Cabotage Rules and the EU Mobility Package: A Practical Guide for Drivers and Dispatchers

The EU Mobility Package changed cabotage rules significantly from 2022 onward. If you are a Croatian, Romanian, Polish or Turkish-licensed carrier operating in Germany or France, getting this wrong costs serious money. This guide explains the core rules, how enforcement works, and what your dispatcher must track.

What Is Cabotage — and What Changed

Cabotage means a foreign truck doing domestic transport inside another EU country. A Croatian truck picking up in Munich and delivering to Hamburg is doing cabotage. It was always regulated. The Mobility Package tightened it.

The current rule: maximum 3 cabotage operations within 7 days after an international delivery into that country. Those 3 operations must follow the initial laden cross-border entry. You cannot start cabotage without first completing an international load into the country.

The 4-Day Cooling-Off Period

This is the rule that catches the most carriers. After you use your 3 cabotage operations — or after 7 days, whichever comes first — your vehicle must leave that country. It then cannot return for cabotage in the same country for 4 consecutive days.

Practical example: Your Croatian truck delivers from Zagreb to Stuttgart (international load). You then do 3 cabotage runs inside Germany — Stuttgart to Frankfurt, Frankfurt to Cologne, Cologne to Dortmund. Day 7 arrives. The truck must exit Germany. It cannot come back for German cabotage until 4 full days have passed.

What dispatchers often get wrong: sending the truck out to Austria for one day and back. That does not reset the counter. Four days means four complete calendar days outside Germany. Enforcement officers check the smart tachograph data and can see exactly where the vehicle was.

The 8-Week Vehicle Return Rule

Separate from cabotage, the Mobility Package introduced the return of vehicle rule. Every truck must return to its country of establishment at least every 8 weeks. This applies regardless of cabotage — it covers all operations including bilateral and cross-trade.

For a Croatian carrier, the truck must physically return to Croatia every 8 weeks maximum. Not just cross the border — return to the operational base. This rule targets the practice of leaving trucks permanently in Western Europe.

Enforcement checks the tachograph location data. If your truck has not been in Croatia for 10 weeks, the fine comes to the company, not just the driver. Keep records: fuel receipts, toll records and tachograph downloads showing the home country return.

Driver Return: Every 3 to 4 Weeks

The driver return rule is linked but separate. Drivers must return home every 3 to 4 weeks — specifically, the regulations state the employer must organise the return so the driver can take their regular weekly rest at home, or at a place of their choice outside the cab, at intervals of no more than 3 to 4 weeks.

This is not optional. It is also not just a rest rule — it connects directly to the posting of drivers framework. A driver who is away continuously is likely subject to the host country's labour law after a threshold period. More on that below.

Posting of Workers: What It Means for Pay

The posting of drivers rules under the Mobility Package mean that when your driver is doing cabotage or cross-trade operations in Germany, French or Dutch rules on minimum pay apply from day one of those operations. Bilateral transport — driving from Croatia to Germany and back — is exempt from posting rules.

Practically, this means:

• If your driver does cabotage in Germany, they must receive at least the German minimum wage for those hours — currently above the general national minimum, check the current Mindestlohn rate as it updates regularly.
• The operator must register the posting in the host country's system before the driver starts. Germany uses the Zoll (customs) online portal. France uses SIPSI. Failing to register before the operation starts is itself a violation, separate from any pay issue.
• You must keep posting documentation in the cab or electronically accessible: employment contract, payslips, proof of social security, posting declaration.

A Real Scenario: Croatian Carrier in Germany

Let's make this concrete. Marko drives for a carrier based in Split. His dispatcher books him on the following sequence in one week:

1. Load in Split, deliver to Munich — this is the international entry load. Legal.
2. Munich to Frankfurt — cabotage operation 1. Legal.
3. Frankfurt to Berlin — cabotage operation 2. Legal.
4. Berlin to Hamburg — cabotage operation 3. Legal.
5. Hamburg to Bremen — cabotage operation 4. Illegal. The 3-operation limit is exhausted.

The dispatcher thought 7 days meant 7 operations. It does not. Three operations maximum within 7 days. Marko gets stopped at a roadside check near Bremen. The officer downloads the smart tachograph, sees the crossing point into Germany, counts the subsequent domestic legs. Fine issued on the spot. The carrier faces a fine in Germany that can range from several hundred euros for minor violations to several thousand for systematic infringement — enforcement agencies have issued fines above €5,000 for repeated or deliberate cabotage violations, though ranges vary by country and severity.

How Enforcement Actually Works: Smart Tachograph Data

From 2023, all new vehicles in international transport must be fitted with a Generation 2 smart tachograph (V2). These units record GNSS position data at every border crossing automatically — no manual input needed. Enforcement officers connect a reader to the tachograph unit at the roadside and pull the data within minutes.

The officer can see: every border crossing with time and GPS coordinates, rest locations, and driving periods. Cross-referencing this against CMR documents and the posting declaration takes minutes. There is no arguing about whether the truck was in Germany on a certain date.

When you are planning routes near borders, use a parking and routing app to check your position relative to country borders — apps like BusTruckPark show truck-suitable stops across Europe so you can plan legal overnight rests that also confirm your location record when needed.

Common Violations and Typical Fine Ranges

Note: Fine ranges are indicative based on reported enforcement actions across EU member states. They change. Check current national enforcement guidance for the specific country.

What Dispatchers Must Track

Build a simple spreadsheet per truck per country. Columns: date of international entry, cabotage operations used (max 3), date of last German cabotage, cooling-off end date, last vehicle return to Croatia, last driver home return. Review it every Monday. If a truck is on operation 2 in Germany and you have no reload back to Croatia planned, book one now — not after operation 3.

Also maintain a posting folder per driver: current employment contract, last three payslips, A1 social security certificate, posting declaration confirmation from the host country portal. These must be producible at roadside — electronically is acceptable in most EU countries now, but have a backup PDF on the driver's phone.

FAQ

Can I do 3 cabotage operations in Germany and then 3 in Austria in the same week?

Yes, the 3-in-7 rule applies per country. If your international entry goes into Germany and you do 3 cabotage operations there, you can then cross into Austria with a new international load and do up to 3 cabotage operations in Austria. Each country resets separately. The 4-day cooling-off also applies per country.

Does the 8-week vehicle return rule mean the driver must also be home?

No. The vehicle return and the driver return are separate obligations. The truck must return to the country of establishment every 8 weeks. The driver must be able to take regular weekly rest at home every 3 to 4 weeks. These can — and often do — happen on different schedules. A relief driver can bring the truck home while the original driver takes rest elsewhere.

Does bilateral transport between Croatia and Germany require a posting declaration?

Under the Mobility Package, pure bilateral transport — loading in Croatia, delivering in Germany, loading in Germany, returning to Croatia — is exempt from posting obligations. The exemption also covers one additional loading or unloading stop in a transit country. But the moment you add a domestic German leg, posting rules apply to those cabotage hours.

What if I am stopped and my posting documents are in the office, not the cab?

This is a violation in most EU countries even if the posting was correctly registered. The documents or access to them must be available during the operation. Many carriers now use a shared cloud folder the driver can access on a smartphone. Make sure the driver knows where to find them and that the folder is updated before each posting trip.