What California Restaurants Need to Do for SB 68: A Practical Checklist

Step 1: Document Every Recipe, Product, and Ingredient

The foundation of SB 68 compliance is an accurate and complete record of every ingredient in every menu item across every location. This means documenting every menu recipe, every sub-product used in those recipes, and every ingredient in those sub-products — noting the source of each.

Step 2: Cross-Check Every Ingredient Against the Big 9

With your ingredient list documented, every item must be verified against the nine major allergens: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soy, and sesame. This requires reading current supplier specification sheets for every composite product, sauce, seasoning blend, and prepared ingredient.

Common hidden allergens that get missed: Worcestershire sauce (fish), soy sauce (wheat), cashew cream (tree nuts), tahini-based dressings (sesame), and seasoning blends with natural flavours that contain dairy derivatives.

Step 3: Get Current Supplier Specification Sheets

Current is the operative word. A specification sheet from two years ago does not reflect what a supplier's product contains today. For every product in your operation, request an updated spec sheet from the supplier — dated within the last twelve months — and verify the allergen declaration against your records.

Step 4: Review Supplier Contracts

As allergen labeling laws expand, supplier contracts become a risk management document. Key provisions to consider: notification requirements when a supplier reformulates a product, substitution protocols that require prior approval and allergen review, and indemnification terms if a supplier change causes an allergen incident.