restaurants making nutrient content claims are subject to the reasonable basis standard. [I]n lieu of analytical testing, restaurants may show they have a reasonable basis for making the claim.
Here, plaintiff is suing under regulatory state laws proscribing deceptive practices. The gravamen of her claim is that the menu labels are not precisely accurate as shown by lab testing, and are thus deceptive. This imposes a broader obligation on defendant’s food labeling than the federal “reasonable basis” standard, by seeking to enforce a more exacting standard of compliance. Thus, her state law claims are preempted . . . to the extent they exceed the federal standard.