The new Food Code is out. Here's what to do with it on Monday.
On September 17, 2026, the FDA released the 2026 edition of the Food Code, its first complete edition since 2022. If you run a restaurant or a food truck, you don't need to read all of it. You need to know three things: whether it applies to you yet, what changed that touches your paperwork, and which records are worth having ready when the health inspector asks.
First: it's a model code, not a federal rule
The Food Code is not law by itself. Your state, county or city decides whether and when to adopt it, and often modifies it on the way. FDA's latest adoption data (as of 2024) shows how uneven that is: only 11 state agencies in 7 states had adopted the 2022 edition, covering about 16% of the U.S. population, and 30 state agencies in 24 states had adopted either the 2022 or the 2017 edition. The 2026 edition will take time to reach your jurisdiction, so the first practical step is a quick call or a visit to your health department's website: which edition is in effect here, and when does it change?
That said, inspectors tend to follow the direction the model code sets, and records you start keeping now are useful no matter when your jurisdiction adopts.
What changed that touches your records
A written employee illness policy. Part 2-5 is now titled "Policies and Procedures for Employee Illness Management," and § 2-501.11 is now "Employee Illness Policy Documentation." In plain terms: how you handle employees who are sick, from reporting symptoms to exclusion and return to work, should exist in writing and be easy to produce. The model inspection form (Form 3-A) now has an item named "Illness Documentation."
Return-to-work testing. The rules for reinstating an employee after certain illnesses now allow validated tests from an accredited laboratory, not just stool cultures (§ 2-201.13).
Sanitizer and disinfectant details. Chemical sanitizers other than chlorine, iodine and quaternary ammonium have a new minimum temperature of 75°F (§ 4-501.114), and test kits must be used according to their label. A new Part 4-10 covers disinfection of equipment and utensils.
Mobile food establishments are now defined. The code adds a defined term for a food establishment that changes location as part of routine operation, and "food establishment" now explicitly includes commissaries. If you run a truck, read your jurisdiction's wording on both.
Gloves and cooling. There is a new, conditional exception that allows double gloving, and regulators may approve an alternative cooling method. Both come with conditions, so don't assume either applies to you without checking with your regulator.
Some management-system provisions are coming too: commentary from law firms covering the release notes that covered establishments will generally need a written food safety management system within four years after their jurisdiction adopts the code. That is not a 2026 deadline for anyone, but it is a reason to start getting your records in order.
The logs worth keeping ready
The Food Code doesn't hand you a list of forms. But the things inspectors check map onto a short list of records:
- Temperature logs for cold and hot holding (41°F or below and 135°F or above), with the time, the reading and who took it. If you haven't already, read our walkthrough of a cold-holding log that holds up.
- Cooling logs for any batch you cool.
- Sanitizer concentration and temperature checks, now with the updated temperature minimums in mind.
- Employee illness policy and acknowledgment, signed or acknowledged by each new hire.
- Opening and closing checks, and for trucks, a pre-operation check every service day.
The common failure is not missing forms; it's blank rows, entries made all at once at the end of the shift, and records nobody can find on inspection day.
Doing it without a binder
A checklist on a phone, reached with a QR code taped to the unit or the truck window, solves the "nobody wrote it down" problem: each entry carries a time, a name, and a reading, and a missed check shows up the same day instead of at the inspection. Respondents don't need an account to fill it in, and the log is searchable when someone asks for last Tuesday.
You can start from two free templates: the restaurant cold-holding temperature log, and, for trucks, the food truck pre-operation checklist. Both are editable, so you can match them to your menu, your equipment and your local rules.
What this does and doesn't do
Good records help you show what you did and when. They don't guarantee a clean inspection, and they don't replace the Food Code text, your local regulator's guidance, or a certified food protection manager's training. Check your local requirements before you change a procedure.
a7reports.com is not affiliated with the FDA or any health department.