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CDPH Variance / HACCP Plan Approval (raw shellfish, sushi, special processes): Chicago restaurant guide

Chicago Department of Public Health — Food Protection

What it is

Under the Chicago Food Code Rules (in force since July 1, 2018), some processes that require a HACCP plan need a CDPH variance before you use them, and any animal food served raw or undercooked must carry a consumer advisory on the menu.

When a restaurant needs it

Raw oysters/shellfish, sushi (acidified rice), curing, smoking for preservation, reduced-oxygen packaging or other special processes. Juicing, Time as a Public Health Control and manual bottle capping no longer need a variance.

How to apply

Have your chef or a food-safety consultant write the HACCP plan and submit the variance request to CDPH Food Protection before the license inspection; keep shellfish tags on file for 90 days.

Documents you’ll need

Fee
No fee published
Processing time
Varies — allow several weeks before opening
Renewal
Keep the plan and logs current; inspectors check them
Who files
The operator submits; a food-safety consultant often writes the plan.

Good to know

Cold holding is 41°F or colder and TCS foods held over 24 hours must be date-marked. Serving raw shellfish without tags or an advisory is a priority violation.

Official source

CDPH — Chicago Food Code major changes (variances, consumer advisory) · CDPH — Food Safety

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Last reviewed 2026-10-06. Guidance only, not legal advice.