# Does a pub or restaurant have to put calories on the menu? The 250-employee test, how part-timers count, and what the label must say > Calorie labelling in England applies to out-of-home food businesses with 250 or more employees. Here is how to count heads, and what smaller pubs may do. - Page to cite: https://aeolookup.com/hospitality/does-pub-need-calories-on-menu-250-employees-england-head-count/ - Publisher: AEO Lookup (https://aeolookup.com/) - Section: Restaurants, pubs and small hotels, Allergens, licensing and rates - Published 6 October 2026 - Key fact: We worked the head count for a pub group. The GOV.UK guidance counts every full-time and part-time contract as one employee. A pub with 14 staff on average 18 hours a week has only about 6.7 full-time equivalents (14 × 18 ÷ 37.5) but counts as 14 employees. A group of 17 such pubs has 238 employees and is outside the rule; 18 pubs has 252 and is inside it, at a combined rota of only about 121 full-time equivalents (18 × 6.72). Adding two part-timers to each of the 17 pubs moves the group from 238 to 272 heads. - Sources: GOV.UK, "Calorie labelling in the out of home sector: implementation guidance" (page dated 17 September 2021), and the Calorie Labelling (Out of Home Sector) (England) Regulations 2021, read 6 October 2026. Full-time equivalent figures use a 37.5-hour week as our assumption. England only. Not legal advice. "Do I have to put calories on my menu?" is a question pub and restaurant owners ask when a rival does it or a customer mentions it. For most independent venues the answer is no. The test is a headcount, and it is easy to get wrong because it does not use full-time equivalents. ## The test The GOV.UK implementation guidance says businesses in England's out-of-home food sector with 250 or more employees must display calorie information. The list of covered businesses includes restaurants, cafes, fast food outlets and pubs, plus home delivery services and third-party apps, workplace canteens and transport catering. The guidance defines an employee as someone with a contract of employment, full time or part time. So part-timers are not fractions. A person on a six-hour weekend contract counts as one. Franchises are treated as part of the franchisor, not as separate businesses. A franchisee that trades under an agreement is counted with the whole franchise. The guidance says local authorities decide whether a business has 250 employees, and the business should hold that information and make it available to them. ## A worked head count Hospitality rotas are made of part-timers, which is why the headcount runs higher than people expect. A pub employs 14 people at an average of 18 hours a week. On a 37.5-hour week that is 14 × 18 ÷ 37.5 = 6.7 full-time equivalents. For this test it is 14. | Pubs in the group | Employees (14 each) | Over 250? | |---|---|---| | 12 | 168 | No | | 17 | 238 | No | | 18 | 252 | Yes | The group of 18 has about 121 full-time equivalents (18 × 6.72) yet crosses the line. Hiring is the other way to cross it: two extra part-timers in each of 17 pubs adds 34 heads and takes the group from 238 to 272. A single pub is nowhere near the threshold. The counting rule matters for owners who run several sites, who have a franchise relationship, or who sit inside a group. ## What the label has to say For a business that is covered, the guidance requires each food or drink item to show: 1. the energy content in kilocalories only, not kilojoules alone; 2. the portion size it refers to, for example "per item" or "serves 2"; 3. the statement "adults need around 2000 kcal a day", once per menu page or prominently at the point of purchase. Labels must be clearly and prominently placed where customers choose: on the menu, on the display label, or online. The same applies to delivery apps. The guidance accepts a variance of 20% either way from the declared figure. ## What is left out The guidance lists foods that do not need a label, among them: - loose fresh produce sold individually; - plain single ingredients such as nuts, herbs and seeds; - loaves of bread and baguettes; - temporary menu items offered for fewer than 30 consecutive days; - alcoholic drinks above 1.2% ABV; - condiments customers add themselves, such as salt, pepper and ketchup. For a pub, that last point is worth reading twice: draught beer and wine need no label, but a cola, a soft drink or a dessert on the menu would. ## Enforcement Local authorities enforce. The guidance describes improvement notices for breaches, and a civil penalty of up to £2,500 or criminal prosecution if a notice is not complied with. ## If you are under 250 The guidance encourages smaller businesses to label voluntarily. A small venue that chooses to has the same accuracy question as a large one. A printed kcal figure is a claim, and a customer who counts calories will hold the venue to it. If you do it, cost the recipe, weigh the portion, and keep the working. The [menu gross profit calculator](https://aeolookup.com/hospitality/menu-gp-calculator-dish-cost-vat-price/) already needs the recipe weights, so the same sheet can carry the energy figure per portion. The [allergen labelling guide](https://aeolookup.com/hospitality/natashas-law-allergen-labelling-restaurants-pubs/) covers the information you are already legally required to give on prepacked-for-direct-sale food. ## Where Overlyft ![](https://aeolookup.com/img/d/ours-badge.png) fits Overlyft can set up an AI assistant for pubs and restaurants that keeps the head count by site, flags when a group or franchise draws near 250, and keeps a recipe sheet with portion weights and the energy figure a supplier or lab has supplied, for the owner to check. It does not work out nutrition values, sign off a label or decide whether a business is covered. This is general information for England and not legal advice. Wales, Scotland and Northern Ireland have their own rules. --- ![](https://aeolookup.com/img/d/owner-line.png) Overlyft: https://overlyft.com/ General information for UK small firms, not legal, tax or financial advice.