Law · Programmatic documents

Technical Note on Conflicts of Interests in National School Meals Program (Technical note No. 3228950/2022/COSAN/CGPAE/DIRAE)


This technical note aims to promote the identification and prevention of conflicts of interest in the implementation of the National School Meals Program [Programa Nacional de Alimentação Escolar (PNAE)].


The technical note was issued by a federal agency [Fundo Nacional de Desenvolvimento da Educação – FNDE]. While not legally binding, it provides interpretation and guidance on existing regulations related to the National School Feeding Program [Programa Nacional de Alimentação Escolar (PNAE)] regarding conflicts of interest (“conflito de interesses”) in implementing PNAE.

In addition, the goal of this technical note is to ensure that practices related to conflicts of interest do not affect public schools neither through public procurement policies nor through marketing practices by the industry of unhealthy foods and beverages.

For the purposes of FULL Global Food Laws, the document provides governmental representatives with important guidelines:

  • A list of actions preventing partnerships with unhealthy food and beverages industries. Some of these actions are education activities, contests, or donations in collaboration with such companies.
  • Furthermore, schools should avoid distributing free samples or gifts of these companies, promoting factory visits related to these products, or accepting donations that could encourage the consumption.