Achieving SB68 compliance requires restaurant chains to complete five critical steps: verify supplier allergen data, update all menu formats, train staff comprehensively, implement allergen management systems, and establish emergency response protocols. This comprehensive checklist ensures your restaurant chain meets California's July 1, 2026 deadline while protecting customers and minimizing liability.
Use this step-by-step compliance roadmap to systematically prepare your operation for California's first-in-the-nation restaurant allergen disclosure law.
Phase 1: Initial Assessment & Planning (Months 1-2)
Determine If SB68 Applies to Your Operation
Before investing resources, confirm whether your restaurant qualifies under the law:
- Count total locations: Include all company-owned and franchised locations operating under the same brand name nationwide (not just California locations)
- Verify menu consistency: Ensure locations offer "substantially the same menu items" as required by the law
- Check exemption status: Confirm you're not operating as a compact mobile food operation or nonpermanent facility
- Document your determination: Create written records of your compliance assessment for future audits
Action Item: If you operate 20+ locations with substantially similar menus, proceed with full compliance implementation.
Assemble Your SB68 Compliance Team
Successful implementation requires cross-functional collaboration:
- Appoint a compliance lead: Designate one person responsible for overall SB68 implementation
- Include operations leadership: Bring in regional managers who understand day-to-day restaurant operations
- Involve culinary/R&D teams: Recipe developers must verify ingredient formulations
- Engage marketing/design: Menu redesign requires creative and brand alignment
- Include IT/technology staff: Digital menu systems need technical implementation
- Add legal/risk management: Ensure compliance strategy addresses liability concerns
- Coordinate with franchisees: If applicable, create communication channels with franchise operators
Create Implementation Timeline
Work backward from the July 1, 2026 deadline:
- Set internal deadline: Target 2-4 weeks before legal deadline as your "go-live" date
- Map major milestones: Identify completion dates for supplier verification, menu updates, training, and testing
- Build in buffer time: Allow extra weeks for unexpected delays or issues
- Schedule regular check-ins: Weekly or bi-weekly team meetings to track progress
Phase 2: Supplier Verification & Ingredient Documentation (Months 2-4)
Request Allergen Information from All Suppliers
This is often the most time-consuming phase:
- Create standardized request form: Design a template asking suppliers to identify all nine major allergens in each product
- Send requests to all vendors: Include produce, protein, dairy, bakery, beverage, and specialty ingredient suppliers
- Request specification sheets: Obtain detailed ingredient lists and allergen statements
- Verify "contains" vs. "may contain": Distinguish between intentional ingredients and cross-contamination risks
- Ask about processing facilities: Understand shared equipment and cross-contact potential
- Set response deadline: Give suppliers 2-4 weeks to provide complete information
- Follow up on non-responses: Send reminder emails and make phone calls to delinquent suppliers
Pro Tip: Many large suppliers already have allergen documentation prepared for retail customers. Ask if they have existing allergen statements you can use.
Create Master Ingredient Database
Organize supplier information systematically:
- Build spreadsheet or database: Create centralized repository for all ingredient allergen data
- Include product codes/SKUs: Link allergen info to specific ordering codes
- Document supplier contacts: Note who provided information and when
- Flag incomplete data: Identify ingredients where allergen information is missing or unclear
- Note update frequency: Record how often suppliers update their formulations
- Establish verification schedule: Plan for quarterly or annual re-verification with suppliers
Analyze Each Menu Item
Map ingredients to menu items:
- List every menu item: Include regular menu, kids menu, seasonal items, and limited-time offers
- Break down recipes: Document every ingredient in each dish
- Identify allergen presence: Cross-reference ingredients with your allergen database
- Note customizations: Track how modifications (no cheese, add bacon) affect allergen content
- Consider garnishes and sides: Don't forget bread baskets, garnishes, and automatic sides
- Review preparation methods: Identify shared fryers, grills, or equipment that might cause cross-contact
- Document findings: Create comprehensive allergen matrix showing which items contain which allergens
Common Oversights to Avoid:
- Butter on the grill (milk allergen)
- Flour used to dust surfaces (wheat allergen)
- Soy oil in fryers (soybean allergen)
- Fish sauce in dressings (fish allergen)
- Sesame in specialty bread buns
Phase 3: Menu Design & Implementation (Months 4-6)
Choose Your Disclosure Method
Select the approach that works for your brand:
Option 1: Direct Menu Labeling
- Design allergen icons or symbols: Create clear, recognizable symbols for each allergen
- Add text callouts: Include written allergen lists below menu items
- Test readability: Ensure allergen info is clearly visible, not buried in fine print
- Maintain brand consistency: Integrate allergen disclosure into overall menu design aesthetic
Option 2: Digital Disclosure
- Develop QR code system: Create unique codes linking to allergen information
- Build mobile-friendly landing pages: Ensure website displays properly on smartphones
- Enable filtering/search: Allow customers to search by allergen or menu item
- Create printed backup materials: Design allergen charts, grids, or booklets as alternative format
- Train staff on backup systems: Ensure servers can quickly provide printed alternatives
Update All Menu Formats
- Printed dine-in menus: Redesign physical menus with allergen information
- Digital menu boards: Update electronic displays with allergen callouts or QR codes
- Online ordering platforms: Add allergen filters to website and app ordering
- Third-party delivery apps: Coordinate with DoorDash, Uber Eats, etc. to display allergen info
- Drive-through menu boards: Ensure allergen information is accessible at drive-through
- Catering menus: Update banquet and catering materials
Create Supporting Documentation
Develop customer-facing materials:
- Design allergen guide: Create detailed handout explaining your allergen management program
- Draft FAQ sheet: Answer common customer questions about allergens and preparation
- Prepare staff talking points: Develop scripts for servers discussing allergens with guests
- Create allergy alert cards: Provide cards customers can present to kitchen staff about their specific allergies
Phase 4: Staff Training & Communication (Months 5-7)
Develop Comprehensive Training Program
Training must cover all staff levels:
Management Training:
- Deep dive on SB68 requirements: Ensure managers understand legal obligations
- Review penalty structure: Explain consequences of non-compliance
- Emergency response protocols: Train on allergic reaction response procedures
- Customer complaint handling: Prepare managers to address allergen-related concerns
Server/Front-of-House Training:
- Menu allergen content: Teach staff which items contain which allergens
- Communication skills: Practice discussing allergens confidently with guests
- Customization impacts: Explain how modifications affect allergen content
- When to involve management: Train on escalating complex allergen questions
- Reading customer cues: Recognize when a guest has serious allergy concerns vs. preferences
Kitchen/Back-of-House Training:
- Cross-contamination prevention: Teach proper sanitation and separation techniques
- Special request protocols: Establish procedures for allergy-specific preparation
- Ingredient verification: Train cooks to double-check ingredients when questions arise
- Equipment cleaning standards: Review procedures for shared equipment
Document Training Completion
Maintain compliance records:
- Create training attendance logs: Record who attended each session and when
- Require signed acknowledgments: Have employees sign forms confirming they understand allergen protocols
- Test comprehension: Use quizzes or practical demonstrations to verify learning
- Schedule refresher training: Plan for quarterly or semi-annual updates
- Train new hires: Incorporate allergen training into onboarding for all new employees
Phase 5: Systems & Technology Implementation (Months 5-7)
Implement Technology Solutions
Leverage technology for accuracy and efficiency:
- Evaluate allergen management software: Research platforms designed for restaurant allergen tracking
- Integrate with POS systems: Connect allergen data to point-of-sale for real-time accuracy
- Create digital menus: If using QR codes, build and test mobile menu pages
- Set up automated alerts: Configure systems to flag menu items when ingredients change
- Enable kitchen display notifications: Show allergy alerts on kitchen screens for special orders
- Test all systems: Run thorough testing before launch, including mobile devices and various browsers
Establish Documentation Systems
Create audit trails for compliance:
- Set up filing system: Organize supplier letters, training records, and menu versions
- Create version control: Track menu updates and effective dates
- Document recipe changes: Maintain records when formulations change
- Log customer incidents: Record any allergen-related customer concerns or reactions
- Schedule regular reviews: Plan monthly or quarterly documentation audits
Phase 6: Emergency Preparedness (Ongoing)
Develop Allergic Reaction Response Plan
Be prepared for emergencies:
- Create written protocol: Document step-by-step response to allergic reactions
- Post emergency numbers: Display 911 and poison control prominently in all locations
- Identify nearest hospitals: Know the closest emergency rooms to each location
- Train on epinephrine auto-injector use: While restaurants don't provide these, staff should recognize them
- Establish incident reporting: Create forms for documenting any allergic reaction incidents
- Review insurance coverage: Confirm your liability insurance covers allergen-related claims
Plan for Menu Changes
Maintain compliance as menus evolve:
- Create change management process: Establish approval workflow for new menu items
- Require allergen analysis: Make allergen verification mandatory for all new recipes
- Update all menu formats: Ensure printed, digital, and online menus stay synchronized
- Retrain staff: Brief employees whenever menu allergen content changes
- Notify regular customers: Consider alerting loyalty program members about significant changes
Phase 7: Final Pre-Launch Checklist (Month 8)
Conduct Comprehensive Audit
Verify everything is ready:
- Spot-check multiple locations: Visit various restaurants to inspect menus and observe staff knowledge
- Mystery shop your restaurants: Have compliance team members dine anonymously and ask allergen questions
- Review all menu formats: Confirm consistency across printed, digital, and third-party platforms
- Test digital systems: Verify QR codes work and websites display correctly
- Confirm training completion: Ensure 100% of staff have completed allergen training
- Verify backup materials: Check that printed allergen materials are available for guests without digital access
- Document readiness: Create written report confirming compliance across all locations
Launch and Monitor
Go live with confidence:
- Set official launch date: Activate new menus at all locations simultaneously or in phases
- Announce to customers: Use social media and in-store signage to highlight your allergen-friendly commitment
- Monitor customer feedback: Track comments about allergen information ease and accuracy
- Address issues quickly: Resolve any gaps or errors immediately
- Celebrate success: Recognize team members who contributed to successful implementation
Ongoing Compliance Maintenance
Quarterly Reviews
Stay compliant long-term:
- Re-verify supplier information: Confirm ingredient formulations haven't changed (quarterly)
- Update menus as needed: Reflect any recipe or supplier changes (ongoing)
- Refresh staff training: Conduct allergen training refreshers (semi-annually)
- Audit documentation: Review training logs, supplier letters, and incident reports (quarterly)
- Monitor regulatory changes: Watch for updates to SB68 or related California regulations (ongoing)
Frequently Asked Questions
Q: How long does full SB68 compliance implementation typically take?
A: Most restaurant chains need 6-8 months for complete implementation. Supplier verification alone can take 2-3 months, followed by menu redesign (2 months), staff training (1-2 months), and system testing (1 month). Starting early is critical.
Q: What's the single most common mistake restaurants make during SB68 implementation?
A: Underestimating the time required for supplier verification. Many suppliers take weeks to respond with allergen data, and incomplete information requires follow-up. Start this process immediately.
Q: Do I need to list allergens that might be present due to cross-contamination?
A: SB68 requires disclosure of allergens in ingredients, not potential cross-contamination. However, advisory statements about cross-contact risk (e.g., "Prepared in a kitchen that handles peanuts") are recommended best practices, even if not legally required.
Q: Can I use the same allergen information for all my locations if they serve identical menus?
A: Yes, if all locations truly use the same suppliers, recipes, and preparation methods. However, you should verify this assumption, as regional suppliers or local sourcing may create variations.
Q: What should I do if a supplier won't provide allergen information?
A: Consider switching suppliers. Without allergen data, you cannot comply with SB68. Most reputable food service suppliers readily provide this information, as retail packaged food manufacturers have been doing so for years.