The Menu Labeling Survival Guide


Restaurant marketers wear many hats, and they'll add one more before December 1, 2016: nutritional guru.

Restaurant marketers wear many hats, and they'll add one more before December 1, 2016: nutritional guru.

Chains with more than 20 locations must make menu item calorie counts and other nutrition information available to consumers by the December 2016 deadline to comply with the FDA menu labeling rules. And even with the draft guidance issued by the FDA on September 11, 2015 containing new details on how to meet the menu labeling requirements, the task is formidable.

The FDA rules—part of the 2010 Patient Protection and Affordable Care Act—cover everything from the type of nutrition information that must be made available to the ways this information needs to be displayed on menus and supplemental nutrition guides. These menu labeling requirements bring heightened data accuracy concerns and layout challenges as well as risk management and legal implications.

The following best practices and tips will help restaurant marketers navigate the challenging road to nutritional compliance.

Survival Step #1: Build the Right Team

Timing: Before Ringing in 2016

The new rules touch nearly every facet of the organization, so it’s important to build a cross-functional team to tackle compliance. Keep the size manageable and include representatives from departments whose work is affected by the FDA requirements: culinary, supply chain, operations, information technology/business intelligence, legal, and of course, marketing.

The first task your new team should accomplish is developing a timeline. Here are some key milestones to include in your plan:

  • Conduct a nutritional analysis on every menu item. Include all recipe variations and all optional menu items.

  • Reformulate recipes for items that do not meet your desired nutritional standards.

  • Finalize nutritional data for core menu items.

  • Establish culinary, training, and operations deadlines for all December 2016 menu content.

It’s also important that one team member immediately takes responsibility for following menu labeling legal developments from the FDA and apprising the team of any new information. Additionally, your entire team should have a basic understanding of the regulations.

Survival Step #2: Get to Work

Timing: Before Basketball and Bracket Mania

Now that your team is aligned around the plan and an understanding of the new law, it’s time to delve into the details. The task at hand can be overwhelming, but answering the following questions will point your team in the right direction:

  • What is the source for nutrition information? Is it manufacturer data, the FDA database, lab testing, or a combination of these resources?

  • Which team member is responsible for gathering which information?

  • Will additional resources and staffing be required?

  • How will menu layouts need to be modified?

  • How will the supplemental nutrition materials be displayed for guests?

  • Which marketing pieces would be considered a “primary writing” as defined by the law?

  • Will market tests be conducted to identify product mix impacts and gather guest feedback?

  • Are there any special cases in which nutritional information would not be required? These could include daily specials, seasonal items offered fewer than 60 days a year, or items being market-tested for fewer than 90 days.

  • When do the updated menu layout and supplemental information layouts need to be approved?

  • Has a nutrition certification process been established for both the corporate office and restaurants per the guidelines?

  • When must the new menus go into production to meet the deadline?

Survival Step #3: Avoid Tunnel Vision

Timing: Before the First June Brides Walk Down the Aisle

While the upfront work and execution of the menu itself is critically important, remember the other implications of compliance and the additional places where nutritional content needs to live. It’s time to plan for:

  • POS feed updates

  • Protocols to update your website and social media channels

  • How to sync your data with mobile apps, kiosks, iPads, and other digital tools

It’s also time to get your legal team involved and initiate content reviews. Ensure the menu updates and supplemental information meet all of the compliance guidelines, and review any special cases and exceptions.

Survival Step #4: Keep It Consistent

Timing: Before the First Back-to-School Ad Runs

Now is the best time to determine how to maintain nutritional data consistency and how to easily manage it across all touch points. Set your brand up for long-term success by establishing processes to:

  • Update and maintain the nutrition data and supplemental nutrition information.

  • Streamline and keep data updated and consistent across all platforms and channels.

  • Identify supply chain process needs and adapt accordingly.

  • Identify your primary data source to avoid errors and duplication of effort.

  • Develop your system communications plan to ensure all team members are ready and informed.

  • Ensure that all your tools, procedures, and processes meet your needs.

  • Address any gaps or missing resources needed for this work to become standard operating procedures.

Survival Step #5: It’s Go Time

Timing: Before Summer Passes You By

At this stage, the team should finalize menu content, design decisions, and rollout plans. Use the following checklist to ensure the team’s due diligence pays off:

  • Finalize all December 1, 2016 menu content.

  • Remove and archive all outdated and eliminated menu items and related nutritional data.

  • Conduct a final review of all menu versions to ensure accuracy.

  • Launch internal communications plan.

  • Deliver all content to print vendor(s).

  • Test all digital channels to ensure content displays accurately.

Menu labeling compliance is no small or easy task. With advance planning, however, you can make steady progress and easily meet the new FDA requirements. Restaurateurs that break this daunting project into smaller tasks and leverage outside expertise will be glad they did so as the December 2016 deadline approaches.

Act now and breathe easier later. It’s a recipe for success. 

The opinions of contributors are their own. Publication of their writing does not imply endorsement by FSR magazine or Journalistic Inc.


Christy Trinkler

Christy Trinkler is a nutritional compliance expert at Trabon ( Since the launch of its first MenuNet system in 1998, Trabon has been the leading provider of menu versioning technologies and marketing services support for the restaurant industry. More than 20 national restaurant brands—including Applebee’s, Red Robin, California Pizza Kitchen, Ruth’s Chris Steakhouse, BJ’s Restaurants, O’Charley’s, and Landry’s—rely on Trabon to streamline and simplify menu versioning management. For more information, please contact Christy Trinkler at (816) 276-2500.

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