How to Present Required Nutrition Information on the Menu

How to Present Required Nutrition Information on the Menu By Anita Jones-Mueller, MPH, President and Sara Lucero, Director of Content, Healthy Dining
January 30, 2017

If you’ve spent time examining the FDA’s menu labeling guidance document, the final rules and final guidance, you’re aware that as of May 5, 2017, covered establishments will need to do much more than just print calories on the menu.  From statements on menus and menu boards to written nutrition information available to guests, restaurants subject to the final rules have much to consider and accomplish before the May deadline.  This includes presenting required calorie information on menus and menu boards in a clear manner that complies with detailed menu labeling guidelines. 

General Posting Requirements
In addition to the required statements on the menu, each standard menu item listed on the menu or menu board will need to declare the corresponding calories in accordance with what’s “usually prepared and offered for sale.”  In some cases, this may be as easy as posting a total calorie count adjacent to the item, and in some cases, more extensive disclosures may be required.  According to the FDA’s menu labeling regulations, the number of calories for each covered menu item must be:

  • “Adjacent to the name or the price of the associated standard menu item;
  • In a type size no smaller than the type size of the name or the price of the associated standard menu item, whichever is smaller;
  • In the same color, or a color at least as conspicuous as that used for the name of the associated standard menu item; and
  • With the same contrasting background or a background at least as contrasting as that used for the name of the associated standard menu item.”

Healthy Dining Dietitian Insight
According to FDA menu labeling regulations, the rounding guidelines used for calories on packaged foods will also apply to calories posted on restaurant menus and menu boards:

“You must declare calories to the nearest 5-calorie increment up to and including 50 calories and to the nearest 10-calorie increment above 50 calories, except that you may express amounts less than 5 calories as zero.”

“Experienced nutrition providers work regularly with FDA’s rounding guidelines and are familiar with the requirements for each required nutrient.  Working with an expert like this can provide added peace of mind not only during the nutrition analysis process but also when it comes time to print required calories on your menu or menu board,” says Nicole Ring, R.D., VP of Nutrition Strategy at Healthy Dining.
 

In addition, FDA menu labeling guidelines specify that along with the number of calories on the menu or menu board, “Calories” or “Cal” must be posted as a column heading or adjacent to the number of calories.  As with the number of calories, these descriptions must also meet certain requirements in order to be considered compliant with menu labeling regulations.

These general guidelines may cover a portion of menu items subject to menu labeling regulations, but not all.  More complex offerings such as variable items and toppings will require more than just a single number of calories printed on your menu.

Multiple-Serving Standard Menu Items
Whether it’s an appetizer, a family-style entrée or a pizza selection, many restaurants offer menu items that that are considered “multiple-serving.”  In these cases, the FDA regulations provide two options for calories disclosures:
  • “For the whole menu item listed on the menu or menu board as usually prepared and offered for sale (e.g., “pizza pie: 1600 cal”); or
  • Per discrete serving unit as long as the discrete serving unit (e.g., pizza slice) and total number of discrete serving units contained in the menu item are declared on the menu or menu board, and the menu item is usually prepared and offered for sale divided in discrete serving units (e.g., “pizza pie: 200 cal/slice, 8 slices”). 
Whichever disclosure option you choose for your restaurant, print size and placement of calorie information should adhere to the general guidelines above.

Variable Menu Items
Guests have increasingly demanded a variety of options both for taste preferences and health reasons.  As such, many menus now offer variable menu items.  In addition to general requirements, variable menu items must also comply with the following FDA regulations:
  • “When the menu or menu board lists flavors or varieties of an entire individual variable menu item (such as soft drinks, ice cream, doughnuts, dips, and chicken that can be grilled or fried), you must declare the calories separately for each listed flavor or variety.   Where flavors or varieties have the same calorie amounts (after rounding) the calorie declaration for such flavors or varieties can be listed as a single calorie declaration adjacent to the flavors or varieties, provided that the calorie declaration specifies that the calorie amount listed represents the calorie amounts for each individual flavor or variety.
  • When the menu or menu board does not list flavors or varieties for an entire individual variable menu item and instead includes a general description of the variable menu item (e.g. “soft drinks”), you must declare the calories for each option as follows:
    • With a slash between the two calorie declarations where two options are available (e.g., “150/250 calories”); or
    • As a range where more than two options are available (e.g., “100 - 250 calories”).
  • When the menu or menu board describes flavors or varieties for only part of an individual variable menu item (such as different types of cheese offered in a grilled cheese sandwich [e.g., “Grilled Cheese (Cheddar or Swiss)”], you must declare the calories for each option as follows:
  • With a slash between the two calorie declarations where only two options are available (e.g., “450/500 calories”); or
  • As a range where more than two options are available (e.g., “450 - 550 calories”).”
Toppings
Burgers, sandwiches, pizzas and so many other menu choices now include options for various toppings to help customize creations.  If these toppings are standard menu items, they are covered by the FDA’s menu labeling regulations and therefore require calories be posted on the menu.  In addition to the general posting guidelines, toppings on the menu or menu board require restaurants to:
  • “Declare the calories for the basic preparation of the menu item as listed (e.g., “small pizza pie,” “single scoop ice cream”).
  • Declare the calories separately for each topping listed on the menu or menu board (e.g., pepperoni, sausage, green peppers, onions on pizza; fudge, almonds, sprinkles on ice cream), specifying that the calories are added to the calories contained in the basic preparation of the menu item. 
Even when it comes to offering toppings, restaurants vary.  For this reason, the FDA menu labeling regulations provide specific guidance and examples for a variety of situations including:
  • Toppings with the same amount of calories – which can be listed as a single calorie declaration adjacent to the toppings, “provided that the calorie declaration specifies that the calorie amount listed represents the calorie amount for each individual topping.”
  • Menu items that come in multiple sizes – “The calories for each topping listed on the menu or menu board must be declared for each size of the menu item, or declared using a slash between the two calorie declarations for each topping where only two sizes of the menu item are available (e.g., “adds 150/250 cal”) or as a range…where more than two sizes of the menu item are available (e.g., “adds 100-250 cal”). If a slash between two calorie declarations or a range of calorie declarations is used, the menu or menu board must indicate that the variation in calories for each topping arises from the size of the menu item to which the toppings are added.
  • A decrease in the amount of toppings as more toppings are added – In these instances, “You must declare the calories for each topping as single values representing the calories for each topping when added to a one-topping menu item, specifying that the calorie declaration is for the topping when added to a one-topping menu item.”
 
Healthy Dining Dietitian Insight
Many restaurants now offer extensive lists of combinations and toppings to allow guests to customize and personalize any meal.  In the interest of consistency, the FDA’s menu labeling regulations require disclosure of nutrition for these standard toppings and combinations in very specific formats.  Working with a menu labeling expert can help ensure that your restaurant is not only providing accurate nutrition information but also in compliance when printing that information on the menu, menu boards and additional written nutrition information.

 
 
Combination Meals
According to the FDA, a “combination meal” is defined as a standard menu item that consists of more than one food item, for example, a meal that includes a sandwich, a side dish, and a drink.

Where a combination meal is not listed on a menu or menu board as a variable menu item but is instead listed as a menu item that comes in only one flavor, variety, or combination, the combination meal would have a “default build.”  As with a combination meal that comes in different sizes, in this situation, the FDA rule requires the covered establishment to provide the number of calories contained in the combination meal listed on the menu or menu board as usually prepared and offered for sale.

As with variable menu items and toppings, FDA menu labeling regulations require calories and additional nutrition information for each option available.  Specifically:
  • “When the menu or menu board lists two options for menu items in a combination meal (e.g., a sandwich with a side salad or chips), you must declare the calories for each option with a slash between the two calorie declarations (e.g., “350/450 calories”).
  • When the menu or menu board lists three or more options for menu items in a combination meal (e.g., a sandwich with chips, a side salad, or fruit), you must declare the calories as a range (e.g., “350-500 calories”).
  • When the menu or menu board includes a choice to increase or decrease the size of a combination meal, you must declare the calorie difference for the increased or decreased size:
    • With a slash between two calorie declarations (e.g., “Adds 100/150 calories,” “Subtracts 100/150 calories”) if the menu or menu board lists two options for menu items in the combination meal; or
    • As a range (e.g., “Adds 100-250 calories,” “Subtracts 100-250 calories”) if the menu or menu board lists three or more options for menu items in the combination meal. “

Healthy Dining Dietitian Insight
“If you haven’t already, now is the time to get started with menu labeling compliance. Completing nutrition analysis, verifying the accuracy of nutrition information and properly disclosing required nutrition information in your restaurant can take time and should all be high priorities as the compliance date approaches,” stresses Nicole Ring, R.D.

 
 
Where are you in the menu labeling compliance process? How are you planning to implement these changes across locations to improve operations while complying with regulations?