Allergy laws · 7 min read
California SB 68 Allergen Disclosure: What Chains Must Do
California SB 68 allergen disclosure requires menu updates. Learn how chains can review ingredients, maintain written options and train staff.
Key takeaways
- California SB 68 requires covered chains to disclose ingredient allergens in each menu item.
- Digital disclosures need a written alternative available on request.
- Keep disclosures current, and have staff confirm guest allergy orders with the kitchen.
California SB 68 allergen disclosure requires restaurant chains with 20 or more locations to give written notice of the nine major allergens contained as ingredients in each menu item. The requirement takes effect July 1, 2026, so covered operators will need to have disclosures in place by then. If you're using a digital format such as a QR code menu, a written alternative must be available on request. Read the SB 68 requirements overview.
Which restaurant chains need SB 68 allergen disclosures?
California's requirement applies to restaurant chains with 20 or more locations. For a covered operator, the practical task is to connect each menu item to reviewed ingredient information and make that information available to guests. California's legislative announcement describes the menu-item disclosure requirement.
Start by assigning an owner for the work. Someone needs to coordinate recipes, supplier documents, menu publishing and location updates. Don't leave each shift manager to rebuild the same information from memory.
A chain can use one approved recipe record while still checking whether a location uses different components. Ask each kitchen to identify substitutions and preparation differences before you publish its disclosures.
For broader requirements across your footprint, consult the restaurant allergy laws by state. Keep that legal review separate from the operational checklist below, which offers practical ways to maintain your menu information.
What allergens should your menu review cover?
The nine major allergens are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. California's disclosure requirement concerns those allergens contained as ingredients in each menu item. The California Senate announcement lists the allergens.
Your review should follow the complete recipe, including purchased components. A dish name won't tell you everything that's in a marinade, dressing or garnish. Use the actual recipe and current supplier information, rather than assumptions about what a dish usually contains.
Work through each item in this order:
- List the complete build. Include the main ingredients, sauces, dressings, toppings, cooking oils and finishing touches.
- Check purchased components. Match the exact product in use to its current ingredient specification. Don't substitute a document for a similar product.
- Record ingredient allergens. Connect each finding to the component that contains it so another reviewer can follow the decision.
- Review available modifications. Check what changes when staff remove or substitute a component. Don't assume removing one topping removes every source of an allergen.
- Have the kitchen confirm the record. Resolve missing information before treating the item as reviewed.
A free allergen matrix builder can help organize the findings. The matrix still needs someone to verify every entry against what the kitchen actually makes.
How do you turn recipes into clear menu disclosures?
Write disclosures that a guest can connect to a specific item. Don't make the guest interpret a broad statement about the whole menu to work out which ingredients apply to their order.
Consider a hypothetical chicken sandwich. Suppose the reviewed build identifies wheat in the bun, milk in the cheese and eggs in the sauce. The disclosure should reflect the sandwich as normally served. A separate modification note can explain what staff can remove, subject to kitchen confirmation.
These records serve different purposes:
| Record | What it should explain |
|---|---|
| Standard item disclosure | Ingredient allergens in the normal recipe |
| Modification note | What changes when an approved component is removed or replaced |
| Preparation note | Relevant shared equipment and cooking methods for staff to discuss |
Keep those distinctions visible. An instruction to remove cheese doesn't establish that the remaining sandwich has no milk ingredients. Staff still need to check the complete build.
Use consistent item names across the recipe record and guest menu. If the kitchen calls it the house chicken sandwich but the printed menu calls it the signature chicken sandwich, make the connection explicit. This guide to how to label allergens on a menu can support your review.
Can you use a QR code menu for SB 68?
Yes. California permits a digital format such as a QR code menu when a written alternative is available on request. A digital disclosure system therefore needs a working process for providing that written information. The SB 68 overview explains digital and non-digital options.
Choose a printed format your team can keep current. That might be an item-by-item chart or a separate allergen menu. Use the same approved ingredient records for both versions, and put a revision date on the printed copy so managers can identify an old one.
Test the guest experience during service. Can a host or server retrieve the written version without hunting through an office? Does the QR code lead to the information you're expecting? Do the dish names match today's menu?
Imagine a party of six sitting down during dinner service. One guest's phone battery is dead. The server should be able to bring the written information and say, "Here's our allergen information. Please tell me about your allergies, and I'll check your order with the kitchen."
Also compare any website, app or kiosk menus your business maintains with the approved records. That's a practical consistency check, rather than a reason to assume every channel has updated automatically.
How should staff handle ingredient and cross-contact questions?
Ingredient information and preparation questions belong in the same conversation, but keep them distinct. Knowing what's in the recipe doesn't answer whether a dish shares a fryer, grill or prep station with another item.
Document the kitchen's actual equipment arrangements. For shared fryers, record which dishes use each fryer and which oil it contains. Ask the kitchen to review these records whenever equipment use or preparation methods change.
A guest might ask whether removing a sauce addresses their allergy concern. Staff shouldn't guess from the menu description. A useful response is: "I'll check the ingredients in the rest of the dish and ask the kitchen about preparation."
Make the handoff specific. The server should communicate the guest's stated allergy, the proposed dish and any requested modification. The kitchen should confirm the order before staff communicate the answer to the guest.
Practice that exchange at a pre-shift meeting. Include a case where information is missing. Staff need to know whom to ask and how to explain that they haven't confirmed an answer yet.
Use a restaurant cross-contact checklist to structure the discussion. Guests should always tell staff about allergies, and staff should confirm each order with the kitchen.
How do you update disclosures after supplier or recipe changes?
Treat allergen information as part of changing a recipe or purchased component. Don't make the update depend on someone remembering to edit a separate document after the new product reaches the line.
For example, imagine a location receives a substitute dressing. Before staff serve it, the manager should obtain its ingredient information, compare it with the approved dressing and identify every menu item that uses it. The resulting review should determine what needs to change in the guest information and staff instructions.
Give the process a clear sequence:
- Record the proposed recipe or supplier change.
- Review the new ingredients and affected dishes.
- Confirm any changes to modification or preparation notes.
- Update digital disclosures and written copies.
- Brief the team before serving the changed item.
Keep the supporting specification, reviewer name and effective date with the record. Retire the previous printed version so staff don't accidentally hand it to a guest.
This workflow for updating allergen information after recipe or supplier changes can help you build a repeatable process. The goal is straightforward: the information at the table should describe the recipe being served that shift.
What should you look for in allergen menu software?
If your team wants guests to filter the menu themselves, evaluate how the software supports restaurant review and ongoing updates. Start with a representative menu item that includes a purchased sauce and a preparation note. Follow it from ingredient review to the guest display, then change a component and check the result.
Can I Dine?™ is one practical option. Restaurants upload their current menu, and an AI-assisted upload prepares a draft for staff to review. The team checks dishes, ingredients, components, cooking oils and shared fryer, grill or prep station groups before publishing a branded QR code menu.
Guests scan the QR code at the table in their phone browser, choose their allergies and dietary needs, and see dishes sorted into suggested, may need a modification, and avoid. A Severe allergy setting removes dishes with relevant shared-equipment or cooking-oil exposure. Explore the restaurant allergen menu software to assess whether that workflow fits your operation.
The product organizes information the restaurant provides. It doesn't inspect kitchens or replace staff confirmation. Keep your written alternative current alongside the digital menu.
Before approving a system, have a manager and server test a complete guest conversation. Can they find the item, explain a proposed modification and confirm the order with the kitchen? That service check connects the disclosure work to the moment your team actually needs it.
Frequently asked questions
When did California SB 68 allergen disclosure take effect?
California SB 68 took effect July 1, 2026. Covered restaurant chains will need to have written notice of the nine major allergens contained as ingredients in each menu item by July 1, 2026. Operators should review their published disclosures against current recipes and supplier information, then correct any differences. [Read about the law taking effect](https://www.allergicliving.com/2026/06/29/adde-allergens-on-menu-act-takes-effect-inspiring-more-states/).
Does California SB 68 apply to every restaurant?
California SB 68's menu disclosure requirement applies to restaurant chains with 20 or more locations. Operators reviewing their obligations should establish whether their business falls within that threshold before choosing a disclosure process. For covered chains, the requirement is written notice of ingredient allergens in each menu item. [See the SB 68 overview](https://www.afslaw.com/perspectives/alerts/california-enacts-first-the-nation-allergen-disclosure-law-restaurant-chains).
Which allergens must covered restaurant chains disclose?
Covered chains must disclose milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame when they're ingredients in a menu item. Review the complete recipe, including purchased sauces, dressings and garnishes, using current supplier information. Guests should tell staff about allergies, and staff should confirm orders with the kitchen. [See California's allergen list](https://sd20.senate.ca.gov/news/sb-68-allergen-disclosures-dining-experiences-sent-governor-newsom).
Can a restaurant use a QR code for SB 68 disclosures?
Yes. A digital format such as a QR code menu is permitted when a written alternative is available on request. Keep both versions connected to the same reviewed ingredient information, and train staff to retrieve the written copy during service. Guests should still tell staff about allergies. [Read the digital disclosure overview](https://www.afslaw.com/perspectives/alerts/california-enacts-first-the-nation-allergen-disclosure-law-restaurant-chains).
How should restaurants maintain allergen disclosures after a supplier change?
Review the substitute product's current ingredient specification before serving it. Identify every dish that uses it, check whether ingredient allergens or modification notes change, and update digital information and printed copies together. Don't rely on the previous product's record. Brief staff on the change, and have them confirm guest allergy orders with the kitchen.
Sources
Can I Dine?™ organizes the information a restaurant provides so guests and staff can have a clearer conversation. It doesn't inspect kitchens or certify allergen-free preparation. Always tell your server about your allergies before ordering.