Action Required by January 1 2026
Summary
This alert is provided for informational purposes only. This is not a change to New Jersey regulations. Existing regulations permit manufacturers to adjust modest meal limits annually based on the applicable Consumer Price Index (CPI). Based on the CPI calculation methodology set forth in regulation, manufacturers may increase modest meal limits for calendar year 2026 to $20.00 for breakfast and lunch and $41.00 for dinner. Any increase is solely at the discretion of each manufacturer and subject to internal company policies.
Regulatory Background
The definition of “modest meals” under New Jersey law includes an automatic annual adjustment mechanism. Specifically, N.J.A.C. 13:45JH-1.2 provides that:
In each succeeding calendar year after 2018, these amounts shall be adjusted if the Consumer Price Index reflects a sum, which, if rounded, consistent with the definition of “Consumer Price Index,” would raise it by one dollar increments.
The Consumer Price Index is defined as the annual average, rounded to the nearest dollar, of the CPI for Food Away From Home, Northeast Urban, as published by the U.S. Department of Labor Bureau of Labor Statistics. Amounts under 50 cents are disregarded, and amounts of 50 cents or more are rounded up to the next dollar.
The CPI for the prior calendar year is used to determine whether an increase applies for the subsequent year. For 2026 limits, the estimated 2025 CPI was used.
2026 Modest Meal Limits
Based on the CPI calculation methodology set forth in N.J.A.C. 13:45JH-1.2, the following modest meal limits are permissible for 2026:
- Breakfast and Lunch: Up to $20.00 per meal
- Dinner: Up to $41.00 per meal
These amounts do not represent a regulatory change. Adoption of the increased limits is optional and remains at the discretion of each manufacturer, consistent with internal
Historical Modest Meal Limits Calculation
|
CPI Year |
Annual Avg CPI (Prior Year) |
Rounded CPI |
% Change |
Increase B/L |
B/L Limit |
Increase Dinner |
Dinner Limit |
|
2018 |
272.515 |
273 |
N/A |
N/A |
$15.00 |
N/A |
$30.00 |
|
2019 |
280.042 |
280 |
2.564% |
$0.39 |
$15.00 |
$0.77 |
$31.00 |
|
2020 |
288.072 |
288 |
2.857% |
$0.43 |
$15.00 |
$0.89 |
$32.00 |
|
2021 |
298.490 |
298 |
3.472% |
$0.52 |
$16.00 |
$1.11 |
$33.00 |
|
2022 |
312.707 |
313 |
5.034% |
$0.81 |
$17.00 |
$1.67 |
$35.00 |
|
2023 |
306.746 |
307 |
3.4% |
$0.58 |
$18.00 |
$1.19 |
$36.00 |
|
2024 |
357.195 |
357 |
6.886% |
$1.24 |
$19.00 |
$2.55 |
$40.00 |
|
2025 |
317.414 |
317 |
2.7% |
$0.51 |
$20.00 |
$1.08 |
$41.00 |
Recommended Actions
- Review and confirm internal meal policies for alignment with the 2026 New Jersey modest meal limits.
- Communicate updated limits to relevant internal teams, including compliance, sales, and field personnel, as appropriate.
- No regulatory filing or external action is required at this time.
For questions regarding this regulatory update or assistance with state transparency and aggregate spend compliance, please contact QPharma.
