran and Germ Don’t Count. FNS says all grain foods served In schools must be made with a combination of whole grains and enriched grains, both of which are considered “creditable grains.” Bran, germ, corn starch, and other grain fractions are considered “noncreditable grains” (except for wheat gluten, which for some reason is not “noncreditable” and can be ignored, USDA told the WGC). Here’s the way it shakes out:

• whole grain – 50% or more of the grain
• non-creditable grain ingredients – no more than 2% of the grain
• enriched grain – all the rest of the grain

While we think whole grains should indeed be top dog in the hierarchy, we’d like to see bran and germ encouraged over enriched grain (basically white flour with a few extra vitamins thrown in); we’re sorry to see bran and germ basically disallowed in schools.

Reconstituting in Your Own Facility is Iffy. We’ve known for some time that both FDA and USDA may have reservations about companies that buy endosperm, bran, and germ separately and reconstitute it in their factories to create a whole grain. This document gives another indication of where the wind is blowing, when it says (p 6) that the results may be considered whole grain “when the reconstitution is done by the original milling facility” – with the implication that reconstitution elsewhere may not be considered whole grain.

Be Prepared to Prove It. Take a good look at page 10 of the guide, which details the ways that school food directors must document that all their grain foods qualify as whole grain-rich. If you aren’t doing so already, we strongly urge all companies to routinely provide proof that will ease your product through the purchasing process. There’s a form on page 25 that schools need to have filled out, to document all their grains. Make sure you know how to represent each of your school grain products, on this form.

Still confused? The document includes ten examples of foods that qualify as whole grain-rich or don’t, that are very helpful in showing you how to thread your way through the new requirements. 

And remember, as you work to understand the new requirements: it’s all for a good cause. We’re delighted that whole grains are now the default in schools. Just imagine the difference it will make, when a whole new generation has grown up seeing whole grains as the natural way of grains rather than the exception. (Cynthia)