IoT Solutions Malta

What the law requires you to record in a frozen load

Quick-frozen food in transit carries a specific EU recording obligation, and a specific minimum retention period. Both are more concrete than operators expect.

Commission Regulation (EC) No 37/2005 governs temperature monitoring in the transport, warehousing and storage of quick-frozen foodstuffs intended for human consumption. It requires that the means of transport be fitted with suitable recording instruments to monitor, at frequent and regular intervals, the air temperature to which the foodstuffs are subjected.

Two details in that sentence do real work. The instrument must record, not merely display, so a thermometer a driver reads and writes down does not satisfy it. And it monitors air temperature at frequent regular intervals, which means a continuous log rather than a reading taken at loading and another at delivery.

The records must be dated and kept for at least one year, and longer where the nature and shelf life of the foodstuff warrants it. Note the floor: one year is a minimum, not a target. Yipii sets sensor history retention by contract, typically around five years, which clears the one-year floor comfortably and covers shelf-life-driven extensions.

Separately, Regulation (EC) No 852/2004 places the general food hygiene obligations on the operator, including the requirement to identify and control hazards. Temperature during transport is a control point in most HACCP plans that involve chilled or frozen goods, which is why the transport leg is usually where the evidence gap shows up in an audit.

A sensor reporting continuously closes that gap in both directions. It alerts while a load is still recoverable, and it produces the dated record afterwards. What it does not do is write your HACCP plan or calibrate your instruments. Both of those stay with the operator and their food safety adviser, and any supplier who implies otherwise is overselling.

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