Food hygiene law requires vehicles to hold food at the right temperature and to let that temperature be monitored. The ATP agreement adds equipment classes and food temperatures, but only for international journeys. For UK-only deliveries the evidence your customer or EHO wants is the journey record: pre-cool, loading time and each compartment's temperature.
Why it matters
The vehicle is where the record usually stops
A chill store has walls, a stable load and a fixed probe. A delivery vehicle opens its doors at every drop, may carry chilled and frozen loads side by side, and is often on a different system from the depot, or on none. When a customer rejects a load or an EHO asks what happened between dispatch and delivery, the answer depends on whether anyone recorded the journey.
Enforcement shows the risk. The FSAI's December 2025 closure orders included 'the use of an unrefrigerated vehicle for transporting meat with no controls in place to maintain the cold food chain' (FSAI 2025 enforcement report), and the FSA and FSS Our Food 2024 review names 'concerns over temperature controls and poor hygiene during processing or transport of meat' among the causes of food incidents.
What the rules say
Hygiene law: hold it and let it be monitored
Regulation 852/2004, Annex II, Chapter IV says that 'where necessary, conveyances and/or containers used for transporting foodstuffs are to be capable of maintaining foodstuffs at appropriate temperatures and allow those temperatures to be monitored'. It also requires vehicles to be clean and in good repair, with effective separation between loads. The chill and hot holding limits in Schedule 4 apply in transit too, and paragraph 5 gives a defence for food above 8 °C 'for a limited period only' while it is transferred between premises and a vehicle.
Two sets of rules go further. For quick-frozen food, Regulation 37/2005 requires EN 12830 recording instruments in the means of transport and a year of dated records, though local distribution may use an easily visible thermometer instead (Article 3). Approved establishments under 853/2004 must keep meat at 7 °C, offal at 3 °C and poultry at 4 °C during transport.
ATP: international journeys only
The ATP agreement sets equipment classes and food temperatures for international carriage of perishable food, where loading and unloading 'are in two different States'. The DVSA guidance says the rules apply to transport to or from ATP countries and 'there are different rules if you're only transporting perishable food within the UK'. So a UK-only fleet does not need ATP certificates, though many customers ask for ATP-class vehicles as a specification.
Where it applies, ATP is specific. Annex 3 gives maximum food temperatures for chilled loads: red meat 7 °C, poultry 4 °C, offal 3 °C, minced meat 2 °C, and 6 °C for dairy, meat products and ready meals unless the label says otherwise. Annex 1 defines classes: an FRC unit can hold any inside temperature 'between + 12 °C and -20 °C inclusive'. Multi-compartment vehicles are marked with both classes or with an M, and equipment is retested 'at least once every six years', with GOV.UK describing a three-yearly retest after the first six years.
Food (not air) temperatures for international journeys under ATP, as amended June 2024. In GB, the general chill limit is 8 °C (Schedule 4); 853/2004 sets the same 7, 4, 3 and 2 °C figures for approved establishments.
What good looks like
Pre-cool, load fast, record the load space
BRCGS Storage and Distribution Issue 4 gives the clearest picture (paraphrased): validate that vehicles hold temperature in all weather at minimum and maximum load (5.4.1); record load-space temperature automatically, with records readily accessible, or by recorded manual checks where there is no such equipment (5.4.2); verify settings and pre-cool before loading or reach temperature within a defined time (5.4.3); alert the driver when the load leaves its limits (5.4.5); and have procedures to settle product status after equipment failure, before release to the customer (5.4.6). BRCGS Food Safety Issue 9 clause 4.16.3 is lighter and also accepts records of refrigeration unit operation.
Multi-temperature vehicles need each compartment treated as its own store: its own set point, its own sensor and its own alarm, with the bulkhead position recorded at loading. Doors are the main risk on multi-drop routes, so plan the load in drop order and keep chilled and frozen doors shut while the other compartment is worked.
- Pre-coolLoad space at set point before loading, reading recorded.
- Load in drop orderDoors open only as long as needed; product off the dock quickly.
- Record the journeyEach compartment logged, with alerts to the driver.
- Check at the dropReceiver probes between packs and checks the record.
- Act on excursionsQuarantine, tell the product owner, decide and record.
Drawn from 852/2004 Chapter IV, BRCGS Storage and Distribution 5.4 (paraphrased) and FSA and FSAI delivery guidance.
Worked example
A rejected delivery on a hot afternoon
This is an illustrative example; times and readings are invented. A distributor runs a two-compartment vehicle on a twelve-drop route: chilled at 3 °C, frozen at −20 °C.
Thursday 13:20, drop 7 takes longer than planned and the chilled door is open for 18 minutes. 13:30, the driver alert fires at 7.2 °C air. 13:45, the next customer probes between packs, reads 7.8 °C and, following its acceptance limit of 5 °C, rejects the chilled lines.
What the distributor does: pulls the journey record, which shows the door event and a recovery to 4 °C by 14:05, and gives it to the product owner, who assesses the product. What changes: the route is re-sequenced so the slow drop goes last, and a strip curtain is fitted to the chilled compartment.
Where it is unclear
Domestic limits and unit records
For UK-only journeys the GOV.UK page does not say what the domestic rules are; they come from hygiene law, 853/2004 for approved meat, and the quick-frozen rules. Whether a refrigeration unit record is enough evidence for high-risk loads is also open: BRCGS Food Safety accepts it, Storage and Distribution asks for load-space records. Both are compared under transport monitoring.
No source we checked gives a figure for dock dwell time, door-open time or pre-cool time. BRCGS Storage and Distribution 7.3.4 asks you to set 'maximum limits for the period of time that particular types of product may remain outside a temperature-controlled environment', which is why our recommendation gives one.
Inspection findings
What the published findings show
The FSAI reported 133 enforcement orders in 2024 and named 'failure to maintain correct temperatures of foodstuffs' among recurring issues, with an unrefrigerated meat vehicle among the December 2025 closures. In the UK there is no published national dataset of transport temperature findings; Our Food 2024 links meat incidents partly to temperature control in processing and transport but does not count them.
In summary
The short version
- Hygiene law asks that vehicles can hold food at the right temperature and let it be monitored.
- ATP applies to international journeys only; UK-only fleets follow hygiene law and customer specifications.
- Quick-frozen loads need EN 12830 recorders and a year of records, except in local distribution, where a visible thermometer is allowed.
- Pre-cool, load in drop order, and treat each compartment as its own store.
- Record the journey and review it before the next shift.
- Set and record your own dock dwell and door-open limits; no source gives a figure.