HB 2844 has been law for weeks and already the pattern is clear. The same mistakes keep showing up — and most of them are costing operators real money. Here are the five we see most often, and exactly how to avoid them.
This is the most common and the most dangerous. Operators who have held city or county health permits for years assume those permits satisfy HB 2844. They don't.
Your Houston medallion, your Dallas permit, your Cameron County license — none of them are DSHS Mobile Food Vendor Licenses. They don't convert, transfer, or substitute. You need a separate DSHS license in addition to any local permits you hold.
The silver lining: holding a current local permit makes you a Category 1 applicant, which means you can keep operating while DSHS processes your application. But you have to apply, carry the receipt, and eventually pass the pre-licensing inspection. The local permit is a bridge, not a destination.
Your MFV type — Type I, II, or III — determines your fees, your equipment requirements, and your inspection standards. Applying under the wrong type is a compliance violation and can result in a failed inspection even if your truck is otherwise ready.
The most common misclassification: operators who do minimal prep assume they're Type I. If you're reheating anything, cold-holding TCS foods, or selling vacuum-sealed products, you're likely Type II. If you're cooking raw proteins or making food to order, you're Type III — regardless of how simple your menu is.
Type III carries the highest fees: 76 application + 00 pre-licensing inspection = ,376 before you get a license. Getting classified correctly from the start matters.
This is the inspection failure we see most often. Operators either don't have a Central Preparation Facility arranged, don't have the authorization letter from the CPF owner, or don't have the CPF's most recent health inspection report on their vehicle.
Any one of these missing: automatic failure. The re-inspection fee is 00 to 00. And your truck is grounded until you reschedule and pass.
A private residence cannot serve as a CPF. If you've been prepping at home and assuming that covers you, it doesn't. You either need a licensed CPF with documentation, or your vehicle needs to qualify for the CPF exemption — which has its own checklist evaluated during inspection.
If you have no current Texas health department license — your local permit expired, you never got one, or you're a new operator — you are a Category 2 applicant. Category 2 operators cannot legally operate until their DSHS pre-licensing inspection is complete and their license is issued.
We've talked to operators who didn't know this. They assumed there was a grace period or that submitting the application was enough. It isn't. Submitting the application and paying the fees does not authorize you to operate. Only a passed inspection and an issued license does.
We're not going to be subtle about this one.
A Type III operator who fails their pre-licensing inspection pays 00 to reschedule. Two failures: ,000. Plus the income lost while the truck is grounded. Plus the time spent correcting deficiencies.
The operators who skip a pre-inspection review to save 9 often end up spending 00 to ,500 learning the same information the hard way — after the inspection, with their truck parked and DSHS fees already paid.
Every item we flag in a pre-inspection review is something that would have cost significantly more to discover at inspection. The math is straightforward.
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