Commissary Compliance · Texas HB 2844
Most operators don't know what's required, don't file it correctly, or don't realize they might qualify for an exemption that saves $300–600/month. Here's everything you need to know before you submit.
Under HB 2844 and 25 TAC §226, every Texas food truck operator must demonstrate one of two things to DSHS: either a valid commissary authorization from a licensed Central Preparation Facility, or an approved CPF exemption under §226.6. Without one or the other, your application is rejected on submission — automatically, no review, no exceptions.
This is the most common reason Texas food truck applications fail. It's also one of the most preventable. The issue isn't that the requirement is unclear — it's that operators either don't know what documentation is required, file the exemption incorrectly, or submit without any commissary documentation at all assuming it won't be checked.
It is always checked. It is one of the first things DSHS reviewers look at.
DSHS requires either a commissary authorization letter OR an approved CPF Exemption Checklist before your application can be processed. Submitting without this — or submitting an incomplete exemption filing — results in an automatic return. You restart the clock and re-pay applicable fees.
Commissary errors show up in four distinct ways, each with its own cost:
No commissary letter and no CPF exemption on file. Application returned as incomplete. You restart the process from submission — weeks of delay, application fees not refunded.
CPF Exemption Checklist filed but doesn't meet all 7 criteria. Rejected. You now need a commissary letter — which requires finding a facility, signing an agreement, and resubmitting.
Application approved but commissary documentation is incomplete or invalid at inspection time. Inspection fails. $400+ rescheduling fee. Weeks of additional delay before you can open.
Operators who don't know about the exemption pay $300–600/month in commissary rental for a facility they may never actually need. Over a year that's $3,600–7,200 in avoidable operating cost.
Every Texas food truck operator has exactly two compliant options for the commissary requirement under HB 2844:
You rent space from a licensed Central Preparation Facility (CPF) and attach their signed authorization letter to your DSHS application. The letter must be from a currently licensed facility, signed by the facility manager, and cover your specific truck. This option requires an ongoing rental arrangement at $300–600/month depending on your market.
If your truck is fully self-contained and meets all 7 DSHS criteria, you can file for a CPF exemption — eliminating the commissary requirement entirely. This option is available to most operators with a well-equipped truck. The exemption must be filed correctly before your main application is submitted.
Most operators who qualify for the exemption don't know it exists. The ones who do know often file it incorrectly. A correct filing — assessed against all 7 criteria and submitted with proper documentation — is what makes the exemption stick.
Your truck must meet every one of these criteria to qualify:
Sufficient onboard potable water for a full service period — cooking, cleaning, and handwashing. Assessed against your menu and service volume.
Wastewater tank must hold at least 15% more than your freshwater tank. Specific ratio required — one of the most common exemption rejection points.
All food stored onboard in labeled, temperature-controlled compartments. No external cold storage dependency between service periods.
All equipment needed to cook and hold food at proper temperatures onboard. Must meet TFER requirements and be functional at inspection.
Properly installed three-compartment sink (wash, rinse, sanitize) with drain boards. Self-contained inside the truck — not a hookup to an external facility.
Separate from the three-compartment sink. Stocked with soap and paper towels at all times. Non-negotiable at every inspection.
Your truck completes an entire service period — startup to breakdown — without depending on any fixed facility for water, food, storage, or cleaning.
When operators go through the Permit Readiness Review, they have two choices for commissary handling: assess and file the exemption themselves, or let us handle it as part of the service.
Most operators keep commissary support enabled — and here's why that's the right call:
"My truck qualified for the commissary exemption and I had no idea it was even an option. That's $450 a month I'm not paying anymore. It paid for itself in the first week."
— Carlos M., Burger Truck · Houston, TX
We assess commissary exemption eligibility in every $99 Permit Readiness Review. If you qualify, the $149 filing add-on handles the full DSHS CPF Exemption Checklist and variance request. Most operators keep it included — because the savings pay for it immediately.
Read the full commissary breakdown in the Commissary Exemption Guide or the complete Texas Commissary Requirements page. Every question about the exemption is answered in our main FAQ →