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Cabotage, domestic haulage performed by a foreign carrier, is strictly limited in the EU: after an international delivery, at most 3 such jobs within 7 days, then a 4-day cooling-off in that country. The request to "drop these off around Germany while you are there" often breaks those limits, and penalties can hit both carrier and shipper.
Where the limits come from: Regulation (EC) No 1072/2009
Access to the EU road haulage market is governed by Regulation (EC) No 1072/2009. A carrier holding a Community licence can carry international loads freely, but domestic jobs in a foreign country are tightly restricted:
- cabotage is only allowed after a load from an international journey has been delivered into the country concerned,
- from the unloading of that incoming load, the carrier has 7 days to perform at most 3 cabotage operations,
- a carrier entering the country empty may perform 1 cabotage operation within 3 days of entry, within the same overall limits,
- every operation must be documented so that enforcement officers can reconstruct the sequence.
The Mobility Package: the cooling-off period
The Mobility Package, introduced by Regulation (EU) 2020/1055, added a cooling-off period to these rules: once the cabotage limit in a given country has been used up, the carrier may not perform further cabotage there with the same vehicle for 4 days. The aim was to end the practice of trucks circulating on one national market for months, formally "on the occasion" of international runs.
Why "while you are there" can be illegal
Picture the typical request: a truck from Poland has delivered goods to a warehouse near Cologne, and the client would like it to drop a few pallets at its customers around Germany on the way. Do the maths: delivering to three consignees means three separate cabotage operations, the entire limit. A fourth drop breaks the regulation. A week-long delivery loop around Germany breaks both the job count and the 7-day window, and coming back a couple of days later for another round collides with the 4-day cooling-off.
| Scenario | Assessment |
|---|---|
| After an international unloading, the truck takes 2 domestic jobs in 5 days | Legal cabotage within the limit |
| Delivering 5 pallets to 5 different consignees after an international delivery | 5 cabotage operations, limit exceeded |
| The truck returns 2 days later for more domestic jobs with the same vehicle | 4-day cooling-off breached |
| A Polish carrier moves goods from France to Spain | Cross-trade, legal with a Community licence |
| Domestic UK deliveries "on the back of" an EU delivery | Heavily restricted since Brexit, see below |
Cross-trade: a different animal from cabotage
Cross-trade is carriage between two countries, neither of which is the carrier's country of establishment. Within the EU the Community licence generally covers it and the cabotage limits do not apply, because the journey remains international. Things get complicated outside the EU: transports involving third countries may require permits, for example from the ECMT system, or fall under bilateral agreements. So an order like "take this from Norway to Switzerland" requires checking the specific carrier's entitlements before the truck moves.
The UK after Brexit
Since the UK left the EU, EU carriers have lost the freedom to run domestic jobs on British soil. The EU-UK Trade and Cooperation Agreement allows only a limited number of cabotage operations, tightly tied to an international journey and confined to a short time window. In practice, regular distribution around the UK with an EU truck has no legal basis. The lawful alternative is a local warehouse and local distribution, which is exactly how we work from our Milton Keynes warehouse.
What does breaking the rules cost?
The carrier bears the brunt: financial penalties imposed by the enforcement authorities of the country where the breach occurred, and with repeated infringements the risk of losing good repute and the licence. The ordering party is not safe either: in many countries liability for commissioning non-compliant transport can extend to the shipper or forwarder, and in the event of damage the insurer will happily use the illegal nature of the journey to refuse payment. On top of that comes operational risk: a truck detained at a roadside check means your goods are standing still with it.
How to plan distribution legally
- split the delivery: an international leg to a single point, then onward distribution by a local carrier or through a groupage LTL network,
- use an intermediate warehouse: the goods arrive on one truck and travel on as domestic shipments,
- if cabotage makes economic sense, plan it deliberately: at most 3 jobs, a 7-day window, documentation for every operation,
- for the UK, assume local distribution from the start instead of cabotage.
The OTSL role
We plan routes so that distribution is legal and predictable: main haul, warehouse, local deliveries, instead of hoping the inspection will not pick your pallets. If your consignees are scattered across Germany, Benelux or the UK, get in touch and we will set up a distribution model without penalty risk.
Step by step
- Route verification. Check the loading and unloading locations to identify potential rules.
- Document review. Confirm that all necessary consignment notes and transport licences are valid and accessible.
- Operation tracking. Keep count of completed domestic legs and days elapsed within the host country.
- Cooling-off management. Schedule vehicle movements to comply with mandatory waiting periods between jobs.
- Record retention. Store transport documents systematically to demonstrate compliance during roadside inspections.
Definitions
- Cabotage: The carriage of goods between two locations within the same country performed by a carrier registered in a different state.
- Cross-trade: Transport of cargo between two different countries carried out by a haulage company from a third nation.
- Community licence: An official authorization allowing a road haulage operator to perform commercial transport across the European Union.
- Cooling-off period: A mandatory waiting time during which a vehicle is prohibited from undertaking further domestic operations in the same country.
When does this rule not apply?
This restriction does not apply to standard international transport operations where goods are loaded in one country and delivered to another.
