Short answer: yes, in nearly every state and county. A commissary kitchen (sometimes called a commercial kitchen or central preparation facility) is a permitted commercial-grade kitchen where you do food prep, dishwashing, water tank fills, and waste tank dumps that the truck cannot legally do at the operating site. Three states have meaningful exceptions. The rest do not.
Why the requirement exists
The FDA Food Code (the model regulation that nearly every state’s health code is based on) treats a mobile food unit as an extension of a fixed commercial facility, not a self-contained operation. The rationale is that water, refrigeration, dishwashing, dry storage, and trash handling at a commercial scale need to happen somewhere with utilities and inspection oversight. A truck has limited tankage and refrigeration. Without a permanent base of operations, food safety and waste handling cannot be inspected the same way.
So the requirement is structural to how mobile food permitting works in the United States. The commissary requirement is what lets the health department issue you a mobile food permit at all.
What a commissary actually has to provide
State by state the rules vary, but the typical list:
- A 3-compartment sink for warewashing
- A handwashing sink, separate
- A potable water connection for filling the truck’s fresh water tank
- A permitted location for dumping the truck’s grey water tank
- Refrigerated and dry storage for inventory
- Permitted commercial cooking equipment, if you are doing prep that the truck cannot accommodate
- A grease trap and proper waste handling
The kitchen has to be permitted by the health department in the same jurisdiction where the truck operates. A home kitchen (with a few state exceptions) does not qualify.
How operators usually solve commissary
Three approaches:
1. Rent space at a shared commissary. Most cities have at least one shared commissary that rents kitchen time and parking to mobile food operators. Rates vary widely. Expect $400 to $1,200 per month for parking plus access. Some include a few hours of kitchen time per week, some charge by the hour ($25 to $45 per hour).
2. Partner with an existing restaurant. A restaurant with a slow morning shift can offer commissary use for $300 to $600 per month plus a written agreement. The health department will inspect this arrangement once the agreement is on file.
3. Build your own. If you have multiple trucks or a commissary catering operation, building your own central kitchen is often the better long-term play. Plan on $30,000 to $80,000 to convert a leased commercial space into a permitted commissary, or $150,000+ to build from scratch. Most operators do not need this until they are running three or more trucks.
State-by-state exceptions worth knowing
California. Cal Code (the California Retail Food Code) requires commissary use for any “Mobile Food Facility” that prepares unpackaged food. The exception: Microenterprise Home Kitchen Operations (MEHKO) under California’s AB-626, which allows certain home-kitchen operations to skip commissary requirements in counties that have opted in. Riverside, Alameda, Solano, Imperial, Lake, and Santa Barbara counties have adopted MEHKO. Los Angeles, San Diego, Orange, and many others have not. MEHKO is for home cooks selling small volumes, not for food trucks. Food trucks in California still need a commissary.
Wyoming. Under the Wyoming Food Freedom Act, certain producer-direct sales of homemade food can skip commercial kitchen requirements. The Food Freedom Act does not apply to mobile food vendors operating in commerce at retail. Wyoming food trucks still need a commercial commissary connection.
Oregon and Washington. Both states allow trucks classified as “Class I” (limited prep, mostly assembly of pre-packaged ingredients) to operate without a traditional commissary, as long as the truck has on-board capacity for everything the truck does. This is rare and usually applies to ice cream, packaged snack, or pre-portioned coffee operations only.
Outside those exceptions, every state requires commissary.
Can you use a home kitchen as a commissary?
In nearly every state, no. A home kitchen is not licensed for commercial food preparation under FDA Food Code section 6-202.111. The exceptions are state cottage food laws (which cover low-risk products like baked goods, jams, and dry mixes for direct retail sale) and the California MEHKO exception above. Neither covers a typical food truck operation.
How the health department checks
When you apply for a mobile food permit, the application asks for your commissary location and includes a Commissary Agreement form signed by the commissary operator. The health department inspects the commissary independently and inspects the truck. Both have to be in compliance for your mobile permit to issue. They will check that you actually go to the commissary by reviewing your daily logs, and in some jurisdictions by spot-checking.
What happens if you skip commissary
Operating without a valid commissary agreement is grounds for permit suspension on the spot. In California, Texas, and most states, an inspector can order the truck to cease operating until commissary is documented. Fines run $250 to $2,500 depending on the state. Repeat violations can mean permit revocation.
How to find a commissary in your city
Three places to look:
- The Food Corridor (thefoodcorridor.com) lists shared commercial kitchens by city. Most U.S. metros have at least one listing.
- Your county health department often maintains a list of permitted shared commissaries.
- Local Facebook groups for food truck operators in your city. Other operators will tell you who is reasonable, who has issues, and who has parking.
What about for trailer operators?
Same rule. A food trailer is a mobile food unit under the same regulations as a truck. Trailer operators sometimes assume they can park at home and skip commissary because they are not driving anywhere overnight. The regulation does not care about that. The commissary requirement is about where prep, dishwashing, and tank servicing happen, and that has to be a permitted commercial facility.
How we factor commissary into a build
When a customer is sizing a build, we ask whether they have a commissary lined up yet. If they do, we know the truck will be filling tanks at a fixed location and we can spec smaller fresh and grey tanks (30 gal fresh, 40 gal grey is typical). If they do not have one yet, we recommend they secure commissary before the build is delivered. The mobile permit cannot issue without it, and the truck can be ready and sitting in the driveway with no permission to operate.
For larger builds catering events away from base, we sometimes spec 60 gal fresh and 80 gal grey to extend operating range between commissary visits. This depends on menu and service style.
Need help thinking through your commissary plan? Get in touch. We have built food trucks for operators across Colorado, Wyoming, Montana, Nebraska, Arizona, and California, and we know the commissary landscape in most of those markets.
Related: complete guide to starting a food truck business.
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