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.