Food guidance · 13 questions

Frozen food and cold stores: −18 °C and its tolerances

The quick-frozen foodstuffs rules, the brief rises they allow in transport and retail cabinets, the recording instruments they require, and what that means for a cold store's monitoring and records.

Reviewed by Jake Farrow, Managing DirectorLast reviewed 19 October 2026

Quick-frozen food must be kept at −18 °C or colder, with brief rises to −15 °C allowed in transport and to −12 °C in retail cabinets. Stores and vehicles must have recording instruments to EN 12830, and the recordings must be kept for at least a year. Other frozen food has no fixed figure in law, so −18 °C is good practice rather than a rule.

Why it matters

Frozen is the one place the law asks for a recorder

Frozen food feels low risk: it is hard, it is cold and nothing grows. But a cold store holds weeks of stock in one room, a failed compressor is noticed only when someone walks in, and product that has partly thawed and refrozen can look fine. The rules reflect that.

Quick-frozen food is the only area of UK food law that fixes a storage temperature, its tolerances, the type of recording instrument and how long to keep the recordings. If you run a cold store, a frozen distribution depot or a frozen vehicle fleet, those rules apply to you whatever your certification standard says.

What the rules say

−18 °C and the two tolerances

Schedule 2 to the Quick-frozen Foodstuffs (England) Regulations 2007 requires quick-frozen food to reach '–18oC or colder' after thermal stabilisation and then be 'maintained at a level no warmer than –18oC'. There are two exceptions: 'brief periods during transport (including local distribution)' when it may be warmer than −18 °C 'but not warmer than -15oC', and a retail display cabinet, where it may be warmer 'to an extent consistent with good storage practice but not warmer than -12oC'. Wales, Scotland and Northern Ireland have the same figures.

Monitoring is set by Commission Regulation (EC) No 37/2005. Transport, warehousing and storage must be fitted with 'suitable recording instruments to monitor, at frequent and regular intervals, the air temperature'. The instruments must comply with EN 12830, EN 13485 and EN 13486, and 'temperature recording shall be dated and stored by the food operator for a period of at least one year, or for a longer period taking into account the nature and the shelf life'. What those three standards cover is explained on our EN 12830 page.

Retail is lighter. Article 3 says retail display cabinets and local distribution need only 'at least one easily visible thermometer', read at the air return side at the load line in open cabinets, and the England Regulations exempt retail cold stores under 10 m³ that use a visible thermometer.

Quick-frozen food: the legal limits
  • Storage: −18 °C or colder

From Schedule 2 to the Quick-frozen Foodstuffs (England) Regulations 2007. The −15 °C transport limit is for brief periods only; −12 °C applies only in retail display cabinets.

Other frozen food, fish, ATP and Ireland

Food that is frozen but not sold as quick-frozen has no statutory −18 °C. SFBB for retailers calls −18 °C 'good practice', which is what most customers and auditors expect. Regulation 853/2004 sets 'not more than −18 °C in all parts of the product' for frozen fishery products, with 'short upward fluctuations of not more than 3 °C' in transport, and −18 °C for frozen minced meat (Annex III).

For international journeys the ATP agreement sets −20 °C for ice cream, −18 °C for quick-frozen food and −12 °C for other frozen food, and allows 'a brief rise of the temperature of the surface of the foodstuffs of not more than 3 °C in a part of the load' during defrosting. In Ireland, S.I. 290/1992 and S.I. 370/1995 set the same −18 °C rule and one-year record, with 3 °C tolerances in transport and in retail, so an Irish retail cabinet may reach −15 °C, not the UK's −12 °C.

What good looks like

A cold store an auditor can read in five minutes

Start with the instrument. Ask your monitoring supplier for the EN 12830 conformity documents and keep them, because 37/2005 asks you to. An annual UKAS-accredited calibration across the working range meets the periodic verification EN 13486 describes, in our view (EN 13486 is licensed; we paraphrase). Calibrate at at least three points that bracket the operating range and the alarm set points (for a +2 °C to +8 °C fridge, for example 0, 5 and 10 °C), to ±0.5 °C; our UKAS laboratory (No. 10723) covers −35 to +40 °C in its air chamber for whole loggers and sensors, and −90 to +135 °C in a dry block for probes. Then decide the logging interval yourself, because 'frequent and regular' is not defined, and set retention to at least a year beyond the longest shelf life you store.

Alarm on what the law cares about, not on every defrost. Air in a cold store swings during evaporator defrost, and ATP's own allowance shows that a brief surface rise is expected. The Cold Chain Federation is exploring higher set points such as −15 °C for energy, but that does not change the law for quick-frozen food or your customer's specification.

Worked example

A defrost that does not finish

This is an illustrative example; times and readings are invented. A third-party cold store runs at −22 °C with defrosts every six hours, which normally recover in 25 minutes. Its alert fires when the air has been warmer than −18 °C for 40 minutes (recovery plus 15), and its action alarm when the air has been warmer than −15 °C for 15 minutes.

Saturday 02:00, a defrost starts and the air passes −18 °C at 02:10, as it does on every defrost. The heater contactor sticks, so the air does not recover. 02:50, the alert fires and the shift lead acknowledges it. The air passes −15 °C at 02:52 and the action alarm reaches the on-call engineer at 03:07. 03:35, the engineer isolates the heater and the room starts to pull down. 05:30, air is back below −18 °C.

What the store does: downloads the record, probes product between packs near the evaporator and the door, and finds the warmest surface at −16 °C. It tells the product owners, records the event and lets each owner decide on release against their specification. What changes: a second high-temperature alarm on defrost termination, and the heater contactor added to the maintenance schedule.

Where it is unclear

"Brief", "frequent" and non-quick-frozen stock

The law never defines how long a 'brief period' at up to −15 °C may last, or how often 'frequent and regular' recording must be. ATP's defrost allowance is also not given in minutes. Food that is frozen but not labelled quick-frozen falls back on the general HACCP duty, so its limit is a business decision. Our positions are under −18 °C and its tolerances.

The editions of the standards also differ: ATP cites EN 13486:2002 while BSI now lists the 2023 edition. Ask your supplier which edition its verification or calibration follows and keep the answer with the certificates.

Inspection findings

What officers look at

The FSA's Practice Guidance for officers starts with air temperature records, which it says 'are an indication of temperature history, including defrost cycles, door openings and breakdowns', then moves to between-pack readings with a total tolerance of +2.8 °C, and to destructive product testing for formal action. A store with credible records and a calibrated instrument can end the check at the first stage.

Under the 2007 Regulations, failing to keep the recording is an offence and records must be shown to an authorised officer on request. We found no published national data on frozen storage findings; the Hillingdon prosecution, where a walk-in freezer was 'sounding an alarm displaying a temperature of 30 degrees Celsius', shows the kind of temperature finding that ends up in a prosecution file.

In summary

The short version

  • Quick-frozen food: −18 °C or colder, brief transport rises to −15 °C, retail cabinets to −12 °C.
  • Stores and vehicles for quick-frozen food need EN 12830 recorders and at least one year of dated records.
  • Retail cabinets and small retail cold stores may use a visible thermometer instead.
  • Other frozen food has no statutory figure; −18 °C is good practice and what customers expect.
  • A cold store has no tolerance: alert when the air stays warmer than −18 °C beyond the measured defrost recovery, and keep the defrost data behind the delay.
  • Ireland has the same −18 °C rule and one-year record, but its retail cabinet tolerance is 3 °C (−15 °C), not the UK's −12 °C.

Frozen food and cold stores

Questions, answered from the source

Last checked 19 October 2026. Each answer links to its source and says whether it is law, formal guidance or interpretation.

What temperatures does 853/2004 set for meat, poultry, mince and fish?Law

Annex III of Regulation (EC) No 853/2004 (GB text): red meat must be chilled to 'not more than 3 °C for offal and 7 °C for other meat' and stay there during storage and transport (Section I, Chapter VII, points 1 to 3); poultry meat must reach 'not more than 4 °C before transport' (Section II, Chapter V, point 4); minced meat must be chilled to 'not more than 2 °C' and meat preparations 4 °C, or frozen to 'not more than -18 °C' (Section V, Chapter III, point 2(c)). Fresh fishery products must be kept at 'a temperature approaching that of melting ice' and frozen fishery products at 'not more than – 18 °C in all parts of the product' (Section VIII, Chapter VII). In transport frozen fish may have 'short upward fluctuations of not more than 3 °C' (Section VIII, Chapter VIII, point 1(b)).

What's agreed, and what isn't

These apply to approved establishments under 853/2004, which is why the 8 °C Schedule 4 rule does not apply to them. 853/2004 does not set a single -18 °C storage figure for all frozen red meat; it says meat for freezing 'must be frozen without undue delay'. Northern Ireland follows the EU text, which has been amended since (for example on warm carcase transport), so figures can differ from GB. Whole fish frozen in brine for canning may be kept at not more than -9 °C.

Status
Law
Applies to
Food manufacturers, Cold stores, Food distribution and transport
Last checked
18 October 2026
Do Irish cold stores, vehicles and retailers have to record frozen food air temperatures, and for how long must records be kept?Law

Yes. S.I. No. 370 of 1995, Regulation 5(1), requires the means of transport, warehousing and storage of quick-frozen food to 'be fitted with suitable recording instruments to monitor, at frequent and regular intervals, the air temperature'. Regulation 7 requires recordings to 'be dated and stored by the operator for at least one year or longer according to the nature of food'. Retail cold chambers under ten cubic metres may use an easily visible thermometer instead (Regulation 5(2)), and retail display cabinets need at least one easily visible thermometer, in open cabinets reading at the air return side at the maximum load line (Regulation 8).

What's agreed, and what isn't

Regulation 6 says measuring instruments in transport registered in the State 'must be approved by the Minister' or a nominated body; the regulations do not say which standard that means, so check with your supervising authority. The Irish S.I. is silent on any instrument standard; check Commission Regulation (EC) No 37/2005, which applies directly, for the EU requirements. 'Frequent and regular intervals' is not defined, so a business needs to decide its own logging interval. Contravening Regulations 5 to 8 is an offence (Regulation 12).

Status
Law
Applies to
Cold stores, Food distribution and transport, Food retail
Last checked
18 October 2026
Do retail freezers and small cold rooms need data loggers?Law

Not under Regulation 37/2005. Article 3(1) says that in retail display cabinets and local distribution the air temperature 'shall only be measured by at least one easily visible thermometer'; open cabinets must have the maximum load line marked and the thermometer must read 'at the air return side at the level of that mark'. Regulation 9(4) of the England 2007 Regulations adds that there is no breach for 'a cold store facility with a capacity of less than 10m3 used for storing stock in retail outlets' where air temperature is measured 'by an easily visible thermometer'.

What's agreed, and what isn't

The exemption covers only quick-frozen food recording rules. It does not remove the general HACCP duty under 852/2004 to monitor critical control points, so a retailer may still choose to record. Scotland applies the same small cold store exemption through SSI 2007/106. The recital to 37/2005 explains that recording on small retail equipment 'would be excessive'.

Status
Law
Applies to
Food retail, Catering, Food distribution and transport
Last checked
18 October 2026
Do vehicles and cold stores carrying quick-frozen food need EN 12830 temperature recorders?Law

Retained Regulation (EC) No 37/2005, Article 2, requires the means of transport, warehousing and storage of quick-frozen foodstuffs to be fitted with recording instruments monitoring air temperature 'at frequent and regular intervals'. The instruments must comply with EN 12830, EN 13485 and EN 13486, operators must keep documents showing conformity, and recordings must be dated and kept 'for a period of at least one year, or for a longer period taking into account the nature and the shelf life'. ATP Annex 2 Appendix 1 sets the same for international carriage, requiring EN 12830:2018 recorders verified under EN 13486:2002 by an accredited body.

What's agreed, and what isn't

Article 3 allows retail display cabinets and local distribution to use 'at least one easily visible thermometer' instead, and lets the competent authority allow a visible thermometer for retail cold stores under 10 m3. The regulation does not specify the recording interval; 'frequent and regular' is unclear. ATP still cites EN 13486:2002, but BSI lists BS EN 13486:2023 as current, so the cited editions differ; ask your supplier which edition the verification certificate follows.

Status
Law
Applies to
Food distribution and transport, Cold stores, Food retail
Last checked
18 October 2026
What does Irish law say about frozen food temperatures and tolerances?Law

The European Communities (Quick-frozen Foodstuffs) Regulations, 1992 (S.I. No. 290 of 1992), Regulation 7(1), require quick-frozen foodstuffs to be kept 'at -18°C or lower', with the exception that the temperature 'may briefly fluctuate upwards by not more than 3°C during transport'. Regulation 7(2) allows tolerances in local distribution and in retail display cabinets which 'shall not exceed 3°C'. The FSAI lists S.I. 290/1992 and S.I. 370/1995 as the current national instruments for quick-frozen food.

What's agreed, and what isn't

The −18 °C rule is statutory only for food sold as 'quick-frozen'. For other frozen food the FSAI advises freezers 'should be maintained at -18° C or colder in food businesses', with ice cream allowed at −12 °C in food service areas; that is guidance. The tolerances apply to the product temperature, not the air, and the regulations do not specify how long 'briefly' is. The Irish instruments were written to implement Council Directive 89/108/EEC and later Commission Directives; the monitoring rules at EU level are now in Commission Regulation (EC) No 37/2005, which applies directly.

Source
S.I. No. 290/1992 - European Communities (Quick-Frozen Foodstuffs) Regulations, 1992 Office of the Attorney General (Irish Statute Book), 9 October 1992
Status
Law
Applies to
Cold stores, Food distribution and transport, Food retail, Food manufacturers, Catering
Last checked
18 October 2026
What temperature must quick-frozen food be kept at, and what tolerance is allowed?Law

Schedule 2 to the Quick-frozen Foodstuffs (England) Regulations 2007 requires quick-frozen food to reach '−18 °C or colder' after thermal stabilisation and then be 'maintained at a level no warmer than −18 °C' except under a permitted exception. The exceptions are: kept 'within brief periods during transport (including local distribution) at a temperature warmer than −18 °C but not warmer than −15 °C', or kept 'in a retail display cabinet at a temperature warmer than −18 °C to an extent consistent with good storage practice but not warmer than −12 °C'.

What's agreed, and what isn't

So the transport tolerance is 3 °C (to -15 °C) for 'brief periods', and retail cabinets may reach -12 °C. The law does not define 'brief periods'. The figures apply to products labelled as quick-frozen, not to all frozen food, and ice cream is excluded. Wales (SI 2007/389) and Northern Ireland (SR 2007/110) have the same figures. Scotland still uses the Quick-frozen Foodstuffs Regulations 1990 (as amended by SSI 2007/106) with the same -18, -15 and -12 °C limits.

Source
The Quick-frozen Foodstuffs (England) Regulations 2007 UK Parliament (legislation.gov.uk), 30 September 2022
Status
Law
Applies to
Cold stores, Food distribution and transport, Food retail, Food manufacturers
Last checked
18 October 2026
What temperature recording is legally required for frozen food stores and vehicles?Law

Article 2 of Commission Regulation (EC) No 37/2005 requires the means of transport, warehousing and storage of quick-frozen foodstuffs to 'be fitted with suitable recording instruments to monitor, at frequent and regular intervals, the air temperature'. Instruments 'shall comply with EN 12830, EN 13485 and EN 13486 standards' and operators must keep documents showing conformity. 'Temperature recording shall be dated and stored by the food operator for a period of at least one year, or for a longer period taking into account the nature and the shelf life of the quick-frozen foodstuffs.'

What's agreed, and what isn't

This is the only UK temperature law with a specific record retention period. It does not specify the recording interval ('frequent and regular') or a calibration frequency, although EN 13486 covers periodic verification. Breach is an offence under regulation 9 of the England 2007 Regulations (and equivalents), and records must be made available to an authorised officer on request (regulation 8).

Status
Law
Applies to
Cold stores, Food distribution and transport, Food manufacturers
Last checked
18 October 2026
What freezer temperature does SFBB for retailers give, and how often should freezers be checked?Guidance

SFBB's 'Frozen storage and display' safe method for retailers says: 'It is good practice to keep frozen food at -18˚C or colder.' It adds that food labelled 'Quick frozen' 'must be stored at -18˚C or colder, or displayed at -12˚C or colder'. You should check freezing equipment temperatures 'at least once a day starting with your opening checks', and check in between frozen food as well. Food that has begun to defrost should be thrown away unless it is meant to be sold defrosted, and must not be refrozen.

What's agreed, and what isn't

For general frozen food, −18 °C is described as good practice, not a legal limit, in this guide. For food sold as quick-frozen, the −18 °C storage figure and the −12 °C retail cabinet limit are in law: Schedule 2 to the Quick-frozen Foodstuffs (England) Regulations 2007 (see the quick-frozen item). Scotland's RetailSafe says it may be sufficient to check that freezer contents are 'still obviously frozen', with occasional thermometer checks.

Status
Formal guidance
Applies to
Food retail, Catering
Last checked
18 October 2026
Can cold stores raise frozen set points from -18 °C to save energy?Interpretation

The Cold Chain Federation says -18 °C has been the standard 'for well over 100 years' and that evidence suggests that for most products it 'could be overly risk averse', citing -15 °C as an example of a higher set point. It also says 'more research and collaboration is needed' and that the new temperature is still undetermined.

What's agreed, and what isn't

This is an industry position, not a change in law or standards. ATP Annex 2 still requires -18 °C for quick-frozen food in international carriage, and quick-frozen food law still applies in the UK; customer specifications and BRCGS audits follow the product specification. Do not change set points for quick-frozen products without checking legal requirements and the product owner's specification. The page is undated and refers to a survey due in summer 2024, so it may be out of date.

Source
Increasing Temperature Set Points For Frozen Food Cold Chain Federation, undated
Status
Interpretation
Applies to
Cold stores, Food distribution and transport
Last checked
18 October 2026
What do ATP class codes such as FRC mean, and how long does an ATP certificate last?Law

ATP Annex 1 defines mechanically refrigerated Class C equipment as able to choose an inside temperature 'between + 12 °C and -20 °C inclusive'; FRC is the mark for Class C mechanically refrigerated equipment with heavy insulation. Annex 1 Appendix 1 requires checks before entry into service, 'periodically, at least once every six years' and when the authority requires. Multi-compartment road equipment with two compartments is marked with both marks (for example FRC-FRA); other multi-compartment equipment uses the highest class plus M (for example FRC-M), mandatory for equipment built from 1 October 2020. GOV.UK says the initial certificate lasts 6 years, then the vehicle or trailer must be retested every 3 years.

What's agreed, and what isn't

The ATP text also allows in-service examinations that extend approval by three or six years depending on the test carried out, so the UK DVSA summary (retest every 3 years) is a simplification; check with the testing station. Certificates or a certification plate must be carried on the equipment. ATP class does not by itself prove the load stayed in temperature; monitoring still applies. GOV.UK lists Cambridge Refrigeration Technology and three other providers for renewals.

Status
Law
Applies to
Food distribution and transport
Last checked
18 October 2026
What temperatures does ATP require for frozen and quick-frozen food in transit, and is a defrost rise allowed?Law

ATP Annex 2 requires the food at any point of the load to be at or below: ice cream -20 °C; frozen or quick-frozen fish, fish products, molluscs and crustaceans and all other quick-frozen foodstuffs -18 °C; all other frozen foodstuffs (except butter) -12 °C; butter -10 °C. Paragraph 4 allows, during operations such as evaporator defrosting, 'a brief rise of the temperature of the surface of the foodstuffs of not more than 3 °C in a part of the load'. Annex 2 Appendix 2 also allows, in measurement, a brief operational rise of up to 3 °C at the surface and up to 2 °C methodology tolerance for non-destructive (between-pack) readings.

What's agreed, and what isn't

The defrost allowance is about surface temperature of the food, not air, and 'brief' is not specified in minutes; that is unclear. Air sensors will show larger swings during defrost, so alarm delays are a site decision. The Cold Chain Federation is exploring higher frozen set points (for example -15 °C) but this does not change ATP or quick-frozen law.

Status
Law
Applies to
Food distribution and transport, Cold stores
Last checked
18 October 2026
Do BRCGS standards require temperature mapping of a cold store or chiller, and how often?Guidance

BRCGS Storage and Distribution Issue 4, clause 7.3.7, requires that where temperature, humidity or controlled-atmosphere stores are used, the uniformity of the condition (for example temperature distribution) is 'established, validated and verified at a frequency based on risk', or that restrictions on product placement are identified. Clause 7.3.8 requires performance to be re-established after changes to equipment. BRCGS Food Safety Issue 9, clause 6.1.5, says that where conditions can vary within equipment critical to safety or quality, its characteristics are validated and verified at a frequency based on risk and performance, and gives temperature distribution in freezers and cold stores as an example.

What's agreed, and what isn't

Paraphrased; checked against the standard. Mapping frequency is not specified; it is risk-based. The standard is silent on the number of sensors, test duration, loaded versus empty studies, or seasonal repeats. Food Safety Issue 9 puts mapping in process control (6.1.5) rather than storage (4.15), and sets no method either. A business needs its own decision, for example map at commissioning, after layout or refrigeration changes, and periodically; agree it with your auditor.

Status
Formal guidance
Applies to
Cold stores, Food distribution and transport
Last checked
18 October 2026
What temperatures does the law set for fresh and frozen fish?Law

Regulation 853/2004, Annex III, Section VIII, Chapter VII: fresh fishery products 'must be maintained at a temperature approaching that of melting ice' (point 1), and frozen fishery products at 'not more than – 18 °C in all parts of the product', except whole fish frozen in brine for canning, which may be 'not more than – 9 °C' (point 2). In transport, frozen fish must be kept at 'an even temperature of not more than – 18 °C in all parts of the product, possibly with short upward fluctuations of not more than 3 °C' (Chapter VIII, point 1(b)).

What's agreed, and what isn't

The law gives no number for 'melting ice'; see the separate question on what it means in practice. Live fishery products are kept at 'a temperature and in a manner that does not adversely affect food safety or their viability', again with no number. Smoked fish has no specific figure in 853/2004; vacuum-packed smoked fish is governed in practice by the FSA's C. botulinum guidance. In the EU (Northern Ireland and Ireland), Delegated Regulation 2024/1141 now lets fish be held at the temperature needed for slicing for up to 96 hours.

Status
Law
Applies to
Food manufacturers, Cold stores, Food distribution and transport, Food retail
Last checked
19 October 2026

Keep reading

Other topics

20-minute compliance check

How would your next audit or EHO visit go on temperature?

In 20 minutes we go through your stores, vehicles, alarms, calibration and records with you. You get the gaps in writing. No product tour.