One of the most asked questions from Texas food truck operators navigating HB 2844: "Do I really need a commissary?" The short answer for most full-service trucks is yes. But there is an exemption — and understanding exactly what it requires is the difference between qualifying and failing your inspection because you assumed you did.
Under HB 2844 and 25 Texas Administrative Code 226, most Type II and Type III mobile food vendors must operate from a Central Preparation Facility — a licensed, fixed food establishment that serves as the base of operations for your vehicle. This is where you get fresh water, dispose of waste, store and prep food, and clean your equipment.
A CPF must be a licensed Texas food establishment. Your garage is not a CPF. Your house is not a CPF. A friend's restaurant might be, if they're licensed and provide written authorization.
If your food vending vehicle is sufficiently self-contained, DSHS may grant a CPF exemption. This isn't automatic — it's evaluated by an inspector during your pre-licensing inspection using the official CPF Exemption Checklist. Every item must pass.
Your vehicle must independently maintain all TCS foods at required temperatures without relying on any external facility at any time.
All food must be stored on the vehicle in a way that prevents contamination and allows safe storage when you're not operating.
Your three-compartment sink must be large enough to fully submerge your largest utensil for complete wash, rinse, and sanitize cycles.
Your potable water must come from a government-approved source — city supply, approved well, or commercial water delivery. Not a private uncertified well.
Sewage and liquid waste must be removed at an approved facility or by a licensed sewage transport vehicle. Dumping in a storm drain or alley does not qualify.
All food equipment, utensils, and single-service articles must be stored on the vehicle in a manner that prevents contamination consistent with Food Code Chapter 4.
In practice, the CPF exemption is most achievable for operators who have invested in larger, fully-equipped trucks with significant on-board storage and self-contained water systems. If your truck:
...you may qualify. The inspector will verify all of it on inspection day.
Most taco trucks, BBQ trailers, and small food trucks operating with compact kitchens will not qualify for the CPF exemption. Common disqualifiers:
If your truck doesn't meet the exemption criteria, you need a licensed CPF. In most Texas cities this means:
Once you have a CPF arrangement, you need a signed authorization letter from the owner and a copy of their most recent health inspection report — both on your vehicle at all times.
Our Pre-Inspection Review includes a CPF status assessment — we'll tell you if you qualify and exactly what you need either way. 9, results in 48 hours.
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