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' ~"' 4 "0II ..... owIlt "'11."1-1 tl " ~~ICI"'tu~ O jIC~r "'O ~" Gathered compliance cost estimates from 14 Working Group companies Just these 14 companies' cost estimates total over $50 million at conservative, low end of range • Estimates did NOT include probable recurring costs [ Extrapolating to entire chain industry: Estimated chain restaurant locations covered: 250 ,000 - 275,000 Source: Chain Store Guide analysis of current restaurant database, with 680 companies operating 20 or more locations under same trade name • Estimate of covered locations does NOT include companies headquartered outside U.S. but operating covered restaurants in U.S. Estimate also does NOT include uSimilar Retail Food Establishments" (SRFE's) covered under the statute, such as: Hotel/motel operators, on-site/contract feeders, movie theaters, bowling alleys, bookstores, convenience stores, grocery stores, schools & universities Average cost per restaurant, based on size of chain • 20-4500 locations: $1333 4501-9000 locations: $600 9001+ locations: $1100 Cost range from chain restaurant industry sample: Collected cost estimates from representative sample of industry participants -14 companies $150 million at low end of range ($600 x 250,000) $367 million at high end of range ($1333 x 275,000) Cost likely doubles, or more, when SRFE's are included Combination Meals Example: Variable Combination Meal - Option A If the primary writing lists a Variable Combination Meal (e.g. a Combination Meal offering more than one choice ofentree or side item(s) or drink), the restaurant may: A. Provide calories as a range reflecting the lowest and highest total meal calorie content among the variations available. Example: The SONIC® menu offers variability in each combination meal. In most of the meals, there is variability within each of the three components: 1. Entree: choice of condiments on burgers, or choice of protein prep on chicken entrees (grilled or fried), etc 2. Side Item: choice of Tots or Fries 3. Soft Drinks: choice of fountain flavors In this example, the low end of the range is a burger with mustard, Tots and Diet Coke ®. The high end of the range is all three sauces, fries and root beer. A nutrition brochure is available upon request for guests. NOTE: This visual example, with one modification, is currently in SONIC" Drive·ln locations where menu labeling has been implemented. " (as pictured)" has been added to this image to compliment proposed "Variable Menu Item" language. Combination Meals Example: Variable Combination Meal- Option B If the primary writing lists a Variable Combination Meal (e.g. a Combination Meal offering more than one choice ofentree or side item(s) or drink), the restaurant may: B. Provide a median average if the calories for all variations within the Variable Combination Meal are within 20% of the median calorie value. If this is the chosen method, the term '}\vg Cal" must be stated on the primary writing adjacent to the calorie disclosure. Example: As shown in Option A, the range for this combination meal is 910 - 1340. The median value is 1125. The median standard permits an Average Calorie disclosure if the low and high are not greater than 20% from the median value. 1. 20% of 1125 is 225 2. 1125 minus 225 equals 900 3. 1125 plus 225 equals 1350 4. Both the low and high are within 20% of median NOTE : This visual example is for purposes of demonstrating calorie disclosure methods and not currently in use at a SONIC" Drive-In. Combination Meals Example: Variable Combination Meal- Option 0 If the primary writing lists a Variable Combination Meal (e.g. a Combination Meal offering more than one choice ofentree or side item(s) or drink), the restaurant may: D. Provide the calories on the primary writing for one specified variation of the Variable Combination Meal. If the restaurant or SRFE elects this option, then the restaurant or SRFE must: i. Identify the items comprising the variation specified; ii. Disclose calories for the other variations ofthe Variable Combination Meal in a separate writing (examples include, but are not limited to: an electronic kiosk, a nutrition brochure, a menu addendum, a nutrition poster or online nutrition application) available at the point ofsale. Example: The "specified variation" chosen represents the entree as pictured (with Mayo), the most popular side item (Tots) and a non­ diet soft drink. Nutrition brochures would be available upon request to view other variations, as well as available online. NOTE: This visual example is for purposes of demonstrating calorie disclosure methods and not currently in use at a SONIC" Drive-In. Combination Meals Example: Variable Combination Meal- Multiple Sizes If a Variable Combination Meal is available in multiple sizes, calories may be provided on the primary writing for each size when a price is also provided for each size. If a Variable Combination Meal is available in multiple sizes, but only one size of meal and one price is provided, while the other size(s) are available via an "upsize or downsize" message and pricing adjustment, then calorie information for the Variable Combination Meal may be disclosed adjacent to the meal while the calorie adjustment range or average associated with the "upsize or downsize" action may be provided adjacent to the "upsize or downsize" message and pricing.
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