5. Secondary School
The provision of school food in secondary schools can be grouped into 3 sets of standards;
1. Nutrient Standards for the analysed secondary school lunch
2. Food Standards for the analysed secondary school lunch
3. Food and Drink Standards across the school day in secondary schools
Please note that the above standards are also applicable to food and drink served in school hostels.
5.1 Nutrient Standards for Analysed Secondary School Lunches
Proposed changes to the nutrient standards for secondary schools have been highlighted in bold in table 5 below.
As with the existing nutrient standards, the proposed nutrient standards have been based on 30% of the daily requirement.
There is an increase in energy requirement from 664 kcals to 745 kcals. As a result, the values for total fat, saturated fat and total carbohydrate have increased as these values are based on % food energy.
It was noted that the proposed new energy requirement represents an increase from the existing value. This could encounter criticism given the backdrop of overweight and obesity in Scotland. However the TWG recognise the importance of ensuring that all pupils that are entitled to a free school lunch can access sufficient calories and nutrients from the school lunch.
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 from young people aged 11-18 years is around 15.4% of food energy  .
Please refer to annexe 1 for definitions of non milk extrinsic sugars, free sugars and total sugars.
The fibre value has also increased slightly to reflect new advice. The new fibre recommendation is reflected in AOAC methodology, which is the standard methodology used in product analysis and food labelling. For completeness values for both AOAC and NSP fibre are included in the updated table.
The TWG recognised that young people in secondary school use the school catering service in a different way to primary school children. Most have the choice to leave the school building and eat out with the school environment. Some young people will choose to purchase what they are eating for lunch during morning break (for example, if attending a lunch time club). Items are most often priced individually so young people can pick and choose what they have, meaning that they might only choose a sandwich or a drink which falls short of the greater energy requirement. Other young people will buy items to add to their home packed lunch or split what money they have been given between morning break and lunch.
The wider range of items that are on offer for young people in a secondary school make nutritionally analysing the entire provision very difficult and time consuming, and meeting the nutrient standards extremely challenging. However, as noted above, the TWG felt that it was important to ensure that young people entitled to a free school lunch could be assured of being able to select a minimum of a two course lunch that meets the nutrient standards for their entitlement. Therefore, the TWG propose that the nutrient standards in secondary school are applied to a minimum of a two choice, two course lunch only. These choices should include a range of lunch options which are popular with young people across the week and should be clearly marketed on the menu. This is referred to below as the analysed school lunch. There will be strong guidance provided around the marketing of food and drinks in school settings.
As the new values are an average across a wide age range, 11-18 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 young person.
All food and drinks provided across the school day will need to meet an enhanced set of proposed food and drink standards set out in section 5.5 to support progression towards the SDGs.
Please refer to annexe 7 for definition of an analysed school lunch.
Table 5 – Proposed updates to statutory nutrient standards for analysed school lunches for pupils in secondary schools
||An average day’s secondary
school lunch – Existing
|An average day’s secondary
school lunch – Proposed
|Energy (calories/kilojoules)||664 kcals||745 kcals|
|2776 kJ||3114 kJ|
||Not more than 25.8 g||Not more than 29.0g|
||Not more than 8.1 g||Not more than 9.1g|
||Not less than 88.5 g||Not less than 99.3g|
|Non Milk Extrinsic Sugars||Not more than 19.5 g||N/A|
||N/A||Not more than 14.9 g|
|Fibre ( AOAC)
||N/A||Not less than 9.0g|
|Fibre ( NSP)
||Not less than 5.3 g||Not less than 6.9g|
||Not less than 13.6 g|| Not less than 27.9g
||Not less than 4.4 mg||Not less than 4.4mg|
||Not less than 300 mg||Not less than 300mg|
||Not less than 187 µg||Not less than 187µg|
||Not less than 11 mg||Not less than 11mg|
||Not less than 60 µg||Not less than 60µg|
||Not more than 894 mg (not
more than 824 mg by 2010)
|Not more than 824mg|
||Not less than 2.8 mg||Not less than 2.8mg|
* Calculated as NMES minus sugars from dried, stewed or canned fruit.
5.2 Nutritional Analysis of Analysed Secondary School Lunches
The analysed two course lunch should include all meal components. Inclusion of a drink with this lunch is at the discretion of the school catering provider (free drinking water should always be available), but this should be considered as part of meeting the nutritional and energy requirements, and must be included in the nutritional analysis.
It is proposed that for secondary 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 nutrition analysis packages are not currently calculated on a daily basis and therefore some software packages will have to be updated to reflect this change.
In the guidance to support these changes it is important to ensure that caterers are more aware of the energy contribution of different lunches and the choices that young people can access across the week.
Table 6 - Nutritional Analysis of Secondary School Lunches
|Existing standard||Proposed new standard for secondary 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 analysed school lunches  served at the school lunch in a day.
Where ‘B’ is the estimated number of analysed 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 analysed schools lunches served at the school lunch in a school week.
Where ‘D’ is the estimated number of analysed school lunches served to pupils during that school week.
Where ‘E’ is the number of days in the school week.
Table 7 – Energy and Nutrient Tolerances for Nutritional Analysis of Secondary School Lunches
|Existing standard||Proposed new standard|
| The average school meal must provide-
d) an amount of energy which shall be either the figure shown in Table A or within 10% of that figure.
e) no more than the amounts of fat, saturated fat, non milk extrinsic sugars and sodium in table A.
f) as a minimum the amounts of all other nutrients shown in table A
|The average school lunch must provide-
d) energy which shall be either the figure shown in Table 5 for secondary or within 15% of that figure.
e) no more than the fat, saturated fat, free sugars and sodium in Table 5 for secondary school.
f) a minimum of all other nutrients shown in Table 5 .
5.3 Summary of Food and Drink Based Standards in Secondary Schools
Table 8 - Summary of food and drink standards across the school day
▲ denotes proposed amended standards. ■ denotes proposed new standards.
||At the Analysed School Lunch|| Out with the Analysed School Lunch (including non-analysed school lunch options and all other items served across the whole school day)
|▲ Fruits and Vegetables (excluding juice)||Not less than two portions of vegetables shall form part of the analysed school lunch.
Not less than one portion of fruit shall form part of the analysed school lunch.
A portion is at least 80g.
A portion of dried fruit should be limited to 30g.
|A variety of fruit and/or vegetables portions must be made available in any place within the premises where food is provided.
Salad or vegetables must be provided and included in the cost of any main lunch item.
A portion is at least 80g.
A portion of dried fruit should be limited to 30g.
|▲ Oily Fish||Oily fish must be provided at least once every 3 weeks.|
|■ Red and Red Processed Meat||No more than 230g of red and red processed meat is permitted over the course of the school week, of which no more than 130g should be red processed meat.|
|■ Sweetened and Baked Products||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 per week (with the exception of savoury snacks that meet the criteria detailed below).
Chips if served must be served as part of a lunch.
|▲ Savoury Snacks||The following savoury snacks can be provided:
|▲ Bread||All Bread and bread rolls must contain a minimum of 3g of AOAC fibre per 100g.
|■ 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.|
|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.|
|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.
|▲ 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 5 for detail on the use of artificial sweeteners.
Please refer to annexe 8 for detail on proposed changes to the Scottish Statutory Instrument.
Please refer to annexe 9 for secondary school product specifications.
5.4 Food Standards for Analysed Secondary 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.
5.5 Food and Drink Standards Across the Full School Day in Secondary Schools
This section applies to the analysed lunch options, non-analysed lunch options and all other items served across the whole school day.
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.
Fruit and Vegetables
A variety of fruit and/or vegetables portions must be made available in any place within the premises where food is provided.
To further encourage the consumption of vegetables, which are lower in Scotland than in the rest of the UK, in secondary schools all main lunch items must incorporate a portion of salad or vegetables as part of the cost of that item. The guidance document will provide further details around this including that this should be clearly marked on the menu and heavily promoted.
Please refer to annexe 7 for definition of a main lunch item.
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 existing standard has been amended to add the word ‘plain’ to savoury crackers, oatcakes and breadsticks to avoid inclusion of high fat, sugar and salt versions of these products. In addition the TWG looked at whether the existing savoury snack criteria should be revised and did not feel that this was necessary.
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 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.
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 an 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.
In the secondary school setting red and red processed meats are frequently served outwith the lunch service, particularly during mid-morning, where the provision of rolls filled with bacon or sausages are often available on a daily basis. In addition to this, red and red processed meat is also available during the lunch service. It is proposed that no more than 230g of red and red processed meat is permitted over the course of the school week, of which no more than 130g should be red processed meat.
The additional restriction on the red processed meat no more than 130g 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 weights of red and red processed meat.
It is acknowledged that the introduction of a standard for red and red processed meat will represent a substantial change to current provision, however this is warranted on the basis of reducing risk of colorectal cancer.
Please refer to annexe 2 for the definition of red and red processed meat.
Please refer to annexe 6 for calculation of red and red processed meat limits.
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 the definition of pastry and pastry products.
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 175g.
- 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.
Sweetened and Baked Products
Products high in fat and sugar, such as traybakes, cakes, muffins and biscuits are not currently restricted outwith the lunch and can be available to buy either from school or catering run tuck shops on a daily basis. Inspection evidence from Education Scotland shows that whilst the quantities and portion sizes of these products do vary, their provision remains of significant concern.
Therefore it is proposed a standard is set to restrict these products across the day, in order to significantly reduce fat and sugar intakes in young people, in line with progress towards the SDGs. Consideration was given to provision of different criteria at lunchtime but this was considered impractical for caterers. On balance it was agreed that products from this category could be provided across the day but within strict limits.
The criteria for inclusion of these products across the school day was set based on 20% of the average young persons 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.
The guidance to accompany the regulations will discourage the provision of sweetened and baked products daily and instead include emphasis on the provision of starchy carbohydrates.
The proposed standard is that only sweetened and baked products meeting the following criteria can be provided:
- No more than 10g of total sugar per portion.
- No more than 19g of fat per portion.
- No more than 6g of saturates per portion can be provided.
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 be available across the school day 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.
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.
- Water (still or sparkling)
- Plain lower fat milk and calcium enriched milk alternatives
- Tea and Coffee
- No added sugar, lower fat milk drinks (e.g. flavoured and hot chocolate) and drinking yoghurts
- Sugar free drinks (excluding high caffeine - 150mg per litre)
The key focus when reviewing the range of permitted drinks in secondary schools was to reduce the provision of drinks high in free sugar.
The TWG consulted with catering and education colleagues who felt that the range of drinks currently provided in schools were not attractive to young people and that this was a contributory factor to young people leaving school at lunchtime to purchase their lunch out of school. This evidence, along with the need to reduce sugar intake considerably, led to the TWG recommending that sugar free drinks be included within the permitted list in schools. 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.
The TWG also recognise that there will need to be careful consideration given to educating young people, parents and educators about the reasons for this change in approach to drinks.
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 typically contributes 100% of the free sugar allowance at the school lunch and would contribute to excess sugar consumption throughout the day.