What restaurant chains, franchises, and ghost kitchens need to know about the 20-location rule
If your brand name appears on 20 locations nationwide, including even a single site in California,
SB-68 applies to you.
California’s Allergen Disclosure for Dining Experiences (ADDE) Act, also known as Senate Bill 68, is the first law in the U.S. to require restaurants to display written allergen information for the nine major allergens, including sesame.
It goes into effect July 1, 2026, and covers restaurant chains with 20 or more U.S. locations under the same name and menu. That means franchised brands, corporate groups, delivery-only kitchens, and virtual brands are all in scope.
The good news? Compliance is achievable, especially if you start now.
Step 1: Check Whether You’re Covered
The 20-location rule includes every U.S. site under your brand, not just those in California.
You’re covered if:
- You operate or franchise 20 or more U.S. locations that share the same brand name, signage, and core menu.
- Your corporate or delivery kitchens prepare the same recipes under that brand.
- You run ghost kitchens or virtual brands using a consistent menu online.
Examples: How SB-68 Applies to Different Food Businesses
| Business Example | Compliance Required? | Reason |
|---|---|---|
| Brand A has 25 restaurants across the U.S., including 2 in California. | Yes | Exceeds 20 locations nationwide and operates in California. |
| Brand B is an international chain with 30 sites worldwide and one in California. | Yes | Meets 20-location threshold; California location triggers coverage. |
| Brand C is a California franchisee of a 40-location national chain. | Yes | SB-68 applies to the overall brand, not individual owners. |
| Brand D has 15 locations nationwide. | No | Does not meet the 20-location threshold. |
| Brand E’s parent company owns several concepts, none with 20 locations each. | No | Compliance is assessed per brand concept, not total ownership. |
| Brand F sells only pre-packaged food with federal allergen labels. | No | Covered under federal labeling laws instead. |
| Brand G operates a mobile food cart. | No | Mobile operations are exempt. |
| Brand H runs a temporary festival booth. | No | Temporary or non-permanent setups are excluded. |
| Brand I has 50 restaurants across the U.S., but none in California. | No | No California presence, so SB-68 does not apply. |
Step 2: Understand What “Mostly the Same Menu” Means
SB-68 applies when your menus are largely identical (same recipes, portion sizes, and allergen content), which is standard practice for most franchise and corporate systems. Even minor regional variations don’t exempt you if the overall offering is consistent.
Step 3: Define Who Owns the Work
Clear accountability between franchisor and franchisee is essential –
| Role | Responsibilities |
|---|---|
| Franchisees (operators) | Must display accurate allergen information on every printed menu, digital board, delivery app, or website. Local managers are responsible for keeping that data current. |
| Franchisors | Must provide and maintain verified allergen data, communicate updates quickly, and ensure each location uses the same information. Training and digital tools help operators stay compliant. |
| Franchise agreements | Should explicitly state who handles allergen data management, updates, and compliance tracking to avoid confusion if inspectors or guests raise issues. |
Step 4: Make Data Consistency Your Priority
Every location should show the same verified allergen details across:
- In-store menus and menu boards
- Online ordering platforms
- Delivery partner listings
- POS and digital menu systems
Start by confirming that vendor and broadliner allergen data align with recipes and menu listings. Automated systems make this easier — allergen changes from a vendor can flow directly into every digital menu, ensuring accuracy chain-wide.
Digital Recipe Management: A Proven Model
Many U.S. restaurant brands already rely on digital food-data platforms to manage allergens, particularly those with complex supply chains, frequently changing menus, limited-time offers, or temporary menus.
These systems automate compliance, streamline allergen information from vendors to customers, and reduce manual checks. Adopting the same approach in California now saves time, lowers risk, and keeps teams audit-ready.
Countdown to July 1, 2026
Health inspectors will verify allergen disclosures at each covered location once the law takes effect.
Make sure:
- Your allergen data from vendors is complete and validated.
- All menus and digital channels show the same information
- Responsibilities for updates and reviews are clearly assigned
Need help building a chain-wide allergen plan?
Visit the ADDE Resource Hub for free templates and checklists, or learn how digital menu management tools can automate SB-68 compliance for your brand.
Talk to an expert View resources See official legislation