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The charitable food system distributes free food to clients across the U.S. Still, many nutrition and health-focused efforts need help to succeed, which was exacerbated during the COVID-19 pandemic. To understand barriers and facilitators across the spectrum of the Social-Ecological Model to distributing nutritious, fresh foods in food pantries across Illinois during the COVID-19 pandemic. Forty-nine representatives of Illinois food pantries were recruited to participate. All focus groups were held via an online platform in October 2021. A script was developed to facilitate a discussion about the challenges and opportunities faced in distributing fresh foods in pantries. The script included a definition of what fresh foods were (and were not), followed by 11 open-ended questions about representatives' experiences and perceptions with follow-up prompts and probing questions. After review from external colleagues, the script was updated to improve flow and clarity. After data collection, a codebook was created based on relevant literature, common themes heard in recordings, and stakeholder interests. Transcripts of each group were coded and analyzed using a basic interpretive approach. The analysis of focus group transcripts resulted in challenges and opportunities, which were organized into five distinct levels of influence, mirroring aspects of the Social-Ecological Model to include 1) societal, 2) community, 3) organizational, 4) interpersonal, and 5) product. Many pantry representatives felt they offered a wide variety of fresh foods that met the client's health needs. However, distribution of fresh foods was impacted by community partners, food bank policies and practices, and the quality of the donated fresh foods. Furthermore, the physical limitations of pantries limited fresh food storage capacity. The COVID-19 pandemic posed unique stressors that highlighted additional opportunities for the charitable food system. Future studies should evaluate the effects of the suggested initiatives and changes at the food pantry, food bank, and policy levels. None [ABSTRACT FROM AUTHOR]