Note on IDENTIFICATION OF ROAD CABOTAGE SERVICES
Interpretative Note No. 27 – 2nd generation intelligent tachograph
SEEPMODE would like to clarify to its customers and partners the understanding that drivers with smart tachographs after August 2023 do not have to record additional entries for loading/unloading operations in the tachograph.
Cabotage is a concern of the road package and this feature will help to identify this type of service, so we understand that this feature is intended to do just that, identify cabotage services.
The European Commission has issued various guidelines and clarifications on the Road Package. One of them concerns cabotage services and tells us that this functionality is an important step for this type of service and its supervision. It doesn’t say it’s compulsory.
Regulation 1054/2020, which updates article 8 of Regulation 165/2014, does not clarify whether it is compulsory, even stating that it is automatic. If it’s automatic, it doesn’t need to be manually activated.
In our experience, the understanding of the inspectors can vary according to the information that each inspector has, which can lead to interpretations that the driver is obliged to activate when loading and unloading, because we know that it doesn’t happen automatically.
What do we recommend?
As a precaution and until further clarification, we recommend that drivers activate the additional inputs for loading/unloading operations.
This way, they are not at the whim of anyone’s moods or understandings.
However, if for any reason there are any offences, our clients and partners can share them with us so that we can analyse them.
Is this recommendation for all tachographs?
No, this procedural recommendation is only for 2nd generation smart tachographs, which are now mandatory for new vehicles registered from 21 August 2023.
What should I do with my drivers?
We recommend that you simply inform drivers of the procedure and that they receive adequate instructions on how to use all the functionalities of smart tachographs, in order to ensure that there is a complete set of records and to avoid time-consuming checks, particularly on the road.”