Colorado permits · updated August 2026
Colorado food trailer permits, explained accurately
Most of what's written about HB25-1295 overstates it. Fire permits really did become reciprocal statewide. Food licences did not — except between Denver and the state. Here's the whole picture, with the statute linked.
Who issues your licence
Colorado's retail food rule is 6 CCR 1010-2, adopted by the State Board of Health in January 2024 and effective 16 March 2024. It is short — seven sections — because §2.6 incorporates the FDA Food Code 2022 by reference, excluding four provisions (patio dogs, preoperational inspections, permit to operate, and inspection/correction of violations).
That structure is genuinely useful: it means the physical specification for your trailer comes from one document you can download and read, rather than from fifty separate city checklists the way it does in Texas.
Who licenses you is the messier half. CDPHE issues retail food licences directly in only nine counties:
- Clear Creek
- Dolores
- Gilpin
- Moffat
- Ouray
- Park
- Pitkin — except the City of Aspen, which runs its own programme
- Rio Blanco
- San Juan
Everywhere else — which includes every Front Range metro, so Denver, Colorado Springs, Aurora, Pueblo, Greeley, Fort Collins and Boulder — you apply to your county or district public health agency. Denver runs its own regime entirely.
The fees, which are statutory
This is unusual enough to be worth spelling out. Colorado retail food licence fees are set in state statute — CRS 25-4-1607, as rewritten by SB25-285 effective 1 January 2026 — and the statute expressly allows a county or district board of health to set fees lower than the listed figures, but not higher.
| Mobile food establishment | 2026 | 2027 | 2028 onward |
|---|---|---|---|
| Full service | $481 | $567 | $682 |
| Prepackaged only | $338 | $394 | $475 |
Separate local fees you should budget for: the City of Colorado Springs charges $110/year for its own mobile food vendor licence ($25 per additional unit, $55 late renewal). Front Range Fire Rescue, covering Windsor and Severance, charges $75 for a twelve-month mobile vendor fire permit. Denver charges a separate zoning permit. Fire permit fees vary by department.
Plan review — and the Denver trap
Mobile units require plan review in Colorado, and it is a real submittal. The common pattern is a $155 filing fee plus hourly review, capped at $580 (CDPHE) or $900 (Boulder, Mesa and Gunnison among others).
What CDPHE asks for: menu, facility floor plans, equipment specifications with manufacturer information, and mechanical diagrams for plumbing, electrical and ventilation.
Turnaround: CDPHE responds within 14 days. Boulder County publishes up to eight weeks, plus 14 business days for revisions. Plan around the slow case.
HB25-1295: what it does and doesn't do
House Bill 25-1295, "Food Truck Operations," was signed on 20 May 2025 and took effect 1 January 2026, creating Article 11.6 of Title 29, C.R.S. A great deal of what's written about it online overstates it. Here is the accurate version.
| Provision | What it actually means |
|---|---|
| Fire safety permit reciprocity — broad and statewide, and real | §29-11.6-103(1): a valid fire safety permit is valid in the jurisdiction of any other local government in Colorado, where it was issued by a local government that has adopted the current International Fire Code (or equivalent) and inspected by a certified fire inspector. This is the genuinely significant part of the bill. |
| Food licence reciprocity — Denver ↔ state health department only | §29-11.6-104(2)(a): an operator holding a valid, active Denver retail food licence is considered to hold a state health department licence — and a state licence holder can operate in Denver through Denver's reciprocal process. That is the whole bridge. A county or district health agency licence does not become portable to other Colorado counties. |
| 14-day advance notice | §§29-11.6-103(2)(a) and 29-11.6-104(1)(b)(i): notify each jurisdiction, with a copy of your licence, through reasonable electronic means, at least 14 days ahead. |
| Commissary is in the statutory definition | §29-11.6-102(6) defines a mobile food establishment as one operated from a movable vehicle, portable structure or watercraft, that can change location, and that "is intended to physically report to and operate from a commissary." |
| Local authority is expressly preserved | §29-11.6-105: nothing in the article prohibits a local government from adopting or enforcing its ordinances, resolutions, regulations, zoning codes, health codes or other codes. CDPHE's own reciprocity page adds that all mobile units remain subject to inspection and enforcement by the local jurisdiction. |
Fire inspection and the FMAC checklist
Colorado has no mandatory statewide fire code for general occupancies. The Division of Fire Prevention and Control adopted the 2021 International Fire Code, but its jurisdiction covers specific categories — limited gaming structures, waste tire facilities, state-licensed health facilities, public school buildings and fire suppression systems. Local governments adopt their own fire codes independently.
In practice, though, the state has converged. The Fire Marshals Association of Colorado publishes a standardised Mobile Food Vehicle pre-inspection checklist keyed to the 2024 IFC — in English and in Spanish — and since HB25-1295 it is effectively the vehicle for reciprocal fire permits. If you are building or buying a trailer for Colorado, that checklist is the document to build to.
| Requirement | Citation |
|---|---|
| Listed LP-gas alarm inside the vehicle, near the LP-gas components | IFC §319.8.5. This is the item out-of-state builds fail on most often. It costs almost nothing and it is pass/fail. |
| Maximum 200 lb aggregate propane | IFC §319.8.1. Denver Fire confirms the same figure. |
| Containers securely mounted and restrained; piping protected | IFC §§319.8.2 and 319.8.4. Plus the general compressed gas provisions: upright with the valve end up, relief devices discharging upward and unobstructed, vent piping designed to prevent moisture collection and freezing, protected from vehicle impact, secured against falling, CGA C-7 labelling visible. |
| Type I hood over grease-laden vapour, with automatic suppression | IFC §319.3 and §319.4.1 (via §904.13). Suppression inspected and tested every six months and after any activation. Denver has required this on grease- and smoke-producing equipment since May 2018. |
| Class K extinguisher sized to your fryers | IFC §319.4.2 / §906.4.2: one to four fryers requires a minimum 1.5-gallon Class K, plus one more per additional group of four. Solid fuel appliances under 5 cubic feet: one 2.5-gallon or two 1.5-gallon Class K units. |
| Appliance gas connectors to ANSI Z21.69 / CSA 6.16; appliances secured | IFC §319.5, with restraining devices so nothing shifts in transit. |
| Cooking oil: 120 gallons aggregate maximum | IFC §319.6. Tanks to §319.7 — metallic to UL 80/142; nonmetallic 200 gallons or less per tank, vented. |
| Hood cleaning intervals | IFC §319.10.1 / §607.3.3: high-volume, 24-hour, charbroil and wok operations every three months; solid fuel monthly; others every six months. |
| Annual LP-gas system inspection | IFC §319.10.3. CNG systems every three years. |
| Electrical | No extension cords as permanent wiring (§604.5), no multi-plug adapters (§604.4), no open junction boxes or spliced wiring (§604.6). Separately, Colorado adopts the 2023 National Electrical Code statewide, effective 1 August 2023, with municipalities permitted to be more stringent only. |
What the trailer must physically have
Because Colorado adopts the FDA Food Code 2022, the plumbing and facility specs are the Food Code's — with local sizing tests layered on at plan review.
| Requirement | Source |
|---|---|
| Wastewater tank 15% larger than the fresh water tank | Food Code §5-401.11(A). Every Colorado county plan review packet we read repeats it verbatim. |
| Fresh water tank — no statewide minimum, but real local tests | Denver: minimum 10 gallons or 3 gallons per hour of operation, whichever is greater, and enough to fill the three-compartment sink at least once every four hours. Mesa County: 5 gallons for pushcarts; for equipped units, sized to fill the three-comp every four hours, with handwashing at 3 gallons per sink per hour. A 12-hour Denver service day implies at least 36 gallons on the hourly test alone. |
| Handwashing sink | Denver: basin minimum 10 in × 10 in, hands-free, continuous flow under pressure, minimum 1 GPM, 100–120°F via combination faucet or mixing valve, used for no other purpose, with soap and individually dispensed paper towels. |
| Three-compartment sink | Food Code default across most of Colorado: compartments large enough to accommodate the largest piece of equipment or utensil used. Denver's published standard is more lenient — at least half the largest piece — but that leniency does not travel to other jurisdictions. Build to the stricter reading. Not permitted on unenclosed units. |
| Hot water | 100°F minimum at the handwashing sink (Food Code §5-202.12); 110°F minimum in the wash compartment of the three-compartment sink, without interruption. |
| Tank and inlet construction | Food Code §5-303.13: inlet 3/4 inch inner diameter or less, with a connection sized or typed so it can't be used for any other service. §5-301.11: materials safe, durable, corrosion-resistant, nonabsorbent. §5-302.11: enclosed inlet to outlet and sloped to drain completely. §5-304.14: tank, pump and hoses used for no other purpose. |
| Plumbing and fuel gas codes | Colorado adopts the 2021 International Plumbing Code and the 2021 International Fuel Gas Code statewide as minimum standards (3 CCR 720-1). The fuel gas adoption is why manufacturer high-altitude installation instructions are enforceable in Colorado rather than merely advisory. |
For what changes physically in a trailer built for Colorado rather than Texas — altitude orifices, freeze protection, brakes and awnings — see building a food trailer for Colorado.
Commissary, and the self-contained route
A commissary is the default in Colorado, and it is written into the statutory definition itself (§29-11.6-102(6)). Denver requires standard units to report to a commissary for servicing, restocking and maintenance each operating day. Elbert County requires a current commissary agreement. Pueblo County states plainly that most mobile units will not be fully self-contained and that it is likely vendors must use a commissary.
A self-contained exemption does exist, but it is local rather than statewide and it is conditional. Denver's version requires all of:
- a mop sink, a food prep sink and a three-compartment sink on board, plus adequate cooking and storage;
- a limited menu — described as a single category, for example burgers only or salads only;
- a written operation plan covering supply storage, maintenance and water servicing;
- department approval before fabrication;
- re-approval for any change after approval.
What we couldn't verify
We'd rather tell you what we don't know than pretend.
- Denver's current licence and fire permit fees. The figures circulating come from a trade association rather than a city page. Get them from Denver Excise & Licenses directly.
- El Paso, Jefferson, Adams, Arapahoe, Weld and Pueblo county mobile licence fees aren't published in fetchable schedules. Budget from the statutory figures and confirm by phone.
- Denver's current mobile unit guide edition. The richest published spec source we found is the 2022 edition. The 10-gallon and 10 in × 10 in figures come from it — confirm they're current with DDPHE.
- A "readily movable" or no-permanent-connections rule. We found none in the state rule or in county packets. Some jurisdictions likely enforce it through zoning instead.
- Any count of licensed mobile units in Colorado. None is published, and the HB25-1295 fiscal note explicitly declines to estimate. Any page quoting you a number is guessing.
Sources
- CDPHE — Retail Food Licensing (including the nine CDPHE-licensed counties)
- CDPHE — Mobile Food Unit Reciprocity
- 6 CCR 1010-2 — Colorado Retail Food Establishment Rules and Regulations
- HB25-1295 Food Truck Operations — bill page
- HB25-1295 — session law text
- CRS 25-4-1607 — retail food establishment licence fees
- SB25-285 enrolled bill (fee schedule)
- Fire Marshals Association of Colorado — Mobile Food Vehicle inspection checklist (EN + ES)
- Denver Fire — Mobile Food Vendors permitting process
- City of Colorado Springs — Mobile Food Vendor Licensing
- Pueblo Department of Public Health — mobile food licensing
- Colorado adopted plumbing and fuel gas codes (3 CCR 720-1)
- FDA Food Code Chapter 5 — water, plumbing and waste
Frequently asked
Do I need a separate licence for every Colorado county?
For food licensing, generally yes. HB25-1295 created reciprocity between a Denver retail food licence and a state health department licence, but it did not make county or district health agency licences portable across other Colorado counties. Fire safety permits, by contrast, did become reciprocal statewide from 1 January 2026.
How much does a Colorado mobile food licence cost in 2026?
Fees are set by state statute (CRS 25-4-1607 as amended by SB25-285). For 2026 the annual mobile food establishment licence is $481 for full service and $338 for prepackaged only, rising to $567/$394 in 2027 and $682/$475 from 2028. A county or district board of health may set fees lower than these figures but not higher. Plan review is separate — commonly a $155 filing fee plus hourly review capped at $580 or $900.
Who issues a food truck licence in Colorado — the state or the county?
CDPHE licenses retail food establishments directly in only nine counties: Clear Creek, Dolores, Gilpin, Moffat, Ouray, Park, Pitkin (except the City of Aspen), Rio Blanco and San Juan. Everywhere else, including all the Front Range metros, you apply to your county or district public health agency. Denver runs its own programme.
Do I need a commissary for a food truck in Colorado?
Usually. A commissary is written into the statutory definition of a mobile food establishment at CRS 29-11.6-102(6). Some jurisdictions allow a self-contained unit instead, but the conditions are strict — Denver's version requires a mop sink, a food prep sink and a three-compartment sink on board, a limited menu, a written operation plan, and department approval before fabrication.
What fails a Colorado food truck fire inspection most often?
For out-of-state builds, the missing listed LP-gas alarm required by IFC 319.8.5. It costs almost nothing and it is a pass/fail item on the statewide Fire Marshals Association of Colorado checklist. Other common items: propane over the 200 lb aggregate limit, unrestrained cylinders, expired suppression service, and extension cords used as permanent wiring.
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