Topic: Hidden allergens and common sources under California’s ADDE Act (SB-68).
Why it matters: The ADDE Act requires full allergen disclosure for every menu item, including hidden or derivative sources. Failing to identify these can lead to inaccurate menus, inspections, or guest incidents.
Key action: Audit all recipes and supplier specifications for derivative ingredients (such as whey, soy lecithin, or anchovy paste) and connect sub-recipes in your menu management platform to ensure total traceability.
The Allergen Disclosure for Dining Experiences (ADDE) Act requires disclosure of the Top 9 major food allergens. While some allergens are easy to spot (like shellfish or milk-based dishes), most compliance failures arise from hidden derivatives or cross-contact risks in sauces, dressings, and processed ingredients. Ensure your food data management system follows the gold standard for recipe creation so that sub-recipes, marinades, weight-change factors and cooking are handled correctly.
To ensure your digital allergen management system remains accurate, recipes must capture these indirect sources of allergens. Use the guide below during recipe standardisation and supplier verification.
Operational guide: hidden allergens and common sources
| Major Allergen | Common Derivatives & Protein Sources | Hidden in Common Foodservice Items |
|---|---|---|
| Milk | Casein, Whey, Lactose, Butterfat, Ghee | Sauces & soups (Alfredo, Béchamel), deli meats, baked goods (glazes), coffee foams. |
| Eggs | Albumin, Lysozyme, Lecithin (egg) | Mayonnaise, Caesar dressing, egg-washed pastries, fried foods (shared oil risk). |
| Wheat | Flour, Gluten, Spelt, Semolina, Modified Food Starch (wheat-based) | Soups, sauces (thickening agents), batter, spice blends (anti-caking), beer. |
| Soybeans | Soy Sauce, Miso Paste, Tofu, HVP, Soy Lecithin | Asian sauces, processed foods, baking ingredients, chocolate (lecithin). |
| Fish | Anchovies, Fish Sauce, Fish Stock, Surimi | Worcestershire sauce, Caesar dressing, relishes, salad dressings. |
| Crustacean Shellfish | Shrimp Paste, Seafood Stock | Shared fryers, seafood soups, bisques, certain sushi rolls. |
| Tree Nuts | Nut Flours, Marzipan, Pesto (pine nuts), Nut Oils* | Baked goods, pesto sauces, granola, vinaigrettes, praline desserts. |
| Peanuts | Peanut Oil**, Peanut Flour, Peanut Protein Hydrolysate | Satay, Pad Thai, curries, mole sauce, baked goods. |
| Sesame | Tahini, Sesame Oil, Sesame Seeds | Buns, bagels, hummus, marinades, spice mixes. |
* Highly refined nut oils may be exempt under FALCPA if no allergenic proteins remain, but documentation must confirm refinement.
** Peanut oil requires declaration unless verified as highly refined.
Reducing risk from derivatives
The ADDE Act allows operators to exclude highly refined oils when verified, but all protein-based derivatives (such as whey or soy sauce) must be disclosed if present in the finished dish. Your menu management platform should link every sub-ingredient to its parent allergen automatically to maintain traceability.
Context: The Allergen Disclosure for Dining Experiences (ADDE) Act makes allergen disclosure mandatory for restaurant chains with 20 or more locations. It amends Section 113820.5 and adds Section 114093.5 to the California Health and Safety Code (HSC).
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