photo from USDA Food and Nutrition Service

By Reed Mangels, PhD, RD

The WIC (Women, Infants, Children) Program serves millions of low-income  pregnant and post-partum people, infants, and children up to age 5 in the United States.  In November 2022, the Food and Nutrition Service of the USDA, which administers the WIC program on the federal level, published their proposed revisions to the WIC program in the Federal Register.  Interested parties were asked to submit comments on the proposed revisions. The Vegetarian Resource Group submitted comments on the proposed revisions with an eye to the need for foods included in the program to be acceptable to vegans and other vegetarians. The final updated revisions were published in April 2024.

How did we do? Did the changes made to the WIC program agree with the comments that VRG made? In many cases, they did. Let’s take a look at VRG’s comments compared to the new regulations.

VRG commented: We support the increase in the fruit and vegetable benefit. We also support an increase in the variety of fruits and vegetables that are available for WIC recipients to choose from.

The new regulations: Permanently increase the fruit and vegetable benefit so that the dollar amount of vouchers to purchase fruits and vegetables increases up to 4-fold. Require that WIC State agencies allow fresh and at least one other form (canned, frozen, dried) of fruits and vegetables.

VRG commented: We support the addition of more non-dairy substitution options for dairy milk, such as plant-based cheese and plant-based yogurt, provided they meet nutrient requirements. We support the addition of plant milks in addition to soymilk, provided they meet nutrient requirements, as options to replace dairy milk. We support the removal of restrictions on the amount of dairy milk that can be substituted.

The new regulations: Plant-based yogurt and plant-based cheese that meets requirements set by USDA for protein and calcium can be used in place of the entire allowance of dairy  milk. Plant-based milk that meets nutrient requirements can be used in place of the entire allowance of dairy milk.

VRG commented: We are concerned that few brands of tofu are currently on the market which meet the proposed requirement that tofu contain a minimum of 200 mg of calcium per 100 grams of tofu. We were only able to find one brand of tofu which met this requirement. We propose a modification of this requirement to better reflect the calcium content of currently available calcium-set products.

The new regulations: Reduce the amount of calcium required to be in tofu to 100 milligrams of calcium per 100 grams of tofu.

VRG commented: In the interest of health of vegans, we propose that non-dairy milks, cheese, and yogurt be fortified with vitamin B12.

The new regulations: No requirement was established for vitamin B12 to be added to plant-based cheese or yogurt. Plant-based milks must contain at least 1.1 microgram of vitamin B12 per cup.

VRG commented: We urge that children be able to receive soy products without “consultation with the participant’s health care provider, if necessary as established by State agency policy.”

The new regulations: Medical documentation generally cannot be required to provide a milk substitution option.

VRG commented: We support the use of an added sugar limit in place of a total sugar limit for yogurt and soy-based milk. Since flavored soymilks are available which contain little or no added sugar, we support the continued inclusion of both flavored and unflavored soymilk provided requirements for added sugars are met.

The new regulations: Limit added sugar in plant-based yogurt and plant-based milk. These products may be flavored or unflavored provided the limits on added sugars are met.

VRG commented: We propose that vegan options be provided in place of infant meat for infants age 6-11 months.

The new regulations: Reduce the amount of infant meat provided through the WIC program but do not allow for a vegan replacement for infant meat. The USDA stated that they appreciated suggestions such as tofu and legumes to replace infant meat but wanted to do additional study and will consider these comments in the future.

VRG commented: We support the proposed expansion of whole grain options to include foods like quinoa, teff, wild rice, millet, corn meal (including blue), and whole wheat naan, which support wider personal and cultural food preferences and can accommodate wheat allergies.

The new regulations: Expand whole grain options to include quinoa, wild rice, millet, triticale, amaranth, kamut, sorghum, wheat berries, tortillas made with folic acid-fortified corn masa flour, cornmeal, teff, and buckwheat. Whole wheat pita, English muffins, bagels, and naan were also added as whole grain options. In addition, WIC State agencies are allowed to authorize other whole grain options that meet WIC standards.

VRG commented: We support the proposed change to require State agencies to authorize canned legumes in addition to dried legumes. We propose adding frozen unflavored dried legumes to the list of authorized foods.

The new regulations: Require that both dried and canned legumes be authorized.

VRG commented: We support the proposed change which requires authorization by State agencies of peanut butter and legumes as substitutes for eggs.

The new regulations: Require states to allow peanut butter and legumes to substitute for eggs.

We would like to see vitamin B12 fortification required for plant-based cheeses and plant-based yogurts that replace dairy milk and to see non-meat options for infants and to have plain frozen legumes allowed in addition to canned and dried legumes. Still, many of our (and others) suggestions were incorporated in the final regulations, making them more vegan-friendly. In addition, even for those who are not 100% vegan, the number of plant-based options has increased.

The USDA received 17,731 comments on the proposed changes to the WIC program. Of these, 15,863 were form letters. There were 1,795 unique comments, of which 993 were deemed substantive. USDA states that importance was given to the substance or content of comments, rather than the number of times a comment was submitted. This is something to keep in mind when submitting comments on proposed regulations–try to be original rather than simply copying and submitting a form letter.

To read more about the WIC program see: The Vegetarian Resource Group Sent in Testimony on the Proposed Revision in the WIC Food Package (2023)

USDA Proposes Updates to the WIC Program (2022)

WIC Programs Offer Foods For Vegans (2020)

WIC Farmers Market Program (2020)

Revisions to the WIC Food Package Make Sense (2014)