Quick answer
Under Standard 3.2.2A, enforceable since 8 December 2023, food trucks, vans and stalls that handle unpackaged, potentially hazardous food must meet food safety management rules. Category one businesses, which make ready-to-eat potentially hazardous food, need a certified food safety supervisor, trained food handlers and records of key controls. Category two businesses need the supervisor and trained handlers.
Key points
- Standard 3.2.2A became enforceable on 8 December 2023.
- Category one (you cook or prepare ready-to-eat potentially hazardous food): supervisor, training and records.
- Category two (you serve it but didn't make it): supervisor and trained handlers.
- The food safety supervisor certificate must have been obtained within the past five years.
- In NSW, records must be kept for three months.
Food safety used to be one of those things many small operators learned on the job. Since December 2023, there’s a national standard that sets out exactly what food service businesses — including food trucks, coffee vans, market stalls and caterers — need to have in place. If you’re starting a mobile food business, planning to hire staff for event season or buying an existing truck, it’s worth understanding what Standard 3.2.2A asks of you.
What is Standard 3.2.2A?
Standard 3.2.2A is part of the Australia New Zealand Food Standards Code. Food Standards Australia New Zealand (FSANZ) calls it the food safety management tools standard. The NSW Food Authority confirms it became enforceable on 8 December 2023.
FSANZ says it applies to food service, catering and retail businesses that handle unpackaged, potentially hazardous food that’s ready to eat. Its list of examples includes caterers, restaurants, cafés, takeaway shops and food vans.
“Potentially hazardous food” is food that needs temperature control to stay safe — think cooked meat, dairy, cooked rice and pasta, prepared salads, egg dishes and sauces. If your menu includes these, the standard very likely applies to you.
Which category is my food truck?
The standard sorts businesses into two categories, based on what you do with the food.
| Category one | Category two | |
|---|---|---|
| What you do | Process unpackaged potentially hazardous food into food that’s ready-to-eat and potentially hazardous, and serve it | Serve unpackaged potentially hazardous ready-to-eat food you didn’t make, with limited handling |
| Examples | A burger truck, dumpling van, taco trailer, caterer | A stall reheating or hot-holding bought-in pies; slicing and serving pre-made products |
| Food safety supervisor | Required | Required |
| Food handler training | Required | Required |
| Records / substantiation | Required | Not required |
The NSW Food Authority gives a useful mobile example of a category one business: “A mobile food vendor that cooks and cools a fried rice dish, containing cooked rice, vegetables and egg at their base kitchen.” Most food trucks that cook on board or prepare food in a base kitchen will be category one.
Category two businesses, according to the NSW Food Authority, serve unpackaged, potentially hazardous, ready-to-eat food they have not made themselves, and only slice, weigh, repack, reheat or hot-hold it without further processing.
Tool one: the food safety supervisor
Every category one and category two business must appoint a food safety supervisor. The rules include:
- Certification. FSANZ says the supervisor must hold recognised, formal certification obtained within the past five years. The NSW Food Authority says NSW certificates are valid for five years from the date of issue, after which they need to be renewed.
- Authority. The supervisor must have the authority and ability to manage and give direction on safe food handling.
- Availability. They must be “reasonably available” to do that.
- Before you trade. The NSW Food Authority says mobile food vendors handling unpackaged, potentially hazardous, ready-to-eat food must appoint a food safety supervisor with a current certificate before operating.
For a one-truck business, the supervisor is usually the owner. If you run two rigs, or you’re often away from the truck, consider certifying a senior staff member too, so there’s always someone reasonably available.
Tool two: food handler training
Everyone handling unpackaged potentially hazardous food needs to be trained. FSANZ says the training must cover safe handling of food, food contamination, cleaning and sanitising, and personal hygiene. It doesn’t have to be a formal qualification in every case, but you should be able to show that staff have the knowledge.
This matters most in event season, when casual staff turn over quickly. Build food handler training into your onboarding, keep a simple record of who’s done it and when, and budget time for it before the first big weekend. Our guide to hiring casuals for event season covers the employment side.
Starting or expanding a food truck? Getting food safety sorted is part of the plan — and so is the funding. See if you qualify — it takes a minute, and asking doesn’t touch your credit.
Tool three: records (category one only)
Category one businesses must keep records, or otherwise demonstrate, that key food safety controls are being met. FSANZ describes this as substantiation. In practice, for a food truck, records typically cover:
- Receiving — temperature of potentially hazardous food when it arrives
- Cold storage — fridge and freezer temperatures
- Cooking — that food reaches safe temperatures
- Cooling — that cooked food is cooled quickly enough
- Reheating and hot-holding — temperatures during service
- Cleaning and sanitising — what was cleaned, when and how
The NSW Food Authority says records must be kept for three months, and that a business should make records each day it’s handling unpackaged potentially hazardous food, unless it can show in another way that it’s meeting the requirements.
A clipboard in the truck works. So do apps and digital thermometers that log automatically. The best system is the one your team actually uses on a busy Saturday.
How does this work at events and markets?
Standard 3.2.2A applies wherever you trade. Event organisers and markets often ask for evidence of your food business registration and may ask about your food safety supervisor. Councils can inspect you at events as well as at your base.
A few event-specific tips:
- Keep records in the truck, not at home. If an inspector asks at a festival, you want to show them.
- Plan cold storage for long events. Multi-day festivals stretch fridge capacity.
- Brief casual staff at the start of every event, not just their first shift.
- Carry your latest council inspection report — the NSW Food Authority specifically asks mobile vendors to do this.
Our food truck permits guide explains registration in NSW, Victoria and Queensland.
What does this cost, and should it be in the budget?
The costs are modest compared with a truck, but they’re real: supervisor certification and renewal every five years, staff training time, thermometers and data loggers, and the time it takes to keep records. They belong in your start-up costs and your weekly running costs. When you add up a new rig in the truck-stop calculator, include them in “rego, duty, upfront insurance and permits”.
Illustrative example: a two-truck business
An operator runs a Korean fried chicken truck and has just bought a second, near-identical truck for festival season. Both trucks cook on board, so both are category one. She’s the certified food safety supervisor, but she can’t be on both trucks at once. Before the season, she puts her most experienced team leader through supervisor certification, runs food handler training for the casual crew, and gives each truck its own temperature log. When a council officer visits the second truck at a festival, the team leader has the records and the inspection report ready. (Illustrative only.)
Why lenders care about food safety
A lender funding a food truck is backing a business that depends on passing inspections and keeping customers safe. You don’t need to prove your food safety system to get food truck finance, but understanding it — and budgeting for it — shows you’re running a real business. For caterers, where one bad incident can cost a whole client book, it matters even more; see mobile catering business loans.
Get the kitchen right, then get rolling
Food safety is one of the foundations of a mobile food business that lasts. Once your menu, your supervisor and your build are planned, let’s talk about funding the rig. Asking won’t dent your credit file and only takes a moment. Your details go to one real person, not a line-up of lenders, and they’ll call you to go through your plans.
Please fill in the form accurately — what you’re buying, what it costs and how you’ll trade — so we can match you properly the first time.
Frequently asked questions
Does a food truck need a food safety supervisor?
If it handles unpackaged, potentially hazardous, ready-to-eat food, almost certainly. Under Standard 3.2.2A, both category one and category two businesses must have a certified food safety supervisor. The NSW Food Authority gives a mobile food vendor as an example of a category one business.
What's the difference between category one and category two?
Category one businesses process potentially hazardous food into food that is ready-to-eat and potentially hazardous, and serve it. Category two businesses serve unpackaged, potentially hazardous, ready-to-eat food they didn't make, with only limited handling such as slicing, reheating or hot-holding.
How long is a food safety supervisor certificate valid?
FSANZ says the supervisor must hold recognised certification obtained within the past five years. The NSW Food Authority says NSW certificates are valid for five years from the date of issue.
What records does a category one food truck need to keep?
Records, or other evidence, that show key food safety controls are being met — for example temperatures when receiving, storing, cooking and cooling food, and cleaning and sanitising. In NSW, records must be kept for three months.
Does the supervisor have to be on the truck at all times?
The rules say a food safety supervisor must have the authority and ability to manage and give direction on safe food handling, and be reasonably available to do so. For a small truck, that usually means the owner or a senior staff member who's there when food is being handled.
Does a coffee-only van need a food safety supervisor?
It depends on what you handle. Check with your council, especially if you serve milk-based drinks alongside food items like toasties or reheated pastries.