By Reed Mangels, PhD, RD

The WIC (Women, Infants, Children) Program provides vouchers to purchase specific foods for low-income pregnant and post-partum people, infants, and children up to age 5. A number of changes have recently been made to the WIC program. One change is in the area of plant-based dairy alternatives.

The WIC Program is a federal grant program which is administered at the national level by the Food and Nutrition Service of the USDA and by 89 WIC state agencies (states, territories, Indian Tribal Organizations, and the District of Columbia). Each WIC state agency determines which eligible foods, including brand of foods and package sizes, will be allowed to be purchased with WIC vouchers in their state. Considerations for which foods to incorporate in each state’s list of approved products include product availability, price, and participant acceptance. It is important to note that WIC state agencies are required to authorize some foods and allowed to authorize other foods. For example, WIC state agencies are required to authorize legumes and peanut butter as substitutes for eggs and allowed to authorize tofu as a substitute for eggs.

In the WIC program, who gets milk and how much do they get?             

The Maximum Monthly Allowances of milk are:

• 12 quarts per month for children age 12 to 23 months,
• 14 quarts per month for children age 2 through 4 years,
• 16 quarts per month for those pregnant or partially or fully breastfeeding or up to 6 months postpartum.

Do the new changes allow plant-based options to replace dairy milk?

Yes. WIC state agencies now have the option (but are not required) to authorize plant-based milk alternatives, plant-based cheeses, and plant-based yogurts to replace dairy milk with some limitations.

• Plant-based milk alternatives that meet nutritional requirements may be substituted for dairy milk on a quart for quart basis up to the Maximum Monthly Allowance for milk. Thus, a child age 2 through 4 years could receive up to 14 quarts of a plant-based milk alternative.
• Tofu that meets nutritional requirements may be substituted for dairy milk at the rate of 1 pound of tofu per 1 quart of dairy milk up to the Maximum Monthly Allowance for milk.
• No more than 1 pound of plant-based cheese that meets nutritional requirements may be substituted for 3 quarts of dairy milk for children age 1 through 4 years, pregnant people, those who are partially or mostly breastfeeding up to one year postpartum, and postpartum people who are not breastfeeding or minimally breastfeeding up to 6 months postpartum. Up to 2 pounds of plant-based cheese that meets nutritional requirements may be substituted for 6 quarts of dairy milk for those fully breastfeeding up to 1 year postpartum.
• 1 quart of plant-based yogurt that meets nutritional requirements may be substituted for 1 quart of milk with a maximum of 2 quarts of yogurt that may be substituted for 2 quarts of milk.

What are the nutritional requirements for plant-based milk substitutions?

• Plant-based milk alternatives may be flavored or unflavored.
  • Must contain <10 grams of added sugar per cup
  • Must contain at least 276 mg of calcium, 8 grams of protein, 500 IU of vitamin A, 100 IU of vitamin D, 24 mg of magnesium, 222 mg of phosphorus, 349 mg of potassium, 0.44 mg of riboflavin, and 1.1 mcg of vitamin B12.
• Plant-based cheese
  • Must contain at least 250 mg of calcium per 1.5 ounces
  • Must contain at least 6.5 grams of protein per 1.5 ounces
  • Cannot be a plant-based curd cheese.
• Plant-based yogurt may be flavored or unflavored.
  • Must contain <16 grams of added sugar per cup
  • Must contain at least 250 mg of calcium, 6.5 grams of protein, and 106 IU of vitamin D per 8 ounces.
  • Cannot be a product sold with accompanying mix-in ingredients such as granola, candy pieces, honey, nuts, etc.
  • Cannot be drinkable yogurt.
• Tofu
  • Must contain at least 100 mg of calcium per 100 grams of tofu.
  • May not contain added fats or oils, sugars, or sodium.

Are there actually products that are commercially available that meet these nutritional requirements?

There are some commercially available plant-based milk alternatives and tofu that meet these nutritional requirements. Few, if any plant-based cheeses and yogurts that are currently available meet the requirements. The USDA’s thinking seems to be that more products will be developed that meet the requirements and that as these become available, WIC state agencies will be able to authorize their use without the need for future changes to WIC regulations.

Will medical documentation be needed to replace dairy milk with plant-based milk substitutes? Medical documentation generally cannot be required to provide a milk substitution option. According to the current regulations, WIC state agencies must provide milk substitutions to participant to “accommodate special dietary needs and cultural and personal preferences. (1)” In certain “medically fragile” WIC participants, medical documentation is required for plant-based alternatives to be used in place of dairy products.

When will these changes to the WIC program be implemented?

WIC state agencies may begin implementing the new regulations immediately and are required to implement most of the regulations within 24 months from the publication date of the regulations – by April 20, 2026. The vitamin D requirement for yogurt is required to be implemented by 36 months from the publication date – by April 2027.

In practical terms, does this mean someone receiving WIC benefits can get vouchers for oat milk or almond milk?

It depends. There may or may not be oat milks or almond milks that meet the nutritional requirements described earlier. States are allowed but not required to authorize plant milks including oat milk or almond milk that meet nutritional requirements as a replacement for dairy milk. In the past, only soymilk was allowed to be authorized. When we last checked, in 2020, all 50 states and the District of Columbia authorized approved brands of soymilk to substitute for dairy milk and almost 70% of states and the District of Columbia authorized certain brands of tofu to substitute for dairy milk. This suggests that WIC state agencies are trying to allow dairy alternatives. The new regulations state that options such as plant-based milk alternatives, plant-based cheeses, and plant-based yogurts “better accommodate special dietary needs as well as cultural and personal preferences while still providing critical nutrients (1).” They also recognize the potential cost of these products and state, “When deciding which types and brands of WIC foods to authorize, including when authorizing plant-based milk alternatives, WIC State agencies should consider factors such as package size, food prices, product availability across their jurisdiction, and program management costs along with participant preference and demand (1).” This suggests that participant demand for alternative products that meet nutritional requirements can help to influence state decisions as to which products to authorize.

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)

Reference

1. Food and Nutrition Service, USDA. Special Supplemental Nutrition Program for Women, Infants, and Children (WIC): Revisions in the WIC Food Packages. 89 FR 28488: 28488-28567. https://www.federalregister.gov/documents/2024/04/18/2024-07437/special-supplemental-nutrition-program-for-women-infants-and-children-wic-revisions-in-the-wic-food. April 18, 2024.