In simple terms, cabotage is the domestic carriage of goods by road carried out by a haulier based in a different country from the one where the transport takes place.
Under EU rules:
- cabotage is permitted only after an international transport operation has been completed with full unloading,
- a maximum of three cabotage operations may be carried out within seven days of the international delivery being completed,
- all operations must be properly documented, including through CMRs and transport orders, and the rules apply to the vehicle rather than to a specific driver,
- a vehicle may not enter another country empty solely in order to carry out cabotage.
On paper, these rules appear straightforward, but in practice, it is easy to make mistakes.
“Such legislation makes it possible to increase transport efficiency by avoiding so-called empty runs, while at the same time protecting the local market from unfair competition,” explains Mateusz Włoch, development and training expert at Inelo, part of the Eurowag Group.
The cooling-off period
The Mobility Package also introduced a new requirement: the so-called cooling-off period. This means that after carrying out cabotage in a given country, the same vehicle cannot perform cabotage there again for the next four days.
Important points to remember:
- this means four full calendar days,
- the break must include at least two working days,
- in practice, weekends and public holidays can extend the break to as much as seven days.
A miscalculation of this period can turn an operation into an illegal one, even if the mistake was unintentional. That is why accurate records and careful planning are essential.
“An apparently harmless mistake like this can cost a company a great deal of money,” says Mateusz Włoch.
The most common cabotage breaches
The most common breaches of cabotage rules do not arise only from deliberate non-compliance. They are also often caused by formal errors and a poor understanding of detailed documentation requirements.
One of the most frequent problems is the inability to produce, during a roadside inspection, the CMR consignment note for the international transport operation that provides the legal basis for starting cabotage.
Another common issue is the absence of a complete set of transport documents covering the period under inspection. For example, one missing waybill may be enough to prevent a haulier from proving that the operation was carried out lawfully.
Inspectors also often find formal errors in the CMR documents themselves, such as missing loading or unloading dates and locations, missing country details, missing signatures, or missing information about trailer changes.
It also happens that a haulier carries out more cabotage operations than the law allows, meaning more than three within seven days, or starts cabotage before the international transport has been fully completed. This is treated as a serious infringement.
Illegal cabotage: fines and other penalties
Breaching cabotage rules can lead to fines running into tens of thousands of euros, and in more serious cases the consequences can be even more severe.
“High fines are not the only consequence of failing to comply with cabotage rules. The authorities may immobilise the vehicle until the penalty is paid, and in extreme cases a transport company may even lose its Community licence,” warns Mateusz Włoch.
In some countries, a company may also be temporarily banned from carrying out cabotage. It is also worth remembering that individual member states may interpret certain rules differently, for example when counting operations involving multiple unloading points, which makes compliance even more complicated.
Illegal cabotage: penalties by country
| Country | Penalty amount | Additional sanctions |
| Belgium | €1,980 for each illegal transport operation | €990 for incomplete documents |
| Czechia | up to CZK 350,000 (approx. €14,400) | penalty for missing documentation or breach of Mobility Package rules |
| Denmark | DKK 35,000 (approx. €4,700) | – |
| France | €15,000 and up to one year in prison | truck seizure for seven days, driving ban for one year, licence withdrawal, loss of good repute |
| Spain | €4,001 for the carrier; €2,001 for the contracting party (operator, shipper, etc.) | – |
| The Netherlands | €4,400 | case referred to the Public Prosecution Service; the penalty may be higher |
| Germany | up to €5,000 for the carrier (€1,000 for a first infringement); up to €20,000 for the contracting party | – |
| Norway | NOK 25,000–50,000 (approx. €2,200–€4,400) | – |
| Sweden | SEK 60,000 (approx. €5,500) | – |
| Italy | €5,000–€15,000 | vehicle detention for three months; repeat offence may lead to confiscation for six months |
| Poland | PLN 12,000 (approx. €2,800) for lack of a permit or failure to comply with the conditions of carriage | – |
Special rules in the Benelux countries
In the Benelux countries — Belgium, the Netherlands and Luxembourg — special rules apply to cabotage operations under a regional agreement.
Under the Benelux Treaty, hauliers holding a Community licence issued in one of these three countries may carry out an unlimited number of domestic road transport operations in the other Benelux states without having to complete full unloading of the incoming international load and without observing the four-day cooling-off period.
In practice, this means that, for example, a Dutch transport company may freely carry out cabotage operations in Belgium or Luxembourg without limits on the number of journeys or the time period.
However, these carriers are still required to register cabotage operations in the EU’s IMI system. That obligation remains in force even though they are exempt from certain Mobility Package restrictions.
