Food and
Nutrition
Service
FNS-245
The Child Nutrition
Labeling Program:
An Overview
Dep ository
PROPtRT/ OF nrc:
IIRo,,o•;
MAY 28 n~.J
UnJVP.f'~i!Y f Norti1 ~;~li ol1; 1 ~
at Gre~n bom
Prepared by
Nutrition and Technical Services Division
Food and Nutrition Service
The following persons had major responsibility for this
publication:
Cheryl Wade
Christine Clay
Kathy Molino
Acknowledgment and thanks to the following persons who helped
prepare this publication:
Linda Singletary
Margie Livingston
Mary Daniels
Joyce Hawkins
April 1984
Contents
Introduction. . • • • . • • . • • . . • . . • • . • • . • • • • . • • • • • . • • . . • . . • • • . • . • 1
Background. . . • . • • • • • • • • • . • • . • . . . • • • • . • . . • • • • . . • • . • • • . • . • • • • 1
Eligibility Criteria for a Product with a CN
Label Statement..... . . . . • • . . • . • . . . . . • . . . . . . . . . . . . . . . . . . . • • 2
Eligible Products •••••••••••••••••••••••••••••••••••••••• 2
Product Contribution ••••.•••••••••••••••••••••••••••••••• 2
Federal Inspection ••••••••••••••••••••••••••••••••••••••• 2
Food Buying Guide•••••••••••••••••••••••••••••••••••••••• 3
Product Samples. . • • • • . • • • • • • • • • • • • • • • • • • • . • • • • • • • • • • • • • • • 3
How To Identify a CN Label ••••••••••••••••••••••••••••••••• 3
Label Statement •••••••••••••••••••••••••••••••••••••••••• 4
Penalty for Misuse of CN Logo •••••••••••••••••••••••••••••• 5
Advantages of Using CN-Labeled Products•••••••••••••••••••• 6
Warranty ••••.•••••••••••••.. ••.•.••.•••••••.•••.•••••. •. • 6
Meal Pattern Contribution•••••••••••••••••••••••••••••••• 6
What A CN Label Statement Is Not ••••••••••••••••••••••••••• 7
Basis for Crediting Meat, Poultry, and
Seafood Products ••••••••••••••••••••••••••• . . . . . . . . . . . . . . . 7
Label Applications and Review Procedures ••••••••••••••••••• 9
What to Submit ••••••••••••••••••••••••••••••••••.•••••••• 9
How to Submit. • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • 9
References ....•.•••••••••••.•.••.••.••.•.••••••..•..••••• 11
Introduction
The Child Nutrition (CN) Labeling Program is a voluntary
Federal labeling program run by the u.s. Department of
Agriculture (USDA). This program is responsible for
reviewing a product formulation to determine the
contribution that a single serving of that product makes
toward the child nutrition meal pattern requirements. The
meal pattern requirements specify the foods and the minimum
amounts that must be served in institutions participating in
the child nutrition programs.
This publication establishes policies and procedures for the
CN Labeling Program. These procedures supersede all other
instructions, written or oral, that the Food and Nutrition
Service (FNS) of USDA has provided. The guidance material
in this publication has been prepared for food
manufacturers, food service directors, State agencies, and
Federal regional offices.
The procedures in this manual apply to the following:
• Food products that contribute significantly to the meat/
meat alternate component of the meal pattern and are
served in main dishes. Meat/meat alternates include lean
meat, poultry, fish, cheese/cheese alternates, eggs,
cooked dry beans and peas, peanut butter, vegetable
protein products, protein fortified macaroni, or any
combination of these.
• Juice drinks and juice drink products that contain a
minimum of 50 percent full-strength juice.
The products listed above must be inspected by one of the
following Federal agencies:
Food Safety and Inspection Service (FSIS) of USDA
Agricultural Marketing Service (AMS) of USDA
National Marine Fisheries Services (NMFS) of the u.s.
Department of Commerce (USDC)
Background
During the 1970's, advances in food technology and marketing
increased the availability and use of commercially prepared
products such as beef patties and combination items
1
Eligible Products
Product
Contribution
Federal Inspection
2
(burritos, pizzas, etc.) in the child nutrition programs.
These products posed a problem for food service directors.
It was difficult at the point of sale to determine their
actual contribution toward meal pattern requirements and to
assure compliance with Federal regulations for serving
specific amounts of foods. This fact, coupled with the
anticipation of increased sales of these products to child
nutrition programs, prompted FNS to form an evaluation
committee to determine a means for properly evaluating the
contribution of these kinds of products toward the meal
pattern requirements. The committee, composed of FNS and
USDA's FSIS staff, worked together to establish and
implement a program to review and monitor such products.
Eligibility Criteria for a Product with a CN Label Statement
The CN Labeling Program is limited to juice drinks, juice
drink products, and products that contain food items which
contribute to the meat/meat alternate component of the meal
pattern and are part of the main dish. The meat/meat
alternate products may also contribute to the bread/bread
alternate and/or vegetable/fruit component of the meal
pattern. The chart below indicates a product's minimum
contribution toward the meal pattern requirements.
Mi.n:i.mJm Contribution Increnent
Product 1bward Meal Pattern EXpression
neat, poultry, o. so oz equivalent 0.25 oz
seafood, nOillleat products neat/neat alternate
juice drinks 2 oz (1/ 4 cup) single-juice
drink products stre~h juice
neat/neat alternate 1/4 serving 1/4 serving
with bread/bread bread/bread alternate
alternate contribution
neat/neat alternate 1/8 cup vegetable/fruit 1/8 wp
with vegetable/fruit
contribution
All CN-labeled products must be produced under an
appropriate USDA or USDC Federal inspection program to
ensure that the label statement accurately reflects the
amount of each ingredient used in the product. This will
help protect local food service directors from exaggerated
claims and will ensure that manufacturers with CN-labeled
products are competing for sales on a common basis.
Food Buying Guide
Product Samples
•
Yield data from the Food Buying Guide for Child Nutrition
Programs (Food Buying Guide), Program Aid Number 1331, 1984,
is used for calculating a CN-labeled product's contribution
toward meal pattern requirements. Using yields from the
Food Buying Guide will help ensure that various meat/meat
alternate items, regardless of cooking methods used or the
addition of other ingredients, will be nutritionally
equivalent.
The Department continues to-review and study yield data for
meat/meat alternates and other food items served in the
child nutrition programs, and, when warranted, considers
additions and changes in the Food Buying Guide.
FNS may request a sample of the product as part of the
review process. If a sample is requested, final label
approval may be delayed until the sample is received and
reviewed. Label applications must be for products that have
been made and tested in a pilot plant or on an assembly
line •
How to Identify a CN Label
A CN label must have the following information printed on
the principal display panel of the label:
• CN label statement
• Product name
• Ingredient listing in descending order of predominance by
weight for all ingredients
• Establishment number (meat, poultry, and seafood items
only)
• Manufacturer's or distributor's name and address
• Inspection legend for the appropriate inspection (see
below)
Rei Meat Proiucts Poultry Proiucts
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DEPARTMENT OF
AGRICULTURE
P-42
3
Label Statement
4
N:mneat Products
(eggs, creese, ream, and peanut butter)
Inspected by tre
u.s. ~part:Jient of Agriculture
in Accordance with
Fm Requiremants
The CN label statement must be an integral part of the
product label and must include the following information:
1. The CN logo which is a distinct border around the CN
statement.
2. A six-digit product identification number assigned by FNS
which will appear in the upper right-hand corner of the
CN label statement.
3. The statement of the product's contribution toward meal
pattern requirements for the child nutrition programs.
This identifies the contribution of a specific portion of
a meat/meat alternate product toward the meat/meat
alternate, bread/bread alternate, and/or vegetable/fruit
component of the meal pattern requirements. It also
identifies the contribution that juice drinks and juice
drink products make toward the vegetable/fruit component
of the meal pattern requirements.
4. A statement specifying that the use of the logo and CN
label statement is authorized by FNS.
5. The month and year the label was approved in final by
FNS.
The samples printed below show the general location for each
component of the CN label statement.
Meat Product
~--------------------VrN1·--------------~------~-------,
oooooo 2
This 3.00 oz serving of raw beef pattie provides
when cooked 2.00 oz equivalent meat/meat alternate
~ for Child Nutrition Meal Pattern Requirements. 3 CN
(Use of this logo and statement authorized by the
Food and Nutrition Service,4 USDA 05-84.) 5
f'N
Juice Drink Product
~------------------~N1·--------------------~------~
oooooo 2
QUALIFIES FOR SCHOOL LUNCH PROGRAMS when
reconstituted according to label directions above.
1/2 cup (4 fl oz) of this orange juice drink will
CN contain the equivalent of 1/4 cup (2 fl oz) single
strength orange juice for the Child Nutrition Meal
Pattern Requirements. 3 (Use of this logo and
statement authorized by the Food and Nutrition
Service,4 USDA 05-84.)~
rN
Penalty for Misuse of CN Logo
c~
FNS has developed a logo to protect the integrity of the CN
Labeling Program, to avoid possible abuse, and to make the
CN label statement easy to identify. The logo is a
distinctive border design that surrounds the label
statement. Companies will not be allowed to use the logo or
statement without permission from FNS.
If a company uses the CN logo inappropriately, FNS will
notify it and give it 30 days to discontinue use of the
logo. If the company continues to use the label, its name
5
6
Warranty
Meal Pattern
Contribution
will be put on a list that will be sent quarterly to all FNS
Nutrition and Technical Services regional offices. Regional
offices will then circulate the list to the States. In
addition, other actions may be taken.
Advantages of Using CN-Labeled Products
All CN-labeled products that are Federally approved and have
a CN logo carry a warranty. If a food service authority
participating in the child nutrition programs purchases such
a product and uses it according to the directions, the
institution will not have an audit claim filed against it,
for that CN-labeled product, for noncompliance with the meal
pattern requirements. If a State or Federal auditor finds
that a CN-labeled product does not actually meet meal
pattern requirements claimed on the label, the auditor will
report this finding to the FNS national office. FNS will
prepare a report on the findings and send it to the
appropriate division of FSIS, AMS, NMFS, Food and Drug
Administration (FDA), or the Department of Justice for
action against the company. That office will then be
responsible for auditing production records to determine
whether the product, as produced, met the conditions of the
CN label statement before it left the plant. If the audit
shows that the product, as produced, does not meet the label
statement, any or all of the following actions may be
taken:
• The company's CN label may be revoked for a specific
period of time;
• The appropriate agency may pursue a misbranding or
mislabeling action against the company producing the
product;
• The company's name will be circulated to FNS regional
offices; or
• FNS will require the food service program involved to
notify the State office of the labeling violation.
The CN label statement tells how the labeled product can be
"credited" or "counted" towards meeting the meal pattern
requirements of the child nutrition programs.
•
•
What a C N Label Statement Is Not
A CN label statement does not do the following:
• Assure that a product is "good for children."
• Assure that a product is "ac~eptable" to children.
• Suggest that products without CN statements are inferior.
Manufacturers must not use the CN label statement to promote
a product's nutritional value or acceptability.
The CN label statement should not be confused with fact
sheets and letters of cer-tification. Letters of
certification are statements provided by a company official
that tell a product's contribution towards the meal pattern
requirements. These may contain pertinent information but
are not recognized by auditors as official documentation of
the product's contribution towards meal pattern
requirements. These letters and fact sheets have not been
reviewed by FNS and may or may not be accurate. Label
statements approved at the State level for State-inspected
plants also are not reviewed by FNS. State approved labels
and fact sheets are not covered by the CN label warranty.
Basis for Crediting Meat, Poultry, and Seafood Products
Meat, poultry, and seafood products used in the Child
Nutrition Programs are credited on the raw basis using the
appropriate cooking yields listed in the Food Buying Guide.
This is done to provide equity in crediting different types
of products regardless of the cooking methods used or the
addition of binders or extenders. This in turn provides for
comparable nutritional value (e.g., protein content) of a
product when it is cooked by several different methods. For
example, suppose ground beef patties weighing 3 ounces are
cooked three different ways: (a) Pan fried, (b) oven
broiled, and (c) grilled. Their cooked weights are 2.20
ounces, 2.75 ounces, and 2.63 ounces, respectively. If
these patties were to be credited according to their cooked
weights, pattie (b) would receive more credit than pattie
(a) or (c) even though all the patties were prepared with
exactly the same amount of meat. The variation in cooked
weights is due to differences in fat and water losses with
only a minimal loss of nutrients.
7
8
Let's take this example one step further. Assume that 3-
ounce beef patties are cooked by the same methods described
above, but these contain 28 percent hydrated soy protein
flour. The presence of the soy protein flour will decrease
the amount of fat and water lost during cooking; therefore,
the cooked weights of the beef-soy patties will be greater
than the cooked weights of the all-beef patties. The
nutritional value of the beef-soy patties, as served, is not
greater. Their higher weights reflect an increased
retention of fat and water only.
How to calculate the actual credit that these various
patties receive depends not on their cooked weight but on
their raw weight and appropriate cooking yield from the Food
Buying Guide. In order to provide equity in crediting ---meat/
meat alternate products, regardless of cooking methods,
FNS credits meat/meat alternate products on the raw basis
and uses the term "equivalent meat" for crediting.
As the above examples imply, the basic concept underlying
product crediting in the Child Nutrition Program is
"nutrient concentration"--the amount of nutrients by weight
in a finished cooked product. When a product is cooked, fat
and water are lost while the essential nutrients are
retained in a slightly more concentrated form. The
following table shows the difference in nutrient
concentration of a 4-ounce raw pattie and a pattie that
weighs 4 ounces after cooking.
Comparison of Nutrient Concentration in a 4-0unce Raw Ground
Beef Pattie and a Pattie Weighing 4 Ounces After Cooking
Raw Groond Beef O:>oked Groond Beef Difference reaoam
l'btrient Pattie (4 oz)* Pattie (4 oz)** Raw ani Cooked Patties
Procein 20.30 g 27.45 g 26.10% rore
Iron 3.05 mg 3.62 mg 16.00% rore
'lbi.anin Oo09 mg I 0.10 mg 10. 00% rore
Riboflavin 0.18 mg 0.24 mg 25.00% rore
Niacin 4.87 mg 6.12 mg 20. 50% rore
Water 15.05 % 13.55 % 10.00% less
Fat 24.05 % 23.02 g 4.30% less
*Ground Beef (no more than 24 percent fat)
**Cooking Methods: oven broiled, pan broiled, or sauteed
Data derived from Agriculture Handbook No. 456, Nutritive
Value of American Foods, 1975.
•
What to Submit
How to Submit
Throughout this explanation, protein has been used as an
indicator of nutritional value. While protein is one of the
primary nutrients supplied by meat/meat alternate products,
there are two other important nutrients, thiamin and iron,
which are supplied through these products. A 1981 USDA
study, the National Evaluation of School Nutrition Programs,
showed that thiamin and iron frequently fail to meet the
nutritional goal of the National School Lunch Program
(NSLP). The goal of the NSLP is for school lunches to meet
an average of one-third of the Recommended Dietary
Allowances for certain key nutrients. Therefore, it is
important to remember that the meat/meat alternate products
that are served daily provide different quantities of
nutrients, in addition to protein, which contribute
significantly to the overall nutritional content of the
school lunch.
Label Applications and Review Procedures
Application and review procedures vary depending on the type
of product. FNS will issue detailed application procedures
as separate manuals for various types of products for
obtaining CN label approval. Manufacturers should request
the manual that pertains to their specific needs. The
following procedural manuals will be available:
Child Nutrition Labeling for Meat and Poultry Products.
Child Nutrition Labeling for Seafood Products.
Child Nutrition Labeling for Nonmeat Products.
Child Nutrition Labeling for Juice Drinks and Juice
Products.
Each manual will contain procedures, sample label
submittals, and supplementary information.
Drink
All CN label applications for meat, poultry, and nonmeat
products! (except nonmeat products produced in a seafood
plant) must be submitted to:
lNonmeat products may contain cheese, eggs, dry beans or
peas, peanut butter, cheese alternates, protein fortified
macaroni, or any combination of these.
9
10
CN Label Reviewer
u.s. Department of Agriculture
Food and Nutrition Service
Nutrition and Technical Services Division
3101 Park Center Drive, Room 602
Alexandria, Virginia 22302
(703) 756-3556
Once FNS reviews and approves these labels, it forwards them
to the appropriate agency for review where appropriate.
All CN label applications for seafood products or nonmeat
products produced in USDC plants must be submitted to:
Approving Officer
National Seafood Quality and Inspection
Laboratory
P.O. Drawer 1207
Pascagoula, Mississippi 39567
Once the approving officer reviews the applications, he or
she forwards the applications to FNS for concurrence. FNS
then returns the applications to the approving officer.
All CN label applications for JU1ce drinks and juice drink
products must be submitted to:
CN Label Reviewer
U.S. Department of Agriculture
Food and Nutrition Service
Nutrition and Technical Services Division
3101 Park Center Drive, Room 602
Alexandria, Virginia 22302
(703) 756-3556
Once FNS reviews and approves the applications, it forwards
them to AMS for concurrence. If AMS concurs, it will notify
the appropriate AMS regional office and area field office.
FNS notifies the manufacturers that the label has been given
final approval. If either the formula or the label is not
given final approval, FNS will send the application
materials back to the manufacturer for revision.
References
The majority of CN-labeled products are used in the National
School Lunch Program. Manufacturers need to understand the
regulations for this program. A reprint from the Federal
Register of the NSLP regulat1ons is available from the
Nutrition and Technical Services Division, FNS.
Manufacturers need to understand the school lunch meal
pattern requirements in order to successfully complete an
application for a CN label. A chart summarizing the school
lunch meal patterns is available from the Nutrition and
Technical Services Division, FNS.
This is an equal opportunity program. If you believe you have
been discriminated against because of race, color, national
or1g1n, sex, age, or handicap, write immediately to the
Secretary of Agriculture, Washingon, DC 20250.
11