What changed on 1 July 2026
California's Allergen Disclosure for Dining Experiences Act -- SB-68, generally called the ADDE Act -- took effect on 1 July 2026. It makes California the first state to require restaurants to give customers written notice of major allergens in the ingredient descriptions of their menu items.
Before it, the American position was essentially that a restaurant had to tell you about allergens if you asked. The ADDE Act moves part of the market to a written standard, and because California is the largest restaurant market in the country, a lot of national chains will implement it everywhere rather than maintain two menus.
Who it covers
The rule applies to restaurants with 20 or more locations nationally. That is the same threshold shape as the federal calorie labeling rule, and it is a national count -- a chain with three locations in California and twenty-two across the country is inside the rule, not outside it.
If you run one venue, or six, the statute does not reach you. The section on smaller operators covers why that is not the end of the question.
The nine, and how they differ from the EU's fourteen
US law works from a list of major food allergens: milk, eggs, peanuts, tree nuts, fish, shellfish, wheat, soy, and sesame. Sesame is the newest of them -- it became a major allergen under the FASTER Act, effective from the start of 2023.
If you operate in both markets, the difference is where the mistakes live. The EU's Annex II list names fourteen, and five of them have no US counterpart.
| Allergen | United States | European Union |
|---|---|---|
| Milk, eggs, fish, peanuts, soy, sesame | Yes | Yes |
| Wheat / cereals containing gluten | Wheat | Broader: rye, barley, oats, spelt too |
| Shellfish | One category | Split: crustaceans and molluscs |
| Tree nuts | Yes | Yes |
| Celery | Not listed | Yes |
| Mustard | Not listed | Yes |
| Sulphites | Not a major allergen; separate labelling rules | Yes, above 10 mg/kg |
| Lupin | Not listed | Yes |
A US chain expanding into Europe usually discovers celery first, and usually discovers it in a stock base bought from a supplier. The EU list is covered in full here.
The digital-format allowance, and its condition
The part of the ADDE Act most relevant to anyone reading this: the disclosure may be provided in a digital format, including via a QR code, rather than printed on a physical menu.
That allowance carries a condition, and the condition is not optional. A restaurant using a digital format must also offer customers a print option.
In practice this is easier than it sounds and worth doing properly:
- Keep the allergen information inside the menu itself, per item, rather than on a separate allergen page a guest has to hunt for.
- Make sure the digital disclosure is reachable without an app, an account, or a tap that hides it behind a filter.
- Keep a current printed copy at the host stand and make sure the floor staff know it exists and know to offer it.
- Reprint the paper copy on the same trigger that changes the menu, or it silently becomes the wrong document.
That last point is the real operational risk of a digital-first disclosure. The digital version updates the moment you change it. The paper copy in the drawer does not, and nobody notices until it matters.
What federal law does and does not require
It is worth stating the negative clearly, because a lot of published advice implies a rule that does not exist.
There is no single federal rule requiring every US restaurant to print allergens beside every dish. Federal allergen labelling law -- FALCPA, and the FASTER Act that added sesame -- governs packaged food labels, not the plate in front of you.
What does apply is the FDA Food Code, which most states adopt in some form. Under it, food establishments are expected to inform consumers about the major allergens in menu items on request, and staff are expected to be able to answer. That is a duty to know and to tell, not a duty to print.
Separately, the federal menu labeling rule requires calorie disclosure at establishments with 20 or more locations. That is a different rule about a different thing, and it is covered in calorie and nutrition labeling on menus.
Crossing the threshold
A rule keyed to a location count has an awkward property: a growing chain walks into it, usually while it is busy opening a location.
If you are at fifteen locations and expanding, the disclosure is a project you will need, and the expensive version is the one done in a hurry. The data work -- allergens recorded per item, sourced from supplier specifications -- is the part with a long lead time, because it depends on documents other companies have to send you. The presentation work is comparatively quick.
Two practical consequences. Build the allergen data before the threshold rather than after it, since the data is useful at any size and the deadline is not negotiable once it arrives. And record it in a system that can produce both a digital and a printed view from one source, because maintaining two documents by hand is how the paper copy ends up describing last quarter's menu.
States and cities that already went further
California is the first state to require written allergen notice in menu descriptions, but it is not the first jurisdiction to legislate in the area. Several have required allergen awareness training for food handlers, allergen notices on menus, or a designated trained person on shift -- Massachusetts, Illinois, Rhode Island, and New York City among them.
If you operate across state lines, the practical consequence is that the strictest jurisdiction you trade in sets your data standard, even where it does not set your menu design. It is cheaper to record allergens once, thoroughly, than to maintain a patchwork.
If you have fewer than twenty locations
You are outside the ADDE Act. You are not outside the reason it exists.
Three arguments for building the disclosure anyway, none of which are legal:
- A guest with an allergy is deciding whether to eat at your venue, often before they arrive. A menu that answers the question converts a table that would otherwise have gone elsewhere.
- It removes the most common interruption a server handles at the table -- going to the kitchen to ask, and coming back with an answer they are not certain of.
- The threshold is a business-size line, not a safety line. A single-site restaurant that gets an allergen wrong faces the same consequence as a chain that does.
The operational method is the same at any size: allergens recorded per item, sourced from supplier specifications, reviewed by someone who knows the recipe. How to put allergen information on a digital menu walks through it, and the nutrition and allergens feature sets out what we model.