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2026 LAW UPDATE:
Illinois Public Act 104-0090 took effect January 1, 2026, expanding required allergen training topics for Certified Food Protection Managers to include gluten and celiac disease awareness. Our course is fully updated to meet the new requirements.

The 2026 Update at a Glance

1. Gluten and celiac disease are now required training topics

The updated law adds a fourteenth required training topic for Certified Food Protection Managers. Section 3.07(c)(14) now requires training to cover:

• What gluten is and where it is 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

2. Sesame is officially codified as a major food allergen

Public Act 104-0090 updates the statutory definition of “major food allergen” in Illinois to include sesame, bringing Illinois into alignment with the federal FASTER Act of 2021. The full list of major food allergens now recognized under Illinois law: milk, eggs, fish, crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame.

3. The 30-day & 3-year training cycle is reaffirmed

The existing requirement remains in place: every Certified Food Protection Manager employed by a covered restaurant must complete ANSI-accredited allergen awareness training within 30 days of hire and renew it every three years thereafter. Proof of training must be available to State or local health department inspectors on request and may be provided electronically.

✓ Required by Illinois Law

Certified Food Protection Managers (CFPMs) employed by Risk Category I restaurants — defined as businesses with at least 51% of sales from ready-to-eat food for immediate consumption. Every covered restaurant must have at least one CFPM with current allergen awareness training on duty whenever the establishment is open.

✗ Not Required by State Law (but strongly recommended)

Food handlers without CFPM certification are not required by Public Act 104-0090 to take allergen training. The law also does not apply to:

• Grocery stores, convenience stores
• Daycare centers and schools
• Assisted living or long-term care facilities
• Risk Category II or III food establishments
• Most multi-state chains and franchises with their own approved internal program

Even when not legally required, allergen training is widely considered best practice for any staff member who handles food or interacts with guests — it reduces liability and protects guests with life-threatening allergies.

1. The definition of a food allergy
2. The symptoms of an allergic reaction
3. The major food allergens (now including sesame)
4. The dangers of allergens and how to prevent cross-contact
5. Proper cleaning methods to prevent allergen contamination
6. How and when to communicate to guests and staff about allergens
7. Special considerations for workstations and self-serve areas
8. Handling special dietary requests
9. Dealing with emergencies, including allergic reactions
10. The importance of food labels
11. Handling food deliveries in relation to allergens
12. Proper food preparation for guests with food allergies
13. Cleaning and personal hygiene to prevent allergen contamination
14. NEW for 2026: Understanding gluten — sources of gluten, symptoms of gluten intolerance and celiac disease, gluten-free food preparation, and cleaning methods to prevent gluten contamination

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Fully updated for Public Act 104-0090 · ANSI-accredited · 3-year certificate

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Does Public Act 104-0090 apply to every employee at my restaurant?

No. The state-mandated allergen awareness training requirement applies only to Certified Food Protection Managers (CFPMs) at Risk Category I restaurants. Food handlers without CFPM certification are not required by Illinois state law to take this specific allergen training — though many restaurants choose to train all staff as best practice.

I took allergen training before January 1, 2026. Do I have to retake it?

Your current certificate remains valid for its full 3-year term. When it expires, your renewal course must include the new gluten and celiac disease content required under Section 3.07(c)(14). Our course already includes this content, so you can renew today and be fully compliant.

What counts as a Risk Category I restaurant?

The Illinois Department of Public Health defines a Risk Category I restaurant as a business primarily engaged in selling ready-to-eat food for immediate consumption — meaning at least 51% of total sales (excluding liquor) come from ready-to-eat food. Most full-service restaurants, fast-casual concepts, food trucks, and similar establishments fall into this category.

Is online allergen training acceptable in Illinois?

Yes. Section 3.07(h) explicitly permits training to be conducted “by any means available, including online, computer, classroom, live trainers, remote trainers, and food service sanitation managers who have successfully completed an approved allergen training.” A proctor is not required. Our course is delivered 100% online, on-demand.

How do I prove compliance to a health inspector?

Keep a copy of each CFPM’s certificate of completion at the restaurant. Per Section 3.07(h), proof may be presented electronically and must be made available on reasonable request from a State or local health department inspector.

Can my local health department add its own allergen training rules?

No. Section 3.07(i) of the Act states that the regulation of allergen awareness training is an exclusive function of the State of Illinois — local jurisdictions are preempted from imposing additional allergen training requirements beyond what the State requires.

• Illinois General Assembly — Public Act 104-0090 (full text)
• Illinois Department of Public Health — Food Allergen Awareness Training FAQ
• Celiac Disease Foundation — Illinois Allergen Awareness Training Law: 2026 Update
• 410 ILCS 625 — Food Handling Regulation Enforcement Act

This information is provided for educational purposes and reflects publicly available statutory language as of the effective date of Public Act 104-0090. It is not legal advice. Restaurants with specific compliance questions should consult their local health department or a qualified attorney.

• Servers & front-of-house staff
• Hosts, bartenders, & baristas
• Chefs, line cooks, & prep staff
• Fast-casual & quick-service staff

• Catering & banquet staff
• Food truck & concession workers
• School & childcare foodservice staff
• Managers & supervisors overseeing food safety

• What food allergies and intolerances are
• The top major food allergens and where they are found
• Recognizing signs and symptoms of an allergic reaction
• Responding to emergencies and when to call for help

• Preventing cross-contact in the kitchen and service areas
• Reading food labels and identifying hidden ingredients
• Communicating safely with guests and coworkers
• Building allergen-safe practices into daily operations

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How long does the Allergen Awareness course take?

Most learners complete the course in about 1 hour, depending on reading speed and experience with food allergies.

Is this training online and self-paced?

Yes. The course is 100% online and self-paced, so staff can complete training at times that work best for your operation.

Does the course include a certificate?

Yes. After passing the assessment, learners can download or print a certificate of completion to show their employer or health inspector.

Is Allergen Awareness training required?

Requirements vary by state and local jurisdiction. Some areas require formal allergen training, while others recommend it as a best practice. Always check with your local health department for specific rules.

Can I take the course on my phone or tablet?

Yes. The course is mobile-friendly and works on smartphones, tablets, laptops, and desktop computers with internet access.