Menu-Labeling Rule Comment Period Extended – Draft Comment Template Available

The Food and Drug Administration has extended its period for comment on its Menu-Labeling Rule.  Comments are now due to be submitted by August 2, 2017.  If you own or operate a chain of 20 or more convenience stores – or even a single franchise store if the franchise store is part of a chain of 20 or more locations doing business under the same name, you are responsible for implementing the requirements of FDA’s Menu-Labeling Rule at your location(s). 

PMCI members subject to the requirements within the FDA’s Menu-Labeling Rule would be required to disclose calorie information on menus and menu boards for standard menu items.  Additionally, the FDA is requiring that foods on display and self-service food items be accompanied by a menu board providing calorie and other nutritional information.  As written the rule would require countless menu’s and calorie displays within PMCI member convenience stores.  The rule is costly and burdensome to convenience store operators and includes potential criminal penalties for non-compliance with the rule. 

PMCI, with the assistance of NACS, has developed a comment template for you to submit on behalf of your company addressing industry’s concerns with the rule.  The comments prepared for you will require you to customize portions of the comment letter to be tailored toward your stores.  Those sections are highlighted in yellow for your convenience.  Once you have customized the letter, insert your electronic signature and place on your company letterhead.  Remember to save your comment letter on your computer.

Once completed, upload your comment letter on the Federal Register website. In the comment field type “See Attachment For Comments” and upload your letter by clicking on the “Add a file” link.  Following the upload of your letter, fill in the Organization Name field by typing your company name and subsequently completing the Category field by selecting “Private Industry”.

The last step in submitting your comments is to check the box certifying that you understand the official statement and clicking the “submit comment” link. 

The comment template prepared for you can be found here.

Please send an email to john@pmcofiowa.com to let us know you submitted comments.