Consumption of food outside the home accounts for one-third of recommended daily calories and may contribute to rising obesity rates. Menu labeling may be a strategy to influence consumer behavior. The Food and Drug Administration (FDA) developed menu labeling requirements which are not yet mandatory. This case study describes implementation from employee perspectives in one made-to-order food establishment. Four data sources were triangulated – employee interviews (n=15), key informant interviews (n=3), organizational documents, and informal participant observation. Employees received varying degrees of training, but only six of fifteen employees were able to calculate total calories accurately (+/- 20 calories) for a hypothetical order. Employees felt confident in their ability to answer nutrition questions from customers, but relied on supervisors and managers. Monitoring of preparation practices mimicked other organizational practices, but employee knowledge was not monitored. This case study revealed barriers to successful implementation of menu labeling in the complex made-to-order context.