Who Does California SB 68 Apply To? The 20-Location Rule Explained

The 20-Location Threshold

SB 68 applies to any food facility — restaurant or food service operation — that operates under the same name or substantially the same menu across 20 or more locations worldwide, where at least one of those locations is in California.

Three details matter here. First, the 20-location count is worldwide, not just California. A chain with 18 California locations and five in Texas has 23 total — it is covered. Second, "substantially the same menu" means a franchise or licensed concept offering similar items counts toward the threshold, even if individual menus vary slightly by location. Third, "food facility" is broader than restaurant — cafeterias, food halls, and food service operations in stadiums, universities, and other venues can be covered if they meet the threshold.

Independent restaurants and any chain with fewer than 20 locations nationally are not covered by SB 68. Food allergy strict liability, however, applies to every food service operation regardless of size.

Two In-Venue SB 68 Compliance Options: Print or QR Code

For covered operators, SB 68 provides two compliant methods for in-venue allergen disclosure.

Option A — Print on the physical menu. Every menu item must have its allergens listed beside it on the printed menu or menu board. This is the most direct approach but creates challenges for chains that reprint menus frequently or have multiple menu formats across locations.

Option B — QR code linking to a digital allergen menu. A QR code on physical menus and menu boards links out to a digital allergen menu. The critical requirement: if a QR code is the primary disclosure method, a printed physical backup must still be available in venue for guests without mobile devices. The QR code cannot be the only option.

The majority of operators Foodini speaks with prefer Option B — for flexibility, brand consistency, and the ability to update allergen data centrally without reprinting.

Digital Menus Under SB 68: Websites, Apps, and Delivery Platforms

The "all physical and digital menus" requirement extends beyond the dining room. Every digital surface where a consumer can view the menu and place an order — the restaurant's website, first-party online ordering, and third-party delivery platforms like DoorDash and Uber Eats — must carry allergen information. This is one of the most common points of SB 68 non-compliance, as operators focus on in-store menus and overlook delivery platform listings.