Hotel Menu Labeling: Guidance for Industry

calorie counts on menus

Menu labeling is a great option for hotels as more and more consumers expect calorie labeling to be a part of the standard menu offering

You might already know that the United States Food and Drug Administration (FDA) published a final rule regarding menu labeling regulations on December 1, 2014 with the rules going into effect on May 7, 2018. This menu labeling rule was introduced as part of the Affordable Care Act as a public health service and requires food service establishments (fast food chains, chain restaurants, etc.) to display calorie counts on restaurant menus and have additional nutrition information available to customers who request it. Menus with calorie information have already been implemented by McDonald’s and Starbucks since 2014 due to New York City requiring nutritional information ahead of the FDA requirements. Food service establishments that aren’t required to follow this new law are still able to voluntarily offer nutrition and calorie labeling as long as they follow the FDA’s standards. This is a great option for hotels as more and more consumers expect calorie labeling to be a part of the standard menu offering. With Americans trying to make healthier choices to combat the obesity epidemic, calorie posting is a valuable asset for any location that offers food choices or has some sort of menu board. Displaying nutritional information gives consumers the opportunity to make lower calorie choices and possibly pay more attention to portion sizes while better managing their calorie intake.

Covered Establishments

Let’s start by talking about which food service establishments are required by the FDA to follow the new nutrition labeling laws. The FDA refers to these as “covered establishments.” These are restaurants and other food establishments that sell restaurant-type food and are part of a chain with 20 or more fixed locations, do business under the same name, and offer menu items that are mostly the same across the board. Here are some examples of covered establishments:

  • Chain Restaurants

  • Fast Food Restaurants

  • Vending Machines

  • Coffee Shops

  • Entertainment venues

  • Retail food establishments

Independent hotels or hotels with independent restaurants likely don’t fall into the “covered establishment” definition, but as mentioned above, they still have the option to voluntarily opt-in to the FDA requirements. If you wish to voluntarily register, you can fill out Form 3757 on the FDA website and submit it to the FDA. You are to renew your registration every other year after you have implemented the federal requirements.

Restaurant-Type Foods

If you are voluntarily deciding to offer nutrition and calorie information to customers, it’s important to have an understanding of what food items you are required to offer menu labeling for. The FDA calls these items “restaurant-type foods”. All of the following are considered “restaurant-type foods” by the FDA and therefore require calorie content to be displayed:

  • Hot buffet foods

  • Foods ordered from a menu or menu board

  • Food on display

  • “Grab and go” items

  • Self-service food and beverages

All of these foods are required to have calorie content displayed and additional nutrition information must be available upon request. It’s also important to know that any menu board a customer uses to make their food selection must follow the menu labeling guidelines. This includes but is not limited to; in-room menus, online menus, and menu boards posted in the restaurant.

The FDA does allow certain items to be exempt from adhering to the menu labeling requirements. These items are:

  • Temporary menu items

  • Daily specials

  • Custom orders

  • Any food that is not on a menu board and not on display or self-service

The menu board must have the number of calories for foods that the FDA requires to be listed. The FDA also requires the succinct statement and the statement of availability appear on the bottom of the menu board. The succinct statement is as follows: “2,000 calories a day is used for general nutrition advice, but calorie needs vary.” The statement of availability is as follows: “2,000 calories a day is used for general nutrition advice, but calorie needs vary.”

The additional nutrition information that is provided upon customer request must include the following information:

  • Total calories (cal)

  • Total fat (g)

  • Saturated fat (g)

  • Trans fat (g)

  • Cholesterol (mg)

  • Sodium (mg)

  • Totalcarbohydrate(g)

  • Dietaryfiber (g)

  • Sugars (g)

  • Protein (g)

The FDA requires this nutrition information to be substantiated by a reasonable basis which can be from any of the following:

  • Nutrient databases

  • Laboratory analysis

  • Nutrition Facts labels

  • Cookbooks

  • Other reasonable means (e.g., calculations)

Using a nutrient database is the quickest way to get your nutrition and calorie information, you will have access to the results the instant you sign-up. MenuCalc is a great nutrient database service that is offered at low price.

MenuCalc is an industry-leading recipe analysis tool used by many restaurant, cafe, and convenience store owners. To start a free trial or learn more, contact us today.

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