Topic: Voluntary use of Precautionary Allergen Labeling (PAL) under SB-68 — managing both supply-chain and operational cross-contact risks.
Why it matters: PAL is not required under SB-68, but applying it appropriately shows due diligence, enhances guest trust, and strengthens inspection defensibility.
Key action: Differentiate between supply-chain and operational PAL, document risk decisions, and ensure consistent communication across menus and systems.
Precautionary Allergen Labeling (PAL) — such as “may contain” or “produced in a facility that also processes” — is voluntary under California’s SB-68 (ADDE Act). The law requires accurate allergen disclosure for known ingredients but does not mandate precautionary statements. When applied responsibly, PAL demonstrates due diligence and transparent risk management.
There are two main PAL types to consider in foodservice:
| Type | Definition | Typical Source | Example Statement |
|---|---|---|---|
| Supply-Chain PAL | Issued by manufacturers or distributors to indicate possible cross-contact during production or packaging. | Supplier allergen declarations, spec sheets, or packaging. | “Manufactured in a facility that also processes peanuts.” |
| Operational PAL | Applied by operators to reflect potential cross-contact during storage, preparation, or service. | Shared fryers, cutting boards, utensils, or prep surfaces. | “Prepared in a kitchen that handles milk, eggs, soy, and wheat.” |
When to use PAL responsibly
Use PAL only when the potential for cross-contact cannot be fully controlled. Overuse undermines guest confidence, while selective, evidence-based use signals strong allergen management.
- Use PAL selectively: Only apply precautionary statements where verified cross-contact risks exist.
- Document justification: Record why PAL was applied — whether due to supplier declaration or operational limits.
- Review regularly: Remove PAL statements once risks are mitigated or suppliers confirm segregation.
- Maintain consistency: Ensure identical PAL language appears across printed, digital, and delivery menus.
Inspection readiness and documentation
Although not required under SB-68, inspectors may view PAL as a sign of proactive risk control. Maintain documentation for each PAL decision to demonstrate due diligence during audits or inquiries.
- For supply-chain PAL: Keep supplier statements or allergen spec sheets attached to ingredient records.
- For operational PAL: Maintain prep-area risk assessments and cleaning procedure logs.
- For both: Include PAL policies in staff training and standard operating procedures.
Context: The California ADDE Act (SB-68) requires allergen disclosure for restaurant chains with 20 or more U.S. locations by July 1, 2026. PAL remains voluntary, but documenting it demonstrates transparency and continuous improvement in allergen control.
Strengthen your allergen disclosure and risk management
Access expert guidance and tools to document PAL decisions, verify supplier data, and ensure your allergen program meets SB-68 expectations.
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