- On October 13, 2025, Governor Gavin Newsom signed Senate Bill 68 (the Allergen Disclosure for Dining Experiences Act) into law, making California the first state to require restaurant chains to disclose major food allergens on their menus. The law will take effect on July 1, 2026
- SB 68 applies to food facilities that are already subject to federal menu labeling requirements under the Food, Drug, and Cosmetic Act and its implementing regulations—namely, restaurant chains with 20 or more locations operating under the same name and offering substantially the same menu items. These establishments will be required to disclose the presence of any of the nine major food allergens (milk, eggs, peanuts, tree nuts, fish, shellfish, wheat, soy, and sesame) that are known or reasonably should be known to be present in each menu item.
- Restaurants may comply by:
- Listing allergens directly on the menu, adjacent to each item, or
- Providing the information digitally, such as through a QR code linking to an online allergen menu. If using a digital format, restaurants must also offer a non-digital alternative, which may include an allergen-specific menu, chart, grid, booklet, or other written materials.
- The law does not apply to compact mobile food operations, nonpermanent food facilities, or prepackaged foods already covered by federal allergen labeling requirements.
- Keller and Heckman will continue to monitor developments related to allergen disclosure laws.