Back by popular demand, we have compiled some of most frequently asked menu labeling questions to our nutrition team over the past two months. As menu labeling is fast becoming a reality for numerous restaurants and similar retail food establishments, a lot of questions are arising as to what exactly will be required from them. As we approach the December 1st deadline (we’re only 9 months out)*, it’s a great time to start planning menu board updates to beat the rush come fall of this year.
How does my buffet/salad bar need to be labeled?
Every item on a self-service line, such as a buffet or salad bar, must have calories labeled. When determining the serving size to base the caloric values off of, the FDA has come up with a list of preferred options, which is as follows:
- By “each” (i.e. one chicken breast, one muffin, etc.)
- By serving utensil, if it dishes out a uniform amount (i.e. one ladle of salad dressing)
- By common household measurement (i.e. one cup of lettuce)
- By weight (i.e. 4 oz of potato salad)
If you offer an option for your guests such as an “all-you-care-to-eat” buffet or bottomless salad bar, then you must have a statement next to the item on your menu that reads, “See buffet for calorie declarations.” That lets the consumer know that he or she will need to keep track of the portions of each item they select to get to the final caloric value of their menu.
Do I need to label ALL my menus, or can I just have calories on the main dinner menu since that’s the one most of my customers look at?
Any piece of writing that contains the name or picture of a menu item, the price, and that the consumer can use it to make their selection must have calories listed. This includes the main dinner menu and also the lunch menu, drink menu, dessert menu, drive-thru menu boards, in-store menu boards, take-out menus, catering menus, etc. Even if there are repeating menu items between two different menus (for example, desserts are listed on the main dinner menu but there is also a separate dessert menu for after dinner), the calories must be listed in both places because the customer could use either one to make his or her selection.
For the additional nutrition information that must be available upon request, does the formatting and order of menu items have to match that of my menu?
The additional nutrition information can be formatted in a manner that is best suited for the menu items. While this may be in a similar order as the menu, the FDA is allowing for some flexibility on this format. This information can also be presented in a manner that is best suited for the establishment. For example, a binder with the information or an electronic device with a copy of the information can be used given to diners upon request.
My restaurant is located in a county that has menu labeling guidelines already enforced. Do I need to follow my county guidelines or the guidelines that will be enforced in December?
While you do have a head start on menu labeling for your restaurant if you’re already in a covered city or county, restaurants with 20 or more locations will be expected to comply with the federal guidelines that will be enforced on December 1, 2015.* For restaurants with 20 or more locations, the FDA regulations will trump any others that are currently in place in some states or counties. If your restaurant does not meet the specified location requirement, voluntary registration to comply with FDA regulations is available. This would result in the requirement to meet federal standards rather than any local nutrition regulations.
*This blog was published prior to the change in deadline for menu labeling. The deadline is now December 1, 2016.
