Updated FDA Menu Labeling Requirements for Restaurants

[et_pb_section fullwidth=”off” specialty=”off” transparent_background=”off” background_color=”#ffffff” allow_player_pause=”off” inner_shadow=”off” parallax=”off” parallax_method=”off” module_id=”articlepardot”][et_pb_row][et_pb_column type=”2_3″][et_pb_video admin_label=”Video” src=”http://youtube.com/watch?v=HwjoDGQfVBA&feature=youtu.be” /][et_pb_text admin_label=”Text” background_layout=”light” text_orientation=”left”]The FDA recently released updated its menu labeling requirements guideline. Since we realize not everyone has the time to read this 53 page document we thought we’d run through the highlights for what we thought was most notable in the new release. You can watch a three minute overview by WAND Digital Guru Jason Bates above or read the summary below.

Enjoy. 🙂

You must identify the calories using Calories or Cal. Let’s start with something easy; the guidelines tell explicitly say you must label the calories using the word Calories or Cal, either as a column heading or next to each calorie count.

You must round the number of calories. The FDA menu labeling guide part two states quite clearly states you should round the number of calories as follows:

  • Fewer than 5 calories – round to 0 o 5 calories
  • 5-50 calories – nearest 5 calorie increment
  • More than 50 calories – nearest 10-calorie increment

There are a number of items that are exempt from the rule. These are the items the FDA says you do not need to post caloric counts for:

  • Condiments for general use (e.g. on counters, tables, etc.)
  • Daily specials only offered that day
  • Temporary menu items (LTOs offered 60 days or less)
  • Custom order created specifically at the customer’s request
  • Food that is part of a test (offered for less than 90 days)
  • Alcoholic beverages on display (e.g. bottles of alcohol displayed behind a bar)

When using Digital Menu Boards you only have to list the standard caloric statement once. If you’re using digital menus that rotate content frequently, the standard statement “2,000 calories a day is used for general nutrition advice, but calorie needs may vary” only needs to be listed on the boards which list standard menu items and prices. To clarify, if you have a five board display and three boards show menu item lists and two boards show promotional LTOs, you only need to list the statement on the three boards showing menu item lists.  

The caloric statement needs to be listed at the bottom of your menu. The FDA has clarified that the “2,000 calories a day is used for general nutrition advice, but calorie needs may vary” should be listed at the bottom of your menu board, above, below or besides the “additional nutritional information available upon request” statement.

There is a different statement to use on children’s menus if you wish. The FDA requires you include this statement on your menus “2,000 calories a day is used for general nutrition advice, but calorie needs may vary.” However, children’s menus can use the following statement “1,200 to 1,400 calories a day is used for general nutrition advice for children ages 4-8 years and 1,400 to 2,000 calories a day for children ages 9/13 years, but calorie needs may vary.” You can use the children’s statement on your children’s menu if you see fit. 

You only have to list calories once. If the name, price and calories of the combo meal are listed in one section of a menu then you do not need to list the calories for that combo meal beneath its photo in another part of the menu. For example, if you are featuring a photo of a Double Cheeseburger combo meal as a promotional call-out on your digital menu board and the combo name, price and calories are also listed under the “combos” section of your menu then you do not have to include the calorie counts under the promotional photo of that combo.  

You do not need to list combined calorie counts when menu items are listed separately. When running a promo such as “combine any soup and salad for $7.99” you do not need to list combined calorie counts as long as each item they can choose is already listed on the menu with its calorie counts next to it.

When posting calorie information on the sneeze guard be sure to label food clearly. If your restaurants use a sneeze guard be sure you’re clearly labeling the items on display (e.g. tomato basil soup, 200 calories per scoop). Also, if your menu with calorie counts is posted at the start of your self-serve line, but not visible by the time the customer moves down the line then you need to post calorie counts in another area towards the end of the line, or on the sneeze guard.

For buffets you must list each calorie counts by each standard menu items. Pretty self-explanatory here folks, but you need to clearly display the calorie counts next to each menu item in your buffet. Also, you can use the serving utensils as the measurement (e.g. 100 calories per serving), assuming your serving utensils serve up a standard serving portion size.

Calorie information for self-serve beverage dispensers or fountains should be posted in terms of calories per cup. For these type of self-service areas you must declare the total number of fluid ounces in the cup offered (e.g. 150 calories per 12 fluid ounces – small). You’ll need to post calorie counts for each size cup offered. Do not take into consideration ice when it comes to this part of requirement, the amount of calories should be based on how many ounces can fit into the cup without ice.

If you are making a health-based claim on an LTO, you need to have proof to back it up. The labeling guide states that in the result that you are promoting an LTO that is not required to show calorie counts but does make a health claim (e.g. Low sodium and less than 15g of fat) you need to either include that item where you include your other nutritional information for all menu items, or have information available (in the form of a card, poster, handout, website, etc.) for customers specifically regarding your LTO health claim.

Some of the topics we didn’t cover here which the FDA has explored more in-depth in their updated guidelines include; definitions for covered establishments, written nutrition information requirements, how to determine nutrient values for foods, requirements for alcoholic beverages and requirements for grab-and-go/self-service foods. The full FDA menu labeling guidelines part two document can be downloaded from the FDA website.[/et_pb_text][/et_pb_column][et_pb_column type=”1_3″][/et_pb_column][/et_pb_row][/et_pb_section]

Is the FDA Menu Labeling Requirement Going to Hurt my Restaurant Sales?


One of the questions we are frequently getting from customers is how the FDA menu labeling requirement mandating caloric counts on restaurant menus will hurt their sales.

It’s a tricky question, but here’s our answer.

Because the FDA caloric bill has not yet gone into effect for compliance nationally, research is relatively sparse in this area. While states like New York and California have had this requirement in place for many years now, much of the sales data is proprietary and very specific to each brand.

That said, there are several ‘self-published’ findings from many large brands. These should be taken with a grain of salt since these findings are published by the brand, but by and large they generally show no decrease in revenue after introducing caloric labeling. The findings also indicate a drop in average caloric value of an order, which would indicate that customers are generally opting towards lower calorie options, even if they are equivalently or more expensive.

Also, as we mentioned in the webinar we did on this topic, this information is very brand specific – brands like Starbucks cultivate an image of healthy options, good for you foods, and generally healthy offerings, and have seen no drop in reported revenue. Conversely, brands like Chipotle have embraced their high caloric values, and are self-reporting that this has actually increased their revenue in the long run in states where compliance is already mandatory.

The advice we’ve given all clients is to develop a strategy around adding caloric counts to your menus that works for your restaurant. Every restaurant concept is unique with different customer expectations. Do some strategizing to figure out what will work best for you.

Need more details on the FDA menu labeling requirement? Check out the National Restaurant Association’s comprehensive resource center.

Preparing for the FDA Menu Labeling: Part Five of Five

Over the past few years, many QSR and Fast Casual concepts have made the switch to Digital Menu Boards in preparation for the upcoming FDA menu labeling requirements. In some states it’s actually already been a requirement for them to meet this mandate.

One of the first questions we get from customers who have made the switch is “now what?” It is easy to put static content on a digital menu board but the real value is in optimizing your assets for the digital medium.  There are endless content strategies that can be employed to maximize product awareness and drive customer behavior.

Below are a few general digital menu board pro tips:WAND Pretzelmaker FDA Menu Compliant

Make them dynamic. There is a reason humans like to watch TV: we’re attracted to dynamic video content. Incorporate dynamic content such as videos and animated movement into your menu boards. It can be a big bold statement if that is on brand or it can be something as simple as showing the steam coming off a cup of coffee. Either way, incorporating movement into your content makes your menu boards more engaging.

Keep animations short and sweet. Just like the typical TV commercial, customers have a tolerance for motion graphics. We advise clients to have promos running for no more than 15 seconds each.

Use all your screens. There are very few restaurants that have just one menu board, typically there are between four to six screens per location. Take advantage of multiple-screens to create unique video content that uses all of them. An example is the full-board take over where all your screens suddenly cut to a short promo for an LTO or special exclusive, in-store only content. It’s a great way to get customers attention and build product awareness.

Change them frequently. With static boards, rolling out an LTO can be cumbersome, time-intensive and costly. With digital you have the ability to update content quarterly, monthly, weekly or daily if you choose. Changing up offers frequently allows you to get the most profitable promos and items in front of your best customers on a regular basis. Plus, you have the flexibility to add or remove content to quickly address supply situations and compliance needs. The power is in your hands.

When you invest in Digital Menu Boards, make sure you are getting the most out of your investment. Hold a brainstorming session with your creative team, look at your marketing calendar and really think about how you can use this channel to increase sales and profits.

Preparing for the FDA Caloric Menu Labeling: Part Three of Five

As we’ve been working through updating our customers’ Digital Menu Boards for the upcoming FDA caloric menu labeling requirements deadline, there’s something really awesome I’ve noticed: lots of restaurants are making the caloric count requirement work for them by creating some truly fantastic promotions in their restaurants.
WAND POP ChickenI thought I’d share a few calorie count promotional ideas of my own to help get you thinking about creative ways you could use this requirement to your advantage in your QSR or Fast Casual restaurant.

5 Under 500
Think about offering something with a clever alliteration such as 5 under 500. This type of promotion is short and catchy and allows you to highlight a number of menu items at once. It’s also easy for customers to grasp the concept right away so if they are in a rush and calorie conscious they can quickly decide what they want.

Daily Calorie Buster
If you have Digital Menu Boards a good promo idea is a daily or weekly Calorie Buster where you can highlight a different menu item that is a lower calorie option for customers to choose. With a name like Calorie Buster you could run some pretty cool dynamic video content to really grab customers’ attention.

Mix ‘n Match 400 Calorie Combos
Customers like to have things created customized for them so another fun idea is to do some sort of mix and match menu where they can choose a couple items to match together to equal a certain calorie amount. It allows you to let your customers choose the menu items they want at the calorie count they desire.

100 Calorie Power Ups
Another idea is to do something like a 100 Calorie Power Up menu, a short list of menu items for customers to choose from. A promo like this is great for adding extra items onto meals and is good for customers who are just stopping for a beverage or dessert. It’s also an easy thing to add onto an order.

I encourage everyone in the QSR/Fast Casual restaurant industry to take a look at how you are embracing calorie counts in your stores in lieu of the FDA caloric menu labeling requirement. When you apply a bit of creativity and have fun with your brand customers will respond and your sales will ultimately increase.


Preparing for the FDA Menu Labeling Requirement: Part One of Five

WAND Digital Menu BoardsGiven our love of menu boards and the impact the FDA ruling has on them, I thought it prudent to start a blog series sharing some advice on how to best prepare. Today’s post is my first of five on this topic. Here are some key facts on the new FDA menu labeling requirement and what they mean for you.

Who. Restaurants with 20+ locations with the same name offering virtually the same menu.
What it means for you: If you’re a QSR/Fast Casual restaurant I’m guessing you fall into this category so the mandate will apply to you. If you’re a chain with less than 20 locations this mandate doesn’t technically apply to you, but if you’re planning to grow your business you definitely want to follow these requirements as you create new menus.

What. Calorie counts on menus (obviously).
What it means for you: You’ll need to label all the major, permanent items on your menus, with a menu (as defined by the FDA) as being any written item that customers will use to make their food selection. The exception to this rule is any seasonal item that is offered for 60 days or less.

When. December 1, 2016. That’s the date the FDA has decreed this mandate to be effective.
What it means for you: You’ll need a formal plan in place ASAP (if you don’t have one already). I recommend designating someone in your organization as the champion of this cause to ensure all requirements are met. The most likely person is someone on your quality control team.

Where. Anywhere your menu is displayed.
What it means for you: You’ll need to make sure each and every menu is updated with calorie counts. This includes menu boards, in-store printed menus, outside menu displays, take-out/delivery menus, online menus and menu apps.

How. Every situation is different.
What it means for you: There’s no one right way to do this. For some restaurants it may be to use the process you have in place currently to update your menus. For others it may mean it’s time to make some changes such as replacing paper menus with online menus or switching from static menu boards to digital menu boards. It’s going to be up to each chain to determine the best approach for how to comply with this mandate given the resources you have.

I personally think the FDA menu labeling requirement is a great thing as it allows chains to be more transparent with guests and build more trust and credibility with the brand. It’s a very exciting time for the restaurant industry. Stay tuned for my second post on this topic coming soon.