4. Primary School
In primary schools, almost all children stay in school at lunchtime, for school lunches or a packed lunch. All children in P1-3 are entitled to a free school lunch, and uptake of this, along with P4-7 uptake, means that 65% of primary school children are having school lunch regularly. Therefore school lunches can have a significant impact on establishing good eating habits and improving children’s diets.
The provision of breakfast clubs and tuck shops in primary schools varies across Scotland, with tuck shop services being less common than prior to the introduction of School Food Regulations in 2008. All breakfast clubs and afterschool clubs run on school premises offering food and drinks, including those provided by private operators, are required to meet the nutritional regulations.
The provision of school food in primary schools can be grouped into 4 sets of standards;
1. Nutrient Standards for primary school lunches
2. Food Standards for primary school lunches
3. Food Standards outwith primary school lunches
4. Food and Drink Standards across the school day (at lunch and outwith lunch)
Please note that the above standards are also applicable to food and drink served in school hostels.
4.1 Nutrient Standards for Primary School Lunches
Proposed changes to the nutrient standards for primary schools have been highlighted in bold in table 1 below.
As with the existing nutrient standards, the proposed nutrient standards have been based on 30% of the daily requirement.
There is a small drop in energy requirement from 557 kcals to 518 kcals. As a result, the values for total fat, saturated fat and total carbohydrate have decreased slightly as these values are based on % food energy.
With respect to the existing nutrient standard for sugar, expressed as non milk extrinsic sugar ( NMES), the value was set at 11% food energy in line with the evidence base at the time. In 2015 SACN replaced NMES with the term free sugars and reduced the recommendation to 5%.
The TWG propose that the nutrient standard for sugars in school meals is reduced from 11% NMES to 7.5% free sugars as a percentage of food energy. A reduction to 5% in a single step was considered unachievable in the school setting at this point in time. It was also set in the context that current dietary monitoring data indicates that average intake of NMES sugars in primary school children is around 14.8% of food energy  .
Please refer to annexe 1 for definitions of non milk extrinsic sugars, free sugars and total sugars.
The fibre value has increased slightly to reflect the updated SDG. The proposed fibre standard is reflected in AOAC methodology, which is the standard methodology used in product analysis and food labelling.
As the new values are an average across a wide age range, 5-11 years, the guidance to support the new regulations will need to ensure that caterers understand and are able to use their professional judgement to adjust portion sizes served depending on age and stage of development of the child.
For completeness, values for both AOAC and NSP fibre are included in the updated table 1 below.
Table 1 – Proposed updates to statutory nutrient standards for school lunches for pupils in primary schools.
||An average day’s primary
school lunch – Existing
|An average day’s primary
school lunch – Proposed
|Energy (calories/kilojoules)||557 kcals||518 kcals|
|2328 kJ||2165 kJ|
||Not more than 21.7 g||Not more than 20.1 g|
||Not more than 6.8 g||Not more than 6.3 g|
||Not less than 74.3 g||Not less than 69.1 g|
|Non Milk Extrinsic Sugars||Not more than 16.3 g||N/A|
| Free Sugars*
||N/A||Not more than 10.4 g|
| Fibre ( AOAC)
||N/A||Not less than 6.0 g|
|Fibre ( NSP)
||Not less than 4.5 g||Not less than 4.6 g|
||Not less than 8.5 g||Not less than 19.4 g|
||Not less than 3 mg||Not less than 3 mg|
||Not less than 165 mg||Not less than 165 mg|
||Not less than 150 µg||Not less than 150 µg|
||Not less than 9 mg||Not less than 9 mg|
||Not less than 45 µg||Not less than 45 µg|
||Not more than 745 mg (not
more than 686 mg by 2010)
|Not more than 686 mg|
||Not less than 2.1 mg||Not less than 2.1 mg|
* Calculated as NMES minus sugars from dried, stewed or canned fruit.
4.2 Nutritional Analysis of School Lunches
The current nutritional analysis software packages used to analyse school lunch menus do so across the full school week. Whilst it was always the intention for variation in menu design to allow higher energy and nutrient values on some days and lower on others that balance across the week, evidence from inspection of school food suggests that there are incidences where there are lunches offered which are out with acceptable tolerances of energy and other nutrients. The current software is not sophisticated enough to demonstrate these variances to allow menu planners to take this into account.
The variation and extremes in energy provision need to be reduced. Therefore the new proposal for nutritional analysis aims to ensure that all school lunches meet the energy standard within acceptable tolerances on a daily basis.
4.3 Nutritional Analysis of Primary School Lunches
It is proposed that for primary schools the existing standard is amended to include a daily energy calculation, in addition to a weekly energy calculation. All other nutrients should be calculated on a weekly basis.
The TWG acknowledged that the calculation of daily energy will potentially be challenging in terms of menu planning and therefore recommend a tolerance of 15% be applied to the daily energy calculation, in addition to the existing 10% weekly energy calculation. It was also acknowledged that some nutritional analysis software packages do not support a function to display values calculated on a daily basis, and therefore some will have to be updated to reflect this change.
Table 2 – Nutritional Analysis of Primary School Lunches
|Existing standard||Proposed new standard for primary schools|
|The average school meal for a school must be calculated in accordance with the following formula;
Where ‘A’ is the total amount of energy and nutrient content provided in all school meals served in the course of a school week.
Where ‘B’ is the estimated number of school meals served to pupils during that school week.
Where ‘C’ is the number of days in the school week.
|The energy contained within the average school lunch must be calculated in accordance with the following formula;
Where ‘A’ is the total energy provided in all school lunches served at the school lunch in a day.
Where ‘B’ is the estimated number of school lunches served to pupils during that school day.
|The energy and nutrient content of the average school lunch should be calculated using the following formula;
Where ‘C’ is the total energy and nutrient provided in all schools lunches served at the school lunch in a school week.
Where ‘D’ is the estimated number of school lunches served to pupils during that school week.
Where ‘E’ is the number of number of days in the school week.
Table 3 – Energy and Nutrient Tolerances for Nutritional Analysis of Primary School Lunches
|Existing standard||Proposed new standard|
|The average school meal must provide-
a) an amount of energy which shall be either the figure shown in Table A or within 10% of that figure.
b) no more than the amounts of fat, saturated fat, non milk extrinsic sugars and sodium in table A.
c) as a minimum the amounts of all other nutrients shown in table A
|The average school lunch must provide-
a) energy which shall be either the figure shown in Table 1 or within 15% of that figure on a daily basis and 10% on a weekly basis.
b) no more than the fat, saturated fat, free sugars and sodium in Table 1 .
c) a minimum of all other nutrients shown in Table 1
4.4 Summary of Food and Drink Based Standards in Primary Schools
Table 4 - Summary of food and drink standards across the school day
▲ denotes proposed amended standards. ■ denotes proposed new standards.
||At the School Lunch||Out with the School Lunch|
|▲ Fruits and Vegetables (excluding juice)||Not less than two portions of vegetables shall form part of the school lunch.
Not less than one portion of fruit shall form part of the school lunch.
A portion must be at least 40g.
A portion of dried fruit should be limited to 15g.
|A variety of fruit and/or vegetable portions must be made available in any place within the premises where food is provided.
A portion must be at least 40g.
A portion of dried fruit should be limited to 15g.
|Oily Fish||Oily fish must be provided at least once every 3 weeks.||No standard.|
|■ Red and Red Processed Meat||No more than 175g of red and red processed meat is permitted over the course of the school week, of which no more than 100g should be red processed meat.||Red and red processed meat is not permitted.|
|■ Sweetened and Baked Products||Sweetened and baked products cannot be served more than three times per week.
When served they should contain no more than 15g of total sugar per portion.
|Only products meeting the following criteria can be provided:
|■ Breakfast Cereals||Only breakfast cereals meeting the following criteria can be provided:
|▲ Deep Fried and Fried Foods||Food that has been deep fried in the cooking or manufacturing process shall not be permitted more than 3 times in a week.
Chips if served must be served as part of a lunch.
|No fried foods can be available outwith the school lunch, with the exception of savoury snacks that meet the criteria outlined below.|
|▲ Savoury Snacks||The following savoury snacks can be provided:
||In addition, only pre-packaged savoury snacks meeting the following criteria can be provided:
|▲ Bread||All Bread and bread rolls must contain a minimum of 3g of AOAC fibre per 100g.
|■ Sweetened Yoghurts, Fromage Frais and other milk based desserts||Only sweetened yoghurt, fromage frais and other milk based desserts meeting the following criteria can be provided:
|■ Pastry and Pastry Products||Pastry and pastry products should not be provided more than twice a week across the school day.|
|Oils and Spreads||Oils must contain a total saturated fat content which does not exceed 16 grams per 100 grams and –
(a) a total monounsaturated fat content of at least 55 grams per 100 grams; or
(b) a total polyunsaturated fat content of at least 30 grams per 100 grams.
Fat spread must contain –
(a) a total saturated fat content which does not exceed 20 grams per 100 grams; and (b) a combined total monounsaturated and polyunsaturated fat content of at least 30 grams per 100 grams.
|Salt and Condiments||No salt shall be available to add to food after the cooking process is complete.
Other condiments may be available to pupils only in individual portions of no more than 10 millilitres.
|▲ Confectionery||No confectionery shall be made available in any place within school premises
Sweetened and baked products must not contain any confectionery.
|▲ Drinks||The only drinks that can be provided are:
Please refer to annexe 2 for definitions.
Please refer to annexe 3 for detail on proposed changes to the Scottish Statutory Instrument.
Please refer to annexe 4 for primary school product specifications.
Please refer to annexe 5 for detail on the use of artificial sweeteners.
4.5 Food Standards for Primary School Lunches
Fruit and Vegetables
Data from the Scottish Health Survey ( SHeS)  shows that children and young people in Scotland consume too few fruit and vegetables. Furthermore the National Diet and Nutrition Survey ( NDNS)  highlights the particularly low consumption of vegetables. To increase fruit and vegetable intake the existing standard has been amended to ensure that three full portions are available at lunch (2 vegetable and 1 fruit). This is in contrast to the existing standard where the emphasis was on provision of choice of fruit and vegetables.
The existing standard to provide oily fish at least once every 3 weeks in school lunches is based on the premise that school lunches provide 30% of dietary requirements. No change is proposed to this existing standard.
Deep Fried food products
Evidence from school inspections demonstrates that fat and saturated fat standards can be achieved in line with the existing standard to limit the provision of products that have been deep fried in the cooking or manufacturing process to no more than 3 times per week. In practice this allows, for example, one portion of fish and chips and one other product to be served over the course of the week. Therefore no change is proposed to this standard.
The decision was made to retain the existing standard to allow only savoury crackers, oatcakes and breadsticks at lunch, these products have also been permitted outwith the lunch. However the standard has been slightly amended to add the word ‘plain’ to avoid inclusion of high fat, sugar and salt versions of these products.
Red and Red Processed Meat
In 2010 SACN published evidence linking the consumption of red and processed meat with an increased risk of developing colorectal cancer in later life, and recommended that intakes are limited to around 70g daily.  The evidence linking the consumption of red and processed meat with the risk of developing colorectal cancer has strengthened in recent years  , with increased risk associated with consuming processed meat. Decreasing intake of processed meat would prevent twice as many cases of colorectal cancer than reducing red meat alone.  Therefore the TWG recommend that a standard for red and red processed meat is introduced, in order to protect the health of children and young people.
Within the primary school setting red and red processed meat tends only to be provided during the school lunch and therefore it is proposed that no more than 175g of red and red processed meat is permitted at lunchtimes over the course of the school week, of which no more than 100g should be red processed meat. Red and red processed meat is not permitted outwith the lunch.
The additional restriction on the red processed meat to no more than 100g reflects the strength of evidence in relation to these products and the risk of developing colorectal cancer in later life. In addition, it will help limit fat and salt which can be high in these types of products.
The maximum values proposed are applicable to the cooked weight of red and red processed meat.
Please refer to annexe 2 for definitions of red and red processed meat.
Please refer to annexe 6 for calculation of red and red processed meat limits.
Sweetened and Baked Products
Sweetened and baked products are common within current lunch provision, but these products can often be very high in sugar.
The proposed standard is that sweetened and baked products cannot be served more than three times per week, and when served they should contain no more than 15g of total sugar per portion. The rationale for restricting the frequency of these items to a maximum of three times per week is to encourage more children and young people to choose to have fruit and lower sugar alternatives with their lunch.
Please refer to annexe 2 for definition of baked and sweetened products.
4.6 Food Standards Outwith Primary School Lunches
Fruit and Vegetables
It is imperative that children have access to fruit and vegetables outwith the school lunch when food is provided. There has been a slight amendment to the existing standard to read ‘fruit and/or vegetables’ as opposed to ‘fruit and vegetables’, in addition to ensuring that full portions are provided.
Savoury Snacks and Deep Fried Foods
The TWG looked at whether the existing savoury snack criteria should be revised and did not feel that this was necessary. However the existing standard has been amended to allow plain savoury crackers, oatcakes and breadsticks outwith the school lunch, which they are not currently, to provide flexibility and choice.
Sweetened and Baked Products
Outwith the school lunch products high in fat and sugar, such as traybakes, cakes, muffins and biscuits are not currently restricted and may be available to buy either from school or catering run tuck shops. This is despite existing guidance that these foods should be limited. Therefore it is proposed to restrict these products in order to significantly reduce fat and sugar intakes in children and young people, in line with progress towards the SDGs.
Cereal bars have been removed from the definition of confectionery and added into this category. This is in recognition of the range of product innovation in this area. Any cereal bars permitted would need to meet the criteria, and contain no confectionery.
The criteria for inclusion of these products outwith the school lunch was set based on 20% of the average child’s overall daily energy requirement for fat (35%) and saturated fat (11%). The free sugar requirement was altered from 5% of energy recommended by SACN up to 7.5% of energy in recognition of the need to take a stepwise approach to sugar reduction in school food.
Therefore the proposed standard is that only sweetened and baked products meeting the following criteria can be provided:
- No more than 7g of total sugar per portion.
- No more than 13g of fat per portion.
- No more than 4g of saturated fat per portion.
Please refer to annexe 2 for definition of confectionery and sweetened and baked products.
Red and Red Processed Meat
It is proposed that the provision of red and red processed meat is not permitted outwith the lunch in primary schools.
4.7 Food and Drink Standards Across the Full School Day in Primary Schools
Oils and Spreads
No change is proposed to the existing oils and spreads standard.
Salt and Condiments
No change is proposed to the existing salt and condiments standard. The guidance document will include further detail to use lower fat varieties of mayonnaise and low salt and sugar condiments such as ketchup.
It is proposed that the definition of confectionery is changed to remove cereal bars. Furthermore sugared or yoghurt coated products are required to be added to the definition of confectionery.
Please refer to annexe 2 for definition of confectionery.
No change is proposed to the existing confectionery standard, other than an amendment to the wording from cakes, biscuits and puddings to sweetened and baked products, in line with the wording of the proposed new standard for this category.
The existing standard for bread was specifically for lunch provision and was introduced to ensure that children and young people had free access to a filling starchy carbohydrate food if they were still hungry after having lunch. In reality, this standard has not been effective in practice, with wide variations in what and how this is offered, and may detract from children eating the main components of their lunch.
The proposed standard, to be applied across the school day, is that all bread and bread rolls provided contain a source of fibre as set out in EU legislation (minimum of 3g/100g)  . This is to increase the fibre content of these products which are popular with children and young people. It should be noted that as part of a review of the regulations in the future, increasing this to a minimum of 6g of AOAC fibre should be considered to support acceptance of wholemeal bread products by children and young people. Guidance will heavily endorse the use of wholemeal products.
As breakfast cereals are provided in schools, for example as part of breakfast club provision or to supplement provision across the day, a standard has been developed to ensure that breakfast cereal provision supports new Government recommendations for sugar and fibre.
It is proposed that breakfast cereals should only be available if they meet specific criteria.
The proposed standard is that only breakfast cereals meeting the following criteria can be provided:
- No more than 15g of total sugar per 100g.
- No more than 440mg of sodium per 100g.
- No more than 1.1g of salt per 100g.
- At least 3g of fibre per 100g.
Sweetened Yoghurts, Fromage Frais and Other Milk Based Desserts
Milk based desserts are a good source of calcium which is important for good bone development. However, they can be high in fat and sugar, therefore a standard for this category is proposed.
It is proposed that sweetened yoghurts, fromage frais and other milk based desserts should be available across the school day if they meet specific criteria.
The proposed standard is that only sweetened yoghurt, fromage frais and other milk based desserts meeting the following criteria can be provided:
- Maximum portion size of 125g.
- No more than 10g of total sugar per 100g.
- No more than 3g of fat per 100g.
Please refer to annexe 2 for definition of other milk based desserts.
Pastry and Pastry products
Pastry and pastry products are high in fat and should be restricted in provision, therefore a new standard for pastry and pastry products is proposed.
The proposed standard is that pastry and pastry products should not be provided more than twice a week across the school day.
Please refer to annexe 2 for definition of pastry and pastry products.
- Water (still or sparkling)
- Plain lower fat milk and calcium enriched milk alternatives
- No added sugar, lower fat milk drinks (e.g. flavoured milk and hot chocolate) and drinking yoghurts
Following consultation with caterers and education, the TWG made the decision to permit the provision of no added sugar milk drinks and drinking yoghurts due to the nutritional benefits of milk, and to allow choice and variety.
The drinks standard is a permitted list, meaning that the choice of drinks provided from the list is at the discretion of schools, Local Authorities and other providers. However it should be noted that in accordance with ‘The Schools (Health Promotion and Nutrition (Scotland)) Act 2007’  children and young people should have access to free drinking water across the school day.
Fruit juice, vegetable juice, smoothies and fruit juice combination drinks have been removed from the permitted drinks list due to their high free sugar content. A 150ml portion of fruit juice exceeds the maximum free sugar limit of 10.4g in the primary school lunch, and would contribute to excess sugar consumption throughout the day.