What Is the Low-Risk MRFE?
Ohio amended its food safety rules effective February 2024 to create a new license classification for mobile vendors whose operations pose a lower food safety risk than a full-service food truck. The Low-Risk Mobile Retail Food Establishment (MRFE) license is issued by the same local health districts as a standard MFSO and carries the same statewide SB 150 reciprocity — but at approximately half the fee.
The reduced fee reflects reduced inspection intensity and the lower inherent risk of operations that don't involve hot food preparation, mechanical refrigeration, or potentially hazardous food handling.
Who Qualifies for Low-Risk MRFE?
The Low-Risk MRFE applies to operations that meet all of the following criteria:
- You sell only shelf-stable products and/or low-risk food items that don't require mechanical refrigeration to stay safe
- Your menu consists of items such as: commercially baked goods, home-produced baked goods (where permitted), jams, jellies, candy, honey, eggs, whole uncut produce, dried herbs, coffee (no milk), or similar shelf-stable goods
- If you use cold storage (ice, gel packs, dry ice), you log temperatures every four hours while operating — this is mandatory for Low-Risk MRFE holders using non-mechanical cold storage
- You do not prepare hot food for immediate consumption on-site
- You do not handle potentially hazardous foods (meats, dairy, cooked grains, cut produce) in ways that require temperature control beyond the log-every-four-hours rule
Who Does NOT Qualify
You cannot use the Low-Risk MRFE license if your operation involves:
- Any hot food preparation (grilling, frying, cooking on-site)
- Sandwiches, wraps, or assembled food items with potentially hazardous ingredients
- Coffee drinks with milk or dairy-based beverages that require temperature control
- Ice cream or frozen novelties sold from mechanical freezer units (this requires standard MFSO)
- Raw meat sales requiring temperature control
- Any operation that a health inspector would classify as medium or high risk under Ohio food safety code
The Temperature Logging Requirement
The most operationally significant Low-Risk MRFE requirement is the four-hour temperature log for non-mechanical cold storage. If you use ice chests, gel packs, or dry ice to keep products cold (rather than a mechanical refrigerator), you must:
- Record the temperature of your cold storage every four hours during operation
- Use a thermometer accurate to ±2°F
- Keep logs available for health inspector review at any time
- Discard any product that has been above safe temperature thresholds
This requirement exists because non-mechanical cold storage degrades over time. Health inspectors want documented proof that operators are actively monitoring product temperatures. Failing to maintain logs — or having logs that show temperatures exceeded safe thresholds — can result in a violation and potentially a citation.
Farmers Market Operators and the Low-Risk MRFE
Ohio's farmers markets have specific rules that interact with the Low-Risk MRFE. Many farmers market vendors were previously operating under a patchwork of exemptions, Cottage Food rules, and temporary vendor permits. The Low-Risk MRFE provides a cleaner, consistent licensing path for vendors who sell baked goods, eggs, honey, jams, and similar items at multiple farmers markets across Ohio counties.
Since the Low-Risk MRFE is statewide under SB 150, a vendor with this license can sell at markets in any Ohio county without additional permits — a significant improvement for vendors who attend markets across multiple counties throughout the season.
How to Apply for Low-Risk MRFE in Hamilton County
Apply through the Cincinnati Health Department (or your home health district) using the same application process as a standard MFSO, but select the Low-Risk MRFE license type. Indicate on your application that your operation qualifies as low-risk and describe your menu and cold storage approach. The health district will review and determine your eligibility during plan review.
If you're borderline — say, you sell mostly baked goods but occasionally offer a hot beverage — discuss your menu in detail with the health district before applying. Operating under a Low-Risk MRFE license with a menu that actually requires a standard MFSO is a compliance violation.