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									Some Thoughts About Posting Product Calories on Menu Boards

What is Menu Board Labeling?

You may have heard in the news that various cities and states are considering
regulations requiring food calories to be posted on restaurant menu boards.

Generally, these regulations would require chain restaurants (of 10 or more units
in the U.S.) to post calories on the menu boards in the same size lettering as the
product listings (other nutrition information is not required, or must be displayed
elsewhere). The regulations do not allow for any variances in the products that
are customized by the customer, or in product offerings that include optional side
choices (like Combo Meals). These variations would create hundreds of different
calorie counts. Wendy’s products are hand-made-to-order, with the customer’s
choice of toppings.

Wendy’s Position

Wendy’s wholeheartedly believes customers should have nutrition and ingredient
information for all the products we serve. In fact, we’ve been offering this
information voluntarily for nearly 30 years.

We’re very proud of the food we serve. We’re also proud of our product
ingredients. We list nutritional information for all main products on posters that
are prominently displayed in every restaurant in North America. We provide this
information – not because it’s required – but because we believe our customers
want it.

These posters include not only calories, but carbohydrates, fats, sodium
cholesterol and other nutrients -- a complete summary for consumers. We
designed the posters similar to the nutrition labels on packaged foods that
consumers are familiar with. We go one step farther by listing potential
allergens, as a service to those customers with restricted diets.

Is Wendy’s opposed to mandatory menu board labeling?

We support the concept of posting calories for consumers to see before they
make their purchase. We’ve done this voluntarily for nearly 30 years using
nutrition brochures, in-store posters and on our website.
Some Thoughts About Posting Product Calories on Menu Boards
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However, government regulators should not force restaurant chains to post
calories ONLY on the menu boards.

Here’s an example: A chicken mandarin salad consists of a bowl of mixed
lettuce, grilled chicken and mandarin oranges. The calories are 170. We also
give you side packets of dressing, roasted almonds and crispy noodles. You
choose how much of the toppings and dressing you want. The total amount of
calories ranges from 170 to 520 depending on how you customize the salad.

Listing a single number of calories next to each product will be misleading. Even
a range of numbers can be confusing, since the range is too broad to have real

We think nutrition posters are a better alternative because they are more
comprehensive and useful for consumers.

Here’s why:

    •   Many customers customize their order --- some add cheese or extra
        mayo, while others take off ketchup or mustard. A sandwich with five
        items (meat, bun, cheese, lettuce and tomato) can be ordered 120
        different ways. Our nutrition posters list every product, plus the individual
        components. Consumers can add and subtract the items they want, and
        get their total number.
    •   Wendy’s offers Choices for every Combo Meal, meaning you have up to
        five choices to substitute for French fries, along with three types of drinks.
        It’s not feasible to list the calories for every food combination. For
        example, a grilled chicken combo (sandwich, side and drink) could range
        from 355 calories to 800 calories, depending on the choices. Consumers
        tell us the range is too broad and in fact, confusing.
    •   Our food is hand prepared; therefore product variations WILL occur and
        portion sizes WILL vary (French fries for example, are put into a carton by
        a hand scoop….it’s not an exact measurement). If we add a few more
        fries to your order, we’re out of compliance with the regulation.
    •   Some customers are interested in calories; others tell us they count carbs;
        while others say sodium is their main concern. Healthy eating is more
        than just counting calories. For example, a diet cola has 0 calories; a
        carton of white milk is about 120 calories. Although milk has more
        calories, we all know it has better nutrition.
    •   Restaurant menu boards are designed for advertising and marketing.
        Nutrition information is educational, and therefore should be distinct from
        advertising. Just as manufactured food packages have a dedicated place
        for Nutrition Facts; our customers have a dedicated place on the Nutrition
        Posters displayed in every store.
    •   The nutrition posters in all Wendy’s in North America contain far more
        information than required by the menu board regulations. In fact, under

October 2007
Some Thoughts About Posting Product Calories on Menu Boards
Page 3 of 3

        the proposed regulations, restaurant chains would actually provide less
        nutrition information than they currently do.
    •   The proposed regulations apply only to restaurant companies with 10 or
        more units in the U.S. If government is truly concerned about educating
        consumers about calories, why not make the regulations apply to ALL

In Summary

We believe our in-store nutrition posters already accomplish far more than the
stated goals for these proposed regulations. The regulations do not provide
consumers with any more information than they currently have. In fact, by
focusing only on calories, regulators are telling restaurant chains to provide less
information than they already do.

Providing calories, or any other nutrition information, should be an education
issue, not a political one.

We are asking local and state governments for a fair, common sense approach
to public health goals.

Thank you for your interest in Wendy’s position on this important issue.

October 2007

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