Practical 9-month SB-68 compliance checklist for U.S. restaurant chains, franchises, and ghost kitchens

To prepare for July 1, 2026, restaurant operators should follow this month-by-month plan to ensure allergen data, menus, and staff are fully ready for inspection and compliance verification.

Month 9 to 8: Assessment & Data Foundation (October/November)

• Appoint an Allergen Champion responsible for cross-functional coordination across culinary, operations, and vendor teams.
• Conduct a full gap analysis of all menu items, sub-recipes, and ingredients at every location.
• Identify missing allergen information from vendors and broadliners; flag any unknowns for follow-up.
• Review existing menu management processes and identify discrepancies between digital, printed, and POS menus.
• Select a menu management software platform capable of storing, syncing, and auditing allergen data across multiple locations.
• Define a clear data structure linking menu items, sub-recipes, and ingredients to allergen information.
• Document current workflows for allergen updates, including who is responsible for vendor communications and data entry.
• Begin drafting a standard template for allergen reporting to maintain consistency across locations.

Month 7: Vendor & Recipe Standardization (December)

• Collect written allergen declarations from all vendors and broadliners for ingredients, sauces, and sub-recipes.
• Populate a master allergen database for all menu items and sub-recipes, linking ingredient-level data.
• Standardize recipe naming and allergen terminology across all locations and digital platforms.
• Verify that all menu variations (seasonal, regional) are captured in the database.
• Update workflow procedures to reflect vendor communications and allergen data entry.

Months 6 to 4: Systems & Menu Infrastructure (January – March)

• Configure menu management software for multi-location syncing.
• Create draft menu templates for digital displays, POS, and printed menus.
• Implement version control to track menu updates and allergen data changes.
• Set automated alerts for new ingredients or recipe changes that may affect allergen status.

Month 3: Final Audit & Menu Setup (April)

• Conduct a full data and allergen audit across all menu items and locations.
• Finalize menu layouts for digital and printed formats.
• Create or update in-store signage and written allergen references for staff and customers.

Month 2: Staff Training & Process Review (May)

• Deliver role-specific training for front-of-house and back-of-house teams.
• Distribute and review allergen standard operating procedures (SOPs).
• Ensure escalation procedures are clearly documented for any allergen-related queries or incidents.

Month 1: Final Verification (June)

• Conduct a full dress rehearsal across all locations.
• Verify alignment of digital, printed, and written menu materials.
• Check that SOPs are followed consistently by staff.

Launch: Go Live! July, 2026

• Ensure all locations maintain inspection readiness.
• Implement ongoing monitoring and update procedures for allergen data.
• Schedule periodic audits to maintain compliance and minimize risk.

Context: California Senate Bill 68 (ADDE Act) mandates written allergen disclosure for restaurant chains with 20 or more locations by July 1, 2026. It amends Section 113820.5 and adds Section 114093.5 to the California Health and Safety Code (HSC).