FDA Food Facility Renewal in 2026: Does Your Restaurant or Prep Kitchen Need It?

Only if that location is required to register with FDA. FDA's September 29, 2026 reminder is about renewing an existing registration, and only facilities that are required to register have to renew, between October 1 and December 31, 2026. Under FDA's 2018 guidance, a restaurant (a place that prepares and sells food directly to consumers for immediate consumption) is exempt from registering as a restaurant, so there's nothing to renew on that basis. A separate prep or central kitchen that only supplies your restaurants is different. FDA says a central kitchen that doesn't prepare and serve food directly to consumers isn't a restaurant, so it can't use the restaurant exemption. It has to be registered unless another exemption fits it.

Work it out one location at a time. There's no single answer for a whole restaurant group. Shops that make and sell food, like bakeries, have a separate test: their annual food sales dollars to consumers have to be greater than their annual food sales dollars to every other buyer. Registration isn't FDA approval of your food or your kitchen, and it isn't your local health permit. FDA charges no fee to register or renew.

This answer uses FDA's September 29 reminder, its current registration pages and FDA's 2018 registration guidance, which the registration page still links. That guidance is nonbinding; the statute and regulations are the requirements. When we checked on October 7, 2026, the official eCFR site returned an access-check page instead of the current regulation text (21 CFR 1.226 and 1.227), so the definitions below are quoted as FDA's guidance states them.

What FDA's September 29 reminder says

FDA's constituent update says that every two years, between October 1 and December 31, the owner, operator or agent in charge of a facility that manufactures, processes, packs or holds food for consumption in the United States is required to renew its registration. For this round:

• Renewals go in electronically through the facility's FDA Industry Systems (FIS) account, unless FDA has granted a waiver allowing mail or fax.
• There is no fee for registration or renewal.
• FDA will consider the registration expired for any facility that fails to renew by December 31, 2026.
• Each registration needs a unique facility identifier (UFI). FDA currently accepts the DUNS number from Dun & Bradstreet, and uses it to check that the address tied to the UFI is the same address on the registration.
• Qualified facilities must also submit a qualified facility attestation during the same period. That's a separate filing, covered below.

The reminder doesn't say which businesses are exempt from registering. That comes from the registration rule, which FDA's guidance explains.

Start with a list of every location

FDA's Q&A guidance says a "facility" includes structures under one ownership at one general physical location. In FDA's own example, a company's separate storage building on the same property as its restaurant is exempt from registration, because the two are under one ownership on the same property. If the same building were at a separate location, or owned by someone else, it would be a distinct facility that has to register. FDA gives the same answer for a retailer's off-site distribution center or warehouse: it doesn't sell food directly to consumers, so it has to register.

So write down each restaurant, shop, prep kitchen, commissary and warehouse as its own line. Then decide each one.

Which test applies to each location

Then, for every location that has to be registered:

The restaurant exemption

FDA's guidance quotes the regulation's definition of a restaurant as an establishment that "prepares and sells food directly to consumers for immediate consumption." Restaurants are not required to register. FDA's small-business guide adds that facilities that provide food to interstate conveyances, such as commercial aircraft, and "central kitchens that do not prepare and serve food directly to consumers" are not restaurants for this rule. FDA's Q&A answers the central-kitchen question directly: a central kitchen that doesn't sell the food it prepares directly to consumers for immediate consumption isn't a restaurant, so it isn't exempt as one.

The exemption belongs to the location that does the selling, not to the company. Your dining rooms can be exempt while your prep kitchen across town isn't.

The FDA guidance we used doesn't say how much other activity a restaurant location can take on before the exemption stops covering it. It also doesn't address delivery-only kitchens or event caterers. If one of your restaurants also packs food for other stores or ships packaged food, it sells to consumers and to businesses, so run the retail dollar test below. If that test isn't met, whether the restaurant exemption still covers the location is an open question for FDA or a qualified adviser. A location that doesn't serve guests on site, or that caters events, is an open question too. Don't assume the answer either way.

The retail food establishment test, in dollars

FDA's guidance says a retail food establishment's primary function is selling food directly to consumers when "the annual monetary value of sales of food products directly to consumers exceeds the annual monetary value of sales of food products to all other buyers." Under that definition, a retail food establishment doesn't have to register, even if it makes, packs or holds food, as long as selling food from that establishment directly to consumers is its primary function. The rules that matter when you run the numbers:

• Dollars, not units or profit. Compare sales dollars of food. A case count, gross margin or food cost doesn't answer it. FDA's registration guidance counts beverages, including alcoholic beverages, as food.
• Businesses aren't consumers. A sale to a café, caterer, grocery store or any other business counts on the other-buyers side, even though a person eventually eats the food. FDA's Q&A says a sale to a separate business that runs a sales platform, rather than to the individual buyers, isn't a consumer sale either.
• Greater than, not equal to. Consumer dollars have to exceed other-buyer dollars. A 50/50 split doesn't pass.
• One establishment at a time. The test looks at food sold from that establishment. Don't use total company sales.
• No income ceiling. FDA's Q&A says there's no income limitation in the retail definition.
• Online and mail order is a "maybe." FDA's answer is that a business selling directly to consumers by internet or mail order may be a retail food establishment, provided it meets the other criteria of the definition.
• Which year isn't spelled out. The guidance says "annual" but the sources we used don't say which 12-month period to use. Until FDA or a qualified adviser confirms the right period for your location, a result based on the period you picked is arithmetic, not a determination. Write down the period, who confirmed it and when.

FDA's own example is a bakery that sells mostly to consumers but makes 40% of its annual sales to wholesale buyers. FDA's answer: it's a retail food establishment and doesn't need to register. So a wholesale account doesn't by itself remove the exemption. The dollar comparison decides it.

Here's the arithmetic for one made-up shop, run three ways. Each case assumes the figures cover the applicable annual period, so the last column is a dollar-test result, not a final answer on registration:

The consumer share is consumer dollars divided by total food sales: $180,000 ÷ $300,000 = 60% in Case A. In Case C, if the unrecorded $30,000 went to consumers, the split would be $180,000 to $120,000 and the test would be met. If it went to businesses, the split would be $150,000 to $150,000 and it wouldn't. The answer depends on data the shop doesn't have yet, so don't guess a split. Pull the invoices and classify the buyers first.

The same goes for blanks when a location relies on this test. If any sales figure is missing, or there are no food sales to compare, there's no share to calculate and no determination. A location with no sales to businesses, or with every sale classified, writes $0 on that line rather than leaving it blank. Locations that don't need the test leave the sales lines blank: a restaurant relying on the restaurant exemption, and a location with records showing it sells no food to consumers. Not knowing whether a location sells to consumers isn't the same as knowing it doesn't.

Totals across locations can hide a problem. Say one company owns two made-up bakeries, with figures for the same assumed annual period:

The combined figure passes, but the industrial park bakery fails on its own numbers, and that location is the one being decided.

Failing this test only means the retail exemption doesn't cover that location. FDA lists other exemptions, so failing isn't proof that the location has to register. Passing it doesn't change your local permits, labeling or any other rule either.

Three made-up locations, worked through

1. A taco restaurant with a dining room

It cooks to order and sells plates, tacos and drinks to guests at the counter and in the dining room. It doesn't sell to other businesses. That matches the restaurant definition in FDA's guidance, so this location doesn't have to register as a restaurant. The owner writes one line on the worksheet: restaurant, prepares and sells food directly to consumers for immediate consumption, no business buyers. The sales lines stay blank, because the retail test isn't needed. If it later starts jarring salsa for a grocery store, that note gets reopened: the retail dollar test then applies, and if it isn't met, whether the restaurant exemption still covers the location is an open question, because the sources we used don't settle it.

2. A retail bakery that also sells to cafés

Its own counter sells bread, pastries and coffee to walk-in customers. It also delivers croissants to three cafés. Its POS and invoices show $180,000 in food sales to consumers and $120,000 to the cafés for the 12 months the owner chose. That's Case A arithmetic: $180,000 is greater than $120,000. If those 12 months are the right period, the bakery meets the retail food establishment test and, under FDA's guidance, doesn't have to register. The sources we used don't say which period is right, so for now the owner marks the result as not decided, asks FDA's registration help desk or a qualified adviser which period applies, and writes the confirmed basis on the worksheet. The report, the invoices and the dates of the period go with it, and the numbers get rerun if the café business grows. At $150,000 each, it would fail this test for that period, and the next step would be checking FDA's other exemptions or planning to register.

3. A separate prep kitchen for three restaurants

A made-up group runs three counter-service restaurants and a prep kitchen in a different part of town. The kitchen makes doughs, sauces, dressings and cut vegetables, and trucks them to the three restaurants. No customer buys anything at the kitchen.

What's established from FDA's guidance:

• It isn't a restaurant. It's a central kitchen that doesn't prepare and serve food directly to consumers.
• It isn't a retail food establishment. It doesn't sell food directly to consumers at all, and FDA's flowchart says the retail exemption doesn't apply in that case.
• It's a separate facility from the restaurants because it's at a different location, the same way FDA treats an off-site storage building.
• Its products aren't meat, poultry or egg products, so the exemption for facilities regulated exclusively by USDA doesn't describe it.

What still has to be confirmed before a final answer:

• That no other exemption on FDA's list fits the kitchen. The owner should read the list in FDA's small-business guide, pages 7 and 8, and record the check.

The kitchen leaves the sales lines on the worksheet blank: with records showing no consumer sales, the retail test isn't needed. Until the other-exemption check is done, the answer is not decided, whether or not the kitchen has a registration on file. Separately, and without deciding anything, the owner notes whether the kitchen already has a registration and who holds the FIS account.

If no other exemption fits, the kitchen has to be registered. If it's registered, renew it in the October 1 to December 31, 2026 window. If it was never registered, that's not something to fix with a renewal. Raise it with FDA's registration help desk or a qualified adviser.

A qualified facility attestation is a separate filing

FDA describes a qualified facility as generally a business that, because of its very small size, has to meet only modified requirements under the Food Safety Modernization Act's preventive controls rules. It isn't the same as being exempt from registration. FDA's Q&A says qualified facilities are facilities that are required to register, and FDA's attestation page says a facility needs a valid food facility registration to submit its attestation.

If a registered location might be a qualified facility, it has a second job in the same October 1 to December 31 window: submitting the attestation, through FDA's Qualified Facility Attestation module or by emailing the form if it must be done manually. FDA's cut-off page describes a different dollar test based on a three-year average, so don't reuse your retail-test numbers for it. We didn't work through the qualified-facility thresholds here. Use FDA's qualified facility attestation page and the guidance it links.

If a location has to be registered: get the renewal ready

1. Find the account. Confirm who can log in to the FIS account that holds the registration. Renewal is electronic unless FDA has granted a waiver. FDA's Q&A says you don't have to use a third-party service to submit, and FDA charges no fee. Third parties may charge for their own services.
2. Check the UFI. Confirm the DUNS number on the registration and that Dun & Bradstreet's address for it is the facility's address. FDA's guidance says that if you add or update the UFI during renewal, FDA won't send the renewal confirmation until it has verified the UFI and that address.
3. Compare the registration with today. Check the owner and contact details, emergency contact, trade names, food product categories and the activities at the facility. If nothing has changed since the last registration, renewal or update, FDA offers an abbreviated renewal, where you confirm there are no changes and certify that the information is truthful and accurate.
4. Know that renewing isn't updating. FDA's renewal guide says updating and renewing are different functions. The guide says that during the renewal period the Update option doesn't appear on the registration system's main menu until the registration is renewed, and that only sections shown with an Edit button can be changed during renewal.
5. Submit and keep the confirmation. FDA's Q&A says the registration number stays the same when you renew. File the confirmation with the worksheet.

A limit on the screens: FDA's 2026 renewal guide, current as of August 7, 2026, still tells you to choose the "Biennial Registration Renewal - 2024" option, with the menu screenshot captioned the same way. We haven't logged in to FDA's system or seen the 2026 screens, so the menu names may differ. FDA prints the window as October 1, 2026, 12:01AM through December 31, 2026, 11:59 PM. The page doesn't name a time zone.

FDA lists these contacts for registration questions: [email protected], 1-240-247-8804, or 1-800-216-7331.

Copy this worksheet for each location

Use one copy per location. The notice at the top travels with every copy: what the worksheet is based on, what we couldn't check, and the renewal dates. Work through it in order. Sections 1 and 2 record facts, section 3 picks the test, and only locations that need the retail test fill in the sales lines in section 4. Section 6 decides whether the location has to register. Any ticked open question in section 5 means it isn't decided yet, and then the sheet gives no registration step. Section 7 records what's on file without deciding anything, and section 8 gives the renewal or first-registration step only when section 6 says the location has to register. Keep the sheet with your private business records, and write down where your registration number, PIN and DUNS number are kept, not the numbers themselves.

FDA FOOD FACILITY WORKSHEET (one copy per location)
From RestaurantLaunch: FDA Food Facility Renewal in 2026,
as of October 7, 2026.

READ THIS FIRST
- Basis: FDA's 2018 registration guidance (Q&A and
  small-business guide). It is nonbinding. We could not
  check the current regulation text (21 CFR 1.226 and
  1.227) on October 7, 2026.
- The sources don't say which 12-month period to use for
  the sales test in section 4. Confirm it with FDA or a
  qualified adviser before relying on that test.
- 2026 renewal window, as FDA prints it: October 1, 2026,
  12:01AM through December 31, 2026, 11:59 PM. FDA's page
  names no time zone.
- FDA's 2026 renewal guide still shows 2024 menu labels.
  We haven't used FDA's registration system, so the
  screens may differ.
- Work in order. Sections 1 to 6 decide whether this
  location has to register. Only section 8 gives a
  registration step, and only when section 6 says yes.
- This sheet records facts and the basis you relied on.
  It isn't an FDA decision or legal advice.
- Keep it with your private business records. Write where
  registration, PIN and DUNS numbers are kept, never the
  numbers themselves.

Location (name and street address, your records): ______
Legal owner of this location: ______
On the same property as another location you own?
  yes / no / not sure   Which one: ______
Person filling this in (name and role): ______

1. WHAT HAPPENS HERE (facts only)
Prepares food: yes / no
Packs or packages food: yes / no
Stores food for other locations: yes / no
Sends food to other locations or businesses: yes / no
  To whom: ______
Prepares and sells food directly to consumers for
immediate consumption here: yes / no / not sure
Serves no guests on site (delivery only), or caters
events: yes / no / not sure

2. WHO BUYS FOOD FROM THIS LOCATION (facts only)
Sells food directly to consumers (individual people),
here or by internet or mail order: yes / no / not sure
  If no, the records that show it: ______
Sells food to businesses, including your own other
locations, cafes, shops, caterers and resellers, or
packs or ships food for other businesses:
  yes / no / not sure   List: ______

3. WHICH TEST APPLIES (tick the first line that fits)
[ ] Consumer sales "not sure", or "no" with no records
    named in section 2: not decided. Unknown isn't no.
    Tick it in section 5.
[ ] No consumer sales, records named in section 2 (for
    example, a separate prep or central kitchen that
    only supplies your outlets): it can't use the
    restaurant or retail exemption. Retail test not
    needed: leave section 4 blank. Go to section 5.
[ ] Delivery only or event catering, yes or not sure:
    not decided. Tick it in section 5.
[ ] Restaurant: prepares and sells food directly to
    consumers for immediate consumption here, and
    business sales in section 2 are "no".
    Evidence: ______
    Retail test not needed: leave section 4 blank.
    Go to section 5.
[ ] Any other location that sells food to consumers,
    like a retail bakery or market, or a restaurant
    that also sells to businesses: the retail test
    applies. Fill in section 4.

4. RETAIL SALES TEST (only if section 3 sends you here)
Sent elsewhere by section 3? Leave this blank and go to
section 5. Blank lines here then don't count.
This location only. Do not add other locations.
Food sales dollars, including beverages. Not units,
not profit. Every sale to a business goes in B. Write
$0 for none: no business sales is $0 in B, and every
sale classified is $0 in C. Don't leave a line blank.
12-month period used: ______ to ______
Period confirmed as the right one by (FDA or adviser,
name, date): ______
Source (POS report, invoices, ledger): ______
A. Food sales to consumers:            $______
B. Food sales to all other buyers:     $______
C. Food sales not yet classified:      $______
STOP, no determination, if A, B or C is blank, if C
is more than $0, or if A + B is $0. Find or classify
the sales first. Don't calculate a share. Tick it in
section 5.
Total food sales (A + B):              $______
Consumer share, A / (A + B):           ______ %
Is A greater than B?  yes / no   (equal = no)
Period not confirmed: the answer above is arithmetic
on an assumed period, not a determination. Tick it in
section 5.

5. OPEN QUESTIONS (any box ticked = not decided)
Tick what section 3 or 4 sent here, and anything else
you know is unresolved for this location.
[ ] Consumer sales not sure, or "no" without records
[ ] Delivery-only kitchen or event catering
[ ] Retail test: A, B or C blank, C more than $0, or
    A + B is $0
[ ] Retail test: period not confirmed
[ ] Retail test not met, and the location prepares and
    sells food for immediate consumption: does the
    restaurant exemption still cover it?
[ ] Another exemption might fit but isn't confirmed
[ ] Other: ______
Who will ask FDA's registration help desk or an
adviser: ______   Ask by (date): ______
Answer, confirmed basis, and where it's filed: ______
When answered, redo sections 3 to 6 with the answer.

6. DOES THIS LOCATION HAVE TO REGISTER? (tick one)
[ ] Not decided: a box is ticked in section 5, or no
    exemption is recorded and FDA's other exemptions
    haven't been checked. Stop here. Skip section 8.
[ ] No, exempt (only if section 5 is clear). Basis:
    [ ] Restaurant (section 3)
    [ ] Retail food establishment: A greater than B,
        period confirmed (section 4)
    [ ] Another exemption on FDA's list: ______
    Evidence: ______
[ ] Yes, has to register. Only if section 5 is clear,
    section 1 shows it prepares, packs or stores food,
    neither the restaurant nor the retail exemption
    covers it, and you checked FDA's other exemptions
    and none fits.
FDA document and section checked, by, date: ______
A separate prep or central kitchen that doesn't serve
consumers can't use the restaurant exemption, and
failing section 4 rules out only the retail exemption.
Neither one alone means it has to register.

7. REGISTRATION RECORD (facts only, fill in any time)
These answers don't decide anything. A record on file
doesn't show the location has to register, and no
record doesn't show one is missing. Section 6 decides.
FDA registration on file: yes / no / don't know
Where the registration record is kept: ______
Who can log in to the FDA Industry Systems (FIS)
account: ______
UFI (DUNS) address matches the facility address on the
registration: yes / no / not checked
Anything changed since the last registration, renewal
or update: yes / no   What: ______

8. REGISTRATION STEP (only if section 6 is "Yes")
Section 6 "Not decided": skip this section. Don't
renew, register or let a registration lapse because of
this sheet. Get the section 5 answer first.
Section 6 "No, exempt" with a registration on file:
confirm with FDA before letting it lapse.
Section 6 "Yes", using section 7:
- Registration on file: renew October 1 to
  December 31, 2026. Renewing and updating are
  separate FDA functions.
  Renewal submitted on (date): ______  By: ______
  Confirmation saved at: ______
- No registration on file: a first registration is
  missing. This isn't a renewal. FDA's guidance says a
  facility that must register does so before it starts
  operating. Take it to FDA's help desk or an adviser.
- Don't know: find out from your records or FDA's help
  desk before any registration step.

9. QUALIFIED FACILITY ATTESTATION (separate from renewal)
Submit only if section 6 is "Yes" and the location is
registered. FDA says qualified facilities are ones
required to register, and its attestation page says a
valid registration is needed to submit.
Might this facility be a qualified facility?
  yes / no / not checked
Checked against FDA's current qualified-facility guidance
on (date): ______  By: ______
Attestation submitted on (date): ______
Confirmation saved at: ______

RESULT FOR THIS LOCATION (copy from sections 6 and 8)
Tick one.
[ ] Not decided (section 6): get the section 5 answer
    first. No registration step yet.
[ ] Exempt, basis recorded in section 6: ______
[ ] Has to register, registration on file: renew
    October 1 to December 31, 2026
[ ] Has to register, none on file: first registration
    missing (section 8), not a renewal
[ ] Has to register, registration status unknown:
    find out before any registration step
This records your basis. It isn't an FDA decision.

What this answer doesn't cover

This covers FDA's restaurant and retail exemptions and the 2026 renewal for US restaurants, bakeries and prep kitchens, as of October 7, 2026. It doesn't work through imported food or foreign facilities, farms, animal food, meat, poultry and egg products under USDA, facilities handling both USDA- and FDA-regulated food, nonprofit food establishments, shared or rented kitchens and who registers them, changes of ownership, or qualified-facility thresholds. Other exemptions and requirements can apply. It isn't legal advice. When your situation isn't clearly covered, ask FDA or a qualified adviser.

FDA registration also doesn't replace state and local approvals. Our guide to restaurant permits covers local approvals in New York City and New Jersey, and our frozen pizza label answer covers ingredient statements and allergen labeling for pizzas sold through other stores. Neither of those covers FDA facility registration.

Sources

• FDA Reminds Food Facilities of Biennial Renewal Requirements, FDA constituent update, September 29, 2026
• Food Facility Registration User Guide: Biennial Registration Renewal, FDA, content current as of August 7, 2026 (still names the 2024 menu option)
• Online Registration of Food Facilities, FDA, content current as of October 1, 2026
• Registration of Food Facilities: What You Need to Know About the FDA Regulation (Small Entity Compliance Guide), FDA, May 2018, nonbinding guidance, pages 2, 6 to 8, 14 and 17
• Questions and Answers Regarding Food Facility Registration (Seventh Edition), FDA, August 2018, nonbinding guidance, questions B.2, B.3, C.1.8, C.3.7, D.1 to D.3, L.2 and O.2 to O.4
• Retail Food Establishment Exemption Flowchart, FDA, May 2018 v.1
• Qualified Facility Attestation, FDA, content current as of September 29, 2026
• FSMA Inflation Adjusted Cut Offs, FDA (referenced for the three-year basis only; thresholds not used here)