A driver says the chicken is fine because it reads under 5 °C. A store manager says frozen food only counts at −18 °C. A handout says R638 has no temperature table. All three are wrong, and each mistake ends as a rejection note, a markdown or an EHP finding.
R638 temperature requirements are set out in Annexure E of the 2018 hygiene regulations: raw fish, poultry, offal and milk no warmer than 4 °C at the core; other chilled perishables no warmer than 5 °C; frozen food no warmer than −12 °C, or −18 °C for ice cream and sorbet; hot food at least 60 °C.
Food Quality Controller Fundamentals: Retail, DC and Wholesale teaches these limits at the dock, in the display cabinet and after a power cut: about 15 hours online, R1 750, with practice tools you can try free first.
R638 temperature requirements: the key facts
| Ice cream and sorbet | Core no warmer than −18 °C; surface no warmer than −16 °C |
|---|---|
| Any other food marketed as frozen | Core no warmer than −12 °C; surface no warmer than −10 °C |
| Raw unpreserved fish, molluscs, crustaceans, edible offal, poultry meat and milk | Core no warmer than 4 °C; surface no warmer than 6 °C |
| Any other perishable food that must be kept chilled | Core no warmer than 5 °C; surface no warmer than 7 °C |
| Perishable food not kept frozen or chilled (hot) | Core at least 60 °C; surface at least 58 °C |
| Exemptions | Reg 8(4)(b): 4 hours (sale directly to a consumer), venison 8 hours, 1 hour during delivery |
| Thawing and refreezing | Reg 8(6): no more than 10 hours to thaw. Reg 8(5): refreeze only if the surface has not exceeded 5 °C |
| Records | Reg 10(16): keep for at least 6 months after the product’s shelf life |
| Source | R638 of 22 June 2018, GG 41730, reg 8 and Annexure E |
Does R638 set numeric temperatures?
Yes. Annexure E of R638 of 22 June 2018 (GG 41730) sets a required core temperature for five categories of food that is stored, transported or displayed for sale. Regulation 8(4) says the core must not exceed the column 3 value, which is why the printed “> −18 °C” means no warmer than −18 °C.
| Type of food (as printed) | Column 3 (as printed) | Read it as |
|---|---|---|
| Ice cream and sorbet, excluding sorbet which is used for soft serve purposes and frozen fish and fishery products | > -18 °C | No warmer than −18 °C |
| Any other food which is marketed as a frozen product | > -12 °C | No warmer than −12 °C |
| Raw unpreserved fish, mollusks, crustaceans, edible offal, poultry meat and milk | < +4 °C | No warmer than 4 °C |
| Any other perishable food that must be kept chilled to prevent spoilage | < +5 °C | No warmer than 5 °C |
| Any perishable food not kept frozen or chilled | > +60 °C | At least 60 °C |
The frozen symbols look back to front, which is where the confusion starts. Some secondary sources print “≥ −18 °C” or claim there is no table; check the Gazette itself. The limits apply to the food, not the air: a cabinet display reading 3 °C tells you about the air, and only a probe tells you about the product.
What is the 2 °C surface rule?
Chilled and frozen food is not saleable if its surface is more than 2 °C higher than the required core temperature. Hot food is not saleable if its core is below 60 °C or its surface is more than 2 °C below 60 °C (reg 8(4)(a)(ii)). A good core reading is therefore not enough on its own.
So raw chicken with a 3.8 °C core and a 6.4 °C surface is not saleable. A warm surface is usually the first sign that a pack sat on a dock or in a trolley, so take both readings.
When can food be outside these limits?
Exemptions, reg 8(4)(b): (i) perishable food sold directly to a consumer within four hours of being processed or prepared; (ii) venison, for up to eight hours after the animal was killed; (iii) whole freshly caught or harvested raw fish, molluscs or crustaceans, or raw meat, for up to one hour during delivery, provided the surface does not exceed 25 °C.
- Four hours is for sale directly to a consumer. Stew ready at 10:00 may be sold to customers until 14:00 even below 60 °C, then discarded. It does not cover food sent to another store or a trade customer.
- Eight hours for venison counts from the kill, not from delivery.
- One hour covers the delivery journey. It is never a reason to accept a warm load: when the doors open, the Annexure E limit applies.
Is −18 °C the legal frozen limit?
Only for ice cream and sorbet. Any other food marketed as frozen must be no warmer than −12 °C at the core. Frozen fish is the awkward case, because the Annexure E wording is ambiguous: frozen fish is also governed by NRCS VC 8017 (SANS 585); follow your specification, typically −18 °C.
Everyone says −18 °C because it is the storage temperature in SANS 10156, the standard for handling chilled and frozen foods, and in most company specifications. Frozen mixed vegetables at −16.0 °C are legal but outside a −18 °C specification: a company decision, not a legal one.
Law, standard or specification: why does your DC reject loads the law allows?
Because the law is only the floor. SANS 10156 7.11 says do not accept chilled food 3 °C or more above, or frozen food 5 °C or more above, the SANS-recommended storage temperature. This is good practice. It never allows sale above the R638 limit. Company specifications sit on top and may be stricter still.
- Law: R638, enforced by the Environmental Health Practitioner (EHP). The floor for every store and DC.
- Standard: SANS 10156. Its recommended storage temperatures differ from R638: up to 5 °C for fresh poultry and 7 °C for pasteurised milk, where R638 says 4 °C for both. The stricter number wins.
- Specification: your company or customer, stricter than the law but never looser. A retailer might accept frozen food at −18.0 °C or colder, accept −17.9 to −15.0 °C with a supplier non-conformance, hold −14.9 to −12.0 °C for QA and reject anything warmer. That is ASC’s fictional Khanya Fresh case, not a legal limit.
What should you do after a power cut?
No South African law sets a power-cut rule. Decide each product from its probed core and surface temperature and how long it was above its R638 limit, using a written power-interruption policy agreed with QA. Never decide by the clock alone, and treat an unknown time above the limit as hold or destroy.
This example decision tree for high-risk chilled food is company policy from ASC’s Course 1, not law. The US “2-hour rule” is not South African law either.
- At or below its limit: sell.
- Above the limit, no warmer than 7 °C, for no more than 90 minutes: move to a working cold room, re-probe, QA decides.
- Warmer than 7 °C, or time above the limit unknown: hold for QA or destroy.
- Ready-to-eat high-risk lines such as polony and dips: always call QA.
- Frozen food: thawed food whose surface has not exceeded 5 °C may be refrozen and then handled under GMP; for frozen fish, the NRCS compulsory specifications apply instead (reg 8(5)). Ice cream with signs of refreezing comes off sale.
- Hot food below 60 °C: sell directly to consumers only within four hours of preparation, then discard.
Keep a generator map, a fuel log and a weekly test run, and probe the uncovered units first when power returns. The free Power Interruption Decision Tool takes you through the readings, a decision for each product and the record.
Worked example: chickens at 5.6 °C core on the dock
06:10 on a Thursday at Khanya Fresh’s Midrand distribution centre (the fictional retailer in ASC’s courses). Tshepo Molefe backs his Highveld Poultry truck onto dock 4; the reefer display reads 3 °C. Thandi Mokoena, the quality controller, probes a pack at the doors: 5.6 °C core, 6.8 °C surface. Tshepo says: “Under 5 °C is legal, just sign.”
Step 1: Name the category
Raw poultry is in the row with raw fish, molluscs, crustaceans, offal and milk: core no warmer than 4 °C, surface no warmer than 6 °C. Tshepo is quoting the 5 °C row for other chilled food.
Step 2: Check the core and the surface
5.6 °C is 1.6 °C over the core limit, and 6.8 °C is over the 6 °C surface limit. It fails both.
Step 3: Re-probe a second pack
Khanya’s rule is to confirm with a second pack from another position before rejecting: 5.4 °C. The reading stands.
Step 4: Rule out the exemptions
None applies. The one-hour exemption covers the journey, not the decision at the dock, and the four-hour exemption is for sale directly to a consumer.
Step 5: Check the standard
SANS 10156 7.11 would only say “do not accept” at 8.0 °C or more (3 °C above its 5 °C for fresh poultry). But SANS never allows acceptance above the law, and the law already fails this load.
Step 6: Decide and record
Thandi rejects the load. She records the time, batch, both readings, the decision and her initials, asks Tshepo to countersign, raises a supplier non-conformance and calls QA if he disputes it. The record is kept for at least six months after the product’s shelf life.
Practise that call on the free Receiving Inspection Simulator: 12 deliveries to triage, probe and decide. Course 1 teaches the rules behind every one: R1 750, about 15 hours.
What does an EHP actually ask for?
An Environmental Health Practitioner checks that you can prove control, not just claim it: temperature logs with real readings, thermometers that have been checked, cabinets and cold rooms within their limits on the day, a written power-interruption procedure, and records kept for at least six months after the product’s shelf life (R638 reg 10(16)).
High-risk food premises are inspected not less than once every three months under GN 1229 of 2015, the National Environmental Health Norms and Standards, so expect these often:
- Show me today’s temperature log. Are those readings, or ticks?
- How do you check your thermometers? Use the ice point: in Midrand water boils at about 94 to 95 °C.
- Probe that cabinet for me now. What is the limit for what is in it?
- Show me the record of your last power cut, and who decided.
- Show me the receiving record for your last raw poultry delivery.
Frequently asked questions
What is the legal fridge temperature in South Africa?
R638 does not set a fridge air temperature. It sets food core temperatures: no warmer than 4 °C for raw fish, shellfish, edible offal, poultry meat and milk, and no warmer than 5 °C for other chilled perishables. Run the fridge cold enough to keep the food within them.
Is there a danger zone in South African food law?
No. The 4 to 60 °C “danger zone” and the 2-hour rule come from US guidance. R638 sets a core limit for each food category, a 2 °C surface rule and three exemptions, all in degrees Celsius.
Can thawed food be refrozen?
Reg 8(5): thawed food whose surface has not exceeded 5 °C may be refrozen and then handled under GMP. For frozen fish, the NRCS compulsory specifications apply instead. Reg 8(6): thawing must be as short as possible and no more than 10 hours.
How long can hot food stand below 60 °C?
Only if it is perishable food sold directly to a consumer within four hours of being processed or prepared; after that, discard it. Otherwise the core must be at least 60 °C, with the surface no more than 2 °C below.
How often must we record temperatures?
R638 sets the limits, not a logging frequency; your procedure, customer and scheme set that. SANS 10156 7.10 says that where there are no recorders, take readings three times a day.
Can I use an infrared gun at receiving?
Only as a screen. An infrared gun reads the surface, so it can flag a problem but never clear one. Confirm with a probe, between packs and then in the core of a sacrificial pack.
Get the temperature call right every time
Every temperature call has the same shape: name the category, check the core and the surface, rule out the exemptions, decide and record.
Food Quality Controller Fundamentals: Retail, DC and Wholesale: Course 1 of the FS60 series, 8 modules, about 15 hours, self-paced on any phone.
- R1 750, no VAT charged; no QC experience needed
- Three practice tools: Receiving Inspection Simulator, Shelf and Date-Code Walk, Power Interruption Decision Tool, each free to try first
- A video-proctored final exam: 35 questions from a bank of 80, 45 minutes, 70 % to pass, 2 attempts
- A QR verified Certificate of Achievement an employer or auditor can check
- ASC Food Safety Training is a FoodBev SETA accredited training provider (587/00337/1900); the FS60 courses are non-credit-bearing short courses
New to QC? Read how to become a food quality controller in South Africa. Compare levels on the food quality control training page, see all courses or contact us about a team of five or more.
Last reviewed: 28 September 2026.
Sources: R638 of 22 June 2018 (GG 41730); NRCS VC 8017; GN 1229 of 2015 (GG 39561); SANS 10156:2014, The handling of chilled and frozen foods.