Cabotage refers to domestic road haulage carried out by a carrier that does not have a registered office in the country where the transport is performed.
EU rules
- Cabotage is only permitted after the completion of an international transport with full unloading.
- The maximum number of cabotage operations is three within seven days following the end of the international transport.
- All operations must be documented (CMR consignment note, transport orders, etc.) and apply to the vehicle, not the individual driver.
- It is prohibited to enter a foreign country empty for the sole purpose of performing cabotage.
“The law is structured 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, Training and Development Expert at Inelo, part of Eurowag Group.
Cooling-off period
The Mobility Package also introduced a new requirement: the so-called “cooling-off” period. After performing cabotage in a given country, the same vehicle cannot carry out further cabotage in that country for the next four days.
Key points:
- The rule applies to four full calendar days.
- The break must cover at least two working days.
- Weekends and public holidays may extend the break to as much as seven days.
Miscalculating this period can result in an illegal operation, even if unintentional. Accurate record-keeping and planning are therefore crucial.
“Such a seemingly innocent mistake can cost a company a lot of money,” adds Włoch.
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Common breaches of cabotage rules
- Failure to present the CMR note documenting the international transport that serves as the basis for lawful cabotage.
- Missing transport documents for the inspected period, making it impossible to prove compliance.
- Formal errors in CMR notes, such as missing loading/unloading dates or locations, missing country codes, signatures, or trailer disconnection details.
- Carrying out more than three cabotage operations within seven days, or starting cabotage before completing the international transport.
Illegal cabotage – fines and penalties
Breaches of cabotage rules can lead to financial penalties reaching tens of thousands of euros, and in severe cases even more. Fines are not the only consequence. Enforcement authorities may immobilise the vehicle until the fine is paid. In extreme cases, a haulier can lose their Community licence. “In some countries, temporary bans on cabotage may also be imposed,” Włoch notes. Each Member State may also have its own interpretation of the rules – for instance, how to count operations in cases of multiple unloading points – which further complicates matters.
Examples of penalties for illegal cabotage
| Country | Fine | Additional sanctions |
| Belgium | €1,980 per illegal transport; €990 for incomplete documents | – |
| Czechia | Up to CZK 350,000 (approx. €15,000) | Fine for missing documents or breaching Mobility Package rules |
| Denmark | DKK 35,000 (approx. €4,700) | – |
| France | €15,000 + up to 1 year imprisonment | Vehicle seizure (7 days), 1-year driving ban, licence withdrawal, loss of good repute |
| Spain | €4,001 for the haulier; €2,001 for the operator/shipper | – |
| Netherlands | €4,400 | Case referred to public prosecutor (OM), penalty may be higher |
| Germany | Up to €5,000 for the haulier (€1,000 for first offence); up to €20,000 for the shipper | – |
| Norway | NOK 25,000–50,000 (approx. €2,100–4,200) | – |
| Sweden | SEK 60,000 (approx. €5,400) | – |
| Italy | €5,000–15,000 | Vehicle impoundment (3 months); repeat offence – vehicle confiscation (6 months) |
| Poland | PLN 12,000 (approx. €2,800) for lack of permit or non-compliance | – |
The Benelux agreement
In Belgium, the Netherlands and Luxembourg, cabotage is subject to special rules under the Benelux Treaty on the free movement of goods.
Under this agreement, hauliers holding a Community licence issued in one of the three countries may perform an unlimited number of domestic road transports in the other Benelux states. This can be done without fully unloading the international consignment or observing the four-day cooling-off period.
In practice, this means, for example, that a Dutch haulier can carry out unlimited cabotage in Belgium or Luxembourg without time or quantity restrictions.
However, the Benelux Treaty does not exempt operators from the obligation to register cabotage operations in the EU’s IMI system. This requirement remains in place despite the exemption from the Mobility Package restrictions.
Navigating the rules – helpful tools
Planning routes, schedules and cabotage operations across multiple countries is a challenge, particularly for companies with large fleets. Integrated TMS and telematics systems can provide valuable support in practice.
By automatically updating data on vehicle locations, loadings and unloadings, these systems continuously monitor compliance, assisting planners and reducing the risk of errors. This not only saves time but also increases legal certainty.
