A third solution which should be allowed is electronic display of calories. Several vending machine manufacturers currently produce electronic devices which display the nutritional facts
panel for an item. This should be allowed, but due to the expense of such electronic equipment, should not be required.
A fourth solution is to allow calorie disclosure to take place in an electronic display associated with the bill or coin acceptor. For example, a customer could press the dispensing button to first display the calorie count of the item on a digital screen. The item would only be vended if the dispensing button was pressed a second time.
A fifth solution could be calorie information printed on the outside of a closed front machine in the vend strip or selection button. This graphic would be included in the snack or beverage brand graphic.
Calorie information should also be allowed to be posted at each individual coil, spiral or stack. For example, such labeling could be placed at each spiral near the price and selection item number. Some manufacturers already produce “calorie label rolls” designed to be used in the machine?s price holder.
For closed front machines, where product is not visible, then a label or “static cling” should be allowed to be placed on the outside of the machine. One label of all food or beverages for vending machines should be allowed. This menu could list all food and beverages which might be stocked in the machines. Grouping items into categories on the menu such as “beverages” “chips” “gums” might help consumers select snacks based on comparing comparable items. Since machines come with different exterior doors and frames, and machines are restocked regularly, the FDA should not regulate the size or design of such outside labels. The operator should be given flexibility to design and print a listing of products, which provides information, but will fit the unique needs of the specific machine.
For glass front vending machines where calorie information is printed on the product and is readable by customers, Section 4025 does not apply. So the FDA should allow front of pack labeling.
It is important that due to the very wide variety of machines in existence today, it is critical that a wide variety of solutions be allowed. Any limiting of potential calorie disclosure solutions, will limit the information that we might be able to provide to customers. If the goal is to provide information to customers prior to purchase, then vending companies must be allowed a variety of labeling solutions to meet the variety of machine configurations.