• Report

Rapid Evidence Review: Comparing the Implementation of International Mandatory Calorie Labelling in the Out of Home Sector

Content: Report

Published by:

  • The Rowett Institute, University of Aberdeen
  • Food Standards Scotland

6. Discussion

This rapid review synthesised evidence on how OOH food businesses have responded to menu calorie labelling policies, focusing on business compliance, operational impacts, and changes in menu composition. Compliance was consistently higher in jurisdictions with mandatory requirements than under voluntary schemes, although variability persisted, particularly in digital ordering environments. Operational challenges were both documented and reported by stakeholders. Enforcement authorities described resource constraints and competing priorities, while businesses reported ongoing implementation burdens related to time, technical expertise, nutritional analysis, and maintaining accurate information as menus changed.

Observed changes in menu calorie content were generally modest and heterogeneous across jurisdictions and business types. Where changes occurred, they were more commonly observed in newly introduced items than in reformulation of existing menu items. Reported business responses included recipe standardisation, integration of nutritional analysis into menu planning, removal of some higher-calorie items, and introduction of lower-calorie alternatives. However, evidence of systematic reformulation across entire menus was limited. Most studies focused specifically on calorie labelling; few examined the effects of broader nutrient labelling beyond calorie disclosure.

6.1 Compliance and implementation in practice

Evidence from jurisdictions with mandatory menu calorie labelling indicates that compliance is generally higher than under voluntary schemes but not uniform across settings or formats. In most cases, legislation required the display of energy information in kilocalories (kcal) or kilojoules (kJ), rather than broader nutrient disclosure at the point of choice. While many businesses complied with in-store display requirements, several studies identified gaps in provision in digital ordering environments, particularly on third-party delivery platforms where legal obligations were either less clearly specified or more difficult to enforce.

In this context, “incomplete” compliance refers to situations where calorie information was provided for some, but not all, eligible menu items; where required contextual statements were missing; where information was inconsistently displayed across menu formats; or where online platforms differed from in-store provision. Compliance challenges were therefore observed both within individual businesses across different menu formats, and between physical and digital environments.

From a business perspective, implementation challenges included limited control over third-party platform design, duplication of effort in updating multiple menu systems, and ongoing requirements to maintain accurate information as recipes and offerings changed. In jurisdictions such as New South Wales and England, legislation explicitly required calorie information to be displayed online where ordering was possible, yet studies still reported lower compliance in digital settings. This suggests that legislative scope alone does not guarantee consistent implementation.

Some studies also assessed the accuracy of labelled calorie information, identifying discrepancies between stated and measured values. These findings highlight practical challenges in nutritional analysis, recipe standardisation, and maintaining up-to-date data, particularly in businesses with frequently changing menus. Compliance therefore relates not only to whether calorie information is displayed, but also to whether it is accurate and consistently applied across platforms.

The Irish experience aligns with broader evidence that voluntary approaches are associated with low uptake and inconsistent implementation, particularly among smaller and independent businesses lacking internal capacity or incentives to adopt non-mandatory measures. In contrast, mandatory schemes are associated with substantially higher baseline compliance with display requirements, although implementation challenges remain, especially in digital environments and in relation to maintaining accuracy over time.

These findings are particularly relevant to the Scottish context, where food purchased for immediate consumption and digital ordering platforms constitute a substantial and growing share of the OOH food environment. Evidence from other jurisdictions suggests that legislative scope alone does not ensure consistent provision or accuracy of calorie information, particularly in online settings. For Scotland, this implies that any future policy development would need to consider not only statutory requirements, but also enforcement capacity, technical support for businesses, and clear guidance. Understanding barriers to feasibility and accuracy is therefore central to designing interventions that can achieve sustained compliance and meaningful reductions in energy purchased or consumed.

6.2 Business response and operational impact

The reviewed studies indicate that businesses have responded to calorie labelling requirements in varied ways. In jurisdictions where legislation had been in place for longer, some OOH food businesses reported integrating calorie labelling into routine menu development and product planning processes, suggesting that implementation becomes embedded over time rather than remaining a discrete compliance task. However, this integration was often accompanied by ongoing operational demands. Costs and resource pressures arose from recipe standardisation, nutritional analysis, menu redesign, staff training, and maintaining up-to-date information as offerings changed. These burdens were reported to be particularly acute for small and independent businesses lacking in-house nutritional expertise or dedicated compliance capacity.

At the enforcement level, several studies and grey literature sources highlighted constraints faced by local authorities responsible for monitoring compliance. Competing regulatory priorities, limited staffing, and resource pressures were reported to reduce the intensity and consistency of enforcement activity. This context is relevant to understanding variation in compliance, as implementation outcomes reflect not only business willingness and capacity, but also enforcement capability and oversight.

Evidence on short-term financial impacts remains limited and context specific. Some studies reported little measurable impact on revenue or staffing time following implementation, although these assessments often did not account for the full costs of nutritional analysis, system changes, and ongoing maintenance. Grey literature from England provides additional insight into business sentiment. While some industry voices suggested that clearer nutritional transparency could enhance consumer trust, others expressed concern that calorie-focused approaches oversimplify food quality and nutritional value. These views reflect broader tensions regarding the framing of calorie information as a proxy for healthfulness.

Overall, the evidence suggests that sustained and consistent implementation depends on support mechanisms such as clear statutory guidance, standardised presentation requirements, access to reliable nutritional analysis tools, and proportionate enforcement. Without adequate support and oversight, compliance may be uneven, particularly in smaller businesses and digital ordering environments.

6.3 Changes in calorie content of menu items

The evidence on changes in menu calorie content following implementation is mixed. Some studies report modest reductions in calories, particularly for newly introduced items or at the transaction level, while others report no change or small increases. Interpretation of these findings is complicated by concurrent trends in product development and consumer demand. In several jurisdictions, reductions were observed prior to formal enforcement, suggesting that changes may reflect anticipation of regulation or broader reformulation trends rather than the direct effect of labelling alone.

Where studies distinguish between “core” or continuously offered menu items and newly introduced products, reductions in calorie content are more commonly observed among new items than through reformulation of existing products. Here, “core” items refer to menu products that are consistently available over time, rather than temporary or seasonal offerings. Changes in calorie content were less evident among these established items.

This pattern may reflect practical and commercial constraints. Reformulating existing menu items can require changes to recipes, portion sizes, ingredient sourcing, pricing structures, and brand positioning, and may carry commercial risks where products are high-selling or central to brand identity. By contrast, introducing new lower-calorie items allows businesses to expand choice without altering established products. Reductions in average menu calories may therefore arise through product turnover and innovation over time rather than through systematic reformulation of items already available on existing menus.

Some studies also report reductions in calories purchased per transaction. In these cases, observed changes may reflect shifts in consumer purchasing behaviour rather than reductions in the underlying energy content of menu items themselves. Where area-level differences were identified, these reflected variation in purchasing patterns rather than systematic differences in menu composition across locations.

Overall, changes in calorie content appear modest and heterogeneous across jurisdictions and business types, with greater changes observed in newly introduced items than in established menu products. Few studies examined broader nutrient reformulation beyond calories.

6.4 Implications for Scotland and future work

Asking businesses to provide nutrition information for OOH foods requires careful consideration of regulatory design and implementation mechanisms. Evidence from other jurisdictions suggests that mandatory measures are more likely than voluntary schemes to achieve high levels of compliance with display requirements. Voluntary approaches are consistently associated with low uptake and uneven implementation, particularly among smaller and independent businesses.

However, even under mandatory regimes, compliance is not uniform. Gaps have been observed in both on-premises and digital environments, including inconsistencies in presentation, coverage across menu items, and accuracy of information provided. Ensuring clarity in statutory guidance, defining responsibilities across physical and online platforms, and supporting enforcement capacity are therefore central considerations.

The evidence base also highlights important uncertainties regarding effectiveness. While some studies report modest reductions in calories in newly introduced products or in calories purchased per transaction, changes in the energy content of existing menu items are generally limited. It remains unclear to what extent observed reductions are attributable directly to labelling, rather than to broader market trends or anticipatory reformulation.

A further unresolved question concerns whether providing broader nutrition information beyond calories would lead to different business responses. Most available evidence relates specifically to calorie labelling. There is limited understanding of whether disclosure of additional nutrients, such as sugar or salt, would prompt greater reformulation of existing menu items, changes in product availability, or different patterns of consumer purchasing.

Finally, implementation burden remains a key policy consideration. Nutritional analysis, menu updates, staff training, and ongoing maintenance represent recurring rather than one-off demands. Understanding how these requirements can be streamlined, standardised, and supported, particularly for smaller businesses, will be important for feasibility and sustained compliance. 

Based on the current evidence, the highest priorities for further work are understanding the business and enforcement implications of mandatory implementation, and assessing whether provision of broader nutrition information beyond calories would lead to different business responses or greater public health benefit.

6.5 Limitations of the review

This rapid review has several limitations. First, the evidence base is relatively small and heterogeneous, with studies differing in jurisdiction, business setting, outcome definition, and timing relative to implementation. Second, most included studies were observational, pre/post analyses, or qualitative interviews, limiting causal inference about the effects of menu calorie labelling on business practice. Third, direct evidence on enforcement mechanisms was limited, with most studies reporting compliance outcomes or stakeholder experiences rather than measuring enforcement activity itself. Fourth, evidence on business costs and financial impacts was often incomplete, with few studies quantifying the full resource implications of nutritional analysis, menu updates, and ongoing maintenance. Finally, the grey literature included in this review was used to provide contextual insight into business perspectives and implementation challenges, but should not be interpreted as equivalent to peer reviewed evidence on effectiveness.

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