California SB 68 (ADDE Act)
California’s Allergen Disclosure in Dining Establishments (ADDE) Act is the most significant allergen disclosure law in the United States and a key driver for digital menu compliance.Effective Date: July 1, 2026Signed: October 13, 2025 by Governor Gavin Newsom
Requirements
SB 68 requires restaurants with 20 or more California locations to:- Disclose the FDA Big 9 allergens for all standard menu items
- Provide allergen information at the point of ordering (menus, kiosks, apps)
- Offer alternative formats upon request (written, verbal)
FDA Big 9 Allergens
The law requires disclosure of the nine major food allergens identified by the FDA:| Allergen | API Value | Notes |
|---|---|---|
| Milk/Dairy | DAIRY | Includes all dairy products |
| Eggs | EGG | Any form of eggs |
| Fish | FISH | All fin fish species |
| Shellfish | SHELLFISH | Crustaceans and mollusks |
| Tree Nuts | TREE_NUT | Almonds, cashews, walnuts, etc. |
| Peanuts | PEANUT | Ground nuts |
| Wheat | WHEAT | Includes spelt and kamut |
| Soybeans | SOY | All soy-derived ingredients |
| Sesame | SESAME | Seeds and oil |
Digital Compliance Options
SB 68 allows digital disclosure methods, which is where SmartMenu API excels: Digital displays must:- Show allergens for each menu item
- Allow filtering by allergen (exactly what SmartMenu provides)
- Be accessible at the point of ordering
Official Resources
SB 68 Bill Text
Official California Legislative Information
Health & Safety Code 114094
Codified law section
Why This Matters for Digital Menus
SB 68 creates a clear mandate: allergen information must be integrated into all menu touchpoints. This includes:- Mobile ordering apps - Must display allergens before checkout
- Self-service kiosks - Must allow allergen filtering
- Website menus - Must show allergen information
- Third-party delivery - Partners must display allergen data
The SmartMenu Advantage
SmartMenu API is designed for exactly this compliance scenario:- Complete allergen declarations
- Source attribution (which ingredient contains the allergen)
- Confidence scores for AI-inferred allergens
Other Allergen Regulations
While California SB 68 is the most comprehensive, other jurisdictions have or are considering allergen disclosure requirements.United States
Federal
| Regulation | Scope | Requirements |
|---|---|---|
| FDA FALCPA | Packaged foods | Big 8 (now Big 9) labeling |
| FASTER Act (2021) | Packaged foods | Added sesame as 9th allergen |
Federal FALCPA applies to packaged foods only. Restaurant menu labeling is regulated at state/local level.
State Laws
| State | Status | Key Points |
|---|---|---|
| California | Enacted (SB 68) | 20+ locations, Big 9, effective July 2026 |
| Massachusetts | Active legislation | Similar to CA SB 68 |
| New York | Under consideration | NYC has existing requirements |
| Illinois | Under consideration | Chicago focus |
Local Ordinances
| City/County | Requirements |
|---|---|
| New York City | Sodium warnings for items >2300mg |
| San Francisco | Sugar-sweetened beverage warnings |
| Massachusetts | Allergen awareness training required |
International
Many countries have stricter allergen disclosure requirements than the US:| Region | Regulation | Allergens |
|---|---|---|
| European Union | EU FIC 1169/2011 | 14 major allergens |
| United Kingdom | Natasha’s Law | 14 allergens, prepacked foods |
| Canada | SFCR | 10+ priority allergens |
| Australia/NZ | FSANZ Standard 1.2.3 | Mandatory declaration |
EU 14 Allergens
If you’re building for international markets, the EU requires disclosure of:- Celery
- Cereals containing gluten
- Crustaceans
- Eggs
- Fish
- Lupin
- Milk
- Molluscs
- Mustard
- Nuts
- Peanuts
- Sesame seeds
- Soybeans
- Sulphur dioxide/sulphites
EveryBite is expanding allergen coverage to support EU requirements. Contact us for international compliance needs.
Compliance Timeline
For California SB 68 compliance:Recommended Steps
Audit Current State
Review existing menu data for allergen completeness. SmartMenu API provides confidence scores to identify gaps.
Integrate SmartMenu API
Connect your ordering systems to SmartMenu for allergen data. See our Quickstart Guide.
Update UI/UX
Ensure allergen information displays at point of ordering. See Displaying Results.
Penalties for Non-Compliance
SB 68 enforcement includes:- Civil penalties for violations
- Health department inspections may include allergen disclosure review
- Private litigation risk from customers with adverse reactions

