Food trucks and street food: obligations under Reg. (EC) 852/2004

Updated 2026-07-12 · Reviewed by: Redazione ce85204 — revisione editoriale assistita da AI (2026-07-12)

A food truck is a movable premises: Annex II Chapter III of Reg. (EC) 852/2004 applies, not Chapters I-II reserved for fixed premises. Both the vehicle and any base kitchen must be registered under Art. 6, and proportionate HACCP-based procedures remain due.

Food trucks, tuk-tuk vans, kiosks, market stalls and street-food pitches are movable or temporary premises. Whoever runs them is a food business operator (FBO) subject to Regulation (EC) No 852/2004, but under a specific structural regime: Annex II Chapter III applies, not Chapters I and II designed for fixed premises. This is the mistake consulting most often makes.

The common mistake: which chapters apply

Chapter III of Annex II sets requirements "for movable and/or temporary premises (such as marquees, market stalls, mobile sales vehicles)" Annex II, Chapter III, point 1 of Regulation (EC) No 852/2004: requirements calibrated to mobility (handwashing facilities, hot and/or cold potable water, washable food-contact surfaces, waste management, temperature control), many of which apply "where necessary" and "so far as is reasonably practicable" Annex II, Chapter III, point 2 of Regulation (EC) No 852/2004.

Chapters I and II — general requirements for premises and specific requirements in preparation rooms — instead concern fixed establishments: applying them as they stand to a food truck is a recurring error. The following do remain relevant:

• Chapter IV on means of transport, when the vehicle carries food between the base and the point of sale Annex II, Chapter IV, point 1 of Regulation (EC) No 852/2004;
• Chapter VIII on personal hygiene Annex II, Chapter VIII, point 1 of Regulation (EC) No 852/2004;
• Chapter IX on foodstuffs, with the cold chain Annex II, Chapter IX, point 5 of Regulation (EC) No 852/2004;
• Chapter XII on training Annex II, Chapter XII, point 1 of Regulation (EC) No 852/2004.

Vehicle and base kitchen: two registrations

Many street-food operations run with a base or support kitchen: fixed premises where sourcing, preliminary preparation, washing and storage take place, while cooking or assembly is completed on board. That kitchen is fixed premises and, as such, subject to Chapters I and II of Annex II. Both the mobile unit and the base kitchen must be registered under Article 6 Article 6(2) of Regulation (EC) No 852/2004; in Italy this is done through the health SCIA notification, often separately for the vehicle and the base.

HACCP in a food truck

The Article 5 obligation remains full Article 5(1) of Regulation (EC) No 852/2004, with proportionate procedures. If frying, grilling or hot holding takes place on board, the critical control points are identifiable as in restaurants; if the activity is limited to serving ready-to-eat products, the flexibility typical of bars applies. The analysis must consider the specific risks of mobility: water supply, waste management, temperature swings, confined spaces that increase the risk of cross-contamination. Training of food handlers follows regional rules (HACCP training in Italy).