Most full-service trucks need a licensed CPF. A narrow exemption exists for units that are fully self-contained — enough onboard refrigeration, water, and waste capacity to operate without restocking from a fixed facility. It's evaluated on inspection day using DSHS's CPF Exemption Checklist. Every item has to pass — not most of them.
One of the most common questions from Texas food truck operators navigating HB 2844: "Do I really need a commissary?" For most full-service trucks, yes. But there's an exemption, and understanding exactly what it requires is the difference between qualifying and finding out you don't on inspection day.
What the Commissary Requirement Actually Is
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 equipment.
A CPF must be a licensed Texas food establishment. Your garage is not a CPF. Your house is not a CPF — even sufficiently equipped ones don't qualify, licensed or not.
What Actually Counts as a CPF — Real Examples
Confirmed directly with DSHS: a CPF doesn't have to be a dedicated commissary building. It just has to be a licensed food establishment willing to authorize your use of it. Real examples that qualify:
The common thread: it has to be a currently licensed Texas food establishment, and the owner has to give you written authorization plus a copy of their most recent health inspection report. That paperwork stays on your vehicle at all times.
The CPF Exemption — What It Actually Requires
If your 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.
Sufficient Cooling and Heating
Your vehicle must independently maintain all TCS foods at required temperatures without relying on any external facility at any time.
Sufficient Food Storage
All food must be stored on the vehicle in a way that prevents contamination and allows safe storage when you're not operating.
Adequate Warewashing Capacity
Your three-compartment sink must be large enough to fully submerge your largest utensil for a complete wash, rinse, and sanitize cycle.
Approved Water Source
Your potable water must come from a government-approved source — city supply, approved well, or commercial water delivery. Not a private, uncertified well.
Proper Waste Disposal
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 doesn't qualify.
Equipment and Utensil Storage
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.
Who Actually Qualifies
In practice, the exemption is most achievable for operators who've invested in larger, fully-equipped trucks with significant on-board storage and self-contained water systems. If your truck has a fresh water tank of at least 30 gallons from an approved source, a wastewater tank at least 15% larger than the fresh water tank, adequate refrigeration without external power, a three-compartment sink large enough to submerge your largest pan, and a documented wastewater disposal plan — you may qualify. The inspector verifies all of it on inspection day.
Who Probably Does Not Qualify
Most taco trucks, BBQ trailers, and small food trucks with compact kitchens won't qualify. Common disqualifiers: compact sinks that can't submerge a full-size hotel pan, small fresh water tanks that need daily refilling from a fixed source, no documented approved wastewater disposal location, and refrigeration that depends on shore power to hold temperature overnight.
Don't assume you qualify without a proper assessment — but the cost of finding out you're wrong is lower than this page used to say. Per DSHS guidance confirmed directly by phone, there is no additional fee for a routine re-inspection after normal corrections — DSHS reschedules and works with you through it. If you show up claiming an exemption you don't actually meet, you lose operating time while you arrange a CPF, but you are not charged a new inspection fee for that routine follow-up. A new fee applies only if you're already licensed and a complaint inspection is triggered later, or at your regular annual re-inspection.
What to Do If You Don't Qualify
If your truck doesn't meet the exemption criteria, you need a licensed CPF arrangement. In most Texas cities this means renting space at a shared commercial kitchen, partnering with a licensed restaurant, church, brewery, or coffee shop that has a permitted kitchen, or using a licensed food production facility. Once you have an 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.
Common Questions
Does my house or garage qualify as a CPF if it's clean and well-equipped?
No. A private residence never qualifies as a CPF, regardless of how it's equipped. DSHS guidelines explicitly exclude private homes and living quarters as a servicing area or approved water source.
What happens if I fail inspection because I claimed an exemption I don't meet?
You'll need to arrange a CPF and reschedule. Per DSHS's own guidance, that routine re-inspection doesn't carry an additional fee — it costs you time, not money, provided it isn't a complaint-triggered or annual re-inspection.
Can a friend's restaurant be my CPF?
Yes, if it's a currently licensed food establishment and the owner provides written authorization and a copy of their most recent inspection report.
Last verified: July 30, 2026. Re-inspection fee guidance updated to reflect a direct phone confirmation with DSHS (July 23, 2026), correcting a prior figure on this page. Commissary examples added from the same source.
Sources: 25 TAC 226; DSHS Mobile Food Vendor Guide; direct DSHS phone confirmation, July 23, 2026.
Updated by: Texas Food Truck Permits Editorial Team