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Tennessee outlines Buy American 10% cap, tracking and accommodation process for 2025–26
Summary
The state agency reminded districts that the Buy American nondomestic cap will be 10% of commercial food expenditures for 2025–26, described the accommodation request process and said it will require evidence that a district has reached the cap before approving temporary relief.
Rhonda, senior compliance and data manager, told the update call that for the 2025–26 school year the Buy American nondomestic purchase cap will be 10% of total commercial food expenditures and that the state will require documentation before granting any accommodation.
Rhonda said USDA clarified that the 10% calculation focuses on reimbursable meal components and the department will track categories (fruit, vegetables, juices, cereal and an "other" category) when districts request an accommodation. She emphasized that the state will not pre‑approve accommodations; districts must demonstrate they have hit the 10% cap and provide category‑level information and a timeline for coming into compliance.
The compliance manager said the agency has created Buy American tracking resources and will continue the conversation at S&P Academy and regional meetings. A poll of call participants showed roughly half had not yet started tracking and those who had were generally finding tracking manageable, Rhonda said.
The state said additional guidance on required documentation and the accommodation process will be published and discussed at upcoming trainings.
