What the European cold chain covers and why it matters
Europe’s cold chain spans temperature-controlled production sites, cross-docking, long-haul and urban transport, and specialized warehouses. It is governed by a blend of international and EU rules: the ATP Agreement defines performance classes for insulated and refrigerated road equipment; EU food hygiene law requires HACCP-based controls; and pharmaceutical wholesale is governed by Good Distribution Practice (GDP). Across these layers the common thread is continuous temperature control, documented monitoring, and product integrity from origin to last mile.
Core compliance anchors: HACCP and GDP
For food, Regulation EC 852/2004 establishes hygiene duties and HACCP-based procedures, reinforced by the European Commission’s 2022 guidance on Food Safety Management Systems FSMS that harmonizes how operators implement GHP/HACCP and embeds the concept of food-safety culture. For forwarding services for the pharmaceutical industry, the EU GDP Guidelines require risk-based temperature control, route planning that minimizes thermal risk, and calibrated, mapped monitoring devices with secure, retrievable records—expectations that directly shape how transport and depots operate.
Temperature integrity end-to-end
The ATP framework, regularly updated by UNECE, specifies the thermal performance of insulated bodies and mechanical refrigeration for vehicles and trailers—critical for multi-stop routes and cross-border movements. Meanwhile, GDP emphasizes continuous control during storage and transport, including at cargo hubs in Europe where unloading/reloading and transit storage occur. Together, these rules make temperature data—not just equipment—central to compliance.
Sustainability rules reshaping sites and fleets
2025 is a pivot year for reporting sustainability in freight forwarding and energy performance:
- F-gas phase-down accelerates the shift to lower-GWP refrigerants. The recast EU F-gas Regulation EU 2024/573 tightens HFC quotas toward a full phase-out by 2050 and extends equipment prohibitions, pushing cold stores and refrigeration equipment toward CO₂, hydrocarbons, and other low-GWP refrigerants. Many new stationary systems fall under strict GWP thresholds, catalyzing redesigns of plantrooms and service practices.
- Energy-efficient buildings become the norm. The 2024 recast Energy Performance of Buildings Directive EPBD makes “zero-emission buildings” the standard for new non-residential sites on a defined timeline, with life-cycle GWP disclosure and solar-readiness provisions—directly impacting new cold warehouses and refurbishments. In parallel, the revised Energy Efficiency Directive EU 2023/1791 raises national energy-saving obligations and embeds the “energy-efficiency-first” principle, putting pressure on facilities to audit, measure, and reduce consumption.
- CSRD tightens ESG disclosure. Large listed EU companies are publishing their first CSRD-aligned sustainability reports in 2025 for financial year 2024, using ESRS standards. Subsequent “waves” of companies saw timelines adjusted by a “stop-the-clock” measure adopted in February 2025—but the direction of travel is clear: granular, audited energy and climate data from logistics operations will be required.
Electrification and the road to zero-emission logistics
Cold-chain road transport is being reshaped by two regulatory levers. First, the AFIR regulation sets binding targets for public recharging along the TEN-T network beginning in 2025, including minimum-power charging pools for heavy-duty vehicles—critical for battery-electric trucks hauling refrigerated loads. Second, the revised CO₂ standards for HDVs legally adopted in 2024 require a 45% fleet-average CO₂ reduction by 2030, 65% by 2035, and 90% by 2040, pushing OEMs and fleets toward zero-emission trucks and trailers. Cities are simultaneously rolling out zero-emission freight zones, tightening access for combustion vehicles in dense urban cores.
From diesel reefers to low- and zero-emission TRUs
Transport refrigeration units TRUs have historically relied on small diesel engines, which add a measurable emissions burden. Independent studies in Europe highlight the additional CO₂ and particle emissions associated with auxiliary TRU engines—evidence that supports the sector’s move to eTRUs powered by vehicle batteries, axle-energy recovery, depot shore power, or hybrid architectures. While technology pathways vary by duty cycle and route length, the trend in 2025 is clear: decarbonize the reefer as well as the truck.
IoT, AI and data-driven operations
Real-time monitoring is now the default expectation in regulated cold chains. GDP requires validated, calibrated monitoring with secure records; Commission HACCP guidance calls for documented procedures embedded in an FSMS. Building on this baseline, 2025 deployments increasingly use IoT sensors, telematics, and AI for anomaly detection, predictive maintenance of refrigeration assets, and dynamic routing that protects temperature while cutting energy and dwell time. Academic and industry analyses point to optimization gains from data-centric planning across fleets and multi-temperature networks—reducing waste and improving service levels.
What multi-temperature, multi-node networks must do in 2025
Cold-chain networks serving grocery, foodservice, and life sciences are converging on a few operational essentials:
- Design for verification – maintain GDP/HACCP documentation that links each product’s temperature range to validated processes, including temperature mapping of vehicles and storage, alarm set-points, and exception handling across hubs.
- Engineer for low energy and low GWP – when retrofitting or extending capacity, align specifications with EPBD and EED requirements; plan refrigeration around low-GWP working fluids and heat-recovery where feasible. Track site energy performance indicators for CSRD/ESRS readiness.
- Electrify where it works first – map duty cycles to AFIR-enabled corridors and depot charging; prioritize urban routes exposed to zero-emission zones and noise constraints; pilot eTRUs for multi-drop city distribution.
- Instrument everything – use validated loggers and telematics to achieve continuous visibility, secure storage of records, and analytics that shorten response times to excursions—meeting auditors’ expectations and cutting product loss.
The 2025 lens: what’s new for practitioners
Compared with prior years, three developments stand out in 2025:
- Regulatory pressure on refrigerants and buildings is immediate – the new F-gas regime and the EPBD recast turn equipment choice and building performance into board-level decisions for cold stores and cross-docks.
- Fleet decarbonization is no longer optional – with AFIR infrastructure targets taking effect and HDV CO₂ standards locked in law, procurement and route design must accommodate battery-electric options—especially for urban and regional cold-chain routes.
- Reporting scrutiny increases – CSRD’s first-wave reporters publish ESRS-aligned disclosures in 2025, while later cohorts prepare under revised timelines—accelerating demand for auditable energy, refrigerant, and waste data from cold-chain operations.