Allergen Disclosure for Dining Experiences Act Knowledge Hub

The 9 Major Allergens Restaurants Must Disclose in California

Learn the 9 Allergens That Must Be Added to Menus and Where to Find Them

Under the Allergen Disclosures for Dining Experiences (ADDE) Act (SB-68), California restaurants are required to disclose 9 allergens in all menu items.

Food allergies affect an estimated 32 million Americans, and mislabeling can lead to severe allergic reactions or death. Accurate identification of these allergens across ingredients, recipe and menus is critical for consumer safety and legal compliance. Make sure your team understand the 9 major allergens, and where to find them.

So, What Are The 9 Major Allergens?

  • Milk
  • Eggs
  • Fish (e.g., bass, cod, flounder)
  • Crustacean shellfish (e.g., crab, lobster, shrimp)
  • Tree nuts (e.g., almonds, walnuts, pecans)
  • Wheat
  • Peanuts
  • Soybeans
  • Sesame

    Sesame was added as the 9th major allergen in 2023 under the federal FASTER Act on prepacked foods,and is also required under the ADDE Act.

Protein Derivatives

Allergens must be disclosed for the 9 major allergens and any ingredient made from them. “Protein derivatives” are ingredients that still contain allergenic protein and can trigger a reaction. Protein derivatives can be easy to spot (e.g. peanut butter) while some are not easy to spot (e.g. tahini).

Hidden allergens can appear in compound ingredients, derivatives, or supplier substitutions. Even with digital menu management systems that help track allergens, staff must understand the 9 allergens and review the information to ensure accurate disclosures and protect guests.

Some areas to keep an eye on in your operations include –
    • Ingredient derivatives: Watch for whey (milk), casein (milk), soy sauce (soy), and egg lecithin (egg).
    • Multi-component items: Break down sauces, dressings, and toppings — sub-recipe allergens must be declared.
    • Supplier updates: Verify new and reformulated ingredients even when packaging looks the same.
    • Ingredient swaps: Keep a list in the kitchen of safe substitutes for all ingredients so allergens remain accurate.

This table contains some examples of allergens, protein derivatives, and where they can be found in a commercial kitchen –

Allergen SourceSample Protein DerivativeHidden Risk in Menu Items
MilkWhey, Casein, Lactose, Ghee, Buttermilk, Milk powderSoups, sauces, baked goods, coffee drinks, desserts
EggsAlbumin, Lysozyme, Lecithin (egg), Dried egg, Egg powder, Egg yolk solidsDressings, glazes, batters, desserts, pasta
WheatModified starch, Semolina, Wheat protein isolateCoatings, sauces, soups, breads, pasta
SoybeansTofu, Hydrolysed Vegetable Protein (HVP), Soy lecithin, Miso, Textured vegetable protein (TVP)Sauces, chocolate, meat alternatives, non-stick sprays
PeanutsPeanut flour, Peanut butter, Peanut oil, Protein isolate, Peanut mealAsian dishes, baked goods, sauces, snacks
Tree nutsNut flours, Marzipan, Oils, Almond meal, Cashew pasteSalads, desserts, pesto, sauces
FishAnchovy, Fish sauce, Fish stock, Fish gelatin, Fish powderCaesar dressing, soups, sauces, seafood broths
Crustacean shellfishShrimp paste, Crab extract, Lobster stock, Crustacean protein powderBisques, stir-fries, shared fryers
SesameTahini, Sesame oil, Seeds, Sesame pasteBreads, sauces, dressings, hummus
Highly refined oils (such as refined peanut or soy oil) are exempt from allergen disclosure under the ADDE Act if they contain no residual protein. Cold-pressed or blended oils may still contain proteins which need to be declared as allergens.

By understanding the 9 major allergens, operators can ensure no hidden allergens go unnoticed and maintain consistent, safe menu offerings across all locations.

Ensure Your Menus Are SB-68 Compliant

Access expert guidance, tools, and templates to accurately identify the 9 major allergens and maintain menu compliance across your California locations.

Ask an Allergen Expert Download Compliance Resources View SB-68 Legislation

Context: California Senate Bill 68 (ADDE Act) requires restaurant chains with 20 or more U.S. locations to provide accurate written allergen disclosures on all menus by July 1, 2026. It amends Section 113820.5 and adds Section 114093.5 to the California Health and Safety Code (HSC).

 

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