On May 7, 2018, the U.S. Food and Drug Administration (FDA) began requiring restaurants with more than 20 locations to provide specific nutrition info on menus. With calorie and nutrition details available, the goal is for consumers to make informed food choices when eating away from home.

The following questions and answers are divided into two parts. First, questions about the FDA requirement itself. Second, the analysis process and how Food & Drink Resources (FDR) can assist in the process.

This article was originally published in early 2018; revised March 2024

Menu Labeling Requirement FAQs

Question: What Exactly Does The FDA Require Of Restaurants?

Answer: Generally speaking, multi-location restaurants with 20 or more locations are required to post calorie information for all standard menu items. The information must appear on menu boards, including digital menu boards, and handheld menus, including online menus. These same restaurants must also provide a full nutritional analysis for customers upon request.

Q: What Needs To Be Included In The Full Nutritional Analysis ‘Available On Request’?
A: When a customer requests the full analysis, they need to be able to view the following: total calories; total fat; saturated fat; trans fat; cholesterol; sodium; total carbohydrates; sugars; fiber; and protein.

Q: What Are The Two Blanket Statements Required For The Full Analysis ‘Available On Request’?
In addition to the nutritional stats listed in the question above, the document must also contain these two statements: “This written information is available upon request” and “A daily caloric intake of 2,000 calories a day is used for general nutrition advice, but calorie needs vary.”

Q: Why Does The FDA Require Nutrition Info To Be Posted?
A: According to the FDA, Americans consume 1/3 of their calories away from home. It’s believed that if consumers have easy access to nutrition facts in restaurants (like they do in grocery stores), then consumers will make healthier food and drink choices.

Q: What If A Brand’s Locations Offer Different Menu Items?
A: The rule applies to restaurants where all 20+ locations are doing business under the same name and “offering for sale substantially the same menu items.”

Q: What About Self-Serve Situations?
When food is on display or for self-serve and is not listed on a menu or menu board, calories must be posted nearby in an obvious manner.

Q: Does The Rule Only Include Restaurants?
The FDA nutrition labeling rule covers any foodservice organization including restaurants (quick service and sit-down), grocery and convenience stores, food takeout facilities and delivery services, entertainment venues, cafeterias, coffee shops, superstores, and some managed food service operations

Q: Are There Foods That Are Exempt?
Yes, custom orders, daily specials, temporary menu items, foods part of a market test, and general-use condiments do not require nutrition labeling.

Nutritional Analysis FAQ

Q: How Can Food & Drink Resources Assist Restaurants With Labeling Requirements?
A: FDR has an in-house dietitian/nutritionist, Stephanie Beaudette, who is equipped and experienced in labeling for both restaurants and food manufacturers. She has more than 25 years of experience as a registered dietitian and has a savvy ability to make ingredient substitutions when it is in your best interest. (More info on our services here.)

Additionally, our chefs work together with Stephanie to re-formulate recipes, if need be, so you can count on a complete service.

Q: How Does Analysis Work?
Using a combination of USDA and regulatory-compliant food databases, along with industry best practices, the FDR team will analyze all of the ingredients of your recipes to determine all nutrition facts and provide that information to you in an FDA-approved format.

Q: What Happens After the Analysis?
A: Once you have determined the calorie content and all nutrition facts for your dishes, two things will need to happen. 1) You’ll need to assess the nutrition facts from a sales and marketing perspective. If you think calorie content will negatively impact sales, it’s time to consider a recipe re-development. 2) You will need to re-create all menu signs and menu boards to include calorie content.

Q: Does FDR Do Recipe Re-Development?
A: FDR manages restaurant menu development from A to Z. Starting with recipe innovation and finishing with nutrition labeling on your menus. Recipe development and re-development is one of our specialties. We are also equipped to do on-the-spot consumer research to ensure the new recipe will satisfy your target customers’ tastes.

Q: How Do You Notify The FDA?
Within 4-6 weeks of analysis, you must supply the FDA information to substantiate the nutrient values such as information from nutrient databases or laboratory analysis and copies of nutrition facts labels, cookbooks, and calculations. The FDA also requires signed statements to verify the information is complete and that the establishment has taken reasonable steps to ensure that the method of preparation and the amount of the standard menu item offered for sale are the same as that on which the nutrient values were determined.

Q: How Long Does This Process Take?
A: Anywhere from two to six months depending on what you need.

Q: How Do We Get Started?
A: Request a bid!

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