Primary source: California Legislative Information — Senate Bill 68 (Allergen Disclosure for Dining Experiences Act). Secondary source: FDA — Food Allergies (Big 9 major allergens).

A guest at the table tells a manager about a sesame allergy. The manager points at the QR sticker on the table. The sticker loads a six-month-old PDF of last quarter’s promotional menu. From the guest’s seat, that’s not a disclosure. It’s a stale page. On July 1, 2026, it’s also a violation of California Senate Bill 68.

Governor Gavin Newsom signed SB 68, the Allergen Disclosure for Dining Experiences Act (ADDE), on October 13, 2025. California is one of the first states to require chain restaurant allergen disclosures directly on the menu.

The law

What California SB 68 allergen law actually covers

SB 68 applies to California food facilities that are part of a chain covered by the federal menu-labeling rules: 20 or more locations under the same name and offering substantially the same menu items, including franchised systems. The disclosure rule covers the FDA’s Big 9 allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. (Sesame became the ninth under the federal FASTER Act effective January 1, 2023.) Every standard menu item that contains one of those nine must carry a disclosure.

What changed. The disclosure has to follow every menu or menu board customers use to make an order selection: printed menus, menu boards, the brand app, the website, in-store kiosks, the page a QR code opens, and delivery menus when those platforms function as the ordering menu. If a location uses a digital allergen disclosure, it also needs a written alternative on hand for customers who cannot access the digital version: an allergen-specific menu, chart, grid, booklet, or other written material. Separately, digital allergen information should be built in an accessible format; a flat-image PDF creates avoidable accessibility and proof problems.

What didn’t change. SB 68 does not require cross-contact warnings about ingredients used elsewhere in the kitchen. The standard is what the restaurant “knows or reasonably should know” about a dish. A violation isn’t automatic just because a guest got sick — the question is whether the restaurant should have known the allergen was in the dish. The California Department of Public Health holds state enforcement authority; the county or city health department is the one running the actual inspection.

Our position

The six places chains forget to update

If your SB 68 plan is “rewrite the menu,” you are still missing the places where guests actually see it: the kiosk, the app, the delivery menu, the QR-code page, the menu board, and the allergen chart sitting in the manager binder. The printed menu is the easy one. The other six are where chains get caught.

In a multi-location QR audit, the failure pattern is almost always the same: the sticker still works, but the page it loads is an older menu the brand has already replaced. Headquarters thinks the rollout is done. The guest at the table sees a menu that doesn’t match what’s in front of them. SB 68 gets argued from the guest’s seat, not the home office.

Here’s why this happens. A 20-location brand has the menu in at least seven different places, and four different teams own it. Marketing owns the print run. Digital owns the app and website. IT owns the kiosks and whatever page a QR code opens. Operations owns the printed allergen chart and the manager binder at every store. Each team finishes its piece on its own calendar. Nobody owns the moment all four updates land in every store on the same day. That is the gap SB 68 will find.

The test

When a manager hears “I have an allergy”

That standard gets tested at the table, not in the boardroom. Once a guest tells a manager they have an allergy, the restaurant is on notice. The next ninety seconds are about getting the answer right. The manager pulls the binder, finds the dish, and reads exactly what’s in it. Memory is not a reference. “I think you’ll be fine” is not an answer. “Safe for allergies” is a phrase nobody should say out loud.

If your locations use a digital allergen disclosure (kiosk, QR, app), each California store needs a written alternative on hand for customers who cannot access the digital version. That can be an allergen-specific menu, chart, grid, booklet, or other written material — but it has to be at the store, not at HQ, not in the franchise portal, and not “we’ll print it if someone asks.” That’s a manager binder problem, not a marketing problem.

The GM owns the binder. The area manager or franchisee owns the printed chart refresh. Whoever runs your QR vendor account owns the URL test. Then pick one person at HQ — usually a director of operations — to run those same checks across every store on a recurring schedule. Date everything. The proof you ran the check is the proof that matters when the inspector or the lawyer shows up.

The checklist

What to track before July 1, 2026

A working SB 68 store proof checklist has one row per location and the columns below. The point isn’t paperwork — it’s being able to prove the right version was live in the store when the guest ordered.

The landscape

How four other states are following California

California sets the July 1, 2026 baseline. Four other states are moving on similar rules. Track all five on the same compliance calendar, but keep enacted laws separate from bills still in committee.

Treating these state bills as “California-but-different” is the same mistake as treating SB 68 as a menu law. Maryland’s HB 181 stalled in 2026, but penalty proposals like its $5,000-per-day exposure are why you keep the watch list on the same calendar as enacted obligations, not as an afterthought.

SB 68 is where the QR code, kiosk, app, delivery menu, printed chart, and manager binder all have to tell the same story. If one is stale, the store has a problem.

VertiSource HR helps employers turn compliance requirements into repeatable store-level workflows: assigned owners, recurring checks, manager acknowledgements, proof files, and multi-state calendars. If your restaurant group operates in California, we can help build the SB 68 store proof checklist before the July 1, 2026 deadline. Start with our HR Cloud HRIS platform, HR support services, or full-service HR — or contact VertiSource HR directly.