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Declaration of Calories

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“Declaration of Calories on Menu Cards in Dubai”

On the 9th May 2019, Dubai Municipality issued an external Circular entitled “Declaration of Calories on Menu Cards in Dubai” to all food establishments in Dubai requiring the declaration of the total calories for each dish on their menu and menu boards.  The calories of each menu item should be on printed as well as digital menu cards in a clear and legible manner. It is intended that these mandatory requirements will be implemented in two phases:

  • Firstly, with restaurants and cafés chains that have 5 or more branches under the same brand. They must adhere to the requirement by 31 October 2019.
  • Secondly, with all food venue establishments including restaurants, caterers, cafeteria, coffee shops, supermarkets, and departmental stores with fresh food counters, kiosks and mobile trucks. Compliance is required by 31 January 2020. Phase two, therefore, has a wide and more far reaching application.

The rationale behind the circular is to build on Dubai’s obesity prevention policy. Without this requirement, nutritional information was difficult to access and understand. It is recognized that consumers often underestimate the amount of calories in their food and the aim of this circular is to enable consumers to make an informed decision and make people think twice about making the ‘wrong’ food choices. It is envisaged that providing a daily calorie recommendation at the point of purchase, and openly informing customers that additional nutritional information is available which is currently proposed in the guidelines for calorie labeling, will improve the overall effectiveness of the policy.

With less than eight months before the Dubai Municipality calorie labeling deadline for phase two (31 January 2020), Dubai’s food service establishments should be preparing to roll out new menus complete with calorie counts.

The Dubai Municipality’s Food and Safety Department has helpfully provided food retailers with guidance about where and how the information should appear.

The Requirements & Guidelines

The Dubai Municipality requires that food retailers provide customers with the following three pieces of information:

  • Calorie information for each food retailer’s menu item. For menu items with several variations (i.e. different types of burger), a calorie range is appropriate, rather than including exact calories for each type. The calorie amounts must be prefaced by “Calories” or “Cal” to give context.  
  • A nutrition statement denoting the recommended daily calorie intake that diners can use as a frame of reference (i.e. “2000 calories a day is general nutrition advice, but calorie needs may vary”). This must appear wherever the calorie information is posted.
  • A statement on the menu, menu board, or website notifying customers that additional nutrition information is available upon request.

Dubai Municipality has particular instructions for how the above information should appear.

For calorie counts, they should be:

  • Next to the menu item or price.
  • In a font size no smaller than the font used to list the menu item or price.
  • In the same legible font colour as the menu item or price.

The nutrition statement information denoting the recommended daily caloric intake, must be:

  • Easily legible (i.e. not hidden or blurred).
  • In a font size no smaller than the font used to display calorie counts.
  • In the same font colour as the calorie counts.

The additional nutrition information made available to customers upon request must be printed using a legible font and must include accurate nutrition information for the following categories:

  • Total calories
  • Calories from fat
  • Total fat
  • Saturated fat
  • Trans fat
  • Cholesterol
  • Sodium
  • Total carbohydrates
  • Fibre
  • Sugar
  • Protein

 

Advertising

It is important note that the requirements also apply to promotional materials, including advertisements (other than billboards, radio or television advertisements), and promotional flyers, and also any social media advertisements that list prices for food/menu items and from which customers can order delivery or take away.

Food establishments are not required to buy any software for calculation of calories. However, by recommendation of the Dubai Municipality, either the Foodwatch Generic Data base or Foodwatch Nutrition Validation Software can be used for calculation of calories. Foodwatch Generic Database will allow establishments to find the calories of common foods in Dubai and the Validation software will facilitate a full recipe analysis. 

By way of conclusion, the circular places a burden on the food retailers to be transparent in relation to the calorie value of each menu item. It will be interesting to see how food retailers react and put this into practice. The effectiveness of the requirements may be limited in relation to buffets and brunches popular in this jurisdiction, where portion sizes vary. In this instance it might be necessary for guidance on portion size. Neither the Circular nor the guidelines impose any penalties on the food retailer for the failure to comply, however, time will tell if such penalties will be introduced depending on whether food retailers take steps to fully digest and comply with the Circular.

 

AUTHOR

Faridah Sarah   Partner, Fatma Al Mutawa Advocates & Legal Consultants (Dubai, UAE)