Streetfire Kitchens Business Plan — Licensing, Food Safety and Trading Rights

Certificates of acceptability, municipal trading permits, event access and the food safety regime a mobile kitchen must maintain.

Licensing, Food Safety and Trading Rights

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3.1 The Certificate of Acceptability
3.2 Trading rights

Two separate permissions are required and they are often confused. The first is the right to handle food, which comes from a Certificate of Acceptability under Regulation R638 of 2018. The second is the right to trade in a particular place, which comes from a municipal trading permit or a private site agreement. A business can hold the first and still have nowhere to park.

Requirement	What it covers	Type
Certificate of Acceptability	Mandatory under Regulation R638 of 2018; issued by an Environmental Health Practitioner after inspection of the commissary and of each truck by registration number	Gating
Business licence	Required under the Businesses Act 71 of 1991 from the local municipality	Gating
Municipal trading permit	Street trading permission; Cape Town issues informal trading permits valid up to three years, Johannesburg routes applications through five city departments	Gating
Food safety training	Person in Charge and every food handler trained under Regulation 10 of R638	Gating
Gas Certificate of Conformity	Required for the LPG installation on each truck	Gating
Fire compliance certificate	SANS 10400-T; required by most municipalities and event organisers	Gating
Zoning and site consent	Applies to the commissary premises and to any fixed trading site	Gating
Vehicle roadworthy and licensing	Each truck licensed, roadworthy and insured	Ongoing
Public liability insurance	Required by almost every event organiser and corporate client	Ongoing
Music licensing	SAMRO and SAMPRA where music is played publicly from the truck	Ongoing
Cold chain and transport hygiene	R638 transport of food requirements between commissary and truck	Ongoing
Labour compliance	BCEA, national minimum wage, UIF and COIDA for crew	Ongoing

3.1 The Certificate of Acceptability

The Certificate of Acceptability is the food-handling licence for every food premises in South Africa, including food trucks, and for a truck it is issued against the vehicle registration number. It is granted by an Environmental Health Practitioner after inspection, and it is issued in the name of the person in charge — the individual legally responsible for food safety management. Operating without one is unlawful and an Environmental Health Practitioner may issue an immediate closure order.

For a truck the inspection tests specific things: a clean washable interior, adequate refrigeration, an onboard handwashing facility, covered waste and a safe water supply. For this venture it means separate certificates for the commissary and for each truck, and it means the Person in Charge and every food handler must complete accredited training under Regulation 10 of R638. Municipal fees vary widely — free in Cape Town, around R2 152 in Tshwane, and typically R200 to R650 elsewhere — and the certificate has no statutory expiry date, though material changes must be reported within 30 days. The plan budgets R74 000 a year for compliance and R46 000 for training, because five trucks and a commissary generate repeated inspections, re-certification on vehicle changes and a continuing training pipeline.

3.2 Trading rights

Type of pitch	How access is obtained	What it is worth to the plan
Municipal street trading bay	Informal trading permit from the municipality; Cape Town issues permits valid up to three years	Low pitch cost, uncertain footfall, subject to by-law enforcement
Office park or business estate	Private agreement with the landlord or facilities manager	The core of weekday trade; predictable lunch volume
Shopping centre	Private agreement, often with a turnover commission	Weekend and evening trade; higher pitch cost
Weekend market	Acceptance onto the roster plus a stand fee	Volume and brand exposure; oversubscribed at the better markets
Festival or sporting event	Application and a stand fee or revenue share	High covers over a short window; concentrated and seasonal
Private event site	Direct booking with the client	No pitch fee, confirmed head count, the highest contribution

A food truck without a place to park is a depreciating vehicle

Weekday street and office park trade is 43.1 per cent of revenue, and every day of it depends on permission granted by someone else — a municipality, a landlord, a facilities manager or a market organiser. Cape Town issues informal trading permits valid for up to three years through an online portal; Johannesburg routes food licences through five city departments. None of these permissions is permanent, none is transferable when a truck is sold, and losing a prime weekday pitch removes a truck’s best trading days at short notice with no recourse. The plan’s response is structural rather than contractual: hold more pitch agreements than trucks, rotate sites so no single landlord controls a disproportionate share of the diary, and treat the ratio of signed pitches to trucks in service as a board-level measure rather than an operational one.

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