When cold goods travel in a vehicle that is not refrigerated, the question to ask is not about the vehicle. It is about the container holding the load. Turkey's Food Hygiene Regulation sets four separate conditions for that container, and all four concern the object itself rather than any paperwork.
First: it has to be cleanable
Article 13 requires vehicles and containers used for carriage to be kept clean, maintained in good condition, and where necessary designed and built to allow adequate cleaning and disinfection, so that food is protected from contamination.
Cleanability is a design property. A container with sharp internal corners, a rough weld seam and a gasket that cannot be removed will leave dirt in the same place after every wash.
Second: it is used for food only
The second paragraph of the same article is explicit: receptacles inside vehicles and containers are not used for carrying anything other than food, because of the risk of contamination. A box that carried a paint tin in the morning cannot carry cheese in the afternoon.
Third: material and upkeep
Article 14 requires materials, tools and equipment in contact with food to be made so as to minimise the risk of contamination, to be produced from material fit for that purpose, and to be kept in working order and well maintained. The same article adds that where chemicals are needed to prevent corrosion, they must be used according to good practice.
Because the obligation moves from the vehicle to the container, in any decision about cold carriage in a standard vehicle the container's paperwork comes first.
Fourth: it must allow the temperature to be monitored
The seventh paragraph of Article 13 requires vehicles and containers, where necessary, to keep the food they carry at appropriate temperatures and to be capable of allowing those temperatures to be monitored. In a closed container that means leaving a measuring point inside: a cable route, a slot for a recorder, or an arrangement that can be read without opening the lid.
| Condition | Where it shows on the container |
|---|---|
| Cleanability | internal corners, gasket, removable shelf |
| Food-only use | internal labelling and a rule of use |
| Material and upkeep | food-safe shell, repairable panel |
| Temperature monitoring | measuring point or recorder position |
An extra marking for non-prepacked goods. For non-prepacked food in liquid, granulate or powder form, the fourth paragraph of Article 13 requires a separate marking: the container is marked clearly and indelibly, in Turkish, with the words meaning For Foodstuffs Only. Indelible means the label has to survive washing.
The exception for single-use containers
Article 14 holds non-returnable transport receptacles and packaging materials outside the cleanability requirement. A single-use box is not expected to be washable; the price of that is a new box every time.
