Buy American Accommodation Process for SY 2026-2027

Date: July 21, 2026

To: Superintendents; Child Nutrition Directors; Child Nutrition Managers

From: Food and Nutrition Division

For questions: Contact Samantha Gray at 501‑324‑9502 or samantha.gray@ade.arkansas.gov

This memo provides an overview of USDA Memo SP 09‑2026, which outlines the Buy American accommodation process for School Year (SY) 2026–2027. The process allows state agencies to approve temporary relief for School Food Authorities (SFAs) that cannot meet the 10% annual limit on non‑domestic commercial food purchases, as required under 7 CFR 210.21(d)(5) and 7 CFR 220.16(d)(5).

The Buy American provision supports the National School Lunch Act’s goal of encouraging the domestic purchase of nutritious foods.

Key Requirements for SY 2026–2027

• The 10% limit on non‑domestic commercial food purchases remains in effect.
• Domestic products must be processed in the U.S. and contain more than 51% domestically grown agricultural commodities.
• Two regulatory exceptions remain available for non‑domestic purchases.
• Temporary accommodations allow SFAs to exceed the threshold only when qualifying under these exceptions.

Accommodation Process

SFAs unable to comply with the 10% threshold may submit the SFA Accommodation Plan (SY 2026–2027) to the Arkansas Department of Agriculture.

State agencies should:

• Promptly review complete requests
• Approve accommodations when fully justified
• Provide technical assistance as needed
• Ensure SFAs continue working toward increased domestic purchasing

Temporary accommodations apply only to non‑domestic purchases that meet at least one of the regulatory exceptions.

Reporting Requirements

State agencies must submit quarterly reports to their FNA regional office detailing:

• Number of accommodation requests received
• Number approved
• Types of non‑domestic products purchased

This reporting helps USDA understand ongoing challenges in meeting the domestic purchasing threshold.

Contact your Area Specialist via email or call 501-324-9502 for further details.