A1 Grass, I am, unfortunately from a personal experience, very familiar with TDA guidelines and enforcement processes. No, I was not the one investigated. The simplest way to put it is this way: TDA considers anyone who applies any type of chemical, and there is no distinction between organic and synthetic, for hire to be a commercial applicator.
If you wish, I can provide direct telephone numbers to confirming State supervisors.
The state allows for quantities below one quart to be made available to unlicensed individuals for home use only. Hence, why Home Depot can sell some chemicals, but not beyond one quart quantities.
The state operates off of a observation/complaint basis. If a TDA employee (I did not say Inspector) reports an application with an unmarked tank, or worse yet, an Inspector sees it - you - the applicator have to prove you have a license. I am speaking of a conceivable LCO setting, try convincing an Investigator that what you are doing is for no pay whatsoever.
There are mandatory fines the Inspectors have no discretion to waive.
Bear in mind, the Structual Pest Control Board has been trying for a number of years to swallow up the TDA.
What I would recommend is that you contact the TDA's enforcement branch in Austin and have a supervisor there confirm what I am saying.
If I am proven incorrect, I will say so.
Dchall, license requirements are in place to protect a multitude of people, from applicators, consumers and bystanders.
Unfortunately, I have to cut this short.