Overview
Pulse-based milks can play a role in school nutrition programs as allowable fluid milk substitutes when they meet USDA requirements. As interest in plant-based options continues to grow among schools and students, understanding how pulse-based milks fit within the National School Lunch Program (NSLP) and School Breakfast Program (SBP) is important for product development and positioning.
In January 2026, USDA Food and Nutrition Service (FNS) issued updated guidance clarifying how schools can accommodate requests for fluid milk substitutes. This update builds on existing regulations and provides greater flexibility in how nondairy options, including pulse-based milks, can be offered in school meal programs.
How Pulse-Based Milks Fit in School Meals
Schools are required to offer fluid milk as part of reimbursable meals. Nutritionally equivalent nondairy beverages, including pulse-based milks, may be offered as substitutes.
Recent policy updates allow a parent or guardian to provide the written statement requesting a fluid milk substitute for school lunch, expanding who can provide documentation which was previously limited to healthcare providers. This change currently applies specifically to the National School Lunch Program; similar alignment with the School Breakfast Program may be considered in the future as USDA harmonizes program policies.
Most schools are expected to continue using this request-based process for nondairy substitutions. However, schools also have the option to offer nutritionally equivalent nondairy beverages more broadly to all students to meet the milk requirement, but this is optional and determined locally.
If a milk substitute costs more than standard milk, the school food authority is responsible for covering the difference, which can influence whether and how broadly substitutes are offered.
USDA Nutrition Requirements for Fluid Milk Substitutes
To be creditable in school meals, pulse-bashed milks must meet the following nutrient standards per cup (8 fluid ounces):
- Calcium — 276 mg
- Protein — 8 g
- Vitamin A — 150 mcg RAE
- Vitamin D — 2.5 mcg
- Magnesium — 24 mg
- Phosphorus — 222 mg
- Potassium — 349 mg
- Riboflavin — 0.44 mg
- Vitamin B-12 — 1.1 mcg
Products must be appropriately fortified and formulated to meet these levels. This is according to the regulations (7 CFR § 210.10(d)(2)(ii)).
Key Considerations for the Pulse Industry
Pulse-based beverages are well positioned because they can meet protein requirements more readily than many other plant-based options, but full nutrient equivalency via fortification remains essential.
Local implementation decisions, procurement practices, and cost considerations will shape how widely nondairy beverages are adopted across districts.
Clear labeling and documentation can help school nutrition operators quickly confirm compliance.
Why This Matters
Pulse-based milks represent an opportunity to expand pulse utilization in school settings while aligning with evolving nutrition standards and student preferences. Understanding how documentation flexibility, local decision-making, and cost considerations interact can help ensure products are positioned for successful adoption.