Browse this category by subcategory.Food
Cava
5
Chipotle
48
Starbucks
5
Food
Three chains, 58 guides, and one question underneath almost every one of them
This section covers three fast casual chains. Chipotle holds 48 guides on menu, pricing, ordering and nutrition. Cava holds 5 and Starbucks holds 5, both concentrated on calories.
Read the titles and the pattern is obvious. People want to know how many calories are in the thing they are about to order. Every guide answers that with a number, and every number ultimately traces back to a figure the chain itself published.
This page is about that figure. Where it comes from, what the law requires it to be, how accurate it is allowed to be, what else the restaurant has to tell you, and the several important things it does not have to tell you at all. It is the layer underneath every calorie count in this section, and it is more permissive than almost anyone assumes.
What the Chipotle hub already covers, so this page does not. That hub owns the corporate layer: the franchise question, the restaurant count, the international markets, the digital sales share and the disclosed price increases, all drawn from securities filings. This page owns the regulatory layer, and names the document behind every requirement.
The one number that decides whether any of this applies
The federal menu labeling rule covers a restaurant that is part of a chain with 20 or more locations doing business under the same name and offering for sale substantially the same menu items. The definition adds a clause that closes the obvious loophole: it applies regardless of the type of ownership, individual franchises included.
| Chain | Locations | Covered? |
|---|---|---|
| Chipotle | 4,201 as of 30 June 2026 | Yes, by a factor of 210 |
| Cava | Several hundred | Yes |
| Starbucks | Many thousands | Yes |
| The independent place on the corner | Fewer than 20 | No. Nothing on this page applies to it |
The Chipotle figure is from the count in the restaurant count guide. The threshold and the ownership clause are quoted from 21 CFR 101.11.
That last row matters more than it looks. A 2013 study of 157 meals from restaurants with no calorie information found that independent and small chain restaurants averaged 49 percent more energy per meal than the equivalent from a major chain. The rule reaches the places whose food is already lighter.
Why there is a calorie number on the board at all, and what it is required to say
Calorie counts on chain menus are not a voluntary courtesy. They are required by a federal regulation with a specific history, a specific scope and a specific compliance date, and knowing all three explains most of what is odd about them.
| Stage | Detail |
|---|---|
| The statute | Section 4205 of the Patient Protection and Affordable Care Act of 2010, adding a new section to the Federal Food, Drug, and Cosmetic Act |
| The final rule | Published 1 December 2014 at 79 FR 71156, codified at 21 CFR 101.11 |
| The compliance date | Extended twice, finally landing at 7 May 2018 |
| Amendments since | None. The section carries a single source note reading 79 FR 71253, Dec. 1, 2014 |
Dates from the Federal Register notices and the eCFR page for 21 CFR 101.11, current as of 17 August 2026.
Read the last row again. The regulation that governs every calorie number on every chain menu board in the United States has not been amended since the day it was published, more than eleven years ago. That single fact explains most of what follows.
What must appear, exactly
- The calorie count for each standard menu item, on the menu or menu board, next to the item.
- A succinct statement about daily intake. The adult wording is fixed: 2,000 calories a day is used for general nutrition advice, but calorie needs vary. Children menus get their own version giving 1,200 to 1,400 calories for ages 4 to 8.
- A statement of availability, also fixed: Additional nutrition information available upon request. That sentence is a legal instruction to the customer, and section 04 is about what happens when you take it up.
- Rounding rules. To the nearest 5 calories up to and including 50, to the nearest 10 above 50, and anything under 5 calories may be shown as zero.
Menu or menu board is defined broadly enough to catch almost everything the customer chooses from: breakfast, lunch and dinner menus, dessert menus, beverage menus, children menus, specialty menus, electronic menus and menus on the internet.
Self-service and food on display are covered too
A salad bar, a buffet line, a cafeteria line or a similar self-service arrangement is covered, and so is food on display, meaning food visible to the customer before they choose where there is no ordinary expectation of further preparation. The requirement is calories per displayed item, giving a bagel, a slice of pizza and a muffin as the examples, or calories per serving where the food is not sold in a discrete unit.
Alcohol splits in a way that explains a lot of empty menu space
| Where the drink is | Calories required? |
|---|---|
| Listed on the menu or menu board as a standard menu item | Yes |
| On display behind the bar, not listed and not self-service | No. Expressly exempt |
So the beer on the printed list needs a number and the identical beer sitting in a fridge behind the counter does not. Chipotle sells beer and margaritas at licensed locations only, which the alcohol guide covers, and whether the calories appear depends entirely on which side of that line the drink sits.
Four kinds of food on a chain menu that need no calorie count at all
The rule applies to standard menu items, defined as restaurant-type food routinely included on a menu or menu board or routinely offered as self-service food or food on display. Everything that is not a standard menu item falls outside it, and the list of what is not is specific.
| Category | Definition in the regulation | Why it matters |
|---|---|---|
| Temporary menu item | A food that appears on a menu or menu board for less than a total of 60 days per calendar year | The seasonal limited-time offer, in one line |
| Custom order | A food order prepared in a specific manner at an individual customer request, requiring a deviation from the usual preparation | The off-menu build |
| Daily special | Prepared and offered on a particular day, not routinely listed on a menu or menu board | Rare in fast casual, common elsewhere |
| Condiments for general use | Including those placed on the table or on or behind the counter | The sauce station |
Definitions from 21 CFR 101.11. Food that is part of a customary market test is also excluded.
The 60-day rule is the one worth remembering
A seasonal item that runs for under 60 days in a calendar year is legally a temporary menu item, and a temporary menu item is not a standard menu item, and only standard menu items need calorie declarations. That is the whole chain of reasoning, and it means an entire category of heavily marketed products can arrive with no number attached.
Seasonal drinks are the obvious case. The Starbucks collection covers pumpkin sauce and the seasonal lineup partly because those figures are harder to find than the year-round ones. Note that many chains publish the numbers anyway, voluntarily. The point is not that they always hide them. It is that if they choose to, nothing stops them.
The custom order exemption and the build-your-own restaurant. A custom order is one that requires the restaurant to deviate from its usual preparation of a standard menu item. In a chain built entirely on the customer choosing every component, the boundary between a standard item assembled to order and a custom order is not obvious, and the regulation does not draw it for the assembly-line format specifically. What chains in this section do in practice is publish per-ingredient figures and leave the addition to the customer, which is a reasonable answer and also not the same thing as a calorie count on a board.
That is exactly the experience the collections describe. The Cava calorie guide opens by noting that the nutrition document lists forty-odd ingredients separately rather than giving a finished meal a number, and the Starbucks guide exists because a drink is a base, a milk, one or more syrups and sometimes a topping, and the board almost never shows the total for the cup you actually ordered.
Eleven nutrients, in writing, on request. And the list is a museum piece
The sentence on the menu board saying additional nutrition information is available upon request is an instruction with legal content behind it. The regulation states that the following nutrition information for a standard menu item must be available in written form on the premises and provided to the customer upon request.
| # | Nutrient | Unit |
|---|---|---|
| 1 | Total calories | cal |
| 2 | Calories from fat | fat cal |
| 3 | Total fat | g |
| 4 | Saturated fat | g |
| 5 | Trans fat | g |
| 6 | Cholesterol | mg |
| 7 | Sodium | mg |
| 8 | Total carbohydrate | g |
| 9 | Dietary fiber | g |
| 10 | Sugars | g, and note the word |
| 11 | Protein | g |
From 21 CFR 101.11(b)(2)(ii). The regulation requires this information to be presented in the order listed and using the measurements listed.
What form it has to take, and how long they can take over it
The written information may be a counter card, a sign, a poster, a handout, a booklet, a loose leaf binder, an electronic device such as a computer, or the menu itself. If it cannot be handed over, it has to be readily available on the premises in a way that lets the customer review it on request.
There is no deadline. The regulation says upon request and on the premises and stops there. It sets no time limit for producing it, and the guidance does not add one.
Now look at rows two and ten again
That list is frozen in the vocabulary of the old Nutrition Facts panel. Packaged food in the United States stopped declaring calories from fat and started declaring added sugars when the label was overhauled. The restaurant list still demands calories from fat, which nutrition science had already moved past, and still says plain sugars rather than distinguishing the sugar that occurs naturally in a tomato from the sugar poured into a syrup pump.
Added sugars are not required on any American restaurant menu, in any form. Not on the board, not in the written booklet. A bottled coffee drink from a supermarket shelf must declare its added sugars because packaged food labeling requires it. The same drink built at the counter need not. The Food and Drug Administration has recommended that chains include added sugars voluntarily, in a supplementary guidance document, and that document has been sitting in draft since December 2023.
And there is no right to an ingredient list
Nothing in the menu labeling rule requires a restaurant to tell you what is in the food. The eleven nutrients above are the ceiling of what a customer can compel, and they describe the nutritional profile of a dish without naming a single component of it. Chains publish ingredient information voluntarily and most large ones do, which is why guides like the one on vegetarian and vegan options can be written at all. They are written from material the company chose to publish, not from material it was required to.
A cookbook is a legal basis for the calorie count on a menu board
This is the section that changes how you read every number in this section of the site, and it turns on one phrase.
The regulation says a covered establishment must have a reasonable basis for its nutrient declarations, and then lists what counts as one. Nutrient databases, with or without software. Cookbooks. Laboratory analyses. Other reasonable means, including the Nutrition Facts panels on packaged foods, and the agency published nutrient values for raw fruits and vegetables and for cooked fish.
No laboratory test is required at any point. A chain may derive the number on its board from a nutrient database and a recipe, and that is a complete legal answer.
What the restaurant has to be able to produce
The substantiation requirement is genuinely demanding, and it is worth listing because it shows what the rule is actually policing. On request, within a reasonable period of time, the establishment must give the agency the name and dated version of the database and the software company; the recipe or formula used; the amount each ingredient contributes; how the database was used, including the calculations; a certification that the database gives accurate results when used correctly and was used per its instructions; a detailed listing of the values determined for each item; anything else pertinent, including what might cause slight variations; and two signed and dated statements from a responsible individual, one certifying the analysis is complete and accurate and one certifying that reasonable steps were taken on preparation method and portion size.
Read what that polices. It polices method. It asks whether the establishment had a defensible way of arriving at the number and whether it took reasonable steps to cook the food the way the method assumed. It does not ask whether the food on the tray matches the number.
Because there is no tolerance. There is no number at all
The whole of 21 CFR 101.11 contains no margin of error, no allowable variance and no percentage tolerance for how far a real portion may sit from its declared calories. The only numbers in it are the display rounding increments, and those govern how the figure is printed rather than how the food may differ from it. The 2016 labeling guide and the 2018 supplemental guidance contain no tolerance either.
Now compare that with the rule for a package.
| Packaged food, 21 CFR 101.9(g) | Restaurant menu, 21 CFR 101.11 | |
|---|---|---|
| Standard | Numeric compliance thresholds tested on a composite sample | Reasonable basis, plus reasonable steps |
| Naturally occurring vitamins, minerals, protein, carbohydrate, fiber | Must be at least 80 percent of the declared value | No figure |
| Calories, sugars, fat, saturated fat, trans fat, cholesterol, sodium | Misbranded if more than 20 percent in excess of the declared value | No figure |
| Consequence of exceeding it | The product is legally misbranded | There is nothing to exceed |
Packaged food thresholds from 21 CFR 101.9(g). The restaurant column is a verified absence: the regulation was read in full and contains no equivalent provision.
The one-sentence version. A bag of tortilla chips that tests more than 20 percent above its stated calories is legally misbranded. A burrito that tests 60 percent above its menu board figure breaks no numeric rule, because no numeric rule exists for it. The restaurant is exposed on its method, not on its arithmetic.
What the agency says instead of a number
Its 2018 guidance addresses natural variation directly and tells establishments they may account for it as part of their reasonable basis, and that declarations could be based on average values obtained by comparing nutrient values across suppliers, or from one supplier where the variation is known.
On enforcement, the same guidance says the agency does not intend to penalize or recommend criminal penalties for minor violations, and gives as its examples of a minimal variation adding extra slices of pepperoni to a pizza or an extra dollop of ketchup on a hamburger when not typically added.
That is a sensible position for a regulator. It is also a very different thing from a tolerance, and worth knowing before you plan a week of eating around a number on a board.
Somebody burned the food and weighed the heat. Here is what they found
Section 05 establishes that no legal tolerance exists. The obvious next question is how far real restaurant food actually sits from its stated calories, and that has been measured, by physically burning it.
The landmark study is Urban and colleagues in the Journal of the American Medical Association in July 2011. It took 269 food items from 42 restaurants across three states and measured their energy content by bomb calorimetry, which is to say by combustion rather than by modeling.
| Finding | Figure |
|---|---|
| Average difference between measured and stated | 10 kcal per portion, 95% confidence interval minus 15 to plus 34 |
| Items measuring at least 100 kcal per portion above stated | 50 of 269, or 19 percent |
| Those items on re-sampling | Averaged 258 kcal per portion above stated |
Urban et al., Accuracy of stated energy contents of restaurant foods, JAMA, 20 July 2011, volume 306 issue 3, pages 287 to 293.
The honest reading, which is more interesting than the scare version
On average, the stated numbers were about right. The mean difference was ten calories, which is nothing. But nearly one item in five was a hundred calories or more over, and when those items were bought again they came in at more than 250 calories over.
Averages hide spread, and a customer eats one plate rather than the mean of 269. A chain can be perfectly honest about its methodology, produce numbers that are correct on average, and still hand a particular person a meal that is 250 calories heavier than the board said.
The comparison that makes the point about tolerances
An earlier study by the same group, published in the Journal of the American Dietetic Association in January 2010, measured 29 reduced-energy restaurant items and 10 supermarket frozen meals the same way.
| What was measured | Average excess over stated | Legal tolerance that applies |
|---|---|---|
| Restaurant items | 18 percent | None |
| Supermarket frozen meals | 8 percent | Misbranded above 20 percent |
The food with the legal ceiling sat closer to its label than the food without one. That is not proof of causation, and the samples are small. It is a suggestive pattern that lines up exactly with what section 05 describes.
Two more figures from the same paper. The worst individual items reached 200 percent of their stated values. And free side dishes pushed the energy actually provided to an average of 245 percent of the stated value for the entree they came with, which is a useful thing to hold in mind next to the chips that arrive with the bowl.
Meals with no number at all
A 2013 study in JAMA Internal Medicine measured 157 meals from restaurants that published no calorie information, in nine categories around Boston. The mean meal came to 1,327 calories, which the authors describe as 66 percent of typical daily energy requirements, and 7.6 percent of meals provided more than an entire day of energy in one sitting.
And the labeling did not make the food lighter
A 2020 study in PLOS ONE tracked 28,238 menu items across 66 of the 100 largest United States chains from 2012 to 2018 and found no significant change in calories or nutrients among items that stayed on the menu across the whole period. Newly introduced items were lighter, down about 120 calories or 25 percent, with saturated fat down 41 percent. Appetizer sodium went the other way, up 112 milligrams or 17 percent.
So the effect, such as it is, shows up in what chains add rather than in what they already sell.
The rule was written for a board on a wall. Most people now order from a phone
The menu labeling rule defines a menu to include electronic menus and menus on the internet. What it did not anticipate, in 2014, was that a large share of orders would be placed on a platform the restaurant does not control.
A 2023 study in Public Health Nutrition looked at the 75 largest chains by outlet count across four cities and checked whether calories appeared consistently, meaning for all items at all locations.
| Where you order | Chains labeling calories consistently |
|---|---|
| The chain own website or app | 60% |
| DoorDash | 27% |
| Uber Eats | 19% |
| Grubhub | 6% |
Greenthal and colleagues, Availability of calorie information on online menus from chain restaurants in the USA, Public Health Nutrition, 2023, volume 26 issue 12. Cities were New York, Los Angeles, Chicago and Houston.
Four chains out of 75 labeled consistently everywhere: McDonald's, Panera Bread, Whataburger and Jamba.
The same burrito, ordered two ways. Walk in and the calorie count is on the board because the law requires it. Order the identical item on a delivery platform and, on the numbers above, the count is probably not there. The agency addressed this in a supplementary guidance recommending that chains voluntarily disclose calorie information on third-party platforms. That guidance has been in draft since December 2023 and remains a non-binding recommendation.
Chipotle delivers through its own app and through third-party apps, which the delivery guide covers on the cost side. The disclosure side is a different question with a different answer depending on which app is open.
Everything in this area is currently a draft
| Instrument | Status | In draft since |
|---|---|---|
| Menu Labeling Supplemental Guidance, Edition 2 | Draft | December 2023 |
| Compliance policy guide on allergen labeling and cross-contact | Draft | May 2023 |
| Voluntary sodium reduction goals, Edition 2 | Draft | August 2024 |
| Front-of-package nutrition labeling | Proposed rule, not final, and packaged food only | 2024 |
The binding instruments are the 2014 regulation and the 2018 final guidance. Every live proposal that would change what a chain restaurant tells you is unfinished, and one of them has been unfinished for over three years.
The bag of chips is covered by allergen law. The burrito next to it is not
This is the single largest gap in what a chain restaurant is required to tell you, and almost nobody knows it exists.
The federal allergen labeling law covers packaged food. The agency states the scope plainly on its consumer page: the labeling requirements do not apply to foods that are placed in a wrapper or container, such as paper or a box for a sandwich, following a customer order at the point of purchase.
So the bag of tortilla chips on the shelf carries a legally mandated allergen statement. The burrito wrapped in foil beside it, made moments earlier from a dozen ingredients, carries no federal allergen requirement at all. Same counter, same company, two different legal regimes.
The nine major food allergens under United States law are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. That list governs the label on a package. It does not, by itself, require a restaurant to tell you anything.
Sesame, and the change that made some products less safe
Sesame became the ninth major allergen through the Food Allergy Safety, Treatment, Education, and Research Act of 2021, signed on 23 April 2021. The mechanism is almost comically small: the statute amends the definition by striking the words and soybeans and inserting soybeans, and sesame. It applies to any food introduced or delivered into interstate commerce on or after 1 January 2023, so the trigger is when the food entered commerce rather than when it was sold.
What happened next is documented by the agency itself. Rather than change production lines to prevent cross-contact, some manufacturers started deliberately adding sesame to products that had never contained it, so that they could truthfully declare it. The agency described the practice in a September 2023 announcement, saying that some manufacturers are intentionally adding sesame to products that previously did not contain sesame and labeling the products to indicate its presence, rather than taking appropriate measures to minimize or prevent cross-contact.
Its verdict on that, in the same announcement: it limits options for consumers who are allergic to sesame, a result the agency does not support.
The instrument meant to address it is still a draft. The compliance policy guide on allergen labeling and cross-contact was issued in May 2023 and remains marked as draft, not for implementation, containing non-binding recommendations. It has been in that state for over three years. A law intended to protect people with a sesame allergy produced a documented reduction in the products available to them, and the fix has not been finalized.
The model code changed. Most states have not adopted it
There is one real development, and it comes with a large asterisk. The 2022 edition of the national model food code added sesame as the ninth allergen and, more importantly, added a requirement for written notification to consumers of major food allergens as ingredients in unpackaged food, plus labeling of bulk food available for self-dispensing.
That is precisely the gap described above, closed. Except for one thing, which the agency states directly: the model food code is neither federal law nor federal regulation. It is provided for jurisdictions to adopt.
| Adoption status, reported December 2025 | Agencies | Share of the US population |
|---|---|---|
| Have adopted the 2022 edition, which contains the allergen notification requirement | 11 state agencies in 7 states | 16.06% |
| Have adopted any of the three most recent editions | 46 state agencies in 36 states | 64.64% |
Figures from the agency page on adoption of the food code by state and territorial agencies, page and data both dated 9 December 2025, drawing on the 2024 annual report.
So the requirement exists in the model code and covers roughly one American in six.
States legislate on allergens because they are not allowed to legislate on calories
Several states have their own allergen awareness laws. Massachusetts requires restaurants to include on all menus a notice of the customer obligation to inform the server about any food allergies, to display an approved poster in the staff area, and to have the person in charge watch a food allergy video as part of an approved food protection manager course. The required menu wording is fixed: Before placing your order, please inform your server if a person in your party has a food allergy. Illinois requires a displayed notice telling consumers that allergy information must be communicated to an employee, and requires that employee to relay it to the person in charge.
Why the state laws are about allergens and never about calories. Federal law preempts any state requirement for nutrition labeling that is not identical to the federal one. A state therefore cannot demand better calorie disclosure from a chain than the federal rule requires. Allergen awareness is not nutrition labeling, so it survives preemption. That is the whole explanation for a pattern that otherwise looks arbitrary.
Gluten free is a defined term for a package and a recommendation for a plate
Two more claims worth checking, because both follow the same pattern as the calorie tolerance: a hard rule for the box and a soft expectation for the tray.
Gluten free
The federal standard is precise. A food may bear a gluten-free claim where any unavoidable presence of gluten in the food is below 20 parts per million. Gluten-containing grains are defined as wheat, rye, barley and their crossbred hybrids.
| Rule | Published | Compliance date |
|---|---|---|
| Gluten-free labeling of foods | 5 August 2013 | 5 August 2014 |
| Extension to fermented and hydrolyzed foods | 13 August 2020 | 13 August 2021 |
The regulation applies to packaged foods. On restaurants, the agency position is a recommendation rather than a requirement: given the public health significance of gluten-free labeling, it recommends that restaurants making a gluten-free claim on their menus be consistent with the definition.
Read that carefully if it matters to you medically. A restaurant that prints gluten free on a menu is being asked to be consistent with a 20 parts per million standard. It is not being required to meet it, and it is not being required to test.
Sodium
Sodium is the nutrient where the gap between guidance and requirement is widest, because there is no requirement at all.
- Phase one targets, final guidance, October 2021. Short-term goals over roughly two and a half years, covering commercially processed, packaged and prepared foods, and explicitly addressed to food manufacturers, restaurant and food service operations.
- Phase two targets, draft guidance, August 2024. Three-year targets across 163 food categories. The comment period closed in January 2025 and the guidance had not been finalized at the time of writing.
- Everything in both is voluntary. There is no enforceable sodium ceiling on any restaurant menu item in the United States.
| Figure | Amount |
|---|---|
| Average American sodium intake | More than 3,300 mg a day |
| Recommended limit, teens and adults | Less than 2,300 mg a day |
| Where most of it comes from | Processed and restaurant foods |
| Intake if both phases of targets were met | About 2,750 mg a day |
Intake figures from the disease control agency page last reviewed 29 June 2026. The projected outcome is from the sodium reduction guidance, which states that phase one and phase two together would support reducing average intake by about 20 percent.
Note the last row. If every target in both phases were met in full, average American sodium intake would still sit above the recommended limit. Sodium is the one nutrient in the eleven-item written disclosure list where the number you can demand tells you something the rest of the system is not doing much about.
Three collections, and which one you need
Each has its own archive. Counts are current as of 19 August 2026.
Chipotle
48 guides. The largest collection in the section, covering menu, pricing, ordering, rewards, nutrition and the company itself.
- Start with the Chipotle hubThe corporate layer, from securities filings: franchising, restaurant counts, international markets, digital sales and disclosed price increases.
- Calories in a burrito or bowlPer-ingredient calories, macros and sodium, plus seven real orders added up.
- Vegetarian and vegan optionsIncluding the animal products that are easy to miss.
- How many locations there areThe count, the growth curve and the top states.
- Delivery, apps and feesWhich is also where section 07 of this page applies.
Cava
5 guides, all about working out what a build-your-own bowl actually comes to.
- The full menu calorie guideWritten because the nutrition document lists forty-odd ingredients separately rather than giving a bowl a number.
- Real bowls, real numbersCommon builds added up rather than a range.
- The chicken and rice bowlThe most ordered build, broken down component by component.
- Building a lighter bowlWhere the calories actually accumulate.
Starbucks
5 guides on the arithmetic of a drink that is assembled from a base, a milk, syrups and toppings.
- How to calculate the totalBecause the board almost never shows the figure for the cup you actually ordered.
- Which milk is lightestUsually the single largest source of calories in a milk drink.
- Vanilla syrup, by the pumpThe syrup that ends up in more drinks than any other.
- The seasonal lineupWhich is also where the 60-day temporary menu item rule in section 03 becomes relevant.
- Putting it togetherA repeatable order rather than a decision made cup by cup.
The tools
- Chipotle Nutrition CalculatorCalories and macros for your own build, which is the only way to get a figure for an assembled order.
- Cava Calorie CalculatorBuild a bowl or pita item by item and total it.
- Starbucks Calorie CalculatorDrink family, size, milk, syrup pumps, whip, cold foam and extra shots.
- All food calculatorsFive tools covering nutrition and portions.
The other eleven sections of the site are on the blog hub.
Questions this section gets, with the document named
Why do some restaurants show calories and others do not?
The federal rule covers chains with 20 or more locations doing business under the same name and offering substantially the same menu items, franchises included. A restaurant with fewer than 20 locations is not covered and is under no federal obligation to show anything.
How accurate does a menu calorie count have to be?
There is no required accuracy. The rule requires a reasonable basis for the number and reasonable steps to prepare the food the way the basis assumed. It contains no tolerance, no margin of error and no percentage. That is different from packaged food, where a product testing more than 20 percent above its declared calories is legally misbranded.
What can a restaurant use to work out the number?
Nutrient databases, cookbooks, laboratory analyses, or other reasonable means including Nutrition Facts panels from packaged ingredients. No laboratory test is required at any stage. A cookbook is an acceptable legal basis.
How far off are the numbers in practice?
A 2011 study measured 269 items from 42 restaurants by combustion. The average difference from stated was ten calories, which is negligible, but 19 percent of items came in at least 100 calories over, and those items averaged 258 calories over when bought again. The average is fine; the individual plate is where the variation lives.
Why is there no calorie count on the seasonal drink?
Probably because it is a temporary menu item, defined as one appearing on a menu for less than a total of 60 days in a calendar year. Temporary menu items are not standard menu items, and only standard menu items require a declaration. Many chains publish the figures anyway, but nothing requires them to.
What can I ask for beyond calories?
Eleven nutrients, in writing, on the premises, on request: total calories, calories from fat, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fiber, sugars and protein. The regulation sets no deadline for producing it.
Why is added sugar not on that list?
Because the list was written before the packaged food label was overhauled and has never been amended. Packaged food declares added sugars and no longer declares calories from fat; the restaurant list still requires calories from fat and plain sugars. Adding added sugars to menus is a voluntary recommendation in a guidance document that has been in draft since December 2023.
Can I make a restaurant tell me what is in the food?
No. Nothing in the menu labeling rule requires an ingredient list. The eleven nutrients are the ceiling of what can be compelled, and they describe a dish without naming any component of it.
Do restaurants have to tell me about allergens?
Not under federal law. The allergen labeling requirements apply to packaged food and expressly do not apply to food placed in a wrapper or container following a customer order at the point of purchase. The 2022 model food code adds a written allergen notification requirement for unpackaged food, but the model code is not federal law and the edition containing it had been adopted by states representing about 16 percent of the population as of December 2025.
Why do some states have allergen laws but none have their own calorie rules?
Because federal law preempts any state nutrition labeling requirement that is not identical to the federal one, and allergen awareness is not nutrition labeling. Massachusetts and Illinois both require allergen notices; neither could impose its own calorie rule on a national chain.
Can a restaurant say gluten free without meeting the 20 ppm standard?
The 20 parts per million regulation applies to packaged foods. For restaurants the agency recommends that a gluten-free claim on a menu be consistent with the definition. Recommends, not requires, and there is no testing obligation.
Is there a legal limit on sodium in a menu item?
No. The sodium reduction targets are voluntary throughout. Phase one was finalized in October 2021 and phase two has been in draft since August 2024. Average American intake is over 3,300 milligrams a day against a recommended limit of 2,300, and even full compliance with both phases would leave it around 2,750.
Why can I not find calories on the delivery app?
Because compliance there is patchy. A 2023 study of the 75 largest chains found consistent calorie labeling on 60 percent of chains own sites, 27 percent on one major delivery platform, 19 percent on another and 6 percent on a third. The agency has recommended voluntary disclosure on third-party platforms in a guidance that remains a draft.
The documents behind everything above
Every requirement on this page is tied to the regulation or agency document that creates it, with the date. All links verified 19 August 2026.
- The menu labeling rule itself. 21 CFR 101.11, current as of 17 August 2026. Source of the 20-location definition and the ownership clause, the succinct statements, the rounding increments, the definitions of standard menu item, temporary menu item, custom order and daily special, the self-service and food-on-display provisions, the alcohol exemption, the eleven-nutrient written disclosure, the reasonable basis standard and the substantiation list. Its source note reads only 79 FR 71253, December 1 2014, and the eCFR change timeline records no changes after January 2017.
- The rule as published, and the deadline. Food Labeling: Nutrition Labeling of Standard Menu Items, final rule, 1 December 2014, 79 FR 71156, made under section 4205 of the Patient Protection and Affordable Care Act. The compliance date of 7 May 2018 is set in the interim final rule of 4 May 2017, 82 FR 20825, and confirmed on the agency menu labeling page, whose content is current as of 13 December 2023.
- The operative guidance. Menu Labeling: Supplemental Guidance for Industry, final, May 2018, source of the alcohol position, the natural variation and average values passages, and the enforcement discretion language including the pepperoni and ketchup examples. The successor, Edition 2, was issued 13 December 2023 and is still marked draft, not for implementation, containing non-binding recommendations. It is the source of the voluntary added sugars and third-party platform recommendations. Also A Labeling Guide for Restaurants and Retail Establishments Selling Away-From-Home Foods, Part II, April 2016.
- The packaged food comparison. 21 CFR 101.9, 2024 edition, for the compliance provisions at paragraph (g): the 80 percent floor for naturally occurring nutrients and the misbranding threshold at more than 20 percent in excess for calories, sugars, fat, saturated fat, trans fat, cholesterol and sodium.
- What measurement found. Urban and colleagues, Accuracy of stated energy contents of restaurant foods, JAMA, 20 July 2011, 306(3):287-293, for the 269 items, 42 restaurants, the ten calorie mean difference and the 19 percent figure. Urban and colleagues, The accuracy of stated energy contents of reduced-energy, commercially prepared foods, Journal of the American Dietetic Association, January 2010, 110(1):116-123, for the 18 percent and 8 percent comparison and the 245 percent side dish figure. Urban and colleagues, The energy content of restaurant foods without stated calorie information, JAMA Internal Medicine, 22 July 2013, 173(14):1292-1299, for the 1,327 calorie mean meal, the 7.6 percent figure and the 49 percent independent restaurant comparison. All three figures are read from the National Library of Medicine records rather than from the journal sites, which could not be retrieved.
- Whether labeling changed the food. Bleich and colleagues, Calorie and nutrient trends in large US chain restaurants 2012 to 2018, PLOS ONE, 10 February 2020, covering 28,238 menu items across 66 of the 100 largest chains.
- Delivery platforms. Greenthal and colleagues, Availability of calorie information on online menus from chain restaurants in the USA, Public Health Nutrition, 2023, 26(12):3239-3246, for the 60, 27, 19 and 6 percent figures and the four consistently labeling chains.
- Allergen scope. Food allergies, agency consumer page, content current 11 March 2026, for the nine major allergens and the statement that the labeling requirements do not apply to food placed in a wrapper or container following a customer order. The same position is set out in Questions and Answers Regarding Food Allergen Labeling, Edition 5, final guidance, January 2025.
- Sesame. Public Law 117-11, the FASTER Act of 2021, approved 23 April 2021, for the amendment mechanism and the 1 January 2023 interstate commerce trigger. The deliberate addition practice and the agency response are quoted from its announcement of 26 September 2023. The instrument itself, compliance policy guide 555.250, was issued 16 May 2023 and remains a draft.
- The model food code and its adoption. Food Code 2022, preface, significant changes, for the addition of sesame and the requirement for written notification of major food allergens in unpackaged food. Adoption figures from the agency page on adoption by state and territorial agencies, page and data dated 9 December 2025. The statement that the model code is neither federal law nor federal regulation is the agency own.
- State allergen laws. Massachusetts General Laws chapter 140 section 6B, with implementation detail and the required menu wording from the state health department allergen awareness guidance, updated 7 October 2024. Illinois, 410 ILCS 625/3.08. The preemption provision is 21 U.S.C. 343-1.
- Gluten free. 21 CFR 101.91 for the 20 parts per million threshold and the definitions. Dates from the final rule of 5 August 2013 and the fermented and hydrolyzed foods rule of 13 August 2020. The recommendation to restaurants is from the agency questions and answers page, content current 30 June 2022.
- Sodium. Sodium reduction in the food supply, content current 1 November 2024, and the voluntary sodium reduction goals guidance: phase one final, October 2021; phase two draft, 16 August 2024, comment period closed January 2025. Intake figures from the disease control agency page on sodium, last reviewed 29 June 2026.
- Front of package labeling. Front-of-package nutrition labeling, content current 8 May 2025. Proposed, not finalized, and packaged foods only.
- Noted and not published. Several things were checked and left out. No statement is attributed to the agency declining to set a tolerance, because the preamble passage could not be retrieved; what is published here is the verified absence of any tolerance in the enacted text and in both guidance documents. No paragraph number is given for the restaurant exemption from packaged food nutrition labeling, because that part of the regulation could not be read. No section number from the body of the model food code is quoted; the requirement is cited from the preface and the agency explanatory page. No median percentage deviation is given for the 2011 study, because only the abstract record could be read. No claim is made about whether the phase two sodium targets were finalized after 1 November 2024, only that no finalization notice could be found. And the longer regulatory sentences on this page are paraphrased rather than presented as pull-quotes, because the retrieval method returned them in fragments.
Scope note. This page describes regulations and guidance as they stood on 19 August 2026. Four of the instruments described here are unfinished drafts and any of them could be finalized without notice to readers, so treat every date as something to re-check. Nothing here is medical, dietary or legal advice. If you have a food allergy or celiac disease, nothing on this page is a substitute for speaking to the restaurant directly and to a clinician; the point of section 08 is precisely that the legal protections you might assume exist mostly do not, which is a reason to ask rather than to rely on a label. All regulations described are United States federal ones unless a state is named, and the rules where you live may be different.