Dallas Calorie Labeling Compliance Checklist for Food Service

Federal FDA Menu Labeling Requirements (21 CFR 101.11)

The FDA's menu labeling rule requires most covered establishments—including chain restaurants with 20+ locations, food trucks, and vending machines operated by such chains—to display calorie information for standard menu items at the point of purchase. Calories must be listed next to the item on menus, menu boards, or displays in a clear, conspicuous format. For restaurant chains operating in Dallas, this applies regardless of whether the location itself is a chain; if the corporate entity operates 20+ establishments nationwide, compliance is mandatory. Secondary menu labeling (serving size, fat, carbs, sodium, protein) must be available in written form upon customer request or via QR code/website. The FDA does not set specific font size rules, but calories must be equally prominent to item names and prices.

Texas State Health Code & Dallas City Health Department Standards

Texas Administrative Code (TAC) Title 25, Chapter 229 incorporates federal FDA requirements and adds state-specific oversight through the Texas Department of State Health Services (DSHS). Dallas City Health Department (DCHD) enforces these standards during routine food service inspections and conducts spot-checks on menu labeling compliance. Dallas inspectors specifically verify that calorie information is accurate, up-to-date, and accessible at point of sale. Operators must maintain documentation showing calorie source data (lab testing, database, supplier info, or manufacturers' labels). If menu items are customizable (e.g., sandwich with add-ons), operators must provide guidance on how calorie counts change or disclose the base item calorie count with notes about modifications. DCHD may request recent recipes, ingredient invoices, or nutrition analysis software records during inspections.

Common Violations & Compliance Checklist Items

Frequent inspection findings include missing calories on digital menu boards, outdated calorie information, inconsistent formatting between front-of-house and online menus, and lack of written secondary nutrition info (sodium, fat, carbs, protein). Verify that all new menu items have verified calorie counts before launch; many violations occur when operators estimate instead of verify. Ensure calorie counts match across POS systems, delivery apps (DoorDash, Uber Eats), website menus, and in-store displays. For made-to-order items, use a consistent standard recipe and calculation method. Document your calorie data sources (USDA databases, lab testing, supplier certifications, or nutrition analysis software like nutritionix or FatSecret API) and retain records for at least 12 months. Train staff on how to direct customers to secondary nutrition info. During DCHD inspections, have your compliance documentation readily available, including any third-party nutrition analysis certificates or correspondence with FDA if you've requested guidance.

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