Special Diets in School Nutrition Programs

Milk Substitutes for Non-disability Reasons

The U.S. Department of Agriculture (USDA) allows school food authorities (SFAs) that operate the school nutrition programs to offer one or fluid milk substitutes (nondairy beverages) for children who do not consume regular cow’s milk due to non-disability reasons. Fluid milk substitutes are plant-based beverages like fortified soy milk that are intended to replace cow's milk. SFAs that choose to offer allowable fluid milk substitutes must make them available to all students.

The guidance below does not apply to fluid milk substitutes for children whose disability restricts their diet.  For detailed guidance on the requirements for meal modification for disability reasons, refer to the CSDE's Guide to Meal Modifications in the School Nutrition Programs.

Allowable Fluid Milk Substitutes (Nondairy Beverages)

Fluid milk substitutes for non-disability reasons must meet the USDA’s nutrition standards for fluid milk substitutes (7 CFR 210.10(d)(2)(ii)). Only certain brands of fluid milk substitutes meet these standards. 

In addition to meeting the USDA’s nutrition standards, all fluid milk substitutes available for sale to students in public schools must meet the state beverage requirements for nondairy milk under C.G.S. Section 10-221q. Nondairy milk substitutes cannot contain artificial sweeteners and cannot exceed 4 grams of sugar per fluid ounce, 35 percent of calories from fat, or10 percent of calories from saturated fat. 

A list of milk that complies with the federal and state requirements is available in List 17: Dairy Alternative Beverages on the CSDE's List of Acceptable Foods and Beverages webpage.

Requesting Fluid Milk Substitutes

Note: The information for fluid milk substitute requests is based on the USDA’s guidance in USDA Memo SP 01-2026: Whole Milk for Healthy Kids Act of 2025 – Implementation Requirements for the National School Lunch Program and is subject to change. Additional guidance from the USDA may impact how the Whole Milk for Healthy Kids Act of 2025 applies to school nutrition programs other than the NSLP, including the SBP, SSO, ASP, and SMP. The CSDE will update this information as the USDA issues future guidance.

Fluid milk substitutes require a written request from the parent/guardian, a state licensed healthcare professional, or a registered dietitian that identifies the reason for the milk substitute. These written requests must be maintained on file with the student’s medical records.

Effective January 14, 2026, the NSLP meal patterns for grades K-12 do not require a written statement to request a fluid milk substitute for non-disability reasons. SFAs have the option to offer all children any nondairy milk substitutes that meet the USDA’s nutrition standards for fluid milk substitutes.

Identifying Acceptable Fluid Milk Substitute Products

Before purchasing any type of commercial nondairy milk substitute, SFAs must ensure that the product complies with the USDA’s nutrition standards for fluid milk substitutes. List 17: Dairy Alternative Beverages of the CSDE’s List of Acceptable Foods and Beverages webpage identifies commercial products that meet the USDA’s nutrition standards for fluid milk substitutes and the nondairy milk requirements of the state beverage statute. If a commercial product is not included on this list, SFAs must contact the manufacturer to obtain documentation that 1 cup provides the minimum amount of each required nutrient. 

Certain brands of soy milk and oat milk are the only currently available commercial products that meet these requirements. Almond milk, cashew milk, rice milk, some brands of soy milk, most brands of oat milk, and other nondairy milk products do not comply with the USDA’s nutrition standards and cannot be offered as fluid milk substitutes for non-disability reasons in the school nutrition programs. 

Lactose-free and Lactose-reduced Milk (Fluid Milk)

Lactose-free milk and lactose-reduced milk are fluid milk (not nondairy beverages) and credit the same as regular milk in the meal patterns for the school nutrition programs. These types of milk are processed by adding lactase enzymes to reduce or eliminate the lactose (naturally occurring milk sugar) found in regular milk. Children who cannot digest the lactose found in regular milk may be able to drink lactose-free/reduced milk. The USDA recommends these types of milk as the first choice for children with lactose intolerance. 

Lactose-free/reduced milk must meet the required fat content and flavored milk restrictions for each USDA meal pattern and must also meet the additional state beverage requirements for nondairy milk under Connecticut General Statutes (C.G.S.) Section 10-221q. For more information, refer to Milk Substitutes for Non-disability Reasons in the "Milk Component" section of the CSDE's Crediting Foods in School Nutrition Programs.

SFAs may choose to offer lactose-free/reduced milk as a fluid milk option for all children. A written statement is not required.

Guidance