Everyone who handles frozen loads knows two numbers: -18 and 3. When they are linked the wrong way, you hear 'it is fine down to -15 °C anyway' on the dock, yet the text of the Communiqué says nothing of the kind.
Article 5(1)(d) of the Turkish Food Codex Communiqué on Quick-Frozen Foods (2014/47) is still in force as published in 2014: the product is kept at -18 °C or colder at every point, and the 3 °C allowance applies only to possible short rises and only at certain stages.
| Stage | Product temperature | 3 °C allowance |
|---|---|---|
| Storage after quick freezing | -18 °C or colder at every point | Not granted |
| Transport and distribution | -18 °C or colder at every point | Up to 3 °C for a short rise |
| Retail display cabinet | -18 °C or colder at every point | Up to 3 °C for a short rise |
The allowance exists for the unavoidable swing when a door opens or a load is transferred. Carrying product routinely at -15 °C turns it into an operating temperature, and when a real excursion happens there is no margin left.
Is it the air or the product being measured
The rule describes the product, while a logger usually records the air in the body. Air warms and cools much faster than product: the air can read -16 °C while a carton in the middle of the pallet sits at -19 °C, and after a long door opening the outer rows stay warm while the air is quickly back to normal. That is why ambient records and product readings are kept apart.
Record-keeping sits in the sister text, Communiqué 2014/48 on temperature monitoring: ambient temperature is logged at regular intervals with devices conforming to TS EN 12830, and records are kept for at least one year. In official controls, Article 5(1)(f) of 2014/47 provides for random temperature checks.
Most of the allowance is spent at transfers, at door openings on multi-drop rounds and on loads waiting at the dock. An insulated container produces no cold; it slows the rate at which the cold stored in the product and in eutectic plates is used up. Matching door-opening times against the temperature record shows at which step the allowance is being eaten.
