Smart Snacks: Is Your Fundraiser, Vending Machine, or School Store USDA Compliant?

Beginning July 1, 2014 schools participating in the National School Lunch and Breakfast Program (that’s most schools) must ensure all foods sold to kids during the school day (called “Smart Snacks”) meet U.S. Department of Agriculture (USDA) nutrition guidelines. But what does it all mean?  Which foods are considered a “smart snack”? And how do I know if my PTA’s fundraiser is compliant?  We get it – it can be confusing! But we’re hoping to clear up some confusion here and get you the resources you need to be successful. If you don’t see an answer here, feel free to ask a question in the comments.

And stay tuned for additional resources to help make sure your PTA is ready to help support healthier foods in school!

What foods are you talking about when you say “Smart Snacks”? 

For the purpose of USDA guidelines, the foods that must meet minimum nutrition guidelines are those sold during the school day in school stores, vending machines, fundraisers, and a la carte lunch lines (think “grab and go” food items not part of a full meal). There are already updated USDA nutrition guidelines for the federally-subsidized school meal.

Foods sold outside of the school day (we’ll get to that in a second) – do not need to meet USDA guidelines.

Wait, did you say fundraisers?

Yes, fundraisers will need to meet the nutrition guidelines if they are sold to kids during the school day or immediately before and after school and are intended to be eaten on the spot.

What do you mean when you say “before and after” school?

The guidelines apply to any food sold

  • on school grounds before the school day begins
  • during the school day; and
  • 30 minutes after the traditional school day ends (think unhealthy fundraisers or unhealthy vending machines as soon as the bell rings).

What about our fundraisers and foods sold on school grounds but not during school day?

The USDA guidelines do not apply to afterschool or weekend events like football games and musical performances, so long as they are not before school or 30 minutes after the traditional school day ends. Your school may have additional restrictions on what can be sold on school grounds, so it’s always important to check first. Additionally, many PTAs are adopting healthy fundraising and event practices. The USDA guidelines are scientifically-backed based on nutrition needs for students. Your PTA may want to use the guidelines as a healthy lifestyle resource for your PTA!

What do you mean when you say foods that are intended to be eaten “on the spot”?

The USDA guidelines are only intended to target “ready to eat foods”. If a student is selling a food product through a catalog-type sale where the food is not intended to be eaten by the student at school, it wouldn’t need to meet USDA guidelines. But your local school may have additional restrictions.

But I heard there can be some fundraisers during the school day that don’t meet the guidelines?

Yes, there is flexibility for states to provide exemptions for infrequent school-approved fundraisers that do not meet the nutrition guidelines. Your administrative office may know this number, but you can also check the National Association of State Board of Education (NASBE) database for “fundraising exemptions” under your state. If your state has not determined the number of exemptions allowable, it is automatically zero, meaning that no exemptions are allowed for fundraisers that do not meet nutrition guidelines. 

What about birthday celebrations and food our PTA gives to kids?

While PTA supports healthy food offerings throughout the day, USDA guidelines only apply to foods sold to kids during the school day. So if a parent or other group is providing food free of charge, they do not need to comply with USDA guidelines. Keep in mind that state and local rules apply – and your school may have stronger restrictions on these items.

How do I know if what we’re selling meets the guidelines?

Good news! There is a simple way to check this using this tool from the Alliance for a Healthier Generation. Just enter what kind of product you’re selling (for the purpose of vending machines, school stores or fundraisers, it’s generally going to be a “snack”) and answer a few simple questions. The tool will let you know if your product is compliant. Just make sure to have the nutrition label handy!

Note: State and local regulations can differ and may be stronger. This is only related to USDA guidelines, which are designed to be minimum guidelines that schools must meet. However, schools are allowed to go beyond these guidelines. You should check with your school about additional guidelines or restrictions to vending machines, school stores and fundraisers.  It may also be part of your school’s Local Wellness Policy.

Have a question we didn’t answer? Please ask below and we’ll do our best to answer!

Excited about these changes and want to become more involved? Consider becoming at PTA Champion for Smart School Foods here!

Could your state PTA or council benefit from an in-person training? Shoot us an email at






  1. Jayne says:

    Thank you for the information. Would this also extend to schools selling ice-cream as an extra lunch option every day and using the money raised to benefit the school? Where can I read more about this?

    • Mollie Van Lieu says:

      Hi Jayne,

      Thanks for the question. Yes – these guidelines apply to all foods sold to kids during the school day so the ice cream you reference would need to meet the nutrition guidelines or could not be sold. Your school food service folks in your school should have received formal notice and information from your state around the guidelines. Not certain which state you’re in – but your state department of education may have information on their site as well. Here’s more information from the USDA:, but if you don’t find what you need – please shoot us an email at


  2. Linda says:

    So, who is responsible for monitoring the PTA to ensure they are compliant with the smart snack rule? What are the consequences if the PTA snacks do not comply?

    • Mollie Van Lieu says:

      Hi Linda,

      This is a great question and doesn’t have a simple answer. Sorry! All schools are different in the way they approach food offerings/fundraisers so there may already be policies and procedures in place at school before any type of food or fundraiser can be sold. Some states and schools have stronger guidelines in place than the Smart Snacks rule so it’s first important to know what the local policy is before addressing compliancy with Smart Snacks.

      That being said, PTAs should ideally be self-monitoring themselves using the calculator referenced in this post if they are not able to determine whether the foods meet the nutrition guidelines. In terms of who ultimately is responsible for monitoring, this is a local decision so the school district or principal is likely making the determination of the individual responsible for monitoring compliance. It may be the school’s principal, school food service personnel, or someone else within the school. This is an important question to ask the school district or school leader.

      Hope that helps. Let us know if you have additional questions.


  3. Michelle says:

    I disagree with this policy. Why the insistance of removing choices for kids? Why can’t a variety of snacks be available to the kids? They are already forced to eat a “healthful” yet often “tasteless” lunch from a menu full of dishes that don’t appeal to kids. Come on, aren’t there bigger, more important issues out there?

    • Stephanie Simms says:

      Hi Michelle,

      Thanks for your feedback. I am the School Nutrition Policy Fellow at National PTA. The USDA guidelines aren’t removing choices but instead making the choices healthier. With the growing rate of childhood obesity and some children being diagnosed with Type 2 Diabetes due to poor nutrition and lack of physical activity, PTA members passed a resolution in 2004 calling for the USDA to set these guidelines to strengthen the food served to kids at school. A variety of snacks sold in schools can be available to kids if they meet the nutrition standards. These standards, which are evidence-based, do not apply to foods that a child brings from home or foods that are given away during the school day- only to those being sold during the school day on school grounds. Please let us know if you have any additional questions.


  4. Scott Harben says:

    While I agree that smarter choices are better its not at school where the problem exists. The kids have two meals not at school, they can bring what ever they want and teaching them choices is not what is happening here. I have sold school snacks for over 8 years while my kids went to school. It is more about politics than it is anything else. If the USDA wants to regulate snacks then they should go to the manufacturers and teach the parents about choices. Ham stringing the PTA’s ability to raise funds hurts. We will lose over 25K in sales. Smaller packs help but the kids will just buy more. Its a band aid on the bigger problem that politicians dont want to tackle. Healthier choices yes but teach at home. One 1oz bag of chips at lunch isnt the problem, its what they get at home that is.

    • Jennifer says:

      I am with you on this Scott. At our middle school we sold lollipops at lunchtime – for a quarter! Now we are not permitted to do this anymore. I hardly think that a lollipop is going to be detrimental to a middle school kid who can just as easily go to the supermarket next door before and after school and buy all sorts of “monster drinks” and crap. We have a very low PTSA budget to begin with, and we will lose $2500 in revenue! There really needs to be some kind of compromise! I happen to be a health conscious mom who cooks dinner nearly every night and avoids most packaged, boxed, processed foods at home. The food at school is not very good, most kids don’t like it, it is processed, and it is this way because funding for decent food items is POOR. And the fact that PE/recess time is practically nonexistent doesn’t help. So I would agree with you that politics and big corporate lobbyists are the problem here.

    • Stephanie Simms says:

      Hi Scott & Jennifer,

      I am the School Nutrition Policy Fellow at National PTA and I appreciate your feedback on this issue. Research shows that many students receive as much as 50% of their calories from school meals- breakfast, lunch, and potentially snacks from school stores, a la carte lines, etc. By ensuring these meals are healthy, we know that children are receiving healthy meals while at school. We cannot control what the meals look like at home. The USDA is giving states the authority to decide if a state will allow fundraisers that are exempt from the Smart Snacks guidelines. If the state decides to allow exemptions, the states then determine how many exempted fundraisers will be allowed and for what length of time. Many manufacturers have changed their products to meet these guidelines as was evidenced at the School Nutrition Association Conference held in July. Also, fundraisers held off school grounds or those held outside of the school day (before school to 30 minutes after school releases) do not have to comply with Smart Snacks guidelines. National PTA is creating an implementation guide and a webpage- both expected to be available in early October- to assist PTAs in these changes. One aspect of the webpage will be a healthy fundraiser section. We want to help PTAs adapt to these changes without the loss of revenue. Please let me know how I can help you and your PTA with the Smart Snacks guidelines at

  5. Carol Becker says:

    Do you know how this impacts PTA giving students food as rewards? For example, we give our top Box Tops classes a reward party which may have ice cream or donuts; does that need to comply with the smart choice rules? Or an incentive when a child meets a certain pledge level for a fun run, we usually give candy or soda? Thanks for your help.

    • Stephanie Simms says:

      Hi Carol,

      I am the School Nutrition Policy Fellow at National PTA. Thank you for your question regarding giving food to students as rewards. Food that is given away as a reward and not sold do NOT have to comply with Smart Snacks guidelines. Only food that is SOLD to students during the school day on school grounds must comply with Smart Snacks. Please let me know if you have additional questions at

  6. Kathy Reyes says:

    I understand the concern for heathier eating but when I’m helping in the cafeteria or having to take lunch for my youngest grandson because he does not eat anything that is served, I see the majority of the children throwing their food away. This week I ate a pre-packed sandwich at lunch with my grandchild and it was by far the worst tuna (I think) sandwich I have ever tasted and the fruit (plum) was tastless. Both my grandsons have yet to eat in the cafetertia this year. I see more children taking their lunch this year than last year. I could understand replacing a healthier lunch a couple of days out of the week but to giving these children tastless food 5 days out of week was extreme. My worry is seeing the children throwing their food away. How health can that be.

    • Stephanie Simms says:

      Hi Kathy,

      I am the School Nutrition Policy Fellow at National PTA and I appreciate your feedback on this issue. Many schools are still adapting to the new nutrition guidelines that went into effect on July 1, 2014. The new guidelines were announced in 2010 and replace outdated standards for school meals to encourage higher fruit and vegetable consumption among other things. Many schools implemented these changes over the past few years and included the students in taste tests which helped determine what the children would or would not eat. Change can be difficult for everyone- including children. I encourage you and other active parents and grandparents in the school to keep an open dialogue with the school nutrition staff, administration, and teachers about gaining acceptance of the new standards. Please let me know if you have additional questions at

  7. Crystle Q. says:

    If our PTA would like to do a fundraiser with World’s Finest Cholcolate, the parents would pick up boxes and sell them around the neighborhood. The parents and students would not sell on school grounds. Would this fundraiser be allowed? Or would we have to sell out of a brochure.

    • Stephanie Simms says:

      Hi Crystle,

      I am the School Nutrition Policy Fellow at National PTA. I reached out to you via e-mail regarding this however, I will post the response here as well. Fundraisers held off school grounds such as the fundraiser you described, do NOT have to meet Smart Snacks guidelines. Only foods SOLD to students at school during the school day (before school to 30 minutes after school releases) have to meet the Smart Snacks guidelines. Please let me know if you have additional questions at

  8. Christy Knight says:

    If we sold fruit, but gave a cookie with each fruit purchase, would that meet the letter of the law?

  9. Christy Taylor says:

    Can the Jr. Class sell bottled water and give a gift of a brownie with each purchase?

    • Stephanie Simms says:

      Hi Christy,

      I am the School Nutrition Policy Fellow at National PTA. Thanks for your question. As you can see this is not the first time I have received this question. Foods and beverages that are given away as “accompaniments” with foods and beverages that are sold MUST meet Smart Snacks guidelines. If you were offering brownies to everyone regardless of whether or not they bought bottled water then it would comply. If you have additional questions please let me know at

  10. Sally says:

    I teach nutrition education in elementary schools in Oregon. I work really hard to educate the kids on eating healthier, and a big part of that is limiting surgery beverages. It is very frustrating to have the PTA give 2 liter bottles of soda out (and candy) during their events. What kind of message does that send? There are plenty of healthier snacks that the kids would love, even cookies have grain in them!

    • Stephanie Simms says:

      Hi Sally,

      I am the School Nutrition Policy Fellow at National PTA. First, I would like to thank you for your commitment to health and wellness in schools! It seems as though your work through nutrition education in schools and PTA events held in schools could work together to improve the servings at events. Feel free to reach out to the PTA to share your ideas regarding what can be served at their events to support your work in the schools by providing healthier options. If there is anything else I can do for you please let me know at

      Stephanie Simms

  11. Ruben Bojorquez says:

    If a PTA is not being compliant with the Smart Snack Rule of selling non compliant food until 30 minutes after the school day ends, might this put at risk our ASB fundraising? If audited, I’ve heard the school’s ASB might be penalized, in terms of possibly shutting them down. Is this true?

  12. lance says:

    hi my question is that my son school Edwin Rhodes in Chino California has ongoing fundraising immediately after school selling ice cream, cotton candy, etc. that doesn’t sound to me they are following or trying to meet any nutinional policies the state inplimented, is that permitted? if not what are their consequences for doing things that are in compliance?

  13. lance says:

    Not in compliance rather*

  14. Delores Lyon says:

    Thanks for sharing this! It really is important to keep the snacks in vending machines and stuff like that healthy. People will be eating out of those machines no matter what is in there, so you might as well make sure that you have healthy options. Plus, it’s easier to make a good decision at the vending machine when there are a lot of healthier options.

  15. Whitney says:

    What about a PTA Parent Coffee Cart, selling coffee’s to ADULTS only on campus during school hours. All of this references selling to the kids— what about selling to the parents?

  16. celestine virgen says:

    Good piece . I Appreciate the info . Does anyone know where my assistant might be able to locate a fillable HUD-1 form to fill in ?

  17. Dustin says:

    Funny how there was never a problem until computers and video games became really advanced. This solution is a complete waste of tax paying dollars. Obama campaign started this non sense and while I am all for healthy choices I think it’s bad that the schools cannot govern themselves. Our freedoms will one day be completely gone and the government can take care of us all.

  18. Maria Leticia says:

    Are we allowed to sell compliant snacks after school if your in the Local Wellness Policy program. Do the times matter?

Speak Your Mind