What kind of property does a food-truck 'commissary' need? Food Sanitation Act licensing, water supply and drainage, and zoning

The key point: A food truck's "commissary (prep base)" generally needs a separately licensed facility, distinct from the vehicle. A vehicle can carry only limited water, and health-centre standards restrict the cooking that can be done on board by the capacity of the supply and drainage tanks, so preliminary processing is basically done in a licensed facility. The keys to choosing a property are three: whether the water supply, drainage and handwashing can meet the facility standards, whether the work area can be separated from living quarters and other uses, and whether zoning and the lease permit that business. Judging the licence category and consulting/applying to the health centre go to an administrative scrivener and the health centre, and the final judgment on zoning or change of use to the designated administrative agency and an architect; the lease and use check are ours.

Starting a mobile food-truck business, or already selling from a vehicle and wanting to rent a prep base—when you do, "where do I do the prep" and "what property will the health centre license" become the first hurdle. Often the vehicle alone cannot complete the work, and unless you grasp the facility standards and the use before choosing a property, you risk a situation where the licence will not be granted after you have signed.

This article organises what can be confirmed before choosing a property that will serve as a food truck's prep base, from the viewpoints of equipment, licensing and use. Which licence category applies, and consultation with the health centre, are the field of the administrative scrivener and the health centre; this article is general information only.

Yotsuba Real Estate Co., Ltd. (四葉不動産株式会社), based in Bunkyo, Tokyo, provides brokerage of leases for business-use property and advance checks of zoning and change of use. For a food truck's prep base, you can consult us from before the property is decided.

Why does a food truck need a "commissary" at all?

A food truck (mobile food sales) operates under the licence of Article 55(1) of the Food Sanitation Act (restaurant business, etc.) for the vehicle itself. But the amount of water a vehicle can carry is limited, and health-centre facility standards generally divide what cooking can be done on board by the capacity of the supply and drainage tanks.

The guidance of health centres such as the Higashimatsuyama Health Centre (Saitama) and the Hitachi Health Centre (Ibaraki) explains the tank-capacity guideline roughly as follows (capacities and conditions differ by locality, so it is safest to confirm with the health centre for the intended site, showing a drawing).

Supply/drainage tank capacity (guideline)	Cooking assumed on board
About 40L or more	Simple cooking only, or a single item; disposable containers assumed
About 80L or more	Simple cooking of up to about two steps, multiple items; disposable containers assumed
About 200L or more	Multi-step cooking, or a business using ordinary tableware

For this reason, "prep"—preliminary processing, cutting, marinating, manufacturing—is hard to complete on board, and the Hitachi Health Centre (Ibaraki) advises that "where prep is needed, it must be done in a facility that has obtained a food business licence." This is why a prep-base (commissary) property is needed separately from the vehicle.

What equipment does a commissary property require? (water supply, drainage, handwashing, zoning of areas)

A commissary is itself a "facility" that obtains a business licence. The facility standards are set, under Article 54 of the Food Sanitation Act, by each prefecture etc. by ordinance, taking into account the standards set by Ministry of Health, Labour and Welfare order (the standards in the appended tables of the Food Sanitation Act Enforcement Regulations). With the 1 June 2021 enforcement of the 2018 amendment, the framework of these standards was levelled nationwide. At the property stage, the following points generally matter.

Item to check	Point to see in the property
Water supply / drainage	Whether the necessary supply and drainage can be installed; a system that can treat drainage properly
Handwashing	Whether a dedicated handwashing station (with disinfection) can be set in the work area
Work area	Whether the preliminary-processing / cooking area can be clearly separated from living quarters and other uses
Floor, walls, ceiling	Whether they can be finished in easy-to-clean, impermeable materials
Ventilation / lighting	Whether sufficient ventilation and lighting can be secured in the workroom
Storage	Whether storage of ingredients and utensils, and refrigeration/freezing, can be placed

Specific figures and details vary by ordinance and health-centre practice. Rather than deciding the details on the property side, it is safest to show a drawing to the health centre and consult in advance. The thinking when checking exhaust and water supply/drainage in a skeleton restaurant property is also useful in Exhaust, grease trap and fire-prevention points when opening a restaurant in a skeleton property (Japanese).

What licence is needed, and who applies?

The business categories requiring a licence are set by Article 35 of the Food Sanitation Act Enforcement Order, under Article 55(1) of the Act. With the 1 June 2021 enforcement of the amendment, the licence categories were reorganised from the former 34 to 32. Which category a commissary falls into changes with the food made and the process.

Likely category	What case (example)
Restaurant business	Prepping food in general that is cooked and served
Prepared-food (sōzai) manufacturing	Manufacturing side dishes such as simmered, grilled or fried food in bulk
Notification category	Some businesses not falling under a licence category (notification under Article 57)

Which category applies, and whether to obtain the vehicle's licence and the commissary's licence separately or handle them in the same facility, is an individual judgment. Judging this category and preparing the licence application / health-centre consultation are the field of the administrative scrivener and the health centre. We do not act as agent for the licence application. We handle the lease and the use check, and connect you to an administrative scrivener and the health centre for the category and application.

What should you check on zoning and the lease?

A commissary is a fixed facility, so unlike the vehicle it is subject to zoning restrictions. Article 48 and appended table 2 of the Building Standards Act set the uses of buildings that may be built in each zone. If you prep as a restaurant business it is treated as a "shop / restaurant"; if you manufacture in bulk as a prepared-food manufacturing business it approaches "factory" treatment, and depending on the scale of manufacture may be restricted in residential zones.

Item to check	Point to see
Zoning	Whether the intended business use is permitted in that zone
Change of use	For an existing building, whether a confirmation application is needed (by scale)
Lease	Whether "manufacturing/cooking of food" can be included in the purpose of use; the scope of restoration
Neighbourhood	Whether odour, drainage or loading/unloading will clash with neighbours

Have a question about your situation?

Tell us about your property search or plans to sell.

Chat on LINEContact us

Conformity with zoning and whether a change-of-use confirmation application is needed are ultimately the judgment of the designated administrative agency and an architect. We check in advance the property's zoning and the lease's purpose of use, and connect you to an architect where a confirmation application is involved.

Can you use your home or an existing restaurant as a commissary?

We often hear "can I prep in my home kitchen," but a commissary needs to be a licensed facility, and unless living quarters and the work area are separated it is hard to meet the standards. Even when using part of a home, the dividing line is whether the work area, handwashing and water supply/drainage can be set to standard and separated from the living space.

To use an existing restaurant as a prep base, you need to confirm with the health centre whether that restaurant's licence category covers prep as well, and—if used as a separate business outside opening hours—how to organise the licence holder and category. In either case, feasibility depends on the individual facility and operation, and no unqualified person may assert "it can be used." At the viewing stage, we check the zoning and lease conditions and connect you to an administrative scrivener and the health centre for the licence feasibility.

For the viewpoint of using and investing in business-use property see consultation on business-property use (Japanese), and for finding a base to open a business generally see finding a base / office to open (Japanese).

How can you consult Yotsuba Real Estate about finding a prep-base property?

Those starting a food-truck business, and those already operating a vehicle who want to rent a prep base, can contact Yotsuba Real Estate directly to request a property search and lease brokerage. Please first tell us:

• The kind of food made and the assumed prep process (preliminary processing, heating, manufacturing)
• The desired area and the assumed size and budget
• Whether the vehicle's business licence is already obtained, or is to come
• Whether there is a premise of using an existing restaurant or your home

Yotsuba Real Estate checks in advance the property's zoning and the lease's purpose of use, and tells you what can be confirmed before the property is decided. Judging the licence category and consulting/applying to the health centre go to an administrative scrivener and the health centre, and the change-of-use confirmation application to an architect—each independent businesses that you contract with separately. We do not receive referral fees.

Consult Yotsuba Real Estate about a food-truck prep-base property—initial consultation is free

In your message, write "looking for a food-truck prep base" and include the food made and the desired area. Without presuming whether a licence will be granted, we begin with the property use check and in what order to proceed to the health-centre consultation and the contract.

Frequently asked questions

Q. If the vehicle is licensed, do I not need a licence for the commissary?
A. The vehicle and the commissary are generally treated as separate facilities, and many health centres advise that where prep is needed it must be done in a licensed facility (Hitachi Health Centre, Ibaraki, and others). How much can be completed on board varies with supply/drainage tank capacity, so confirm with the health centre for the intended site, showing a drawing.

Q. What licence category will the commissary be?
A. Depending on the food made and the process, it divides into restaurant business, prepared-food manufacturing and so on. The licence categories are set by Article 55(1) of the Food Sanitation Act and Article 35 of its Enforcement Order, reorganised from 34 to 32 with the 1 June 2021 amendment. Judging the category and the application is the field of the administrative scrivener and the health centre, so confirm the specific category there.

Q. Can I make my home kitchen a commissary?
A. A commissary needs to be a licensed facility, and the dividing line is whether you can separate living quarters from the work area and set handwashing and water supply/drainage to standard. In many cases a dedicated area separated from the living space is required. Feasibility depends on the individual facility and health-centre practice, so it cannot be asserted.

Q. I'd be in trouble if the licence isn't granted after I rent. What order should I follow?
A. Before deciding on a property, it is safest to confirm that the intended business is permitted under zoning and that the layout can meet the facility standards, and to consult the health centre in advance before signing. We handle the property use check and the lease, and connect you to an administrative scrivener and the health centre for the category and consultation.

Sources

The following public materials are starting points for investigation. Laws are amended, so check the current text, enforcement date and latest amendment on e-Gov Law Search. Health-centre standards differ by locality. All were consulted on 22 October 2026. They do not establish whether a particular property or business conforms to a licence. The sources below are in Japanese.

• e-Gov Law Search: Food Sanitation Act, art. 54 (facility standards), art. 55(1) (business licence), art. 57 (business notification): the licence and notification system amended by Act No. 46 of 2018, in force 1 June 2021
• e-Gov Law Search: Food Sanitation Act Enforcement Order, art. 35 (business categories requiring a licence): reorganised from 34 to 32 with the amendment in force 1 June 2021
• e-Gov Law Search: Building Standards Act, art. 48 and appended table 2 (use restrictions on buildings within zones)
• Hitachi Health Centre, Ibaraki: On mobile food business (food trucks): that prep must be done in a licensed facility, and the handling categories by supply/drainage tank capacity (consulted 22 October 2026)
• Higashimatsuyama Health Centre, Saitama: Guide to food trucks (automobile food business): supply/drainage tank capacity (about 40L / 80L / 200L) and the division of handling (consulted 22 October 2026)

This article provides general information. Individual judgments require review by the health centre and the appropriately qualified professional. It does not guarantee that a particular property or business conforms to a business licence.

Joji Uramatsu (浦松 丈二), Representative Director and licensed real estate transaction specialist, Yotsuba Real Estate Co., Ltd. (四葉不動産株式会社). We provide brokerage of leases for business-use property and use checks. Author profile

Updated: 22 October 2026