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Menu labeling compliance without the spreadsheets

Chain restaurants (20+ locations) need menu-item nutrition disclosures under 21 CFR 101.11. NFL generates them from your recipes.

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Menu items roll up to per-serving nutrition automatically.

FDA menu-labeling rule

The FDA's menu-labeling rule (§ 101.11) requires calorie disclosures for standard menu items at restaurants with 20 or more locations, plus written nutrition information on request. Enforcement is routine. NFL turns your recipes into the disclosure documents.

  • Build each menu item as a recipe once; update the ingredient amounts per plate
  • Recipe variants (gluten-free, vegan, kids portion) get their own labels without duplicating work
  • Export a PDF of the full nutrient disclosure for in-store binders or the request-only copy
  • Cost tab doubles as a plate-cost calculator, so you know your food-cost % alongside the nutrition numbers

Multi-location operators can give each location access to shared recipes while keeping format and branding consistent. Single source of truth for every disclosure across the chain.

Does the rule actually cover you?

Three conditions have to hold together. You are part of a chain of 20 or more locations; those locations do business under the same name; and they offer for sale substantially the same menu items. Miss any one and § 101.11 does not apply to you.

The category is broader than the word "restaurant" suggests. Bakery chains, coffee shops, convenience stores, movie theatres, amusement parks, grocery stores selling prepared food - if the establishment sells restaurant-type food and meets the three conditions, it is covered. A twenty-two-location café group is in scope; an eighteen-location one is not.

Franchises usually count toward the twenty even under separate ownership, because the test is the name and the menu rather than the corporate structure.

What has to appear where

On the menu and menu board: calories for each standard menu item, next to the item name or price, in type no smaller and no less prominent than the name or price itself.

The succinct statement, verbatim: "2,000 calories a day is used for general nutrition advice, but calorie needs vary." It goes on menus and menu boards.

The statement of availability, telling customers that additional written nutrition information is available on request.

Available on request: full written nutrition information covering a defined nutrient set - total calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fiber, sugars, and protein among them. It has to be in the establishment and produced when a customer asks.

Self-service items and food on display get their own declarations, on a sign adjacent to the food.

The exemptions people forget they have

Not every item on the menu is a standard menu item. Daily specials, custom orders, and temporary menu items appearing on the menu for fewer than 60 days a year fall outside the requirement. So do condiments for general use and food used only in test marketing.

This matters practically: a seasonal rotation that changes every six weeks may not need declarations at all, while the core menu behind it does. Knowing which of your items are genuinely standard is the difference between calculating forty disclosures and calculating a hundred and forty.

Variable items - a pizza where the customer picks toppings, a build-your-own bowl - have their own treatment, generally declared as ranges or per-option so the customer can assemble the figure.

Packaged food sold in your restaurant is a different rule

The jar of house hot sauce by the register, the loaf of bread in the retail case, the take-home cookie box - these are packaged foods, not menu items. They fall under the ordinary § 101.9 Nutrition Facts regime rather than § 101.11 menu labeling, and they need a full panel, ingredient statement, net quantity declaration, and allergen line.

Restaurant groups launching a retail line hit this transition without expecting it: the menu-labeling work they already did does not carry across, because it is a different disclosure under a different rule. NFL builds both from the same recipe, so the retail SKU reuses the work rather than starting over.

Restaurant menu labeling: common questions

We have 20 locations but different menus per region. Are we covered?
The test is "substantially the same menu items." Genuine regional divergence can put you outside it, but overlapping core menus generally will not. This is a question worth asking counsel rather than assuming.
Do alcoholic drinks need calories?
Alcoholic beverages that are standard menu items are generally within scope. Drinks not on the menu are treated differently.
Do we need lab testing for menu items?
The rule requires a reasonable basis for the declared values. Nutrient databases, cookbooks, and analysis all qualify. NFL computes from USDA FoodData Central and keeps the recipe that produced the number, which is what a reasonable basis looks like when someone asks how you got it.
What about vending machines?
Operators with 20 or more machines have their own requirement under § 101.8.

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