Illinois (IL)

HACCP plans in Illinois

What the FDA's 2024 Food Code adoption report lists for Illinois, what we have and have not verified, and how to find out where a HACCP plan or variance goes.

Reviewed October 8, 2026 5 official sources cited
Food Code edition
2022 Food Code
Edition check
Not yet verified
Local rules checked
Chicago Department of Public Health, Food Protection Program

Which Food Code edition Illinois uses

The FDA report on Food Code adoption (calendar year 2024 (period ending december 31, 2024)) lists Illinois as using the 2022 Food Code.

ClearHACCP builds plans to the FDA Food Code 2022 and prints the section next to every limit. We have not yet verified how Illinois's edition compares, so plans for Illinois are checked by a person. Older editions also call for HACCP plans and variances for special processes, but paragraph numbers and some details differ. Ask your plan reviewer which edition and forms they work from.

Agencies the FDA report lists

AgencyEditionAs reported
Illinois Department of Public Health 2022 Restaurants and retail food stores. Manual short-form. Effective 2024 (rulemaking completed and effective in 2024).

Agency names and editions are copied as printed in the FDA report. A state can adopt a newer edition after the report period.

Where a HACCP plan or variance goes in Illinois

We have verified the local rules for Chicago Department of Public Health, Food Protection Program, quoted word for word below with links to the source. Anywhere else in Illinois, check with the health department that issues your permit.

Verified local rules

Chicago Department of Public Health, Food Protection Program Verified

Submitting a HACCP plan 3
  • The reduced oxygen packaging HACCP plan must be provided to CDPH before the process starts.

    "Is provided to the DEPARTMENT prior to implementation as specified under Paragraph 8-201.13(B)."

    3-502.12(B)(7), Effective October 1, 2023 (published September 28, 2023)
  • Before starting an activity that requires a HACCP plan, the applicant or license holder must submit the plan to CDPH for approval.

    "Before engaging in an activity that requires a HACCP PLAN, a LICENSE applicant or LICENSE HOLDER shall submit to the DEPARTMENT for approval a properly prepared HACCP PLAN"

    8-201.13(A), Effective October 1, 2023 (published September 28, 2023)
  • Before reduced oxygen packaging without a variance, the operator must develop a HACCP plan and keep a copy on the premises.

    "Before engaging in REDUCED OXYGEN PACKAGING without a VARIANCE as specified under Section 3-502.12, LICENSE applicants or LICENSE HOLDERS shall develop a properly prepared HACCP PLAN and retain a copy in their records available for inspection on the premises."

    8-201.13(B), Effective October 1, 2023 (published September 28, 2023)
Variances 4
  • A variance from CDPH is required before smoking food for preservation rather than flavor, and before curing food.

    "Smoking FOOD as a method of FOOD preservation rather than as a method of flavor enhancement; Pf (B) Curing FOOD;"

    3-502.11 Variance Requirement, (A) and (B), Effective October 1, 2023 (published September 28, 2023)
  • A variance is required before sprouting seeds or beans.

    "(H) Sprouting seeds or beans."

    3-502.11 Variance Requirement, (H), Effective October 1, 2023 (published September 28, 2023)
  • A variance request must state the proposed variance and cite the relevant Code sections.

    "A statement of the proposed VARIANCE of the Code requirement citing relevant Code section numbers;"

    8-103.11(A), Effective October 1, 2023 (published September 28, 2023)
  • A variance request must analyze how the public health hazards addressed by the cited sections will be handled another way.

    "An analysis of the rationale for how the potential public health HAZARDS and nuisances addressed by the relevant Code sections will be alternatively addressed by the proposal;"

    8-103.11(B), Effective October 1, 2023 (published September 28, 2023)
Forms and templates 1
  • The CDPH plan review application asks for a HACCP plan for specialized processes such as on site vacuum packaging.

    "Provide a HACCP plan for specialized processing methods such as vacuum packaged foods items prepared on-site or otherwise required by the regulatory authority."

    Plan Review Application, Specialized Processes, undated
Food Code edition 2
  • Chicago enforces its own Chicago Food Code Rules issued by CDPH, which were amended and reissued to replace the version effective in early two thousand nineteen.

    "THESE UPDATED CHICAGO FOOD CODE RULES SUPERSEDE THE CHICAGO FOOD CODE RULES WHICH WERE PUBLISHED ON JANUARY 1, 2019"

    Preamble (order of the Commissioner), Effective October 1, 2023 (published September 28, 2023)
  • The current Chicago Food Code Rules took effect on the date shown on the cover.

    "Effective October 1, 2023"

    Cover page, Effective October 1, 2023 (published September 28, 2023)
Records 3
  • Cooling and cold holding records for cook-chill and sous vide must be kept for a minimum period.

    "Hold such records for at least six (6) months;"

    3-502.12(D)(2)(b), Effective October 1, 2023 (published September 28, 2023)
  • If a variance is granted, the establishment must keep the variance information on the premises for inspection.

    "If the variance is granted, the RETAIL FOOD ESTABLISHMENT shall retain a copy of the information specified under Section 8-103.11 in its records and available for inspection on the premises."

    8-103.10, Effective October 1, 2023 (published September 28, 2023)
  • Supporting documents for the HACCP plan include blank copies of the record forms.

    "Copies of blank records forms that are necessary to implement the HACCP PLAN;"

    8-201.14(E)(2), Effective October 1, 2023 (published September 28, 2023)
Training 2
  • The reduced oxygen packaging HACCP plan must describe a training program for the person responsible for the operation.

    "Describes the training program that ensures that the individual responsible for the REDUCED OXYGEN PACKAGING operation understands the:"

    3-502.12(B)(6), Effective October 1, 2023 (published September 28, 2023)
  • Supporting documents for the HACCP plan include an employee and supervisor training plan.

    "FOOD EMPLOYEE and supervisory training plan that addresses the FOOD safety issues of concern;"

    8-201.14(E)(1), Effective October 1, 2023 (published September 28, 2023)
Standard operating procedures 1
  • The reduced oxygen packaging HACCP plan must include operational procedures such as no bare hand contact with ready to eat food.

    "Includes operational procedures that: (a) Prohibit contacting READY-TO-EAT FOOD with bare hands"

    3-502.12(B)(5), Effective October 1, 2023 (published September 28, 2023)
Labels 1
  • Cook-chill and sous vide packages must be labeled with the product name and packaging date.

    "Labeled with the product name and the date PACKAGED;"

    3-502.12(D)(1)(g), Effective October 1, 2023 (published September 28, 2023)
Monitoring 1
  • Cook-chill and sous vide storage units need continuous electronic time and temperature monitoring checked visually each day.

    "Held in a refrigeration unit that is equipped with an electronic system that continuously monitors time and temperature and is visually examined for proper operation twice daily,"

    3-502.12(D)(1)(e), Effective October 1, 2023 (published September 28, 2023)
Flow diagram 1
  • The HACCP plan must include a flow diagram or chart for each food or category.

    "A flow diagram or chart for each specific FOOD or category type that identifies:"

    8-201.14(C), Effective October 1, 2023 (published September 28, 2023)
CCP summary 1
  • The HACCP plan must include a critical control point summary for each food or category.

    "A CRITICAL CONTROL POINTS summary for each specific FOOD or category type that clearly identifies:"

    8-201.14(D), Effective October 1, 2023 (published September 28, 2023)
Sous vide 2
  • Cook-chill and sous vide packaging of TCS food requires a HACCP plan provided to CDPH before the process starts.

    "using a cook-chill or sous vide process shall: (1) Provide to the DEPARTMENT prior to implementation, a HACCP"

    3-502.12(D)(1), Effective October 1, 2023 (published September 28, 2023)
  • Cook-chill and sous vide product must stay within the same business entity and may not be distributed or sold to another business or to consumers.

    "Prepared and consumed on the PREMISES, or prepared and consumed off the PREMISES but within the same business entity with no distribution or sale of the PACKAGED product to another business entity or the CONSUMER,"

    3-502.12(D)(1)(a), Effective October 1, 2023 (published September 28, 2023)
Cook-chill 1
  • Cook-chill and sous vide food must be cooled in the bag and then either chilled further and kept for up to the longer limit, held cold for the shorter limit, or frozen; Chicago lists only these three options.

    "Cooled to 5°C (41°F) in the sealed PACKAGE or bag as specified under Section 3-501.14 and: P (i) Cooled to 1°C (34°F) within 48 hours of reaching 5°C (41°F) and held at that temperature until consumed or discarded within 30 days after the date of PACKAGING;P (ii) Held at 5°C (41°F) or less for no more than 7 days, at which time the FOOD must be consumed or discarded; P or (iii) Held frozen with no shelf life restriction while frozen until consumed or used."

    3-502.12(D)(1)(d), Effective October 1, 2023 (published September 28, 2023)
Vacuum packing (ROP) 7
  • A variance is required for reduced oxygen packaging of TCS food unless botulism and Listeria are controlled under the criteria of section 3-502.12.

    "Packaging TIME/TEMPERATURE CONTROL FOR SAFETY FOOD using a REDUCED OXYGEN PACKAGING method except where the growth of and toxin formation by Clostridium botulinum and the growth of Listeria monocytogenes are controlled as specified under Section 3-502.12;"

    3-502.11 Variance Requirement, (D), Effective October 1, 2023 (published September 28, 2023)
  • Reduced oxygen packaged food without a variance must be held cold and also meet a second barrier such as low water activity or low pH.

    "requires that the PACKAGED FOOD shall be maintained at 5°C (41°F) or less and meet at least one of the following criteria: Pf (a) Has an Aw of 0.91 or less, Pf (b) Has a pH of 4.6 or less,"

    3-502.12 Reduced Oxygen Packaging Without a Variance, Criteria, (B)(2), Effective October 1, 2023 (published September 28, 2023)
  • A meat or poultry product cured at a USDA regulated plant and received intact is an accepted second barrier for reduced oxygen packaging.

    "Is a MEAT or POULTRY product cured at a FOOD PROCESSING PLANT regulated by the USDA"

    3-502.12(B)(2)(c), Effective October 1, 2023 (published September 28, 2023)
  • Food with a high level of competing organisms such as raw meat, raw poultry or raw vegetables is an accepted second barrier for reduced oxygen packaging.

    "Is a FOOD with a high level of competing organisms such as raw MEAT, raw POULTRY, or raw vegetables;"

    3-502.12(B)(2)(d), Effective October 1, 2023 (published September 28, 2023)
  • Reduced oxygen packages must be labeled to keep the food cold and to discard it within the stated number of days of packaging.

    "Maintain the FOOD at 5oC (41oF) or below, Pf and (b) Discard the FOOD if within 30 calendar days of its PACKAGING"

    3-502.12(B)(3), Effective October 1, 2023 (published September 28, 2023)
  • Refrigerated shelf life of reduced oxygen packaged food is capped, not counting frozen time, or the manufacturer date if sooner.

    "Limits the refrigerated shelf life to no more than 30 calendar days from PACKAGING to consumption, except the time the product is maintained frozen, or the original manufacturer’s “sell by” or “use by” date, whichever occurs first;"

    3-502.12(B)(4), Effective October 1, 2023 (published September 28, 2023)
  • No HACCP plan is needed for reduced oxygen packaged TCS food that is labeled with time and date, held cold, and removed from the package within the stated hours.

    "Held at 5°C (41°F) or less during refrigerated storage, P and (3) Removed from its PACKAGE in the RETAIL FOOD ESTABLISHMENT within 48 hours after PACKAGING."

    3-502.12(F), Effective October 1, 2023 (published September 28, 2023)
Vacuum packing fish 1
  • Fish may be reduced oxygen packaged only if frozen before, during and after packaging and labeled to be kept frozen until use.

    "Except for FISH that is frozen before, during, and after PACKAGING and bears a label indicating that it is to be kept frozen until time of use, a RETAIL FOOD ESTABLISHMENT may not PACKAGE FISH using a REDUCED OXYGEN PACKAGING method."

    3-502.12(C) Fish, Effective October 1, 2023 (published September 28, 2023)
Vacuum packing cheese 1
  • Reduced oxygen packaged cheese must carry a use by date no later than the limit shown or the manufacturer date if sooner.

    "Labels the PACKAGE on the principal display panel with a “use by” date that does not exceed 30 days from its packaging or the original manufacturer’s “sell by” or “use by” date, whichever occurs first;"

    3-502.12(E)(3), Effective October 1, 2023 (published September 28, 2023)
Sushi rice 1
  • Chicago exempts food acidified with vinegar (such as sushi rice) from the variance requirement if a recent certified lab product assessment of pH is on file with no process change, or if the person in charge has a pH meter on site.

    "however, a FOOD that has vinegar as a FOOD ADDITIVE is not required to obtain a variance if: (i) a product assessment has been completed within the past five (5) years and the Person in Charge has records verifying the pH from a certified lab, and there has been no change in process, Pf or (ii) The Person in Charge has a pH meter available onsite capable of determining the pH."

    3-502.11 Variance Requirement, (C), Effective October 1, 2023 (published September 28, 2023)
Other requirements 1
  • CDPH may require scientific data showing the proposal does not compromise food safety.

    "Additional scientific data or other information, as required by the DEPARTMENT, supporting the determination that FOOD safety is not compromised by the proposal."

    8-201.14(E)(3), Effective October 1, 2023 (published September 28, 2023)

Quoted from the official sources linked, retrieved 2026-10-08. Rules and fees change; confirm with the health department before you submit.

What needs a HACCP plan

Under the FDA Food Code 2022, a restaurant needs a HACCP plan before it starts any process that needs a variance, or before it vacuum packs without one:

FDA Food Code 2022, 8-201.13(A)

Before engaging in an activity that requires a HACCP PLAN, a PERMIT applicant or PERMIT HOLDER shall submit to the REGULATORY AUTHORITY for approval a properly prepared HACCP PLAN as specified under § 8-201.14 and the relevant provisions of this Code if:

In a restaurant that usually means sous vide and cook-chill, vacuum packing, acidified sushi rice, curing and smoking to preserve.

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Frequently asked questions

Does Illinois require a HACCP plan for sous vide?
The FDA Food Code requires one for sous vide and cook-chill in a restaurant (3-502.12(D) in the 2022 edition). The FDA report lists Illinois as using the 2022 Food Code; we have not verified how Illinois applies it. Ask your health department which forms its plan reviewers use. Check your process free.
Who approves HACCP plans in Illinois?
The regulatory authority for your permit, which in most places is your city or county health department, sometimes a state agency. See the verified local requirements on this page for how it works where we have checked.
Will a ClearHACCP plan work here?
Plans are built to the FDA Food Code 2022 and print the section for every limit. If your health department runs an older edition or adds rules, tell us what it asks for and we revise the plan free for 12 months. Only your regulatory authority approves a plan.

Sources

  1. FDA, Adoption of the FDA Food Code by State and Territorial Agencies Responsible for the Oversight of Restaurants and/or Retail Food Stores (2024 report)
  2. FDA, Food Code adoption by state (overview page)
  3. FDA Food Code 2022, full text (PDF)
  4. Chicago Department of Public Health, Food Protection Program: Preamble (order of the Commissioner)
  5. Chicago Department of Public Health, Food Protection Program: Plan Review Application, Specialized Processes

Every temperature, time and pH on this page is quoted from the FDA Food Code 2022 with its section number. Your state or county may run an older edition or add its own rules, and only your regulatory authority approves a HACCP plan or grants a variance. This page explains the rules in plain words; it is not legal advice.

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