Special Diets in the Child and Adult Care Food Program

Milk Substitutes for Non-disability Reasons

The U.S. Department of Agriculture (USDA) allows CACFP facilities to offer one or fluid milk substitutes (nondairy beverages) for participants 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. CACFP facilities that choose to offer allowable fluid milk substitutes must make them available to all participants.

The guidance below does not apply to fluid milk substitutes for participants whose disability restricts their diet. For detailed guidance on the CACFP meal modification requirements for disability reasons, refer to the CSDE's guides below.

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 226.20(g)(3)). 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 children in child care centers that operate in public schools must meet the state beverage requirements for nondairy milk under Section 10-221q of the Connecticut General Statutes (C.G.S.) 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.  

Requesting Fluid Milk Substitutes

Fluid milk substitutes require a written request that identifies the reason for the milk substitute. These requests may be submitted by child's parent/guardian or the adult participant or their caregiver, a state licensed healthcare professional, or a registered dietitian These written requests must be maintained on file with the student’s medical records.

Identifying Acceptable Fluid Milk Substitute Products

Before purchasing any type of commercial nondairy milk substitute, CACFP facilities must ensure that the product complies 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.

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.  

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 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 required fat content and flavored milk restrictions for each CACFP meal pattern. For child care programs that operate in public schools, these types of milk must also meet the additional state beverage requirements for nondairy milk under C.G.S. Section 10-221q. For more information, refer to Milk Substitutes for Non-disability Reasons in the "Milk" section of the CSDE's Crediting Foods in the Child and Adult Care Food Program webpage.

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

Guidance