‘Tis the season that we’re seeing limited time only (LTO) foods added to menus. At the beginning of fall, it’s pumpkin, spice, and everything nice. Are you unsure what the labeling laws are for these seasonal, LTO menu items? The FDA has made it very clear and concise, temporary menu items are exempt from menu labeling.
According to the FDA (21 CFR 101.11(a)), a temporary menu item means a food that appears on a menu or menu board for less than a total of 60 days per calendar year. The 60 days includes the total of consecutive and non-consecutive days the item appears on the menu.
If you offer an apple spice cake on your menu from October 1st through November 30th, you’re a day too many and are required to post calories and have nutrients available. If you’re hoping to avoid that hassle, omit one day that it shows up on your menu, and you’re good to go. To reiterate, FDA labeling laws do not apply for temporary menu items. Now, if you’ll pardon us, we have some pumpkin spice lattes that are getting cold.