It's 8:40 at a coffee shop in Manhattan. Mobile orders are stacking up and two iced lattes sit side by side at the hand-off counter. One is oat. One is almond. A customer reaches for the wrong one, and the only thing between her and a tree nut is whoever is calling names.
Behind the register is a cooler of house cold brew bottles, made before anyone ordered.
The cup is a good practice question. The cooler is a legal one, and in New York it changes on 11/12/2026, when the state's prepackaged allergen law starts.
Drink labels for coffee shops in 60 seconds
- Made-to-order cup stickers are not legally required under federal allergen labeling, because the drink is packed after the order. New York's new law excludes them too.
- They're still worth printing. Almond milk is a tree nut, soy is soy, oat and coconut are neither. FDA dropped coconut as a major allergen in January 2025.
- In New York, our reading is that bottled cold brew, smoothies and overnight oats made in store are likely covered from 11/12/2026. No official guidance yet.
- Cold brew is treated as TCS by the regulators we checked: up to 7 days at 41°F or below, or 48 hours if your health department counts sealed bottles as reduced oxygen packaging.
- Bottled untreated juice needs the unpasteurized warning. Juice by the glass doesn't.
- Chains with 20+ locations have calorie rules. California's SB 68 is a menu rule.
Part 1: Cup stickers, made to order
What the law asks: almost nothing
Federal allergen labeling covers food a store packs in advance, not food packed on demand. FDA says the labeling requirements do not apply to foods "placed in a wrapper or container" following "a customer's order at the point of purchase."
A latte made after the order is exactly that. New York's law draws the same line: prepackaged food "does not include food that is not in packaging or is packaged after a customer has ordered."
So you don't need allergens on a cup sticker to comply. But the risk at the hand-off counter is real, and a sticker is the cheapest fix. Our made-to-order labels guide covers the general case.
Milk swaps and the 9 major allergens
The 9 major food allergens are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. The milk menu maps like this:
- Dairy is milk. FDA treats "milk" as milk from cows, goats, sheep or other ruminants.
- Almond is a tree nut.
- Soy is soy.
- Oat is none of the 9. Some oat drinks carry a wheat cross-contact statement from the supplier, so read the carton.
- Coconut is none of the 9. FDA's guidance FAQ: "No, the FDA no longer considers coconut a major food allergen."
So the allergen comes from the build, not the menu default. Sauces count too: some chocolate or caramel sauces contain milk.
What a good cup sticker shows
- Order number, name, drink and size
- The milk, marked as a swap, and each modifier
- A CONTAINS line built from the actual drink
- A cross-contact note for shared steam wands or blenders
Here's a 2x2 in sticker. Ingredients and allergens are illustrative.
#A142 · MAYA · 1 of 2
ICED LATTE 16 oz
Almond milk (swap)
+ Vanilla syrup, 2 pumps
+ Extra shot
CONTAINS: TREE NUTS (ALMOND)
Shared steam wands and blenders
Mobile · 8:42 AM
With dairy, the line would read "CONTAINS: MILK." With oat or coconut, there'd be no milk or tree nut line unless another component added one. This assumes the syrup contains none of the 9. And don't print "dairy-free" on a cup made with a shared steam wand.
Part 2: Drinks made in store and sold from the cooler
Make a drink before anyone orders it, cap it and put it in the fridge, and federal allergen labeling applies. Other rules stack on top.
New York from 11/12/2026
New York's prepackaged allergen law (Chapter 494 of 2025) takes effect 11/12/2026. It covers food "prepared, prepacked and offered or sold to customers on the same premises," and requires a notice identifying any ingredient that is a major food allergen.
The bill says "food," not "drink." But New York's Agriculture and Markets Law defines food to include "all articles of food, drink, confectionery or condiment."
Our reading, from those definitions: bottled cold brew, pre-poured smoothies and overnight oats made in store and put in the cooler before anyone orders are likely covered. A latte made after the order is not. No New York agency has published guidance on drinks yet.
The duty is narrow: name the major allergens. Our New York allergen labeling law guide covers scope and who's included.
Bottled cold brew: 7 days or 48 hours
We found no FDA guidance specific to cold brew. The regulators we checked, Wisconsin and Maricopa County in Arizona, treat cold brew made without a heat step as time/temperature control for safety (TCS) food unless you prove otherwise.
As TCS food held over 24 hours, it needs a date mark under the Food Code as your state adopts it: 41°F or below, 7 days maximum, brew day counted as day 1.
Sealed bottles are less clear. Maricopa County says kegging, or "a similar packaging method, such as bottling," is reduced oxygen packaging (ROP). Without a HACCP plan and variance, sealed product must be held in the package less than 48 hours, then discarded, removed from the package or unsealed. Wisconsin names kegging and nitrogen but doesn't say ordinary bottles count. Both treat nitro as ROP.
So your bottle might carry a 7-day date or a 48-hour one. Check with your local health department before you print it.
Here's a 2x4 in New York bottle label using the conservative 48-hour version. Ingredients are illustrative.
VANILLA SWEET CREAM COLD BREW
Ingredients (illustrative): cold brew coffee (water, coffee), cream (milk), sugar, water, vanilla extract
CONTAINS: MILK
Net 12 fl oz (355 mL)
Bottled: 11/16/26 7:30 AM
Discard by: 11/18/26 7:00 AM
Keep refrigerated at 41°F or below
Made by Corner Cafe, 123 Main St, Brooklyn, NY
Under New York's law, the CONTAINS line is the required part. A plain black cold brew has no allergen to name. The other lines are Food Code elements where adopted; we haven't verified New York's own code, so treat them as good practice.
Bottled juice and smoothies
Juice sold by the glass needs no warning label. Untreated juice you bottle for the cooler does.
A shop selling juice only to consumers is exempt from federal juice HACCP, but that exemption doesn't extend to the label. The Food Code says juice packaged in a food establishment must be treated to a 5-log reduction or carry the warning from 21 CFR 101.17(g):
WARNING: This product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems.
Place it prominently, "WARNING" in bold capitals, in a hairline box. If you also sell juice wholesale to another business, you lose the HACCP exemption.
Smoothies are less settled. Nothing we checked says whether a bottled whole-fruit smoothie needs the warning. With pasteurized juice and frozen fruit, the issue mostly falls away. With fresh, untreated pressed juice, the rules point toward the warning. Ask your health department.
Overnight oats and parfaits
These are ready-to-eat TCS food. Held over 24 hours, they need a date mark: 7 days maximum at 41°F or below, prep day as day 1. A shorter date for quality is your choice, not a rule. Ingredients below are illustrative.
OVERNIGHT OATS, ALMOND BUTTER AND BANANA
Ingredients (illustrative): rolled oats, almond milk (water, almonds), Greek yogurt (milk), banana, almond butter (almonds), chia seeds, honey, cinnamon
CONTAINS: MILK, TREE NUTS (ALMOND)
Net wt 10 oz (283 g)
Made: 11/02/26
Use by: 11/08/26
Keep refrigerated at 41°F or below
Made by Corner Cafe, 123 Main St, Anytown, USA
11/02 to 11/08 is 7 days with 11/02 as day 1. "TREE NUTS (ALMOND)" names the specific nut, as the Food Code asks. For general cooler rules, see our grab-and-go labeling requirements.
Chains with 20+ locations
Chains with 20 or more locations under the same name and substantially the same menu fall under federal menu labeling, drinks included:
- Calories on menus and boards, declared for each flavor.
- Custom orders aren't covered.
- For a bottle on display in the cooler, calories go close to the item, on a sign or tag. Not required on the bottle.
California's SB 68 adds written allergen notification for each menu item at the same chains from 07/01/2026: on the menu, by QR code to a digital menu, or in a separate allergen menu, chart, grid or booklet. It's a menu rule, not a cup or bottle rule.
Coffee shop label checklist
- Mark every drink and cooler item: made after the order, or packed before it.
- Map your milks: dairy is milk, almond is tree nut, soy is soy, oat and coconut are neither.
- Check every syrup, sauce and topping against its supplier label.
- Build the cup sticker's CONTAINS line from the actual drink, swaps included.
- Add a cross-contact note for shared equipment. Skip "dairy-free."
- Ask your health department if cold brew is TCS and if sealed bottles are ROP. Set 7-day or 48-hour dates.
- Hold the cooler at 41°F or below and count prep day as day 1.
- Bottling untreated juice? Add the boxed warning or treat to a 5-log reduction.
- In New York, put a CONTAINS line on everything you make and pack before the order, from 11/12/2026.
- 20+ locations? Calories by the cooler, and check SB 68 in California.
What's still unclear
- New York and drinks. The Agriculture and Markets Law includes drink in "food." We didn't find a Public Health Law definition that clearly does. No agency guidance yet.
- Pre-poured cups at rush. Iced tea or cold brew poured into lidded cups before any order is, by the text, likely prepackaged in New York. Unconfirmed.
- Bottles and ROP, and whether cold brew is TCS everywhere. See above.
- Which code applies. New York uses its own State Sanitary Code and New York City has its own Health Code. FDA's latest model is the 2026 Food Code; state adoption takes time.
- California and modifiers. SB 68 doesn't say how to show milk swaps or syrups.
How Dill handles it
Dill keeps your recipes, ingredients, allergens and shelf lives in one place. Recipes are built from ingredients, so when you change an oat milk supplier or a syrup, every drink that uses it updates.
At the bar, Dill connects to POS data (Clover, Lightspeed, EposNow, CyBake, PosHub), so products aren't retyped, and prints made-to-order labels. For the cooler, staff pick the item on a tablet or phone (iOS and Android) and the label prints with the right allergens, dates and who made it. A change made once reaches every site.
It runs on Brother label printers, with other hardware on request. The numbers so far: hundreds of businesses, thousands of sites between them, and over 65 million labels printed.
Book a demo and get your cup and cooler labels set up before 11/12/2026.
FAQ
Do I legally need allergens on a latte cup sticker?
No. Federal allergen labeling doesn't apply to drinks put in a cup after the customer orders, and New York's law excludes them too. It's still good practice, because milk swaps change the allergens.
Is oat milk an allergen?
Oats aren't one of the 9 major allergens. Some oat drinks carry a supplier wheat cross-contact statement, so read the carton.
Is coconut a tree nut?
Not for labeling. FDA's January 2025 guidance says it no longer considers coconut a major food allergen.
Is cold brew a TCS food?
The state and local regulators we checked treat it as TCS unless you show otherwise. FDA has no cold-brew-specific guidance, so check with your local health department.
How long can I keep bottled cold brew?
Up to 7 days at 41°F or below, brew day as day 1, if your health department treats it as ordinary TCS food. If sealed bottles count as reduced oxygen packaging, 48 hours without a HACCP plan and variance.
Does New York's law cover bottled cold brew?
Our reading is yes, if you make and bottle it in store before anyone orders, from 11/12/2026. There's no official guidance on drinks yet.
Do I need the juice warning on fresh juice by the glass?
No. FDA doesn't require it for juice sold by the glass. It applies to untreated juice you package.
This post is general information, not legal advice. Check the rules for your business with your local health department.
