The requirement for facilities to prepare or serve food and drinks for pupils was clear in the previous Standards for School Premises that came into force in 1999.
They also encouraged the inclusion of cold storage for sandwiches and similar items brought into school by pupils.
The wording of the new rules is vaguer and Bull believes this will leave them wide open to interpretations that affect the quality and capacity of school catering facilities.
She said: “As part of the Government’s targets for reducing obesity levels and its aim to improve children’s health through better diets and lifestyles, school meal providers are expected to prepare nutritious meals from fresh ingredients.
“Not having kitchen and dining facilities clearly specified within the new school premises regulations shows a worrying contradiction in policy.
“Complying with the nutritional standards for school food provision is mandatory by law in all maintained schools in England.
“These require schools and caterers to provide a daily meal for pupils and a Free School Meals service for those children and young people who are eligible.
“It would be impossible for them to comply with the law without appropriate kitchen and dining facilities being retained by head teachers and also included in the planning for new school builds.”