A distributor who serves eighteen stores out of one warehouse usually calls with a single question after reading the amendment of 21 February 2025: if the round never crosses the municipal boundary, what is the driver still expected to carry? The answer differs from the one that held a few years ago, because a new paragraph was added to the scope article of the regulation in February 2025.
Paragraph (c), added to Article 2(2) of the Regulation on Special Equipment to be Used in the Carriage of Perishable Foodstuffs by the Official Gazette of 21/2/2025 no. 32820, leaves urban carriage of perishable food outside the scope of that regulation. Where a round starts and ends inside the city, this regulation is no longer the ground for asking a vehicle for an ATP Certificate of Compliance, nor for the Perishable Food Transport Certificate that stands in for it domestically.
The municipal boundary draws the line. Counting kilometres will not tell you which side of the scope you are on, because paragraph (v), added to Article 4(1) by the same amendment, ties the term to an administrative border: the boundary of a city together with the adjacent area of the same municipality counts as urban. Open the text and the exemption sits in the scope article while the yardstick for it sits in the definitions article, so the two have to be read side by side. In a metropolitan province that definition can swallow a long delivery round whole, while in a small district a store minutes from the depot may sit in the neighbouring municipality, and that one stop carries the whole round back into scope. The exemption describes the trip rather than the plate, so a van working inside the city in the morning falls back under the regulation once it crosses out of the city boundary and its adjacent area into a neighbouring municipality after lunch, which makes the certificate question part of route planning.
| Where the round goes | What the regulation says |
|---|---|
| City boundary and the adjacent area of the same municipality | Out of scope, Article 2(2)(c) |
| A single stop in the neighbouring municipality | In scope, the certificate regime applies |
| Equipment without an ATP certificate, under 15 years from manufacture | Perishable Food Transport Certificate, Article 19(1) |
| Equipment running on that certificate | Periodic inspection every 3 years, Article 19(6) |
The exemption does not lift the duty to hold temperature
Sitting outside the certificate regime does not mean the load may travel at whatever temperature the day supplies. Article 13(7) of the Food Hygiene Regulation requires vehicles and containers carrying food to keep it at suitable temperatures where necessary and to allow those temperatures to be monitored, while Article 22(1) of Law no. 5996 puts the operator under a duty to meet the conditions of the law at every stage of its own activity and to verify that it has. Neither provision names a device or hands you an equipment list, so which box, which cold source and which record will do the job is left to the carrier to settle. With no inspection certificate to hand over, the proof gathers in those same places: the insulation of the box, the lid seal, the cold source placed inside and the temperature record kept through the delivery.
Since the equipment is the only evidence a city operator has left, choosing a container for urban cold distribution turns into a food safety decision of its own.
ISO 23412:2020 shows the same arrangement from another side: among the cases it puts outside its own scope, item (b) separately names parcels carried at ambient temperature that hold their own refrigerant, an ice pack, a chilled foam block or dry ice, and are enclosed in leak-proof thermal packaging. An unrefrigerated vehicle working together with a closed box that brings its own cold has a name and a place in an international standard. That is exactly where urban distribution stands today: the transport certificate has left the table, the duty to keep food at a suitable temperature stayed where it was, and nothing except the equipment itself and the records it keeps is left to show for it.
