⚠ HB 2844 IS NOW IN EFFECT — ALL TEXAS MOBILE FOOD VENDORS MUST HOLD A DSHS LICENSE TO OPERATE
CPF / COMMISSARY REQUIREMENTS · HB 2844 · DSHS

Does Your Texas Food Truck
Need a Commissary?

The CPF requirement is one of the most misunderstood parts of Texas food truck licensing — and one of the most common reasons DSHS applications get delayed or returned. Here's exactly what it means, who needs one, and what documentation the state requires.

Short answer: Most Type II and Type III food trucks in Texas need a Central Preparation Facility (CPF). Some operations qualify for an exemption — but the exemption has specific requirements that must all be met simultaneously. Don't assume either way without confirming your specific situation.

What Is a CPF / Commissary?

A Central Preparation Facility (CPF) — commonly called a commissary — is a licensed, fixed food establishment that serves as the operational base for your mobile food unit. It's where your truck reports for supplies, cleaning, and servicing operations.

Under Texas law, the CPF must be an approved retail food establishment — meaning it holds its own food establishment permit and has passed its own health inspection. A private residence cannot be used as a CPF.

Specifically, your CPF is where you:

Who Needs a CPF Under HB 2844?

The default rule is that all mobile food units operating in Texas must operate from a CPF. Whether you need one in practice depends on your MFV type and whether you qualify for the exemption.

MFV TypeOperation TypeCPF Requirement
Type I Pre-packaged items only — no food preparation on the truck CLEARER PATH TO EXEMPTION

Type I operators selling only pre-packaged foods or non-TCS beverages have the most straightforward path to qualifying for the CPF exemption under the state rules.
Type II Limited preparation — reheating, assembling, serving EXEMPTION POSSIBLE

Could qualify if the truck can document approved water and waste sources and equipment is sufficient — but the documentation requirements are strict.
Type III Full cooking from scratch CPF MOST LIKELY REQUIRED

The grey water volume, cooking waste, and grease from complex preparation makes the full exemption difficult in practice for most Type III operations.
The most common mistake: Type II and III operators assuming they don't need a CPF without confirming it — and discovering the gap at their DSHS inspection. A missing CPF authorization letter is one of the top reasons applications get returned and inspections fail.

What Documents Does DSHS Require for Your CPF?

If you need a CPF, you must provide two documents — both must be physically on your truck during the inspection:

  1. Signed authorization letter from the CPF owner or manager, confirming your truck is authorized to operate from that location. If the CPF is not owned by you, this letter must be notarized.
  2. Most recent health inspection report from the CPF, showing the facility is currently permitted and in good standing.
Don't leave these at home. Having the commissary relationship but not having the physical documents on the vehicle is treated the same as not having a commissary at all during inspection. This catches operators off guard constantly.

CPF / Commissary Authorization Review — We Help You Get It Right

Included in $99 Review

Getting your commissary documentation wrong is one of the most common reasons DSHS applications get returned. We confirm exactly what you need, what form the authorization letter must take, whether your CPF qualifies, and whether you might be eligible for the exemption — before your application goes in.

  • Confirm whether you need a CPF for your specific truck type and county
  • Verify whether you qualify for the CPF exemption — and what documentation you'd need
  • Review the authorization letter format and ensure it meets DSHS requirements
  • Identify if your current CPF arrangement is compliant or needs to be updated
  • Confirm both required documents (letter + inspection report) are in order
GET MY CPF SITUATION CONFIRMED — $99 → OR CALL / TEXT (956) 592-2896 WITH QUESTIONS

The CPF Exemption — What It Actually Takes to Qualify

Under HB 2844 rules, some operators may qualify to operate without a CPF — but all of the following conditions must be met simultaneously:

Important nuance: Even if you qualify for the CPF exemption, you still need to dispose of grey water at an approved facility. In practice, this often means using a commissary-type facility for waste disposal — just without a formal agreement or authorization letter. Whether that configuration meets the exemption requirement in your county needs to be confirmed for your specific situation.

Finding a CPF in Texas

Most commercial kitchen rental facilities, established commissaries, and licensed restaurants in Texas can serve as your CPF. In major markets like Houston, Dallas, San Antonio, and Austin, there are dedicated commissary kitchen networks that specifically work with food truck operators. In smaller markets like the RGV, options are more limited — confirming your CPF status early matters more in those markets.

What you're looking for is a facility that:

City-Specific CPF Notes

Houston: All mobile food units must operate from a licensed CPF. A notarized commissary agreement must be submitted with your permit application.

Dallas: Requires documented daily commissary use, commissary approval, and updated commissary documents at renewal.

Austin: CPF and restroom access paperwork required as part of the permitting process through Austin Public Health before DSHS transition.

San Antonio / Bexar County: CPF requirements follow DSHS state standards — confirm with your county for any additional local requirements.

RGV / Brownsville / McAllen / Laredo: CPF requirements follow state DSHS standards. Commissary options may be more limited in border markets — confirming early is especially important.

Not sure if your CPF situation is compliant — or whether you even need one?

GET MY CPF CONFIRMED — $99 →

Frequently Asked CPF Questions

Can I use a restaurant I have a relationship with as my CPF?

Yes — if the restaurant holds a current food establishment permit and is willing to provide a signed authorization letter, it can serve as your CPF. The authorization letter must confirm they allow your truck to use the facility for servicing operations, and you need their most recent inspection report.

Does my CPF need to be in the same county I operate in?

Not necessarily under the statewide DSHS license — but your CPF must be a licensed food establishment, and you need to be able to reasonably service the truck from that location. Confirm the specifics of your arrangement with your compliance review.

How often do I need to go to the commissary?

The state rule requires mobile food units to report to the CPF for supplies and cleaning and servicing operations. The frequency isn't rigidly defined as a daily count in all cases, but the expectation is regular use — and some local jurisdictions (like Dallas) specifically require documented daily commissary use.

What if my CPF closes or loses its permit?

Your CPF arrangement is part of your DSHS license. If your CPF loses its permit or closes, you need to secure a new CPF and update your documentation promptly. Operating without a valid CPF arrangement when one is required puts your license at risk.