Carrier types
Starting a reefer trucking company: authority, coverage, and food safety
A reefer company runs on the same authority paperwork as a dry van fleet, plus two deltas: the FDA's food safety transport rule reaches motor carriers hauling food, and your cargo policy needs limits and breakdown coverage that match what shippers write into their contracts.
By Evan Reid, Founder of Haul Handbook · Updated Jul 18, 2026
Authority first: the reefer part comes later
Companies that transport passengers in interstate commerce for compensation, or transport federally regulated commodities owned by others (or arrange their transport) for compensation in interstate commerce, need interstate operating authority in addition to a USDOT number. Produce, meat, and dairy are for-hire freight like any other, so the launch sequence matches the one in how to get your own authority, and the new entrant safety audit arrives on the same clock. One carve-out matters in food hauling: Private carriers hauling their own cargo, for-hire carriers hauling exclusively exempt (not federally regulated) commodities, and carriers operating exclusively inside a federally designated commercial zone do not need interstate operating authority.
Whether a food load is exempt is set by statute, not left to judgment. 49 U.S.C. 13506(a)(6) exempts from federal economic authority the motor transportation of ordinary livestock; agricultural or horticultural commodities other than manufactured products of them; the commodities listed as exempt in the Commodity List incorporated in ruling numbered 107 (March 19, 1958) of the Interstate Commerce Commission, other than frozen fruits, frozen berries, frozen vegetables, cocoa beans, coffee beans, tea, and bananas; ordinary cooked or uncooked fish and fresh or frozen shellfish; and livestock and poultry feed and agricultural seeds and plants moved to a farm or a place that sells farm supplies. The commodities that are not exempt, and so move only under operating authority, are enumerated as Administrative Ruling No. 133 in 49 CFR 372.115, which lists meat and meat products (fresh, frozen, or canned), canned and frozen fruits and vegetables, butter, and other processed and manufactured foods. A carrier confirms a specific commodity against that non-exempt list before skipping an authority step.
The FSMA sanitary transport rule
The FDA's Sanitary Transportation of Human and Animal Food rule (21 CFR part 1, subpart O) applies to shippers, loaders, carriers, and receivers moving food by motor vehicle, whether or not the load crosses state lines. It sets requirements in four areas: vehicles and transportation equipment (section 1.906), transportation operations such as temperature control (section 1.908), carrier training where a written contract makes the carrier responsible for sanitary conditions (section 1.910), and records (section 1.912).
What that means day to day: written temperature expectations from the shipper, a trailer that can hold them, pre-cooling before loading, and records that prove the cold chain held. Read the rule text once; it is short, and brokers quote it back at you in contract language.
Cargo limits and reefer breakdown coverage
FMCSA requires no cargo insurance filing from a food carrier; the federal cargo filing (BMC-34) applies to household goods carriers and household goods freight forwarders only. The cargo limits a reefer carrier must hold come from shipper and broker contracts, and coverage for spoilage after a refrigeration unit failure is a policy endorsement bought in the insurance market, not a federal filing.
Reefer breakdown terms vary by insurer and no regulator publishes them, so this record stays qualitative. The pattern mirrors car hauling: the regulator sets liability, the contract sets cargo. The liability filings themselves, BMC-91 and its siblings, are covered in the insurance filings guide.
The running costs reefers feel more than dry vans
IFTA taxes the diesel that propels the truck, not the diesel that runs the trailer's refrigeration unit. Under the IFTA Articles of Agreement, motor fuels are the fuels placed in the fuel supply storage unit of a qualified motor vehicle and used to propel it (Section R239), and the licensee must report the fuel placed in the supply storage unit used to propel the qualified motor vehicle as taxable (Section R820). Reefer-unit diesel drawn from a separate tank that powers only the refrigeration unit is not used to propel the vehicle, so it is generally not IFTA propulsion fuel. What puts a reefer company on the IFTA calendar is the tractor's propulsion diesel across the jurisdictions it runs, the same as any other qualified motor vehicle. The current per-state matrix lives in IFTA fuel tax rates by state, and the full startup budget math is in how much it costs to start a trucking company.
Frequently asked questions
Does FSMA apply to a small reefer carrier?
- The rule does not cover a non-covered business: a shipper, loader, receiver, or carrier with less than $500,000, adjusted for inflation, in average annual revenue, calculated on a rolling basis over the 3 years before the applicable calendar year. Above that line, the rule's carrier duties apply.
What does the FSMA transport rule require from carriers?
- The FDA's Sanitary Transportation of Human and Animal Food rule (21 CFR part 1, subpart O) applies to shippers, loaders, carriers, and receivers moving food by motor vehicle, whether or not the load crosses state lines. It sets requirements in four areas: vehicles and transportation equipment (section 1.906), transportation operations such as temperature control (section 1.908), carrier training where a written contract makes the carrier responsible for sanitary conditions (section 1.910), and records (section 1.912).
What insurance does a reefer company need?
- FMCSA requires no cargo insurance filing from a food carrier; the federal cargo filing (BMC-34) applies to household goods carriers and household goods freight forwarders only. The cargo limits a reefer carrier must hold come from shipper and broker contracts, and coverage for spoilage after a refrigeration unit failure is a policy endorsement bought in the insurance market, not a federal filing. Liability works like any property carrier: your insurer files proof of coverage with FMCSA.
Do reefer carriers need a special authority type?
- No. Refrigerated freight moves under regular property carrier authority. Companies that transport passengers in interstate commerce for compensation, or transport federally regulated commodities owned by others (or arrange their transport) for compensation in interstate commerce, need interstate operating authority in addition to a USDOT number.
Sources
Primary statutes and official agency pages this guide relies on. Laws and fees change, so confirm against the current source before you act.
- Get Operating Authority (Docket Number) · Federal Motor Carrier Safety Administration (FMCSA), U.S. DOT
- 49 U.S.C. 13506, Miscellaneous motor carrier transportation exemptions (agricultural and other exempt commodities, subsection (a)(6)) · Office of the Law Revision Counsel, U.S. House of Representatives
- 49 CFR 372.115, Commodities that are not exempt under 49 U.S.C. 13506(a)(6) (reproducing Administrative Ruling No. 133, the non-exempt commodity list) · U.S. Government Publishing Office (govinfo.gov), Code of Federal Regulations, Title 49, 2024 edition
- 21 CFR Part 1, Subpart O, Sanitary Transportation of Human and Animal Food · Office of the Federal Register, eCFR
- Insurance Filing Requirements · Federal Motor Carrier Safety Administration (FMCSA), U.S. DOT
- IFTA Articles of Agreement, effective January 1, 2026, Sections R239 (Motor Fuels), R820 (Taxable Fuel Use), and R830 (Exempt Fuel Use) · International Fuel Tax Association, Inc. (IFTA, Inc.)
Haul Handbook publishes educational information about trucking registration and compliance requirements. This is not legal, financial, or tax advice. Rules, fees, and deadlines change; confirm with the agency before you file or pay.