Overview
On October 9, 2025, Assembly Bill 671 (Wicks) was enacted and becomes effective on January 1, 2026. This new law aims to speed up restaurant tenant improvement projects and streamline the plan approval process by amending the Government Code, Business & Professions code and the California Retail Food Code (CRFC). This document will focus only on the changes to the CRFC, which includes a new mandated resubmittal review turnaround time for complete plan submissions for restaurants.
Statuary Reference
AB 671 amends Section 114380 of the Health and Safety Code by adding subsection (f). The new provisions establish specific timelines and deemed-approval rules for restaurant tenant improvement plan reviews.
Scope of Application
Applies only to restaurant tenant improvement plans. Does not apply to other food facilities such as convenience stores, commissaries, or mobile food facilities or to the construction of a new building.
FAQ
1. When will the law take effect?
January 1, 2026
2. Does AB 671 remove any environmental health department oversight in the food facility permitting process?
No. AB 671 does not remove the environmental health department’s oversight. Local environmental health departments may continue to conduct inspections and plan reviews as necessary to ensure compliance with applicable health and safety codes.
3. What is the definition of a restaurant?
For the purposes of this legislative change, a restaurant is defined in Section 66345.1 of the Government Code as a retail food establishment that prepares, serves, and vends food directly to the consumer and is not a fast-food restaurant as defined in Section 1474 of the Labor Law.
Fast-food restaurant is a limited-service restaurant that is part of a chain with more than 60 national locations and has standardized décor, marketing, and menus. Exceptions: locations within airports, hotels or grocery stores are not considered fast-food restaurants.
4. What is the definition of tenant improvement?
Tenant improvement refers to a modification to the interior of an existing building.
5. Have there been any changes to the initial plan review turnaround time?
No. Initial plan reviews should still be completed within 20 business days.
6. What is a "complete plan"?
A complete plan is not defined by law. It generally includes completed application, menu, payment confirmation, full set of plans (title sheet, floor plans, equipment, mechanical, plumbing, finish schedules), specification sheets, finish samples, standard operating procedures (if applicable).
7. What does the new law say about resubmittal review turnaround time?
Resubmittals should be reviewed within 10 business days. However, unlike initial plan reviews, the bill does not specify that plans will be automatically deemed approved if not reviewed within that timeframe.
8. Would all submittals need to be reviewed within the mandated 10 business days?
Yes, plan resubmittals, which are plans submitted with only changes directly linked to comments or corrections issued by the health department, should be reviewed within 10 business days.
9. What is the difference between "resubmittals" and "change of scope"?
Resubmittals address only the items identified by the environmental health department as needed corrections. Resubmittals should be reviewed within 10 business days.
Change of Scope includes plans submitted with changes outside the scope of the issued correction letter or with a change to the scope of work or operations that go beyond correcting identified deficiencies. Change of Scope revisions will be reviewed within 20 business days.
10. What is the process if revised plans include new information not previously reviewed?
If revised plans include new information not previously reviewed, the plans will be considered a change of scope. The applicant will be notified as soon as feasible that the revised plans may require up to 20 business days for review as they are not a resubmittal that is subject to the 10-business day review timeline. New comments or corrections may be issued based on the newly submitted information.
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