Topic: Managing limited-time offers (LTOs) and specials under California’s Allergen Disclosure for Dining Experiences (ADDE) Act.
Why it matters: Temporary or seasonal menu items can be overlooked during allergen verification, but inspectors review every active menu at the time of inspection. Unverified specials can create immediate compliance breaches under SB-68.
Key action: Apply the same allergen review, approval, and recordkeeping workflow to LTOs as to your standard menu — ensuring each temporary item is validated before launch.
The Allergen Disclosure for Dining Experiences (ADDE) Act (SB-68) applies to all menu formats — printed, digital, and delivery — including limited-time offers, seasonal items, and kids’ menus. California inspectors assess allergen disclosure accuracy for every item available when an inspection occurs. That means even one unverified special can trigger a finding of non-compliance, regardless of how accurate your core menu may be.
Operationalizing LTOs for compliance
Temporary items often move quickly from concept to menu board, leaving little time for verification. The following workflow aligns with SB-68 expectations and CDPH inspection standards, helping operators prove due diligence for each limited-time offer.
| Step | Action | Outcome |
|---|---|---|
| 1. Capture and review the recipe | List every ingredient, topping, and garnish before launch. Example: if a summer shake includes new sprinkles or whipped topping, confirm allergen declarations directly from the supplier. | Ensures the allergen list reflects accurate, verified supplier data. |
| 2. Enter data centrally | Add the recipe to your digital menu management system so allergens populate automatically across menu formats. | Maintains consistency between printed, online, and in-store menus. |
| 3. Require QA or allergen champion sign-off | Each LTO must be approved by your designated Allergen Champion or QA lead prior to release. | Demonstrates an internal control process aligned with SB-68’s “reasonable knowledge” standard. |
| 4. Verify menu presentation | Check that allergen icons, text, and disclosures display correctly in every menu version. | Prevents data mismatches between channels during inspection. |
Preventing compliance gaps with digital controls
Even small operational changes — like a supplier swap or regional ingredient variation — can undermine compliance if not tracked digitally. Integrating allergen data into your core recipe system helps eliminate these blind spots.
| Scenario | Risk | Digital Control |
|---|---|---|
| Supplier substitution during an LTO | A gluten-free bun is replaced by a wheat-based version mid-promotion. | Systems that sync with supplier data automatically flag and update allergen information before an inspection can occur. |
| Regional product variation | One site sources a local brownie mix for a dessert promo. | Logging this in your allergen management system maintains consistency across statewide disclosures. |
| Premature menu publishing | An LTO is added to delivery apps before allergen data is finalized. | Releasing items only after sign-off ensures compliance with SB-68’s requirement for disclosure at the point of ordering. |
Recordkeeping for SB-68 inspections
Every temporary item should generate a digital paper trail showing who verified it, when it was approved, and which data sources were used. Inspectors from the California Department of Public Health (CDPH) and local health departments may request evidence of these controls during an inspection or complaint review.
| Record Type | Purpose | Example Evidence |
|---|---|---|
| Allergen review log | Documents who verified the recipe and allergen list before launch. | Automatically created within most digital menu management systems. |
| Menu version capture | Shows what allergen disclosures were live at any given time. | Export or screenshot of digital and printed menus with timestamps. |
| Supplier confirmations | Verifies that allergen data came directly from manufacturer or distributor declarations. | Stored PDFs, emails, or API-linked records from suppliers. |
| Change management log | Tracks edits made during the promotional period. | Version control entries generated when allergen or ingredient data is modified. |
Context: The ADDE Act (SB-68) adds Section 114093.5 to the California Health and Safety Code, requiring restaurant chains with 20+ U.S. locations to maintain accurate allergen disclosures by July 1, 2026. Each menu — including LTOs — must reflect verified allergen data at the time of ordering.
Keep your LTOs fully compliant under SB-68
Access expert checklists and templates to help you validate allergen data, document approvals, and demonstrate compliance during CDPH inspections.
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