The cart is overflowing with groceries as the shopper finally reaches checkout after waiting in a long line that still snakes down the aisle behind her.

The hardworking associate quickly and efficiently rings up each item until, near the end, one scans as ineligible under the Supplemental Nutrition Assistance Program (SNAP). It’s not because the shopper has made a mistake. Rather, it’s because the state has just implemented new food restriction waiver requirements.

The associate hesitates. The shopper looks confused. In that brief moment, policy becomes personal — and operational complexity becomes visible.

As states introduce new SNAP restrictions, product eligibility rules are becoming more nuanced. Nearly $100 billion is spent annually in SNAP benefits, so even incremental changes in how products are defined and restricted can introduce moments like these.

The implications are real for grocery retailers and brands, and how they respond will directly affect the customer experience.

For many grocery retailers, SNAP represents a meaningful share of total transactions. Errors carry both financial and reputational consequences. Increased training requirements and compliance oversight add cost, while inconsistent eligibility at checkout can lead to shopper confusion and dissatisfaction.

The challenge is not simply understanding the new rules; it’s translating them into real-time execution at checkout.

Navigating state-level SNAP differences

For years, SNAP eligibility was relatively straightforward. Non-food items were ineligible, as were hot prepared foods. Most other food items were eligible. Retailers and consumers understood the boundaries.

Today, that simplicity is slipping away.

As of early March, 22 states have received USDA approval for waivers that restrict certain product categories, and many have already begun implementation.

Restriction definitions vary. In some states, beverage eligibility may depend on the percentage of natural juice, while in others, it may hinge on added sugar thresholds. The definition of “candy” can also differ across jurisdictions.

“Eligibility is becoming more nuanced and more complex,” says Kerri Fulton, government policy and regulations director at GS1 US. “Individual states are putting forward their own product restrictions, definitions, and timelines.”

These variations now introduce new operational considerations, especially for retailers managing stores in multiple states. The same product may be eligible in one state and restricted in another. Waivers are implemented at different timelines. Shoppers living near state borders may encounter different rules depending on which state they’re shopping in on a given day.

SNAP-authorized retailers bear primary responsibility for compliance. But translating state-level policy language into consistent checkout logic requires coordination across systems, partners, and product data.

Where execution gets complicated

While checkout systems operate at the SKU level, most state waivers identify broad product categories. And their approaches to defining those categories can vary.

Consider beverages. 

A product with partial juice content may be SNAP-eligible in one state but not in another. Candy definitions may hinge on ingredients or preparation. Without consistent product identification and classification, applying nuanced rules across thousands of SKUs becomes challenging.

Successful implementation depends on the ability to identify products accurately and share relevant information across the supply chain.

Almost every item scanned at checkout is identified by a Global Trade Item Number (GTIN), the number embedded in a UPC barcode. GTINs uniquely identify products across retailers and geographies, forming the backbone of retail transactions.

Beyond identification, structured classification systems such as GS1’s Global Product Classification (GPC) standard provide a consistent way to define a product. GPC organizes products into standardized segments, families, classes, and bricks, enabling brand owners to classify products using a shared taxonomy and pass along that information to retailers.

Retailers then interpret that standardized data within their own systems and apply eligibility logic based on state requirements.

“Implementation on the ground really hinges on being able to identify a product and capture information about it,” Fulton said. “Standards provide a scalable, interoperable foundation.”

In practice, that means retailers can apply different eligibility rules to consistent product definitions, instead of redefining the products for each jurisdiction.

Navigating SNAP changes together

While SNAP-authorized retailers are ultimately responsible for compliance, they do not operate in isolation.

Brand owners can play a role by ensuring that product classification data is accurate and aligned with standardized structures. Retailers can use that information to configure point-of-sale systems and apply state-specific rules.

Fulton notes that many retailers and brands already use established systems and standards to share product data. As SNAP requirements evolve, she sees an opportunity to integrate new considerations into existing frameworks.

“This is a new and unique requirement,” she said. “Instead of going for one-off solutions, this is an opportunity to streamline and integrate with the other systems and standards already in place.”

Isolated adjustments may address immediate needs, but they become harder to manage as additional states introduce variations. Integrating SNAP-related classifications into broader data-sharing practices can help support consistency over time.

Brands that have not yet assessed how SNAP-related classifications are created and applied across their systems may benefit from reviewing product data governance processes now. That includes confirming how products are classified and shared across trading partners. Entering accurate GPC data at the product level supports consistent interpretation at the point of sale.

Retailers impacted by waivers may also consider scenario planning to ensure they can import standardized product data, interpret it correctly, and configure their systems for state-level rules. 

From reaction to readiness

USDA has approved waivers in multiple states, and additional waivers are possible. Now, retailers face a choice: adapt reactively, responding to each new development, or adapt proactively, strengthening the underlying data infrastructure that supports eligibility decisions.

The more variation that emerges across jurisdictions, the more valuable consistent product identification and classification become.

“People are looking for ways to find commonality, scalability, and interoperability,” Fulton said. “That’s what standards are designed to provide.”

So, if we return to that busy grocery store — the conveyor belt filling, the line stretching down the aisle — now things can run more smoothly.

Clear product definitions. Accurate classification data. Systems are aligned before the shopper ever reaches the register.

Now, each product scans as expected.

The line keeps moving.

Customers leave happy, without ever seeing the complexity behind the scenes.