Law · Programmatic documents

Technical Note on Food Sales in Public Schools participating in National School Meals Program (Technical note No. 2974175/2022/COSAN/CGPAE/DIRAE)


This technical note offers a comprehensive overview and general guidelines on food sales in public elementary and secondary schools enrolled in 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) tasked with implementing the policies of the Ministry of Education of Brazil [Ministério da Educação]. 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)].

In addition, the goal of this technical note is to ensure that public schools’ canteens complement and support the nutritional needs of students who participate in the PNAE program. For this reason, it is directed to all public school units in the network covered by the PNAE.

For the purposes of FULL Global Food Laws, the regulation provides two important guidelines:

  • First, it states that school canteens ought to offer healthy and adequate food options for students, substituting ultra-processed products with non-processed or minimally processed foods (para 4.21). This interpretation is in line with what is foreseen by the Food Guide for the Brazilian Population [Guia Alimentar para a População Brasileira] and by Resolution CD/FNDE No. 6 of 2020.
  • Second, the technical note states that the current legislation prohibits the advertising, marketing, and promotion (including sponsorship of school and extracurricular activities) of ultra-processed foods within school environments (para 4.23). This interpretation stems from Law on Consumer Defense No. 8.078 of 1990 and Resolution No. 163 of 2014 issued by the National Council for the Rights of Children and Adolescents [Conselho Nacional dos Direitos da Criança e do Adolescente, CONANDA].