As restaurant operators continue to prepare for the May 5, 2017, menu labeling deadline, many questions and challenges remain. I see this daily as my team continues to field calls from operators looking for further guidance and understanding.
Establishments that don't check every box by the end of inspection will be deemed "not compliant" with the FDA's mandated menu labeling requirements. Use this checklist to ensure all your bases are covered.
- Calories are next to the name or price of every standard menu item on every menu/menu board.
- Calories are the same size as the menu item name or price.
- Calories are in a font color that is the same as the name or price of the menu item, or in a color that is equally easy-to-read.
- Calories are rounded per FDA specifications.
- Slashes (two menu item options) and dashes (three or more menu item options) are used correctly.
- Food-on-display and self-serve food are labeled with calories and the correlating serving size.
- Caloric values look reasonably accurate given the description of the menu item.
- The two disclaimer statements are adjacent to one another at the bottom of the menu/menu board, and are in a font size no smaller than the smallest calorie declaration.
- Additional nutrition information is available upon request (if electronic is a method of obtaining that information given to you).
- The establishment can provide the two levels of certifications within a reasonable time frame.
So far, the biggest challenge to the regulation has come in the form of rounding up some of the caloric and nutritional information displayed on menu boards. This is because each nutrient has to be rounded in a certain way and it's not all common sense.
For example, items that have up to 50 calories must be listed in the closest five-calorie increment. Items that contain 50 calories or more must be rounded to the nearest 10-calorie amount. Items that have less than five calories can be listed as zero. In regard to the additional nutritional information upon request, if a covered establishment chooses to round those numbers, they must match the FDA's rounding rules regarding packaged goods for retail.
Another challenge surrounds serving size and weight. The FDA is not requiring that a serving size or weight be listed for each item on menu boards or menus. This information is also not required on additional nutrition information. However, you must make it clear to guests concerning exactly what they are getting for the listed caloric amounts. For example, salads that come with dressing must be listed as such, and you must also account for all condiments that are regularly included on sandwiches.
Multi-serving dishes, such as appetizers and desserts — which may actually be intended for more than one person — must be listed as their total amount, unless there is a clearly "discernible serving unit," like that in an order of bread sticks, a large, sliced pizza or a basket of cookies. In only those cases, nutritional information may be listed for "one each," instead of for the total batch. You may also list both total and individual serving values, according to the FDA.
It remains unclear as to exactly when health inspectors will begin making restaurant rounds, but thorough advanced preparation will always yield the best results for restaurant operators.
Topics: Health & Nutrition
Betsy Craig / Betsy Craig brings 20 years of food service industry experience to MenuTrinfo, LLC a menu nutritional labeling Company. Her commitment to the betterment of the food industry and her desire to affect the dining public are the driving forces behind her new company Kitchens with Confidence, LLC.