Milk Substitutes
for Nondisability Reasons
The U.S. Department of Agriculture (USDA) meal patterns for the Child and Adult Care Food Program (CACFP) allow two types of optional fluid milk substitutions for participants who do not consume regular cow’s milk due to non-disability reasons. These include lactose-free or lactose-reduced milk and fluid milk substitutes that meet the USDA’s nutrition standards for fluid milk substitutes. These requirements do not apply to fluid milk substitutes for participants whose disability restricts their diet.
For detailed guidance on the meal modification requirements for disability reasons for children in the CACFP, refer to the CSDE's guides below.
- Adult Day Care Centers: Guide to Meal Modifications in CACFP Adult Day Care Centers (CSDE)
- Child Care Programs: Guide to Meal Modifications in CACFP Child Care Programs (CSDE)
Lactose-free/reduced Milk
Lactose-free and lactose-reduced milk are fluid milk and credit the same as regular milk in the milk component for the CACFP meal patterns. These types of milk are processed by adding lactase enzymes to reduce or eliminate the lactose (naturally occurring milk sugar) found in regular milk. participants 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 participants with lactose intolerance.
Lactose-free/reduced milk must meet the meal pattern requirements below for each age group:
- Age 1: Unflavored whole milk
- Ages 2-5: Unflavored low-fat or fat-free milk for ages 2-5
- Ages 6 and older and adult participants: Low-fat or fat-free milk, either unflavored or flavored
The USDA’s CACFP best practices recommend serving only unflavored milk.
Child care centers in public schools must also meet the additional state beverage requirements for milk under Connecticut General Statutes (C.G.S.) Section 10-221q.
Fluid Milk Substitutes that Meet USDA’s Nutrition Standards
Section 7 CFR 226.20(g)(3) of the CACFP regulations allows CACFP facilities to offer one or more fluid milk substitutes (plant-based beverages designed to replace cow's milk) that meet the USDA’s nutrition standards for fluid milk substitutes. Only certain brands of fluid milk substitutes meet these standards. Child care centers in public schools must also meet the additional state beverage requirements for nondairy milk substitutes under C.G.S. Section 10-221q.
Identifying Acceptable Fluid Milk Substitute Products
Before purchasing, CACFP facilities must ensure that fluid milk substitutes comply with the USDA’s nutrition standards for fluid milk substitutes. Commercial products that meet the USDA’s nutrition standards for fluid milk substitutes are identified in the CSDE's resources below.
- Adult Day Care Centers: Allowable Fluid Milk Substitutes for Non-disability Reasons for Adult Participants in the CACFP (CSDE)
- Child Care Programs: Allowable Fluid Milk Substitutes for Non-disability Reasons for Children in the CACFP
If a commercial product is not listed, CACFP facilities 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 CACFP.
Guidance
- Allowable Fluid Milk Substitutes
- Adult Day Care Centers: Allowable Fluid Milk Substitutes for Non-disability Reasons for Adult Participants in the CACFP (CSDE)
- Child Care Programs: Allowable Fluid Milk Substitutes for Non-disability Reasons for Children in the CACFP
- Identifying Products that Meet the USDA’s Nutrition Standards for Fluid Milk Substitutes in the CACFP (CSDE)
- CACFP regulations 7 CFR 226.20(g)(3): Fluid milk substitutes for non-disability reasons
- USDA Memo CACFP 01-2025: Nutrition Requirements for Fluid Milk and Substitutions in the CACFP, Questions and Answers
- Lactose Intolerance Facts (Undeniably Dairy)