This checklist is a practical way to review how prepared your business is today. It helps teams assess whether allergen information is clear, accessible, and supported by a process that can hold up in service and during an inspection.
This resource is guidance only and does not constitute legal advice. Refer to SB-68 and the California Health & Safety Code for the full legislative text.
Need a version your team can use operationally? Download the complete SB-68 Compliance Checklist as a printable, audit-ready PDF, ready to share across teams and locations. Download the SB-68 Compliance Checklist (PDF)
SB-68 Compliance Checklist (Quick Self-Assessment)
Use this checklist to assess whether your allergen information is accurate, accessible, and controlled across menus, locations, and day-to-day workflows.
It is a quick way to test whether the basics are in place before problems show up in service, customer queries, or inspections.
1. Does the law apply to your business?
- You operate 20+ locations under the same brand with a similar menu
- You sell food directly to consumers (restaurant, café, takeaway, delivery, ghost kitchen)
- You’ve assessed whether franchised or licensed locations count toward the 20-site threshold
- You’ve reviewed allergen requirements separately for packaged vs prepared foods
- Your business is not exempt (e.g. mobile operations, temporary facilities, pre-packaged-only businesses)
2. Have you correctly identified allergens in your menu?
- Every menu item has been reviewed for the 9 major allergens
- Protein-derived ingredients (e.g. casein, whey, soy sauce) are included in your assessment
- Exempt ingredients (e.g. highly refined oils) are handled correctly
- Multi-component items (e.g. meal deals, build-your-own options) include allergens across all components
- Supplier allergen data is validated regularly, not just at onboarding
- Change logs and version history are maintained for allergen updates
3. Are your allergen disclosures compliant and accessible?
- Each menu item includes a clear allergen statement (not just symbols)
- Digital disclosures are accessible and functional (e.g. QR codes, screens are reliable and usable)
- A written alternative is always available (menu, chart, or booklet on request)
- Allergen names are consumer-friendly (e.g. “milk” instead of technical ingredient terms)
- Pictograms are applied consistently across all platforms (in-store, web, app)
- Accessibility standards are met (e.g. screen reader compatibility, readable formats)
- Information is consistent across all channels, including apps, websites, and third-party delivery platforms
4. Do you have the right processes in place?
- A documented allergen data flow exists (supplier → recipe → menu → customer)
- Systems are in place to detect mismatches between supplier data and menu disclosures
- Recipe audits are conducted regularly
- Internal mock audits are completed on a consistent basis
- Staff training covers front-of-house, kitchen, and delivery roles
- Training records are maintained and kept up to date
For a more detailed look at this, read our How to Comply guide.
5. Are you audit-ready?
- Allergen information can be verified across all customer-facing channels
- Documentation is readily available (supplier specs, allergen logs, training records)
- A clear process exists for identifying and correcting allergen errors
- Standard operating procedures (SOPs) are in place for handling allergen queries
- Evidence shows proactive monitoring—not just reactive fixes
Take a look at our How to Carry Out Internal Allergen Audits article for more information.
Download the Full SB-68 Compliance Checklist
If you are managing allergen compliance across multiple locations or teams, a structured version of this checklist can make reviews easier to run and easier to document.
The full checklist includes:
- a complete version of each review area
- a format that can be used during site reviews or internal audits
- a structure that supports documentation, tracking, and sign-off across teams
It’s designed to help you move from a quick self-assessment to something your team can actually use day-to-day.
Download the SB-68 Compliance Checklist (PDF)
Why Most Restaurants Struggle with SB-68 Compliance
Even for well-run operations, SB-68 exposes gaps that don’t show up in day-to-day service. The challenge isn’t usually awareness, it’s execution at scale, across menus, locations, and systems.
Manual processes break at scale
It’s designed to help you move from a quick self-assessment to something your team can actually use day-to-day.
- Menu updates don’t sync: A recipe change may be updated in one place but missed somewhere else. Website menus, delivery platforms, PDFs, and printed materials can all drift apart if updates are pushed through different workflows.
- Data inconsistencies build up quickly: Different teams working from different versions of recipes or supplier specs leads to conflicting allergen information.
- Version control becomes unclear: Without a clear source of truth, it’s difficult to track what changed, when it changed, and which version is currently live across locations. For a more in-depth look at this, read our Building a Central Allergen Database for Compliance with the ADDE Act article.
This is where many operators get caught out, especially when asked to prove consistency during an audit.
Allergen data is harder to control
Allergen status is not static. Supplier changes, reformulations, substitutions, and location-level tweaks can all affect what should appear against a menu item. If that information is not reviewed and updated consistently, accuracy starts to slip.
- Hidden ingredients are easy to miss: Items like sauces, marinades, and pre-prepared components often contain allergen sources that aren’t obvious at a glance.
- Supplier changes introduce risk: Even small changes in supplier specs can affect allergen status, and these don’t always flow through to recipes or menus in real time. For a more detailed look at this issue, read our Why Spreadsheets Fail for ADDE Act Allergen Management article.
- Recipe variations complicate tracking: Seasonal changes, substitutions, or location-specific tweaks can alter allergen profiles without being consistently documented.
Without tight control over how this data is managed and updated, it’s difficult to stay accurate, let alone audit-ready.
Multi-channel menus create risk
Most operators are not managing a single menu. They are managing multiple versions of the same menu across different channels.
- Web, in-store, and delivery platforms drift apart
Updates made to one channel do not always flow through to others. A corrected allergen on your core menu can remain outdated on a delivery app or PDF. - Outputs become inconsistent
The same item can display different allergen information depending on where the customer sees it. This is often caused by disconnected systems or manual updates across channels.
When allergen data is not centrally controlled, consistency becomes difficult to maintain. That is where risk builds, especially in multi-location environments.
How to Use This Checklist in Practice
A checklist is only useful if it turns into action. For most teams, that means building it into existing workflows rather than treating it as a one-off review.
To get the most value from this checklist, follow these five steps:
1. Run an initial assessment
Start by working through the checklist as it stands today. Do not aim for perfection on the first pass. The goal is to identify where you have clear coverage and where things are unclear, undocumented, or inconsistent.
This is often where gaps show up quickly, especially around supplier data, menu consistency, and documentation.
2. Assign ownership by function
Allergen compliance rarely sits with one team. Culinary may own recipes, procurement may manage supplier data, operations may control menu rollout, and QA or compliance may oversee audits and records. The important thing is to make ownership clear.
3. Prioritize the gaps
Start with the issues that affect what customers actually see and use. That usually means missing allergen statements, mismatches between channels, outdated supplier data, or weak backup formats.
Lower-risk items, like formatting or documentation structure, can follow once core accuracy is in place.
4. Implement fixes in your workflow
The strongest fixes are the ones that become part of normal operations. That may mean improving supplier-data checks, tightening recipe approvals, or making sure menu updates flow through every channel from one controlled process.
5. Schedule recurring audits
Compliance does not stand still. Menus change, suppliers change, and teams change. A regular review cycle makes it easier to catch gaps before they become service issues or inspection problems.
Set a regular review (whether quarterly or aligned to menu updates), and include:
- recipe checks
- menu spot checks across channels
- training refreshers
- documentation reviews
- substitute lists
Teams that treat this as an ongoing process are far more likely to stay accurate and audit-ready.
Common SB-68 Compliance Gaps
Most SB-68 issues are not caused by a lack of effort. They usually come from small breakdowns across systems, teams, and updates that build over time.
These are the gaps that tend to cause the most trouble in practice.
Missing allergen statements on some items
Core menu items are often covered, but edge cases get missed.
- Limited-time offers
- Seasonal items
- Build-your-own or modifier-based dishes
- Items added quickly at location level
These gaps usually appear when menu changes move faster than the underlying data and approval process.
Inconsistent information across platforms
The same item can show different allergen information depending on where it appears.
- In-store menus vs website
- Owned channels vs third-party delivery apps
- PDFs or printed materials that are not updated
This usually comes back to disconnected systems or manual publishing workflows.
No alternative written format available
Digital access is not always enough. If allergen information is only available via QR codes or screens, teams can struggle to provide it when:
- devices are unavailable
- connectivity drops
- customers request a physical format
A clear backup format is often overlooked until a customer or inspector asks for it.
Poor version control
Many teams cannot easily answer simple questions like:
- What changed in this recipe?
- When was the allergen data last updated?
- Who approved it?
Without version history and change logs, it becomes much harder to verify accuracy or show control during an audit.
Lack of training documentation
Training may be happening, but not always recorded or consistent.
- Front-of-house teams may not know how to handle allergen queries
- Kitchen teams may not understand the impact of substitutions
- Records of training and refreshers may not be maintained
That creates risk in day-to-day service and makes inspections harder to manage.
Frequently Asked Questions
What is the SB-68 compliance checklist?
The SB-68 compliance checklist is a practical tool for reviewing whether your allergen disclosures, supporting data, and internal processes are ready for California’s requirements.
It helps teams check the areas that matter most:
- how allergens are identified in recipes
- how information is presented to customers
- how data is managed and updated
- how prepared you are for an inspection
In practice, it gives operations, QA, and compliance teams a structured way to spot gaps before they turn into service problems or inspection issues.
What’s the difference between SB-68 and the ADDE Act?
They refer to the same piece of legislation. SB-68 (Senate Bill 68) is the bill number assigned during the California legislative process. The official legislative title is Chapter 741, Senate Bill 68 – Major Food Allergens. The ADDE Act (Allergen Disclosure for Dining Experiences Act) is the informal name used in industry for this bill . Both terms are used interchangeably across industry guidance and regulatory documentation. In practice, when someone references SB-68 or the ADDE Act, they are talking about the same set of requirements: written allergen disclosure in California for restaurant chains with 20 or more U.S. locations, effective July 1, 2026.
Is this checklist enough to ensure compliance?
No. The checklist helps teams prepare, but it does not replace a full compliance review. It is useful for spotting gaps, improving internal checks, and getting closer to audit readiness. Compliance still depends on whether allergen information stays accurate across recipes, supplier data, menus, and service workflows.
Who needs to follow SB-68?
SB-68 generally applies to restaurant businesses operating at scale, particularly those with 20 or more locations under the same brand and a similar menu.
It covers businesses selling food directly to consumers, including dine-in, takeaway, and delivery formats. Franchise and mixed-format businesses should review scope carefully, because coverage is not always straightforward.
Although SB-68 legally applies only to large chains, all food businesses are encouraged to voluntarily implement allergen disclosure to protect customers, reduce liability, and demonstrate good foodservice practice.
Can I rely on digital allergen menus only?
Digital menus can be part of allergen disclosure, but they are not always enough on their own. In practice, you need to ensure:
- information is always accessible
- systems are reliable and up to date
- a written alternative is available if needed
Relying on one format can create gaps, especially when devices fail, connectivity drops, or a customer asks for the information another way.
What should I prepare for an inspection?
Inspectors will typically look for consistency and evidence. You should be able to show:
- accurate allergen information across menus and channels
- supplier specifications and supporting data
- change logs or version history for updates
- staff training records
- clear processes for handling allergen queries and correcting errors
It’s not just having the information, but being able to show how it is maintained, updated, and controlled. With digital systems, all information is kept in one place and easy to find if audited.
What happens if my restaurant fails an SB-68 inspection?
Violations under SB-68 can result in fines ranging from $500 to $2,500 per offense. Repeat violations may put your operating permits at risk. Beyond the financial penalties, enforcement actions can trigger negative publicity, loss of customer trust, and increased scrutiny on future inspections. Common triggers for failure include missing or incorrect allergen statements, inconsistencies between channels, and a lack of supporting documentation such as change logs, supplier specs, or training records. Most operators who encounter issues focus on tightening processes and documentation immediately to prevent repeat findings.
This resource is provided for informational purposes only. For a compliance review specific to your business, consult with a qualified food safety or regulatory professional.
Download the full SB-68 checklist
For teams managing allergen compliance across multiple locations, a quick self-assessment is only the starting point.
The full SB-68 checklist helps teams move from a quick review to a process they can use in day-to-day operations.
- A full checklist covering each stage of allergen compliance
- A format that can be shared across operations, QA, culinary, and compliance teams
- A structure that supports documentation, tracking, and sign-off
- A practical resource for site reviews, audits, and ongoing checks
It is designed for teams managing allergen data, menu updates, and audit preparation across real restaurant workflows.
Related Posts
Check if Your Business Must Comply with the ADDE Act
ADDE Act Explained: What California Restaurant Operators Need to Know
Are You Ready for SB-68 Inspections? A Foodservice Operator’s Guide to Audit Success
Sesame as One of 9 Major Allergens: How California Operators Can Update Allergen Protocols