Feeding Infants in the CACFP: Updated Guidance

• Updates product-based sugar limits for breakfast cereals and yogurt from total sugars to added sugars – effective October 1, 2025; 
• Includes updated information on tofu crediting; 
• Includes one new question and answer stating that Tempeh may credit toward the meats and meat alternates component in the infant meal pattern. 

This memorandum supersedes CACFP 11-2023, Feeding Infants and Meal Pattern Requirements in the Child and Adult Care Food Program, Questions and Answers (Revised September 2023). 

 

Why It Matters 

Ensuring that infants receive the proper nutrients and foods is crucial for their development. It’s important that child care provides understand the CACFP infant meal pattern requirement to help support healthy growth.   

 

Updated Guidance 

Creditable Infant Formulas 

Formulas classified as Exempt Infant Formulas by the FDA may be served as a part of a reimbursable meal if the substitution is due to a disability and is supported by a medical statement signed by a State licensed healthcare professional or a registered dietitian. Prior to the April 2024 final rule, institutions and facilities could only accept medical statements signed by licensed physicians or licensed healthcare professionals authorized by State law to write medical prescriptions.  

Medical statements must be submitted and kept on file in a secure location by the institution or facility. For more information on providing meal accommodations for participants with disabilities, see CACFP 14-2017, SFSP 10-2017 Modifications to Accommodate Disabilities in the Child and Adult Care Food Program and Summer Food Service Program, https://www.fns.usda.gov/cn/modifications-accommodate-disabilities-cacfp-and-sfsp. 

Solid Foods - Grains 

Grains are an important part of meals and snacks in the CACFP. To make sure infants get enough grains, required amounts of grain items are listed in the infant meal pattern as ounce equivalents (oz eq). Ounce equivalents approximate the amount of grain in a portion of food. Iron-fortified infant cereal is the only grain that may count towards a reimbursable breakfast, lunch, or supper in the CACFP infant meal pattern. Serving infant cereal in a bottle is not allowed. Neither the infant cereal nor the breast milk or formula in the bottle may be claimed for reimbursement when infant cereal is added to breast milk or formula in a bottle, unless it is supported by a signed medical statement. Institutions and facilities may serve bread/bread-like items, crackers, iron-fortified infant cereal, or ready-to-eat cereal as part of a reimbursable snack to infants that are developmentally ready to accept them. The ounce equivalent requirements vary for the different grain items. 

As a reminder, all ready-to-eat cereals served to infants must meet the same sugar limits as breakfast cereals served to children and adults in the CACFP. The April 2024 final rule updated the product-based sugar limits for breakfast cereals by replacing total sugar limits with added sugar limits. Through September 30, 2025, breakfast cereals must contain no more than 6 grams of total sugars per dry ounce. By October 1, 2025, breakfast cereals must contain no more than 6 grams of added sugars per dry ounce. However, with State agency approval, institutions and facilities may choose to implement the added sugars limits for breakfast cereals (including ready-to-eat cereals for infants) early. Ready-to-eat cereals must also be whole grain-rich, enriched, or fortified in order to be creditable in the CACFP. For more information on the breakfast cereal sugar limits and creditable grains, please see memorandum CACFP 05-2025, Grain Requirements in the Child and Adult Care Food Program; Questions and Answers, December 19, 2024, https://www.fns.usda.gov/cacfp/grain requirements-cacfp-questions-and-answers. 

In an effort to accommodate cultural food preferences and to address product availability and cost concerns in outlying areas, eligible Institutions and facilities have the flexibility to serve vegetables to meet the grains requirement. Effective July 1, 2024, these eligible Program operators include institutions and facilities in American Samoa, Guam, Hawaii, Puerto Rico, and the U.S. Virgin Islands, and institutions or facilities in any State that serve primarily American Indian or Alaska Native participants. USDA recognizes the concern that allowing this flexibility for infants could result in a reduced consumption of critical nutrients, such as iron. However, the infant meal pattern allows a variety of foods to meet the required meal components for meals and snacks, and only currently requires a grain item at snack when an infant is developmentally ready to accept those foods. Allowing institutions and facilities to serve culturally responsive meals and snacks can improve meal consumption and strengthen relationships between providers, families, and participants. Any vegetable, including vegetables such as breadfruit, prairie turnips, plantains, sweet potatoes, and yams, may be served to meet the grains requirement in eligible programs. Additional detail on this flexibility can be found in CACFP 03, 2025, Substituting Vegetables for Grains in American Samoa, Guam, Hawaii, Puerto Rico, the U.S. Virgin Islands, and Tribal Communities, October 30, 2024, https://www.fns.usda.gov/cn/substituting-vegetables-grains-hawaii-territories-tribal. 

Solid Foods – Meat and Meat Alternates 

Meats and meat alternates are good sources of protein and provide essential nutrients, such as iron and zinc for growing infants. FNS acknowledges that yogurt is often served to infants as they are developmentally ready. In recognition of this, the infant meal pattern allows yogurt, including soy yogurt, as a meat alternate for older infants who are developmentally ready to accept yogurt. The April 2024 final rule updated the product-based sugars limits for yogurts by replacing total sugars limits with added sugars limits. Through September 30, 2025, yogurts must contain no more than 23 grams of total sugars per 6 ounces. By October 1, 2025, yogurt must contain no more than 12 grams of added sugars per 6 ounces. However, with State agency approval, Institutions and facilities may choose to implement the added sugars limits for yogurt early. 

In addition, while cheese food and cheese spread are creditable for children one year and older, the infant meal pattern does not allow cheese food or cheese spread to credit as a meat alternate. This is due to these products’ higher sodium content, and the AAP and Dietary Guidelines recommend caregivers choose products lower in sodium. Natural or processed cheese is creditable while cheese product is not creditable in the CACFP for infants or any other age group. 

Tofu may credit as a meat alternate in the CACFP infant meal pattern. Tofu must be commercially prepared and meet the following definition, established in 7 CFR 226.2: “a soybean-derived food...basic ingredients [in tofu] are whole soybeans, one or more food grade coagulants (typically a salt or acid), and water.” Noncommercial tofu and soy products are not creditable. The minimum serving amount of tofu for infants 6 through 11 months is 0-4 tablespoons (¼ cup), or 2.2ozw, containing at least 5 grams of protein. For more information refer to CACFP 02-2024, Crediting Tofu and Soy Products in the School Meals Programs, Child and Adult Care Food Program, and Summer Food Service Program, November 29, 2023, https://www.fns.usda.gov/cn/crediting-tofu-and-soy-yogurt-products-school-meal programs-and-cacfp. 

 

New Question and Answer 

Is tempeh creditable in the infant meal pattern? 

Tempeh may credit toward the meats and meat alternates component in the infant meal pattern. Institutions and facilities may credit 1 ounce of tempeh as 1 ounce equivalent of meat alternate. In the CACFP infant meal pattern, the minimum serving amount of tempeh is 0-4 tablespoons (1/4 cup). This method of crediting applies to tempeh with ingredients limited to soybeans (or other legumes), water, tempeh culture and for some varieties, vinegar, seasonings, and herbs. The firm texture of tempeh may pose a choking hazard for infants and toddlers; therefore, operators should cook tempeh to soften the texture, then cut into an age-appropriate size and shape. 

For tempeh that includes other ingredients that are creditable for infants, those ingredients may also credit toward other requirements of the infant meal pattern. For example, vegetables included in tempeh may count toward the vegetable requirement if documentation shows that the vegetable is present in minimum creditable quantities (0-2 tablespoons). Varieties of tempeh that include non-creditable foods in the infant meal pattern as ingredients, such as brown rice, sunflower seeds, sesame seeds, and/or flax seed, may be served to an infant, however, only the ingredients that are creditable in the infant meal pattern, such as vegetables, will count towards the reimbursable meal or snack. Documentation of a Child Nutrition (CN) Label or Product Formulation Statement (PFS) must show how much tempeh and any other creditable foods these products contain. 

 

Updated Questions and Answers 

If a State licensed healthcare professional or registered dietitian prescribes whole cow’s milk or a fluid milk substitute as an alternative for breast milk or infant formula for an infant (birth through 11 months of age), is the meal reimbursable? 

For children younger than 12 months of age, cow’s milk or a fluid milk substitute may be served as an alternative for breast milk and/or infant formula, and be part of a reimbursable meal, only if the alternative is supported by a medical statement signed by a State licensed healthcare professional or registered dietitian. A State licensed healthcare professional means an individual who is authorized to write medical prescriptions under State law. This may include, but is not limited to, a licensed physician, nurse practitioner, or physician’s assistant, depending on State law. By October 1, 2025, Institutions and facilities must also accept a medical statement signed by a registered dietitian. The statement should include a description of the infant’s physical or mental impairment and an explanation of how to modify the meal or meal service to accommodate the infant’s disability. The statement must be submitted and kept on file in a secure location by the institution or facility. 

FNS recognizes that infants have unique dietary needs and decisions concerning diet during the first year of life are for the infant’s health care provider and parents or guardians to make together. In addition, FNS understands that a transition period is needed when infants are weaned from breast milk or infant formula to cow’s milk. Therefore, a one-month transition period is allowed for children 12 to 13 months of age. Please see question number 13 for more information. 

Are tofu and soy yogurt allowed in the infant meal pattern? 

Yes, tofu and soy yogurt may credit as a meat alternate in the infant meal pattern. The minimum serving amount of tofu for infants 6 through 11 months is 0-4 tablespoons (¼ cup), or 2.2ozw, containing at least 5 grams of protein. Tofu must be commercially prepared and meet the following definition, established in 7 CFR 226.2: “a soybean derived food...basic ingredients [in tofu] are whole soybeans, one or more food-grade coagulants (typically a salt or acid), and water.” Noncommercial tofu and soy products are not creditable. 

The serving size of soy yogurt is the same for dairy yogurt, 0-4 oz or ½ cup, for infants 6 through 11 months. Through September 30, 2025, yogurt must contain no more than 23 ounces of total sugars per 6 ounces. Effective October 1, 2025, all soy yogurt served to infants must contain no more than 12 grams of added sugars per 6 ounces. However, with State agency approval, Institutions and facilities may choose to implement the added sugars limits for yogurt early. For additional information, see CACFP 02-2024, Revised: Crediting Tofu and Soy Yogurt Products in the School Meals Programs, Child and Adult Care Food Program, and Summer Food Service Program, November 29, 2023, https://www.fns.usda.gov/cn/crediting-tofu-and-soy-yogurt-products-school-meal programs-and-cacfp. 

Is yogurt creditable in the infant meal pattern? 

Yes. Yogurt is an allowable meat alternate for infants consuming solid foods. Through September 30, 2025, yogurt must contain no more than 23 grams of total sugars per 6 ounces. Effective October 1, 2025, all yogurts served in the CACFP, including those served to infants, must contain no more than 12 grams of added sugars per 6 ounces. However, with State agency approval, Institutions and facilities may choose to implement the added sugars limits for yogurt early. Yogurt is a good source of protein, and the American Academy of Pediatrics recommends infants consume foods from all food groups to meet infants’ nutritional needs. 

Is there a sugar limit for ready-to-eat and infant cereals served to infants? 

Yes. Through September 30, 2025, ready-to-eat cereals must contain no more than 6 grams of total sugars per dry ounce. Effective October 1, 2025, all ready-to-eat cereals must contain no more than 6 grams of added sugars per dry ounce. However, with State agency approval, Institutions and facilities may choose to implement the added sugars limits for ready-to-eat cereals early. 

 

Read the full Guidance on Feeding Infants and Meal Pattern Requirements in the Child and Adult Care Food Program; Questions and Answers (CACFP 06-2025).