Written Allergen Menus Move Closer in 2026: UK Review and California's New Law

In 2026, the question of whether restaurants must put allergen information in writing is moving from guidance toward law on both sides of the Atlantic. In the UK, the Food Standards Agency (FSA) is reviewing this spring whether food businesses adopted the written-allergen best practice it published in March 2025 — an assessment that will inform ministers on whether to make written allergen menus a legal requirement. In the United States, California has already decided: its Allergen Disclosure for Dining Experiences Act (SB 68) takes effect on 1 July 2026. Notably, both frameworks accept a digital menu as a valid way to provide that information.

TL;DR

• The UK FSA’s best practice guidance (updated 5 March 2025) says allergen information for non-prepacked food should be available in writing, backed by a conversation with staff.
• The FSA is evaluating compliance with that guidance, with findings expected in spring 2026, to decide whether a written-menu law (informally “Owen’s Law”) is needed.
• In the US, California SB 68 requires covered restaurants to disclose major allergens in writing from 1 July 2026 — explicitly allowing a digital format such as a QR code.
• Both regimes name digital menus as compliant, which is where a per-dish allergen-tagged menu becomes directly useful.

What’s happening, and when

The UK’s Food Standards Agency published best practice guidance for non-prepacked food — meals cooked and served on site, the kind a restaurant or café sells across the counter — most recently updated on 5 March 2025. Its core message is that allergen information should be made “easily available in writing” for the 14 major allergens, supported by a conversation between staff and the customer. Importantly for operators, the FSA states this information can be provided in person and digitally or online, not only on a printed card.

That guidance is currently voluntary. What makes spring 2026 a turning point is that the FSA is now assessing how well businesses have adopted it. The outcome of that evaluation is what the agency will use to advise ministers on whether written allergen information should become a legal requirement rather than best practice — the change campaigners refer to as “Owen’s Law.”

Across the Atlantic, the direction is no longer hypothetical. California Governor Gavin Newsom signed SB 68, the Allergen Disclosure for Dining Experiences Act, into law on 13 October 2025, and its menu-disclosure requirements commence on 1 July 2026.

What changed in the rules

For the UK, nothing in the baseline law has changed yet: restaurants must already provide accurate allergen information, and Natasha’s Law (in force since 2021) covers pre-packed for direct sale (PPDS) items like a pre-made sandwich. What is shifting is the FSA’s stated expectation that the information be written, and the prospect that this expectation becomes mandatory after the spring 2026 review.

California’s SB 68 is more concrete. According to the bill text on California Legislative Information, from 1 July 2026 a food facility that is already subject to federal menu-nutrient disclosure rules — broadly, restaurant chains with 20 or more locations offering substantially the same menu items — must provide written notification of the major food allergens it knows, or reasonably should know, are present in each menu item. The disclosure can appear directly on the menu or in a digital format, provided a non-digital alternative is available for guests without a smartphone. The law also formally adds sesame to California’s list of major allergens, aligning the state with the federal FASTER Act, which made sesame the ninth major US allergen.

Why it matters to restaurateurs

The practical takeaway is the same in both jurisdictions: “we’ll tell you verbally” is being downgraded; “it’s written down and accurate” is being upgraded. For an independent UK restaurant, a mandatory written-menu rule would mean every dish needs documented allergen data that staff and guests can rely on. For a US chain of 20+ sites, the written disclosure is already a dated, near-term obligation.

This is where the format you choose starts to matter — and where a digital menu earns its place, because both regulators explicitly recognise it. A printed allergen sheet has to be reprinted and reconciled every time a recipe or supplier changes; across a multi-site operation, keeping dozens of sheets correct at once is exactly where errors creep in. A digital menu lets you tag allergens once per dish, shown consistently for every guest, with edits propagating instantly.

This is a compliance and safety point first: written allergen information should always sit alongside a conversation with at-risk guests, never replace it — the FSA is explicit on that. Software doesn’t remove a kitchen’s responsibility; it makes the written half of that duty easier to keep accurate.

Context and background

UK allergen rules have tightened since the death of Natasha Ednan-Laperouse, whose name attached to the 2021 PPDS labelling law. The current debate is about closing the remaining gap: food cooked to order, where allergen information has historically been given verbally and inconsistently. The FSA Board signalled its direction on 13 December 2023, when it agreed it wanted written allergen information mandated in the non-prepacked sector and committed to writing to ministers; the March 2025 guidance and the spring 2026 evaluation follow from that.

California’s SB 68 reflects the same trajectory in a different legal system, with digital menus treated as a first-class way to comply. Together they suggest written, machine-readable allergen information is becoming the baseline expectation for menus, not a premium feature.

What restaurateurs should do now

1. Audit your allergen data per dish. Make sure you have accurate, written allergen information for all 14 (UK) / 9 (US) major allergens for every item you serve — this is the foundation either rule rests on.
2. Move it to a format you can keep current. Choose a way to publish allergen information that you can update the moment a recipe or supplier changes, so a single change doesn’t mean reprinting every menu.
3. If you use a digital menu, make sure it offers a non-digital fallback. California’s law requires one; it’s good practice everywhere for guests without a phone.
4. Keep the conversation. Train staff to ask about allergies and confirm verbally with at-risk guests — written information supports your team, it doesn’t replace them.
5. Watch the spring 2026 FSA outcome if you operate in the UK, since it will signal whether written allergen menus are about to become law.

A digital menu makes the written, always-current side of this straightforward: you tag each dish’s allergens once, and guests see them on every device — in the language they speak, updated the instant a recipe changes. If you want to get ahead of the 2026 direction of travel, you can build a free allergen-tagged digital menu with ShevaFood and have it live before your next service.

For the wider picture on how digital menus work end to end — setup, costs and the difference between a real menu and a PDF behind a code — see our pillar guide, The Complete Guide to QR Code Menus for Restaurants.