Doyle says that the FDA is failing to account for the ways in which restaurants service their customers. The proposed regulations would require franchises to provide calorie information on in-store menu boards; for Domino's, this would cost each store between $1,600 and going up to $4,700 per year. As a delivery-oriented business, 90% of Domino's' orders are placed by phone and online. As a result, the vast majority of our customers never visit the restaurant, so menu boards are irrelevant, Doyle maintains.
The FDA is also failing to recognize the challenges posed by customizable or "variable menu items" like pizza, Doyle says. Under the proposed rules, the calories for each entire pizza would have to be provided, within a range that could be as wide as 2,000 calories -- again making the information irrelevant/not useful to consumers, he contends.
Finally, Doyle maintains that the legislation, as written, is unfair to small business owners/franchisees.
In July, the National Restaurant Association filed comments with the FDA that also asked for greater flexibility.