Here it is: The FDA will begin enforcing the menu labeling final rule on May 7, 2018, so you have less than a year to make sure you're in compliance. The FDA allows for use of various resources, as long as you have a reasonable basis for your nutrient declarations and that you have performed your due diligence to report information as accurately as possible.
You may determine nutrient values by using any of the following:
- Nutrient databases (with or without computer software programs)
- Cookbooks (published with nutrient analysis that you will have to substantiate)
- Laboratory analysis
- Other reasonable means - Nutrition Facts on labels on packaged foods that comply with the nutrition labeling requirements, for example
If you choose to use a nutrient database to analyze your recipes, you must provide both the database details and the recipe information with the resulting documentation. (There are many, many databases available and we offer this ebook to help you decide which is right for you.)
Nutrient Database Analysis: Database Details
Required database information includes:
- Database name, version number, and version date. Whether the database is used with software, you must still have a name for the database and a version number and/or a version date (sometimes these are the same).
- Name of the software company, the software, and the software's version number, if you choose to use a database linked to software.
- Website address for the database or the software.
Adding Supplier Ingredients
If you have added supplier ingredients to your software database, be sure you maintain records of the supporting documentation for these ingredients with appropriate dates and notes.
Recipe or Formula Information + Reports
When you use a database, you will need to document the following (per the CFR):
- How much of each nutrient an ingredient (in the specified amount) contributes to the menu item. In Genesis, our nutrition analysis program, this is detailed in the Single Nutrient Report.
- How the database was used including calculations or operations (such as worksheets or computer printouts) to determine the nutrient values for the standard menu items. ESHA will provide a copy of protocols upon request.
- If this information is not available, certification attesting that the database will provide accurate results when used appropriately and that the database was used in accordance with its instructions.
- A detailed listing (such as a printout) of the nutrient values determined for each standard menu item. This is available as the Food Menu report in Genesis.
- Any other information pertinent to the final nutrient values of the standard menu item (such as information about what might cause slight variations in the nutrient profile - moisture variations, for example). Genesis R&D allows for and reports moisture adjustments.
- A statement signed and dated by a responsible individual, employed at the covered establishment or its corporate headquarters or parent entity, who can certify that the information contained in the nutrient analysis is complete and accurate.
- A statement signed and dated by a responsible individual employed at the covered establishment certifying that the covered establishment has taken reasonable steps to ensure that the method of preparation (e.g., types and amounts of ingredients in the recipe, cooking temperatures) and amount of a standard menu item offered for sale adhere to the factors on which its nutrient values were determined.
Genesis R&D Labeling Software and ESHA's popular and highly respected nutrition database can help you make complying with the new regulations much smoother and easier than you might expect. We also understand how busy you are, so we offer our Consulting Services as yet another option to achieve compliance. The Consulting Service team can take care of this for you, from initial analysis to the final results, with all the necessary documentation in between.
Whatever route you choose, please know that we are here to help.