Explaining FDA Menu Label Compliance: 5 Common Myths


As the countdown begins (6 more months) for the Food and Drug Administration’s (FDA) Menu Labeling Requirements, there may still be fuzzy grey areas that have not been clearly defined. Here are 5 common myths the operations need to understand.

Q. If I have 20 restaurants but they are all different concepts with different menus, do I still have to declare calorie counts and portion sizes?

No. The restaurants must be doing business under the same name and over the same core menu. Restaurant Groups with separate concepts must only menu label if there are 20 establishments under the same concept name.

Q. Must I send all of my menu items to a laboratory for analysis?

No, you must meet the FDA Reasonable Basis Standard. Menu items must be analyzed by portion size via a variety of methods.

The USDA nutrient database, available on the USDA website

A software that uses database information to populate nutritional information

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Laboratory analysis

Q. Do I need to also display calorie content on any specials I may run?

Operations must only declare calorie information on standard menu items that are commonly or routinely offered on a menu for more than 60 days. Condiments, daily specials and custom orders are not subject to the labeling requirements.

Q. If my menu items have variations (pizza and combos) will they not be subject to menu labeling?

Incorrect: menu items that come in a variety of flavors, varieties and combos and are offered as a single menu items will still be subject to the labeling requirements. These may include pizza, items that come grilled or fried or soft drinks.

Q. Is alcohol not subject to the menu labeling regulations?

Incorrect: if you have a standard specialty drink or printed drink menu that is standard for 60 or more days, those drinks must declare calorie content. Bottles of liquor that are behind a bar do not fall under the labeling guidelines. Nonalcoholic drinks must also declare caloric information.

Make sure that your operation is compliant by the December 1, 2015 deadline. Analyze whether your operation meets the necessary requirements and take the proper steps to make sure that you have the items analyzed on your standard menu. You have several resources to ensure you are compliant. Contact your back office software company, local laboratory, or do some digging on the UDSA website. If you are not an operation that falls under the compliance radar, you may want to take some proactive steps to be sure you stay competitive in the search for healthy food alternatives.