The UK Government's consultation on updating the School Food Standards is live and one important weakness within is a distinct failure to address the needs of middle schools. The proposals are largely built around a simple distinction between primary and secondary education, yet around 100 middle schools in England continue to educate pupils across the 9–13 age range. These schools serve children who are neither fully primary-aged nor fully secondary-aged, but the consultation contains no specific framework explaining how they should be treated under the revised standards.
This matters because the consultation proposes different implementation approaches for primary and secondary schools, including phased introduction of some requirements in secondary settings. However, middle schools contain both Key Stage 2 and Key Stage 3 pupils. Legally, middle schools are secondary. However, it is unclear whether they would be expected to follow primary rules, secondary rules, or more likely a combination of both: a lack of clarity that risks inconsistency and uncertainty for school leaders, governors, caterers and academy trusts.
The issue is particularly important because the consultation is attempting the most significant overhaul of school food standards in more than a decade. Proposed changes include increasing fibre, restricting foods high in fat, salt and sugar, reducing sugary desserts, increasing fruit and vegetables, and strengthening accountability through designated governors and published food policies.
Children aged 9–13 represent a distinct developmental group. During these years, growth accelerates, nutritional requirements increase and eating habits become more independent. A Year 5 pupil and a Year 8 pupil may be eating in the same dining hall but have very different dietary needs, levels of physical activity and expectations of school food. A framework designed exclusively for primary schools risks underestimating these differences, while a secondary-school model is inappropriate for younger pupils. Middle school children, from the age of 9 are afforded agency to choose their own meals.
The policy calls for different portion sizes, main meal recipe formulations, desserts and drinks between primary and secondary, making implementation challenging or impossible for middle schools - especially those standalone schools with smaller kitchens, limited storage or low buying power.
The challenge is also significant in Multi Academy Trusts. Many trusts operate a mixture of primary, middle and secondary schools under common catering contracts. The consultation rightly proposes appointing a lead governor for food and strengthening accountability, but it does not explain how trusts should manage food governance where schools do not fit neatly into the primary-secondary divide.
A better approach would be to establish a specific middle-school category within the regulations. Rather than forcing middle schools into one framework or another, the Government could set common nutritional outcomes while allowing flexibility for this group in delivery. For example, schools could be required to provide age-appropriate portion sizes, different menu pathways for younger and older pupils, and phased implementation arrangements that reflect their mixed-age populations.
The consultation could also require academy trusts operating middle schools to publish a dedicated food policy explaining how nutritional standards are adapted for different year groups. Trust boards could monitor meal uptake separately for Key Stage 2 and Key Stage 3 pupils, helping identify whether healthier menus are being accepted across all age groups. Fundamentally, middle schools are adept at providing education and facilities across these ages and we should trust them to interpret any guidance to suit their student base.
This is particularly important because evidence suggests that implementation matters as much as policy design. Recent pilots have shown that changes to school food can affect meal uptake if they do not reflect pupil preferences and behaviour. A framework that recognises the unique nature of middle schools would therefore improve compliance, increase meal uptake and ensure that healthier food standards achieve their intended outcomes.
If the Government is serious about creating a school food system that works for every child, middle schools should not be treated as an afterthought. The original School Food Standards introduced in 2014 did acknowledge middle schools in implementation guidance and this nuance has been lost in the current consultation. The Department already recognises middle schools for funding and census purposes, and a similar approach should be adopted for school food policy.
The final regulations should explicitly recognise mixed-age settings and provide a practical framework that reflects the realities of how these schools operate for around 60,000 English school children. By doing so, ministers would close a significant gap in the consultation and ensure that updated School Food Standards are genuinely applicable across the whole education system.
