Illinois Food Safety Managers Additional Training for 2026

Illinois Allergen Awareness Training Law: What the 2026 Update Actually Requires

Clarifying Public Act 104-0090 (SB1288)

Recent discussions surrounding Illinois Public Act 104-0090 have led to widespread confusion about new food service training requirements. Some reports have incorrectly suggested that all restaurant employees in Illinois will be required to complete gluten-free or allergen training beginning in 2026. This is not accurate.

While earlier drafts of the legislation proposed broader training obligations, the final version signed into law makes a targeted update to existing allergen awareness requirements. The law does not establish a new statewide training mandate for all food service workers.

What the Law Does Not Require

Public Act 104-0090 does not require:

• All food service employees to complete gluten-free or allergen training
• Restaurants to obtain a gluten-free certification
• New training for line cooks, servers, or general food handlers
• Menu changes or gluten-free food service operations

These misconceptions stem from earlier versions of the bill, not the enacted law.

What Changed During the Legislative Process

As the bill progressed through the Illinois General Assembly, its scope was narrowed. The final enrolled version amends Section 3.07 of the Food Handling Regulation Enforcement Act, which governs allergen awareness training for certified food service sanitation managers. This amendment is what became Public Act 104-0090.

What the Law Actually Requires (Effective January 1, 2026)

1. Applicability is limited to certified food service sanitation managers

Illinois food establishments are already required to employ at least one certified food service sanitation manager. The updated training requirement applies only to this role.

2. Training timelines remain unchanged

Certified managers must complete ASTM accredited allergen awareness training:

• Within 30 days of employment

Every three years thereafter

These requirements were already in place prior to the amendment.

3. Gluten-related content is added to existing allergen training

The law expands required training topics to include:

• What gluten is and where it is commonly found
• Symptoms of gluten intolerance and celiac disease
• Best practices for gluten-free food preparation and handling
• Proper cleaning methods to prevent gluten cross-contact

This content is added to the existing allergen awareness framework rather than creating a separate training program.

4. General food handlers are not regulated by this update

Section 3.07 applies exclusively to certified food service sanitation managers. The law does not impose new training requirements on other restaurant staff.

5. Approved training programs remain unchanged

Training must continue to be accredited by ANSI or another recognized accreditation body operating under ASTM E2659-09. Most existing allergen awareness courses are expected to incorporate the new gluten-related material by 2026 without requiring restaurants to change providers.

Key Takeaways

• Public Act 104-0090 updates allergen awareness training for certified food service sanitation managers
• Gluten and celiac disease topics are added to existing training requirements
• No new statewide training mandate applies to all restaurant employees
• The amendment strengthens food safety awareness while preserving the current training structure