USDA FNS: Updated Staple Food Stocking Standards for Retailers in the Supplemental Nutrition Assistance Program (November 24, 2025)

November 24, 2025 SNAP Retailer Policy Division Food and Nutrition Service U.S. Department of Agriculture 1320 Braddock Place Alexandria, VA 22314 RE: Comments on Updated Staple Food Stocking Standards for Retailers in the Supplemental Nutrition Assistance Program; FNS-2025-0018 To Whom It May Concern: 1 On behalf of FMI – The Food Industry Association and the tens of thousands of grocery stores operated by our food retailer member companies, thank you for the opportunity to provide comments regarding USDA’s proposed rule updating the staple food requirements for retailer participation in the Supplemental Nutrition Assistance Program (SNAP), published in the Federal Register on September 25, 2025. For more than 50 years, FMI and our food retailer members – from national supermarket chains and regional grocers to independent operators – have partnered closely with USDA to ensure the successful administration of SNAP and other nutrition assistance programs. During this time, USDA and America’s food retailers have played complementary roles in delivering SNAP, pairing effective program administration with retailer-driven access to nutritious, affordable foods in every community. Our shared commitment to supporting Americans and increasing access to safe, healthy foods remains the cornerstone of that partnership. FMI members are deeply invested in improving nutrition, health, and well-being. Food retailers today serve as full-service health and wellness destinations, providing registered dietitians in stores, personalized nutrition guidance, food-as-medicine programs, and an ever-expanding assortment of nutritious products. FMI members’ supermarkets are often the first – and sometimes the only – source of nutritious food in rural communities, urban neighborhoods, and underserved areas where SNAP participation is highest. This role places retailers at the center of efforts to improve food access and support the health of individuals and families who rely on SNAP. Support for USDA’s Proposed Updates November 24, 2025 FMI appreciates USDA’s goals of modernizing the stocking standards to better reflect SNAP Retailer Policy Division today’s food marketplace and support improved access to nutritious staple foods for Food and Nutrition Service SNAP participants and their families. We agree that ensuring a broad range of staple U.S. Department of Agriculture foods in the categories of fruits and vegetables, dairy, grains, and proteins aligns with 1320 Braddock Place SNAP’s core purpose of reducing food insecurity by ensuring eligible households can Alexandria, VA 22314 reliably purchase nutritious staple foods needed to consistently put balanced meals on their tables. RE: Comments on Updated Staple Food Stocking Standards for Retailers in the Supplemental Nutrition Assistance Program; FNS-2025-0018 FMI and our food retailer members generally meet – and typically exceed – the proposed requirements already, particularly among traditional grocery formats. To Whom It May Concern: Considerations Related to Retailer Diversity and Store Format Differences 1 On behalf of FMI – The Food Industry Association and the tens of thousands of grocery stores operated by our food retailer member companies, thank you for the opportunity At the same time, we respectfully offer several considerations to support effective, to provide comments regarding USDA’s proposed rule updating the staple food practical implementation and to help USDA assess how the updated requirements may requirements for retailer participation in the Supplemental Nutrition Assistance Program affect different types of retail formats, including smaller-format stores. Our intent is not (SNAP), published in the Federal Register on September 25, 2025. to oppose these changes but to provide insight into how they may play out operationally for retailers whose footprints or business models differ from traditional For more than 50 years, FMI and our food retailer members – from national supermarket supermarkets. While we generally support the proposed changes, it is important to chains and regional grocers to independent operators – have partnered closely with recognize that smaller-format and convenience-oriented stores will USDA to ensure the successful administration of SNAP and other nutrition assistance likely experience challenges in implementing the updated requirements. programs. During this time, USDA and America’s food retailers have played complementary roles in delivering SNAP, pairing effective program administration with Many FMI members operate a variety of store formats beyond traditional supermarkets. retailer-driven access to nutritious, affordable foods in every community. Our shared These include small-footprint “express” grocery stores, limited-assortment neighborhood commitment to supporting Americans and increasing access to safe, healthy foods markets, hybrid grocery-fuel locations, and convenience-oriented formats with remains the cornerstone of that partnership. significantly constrained shelf, dry storage, and refrigeration capacity. These stores can play an important role in food access – particularly in rural communities, small FMI members are deeply invested in improving nutrition, health, and well-being. Food towns, and urban neighborhoods where traditional grocery stores may not be viable. retailers today serve as full-service health and wellness destinations, providing registered Because these formats are designed around rapid turn, limited SKU assortments, and/or dietitians in stores, personalized nutrition guidance, food-as-medicine programs, and an smaller refrigeration footprints, they may face significant challenges in meeting the ever-expanding assortment of nutritious products. FMI members’ supermarkets are often expanded dairy and grain variety requirements as proposed. For example, adding the first – and sometimes the only – source of nutritious food in rural communities, urban multiple refrigerated dairy varieties may require expansion of cooler space that is not feasible within existing footprints, while meeting seven distinct grain varieties may require SKU proliferation that conflicts with small-format inventory strategies. Cnelarighifboication rhoodson, an Oud ut-ofnders-Stock erved Situarateasion wsh e re SNAP participation is highest. This role place s retailers at the center of efforts to improve food access and support the health of FMindIivi apdupralseci anatesd f amilthat thiese w prhoo porelsye od run SNAle incoP. rporates a 21-day documentation allowance for retailers that do not meet the stocking requirements at the time of an FNS store visSuit,pport permittingfor USDA’s storesP toroposed demonUstrpdatate esthat required items were ordered or received November 24, 2025 w ithin the previous 21 days. This is a helpful acknowledgment of the normal fluctuations FMthat occurI appre ciinates retail USDA inve’sn togory alsman of moagemedernnizt,ing an d,th increase stockiningg sly, prtanodardudsct toloss better due toref lect SNAP Retailer Policy Division otorgday’saniz efood red mtail arcrimketpelac. e and support improved access to nutritious staple foods for Food and Nutrition Service SNA P participants and their families. We agree that ensuring a broad range of staple U.S. Department of Agriculture foOuotds-of in th-stockse categor are ineviiestab of lefru in fits oanod red vetail,getabl especes, dairy, ially forgr perisains, anhabd prole iteteimsn san aligns d itemswith 1320 Braddock Place affSNAecteP’sd b corye s puupprplyo schae oif nredu variabilicing fty. oWod ie nensecoucurraityge by UeSDAnsu rinto g emake ligiblecle arho thusat eholds can Alexandria, VA 22314 relretailiablyers pu remairchasn ein c nuotrmitiouplians scetap asle lon foog asds n theeeded y routotin conely scarristenty thly epu reqt balanuired varieced mtieealss an on d cantheir demtableons.s trate reasonable efforts to keep them in stock as required, and that RE: Comments on Updated Staple Food Stocking Standards for Retailers in the tem porary out-of-stocks alone should not jeopardize a store’s SNAP authorization. Supplemental Nutrition Assistance Program; FNS-2025-0018 FM I and our food retailer members generally meet – and typically exceed – the proposed requAdditioiremenallynts, w alreadye encou, parage rticUularlySDA amoto clnarg traify thditionat requal grireodce itery msfor keptmats in s. ecure locations – To Whom It May Concern: s uch as locked cases, backroom inventory, or other controlled-access areas to prevent Cthoneft si–dera shotiuld onbe s Retrelatated ed asto Reavatailabiler le Dstoiversick forty complianand Store ceForm purpatos eDsi, sffeo renloncesg as they are 1 On behalf of FMI – The Food Industry Association and the tens of thousands of grocery o ffered for sale to customers. This clarification would help ensure that retailers taking stores operated by our food retailer member companies, thank you for the opportunity nAet the cessarsamey step tims eto, w rede resucepec thtfulleft doy o nffoet ir sneadvverael rtconentlyside facraetio complianns to sucepp chaort lleeffnegectisve, . to provide comments regarding USDA’s proposed rule updating the staple food pr actical implementation and to help USDA assess how the updated requirements may requirements for retailer participation in the Supplemental Nutrition Assistance Program affReequctest difffoerenr Ct tlearypes, P raof ctiretailcal W forrittenmats, incl Guiudadinnceg s maller-format stores. Our intent is not (SNAP), published in the Federal Register on September 25, 2025. to oppose these changes but to provide insight into how they may play out operationally FMfor Iretail stroneglyrs w ehnocouse fooragtpesrin USDAts or bu to issinessue sti momeldye, wls rittendiffer gufroidanm trceaditio that cnalle arly explains how For more than 50 years, FMI and our food retailer members – from national supermarket sretailupermarkers sheotsuld . Winthileerp wree t andgenerally implem suppenot thert th eu pdproated posesd ctockinhang sgestan, itdar is imdspo. Grtiveannt to the chains and regional grocers to independent operators – have partnered closely with recognscope anized c thoatmple smallxityer -oforf thmat e pranopod csoend cveniehanngcees-, clorieearn ted guidanstoresce wwililll be essential to USDA to ensure the successful administration of SNAP and other nutrition assistance lirekelyduci enxpg cerieonnfusceion cha dullerinngesg imple in implmeenmetatniontin g the and helupdpinated g retailerequrs ireadjmeunstst pro. duct programs. During this time, USDA and America’s food retailers have played as sortments, planograms, and operational practices to fully comply with the updated complementary roles in delivering SNAP, pairing effective program administration with sMatanndary FMdsI. me mbers operate a variety of store formats beyond traditional supermarkets. retailer-driven access to nutritious, affordable foods in every community. Our shared T hese include small-footprint “express” grocery stores, limited-assortment neighborhood commitment to supporting Americans and increasing access to safe, healthy foods Wmarke alestso , henycoubrid ragrge oceUSDAry-fuel to locatioengagen sdirec, and ctly ownithvenie FMnI cean-d reorietailented rs forasmats guidan withce is remains the cornerstone of that partnership. sdeveignifilopcaned.tly Retail constrer iainnped sut wheillfl , dryhelp setonsraure ge, andthat c reflarifrigeratioicationsn ar capacitye practi. Tcalh, weseo rkable across difstoferesren cant op playera tinang e imnpviroortannmet ronlets , anin fd sood acuppcoertivess – opaf thrticeu prlarlyogr in ruam’sr al gocommuals. Earlynitie ansd, s mall FMI members are deeply invested in improving nutrition, health, and well-being. Food otonwgonsin, ang did uralobagune nweilighl alsboor hheolp odside wnhtifere y antradiy utionintnal engrded ocechary slltoenresges m aaynd e nont besure viablea . retailers today serve as full-service health and wellness destinations, providing registered Bsmoecauothsee thr tranese sforitionmats on ceare th dese figninal erud arole isu imnd rapid plementuted.rn, li mited SKU assortments, and/or dietitians in stores, personalized nutrition guidance, food-as-medicine programs, and an s maller refrigeration footprints, they may face significant challenges in meeting the ever-expanding assortment of nutritious products. FMI members’ supermarkets are often eFMxpIan apded precidairy ates anUSDAd grain variety’s commitme requnt to miremeondtesrn asiz ingpro pothes eSNAd. FoPr e stoxackinmpleg re, addquireingme nts in the first – and sometimes the only – source of nutritious food in rural communities, urban multiplea manne r threfriat progerated modteairy s accvaresies tieto sn mayutritiou requs fooire edsxp. Wanes ionshar oef UcooSDAler ’ss pagoceal othf at isupps orting notimpr feoasved iblefoo wd sithein ecurxisitytin forg f indooivitpdurinalsts, w anhd file amemielitines g swheov releny dis ontin SNAct grP,ain an d wvariee tieloos k may requforwairerd SKU pro to continlifeueradtio collabon that craotionflnic wtsith w thithe sDemallpa-rtformemat nt asinv imenplemtory setrnategietation smo. ves for ward. Cn elarighifboication rhoodson, an Oud ut-ofnders-Stock erved Situarateasion wsh e re SNAP participation is highest. This role place W e aps prretaieciatelers thate th oepp ceonrtter unityof etoff oshrtars eto o imur vieprowve s fooon d acthe prceosspo ansed sd ruupple oanrtd w thee hlceoalthme of FMindconIivitin apduuprealsd eeci anatesngagd f amilthemeat thienst we w prhithoo porelUSDAsye od run th SNAlero uincoP.gh orpuot the ratesim a plem21-day entatdoioncumenta procestios. nIf allowance you have anfor y retail quesetiors nths ator w dois nho tt mo diseecusst the th stoe tockinpic g rein gqureater iremedetailnts at th, plee astimee do o f nanot hes FNS itate store to convisSuit,pport t act permittingmefo r atU pmatSDA’s storesz@P fmtoroposed i.odemrg oonr (Ustrpdat202ate ) esth452at - requ8444.ire d items were ordered or received November 24, 2025 w ithin the previous 21 days. This is a helpful acknowledgment of the normal fluctuations FMth at occurI appre ciinates retail USDA inve’sn togory alsman of moagemedernnizt,ing an d,th increase stockiningg sly, prtanodardudsct toloss better due toref lect SNAP Retailer Policy Division otoSirgnday’sceanreliz eyfood re, d mtail arcrimketpelac. e and support improved access to nutritious staple foods for Food and Nutrition Service SNA P participants and their families. We agree that ensuring a broad range of staple U.S. Department of Agriculture foOuotds-of in th-stockse categor are ineviiestab of lefru in fits oanod red vetail,getabl especes, dairy, ially forgr perisains, anhabd prole iteteimsn san aligns d itemswith 1320 Braddock Place affSNAecteP’sd b corye s puupprplyo schae oif nredu variabilicing fty. oWod ie nensecoucurraityge by UeSDAnsu rinto g emake ligiblecle arho thusat eholds can Alexandria, VA 22314 relretailiablyers pu remairchasn ein c nuotrmitiouplians scetap asle lon foog asds n theeeded y routotin conely scarristenty thly epu reqt balanuired varieced mtieealss an on d Peter Matz cantheir demtableons.s trate reasonable efforts to keep them in stock as required, and that Director, Food and Health Policy RE: Comments on Updated Staple Food Stocking Standards for Retailers in the tem porary out-of-stocks alone should not jeopardize a store’s SNAP authorization. Supplemental Nutrition Assistance Program; FNS-2025-0018 FM I and our food retailer members generally meet – and typically exceed – the proposed Arequ dditioiremenallynts, w alreadye encou, parage rticUularlySDA amoto clnarg traify thditionat requal grireodce itery msfor keptmats in s. ecure locations – To Whom It May Concern: s uch as locked cases, backroom inventory, or other controlled-access areas to prevent Cthoneft si–dera shotiuld onbe s Retrelatated ed asto Reavatailabiler le Dstoiversick forty complianand Store ceForm purpatos eDsi, sffeo renloncesg as they are 1 On behalf of FMI – The Food Industry Association and the tens of thousands of grocery o ffered for sale to customers. This clarification would help ensure that retailers taking stores operated by our food retailer member companies, thank you for the opportunity nAet the cessarsamey step tims eto, w rede resucepec thtfulleft doy o nffoet ir sneadvverael rtconentlyside facraetio complianns to sucepp chaort lleeffnegectisve, . to provide comments regarding USDA’s proposed rule updating the staple food pr actical implementation and to help USDA assess how the updated requirements may requirements for retailer participation in the Supplemental Nutrition Assistance Program affReequctest difffoerenr Ct tlearypes, P raof ctiretailcal W forrittenmats, incl Guiudadinnceg s maller-format stores. Our intent is not (SNAP), published in the Federal Register on September 25, 2025. to oppose these changes but to provide insight into how they may play out operationally FMfor Iretail stroneglyrs w ehnocouse fooragtpesrin USDAts or bu to issinessue sti momeldye, wls rittendiffer gufroidanm trceaditio that cnalle arly explains how For more than 50 years, FMI and our food retailer members – from national supermarket sretailupermarkers sheotsuld . Winthileerp wree t andgenerally implem suppenot thert th eu pdproated posesd ctockinhang sgestan, itdar is imdspo. Grtiveannt to the chains and regional grocers to independent operators – have partnered closely with recognscope anized c thoatmple smallxityer -oforf thmat e pranopod csoend cveniehanngcees-, clorieearn ted guidanstoresce wwililll be essential to USDA to ensure the successful administration of SNAP and other nutrition assistance lirekelyduci enxpg cerieonnfusceion cha dullerinngesg imple in implmeenmetatniontin g the and helupdpinated g retailerequrs ireadjmeunstst pro. duct programs. During this time, USDA and America’s food retailers have played as sortments, planograms, and operational practices to fully comply with the updated complementary roles in delivering SNAP, pairing effective program administration with Mastanndary FMdsI. me mbers operate a variety of store formats beyond traditional supermarkets. retailer-driven access to nutritious, affordable foods in every community. Our shared T hese include small-footprint “express” grocery stores, limited-assortment neighborhood commitment to supporting Americans and increasing access to safe, healthy foods Wmarke alestso , henycoubrid ragrge oceUSDAry-fuel to locatioengagen sdirec, and ctly ownithvenie FMnI cean-d reorietailented rs forasmats guidan withce is remains the cornerstone of that partnership. sdeveignifilopcaned.tly Retail constrer iainnped sut wheillfl , dryhelp setonsraure ge, andthat c reflarifrigeratioicationsn ar capacitye practi. Tcalh, weseo rkable across difstoferesren cant op playera tinang e imnpviroortannmet ronlets , anin fd sood acuppcoertivess – opaf thrticeu prlarlyogr in ruam’sr al gocommuals. Earlynitie ansd, s mall FMI members are deeply invested in improving nutrition, health, and well-being. Food otonwgonsin, ang did uralobagune nweilighl alsboor hheolp odside wnhtifere y antradiy utionintnal engrded ocechary slltoenresges m aaynd e nont besure viablea . retailers today serve as full-service health and wellness destinations, providing registered Bsmoecauothsee thr tranese sforitionmats on ceare th dese figninal erud arole isu imnd rapid plementuted.rn, li mited SKU assortments, and/or dietitians in stores, personalized nutrition guidance, food-as-medicine programs, and an s maller refrigeration footprints, they may face significant challenges in meeting the ever-expanding assortment of nutritious products. FMI members’ supermarkets are often eFMxpIan apded precidairy ates anUSDAd grain variety’s commitme requnt to miremeondtesrn asiz ingpro pothes eSNAd. FoPr e stoxackinmpleg re, addquireingme nts in the first – and sometimes the only – source of nutritious food in rural communities, urban multiplea manne r threfriat progerated modteairy s accvaresies tieto sn mayutritiou requs fooire edsxp. Wanes ionshar oef UcooSDAler ’ss pagoceal othf at isupps orting notimpr feoasved iblefoo wd sithein ecurxisitytin forg f indooivitpdurinalsts, w anhd file amemielitines g swheov releny dis ontin SNAct grP,ain an d wvariee tieloos k may requforwairerd SKU pro to continlifeueradtio collabon that craotionflnic wtsith w thithe sDemallpa-rtformemat nt asinv imenplemtory setrnategietation smo. ves for ward.