2026 Amendments to the Manufacturing, Processing, Packing or Holding of Food Code (77 Ill. Adm. Code 730) Frequently Asked Questions
What is the Manufacturing, Processing, Packing or Holding of Food Code (77 Ill. Adm. Code 730)?
The Manufacturing, Processing, Packing or Holding of Food Code (77 Ill. Adm. Code 730) is the administrative code that establishes requirements for wholesale food businesses operating in Illinois. It also aligns state standards with federal food safety requirements.
What amendments were made to the Manufacturing, Processing, Packing or Holding of Food Code in 2026?
In March 2026, IDPH adopted new requirements for food processing plants and food storage facilities (warehouses) including annual permitting requirements, fees for follow-up inspections or reinspections, updates to adopted federal standards, and clarified that such facilities cannot operate within private residence kitchens.
I submitted a Manufactured Food Application before July 1, 2026. What fees do I have to pay in 2026? Will I receive a permit?
If you sent in an application before July 1, 2026, no fees are required for 2026. You will be issued a permit for the remainder of 2026 and 2027, with the permit expiring December 31, 2027. You will need to submit a renewal for your permit by December 1, 2027, to avoid a late filing fee for the 2028 permit.
I submitted a Manufactured Food Application on or after July 1, 2026. What fees am I required to pay to obtain a permit, and how long will my permit be valid?
If you apply July 1 – December 31, 2026, an initial application fee and annual fees for all applicable facility types/product types will be required. Once all fees are paid and a satisfactory inspection is completed, you will be issued a permit for the remainder of 2026 and 2027, with the permit expiring December 31, 2027. You will need to apply for renewal by December 1, 2027, to avoid a late filing fee.
Can I start manufacturing/storing my product if I submit the manufactured food application but have not received an inspection yet?
No. You must first obtain a permit and receive a satisfactory inspection. IDPH must be notified of the intent to operate at least 45 days prior to the beginning of operations.
I am already operating, but did not register or receive an inspection before July 1, 2026. What should I do?
You should notify IDPH immediately and complete an application and pay applicable fees. IDPH may ask you to cease operation until an inspection can be completed.
How long is an IDPH permit for manufactured food valid for?
An IDPH permit is valid for one year. Permits expire on December 31 of the year they are issued unless they were issued after October 1.
I have a facility that has already been inspected by IDPH, and I am considered registered. I understand my registration will be converted to a permit, but I may end up changing locations in the next few months. If I change locations, is my permit still valid?
No. Permits are not transferable between locations. Permit holders must notify the department within 30 days of the change of location. When changing locations, the business must complete a new application with applicable fees.
I am a new owner of a wholesale food business. The previous owner was permitted by IDPH. Can I transfer the permit to myself?
No. Permits are not transferable between owners. The new owner is subject to all applicable application and permit fees. Permits may also not be transferred between locations.
I am just starting wholesaling, and I am unsure if it will be a long-term option for me. If I apply and pay the applicable fees, but decide wholesaling isn’t working out for me after a few months, are the 2026 fees refundable?
All fees are nonrefundable. We recommend reviewing the IDPH Manufactured Food Guide for more information about the requirements for food processors and warehouses before applying. The IDPH Manufactured Food Program also has staff available to answer questions at DPH.MfgFood@illinois.gov.
When it is time to renew my permit, how long do I have to renew?
To avoid a late filing fee, renewals must be submitted prior to December 1st of a calendar year. Renewal applications received by IDPH after December 1st of each year shall include a late filing fee. Renewals received 90 days past the expiration date of the permit will not be granted, and applicants will need to complete an initial permit application and all applicable fees.
Where can I find more information about how the application process and fees?
The manufactured food program has information about the application process and fees available on the Manufactured Food Program website and within the applications.
I have a food processing facility that has already been inspected by IDPH. Some issues were found, and an inspector plans to return after all issues have been addressed. If the inspector returns and all corrective actions have not been made, what will happen to my permit with IDPH?
When a follow-up or reinspection is required to ensure corrective actions have been completed, a $200 reinspection fee will be charged. IDPH may deny, suspend, or revoke a permit if a permitted facility fails to take corrective actions upon inspection findings.
I want to operate a wholesale food business from a shared kitchen. Is that possible?
Yes. Food processing plants can operate in a shared kitchen. The facility where the product is processed must also be permitted as a processor. Users of a shared kitchen must be separately permitted and complete the Shared Kitchen User Application.
Do I need a permit if I allow other wholesale firms to use my commercial kitchen space as a shared kitchen?
Yes. Any firm that allows another firm to use their commercial kitchen as a shared kitchen must be licensed by the Department. Users of shared kitchen must be separately permitted.
What application must I complete to provide my space to other businesses as a shared kitchen?
The facility must apply like any other processor using the Application for Food Processing Plant or Food Storage Facility and pay the appropriate fee. Users of shared kitchen spaces must be separately permitted and apply using the Shared Kitchen User Application.
How can I renew my permit as a shared kitchen user?
Shared kitchens can renew their permits annually. However, shared kitchen users will not be renewed until the shared kitchen they are operating from is renewed.
I want to operate a wholesale food business from my home kitchen. Is that allowed?
No. Food processing plants are not permitted to be located within a private residence. Food processing plants may be located on the same premises of a private residence, but must be completely separated. The main intent of the food processing plant must be for the preparation and processing of food. The food processing plant must be completely physically separate from the residence, with no direct access from the residence to the food processing plant. Doorways connecting the food processing plant and the residence are not permitted. Entry/exit to the food processing plant must be external.
My facility is a licensed Grade A and/or manufactured dairy plant. Am I required to get an additional permit?
Depends. A manufactured dairy plant may need to receive an additional permit if they process or store non-dairy food products. Additionally, food storage facilities storing dairy products must obtain an annual permit.
I had an issue at a routine inspection and my inspector scheduled a follow-up inspection. Is there a fee for the follow-up inspection?
Yes. If an IDPH inspector needs to conduct a follow-up inspection to ensure compliance with a corrective action order, a $200 fee will be incurred for each reinspection required.
What other type of reinspections may incur a fee?
A $200 reinspection fee may be charged for IDPH response to a substantiated complaint including follow-up inspections to ensure correction of issues. A permittee may also request an inspection for $200.
What are special products?
Special products are foods like juice (100%), acidified foods, seafood, or molluscan shellfish that fall under more specific regulations. These products have additional food safety requirements and require a more in-depth inspection by IDPH inspectors with advanced training.
What are the fees for special products?
If you are a food processing plant producing special products, you must pay an additional $350 fee annually in addition to your permit. If you process multiple special products, only one fee applies. Special product fees are only applicable to storage facilities for seafood and molluscan shellfish.
I am a food storage facility storing seafood and molluscan shellfish. Do I need to pay a molluscan shellfish fee and a seafood HACCP fee?
No. If you have a molluscan shellfish permit, you do not need to pay a separate fee for Seafood HACCP.