Quick answer
What is the difference between a CN label and a product formulation statement?
A CN label is a USDA-approved crediting statement printed on the carton, and it carries a warranty against audit claims. A product formulation statement (PFS) is the manufacturer's own signed crediting document; USDA does not review it, so the school must check its math. Either one lets a processed egg product credit.
The CN label vs product formulation statement question decides how much checking happens before an egg item goes on the menu. Plain whole eggs credit straight from the Food Buying Guide (FBG), but precooked scrambled eggs, patties, omelets and breakfast sandwiches need one of these two documents. See our guide to eggs in school meals.
Which egg products need a CN label or PFS?
| Egg item | How it credits | Document needed |
|---|---|---|
| Shell eggs, frozen whole eggs, dried whole eggs | FBG yields (1 large egg = 2 oz eq) | None beyond your recipe and invoices |
| Precooked scrambled eggs with added ingredients | Manufacturer documentation | CN label or PFS |
| Egg patties, folded eggs, omelets | Manufacturer documentation | CN label or PFS |
| Breakfast sandwiches, burritos, egg bakes | Each creditable component | CN label or PFS (often for grains and meat alternate) |
The FBG says this directly: its yields are for whole eggs, and for blends and specialty egg products you use a CN-labeled product or the manufacturer's documentation. Our guide to egg crediting in school meals has the full yield table.
What is a CN label?
The Child Nutrition (CN) Labeling Program is a voluntary federal program run by USDA's Agricultural Marketing Service (AMS) with the Food and Nutrition Administration (formerly FNS), the Food Safety and Inspection Service and NOAA's Seafood Inspection Program..
A valid CN label shows:
- the CN logo, which has a distinct border
- the meal pattern contribution statement, for example the oz eq of meat alternate per serving
- a unique 6-digit CN identification number assigned by AMS
- the USDA authorization statement
- the month and year of approval
- the normal federally required label information
CN labels are only available for main dish products that provide at least 1/2 oz eq of meat/meat alternate, so an egg entree can qualify. A label with all X's or zeros in place of the number is not valid.
Why the CN label matters
A CN label gives you a warranty against audit claims when you prepare the product according to the manufacturer's directions. Acceptable copies are the original label from the carton, a photo of the label still attached to the carton, or a watermarked copy from the vendor showing the product name and CN number, kept with the bill of lading.
When a valid CN label or watermarked label is on file, you cannot ask the manufacturer for a PFS on the same item. AMS publishes lists of authorized CN labels to check against.
What is a product formulation statement?
A PFS is a document the manufacturer writes to show how a product credits toward the meal pattern. It is common for egg items that have no CN label. Unlike a CN label, USDA does not review, approve or monitor PFS forms, so they vary between companies, and the school food authority (SFA) is responsible for checking them.
According to the Connecticut State Department of Education's PFS guidance (revised October 2026), an acceptable PFS:
- is on company letterhead and signed by a person of authority, such as a quality control manager (handwritten, stamped or electronic signature)
- names the product as it appears on the label and gives the product code
- states the serving size as purchased or served, by weight or by measure with its weight
- lists each creditable ingredient in a form that matches an FBG item
- shows the calculation for each meal component, rounded down to the nearest 1/4 oz eq
- comes with the product label and ingredient statement attached
Manufacturers do not have to use USDA's PFS templates, but other forms must include the same information. USDA also publishes a completed sample PFS for a breakfast sandwich crediting both grains and meat alternate.
CN label vs product formulation statement at a glance
| Question | CN label | PFS |
|---|---|---|
| Who prepares it? | Manufacturer, approved by AMS | Manufacturer only |
| Reviewed by USDA? | Yes | No |
| Warranty against audit claims? | Yes, when prepared as directed | No |
| Who checks the math? | USDA, at approval | Your SFA, before purchase |
| Where it appears | On the carton | Separate signed document |
| Which products | Main dish items with at least 1/2 oz eq meat/meat alternate | Any processed product |
| Effort for your staff | Low: file the label | Higher: review and file |
How to review a PFS for an egg product
Federal guidance, set out in USDA memo SP 05-2025 on accepting processed product documentation, requires SFAs to get and verify a PFS before they buy, serve and claim the item. These red flags are the ones that most often mean you need a revised form:
- Crediting exceeds weight. A 1.5 oz egg patty cannot credit as 2 oz eq.
- Names do not match. "Egg" on the PFS for an item labeled "egg and cheese omelet" is too vague.
- No rounding down. 1.4 oz eq must be stated as 1.25 oz eq.
- Ingredients without a form. The PFS should say whether the egg is frozen, liquid or dried whole egg.
- Higher crediting than the FBG with no explanation. The PFS must show how it gets there.
- Missing signature, letterhead or label.
If anything is missing or wrong, ask the manufacturer for a revised PFS. Do not credit the item until it arrives.
Which should your district ask for?
Ask for a CN label when you can. It saves review time and carries the audit warranty. FBG guidance says that if you want CN-labeled products, you must state this clearly in your purchasing specifications.
A PFS is fine when the egg item you prefer has no CN label. Whatever you accept, write it into the bid and compare cost per oz eq, not cost per case. The K-12 egg product checklist lists the documents to request with each bid, and the Buy American rules for school food cover the separate domestic content paperwork.
Keep the paperwork review-ready
Store CN labels and PFS forms in one binder or shared folder by menu item, and replace them when a formula changes. State agencies check this file during the Administrative Review. Request the documents with every sample, and choose the format first with our comparison of egg patties vs scrambled eggs for school breakfast.
FAQ
Is a CN label required for school food?
No. There is no federal requirement that schools buy CN-labeled products. A processed product needs either a CN label or an acceptable PFS to credit, unless it is listed in the Food Buying Guide. If your district wants CN labels only, the purchasing specifications must say so.
Who signs a product formulation statement?
A person of authority at the manufacturer, such as the quality control manager or a nutrition or research and development lead. The PFS must be on company letterhead, and the signature can be handwritten, stamped or electronic. Unsigned forms cannot be accepted as crediting documentation.
Can schools accept a PFS instead of a CN label?
Yes. A PFS is acceptable crediting documentation when it has every required element and the calculations are correct. The SFA must verify it before purchasing and serving the item, because USDA does not review it and it carries no warranty against audit claims.
Do scrambled eggs need a CN label?
Scratch scrambled eggs made from shell, frozen or dried whole eggs credit from the FBG and your standardized recipe. Precooked scrambled eggs with added ingredients are a processed product, so they need a CN label or a PFS from the manufacturer.
Next step
Before your next bid, list every processed egg item on the menu and the document you hold for it. Schools are one of the markets Echo Lake Foods serves; see the Schools note on our solutions page, and ask Echo Lake Foods for its School Breakfast/Lunch Program specifications and the crediting documents for any item you want to test. For students who leave eggs on the tray, see how to fix low school breakfast acceptance.
