Who must comply, who’s exempt, and why small operators should still pay attention.

A Big Law with a Targeted Reach

California’s new Allergen Disclosure for Dining Experiences (ADDE) Menu Act, signed into law in October 2025, is the first of its kind in the U.S. to require written allergen information on menus.

But while the headlines make it sound like every restaurant and food truck will have to overhaul their menus, the truth is more nuanced. The ADDE Menu Act’s requirements depend heavily on the size and scope of your business.

Here’s a breakdown of who’s affected — and why even exempt businesses should start paying attention now.

⚖️ Who Must Comply

The law applies to restaurants and food service businesses with 20 or more locations nationwide that operate under the same name and branding.

That means:

• Chain restaurants such as McDonald’s, Panera, or Shake Shack

• Franchise groups that share a brand and standardized menu

• Multi-unit restaurant companies with centralized management

• Food truck brands that have 20 or more trucks operating under the same name

If your operation falls into this category, you’ll need to:

1. Disclose in writing which of the “Top 9” allergens are present in each menu item (milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soy, sesame).

2. Display this information on printed menus or through digital access (like a QR code).

3. Provide a printed option for customers who can’t use digital devices.

4. Keep information current whenever recipes or suppliers change.

5. Train staff to understand and communicate allergen information clearly.

The compliance deadline is July 1, 2026, and enforcement will come through the California Department of Public Health and local health agencies.

🚫 Who Is Exempt (for Now)

The ADDE Menu Act does not apply to small, independent, or local food service businesses.

That includes:

• Independent restaurants with fewer than 20 locations

• Local chains that don’t meet the national threshold

• Single-location food trucks or small local fleets

So, a mom-and-pop diner, a single taco truck, or a small three-location café chain does not have to comply with the new labeling requirements.

This exemption was a deliberate choice. Lawmakers limited the scope to large chains after small business advocates and the California Restaurant Association argued that smaller operators would struggle with the administrative and technical burden of constant allergen documentation.

💡 Why Small Operators Should Still Care

Even though you may not have to comply, here’s why it’s smart to start preparing anyway:

1. Consumer Expectations Are Changing

Customers increasingly expect transparency about ingredients and allergens. Many families with food allergies already prefer chains precisely because they can access clear allergen data.

By offering your own allergen list — even voluntarily — you can stand out as a trusted local option for these customers.

2. It’s Likely a Preview of What’s Coming

California often leads the nation in restaurant regulation. Once the ADDE Menu Act is fully implemented, other states — or even local cities — could expand similar requirements to smaller operations. Getting ahead of that curve now can save headaches later.

3. Operational Benefits

Tracking allergens means documenting ingredients, standardizing recipes, and training staff — all of which improve food safety, consistency, and customer confidence.

For food trucks especially, where menu changes are frequent, a clear ingredient tracking process can make daily operations smoother and reduce costly errors.

📋 Practical Steps for All Operators

Whether you’re a major chain or a one-truck start-up, here are steps you can take to prepare or voluntarily align with best practices:

1. Create a simple allergen chart listing menu items and which of the Top 9 allergens they contain.

2. Audit suppliers to ensure you have up-to-date ingredient information.

3. Train your team to respond accurately to allergen inquiries — “I’ll check” is better than guessing.

4. Consider digital menus or QR codes for easy updates and transparency.

5. Market your transparency — diners appreciate restaurants that care about their safety.

🕒 Timeline and Next Steps

• Now–Spring 2026: Large operators begin auditing ingredients and updating menu systems.

• By July 1, 2026: All covered chains (20+ locations) must have allergen disclosures in place.

• Beyond 2026: Other states — or California cities — may explore similar rules for smaller businesses.

Small operators won’t be required to make changes immediately, but being proactive now can save costs later and build stronger customer relationships today.

The Bottom Line

The ADDE Menu Act is aimed squarely at large, multi-location chains — not independent restaurants or single food trucks. But its ripple effects will touch everyone in the food industry.

Customers are already learning to look for allergen transparency, and sooner or later, those expectations will extend to every menu.

So even if you’re not required to comply yet, now’s the time to think about how your business can communicate safety and trust — whether that’s through a printed allergen guide, a digital menu, or simply better staff training.

Transparency is no longer just a regulatory issue — it’s good business.