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

Clarifying Public Act 104-0090 (SB1288)

Last week the Celiac Disease Foundation held a seminar in partnership with the Illinois Department of Public Health (IDPH) to provide education on celiac disease, the gluten-free diet, and the updated Public Act 104-0090 that deals with training of food handlers. Since the bill’s passage, widespread misinformation has circulated across news outlets, advocacy groups, and social media, leaving many to believe that all food service workers in Illinois will soon be required to complete gluten-free training. This is not the case.

While the original version of the bill had proposed sweeping changes in training that applied to all food service handlers, the final version of the bill that passed the state legislature earlier this year was modified in a way that only applied this requirement to certain food handlers. While the final law – taking effect on January 1, 2026 — is a revision of existing allergen awareness training requirements, it does not create an entirely new law. Instead, it adds gluten-related topics to existing training that certified managers are currently required to complete, but it does not create a new statewide gluten-free training requirement for all staff. 

What the Law Does Not Require 
The law does not mandate: 

• • All food service employees take gluten-free or allergen training. 
  • A “gluten-free certification program” be established for restaurants. 
  • New training requirements for line cooks, servers, or general food handlers. 
  • Restaurants to operate as gluten-free facilities or alter their menus. 

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

What Changed During the Legislative Process 
As is often the process as legislation is being crafted and debated, the bill evolved as it moved through the General Assembly. The final enrolled version amends only Section 3.07 of the Food Handling Regulation Enforcement Act, which covers allergen awareness training for certified food service sanitation managers. This is the version that ultimately became Public Act 104-0090. 

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

1. The requirement applies only to certified food service sanitation managers.
   Illinois restaurants must employ at least one certified food service manager, and the training requirement applies only to this role—not the entire staff.
2. Managers must complete American National Standards Institute-accredited (ANSI) allergen awareness training:

• • Within 30 days of employment, and 
  • Every 3 years thereafter 

This timeline is consistent with previous law. 

3. The updated law adds gluten-related content to the existing list of required training topics.
   Training must now include (per subsection (c)(14)):

• • 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 

This is an addition to the broader list of allergen awareness topics currently required. 

4. The law does not regulate food handlers or general staff. Section 3.07 applies exclusively to certified food service sanitation managers.
5. Approved training programs remain the same. Training must be accredited by ANSI or another recognized accreditation body under ASTM E2659-09. Most allergen courses will incorporate the new gluten-related content by 2026 without requiring restaurants to change programs.

To address these misunderstandings and ensure Illinois residents receive accurate information, the Celiac Disease Foundation is actively partnering with IDPH to support clear, evidence-based communication about the updated law. As part of our broader advocacy mission, we are working with state officials, health partners, and community stakeholders to correct misinformation and reinforce what the law does, and does not, require. Additionally, the Foundation will launch a targeted social media education campaign to help the public, restaurants, and the celiac disease community better understand the law’s intent and its practical implications. This coordinated effort reflects our commitment to advancing policies that protect people with celiac disease while empowering them with tools, resources, and accurate guidance to stay safe.

As state initiatives to raise awareness and address food safety in public settings continue to gain momentum, in 2026, the Celiac Disease Foundation will expand this work by partnering with state departments of public health across the country to raise awareness of celiac disease and its impact on local communities. These efforts will help public health officials better understand the prevalence of the disease in their regions, the unique challenges residents face in accessing safe gluten-free food, and the broader public health implications of delayed diagnosis or inadequate dietary support. By strengthening relationships with state agencies and providing region-specific education, the Foundation aims to ensure that celiac disease is recognized as a significant public health concern and that communities receive the guidance and support they need.

Key Takeaways 

• • The law updates allergen training certified food service managers. 
  • It ensures that gluten and celiac disease are thoughtfully included in existing allergen education. 
  • It does not create new requirements for all restaurant employees. 
  • Importantly, it represents a key step at the state level to strengthen awareness and safety for people with celiac disease and gluten-related disorders while keeping the overall training structure the same.