SNAP Stocking Requirements

Last Updated: January 05, 2026

The Issue

Convenience stores provide essential access to nutrition for low-income Americans who live in rural or urban environments. Out of the more than 150,000 convenience stores in the United States, more than 118,000 participate in the Supplemental Nutrition Assistance Program (SNAP) – representing approximately 45% of all retail outlets authorized to accept SNAP benefits. Convenience stores are often the only establishments easily accessible by walking or public transportation, or the only food retail locations open for business with extended or 24-hour service.

In 2014, a comprehensive Farm Bill was passed and signed into law that imposed additional obligations on SNAP retailers, including increasing retailer stocking requirements from 4 varieties of food to 7 varieties of food in the four staple food groups. Subsequently, the U.S. Department of Agriculture’s Food and Nutrition Service (FNS), the agency that oversees SNAP, finalized a rule in December 2016, enacting the 2014 Farm Bill’s provisions. However since 2017, Congress has passed legislation delaying the increase in stocking requirements from going into effect until FNS expands its definition of “variety” so that it would be workable for small format retailers.

In September 2025, FNS published a proposal to update the SNAP retailer stocking requirements (including how “variety” is defined). NACS filed public comments on behalf of the industry cautioning that the proposal, as drafted, could reduce SNAP access by making compliance unworkable for many small-format stores, particularly due to how the rule treats the grains and dairy categories.

Retail Impact

Many financially challenged Americans rely on convenience stores to redeem their SNAP benefits, especially in both urban and rural areas where they do not have access to traditional grocery stores or because they shop during hours when larger format food stores may be closed. The local convenience store is often their only outlet to redeem this benefit.

To participate in SNAP, convenience stores must meet so-called “depth of stock” requirements that specify the amount and types of foods they must have available on their shelves for customers. The 2014 Farm Bill expanded these requirements. Subsequently, FNS finalized a rule in 2016 enacting the depth of stock provisions as well as additional provisions.

Under the 2016 Final Rule, to participate in SNAP, convenience stores must:

  • Stock 7 varieties of foods in each of the 4 staple food categories: (1) protein, (2) grains, (3) vegetables or fruits, and (4) dairy
    • There must be at least 1 perishable food item in 3 of the categories.
    • Stores must have three units of each variety (84 total items) on shelves. 

Meeting the new requirements can be difficult for convenience stores and other small format retailers who face constraints on supply and delivery. On average, convenience stores get food deliveries 1-2 times a week, which can make stocking certain foods, particularly perishable foods, difficult. Convenience stores have limited space and storage. The average convenience store is approximately 3,600 square feet – over 11 times smaller than the average supermarket. This means that convenience stores have limited space in which to display and store products, particularly perishable products that must be refrigerated or frozen.

In its final rule in 2016, FNS defined what counts as “variety” in an overly narrow way where a retailer can only count one item per species (i.e. if you stock sliced ham and a can of pork sausages as two separate varieties – only one can count as pork). As defined in the 2016 final rule, the definition of “variety” would present significant compliance challenges for small format retailers. In its proposed rule published in September 2025, FNS redefined what qualifies as “variety” in the staple food categories in ways that would make compliance more difficult for convenience retailers, particularly in the grains and dairy categories.

NACS Position

It is critical that Congress and the Trump Administration understand the important role convenience stores have in SNAP. Convenience stores represent 45% of all retail outlets authorized to accept SNAP benefits. They are intensely local businesses that serve as a gathering place and source of community pride and offer an ever-growing range of products and services.

NACS has long advocated for FNS to expand the definition of variety and believes that the agency’s 2025 proposed definition does not provide retailers with more flexibility to meet their requirements in grains and dairy. NACS filed public comments on the proposal and will continue to work with policymakers to ensure the final rule provides the greatest possible flexibility for the program’s retail partners.