Arizona's HB 2042 (signed March 29, 2024) opened the door for home food sellers to make and sell perishable foods — tamales, pizzas, cheesecakes, dairy, and even certain meat products — all from a home kitchen.
TCS stands for Time/Temperature Control for Safety. These are foods that can support the rapid growth of harmful bacteria when held at unsafe temperatures. If a food needs to be refrigerated, frozen, or kept hot to stay safe, it's a TCS food.
Before 2024, Arizona's cottage food program was limited to non-TCS (shelf-stable) items — baked goods, jams, candies, and similar products. The signing of HB 2042 on March 29, 2024, changed that dramatically. Arizona now allows home food sellers to produce and sell nearly all TCS foods, making it one of the most permissive cottage food states in the country.
One of Arizona's most popular cottage food items — must maintain temperature during transport
Prepared meals sold hot or cold; transport under 2 hours
Cream pies, pumpkin pies, pecan pies, sweet potato pies with perishable fillings
Prepared Mexican dishes — a natural fit for Arizona's Sonoran food traditions
Pre-cut produce must be kept at safe temperature throughout handling and sale
Must maintain freezing temperature during storage and delivery
Milk, cheese, butter, ice cream — direct consumer sale only; in-person delivery required
From federally inspected sources; direct sale only; no third-party delivery platforms
Selling TCS foods from your home kitchen is allowed — and you don't need a commercial kitchen to do it. However, TCS products come with specific handling, temperature, and delivery rules that shelf-stable products don't have. Here's what you need to know.
This is one of Arizona's biggest advantages. Unlike many states that require a licensed commercial kitchen for any perishable food, Arizona allows all TCS cottage food products to be prepared in your residential home kitchen. The same kitchen requirements apply as for shelf-stable products: it must be your primary residence, not exceed 1,000 square feet, and all food must be prepared and stored inside (no outdoor storage).
No home inspection. Arizona does not inspect cottage food home kitchens — for shelf-stable or TCS products. You are responsible for maintaining safe food handling practices, which is why the ANAB-accredited food handler training course is required before you can register.
This is the core safety rule for TCS foods in Arizona. When potentially hazardous food is out of temperature control (above 41°F for cold foods or below 135°F for hot foods), a clock starts ticking:
In practical terms, this means that when you transport TCS products to a customer or a farmers market, you need to keep them at safe temperatures and plan your delivery so that the food is never out of temperature control for more than 2 hours. Arizona's statute specifically requires that TCS cottage food products transported before final delivery be maintained at appropriate temperature and limited to a single trip not exceeding two hours.
Invest in temperature control. If you're selling TCS foods, a good insulated bag, cooler, or hot-holding container is essential equipment. Consider a food thermometer to verify temperatures at the point of sale. These tools are inexpensive and show your customers you take food safety seriously.
Not all TCS foods have the same selling freedom. The rules depend on what's in your product — specifically, whether it contains meat, poultry, or dairy.
| Sales Channel | TCS (No Meat/Dairy) | Dairy Products | Meat & Poultry |
|---|---|---|---|
| Home / In-Person | Yes | Yes | Yes |
| Farmers Markets | Yes | Yes | Yes |
| Online (Your Website) | Yes | Conditions In-person delivery only | Conditions In-person delivery only |
| Third-Party Delivery | Yes | No | No |
| Retail Stores | Conditions Separate display, signage | No Direct sale only | No Direct sale only |
| Ship Within AZ | Conditions Temp control required | No In-person only | No In-person only |
TCS foods without meat or dairy (like tamales with vegetarian filling, cheesecakes, custard pies, cut fruit) have the widest reach — you can sell them online, through third-party delivery platforms, and in retail stores with the standard display conditions.
Dairy products (milk, cheese, butter, ice cream) and meat/poultry products are the most restricted. You can sell them online, but you must deliver in person — no DoorDash, no UberEats, no shipping via a carrier. These products also cannot be placed in retail stores; they must go directly from you to the consumer.
Arizona's cottage food program allows certain meat and poultry products, but they must meet federal requirements:
Federally inspected source. Meat and meat by-products must come from a USDA-inspected source. You cannot slaughter your own cattle, hogs, or other large animals for cottage food sale — the meat must be purchased from a federally inspected processor.
Poultry has two paths: You can sell poultry products if the poultry comes from a federally inspected source. Alternatively, if you raise your own birds, you may qualify for the federal 1,000-bird exemption under 9 CFR § 381.10(c), which allows producers who slaughter fewer than 1,000 of their own poultry per year to sell directly to consumers without federal inspection.
In either case, meat and poultry cottage food products can only be sold directly to consumers with in-person delivery. See the Special Categories page for a deeper dive into meat and poultry licensing paths.
While Arizona does not inspect your kitchen, food safety is your responsibility — and it protects both your customers and your reputation. Here are the most important practices for TCS food sellers:
Keep cold TCS foods at or below 41°F (5°C) and hot TCS foods at or above 135°F (57°C). Use a calibrated food thermometer to spot-check temperatures during preparation, storage, and transport. Document temperatures if selling at a farmers market — some market coordinators may ask.
Plan your delivery route so that TCS products are in transit for the shortest time possible. Arizona limits TCS transport to a single trip not exceeding two hours. Use insulated bags, coolers with ice packs, or hot-holding containers as appropriate. Never combine hot and cold TCS items in the same container.
When handling raw meat or poultry alongside other cottage food products, use separate cutting boards, utensils, and storage containers. Wash hands thoroughly between handling different product types. Your ANAB-accredited food handler training covers these practices in detail.
Reminder: No interstate sales. Even for TCS foods, all cottage food sales must stay within Arizona. You cannot deliver perishable products across state lines.
Find out if your prepared meal qualifies as a TCS food and see exactly which delivery channels and rules apply in Arizona.
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