I suspect they will try to post the smallest value that they can get away with.  Subway sort of does this with their 6 grams of fat claims - assumes no cheese, select veggies and select sauces. So when their menu says "turkey sub", it will likely use the combination of bread, meat and toppings that get the lowest value. Obviously, they cannot list all combinations of sub, but hopefully they will be forced to post the caloric values of cheese and sauces (and not per slice or tbsp, but per the amount usually put on a sub). I recently looked at a Starbucks nutritional info sheet, to see how easy it was to over"eat" there. They list combinations of milk and size, but assume no whip, no flavour shot etc. I can definitely picture someone getting a drink, adding a bunch of crap to it, and claiming it is only X calories.