lion’s mane extra long teeth
Lion’s mane, extra long teeth. Photo by Nick Frillman

The Illinois Department of Public Health provides guidelines for the sale of specialty mushrooms in Illinois. Specialty mushrooms are any cultivated mushroom species available for food or for use in supplements, outside of the Agaricus family of mushrooms, including white/brown button, bella, baby bella, portobello, and others. Specialty mushrooms are mushrooms grown on straw, wood-based, and/or supplemented substrates, compared to Agaricus species, which grow on manure-based substrates. Examples of specialty mushroom species include, but are not limited to reishi, lion’s mane, oyster, king oyster, Chicken of the Woods (cultivated), Hen of the Woods (cultivated), morel (cultivated), king stropharia/winecap, shiitake, and others. 

  • “Raw agricultural commodity” means any food in its raw or natural state in accordance with the Illinois Food, Drug and Cosmetic Act (410 ILCS 620/2.18)
  • IDPH identifies mushrooms with only a harvest cut as raw agricultural commodities. Packaged mushrooms that are not ready-to-eat remain raw agricultural commodities.
  • Cottage Food Operations. Per Section 4 (b)(1.5)(L ) of the Food Handling Regulation Enforcement Act (410 ILS 625/4), wild-harvested, non-cultivated mushrooms are prohibited ingredients for cottage food products.

Wild mushrooms include any mushroom that is harvested from wild settings, such as state forest or state recreation area lands, private or public woodlots. Wild mushrooms can be defined as any mushroom harvested for sale or consumption and not intentionally cultivated.

  • Retail Food Establishments. Food establishments as defined by the 77 Ill. Adm. Code 750.100 must comply with the 2017 FDA Food Code. The following sections are from the 2017 FDA Food Code
  • Section 3-201.11 (A) Food shall be obtained from sources that comply with law
  • Section 3-201.16 (A) Wild Mushrooms.
    • (A) Except as specified in (B) of this section, mushroom species picked in the wild shall not be offered for sale or service by a food establishment unless the food establishment has been approved to do so
    • (B) This section does not apply to: 
      • (1) Cultivated wild mushroom species that are grown, harvested, and processed in an operation that is regulated by the food regulatory agency that has jurisdiction over the operation; or
      • (2) Wild mushroom species if they are in packaged form and are the product of a food processing plant that is regulated by the food regulatory agency that has jurisdiction over the plant.

Retail and Wholesale Regulations and Regulatory Authorities


Retail / Direct to the Consumer

On the Farm
  • Regulation: Not applicable. "Food establishment" does not include operations selling whole, uncut produce (77 Ill. Adm. Code 750.100). There is no restriction on selling specialty mushrooms or mushroom products direct-to-consumer, on-farm.
Farmers Markets
  • Regulation: Food Handling Regulation Enforcement Act (410 ILCS 625).
    • Section 3.3 Farmers Markets.
    • Section 3.5 Product origin
  • Regulatory Authority: Local health departments may regulate fresh specialty mushrooms and specialty mushroom products at farmers markets, as provided under Section 3.3 and 3.5 of the Food Handling Regulation Enforcement Act (410ILCS 625).


To In-state food establishment

As defined in 77 Ill. Adm. Code 750.100, i.e. restaurants, grocery stores, etc.

  • Regulation: Not applicable. IDPH/IDOA have not adopted the FSMA Produce Safety Rule for in state sales.
  • Regulatory Authority: IDPH. Food establishments are regulated and inspected by LHD.
  • Regulation: Currently, specialty mushrooms are NOT on the list of “rarely consumed raw” produce under the regulation of the Food Safety Modernization Act Produce Safety Rule; therefore are considered COVERED produce under current FSMA-PSR guidelines.
  • Regulatory Authority: FDA. IDPH may conduct GMP inspections of Illinois mushroom processing facilities under contract with FDA.

Questions and Answers

Since mushrooms are not on the “rarely consumed raw” list of produce, does this mean that specialty mushroom species (like shiitake, lion’s mane, oyster, and others) can be eaten raw?

While it is the case that mushrooms are on the “rarely consumed raw” list, University of Illinois Extension does NOT recommend the consumption of any specialty/gourmet mushroom species in a raw state. Always cook specialty mushrooms thoroughly before consumption.

What does “mushrooms are COVERED” mean for mushroom growers?

It means that specialty mushrooms are covered by the Food Safety Modernization Act (FSMA) Produce Safety Rule (PSR), and thus subject to recently updated federal food safety regulations.

Consider reading this helpful flowchart resource from University of Minnesota Extension to see whether or not your mushroom farm is “qualified exempt” from the Produce Safety Rule

Note: the majority of farms are qualified exempt for various reasons, but that doesn’t mean that your farm doesn’t need a food safety plan; it most certainly does! 

I’m qualified exempt according to this flow chart. What do I do now?”

Follow the flow chart. Follow all FSMA PSR regulations carefully, and contact your local Ag service provider to help you confirm your understanding of this complex document

Even if qualified exempt, the rule states that at least one person on your farm must complete food safety training class equivalent to the Produce Safety Rule standardized curriculum recognized by the FDA.

In addition, you must:

  • Create a food safety management plan for your mushroom farm that will help to prevent/lower the possibility of a foodborne illness outbreak on your farm.
  • Keep it on file and have it available.
  • Be able to demonstrate that you are following it.

Even if your farm is qualified exempt, an inspector could come to your farm and at any time ask you for your produce safety plan and the certificate of a member of your farm indicating completion of a recognized PSR training class.

Reach out to your local Extension educator to help you identify your farm’s next steps in the Produce Safety Rule requirements.


The Produce Safety Alliance, a national group based in Cornell University in New York, has a training that, at this time, is the only approved training one can take to comply with the Produce Safety Rule

The Land Connection, a non-profit organization serving small farmers of central Illinois based in Champaign, has a FSMA PSR training page to notify farmers of upcoming training opportunities.