The ketchup as a vegetable controversy refers to proposed United States Department of Agriculture (USDA) Food and Nutrition Service (FNS) regulations, early in the presidency of Ronald Reagan, that intended to provide more flexibility in meal planning to local school lunch administrators coping with National School Lunch Plan subsidy cuts enacted by the Omnibus Regulation Acts of 1980 and 1981.
The regulations allowed administrators the opportunity to credit items not explicitly listed that met nutritional requirements. While ketchup was not mentioned in the original regulations, pickle relish was used as an example of an item that could count as a vegetable. Reagan withdrew the proposal after an almost immediate public outcry.
The Omnibus Reconciliation Act of 1980, signed into law by President Jimmy Carter, reduced the Federal School Lunch and Child Nutrition Programs budget by approximately eight percent. Building upon these reductions, the Omnibus Reconciliation Act of 1981 (passed as the Gramm-Latta Budget) made further spending cuts to the Federal School Lunch Program decreasing its fiscal year 1982 budget by 25 percent.
To administer the requirements made by both Omnibus Reconciliation Acts, the USDA’s Food and Nutrition Service (FNS) was tasked with proposing ways to implement the regulations while maintaining nutritional requirements for school lunches despite the lower funding. Among the recommendations made was a proposal to give local school lunch administrators flexibility in accrediting substitute food items that met FNS nutritional requirements and regulations. The report stated an item could not be counted as a bread that was not enriched or whole-grain, ‘but could credit a condiment such as pickle relish as a vegetable.’
While ketchup was not specifically mentioned as a potential substitute, critics demonstrated outrage in Congress and in the media against the Reagan administration for cutting school lunch budgets and allowing ketchup and other condiments to count as vegetables. According to ‘New York Times’ reporter Benjamin Weinraub, ‘the opposition had a Dickensian field day of outrage and mockery that contrasted school children’s shrinking meal subsidies with the Pentagon generals’ groaning board of budget increases.’
In addition to the recent omnibus acts, the Food and Nutrition Service proposed regulations had roots in two previous pieces of legislation: the National School Lunch Act of 1946 and the Child Nutrition Act of 1966. The 1946 law established the nonprofit National School Lunch Program to ensure the health and well-being of American children and increase the domestic consumption of agricultural products and commodities. The act was also a matter of national security (malnourished children grow up to be poor soldiers).
Under the National School Lunch Act, eligible students at all participating schools gained access to free or reduced-cost school lunches. Served lunches had to meet minimum nutrition requirements, which continue to be set by the Secretary of Agriculture to this day. As the 1981 Food and Nutrition Service regulations later explained, while no formal requirement existed requiring that school lunches provide a specific percentage of daily nutrients, it had come to be expected that meals would generally provide one third of daily Recommended Dietary Allowances (RDA). The 1966 law added the Special Milk Program, a breakfast program, and added support for non-food items such as equipment and additional staff. In addition, the act centralized the management and ongoing administration of the School Lunch Program to the US Department of Agriculture.
The Omnibus Reconciliation Act of 1980 amended both the National School Lunch Act of 1946 and the Child Nutrition Act of 1966 by cutting funding for the Federal Milk Program, establishing ceiling rates for grants on nutrition, and reducing provisions to specific, qualified institutions. It also made a range of cost-savings provisions—including reducing federal funding for school lunch general reimbursements, commodity, special assistance, and the child care food program-to reduce the Federal School Lunch and Child Nutrition Programs budget by eight percent. The 1981 omnibus act extended the spending cuts by ending federal assistance for food service materials and shrinking appropriations allocated for nutrition education, special assistance, the child care food program, and the Federal Milk Program. The term ‘school,’ as defined in the Child Nutrition Act, now excluded private institutions with annual tuition exceeding specified amounts.
The act required that the Secretary of Agriculture review its nutritional requirements to find opportunities for cost savings at the local level. The act went on to require the USDA to ‘exhaust all alternatives for lowering local program costs’ and ensure that proposals demonstrated a notable fiscal impact to the local community while meeting nutritional requirements. While all alternative plans had to meet the nutritional requirements established by the Secretary of Agriculture, the act did not require meals to deliver one third of RDA.
Reporting on the proposed directive, ‘Newsweek’ illustrated its story with a bottle of ketchup captioned ‘now a vegetable.’ The proposed directive was criticized by nutritionists and Democratic politicians who staged photo ops where they dined on nutrition-poor meals that conformed to the new lax standards. Compounding this outrage and even though the purchase was privately financed, the same day that the USDA announced the cost-cutting proposal for school lunches, the White House purchased $209,508 worth of new china and place settings with the presidential seal embossed in gold.
Critics of the FNS proposed regulations argued that low-income children would be the most affected by the proposed meal quantity reductions in the plan as they depend upon school lunches for upwards of half of daily nutrients. Carl D. Perkins, Subcommittee Chairman and US Representative from Kentucky, cited a Washington State study which found the state’s low income children received 48 percent of their daily nutrition intake from the meals offered in the School Lunch Program. In the hearing, he voiced the concern of other critics of the regulation, asking, ‘By watering down the requirements for a school lunch, isn’t the department showing it is not concerned with the health of millions of low-income children who cannot supplement their diets with alternative sources of nutrition?’
In his testimony before the Subcommittee on Elementary, Secondary, and Vocational Education, FNS Administrator Hoagland countered this statistic citing the Nationwide Food Consumption Survey of 1977–1978 which found that children’s eating patterns have evolved from eating three to now five meals a day, and that the previous theory that children receive one third of nutrients at lunch time was no longer true. In addition, Hoagland noted that the recent expansion of the Food Stamp Program (which supported those with an income of 130 percent of the gross income poverty line) and other similar programs that provided food assistance to low-income children now offered an additional safety net to such populations.
Another argument in support of the adjusted meal plans was voiced by Elizabeth Cagan, director of the New York City Bureau of School Lunches at the subcommittee hearing: ‘Unless food gets inside a kid, it doesn’t give him any nutrition,’ She added that in New York City she has observed much food served to younger children was wasted – especially green beans, peas, carrots, and mixed vegetables.
After President Reagan removed the original proposed regulations on September 25, 1981, the Food and Nutrition Service submitted revised proposals on November 17, 1981 that removed all mention of condiments counting as vegetables and adhered to the goal of providing one third of all daily nutrients in school lunches. Despite such revisions, the Reagan Administration’s policy was never implemented and FNS Administrator Hoagland was fired at the end of November. ‘Mr. Hoagland… was lashed on Capitol Hill and skewered by the White House, which removed him from his job two days before Thanksgiving.’ He attributed the strength of hunger lobby groups as the source of the FNS regulations downfall. ‘”I may have let the President down by not carefully orchestrating the groups.’ According to the ‘Washington Post,’ ‘there’s a lobby guarding every dish.’
In 2011, Congress passed a bill that barred the USDA from changing its nutritional guidelines for school lunches. The proposed changes would have limited the amount of potatoes allowed in lunches, required more green vegetables, and declared a half-cup of tomato paste to count as a serving of vegetables, rather than the current standard of 2 tablespoons. The blocking of these proposed higher standards meant that the smaller amount of tomato paste in pizza could continue to be counted as a vegetable in school lunches. The move resulted in widespread mockery, with headlines saying Congress had declared pizza to be a vegetable. The blocking legislation was criticized heavily, since the change had also been lobbied for by food companies such as ConAgra, and the block was a substantial blow to efforts to make school lunches healthier.
The Daily Omnivore 
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