Other States Following California: Allergen Menu Laws Coming Nationwide
California was first. Michigan, New Jersey, and Illinois are next. If your restaurant operates in any of these states — or plans to — the time to act is now.
California Set the Precedent
On October 13, 2025, Governor Newsom signed SB-68 — the Allergen Disclosure for Dining Experiences (ADDE) Act. It took effect July 1, 2026, making California the first state to mandate restaurant allergen disclosure on menus.
The law requires chains with 20+ locations to identify the 9 major FDA allergens in each menu item. Within months of signing, three other states introduced similar legislation.
States With Pending Legislation
Michigan — HB 5402
Michigan's bill proposes requiring restaurants to list the same 9 major FDA allergens on menus. The bill was introduced in the state legislature and mirrors California's approach of written allergen identification per menu item.
New Jersey — A4826
New Jersey's Assembly Bill 4826 requires food service businesses to provide written notice of major food allergens in each menu item. The bill is modeled on the federal allergen definitions and California's implementation approach.
Illinois — Allergen Training Update
Illinois updated its allergen awareness training law in 2026, requiring certified food service sanitation managers to receive training on allergen identification, cross-contamination prevention, and customer communication. While not yet a menu-disclosure mandate, it signals the direction Illinois is heading.
New York — S7566
New York's Senate Bill S7566 requires allergen awareness training for restaurant staff, with certification required within 30 days of hire. Like Illinois, this is a training mandate that precedes a likely disclosure mandate.
The Pattern Is Clear
Legislative trends in food safety follow a predictable pattern:
- One state leads — California passes the first law
- Others follow within 1-2 years — Michigan, NJ, IL introduce similar bills
- Industry adapts nationally — multi-state chains implement everywhere rather than managing state-by-state
- Federal action consolidates — a national standard eventually emerges
This is exactly how calorie disclosure on menus played out. California led, others followed, and eventually the FDA mandated it nationally for chains with 20+ locations. Allergen disclosure is on the same trajectory.
What Multi-State Chains Should Do Now
If you operate in multiple states, implementing allergen disclosure only in California creates inconsistency across your brand. Customers who see it in your LA location will expect it in your Chicago location.
The practical move: implement nationally now. The cost is the same per-menu whether you do one state or all of them. You avoid scrambling each time a new state passes a law, and you get the customer trust benefits everywhere immediately.
What Independent Restaurants Should Do
Even if you're a single-location restaurant in Michigan, New Jersey, or Illinois, getting ahead of pending legislation has advantages:
- No last-minute scramble when the law passes
- Stronger legal defense if a claim arises (lawsuits don't wait for legislation)
- Competitive advantage over restaurants that wait
- Customer trust — especially with allergy-conscious diners actively seeking safe options
MenuComply Works in Any State
MenuComply isn't California-specific. The 9 major FDA allergens are federal — they're the same in every state. Whether you're in California complying with SB-68 or in Michigan getting ahead of HB 5402, the process is identical: upload your menu, verify allergens, publish your disclosure.