FDA Menu Labeling – 20-Location Chain Trigger (21 C.F.R. § 101.11)
🟠 HighFDA requires calorie and nutrition disclosure on menus for chain restaurants with 20 or more locations under the same name offering substantially the same menu items, regardless of franchise ownership type.
Recommended Action
Add to Playbook
Document this in your market-entry checklist. Address it as part of launch preparation.
Risk Scores
Priority Score = Business Impact + Legal Complexity + Urgency. Maximum is 15. Confidence is not included in the score — it reflects how reliable the source is.
High — significant risk to market entry speed or budget
Moderate — a lawyer should review this before action
Plan before launch — must be resolved before entering this market
Primary law — a statute, regulation, or official government publication
High — plan before launch
Source
FDA — Menu Labeling Requirements →Tier 1 Source
Primary legal source — a statute, regulation, or official government publication. Highest reliability.
Signal Currency
How current is this signal? The gap between when it was published and when it was added here tells you whether you're looking at breaking news or established law.
99 month(s) after publication
Added to dashboard: 9 June 2026 (87 days ago)
Originally published: 7 May 2018
Citation & Practice Notes
Specific statute, regulation, or case law supporting this signal, plus practical notes on sequencing, timing, or related obligations.
21 C.F.R. § 101.11. Compliance date May 7, 2018. Build into U.S. operating system before 20-location threshold.
How to read this signal
Where it comes from
Every signal starts from a named source, tiered by how close it sits to the authority that actually decides the question. A Tier 1 source is the regulator, legislature or court itself. Lower tiers are reporting about those bodies, useful for noticing a development early but not for settling what the rule is. The source is linked above so the underlying document can be read directly rather than taken on trust.
What the four scores mean
Business impact, legal complexity, urgency and confidence are scored separately because they move independently. A settled rule can be high impact and low complexity; a fast-moving proposal can be urgent and low confidence at once. Confidence tracks how firmly the underlying position is established, so a low confidence score is a statement about the state of the evidence rather than a hedge about the analysis.
What the counsel flag is for
The outside counsel flag marks signals where the next step turns on a judgement a qualified lawyer in that jurisdiction should make: an obligation whose trigger is genuinely contested, a deadline with consequences attached, or a question where national implementation diverges from the headline rule. It is a routing instruction, not a severity rating.
This tracker is independent analysis published under RN Collins' own byline. It is not commissioned or endorsed by any company named in it. Where an official source has been moved or withdrawn by the body that published it, the link above points to that body's current page for the same material.