Published: 24.09.2026. · HACCP

Frozen-food temperatures in transport and storage: Montenegro’s new 2026 rules

Publisher: ConsultHQ

Montenegro introduced a new framework for quick-frozen food and temperature monitoring in transport, warehousing and storage in 2026. Rulebook 122/2026 sets requirements for suitable temperature measuring and recording instruments. Regulation 98/2026 sets the broader regime for quick-frozen food, aligned with EU rules.

For distributors, cold stores, logistics companies and food producers, compliance means more than knowing whether a chamber is cold enough. They need evidence of the conditions to which the product was exposed throughout the relevant part of the chain. Temperature monitoring is therefore part of the food-safety system, not merely a technical function.

The new Quick-Frozen Food Regulation has applied since 17 July 2026

The Regulation on Quick-Frozen Foodstuffs Intended for Human Consumption was published in Montenegro’s Official Gazette 98/2026. It entered into force on 17 July 2026 and replaced the earlier rulebook on detailed conditions for quick-freezing food.

When adopting it, the government stated that the aim was full alignment with the EU acquis in this area. It provides the basis for specific rules on temperature monitoring and control methods.

A specific temperature-monitoring Rulebook has applied since 25 August

The Rulebook on Monitoring Temperatures in Means of Transport, Warehouses and Storage Areas for Quick-Frozen Foodstuffs Intended for Human Consumption was published in Official Gazette 122/2026 on 17 August. It entered into force on 25 August 2026.

According to the official food-safety authority, it sets particular requirements for:

• temperature monitoring during transport;
• warehousing and storage of quick-frozen food;
• temperature measuring instruments;
• devices that record temperature data.

It transposes Commission Regulation (EC) No 37/2005 into Montenegrin law.

EU rules require regular cold-chain monitoring

Regulation 37/2005 covers monitoring in vehicles, warehouses and storage areas used for quick-frozen food. Relevant facilities and vehicles must have suitable instruments recording the air temperature to which products are exposed at frequent, regular intervals.

This is different from an occasional manual reading. A single reading in the morning cannot show what happened several hours earlier. Records make it possible to reconstruct the temperature history for the relevant period.

The basic EU regime for quick-frozen food is −18 °C

The European framework defines quick-frozen food through a rapid freezing process after which product temperature is maintained at −18 °C or lower at all points in the product. EU rules permit only short variations within specified limits during transport.

Operators must distinguish between:

• air temperature in the chamber or vehicle;
• temperature of the product itself;
• permitted short-term variations;
• conditions relevant to deciding the product’s status.

A temperature shown on a cold-room display is not, by itself, a complete control system.

Measuring instruments must meet technical requirements

Regulation 37/2005 links temperature monitoring to European instrument standards. It refers to EN 12830, EN 13485 and EN 13486 for equipment used to measure, record and verify temperatures.

Buying any data logger is not enough. The operator needs documentation showing that the instruments are suitable for their purpose and meet the applicable technical requirements. This may be reviewed during an official or customer inspection.

Temperature records must be retained

EU Regulation 37/2005 requires dated temperature records to be kept for at least one year, or longer where the nature and shelf life of the quick-frozen food justify it.

An operator should know where records are held, who can access them, how long they are kept, which vehicle or store and period they cover, and what happens when a record shows a deviation. Digital recording is appropriate if data remain reliable and accessible.

A cold store or vehicle is more than refrigeration equipment

A common mistake is to leave temperature control entirely to the refrigeration technician. Equipment maintenance matters, but the food-safety system must also establish who reviews data, who responds to an alarm, how affected goods are identified and who decides their status.

Without those answers, the business has refrigeration equipment but lacks a complete cold-chain control process.

A temperature deviation should be recorded and assessed

An alarm does not automatically make a product unsafe. Nor should it be ignored because the temperature later returned to range. The operator should establish what happened.

Duration, measured temperatures, affected products and other relevant facts can change the decision. The event should be linked to deviations and corrective actions. Repeated events call for a review of the underlying cause.

Transport is part of the cold chain

Food can be stored correctly and still lose temperature control during transport. The new Rulebook expressly covers means of transport. A logistics company should be able to demonstrate conditions during the journey, including when an external carrier is used.

Food manufacturers and distributors should not assume their responsibility ends when a truck leaves the loading bay. Contractual responsibilities and temperature requirements should be clear.

Storage controls should connect to HACCP

Temperature control for quick-frozen food is not a separate technical project outside HACCP. Where temperature matters to product safety or quality, it should connect to procedures, responsibilities and records.

The HACCP system should show where temperature is controlled and how the organisation handles deviations. The temperature-monitoring Rulebook 122/2026 adds specific technical requirements for transport and storage. Both levels should work together.

A separate Rulebook also covers official sampling of quick-frozen food

The Rulebook on Specific Requirements for Sampling Procedures and Laboratory Analysis Methods for Quick-Frozen Food was published on the same day as the temperature-monitoring Rulebook and entered into force on 25 August 2026.

The new framework therefore concerns more than a single thermometer: it connects the product, storage conditions and methods used to assess compliance.

Frozen-food distributors should review their carriers

A company can have an excellent warehouse but poor evidence of conditions during outsourced transport. Requirements for a third-party carrier may cover:

• appropriate temperatures;
• measuring and recording devices;
• access to data;
• notification of deviations;
• procedures for breakdowns;
• retention of temperature records.

There is no need for an unnecessarily complex agreement, but responsibilities should not be left unclear.

Cold stores should review more than maintenance records

Refrigeration service documents do not by themselves prove that a food warehouse complies. The business needs data showing actual storage conditions. Review instruments, records, alarms, calibration or other appropriate checks, access to data, review responsibilities and response to deviations.

If a digital system reliably covers these needs, parallel paper tables add no value.

Small shops should not automatically be treated as distribution centres

EU rules contain specific provisions for local distribution and retail display cabinets. Requirements for a large warehouse should not automatically be applied to every small freezer in a shop. The exact obligation depends on the activity and the applicable national rule.

The central responsibility remains: quick-frozen food must be held under conditions that maintain its required temperature regime.

What manufacturers and distributors should check now

After 25 August 2026, operators handling quick-frozen food should review their temperature-control system. Check:

• which warehouses and vehicles fall within scope;
• which instruments monitor them and whether they meet applicable requirements;
• where records are stored and for how long;
• who reviews readings and how deviations are recorded;
• how external carriers are covered;
• whether HACCP documents match actual controls;
• whether contracts and procedures reflect the temperature-monitoring Rulebook 122/2026.

This is more useful than simply adding a new rulebook title to a HACCP folder.

New rules do not automatically require replacing all refrigeration equipment

The first step is to assess the existing instruments and documents. If they provide reliable evidence and satisfy the applicable requirements, an unnecessary replacement is not needed.

If the system cannot produce verifiable records, there is a genuine gap. A project should therefore begin with a technical and documentation review, not an uninformed equipment purchase.

ConsultHQ can review the cold chain in a HACCP gap analysis

Temperature monitoring works when it is connected to the operation. ConsultHQ can review warehousing, transport, existing temperature records, procedures and HACCP documentation against the 2026 framework.

Where outside carriers are used, the review can include contractual responsibilities and evidence supplied by the logistics partner. The aim is a system that shows where the product was, under which conditions and how the business responded to a temperature deviation.

Related services: warehouse and logistics systems, HACCP for food production and gap analysis.

Official sources: Quick-Frozen Food Regulation (98/2026); Temperature Monitoring Rulebook (122/2026); Montenegrin food-safety authority notice; EU 37/2005.

← All articles