FDA Menu Labeling: A Compliance Guide for the F&B Industry

The Food and Drug Administration (FDA) plays a pivotal role in standardizing menu labeling, a critical measure for ensuring informed food choices among consumers. The necessity for transparency in calorie counts and nutritional information on menus has escalated, not merely as a consumer preference but as an essential component of public health awareness. Adherence to FDA menu labeling regulations yields significant benefits. For the public, it facilitates healthier dietary choices through readily available and accurate nutritional data. For businesses within the food and beverage sector, compliance is a legal obligation and instrumental in cultivating consumer trust. 

This article aims to guide you through the intricacies of FDA menu labeling, highlighting the standards for calorie counts and nutrition information, as well as exemptions to the rules and future menu labeling trends. By understanding and implementing these guidelines, your establishment can not only fulfill regulatory requirements but also reinforce its commitment to customer well-being and fortify its market position.


  • FDA Menu Labeling for “Covered Establishments” applies to chains with 20+ locations, offering substantially the same menu items. This includes food service providers like restaurants, grocery stores, cafeterias, and more.
  • Calorie information must be displayed for standard menu items, with a statement about suggested caloric intake and the availability of additional nutritional information upon request.
  • Calorie information for self-service foods and buffet items must be clearly visible, with exemptions for certain items like daily specials. 
  • Calorie information is required for regular alcoholic beverages on the menu, with seasonal items and specials being exempt from these requirements.
  • The total calorie count for combination meals must be displayed, with a range for meals with multiple options. Individual calorie listing for each component is also an option.
  • A legible typeface, adequate size, and contrasting colors are required for calorie information, which must be clearly associated with the corresponding menu item.
  • Digital solutions offer dynamic ways to display nutritional information, with real-time updates and enhanced customer experience. Food Label Maker can assist in integrating nutritional information into these platforms.
  • Anticipated trends include increased demand for transparency, technological integration, emphasis on calorie reduction, and potential expansion of FDA regulations. Predictive analytics and AI could also play a larger role in menu planning and labeling.

Key Aspects of FDA Menu Labeling

“Covered Establishments” under FDA Regulations

The final FDA menu labeling rule, effective from May 7, 2018, specifies the establishments that fall under its purview. “Covered establishments” are defined as

  1. Part of a chain that operates 20 or more fixed locations
  2. Conducts business under the same name or a minor variation of the same name
  3. Offers substantially the same menu items across these locations 

This broad definition also includes a variety of food service providers such as:

  • Quick-service and sit-down restaurants
  • Grocery and convenience stores
  • Food takeout and delivery services
  • Entertainment venues
  • Cafeterias
  • Coffee shops
  • Superstores
  • And some managed food service operations

The intent behind this broad categorization is to ensure that a significant portion of the population has access to nutritional information, which will aid them in making informed food choices a feasible reality across various dining contexts.

Calorie Display Mandates for Standard Menu Items

An important requirement of FDA menu labeling is the disclosure of calorie information for standard menu items. This includes items listed on menus and menu boards, as well as foods on display and self-service foods. Establishments must present a statement regarding suggested caloric intake. It must state that “2,000 calories a day is used for general nutrition advice, but calorie needs vary”. 

This statement must be prominently displayed at the bottom of menu boards and on each page of multi-page menus, as well as adhere to specific size and color requirements. The objective is to provide consumers with immediate, accessible nutritional information at the point of decision-making, empowering them to make choices that align with their dietary needs and preferences.

Nutritional Information Disclosure

How and When Nutritional Facts Need to Be Displayed or Made Available

The FDA mandates that, as aforementioned, calorie amounts need to be displayed on menus and menu boards. Although for additional nutritional information for standard menu items such as fat, sodium, and sugar content, suppliers must have this information available upon request. The FDA requires establishments to state that, “Additional nutrition information available upon request”, so that consumers know they can request and have access to such information. This ensures that customers can make informed choices about their food, particularly in terms of nutritional value.

Self-Service Foods and Buffet Items

The FDA menu labeling rules for self-service foods and buffet items are designed to ensure that consumers have clear and accessible nutritional information, particularly calorie counts, for the food items they are selecting. Here are the key aspects of these rules:

  • Calorie Information Display: Calorie information for each item available at self-service stations and buffets must be clearly visible but can be displayed in a number of ways. It can be done through signs next to the food, by attaching it to a sneeze guard (like using a gel cling or hanging placard), or using a single sign that lists calorie counts for multiple items alongside their names.
  • Standard Menu Items: These calorie labeling rules apply to standard menu items that are routinely included on a self-service buffet or food line, and are regularly offered as part of the day-to-day operations of the establishment.
  • Exemptions: Certain items may be exempt from these labeling requirements, such as daily specials, temporary menu items, or items that are part of a market test.
  • Additional Nutritional Information: While calorie information must be displayed, additional nutritional information, as we have stated, should be available upon request. This information can be provided in various formats, such as brochures, posters, or electronic means.

By following these rules, establishments offering self-service foods and buffet items can help consumers make better choices about their dietary intake when posed with such a large selection of food options to choose from. 

Alcohol, Seasonal Items, and Daily Specials

The FDA’s menu labeling requirements extend to alcoholic beverages offered on the menu. However, there are exceptions for certain seasonal items, daily specials, or items not regularly listed on the menu. These items are not required to have the same detailed nutritional labeling as standard menu items, providing some flexibility for establishments in offering temporary or unique dishes.

Alcoholic Beverages:

  • Alcoholic beverages that are listed on the menu and are part of the regular menu offerings must have their calorie information displayed.
  • This includes mixed drinks, beers, wines, and spirits that are standard items found on your daily operational menu.

Seasonal Items:

  • Seasonal menu items, which are offered for sale as a temporary menu item, are exempt from the menu labeling requirements. This applies to items that are available for less than a total of 60 days per calendar year (either consecutively or non-consecutively).
  • Alcoholic drinks that are displayed but not self-served are also exempt from the menu labeling requirements. For instance, beers available on tap and standard offerings poured by a bartender or water/waitress, are not required to have calorie and other nutritional information labeled on them.

Daily Specials:

  • Items that are offered as a special of the day or as a non-standard, temporary menu item do not require calorie or other nutritional information labeling.
  • This exemption is designed to allow chefs and food establishments the flexibility to change menu items daily without the need for recalculating and relabeling nutritional information.

Market Test Items:

  • Items that are on the menu for less than 90 consecutive days to test consumer acceptance are also exempt from the labeling requirements.

Rules for Combination Meals (e.g., a Combo at Fast-Food Restaurants)

The FDA menu labeling rules for combination meals, such as those commonly found in fast-food restaurants, are designed to provide clear and comprehensive calorie information to consumers. Here’s an overview of these rules:

Total Calorie Display:

  • For combination meals (e.g., a burger with fries and a drink), the total calorie count for the entire meal must be displayed.
  • This means the calorie information should reflect the sum of all items included in the combo, providing a complete picture of the caloric intake.

Range of Calories:

  • If the combination meal has multiple options or variations (for example, different types of drinks or side items), the menu should display a calorie range.
  • This range represents the lowest to the highest calorie count possible, depending on the choices a customer makes within the set options of the combo.

Component Calorie Listing:

  • In addition to the total or range of calories, some establishments may choose to list the calorie content of each component of the meal separately.
  • This approach allows customers to understand the caloric contribution of each part of the meal, aiding in more informed decision-making.

By adhering to these rules, fast-food and other restaurants offering combination meals can ensure they are providing their customers with the necessary information to make informed dietary choices, while also complying with FDA regulations. This approach to labeling helps consumers understand their total caloric intake when selecting combo meals, aligning with the FDA’s goal of promoting public health.

Labeling Design & Presentation

Typeface, Size, and Color Requirements

When it comes to FDA menu labeling, the design and presentation of the information are as crucial as the content itself:

  • Legibility: The typeface used for displaying nutritional information, including calorie counts, must be legible and avoid overly stylized fonts that may hinder readability.
  • Size: The size of the text must be large enough to be easily read by the average person, typically comparable in size to the name or price of the menu item. This ensures that the calorie information is not overshadowed by other text.
  • Color and Contrast: The color of the text and its background should be enough of a significant contrast that the text stands out and is easy to read under various lighting conditions. The goal is to make it easy for customers to read at a glance.

Calorie Counts

  • Visibility: Calorie information must be displayed clearly and prominently alongside the name or price of the menu item.
  • Format: The calorie count must be presented in a manner that is clear and conspicuous. It should be easy for customers to associate the calorie count with the corresponding menu item.
  • Units: The calorie content must be expressed in terms of calories, abbreviated as “Cal” or “Kcal”. For example, “500 Cal”.
  • Context Statement: Menus and menu boards must include a contextual statement about suggested daily caloric intake, such as “2,000 calories a day is used for general nutrition advice, but calorie needs vary.”
  • Consistency in Presentation: The presentation of calorie information should be consistent across all items, making it easy for consumers to understand and compare options.

Digital Menus & Online Ordering Platforms

The integration of technology into FDA menu labeling practices, particularly through digital menus and online ordering platforms, has revolutionized the way nutritional information is presented and accessed. These digital solutions offer dynamic and flexible ways to display menu items and their nutritional content, allowing for real-time updates and ensuring compliance with FDA regulations. This is especially beneficial for items with frequently changing information, like daily specials or seasonal offerings.

Digital displays and online menus

Digital menus not only comply with regulatory requirements but also enhance the customer experience. They provide an interactive platform for customers to easily access detailed nutritional information, including calorie counts and allergen data. Additionally, these menus can be tailored to match the brand’s aesthetic, creating a visually appealing and informative dining experience.

Food Label Maker plays a pivotal role in this digital shift as their services integrate seamlessly with digital menus and online platforms, ensuring accurate and FDA-compliant display of nutritional information. Their tool simplifies the management of menu labeling for food establishments, helping them keep pace with the evolving digital landscape. By utilizing Food Label Maker’s expertise, restaurants, and food businesses can maintain regulatory compliance while enhancing customer trust and satisfaction through clear, accessible nutritional information.

Overall, the move towards digital menus represents a significant change in the food and beverage industry, driven by technological advancements and the need for compliance and customer engagement in menu labeling.

As we look toward the future of menu labeling, several trends and potential changes are emerging, shaped by evolving consumer behaviors and rapid technological advancements. Although studies are still emerging and little research has been conducted regarding FDA menu labeling’s impact on consumers, a few factors are likely to influence the direction of FDA regulations in the coming years:

  • Consumer-Driven Demand for Transparency: Today’s consumers are increasingly health-conscious and demand greater transparency in their food choices. This trend is expected to continue, driving the need for more detailed and accessible nutritional information. As a result, we may see the FDA expanding menu labeling requirements to include more comprehensive nutritional data or to cover a broader range of food establishments.
  • Technological Integration: The integration of technology in menu labeling is set to grow as digital menus and online ordering platforms are becoming more sophisticated. An example of this would be the emerging trend of menus being opened on mobile devices with a QR code or companies like Food Label Maker offering personalized nutrition information based on individual dietary preferences. This could lead to regulations that specifically address digital menu labeling and ensure consistency across various platforms.
  • Health and Longevity Improvements: Studies project that in various settings like coffee shops, restaurants, and some fast-food establishments, FDA menu labeling has been shown to prompt consumers to opt for lower-calorie purchases. This could further suggest a positive long-term impact on public health.
  • Consumer Education: Studies have also shown that consumers are slowly becoming more educated about the calorie content and nutritional value of the food they are eating at restaurants and establishments that sell food due to menu labeling. 
  • Calorie Reduction: Menu labeling has been associated with a decrease in the calorie content of restaurant offerings. In the future, we can expect more emphasis on calorie reduction as a result of menu labeling, potentially leading to healthier menu options.
  • Predictive Analytics and AI: The use of predictive analytics and AI in menu planning and labeling could become more prevalent. These technologies can help predict consumer preferences and dietary trends, leading to more dynamic and responsive menu labeling. The FDA might adapt its regulations to accommodate these innovations, ensuring that labeling remains relevant, safe, and effective.

In summary, the landscape of menu labeling is evolving, influenced by technological progress, consumer preferences, and international trends. These factors are expected to guide the FDA’s strategies in menu labeling, aiming to keep them current, informative, and advantageous for consumers and the food and beverage sector alike.