1. The product includes the following FDA-approved whole grain health claim on its packaging: “Diets rich in whole grain foods and other plant foods and low in total fat, saturated fat, and cholesterol may reduce the risk of heart disease and some cancers” (FDA, 2008).

2. Product ingredient listing lists whole grain first, specifically:

   1. Nonmixed dishes (e.g., breads, cereals): Whole grains must be the primary ingredient by weight.

   2. Mixed dishes (e.g., pizza, corn dogs): Whole grains must be the primary grain ingredient by weight (a whole grain is the first grain ingredient in the list).

Whole grain ingredients are those specified in the HealthierUS School Challenge Whole Grain Resource guide (USDA/FNS, 2009) and include whole wheat flour, rye flour, brown rice, bulgur, hulled and dehulled barley, quinoa, oatmeal, and popcorn, among others. (Popcorn is not to be served to young children because of its choking hazard.)

For foods prepared by the CACFP provider, the recipe is used as the basis for a calculation to determine whether the total weight of whole grain ingredients exceeds the total weight of non-whole grain ingredients. Detailed instructions for this method appear in the HealthierUS School Challenge Whole Grains Resource guide (USDA/FNS, 2009).

Breakfast cereals

Ready-to-eat cereals and hot cereals (instant-, quick-, and regular-cooking forms), whether whole grain-rich or enriched [must conform to FDA standard of identity], must contain less than or equal to 21.2 g sucrose and other sugars per 100 g dry cereal (less than or equal to 6 g per dry oz of cereal, as specified in WIC Food Packages [IOM, 2006]).