State-Level Variability in Implementation Approaches to SNAP Food Restriction Waivers: A Content Analysis of Bills, Waiver Requests, and Waiver Approvals

Background: Since 2025, US states have rapidly adopted waivers to restrict the purchase of "non-nutritious items" like soda and candy with Supplemental Nutrition Assistance Program (SNAP) benefits. States have proposed various approaches in terms of food categories restricted and implementation strategies, which may influence the downstream effects of waivers on program participation and participants diets and health. Objective: To examine and describe contextual information related to the adoption and implementation of state-level SNAP food restriction waivers. Design: A content analysis was conducted including publicly available state-level: (1) bills introduced related to SNAP food restriction waivers (2025 to early 2026), (2) waiver requests, and (3) waiver approvals (up to June 2026). Codebooks that captured key elements, such as food and beverage group restrictions and definitions, rationale for restrictions, implementation supports, and evaluation plans, were applied independently by two coders, and discrepancies were resolved through consensus. Participants/setting: United States Intervention: N/A Main outcome measures: N/A Statistical analyses performed: Descriptive statistics were used to summarize the presence of coded elements in documents. Results: Seventy-one bills, 22 waiver requests, and 23 waiver approvals were included. Bills mostly proposed restricting candy (65%) and soft drinks (59%). Of the approved waivers, all restrict the purchase of specific beverage groups with SNAP benefits and 65% restrict the purchase of specific food groups with SNAP benefits. There is a high level of variability in how the same food or beverage groups (e.g., soda) are defined across states. States varied in the implementation supports described in waiver requests, describing strategies like communications plans, nutrition education, and staff training. Conclusions: The current state of SNAP food restriction waivers is highly variable and shifting rapidly. Understanding characteristics of early-adopting states can inform future impact and implementation evaluations of waivers and efforts of additional states that may pursue SNAP food restriction waivers.