Skip to content

Grain Requirement in the CACFP; Q&A

April 4, 2018



Whole grain-rich can be a confusing term. This memo outlines and provides additional clarification to the grains component of the new meal pattern as well as provides an extensive and updated Q&A. Please note that this memo introduces ingredients you can disregard when determining if a product is whole grain-rich. This includes cornstarch.

This memo supersedes CACFP 01-2018.

  • All grains served must be made with enriched or whole grain or flour or bran or germ.
  • Grain is a required component at breakfast, lunch, and supper meals, with an option at snack.
  • One serving of grains a day must be whole grain-rich.
  • Ounce equivalents (oz eq) are not required until October 1, 2019 while the rest of the new meal pattern has already gone into effect as of October 1, 2017 (currently in transition period).
Enriched Grains and Fortified Breakfast Cereal

Creditable criteria (must meet at least one):

  1. Labeled as enriched.
  2. An enriched grain is the first ingredient listed (or second after water).
  3. A cereal is listed as fortified or includes the vitamins and minerals that have been added to the product. Does not need to be enriched.

Whole Grain-Rich

  • One serving a day.
  • Applies only to children and adults, not infants.
  • Contains at least 50% whole grains and the remaining grains are enriched, or 100% whole grain.

Creditable Criteria (must meet at least one):

1. Product is listed on a State Agency’s WIC-approve whole grain food list.
2. Labeled as “Whole wheat” and has a Standard of Identity issued by the FDA.
  • Please reference full-text for a comprehensive list of approved Standard of Identity terms for whole grain-rich breads and pastas.
  • Any other product must be evaluated based on one of the other methods listed in this memo.
3. Includes one of the following health claims (for CACFP only):
  • 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.
  • 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.
4. Meets the whole grain-rich criteria under the National School Lunch Program (NSLP).
  • One exception are grain-based desserts.
5. Meets FNS’ Rule of Three:
  • First ingredient must be whole grain and the next two grain ingredients (if any) must be whole grains, enriched grains, bran, or germ.
  • Any grain derivatives (by-products of grains) may be disregarded.
  • Any non-creditable grains (not enriched or whole flours) that are labeled as 2% or less may be disregarded as well.
  • Mixed dishes (pizza crust, burritos, etc): the first grain ingredient must be whole grain and the second two grains (if any) must be whole grains, enriched grains, bran, or germ.
  • Ready-to-eat Breakfast Cereals: if the first ingredient is a whole grain and the cereal is fortified, it’s creditable.
  • Please reference full-text for a comprehensive list of approved whole grains, brans and germs, enriched grains, disregarded ingredients, and non-creditable grains or flours).
6. Proper documentation from a manufacturer or a standardized recipe that demonstrates whole grains are the primary grain ingredient by weight.

Grain-Based Desserts

  • No changes. Please refer to the full-text memo under superscript 3 or 4 in Exhibit A (Attachment 2) for a full list.

Breakfast Cereals

  • Must contain no more than 6 grams of sugar per dry ounce (21.2 grams of sugar per 100 grams of dry cereal) and be made from enriched or whole grain meal or flour, or be fortified, to be creditable.
  • Reminder: infant cereals and ready-to-eat cereals must be iron-fortified.
  • To determine if a cereal meets the sugar limit:
    • Utilize any State Agency’s WIC approved breakfast cereal list.
    • Use USDA’s Team Nutrition training worksheet.
    • Calculate using either Standard Method or Round Method. Only one method is needed to prove the cereal is within the sugar limits.
    • Standard Method: Find serving size in grams, divide by total sugars, if the answer is equal or less than 0.212, then it’s creditable.
    • Rounding Method: Find serving size in grams, multiply the serving size by 0.212. If the answer ends in 0.5 or more, round the number up to the nearest whole number. Find the sugars listed on the Nutrition Facts label. If that number is equal to or less than the number you came up with after rounding, the cereal meets the sugar limit.
  • State Agencies should not impose additional paperwork burdens to prove compliance. Instead, they are encouraged to update forms if needed. An example would be to write WW or WGR in front of a food item to signify compliance. Another way to update a form could be a simple checked box.
  • State Agencies and Sponsoring Organizations must verify the creditability of food served during on-site reviews.
  • During the current transition period (until September 30, 2018), State Agencies and Sponsoring Organizations must provide technical assistance instead of fiscal action.

Please reference the entire memo along with the extensive Q&A included in the full-text memo for further clarification. This summary is not intended to replace the USDA memo.

Why It Matters

Sometimes transitions are difficult; the move to whole grains have been no exception. Many asked for additional guidance and this clarification proved that your voice is heard. Your voice matters. We must continue to advocate for the children in our care, provide the healthiest meals possible, and work together to ensure the highest level of participation and integrity possible.

For more information, Check out Grain-Requirements in the Child and Adult Care Food Program-Questions-and-Answers (CACFP-09-2018).