The, FDA is clarifying that the compliance date remains December 1, 2016, but … will not begin enforcing the final rule until May 5, 2017, which is one year after the date that the Notice of Availability for the final guidance published in the Federal Register.
As always, we recommend that companies consult with their legal counsel. Remember that the FDA is not the only way rules are enforced. Our legal system also allows private enforcement.
See the FDA Menu and Vending Machines Labeling Requirements for further guidance and detail.
Source: Constituent Updates > Clarification on Menu Labeling Compliance Date