Monitoring the cold chain in transport: temperatures and proof.
Between the cold room and the customer lies the journey, and that is where the cold chain breaks most easily. This guide shows which rules apply to chilled and frozen food on the road, what the ATP Agreement covers, what you have to record and where the gaps are in daily work. Pick your country and you see only the rules that apply there.
- Basic duty: transport containers must, where necessary, be able to keep food at the appropriate temperature, and it must be possible to monitor the transport temperature.
- Chilled: for meat, poultry, minced meat and fish the law sets maximum temperatures that also apply during transport. They refer to the product, not to the air in the load space.
- Frozen: the goods must stay at −18 °C or colder, brief rises during dispatch are allowed within limits. Recording instruments for the air temperature are mandatory, and records must be kept for at least one year.
- ATP: the Agreement applies to cross-border carriage of certain perishable foodstuffs and to the approval of the vehicles. For purely domestic transport each state decides for itself.
- Switzerland: according to the UN Treaty Collection, Switzerland has signed the ATP but not ratified it. Domestically, the rules of the FDHA Hygiene Ordinance are the main reference.
- The same everywhere: the gaps are at the loading dock, during transhipment, with door openings on multi-drop rounds and in the vehicle overnight.
Who this guide is for
- Food suppliers and producers who deliver themselves
- Caterers who bring food to customers chilled
- Delivery services carrying chilled goods
- Wholesalers with their own fleet
- Small hauliers carrying chilled or frozen food
Medicines are covered by their own guidelines, summarised in a short section further down. For storage before and after transport, see the guide to cold room monitoring, and for documentation the guide to the HACCP temperature log.
What the EU requires for every food transport
The general basis is Regulation (EC) No 852/2004 on the hygiene of foodstuffs. It applies directly in Austria and Germany. Two points in Annex II are decisive for transport:
- Chapter IV point 7: conveyances and containers must, where necessary, be capable of maintaining foodstuffs at appropriate temperatures and allow those temperatures to be monitored. The Regulation does not name a specific instrument here.
- Chapter IX point 5: the cold chain is not to be interrupted. Limited periods outside temperature control are permitted where this is necessary for practical reasons, including transport, provided it does not result in a risk to health.
Chapter IV also requires clean, well-maintained containers, separation from other goods where necessary, and cleaning between different loads. Regulation 852/2004 does not give specific figures. These are set in Regulation (EC) No 853/2004 for food of animal origin and in the rules for quick-frozen foods.
Transport temperatures: food of animal origin
The following values from Annex III of Regulation (EC) No 853/2004 expressly also apply during transport. They are maximum temperatures in the product, not in the load space.
| Goods | Maximum | Reference (Annex III) |
|---|---|---|
| Meat of domestic ungulates (cattle, pigs, sheep, goats) | 7 °C | Section I, Chapter VII, points 1 and 3 |
| Offal | 3 °C | Section I, Chapter VII, points 1 and 3 |
| Poultry and lagomorph meat | 4 °C | Section II, Chapter V, point 4 |
| Minced meat | 2 °C (core) | Section V, Chapter III, point 2(c) |
| Meat preparations | 4 °C (core) | Section V, Chapter III, point 2(c) |
| Fresh fishery products | close to the temperature of melting ice | Section VIII, Chapter VIII, point 1(a) |
| Frozen fishery products | −18 °C throughout, brief rises of no more than 3 °C | Section VIII, Chapter VIII, point 1(b) |
There are exceptions for some cases, for example authorised transport of carcases before they reach the target temperature. These exceptions require approval by the authority. Retailers that supply other establishments and limit themselves to storage or transport still have to meet the temperature requirements of Annex III (Article 1(5)).
For plant-based food, prepared dishes and dairy products, EU hygiene law sets no general transport temperatures. Here the manufacturer's information on the label, your own hazard analysis and, where they exist, national rules apply.
Frozen: −18 °C and recording duty
Quick-frozen foods must be kept at −18 °C or colder at all points of the product. During dispatch, brief rises of no more than 3 °C are permitted. The national rules listed in the country section below set this out.
Regulation (EC) No 37/2005 is particularly important for transport. It requires means of transport for quick-frozen foods to be fitted with suitable recording instruments that monitor the air temperature frequently and at regular intervals. The instruments must comply with standards EN 12830, EN 13485 and EN 13486. Records must be dated and kept for at least one year, or longer depending on the type and shelf life of the goods. For retail display cabinets and local distribution, the Regulation allows an easily visible thermometer instead. What counts as local distribution in your case should be clarified with your authority.
The ATP Agreement: what it covers
The ATP is an agreement of the United Nations Economic Commission for Europe (UNECE) on the international carriage of perishable foodstuffs. It covers two things:
- The vehicles: a vehicle may only be designated as insulated, refrigerated or heated within the meaning of the ATP if it has been tested and meets the standards of the Agreement. Contracting Parties recognise each other's certificates.
- The carriage: such vehicles must be used for frozen and quick-frozen foodstuffs and for certain chilled foodstuffs, such as meat, poultry, minced meat, fish, fresh dairy products and ready-prepared foods. The maximum temperatures apply during loading, carriage and unloading.
The ATP applies to carriage for hire or reward and on own account by road and rail when the places of loading and unloading are in two different states and the place of unloading is in the territory of a Contracting Party. For quick-frozen foodstuffs it additionally requires an instrument that measures, records and stores the air temperature. Records must be kept for one year or longer, depending on the food. Transitional periods apply to some of the testing requirements.
The ATP does not apply to purely domestic transport by itself. Each state decides whether to apply it domestically as well. Monaco, for example, requires the ATP certificate for national carriage too, according to its government portal. For Austria, Germany and Switzerland we found no rule that extends the ATP in general to domestic transport. Please clarify this case by case with the competent authority or an ATP testing body.
Do you know how warm the load space was after the fourth stop?
Get your setup →Austria: frozen food ordinance and EU law
What applies
- EU law: Regulations (EC) No 852/2004, 853/2004 and 37/2005 apply directly in Austria, with the temperatures above and the recording duty for frozen goods.
- Ordinance on quick-frozen foods (BGBl. No 201/1994), § 4: the temperature must be constant at −18 °C or colder. During dispatch, local distribution and in retail freezer cabinets, a brief rise of 3 °C is permitted, up to −15 °C at most.
- ATP: Austria is a Contracting Party, ratified in 1977.
We did not find separate Austrian rules with transport temperatures for chilled goods. Whether further requirements apply to your business should be clarified with the food inspectorate of your federal state.
Germany: Tier-LMHV and TLMV
What applies
- Tier-LMHV, § 15(3): based on the internal temperature, the following may only be stored and transported at no more than: meat of domestic ungulates 7 °C, offal 3 °C, poultry and lagomorphs 4 °C, large wild game 7 °C, small wild game 4 °C, mechanically separated meat 2 °C, frozen mechanically separated meat −18 °C.
- TLMV, § 2(4): quick-frozen foods must be kept at −18 °C or colder at all times until they reach the consumer. During dispatch, brief fluctuations of no more than 3 °C are permitted, and in local distribution deviations of no more than 3 °C. Local distribution means local delivery to retailers, to catering establishments and to private households (§ 2(5)).
- TLMV, § 2a: whoever is responsible for transporting quick-frozen foods must measure and record the air temperature with instruments as defined in Regulation (EC) No 37/2005, often enough that the temperature history can be traced.
- LMHV: the general food hygiene ordinance contains only a special rule on raw sugar in sea-going ships for transport, and no transport temperatures for road.
- ATP: Germany has been a Contracting Party since 1974. According to the Federal Ministry of Transport, the ATP determines which means of transport are to be used in international carriage.
Switzerland: FDHA Hygiene Ordinance
What applies
- HyV Art. 12(7): transport containers for food that must be kept at a certain temperature must be able to hold that temperature, and the transport temperature must be possible to monitor.
- HyV Art. 24(3): the cold chain must not be interrupted. Deviations are only permitted for a limited time, for example during transport, and only if health is not put at risk.
- HyV Art. 29(1) and (4): during transport these core temperatures apply: meat of domesticated ungulates and game 7 °C, poultry and rabbits 4 °C, meat preparations and meat products 4 °C, offal 3 °C, minced meat 2 °C. There are exceptions for short direct transports from the slaughterhouse.
- HyV Art. 44: fresh fishery products must be stored and transported at the temperature of melting ice, no more than 2 °C.
- HyV Art. 25(3) and Annex 2: quick-frozen foods must be kept at −18 °C or colder. During transport the temperature may rise briefly, but must not exceed −15 °C in the outer layers. Vehicles need recording instruments to SN EN 12830 and SN EN 13486, and records must be kept for at least one year.
- ATP: according to the UN Treaty Collection, Switzerland signed the Agreement in 1971 but has not ratified it. What this means for transport to EU states should be clarified with an ATP testing body or the authority.
Medicines: the EU GDP guidelines
In the EU, wholesale distribution of medicinal products for human use is covered by the Guidelines on Good Distribution Practice (2013/C 343/01). Chapter 9 requires that the storage conditions stated by the manufacturer are maintained during transport and that it can be shown the products were not exposed to conditions that could affect their quality. A risk assessment of delivery routes should determine where temperature controls are needed. Temperature monitoring equipment in vehicles should be maintained and calibrated at least once a year, and temperature excursions should be reported to the distributor and the recipient and investigated under a defined procedure. More on fridges for medicines is in the guide to medicine fridge monitoring.
Where checks in transport leave gaps
- Loading dock. The goods stand in the warm until the vehicle is loaded. The ATP expressly covers loading and unloading as well.
- Transhipment and interim storage. Responsibility changes at every handover, and there is often no measurement in between. The GDP guidelines single this point out for medicines.
- Door openings on multi-drop rounds. On a round with ten or twenty customers the door opens often, and the rear of the load space warms faster than the front.
- Vehicle overnight. When a loaded vehicle stands overnight, nobody is watching the refrigeration unit.
- Handwritten notes. One reading at departure and one on arrival do not show what happened in between.
What a sensor adds
A sensor measures around the clock, alerts the people you name as soon as the temperature leaves your limit, and writes every deviation with start, end and duration to a continuous, time-stamped record. Where it makes sense, a door or opening contact can also be used. If a sensor or the connectivity unit stops sending data, Frigo alerts the named people. Frigo automatically creates a monthly PDF report per sensor, and you can export the data at any time. This supports your own checks and documentation.
Important: Frigo measures the air temperature at the sensor's location, not the core temperature of the goods. Legal limits mostly refer to the product. Frigo does not cool anything and does not intervene in the refrigeration unit. Frigo is used for temperature-sensitive transport and vehicles. In the vehicle the connectivity unit is connected to the power supply and transmits over the mobile network; we agree the details with you.
Whether a measuring system meets the standards required for frozen transport, such as EN 12830, has to be clarified case by case. This guide makes no statement on that for Frigo.
How the system is built is explained under How does Frigo work?.
Four things to set per vehicle
- the target range per type of goods, for example no more than 4 °C for poultry or −18 °C for frozen goods
- the limit and how long a deviation may last, for example during defrosting or at a stop
- who is notified, driver, dispatch or on-call staff, including at night
- what happens after a deviation: check the goods, record the decision, inform the recipient
Frequently asked questions
What temperature applies when transporting chilled meat?
Under Annex III of Regulation (EC) No 853/2004, no more than 7 °C for meat of domestic ungulates, 3 °C for offal, 4 °C for poultry, 2 °C for minced meat and 4 °C for meat preparations. The values apply in the product and expressly also during transport. In Switzerland, Art. 29 of the FDHA Hygiene Ordinance sets comparable values.
Do I need a temperature recorder for frozen transport?
Yes. Under Regulation (EC) No 37/2005, means of transport for quick-frozen foods must be fitted with recording instruments for the air temperature that comply with standards EN 12830, EN 13485 and EN 13486. Records must be kept for at least one year. In Switzerland this is set out in Annex 2 of the FDHA Hygiene Ordinance.
Does the ATP also apply to transport within one country?
The Agreement itself applies to carriage where the places of loading and unloading are in two different states. Whether a state also applies it domestically is up to that state. For Austria, Germany and Switzerland we found no general domestic obligation. Please clarify this case by case with the authority or an ATP testing body.
May the temperature rise briefly during deliveries?
Within narrow limits. Regulation (EC) No 852/2004 allows limited periods outside temperature control where this is necessary for practical reasons and does not put health at risk. For quick-frozen foods, brief rises of no more than 3 °C are permitted during dispatch, in Austria and Switzerland up to −15 °C at most.
Does Frigo replace a temperature recorder to EN 12830?
We do not make that promise. Whether a measuring system meets these standards has to be clarified case by case. Frigo supports your own checks and documentation with a continuous, time-stamped record and monthly PDF reports, and alerts the named people to deviations.
How is Frigo installed in a vehicle?
The sensors are stuck on, with no drilling and no cables. In the vehicle the connectivity unit is connected to the power supply and transmits over the mobile network. Without power, for example when the vehicle is parked, it keeps running on its built-in battery for about four hours. We agree the details with you. Frigo measures the air temperature at the sensor's location, not the core temperature of the goods.
Sources
- EU: Regulation (EC) No 852/2004 on the hygiene of foodstuffs, Annex II Chapters IV and IX (consolidated version of 24 Mar 2021, EU)
- EU: Regulation (EC) No 853/2004 laying down specific hygiene rules for food of animal origin, Annex III (consolidated version of 7 May 2026, EU)
- EU: Regulation (EC) No 37/2005 on the monitoring of temperatures in the means of transport, warehousing and storage of quick-frozen foodstuffs (12 Jan 2005, EU)
- Federal Ministry of Transport: ATP Agreement, with unofficial translation of the UNECE version of 25 Aug 2026 (as of 10 Sep 2026, Germany, in German)
- United Nations Treaty Collection: status of the ATP Agreement (accessed October 2026, international)
- Government of Monaco: Certificate for refrigerated carriage (27 Aug 2026, Monaco)
- Federal Ministry of Health: Ordinance on quick-frozen foods, BGBl. No 201/1994, § 4 (RIS, Austria, in German)
- Federal Ministry of Justice: Food Hygiene Ordinance for food of animal origin (Tier-LMHV), § 15 (last amended 11 Apr 2024, Germany, in German)
- Federal Ministry of Justice: Ordinance on quick-frozen foods (TLMV), §§ 2 and 2a (last amended 5 Jul 2017, Germany, in German)
- Federal Department of Home Affairs: FDHA Hygiene Ordinance (HyV), SR 817.024.1 (as of 1 Jul 2025, Switzerland, in German)
- European Commission: Guidelines on Good Distribution Practice of medicinal products for human use, 2013/C 343/01, Chapter 9 (23 Nov 2013, EU)
Your cold chain in view on the road
See deviations in the load space while the round is running, and have the history as a record.
To logistics →This article is guidance, not legal advice. What counts are the regulations in their current version, the information from the competent authority and the information from the manufacturers of the goods and the vehicle. Frigo measures the air temperature at the sensor's location, not the temperature in the product, does not cool anything and does not replace any duties, tests or certificates. Alerts require a working connection. During a power cut the connectivity unit keeps running on its built-in battery for about four hours, after that Frigo reports that the connectivity unit has stopped sending data. Sources as of: October 2026.