Fifteen years on the plate: changing the body to stay in the cold chain

The maker's plate on the door pillar carries a date, and the model year on the registration document points at the same figure. In perishable-food transport that date eventually becomes the number that closes the file, however well the vehicle has been looked after, because the age of the equipment is the first thing certification looks at.

The same number reaches the file from the domestic side as well. Under Article 19(1) of the regulation, a Perishable Food Transport Certificate is issued to special transport equipment that holds no ATP conformity certificate and is not more than fifteen years past its date of manufacture. For a truck that never leaves the country the practical effect is plain: the year the ATP class falls away is also the year the domestic certificate reaches its ceiling, so both doors close on a single calendar date.

A second paragraph added to Article 19 of the same regulation by the Official Gazette of 21/2/2025, No. 32820, opens a door beside that closed file. Where a vehicle cannot be issued a Perishable Food Transport Certificate because its model year puts it past fifteen, replacing its body with an ATP-compliant body moves certification onto the ATP legislation, and the vehicle may go on carrying perishable foodstuffs. The question therefore stops being about the scrapyard and turns into a question about the body.

When the body changes, the file changes lane with it: the vehicle leaves the domestic certificate behind, joins the ATP certification route, and its first application goes to the approval body. That paperwork never stands on its own, since Article 14(5) requires every ATP conformity certificate to refer back to the ATP type test report, while Article 11(10) puts the type test report in the manufacturer's name and issues the conformity certificate in the name of the equipment owner or operator. Those are the two lines to read first on the document that reaches you: which type test report the body rests on, and whose name the certificate carries.

The gap between those two coefficients is read again in the fifteenth year. The paragraph quoted earlier treats heavily insulated equipment as normally insulated from that year onwards, and its second sentence bars certification for normally insulated equipment past fifteen years, yet how the two sentences meet on one and the same body does not follow from the text alone. The answer is written at the inspection bench: under Article 12(7), the insulation class of the equipment may be changed on the report of an approval body expert following periodic inspection and testing.

Because the class rests on a report, two further moments in the life of a body are fixed as well. Article 12(6) makes it the user's own obligation, after an accident, an impact or any comparable event, to have the equipment checked for whether the type approval conditions still hold, and this exceptional inspection runs through the same procedure as the periodic one. For equipment carrying a Perishable Food Transport Certificate, Article 19(7) sends any repair, alteration or replacement on the insulated body or on the refrigeration or heating unit above it to an exceptional inspection. On either route, touching the superstructure leaves a trace in the file.

The distinction reorders the spending too, since a vehicle stays in the cold chain on the insulating performance of its shell, so the money goes into the body first and into the hardware bolted to it afterwards. The same logic reaches inside the body: a round built on insulated containers that hold the temperature within their own walls shifts part of the work away from the superstructure and onto the boxes.

Anyone weighing the delivery side before committing to a new body can start from the comparison on our refrigerated vehicle alternative page.

The work waiting on either side of that six-month window differs. Article 14(3) says that where the equipment consists of an unused insulated body, together with an unused heating or cooling unit if one is fitted, built on a type approval test, no physical inspection is required for the certificate. Article 14(4) sends the used case through a periodic inspection at first certification and makes the certificate depend on a favourable result. Who files the application is settled in Article 14(2): a customer who has bought equipment conforming to the approved type may go to the approval body directly.

A body bought abroad is read against a different article. Article 17 ties the national ATP conformity certificate for equipment manufactured in another country and registered here to three documents: a type test report drawn up by the competent authority of an ATP contracting party, or for series production the type test report of the reference equipment of that series; the ATP conformity certificate issued by the competent authority of the country of manufacture, or for equipment already in service the one from the country where it was previously registered; and, for series-produced equipment, a manufacturer's declaration of the technical characteristics. The same article leaves the approval body free to put used equipment through a periodic inspection where it sees the need. For a buyer who has found a well-priced second-hand insulated body in Europe, whether those three documents exist is the question that comes before any look at the body itself.

The line these articles draw stops there. Between them, the regulation and ATP fix the K coefficient of the body, the route its certificate takes and the calendar it runs on; neither of them says how many doors it needs, how the inside is arranged, what the floor has to carry, or which body earns its keep on a round with many stops a day. That part is set by the route, the loading pattern and the goods themselves, it stays with the carrier, and the cost side of the decision is worked out over the two lines above.