Reefer transport: how it works and which rules apply

Reefer trailers and the temperature of the goods

A reefer trailer has an insulated body and a cooling unit that holds a set temperature. The ATP test checks that the unit can cool the empty body and then keep that temperature. So the goods must already be at the right temperature when they are loaded. Cool warm goods in a cold store first.

The food rules expect this. The ATP limits apply from the moment of loading. Regulation (EC) No 853/2004 says meat must reach its temperature before transport and stay at it during transport. The cooling should not freeze chilled food anywhere in the load (ATP Annex 3).

Agree two more points before loading. The driver starts the cooling unit early, so the trailer reaches the set temperature before the doors open. Write the set temperature on the transport order and on the CMR note.

RNJ Transport owns no reefer trailers. Our own trucks pull curtainsiders without cooling. We book temperature-controlled loads on reefer trucks of checked partner carriers, and you keep one contact person for the load. Our page on temperature-controlled transport explains how we book them.

ATP maximum temperatures for food

The ATP Agreement sets the highest temperature the food may have at any point of the load. The limit applies on loading, during the trip and on unloading. Annex 2 covers frozen and quick-frozen food, and Annex 3 covers chilled food. The table shows both annexes in the current text.

Journeys and goods under the ATP Agreement

The ATP Agreement applies to road and rail transport of frozen food and of the chilled food in Annex 3. The goods must be loaded in one country and unloaded in another, and the country of unloading must be an ATP party. The rule covers transport for hire and transport on own account.

A sea crossing of less than 150 km counts as part of the trip, if the goods stay in the same equipment. With a longer sea crossing, ATP looks at each land journey separately. For a route with a ferry, such as Klaipėda to Karlshamn, ask the authority in the country of loading how ATP applies.

All countries on our main lanes are ATP parties: Lithuania, Latvia, Estonia, the Netherlands, Belgium, Germany, Sweden and Norway. Countries do not have to apply ATP to food that is not meant for people to eat.

For transport for hire, ATP Article 4 makes the consignor named in the transport document responsible for compliance. A carrier, or anyone else who agreed to provide services such as cooling, is responsible as far as compliance depends on those services. Check your contract for who does what. EU food hygiene rules apply on every trip too. Regulation (EC) No 852/2004 says vehicles must be able to keep food at suitable temperatures where needed, and allow those temperatures to be monitored.

ATP equipment classes and winter heating

An ATP certificate shows what the trailer can do. Mechanically refrigerated equipment has classes A to F, tested at an outside temperature of +30 °C. Heated equipment has classes A to D. The class mark, such as FRC, is shown in large letters on both sides of the trailer, near the front, with the expiry date.

Temperature records for frozen and chilled food

A temperature record shows the air temperature in the trailer during the whole trip. For quick-frozen food, EU law requires a recorder in the vehicle (Regulation (EC) No 37/2005). The operator dates each record and keeps it for at least one year. For chilled food, ask for a record before loading.

ATP requires recorders that meet the standard EN 12830:2018. Recorders in service that meet EN 12830:1999 may stay in use. ATP amendments in force since 25 August 2026 update the rules for checking recorders, under the standard EN 13486:2023. The new recorder rules apply no later than 12 months after that date.

Quick-frozen food stays at −18 °C or colder at all points. Directive 89/108/EEC allows brief rises of up to 3 °C during transport. Regulation (EC) No 853/2004 sets limits for meat, poultry and fish as well:

• Meat of cattle, pigs, sheep, goats and horses: 7 °C, and offal 3 °C, before and during transport
• Poultry meat: 4 °C before and during transport
• Minced meat 2 °C and meat preparations 4 °C, or frozen to −18 °C
• Fresh fish: close to the temperature of melting ice. Frozen fish: −18 °C, with short rises of up to 3 °C

Written instructions and carrier liability

Give the carrier its instructions in writing. Under CMR Article 18(4), a carrier with a temperature-controlled vehicle can use the exemption for goods that spoil by nature only if it proves two things. It took all due steps in choosing, maintaining and using the equipment, and it followed your special instructions.

Write the set temperature, the mode and the product on the transport order and the CMR note.

The carrier’s liability has a limit. CMR caps compensation at 8.33 SDR per kilogram of gross weight (Article 23(3), as amended by the 1978 Protocol). Our guide to CMR insurance shows the limit in euros and explains the exemptions. Tell us the value of the goods when you book, so we can talk about cover before the truck leaves.

Medicines follow separate EU rules, the Good Distribution Practice guidelines (2013/C 343/01). Ask us before you plan such a load.

RNJ Transport gives you one contact person and one invoice for a reefer load, as for any other load. We check the partner carrier before every load. This guide gives the general position under ATP, EU food law and CMR. For your own case, check your contract and ask the competent authority.

Checklist before a reefer load

Agree these points with the forwarder before the truck comes. Write each point on the transport order. The set temperature also goes on the CMR note.