COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the 2015-2016 implementation of Regulation (EC) No 561/2006 on the harmonisation of certain social legislation relating to road transport and of Directive 2002/15/EC on the organisation of the working time of persons performing mobile road transport activities (29th report from the Commission on the implementation of the social legislation relating to road transport)
Date: 2018-10-18
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU Member State, application of EU law, arrangement of working time, drivers, driving period, rest period, road safety, road transport, social legislation, transport statistics

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.10.2018 SWD(2018) 439 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL  on the 2015-2016 implementation of Regulation (EC) No 561/2006 on the harmonisation of certain social legislation relating to road transport and of Directive 2002/15/EC on the organisation of the working time of persons performing mobile road transport activities  (29th report from the Commission on the implementation of the social legislation relating to road transport) {COM(2018) 698 final}  
 
 
1. Social legislation in road transport – objectives and key provisions 

The  EU  social  rules  in  road  transport  are  established  by  four  interrelated  acts  :  Regulation 
(EC)  No  561/2006,  which  establishes  rules  on  driving  times,  breaks  and  rest  periods  for 
professional drivers, Regulation (EU) No 165/2014 on recording equipment in road transport, 
Directive  2002/15/EC,  which  sets  out  complementary  provisions  on  the  organisation  of  the 
working  time  of  persons  performing  mobile  road  transport  activities  and  Directive 
2006/22/EC, which determines minimum requirements for enforcement of these rules. 

Regulation (EC) No 561/2006 applies to employed and self-employed drivers engaged in the 
carriage by road of goods where the maximum permissible mass of the vehicle exceeds 3.5 
tonnes  and of  passengers  by  vehicles  carrying more  than  nine  persons including  the  driver. 
The maximum weekly driving time of a driver should not exceed 56 hours (provided that no 
more  than  90  hours  are driven in  any  two  consecutive  weeks).  The  total  daily  driving  time 
should  not  exceed  9  hours,  although  twice  a  week  it  can  be  extended  to  10  hours.  Breaks 
should  last  for  at  least  45  minutes  (which  may  be  separated  into  a  break  of  15  minutes 
followed by 30 minutes) and should be taken not later than 4.5 hours of driving period. The 
daily rest period is determined at the level of minimum 11 hours, which can be reduced three 
times a week to 9 hours.  

The Commission has undertaken an ex-post evaluation1 of the social rules which concluded 
that  the  legislations  remain  a  relevant  tool,  but  it  is  only  partially  effective.  The  effects  in 
terms  of  enhancing  road  safety  were  positive.  However,  although  road  safety  levels  have 
improved in the period covered by the evaluation, the impact of the social legislation could 
not be discerned from the impacts of other road safety measures implemented across Member 
States. The insufficient effectiveness and efficiency of the social legislation is mainly due to 
the  lack  of  clarity  of  certain  rules,  leading  to  diverging  national  interpretations  and 
application  of  the  rules,  inconsistent  and  ineffective  enforcement  practices  and  a  lack  of 
administrative cooperation. 

This is the reason why the Commission has tabled two proposals2 on 31 May 2017 revising 
the  social  rules  where  discussions  are  under  way  since  summer  2017  in  the  European 
Parliament and the Council.  

Regulation (EU) No 165/2014 repealed Council Regulation (EEC) No 3821/85 on recording 
equipment  in  road  transport.  The  new  Regulation  sets  out  obligations  and  requirements  in 
relation to the construction, installation, use, testing and control of tachographs used in road 
transport, in order to verify compliance with  the provisions of  Regulation (EC) No 561/2006 
It  also  aims  at  reducing  administrative  burden  and  making  fraud  to  the  tachograph  more 
difficult. The smart tachograph will be fitted in vehicles registered for the first time as of 15 
June 2019. It will feature a new set of advanced communication capabilities with respect to 
the current digital tachograph, such as satellite geo-localization or short range communication 
for  the  transmission  of  information  to  enforcement  authorities.  Those  communication 

1 SWD(2017) 184 final from 31.05.2017. 
2 COM(2017) 277 final and COM(2017) 278 final 

2 

 
 
                                                            
capabilities will broaden the areas of enforcement where the tachograph is applied, extending 
it  to,  for  instance,  the  control  of  cabotage  operations  or  the  application  of  the  rules  on  the 
posting of drivers. 

Directive 2002/15/EC,  known as the “Road Transport Working Time Directive”, applies to 
mobile workers such as drivers, crew and other travelling staff, both with the employment or 
self-employment status. The Directive complements Regulation (EC) No 561/2006 by putting 
in place limitations on the maximum weekly and maximum average weekly working time of 
workers  in  the  road  transport  sector  as  well  as  adequate  breaks  and  night  work  provisions. 
Working  time  is  defined  in  the  Directive  as  time  devoted  to  all  road  transport  activities, 
including  driving,  loading  and  unloading,  assisting  passengers  boarding  and  disembarking 
from the vehicle, cleaning and technical maintenance and all other work intended to ensure 
the safety of transport operation. Specific time limits are set out in relation to weekly working 
time (excluding  breaks and  periods of availability) which amounts to  maximum 48 hours a 
week, which may be extended to 60 hours, provided that over four months, an average of 48 
hours  a  week  is  maintained.  Moreover,  a  limitation  to  10  hours  on  daily  working  time  is 
introduced in case of night work. Each mobile worker is obliged to take a break after working 
consecutively for 6 hours, which should be at least 30 minutes, if working hours range from 
six to nine hours and at least 45 minutes, if working time equals to more than nine hours.  

Directive 2006/22/EC also called the "Enforcement Directive" aims at verifying compliance 
and  ensuring  application  of  the  driver's  hours  rules  established  by  Regulation  (EC)  No 
561/2006  and  Regulation  (EU)  No  165/2014.  The  Directive  promotes  harmonised 
enforcement of the social rules in road transport by means of minimum requirements for the 
uniform and effective checks to be carried out by Member States. The minimum threshold of 
checks of the total number of days worked by drivers falling under the scope of Regulation 
(EC) No 561/2006 and Regulation (EU) No 165/2014 is set at 3% from 2010. In addition, the 
total number of working days actually checked should be carried out in a proportional manner 
for  checks  at  the  roadside  and  at  premises  of  transport  undertakings,  30  %  and  50  % 
respectively.  In  order  to  encourage  cooperation  between  Member  States,  an  obligation  of 
minimum  6  concerted  roadside  checks  per  year  undertaken  by  two  or  more  enforcement 
authorities was introduced.  

This Staff working Document is accompanying the Report and provides more national figures 
and details as well as updates on other relevant aspects in the field. 

2. Checks 

As mentioned in the report, total working days checked in the EU continued to decrease since 
2013-2014.  However,  looking  at  the  national  figures  the  decrease  of  around  -12.8%  of 
working  days  checked  seemed  to  mainly  result  from  the  lower  number  of  working  days 
checked reported by Germany, Romania and France3. 

3 Germany, France and Romania reported together around 17.4 million less working days checked compared to 
the last report. Germany explained that data of three Länder were missing for this report. 

3 

 
 
                                                            
Overall, the majority of Member States performed significantly more working days checked 
than  required.  If  100%  represents  the  minimum  threshold  percentage  of  3%,  the  top  five 
Member States are France (395%), Germany (382%), Bulgaria (375%), Austria (359%) and 
Latvia (340%), which accounted for more than half of the working days checked in the EU 
(around 68 out of 131 million). Compared to the last report, Croatia and Lithuania made great 
improvements and now meet the threshold of 3%. 

Only three Member States did not meet the minimum threshold, namely Greece (5% out of 
100%), Netherlands (72%) and Malta (94%). 

The Netherlands have applied since 2009 a "monitoring based on trust" system where 64 road 
transport undertakings have concluded an enforcement agreement with the Environment and 
Transport  inspectorate.  The  agreement  covered  over  2.8  million  days  worked  by  drivers 
during 2015-2016 which are in addition to the 1.2 million working days checked reported by 
the  Netherlands.  Adding  these  figures  together  would  allow  the  Netherlands  to  meet  the 
minimum  threshold.  The  Dutch  authorities  informed  the  Commission  that  the  continuous 
development and expansion of the risk analysis enables the Dutch inspectorates to focus its 
efforts on those road transport undertakings whose level of compliance is poor. Furthermore, 
non-compliant undertakings fall under specialised enforcement and are subject to a rigorously 
applied corrective procedure. 

The  Directive  also  requires  that  at  least  50%  of  the  total  number  of  working  days  checked 
should  be  done  through  checks  at  the  premises  of  undertakings  and  at  least  30%  on  the 
roadside. However, looking at the number of Member States which have met the threshold, 
only the following six Member State have the required balanced share between working days 
checked at premises and the roadside: Bulgaria (59% of working days checked at premises), 
Cyprus (52%), Latvia (57%), Luxembourg (68%), Romania (51%) and Slovakia (58%).  

Based on the figures reported the upward trend continues as regards working days checked at 
the premises with the EU average rising to 26% compared to 23% in 2013-2014 and 18% in 
2009-2010. The most significant improvements compared to the last report were reported by 
Romania  (rise  from  14%  to  51%)  and  by  Luxembourg  (from  39%  to  68%).  Both  Member 
States have now met the threshold. 

Ireland  continues  to  be  the  only  Member  State  which  has  not  met  the  threshold  for  the 
roadside checks because 93%  of total working days  are checked at the premises. However, 
the reason seems  to  be  that not  many other non-Irish, except British registered vehicles are 
circulating on Irish roads. 

3.  Checks  compared  to  the  number  of  enforcement  officers  and  equipment  to  analyse 
tachographs 

Based on the number of enforcement officers reported from all Member States, the number of 
control  officers  involved  in  checks  remained  stable  with  a  slight  increase  from  61,211  in 
2013-2014  to  61,503  in  2015-2016.  The  number  of  enforcement  officers  trained  to  analyse 

4 

 
 
the digital tachograph has continued to decrease by 5.7% as well as the units of equipment 
provided to control officers to analyse the tachograph by 5.5% compared to the last report.  

Table 1: Overview of national enforcement capacity in 2015-2016 per Member State 

Member  
States 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE4 
IT 
LV 
LT 
LU 
MT 
NL 
PL5 
PT 
RO 
SK 
SL 
ES 
SE 
UK 

Control 
officers 
involved in 
checks 
1150 
3654 
198 
315 
136 
693 
68 
206 
455 
6000 
16795 
1171 
700 
11 
11309 
28 
426 
26 
2 
100 
1344 
14909 
318 
40 
80 
512 
249 
608 

Control officers 
trained to analyse 
the digital 
tachograph 
1150 
3510 
198 
315 
10 
693 
68 
58 
207 
6000 
4528 
437 
600 
11 
1333 
28 
148 
20 
2 
300 
1193 
1315 
318 
41 
310 
395 
227 
310 

Units of equipment provided to 
control officers to analyse the 
tachograph 

485 
123 
220 
150 
8 
136 
31 
19 
109 
3500 
2321 
350 
350 
11 
304 
12 
55 
15 
1 
85 
240 
343 
318 
40 
36 
445 
205 
310 

Total 

61,503 

23,725 

10,222 

4. Roadside checks 

As  mentioned  in  the  report,  in  general  32%  of  vehicles  checked  at  the  roadside  are  from 
another  EU  country6.  However,  in  some  Member  States  the  percentage  of  vehicles  from 
another  EU  country  constitutes  more  than  half:  namely  in  Luxembourg  (64%),  Belgium 
(62%),  Austria  (61%),  France  (60%),  the  Netherlands  (54%)  and  the  UK  (53%).  The 

4 Ireland explained that this figures does not include members of the police force and solely refers to staff from 
the Road Safety Authority. 
5 Poland explained that this figure does not include police officers involved in roadside checks 
6 Data from Denmark and Finland are missing for these figures as they were not complete.  

5 

 
 
 
                                                            
geographic  location  and  volume  of  transit  operations  may  in  certain  Member  States  play  a 
factor.  Member  States  whose  share  of  checking  vehicles  registered  in  non-EU  country  was 
the largest are Slovenia (43%), Croatia (23%) and Lithuania (21%). A complete overview per 
Member State can be found in Table 2 below. 

Table 2: Share of checked vehicles on the roadside by country of registration 

Member  
States 
AT 
BE 
BG 
HR 
CY 
CZ 
DK7 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SL 
ES 
SE 
UK 
EU 
average 

Nationals 

35% 
34% 
71% 
65% 
100% 
55% 

Non-
nationals 
61% 
62% 
14% 
12% 
0% 
41% 

Third  
nationals 
4% 
3% 
15% 
23% 
0% 
4% 

85% 

38% 
60% 
82% 
56% 
95% 
86% 
57% 
46% 
35% 
67% 
44% 
66% 
97% 
83% 
45% 
30% 
89% 
56% 
45% 

63% 

12% 

60% 
35% 
11% 
33% 
5% 
13% 
33% 
33% 
64% 
33% 
54% 
16% 
3% 
10% 
48% 
28% 
10% 
41% 
53% 

32% 

2% 

1% 
5% 
7% 
11% 
0% 
1% 
10% 
21% 
1% 
0% 
2% 
19% 
0% 
7% 
7% 
43% 
1% 
2% 
3% 

5% 

5. Roadside checks – type of tachograph 

According to Article 2 of Directive 2006/22/EC, the threshold of minimum checks of number 
of days worked by drivers of vehicles will be raised to 4% once 90% of vehicles checked are 
equipped with a digital tachograph. Compared to the last report, the share of vehicles checked 
at the roadside that were equipped with the digital tachograph increased from 64% to 72%8. 
There is therefore no base to raise the threshold of minimum checks to 4% for the time being. 

7 Data not available for Denmark 
8 This does not include data from Denmark and Finland due to their incompleteness.  

6 

 
 
 
 
 
 
 
 
 
                                                            
The  highest  share  of  digital  tachograph  (above  80%)  was  found  during  roadside  check  in 
Austria  (91%),  Luxembourg  (86%),  France  (85%),  Slovakia  (82%)  and  Sweden  (82%).  In 
contrast,  the  lowest  percentage  of  digital  tachograph  was  reported  in  Cyprus  (28%)  and 
Greece (27%). Table 3 below provides a full overview. 

Table 3: Overview of the number of vehicles stopped for roadside check by type of tachograph 

Member  
States 
AT 
BE 
BG 
HR 
CY 
CZ 
DK9 
EE 
FI10 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SL 
ES 
SE 
UK 
Total 

Analogue  
tachograph 
23,568 
14,449 
70,375 
18,864 
4,759 
37,287 

% 
analogue 
9% 
27% 
24% 
61% 
72% 
29% 

Digital  
tachograph 
240,479 
38,871 
225,521 
12,020 
1,841 
89,479 

% 
digital 
91% 
73% 
76% 
39% 
28% 
71% 

3,934 

49% 

4,094 

51% 

115,617 
523,487 
29,783 
23,203 
2,293 
308,395 
10,258 
31,188 
415 
15 
7,248 
319,046 
34,600 
172,162 
2,468 
7,207 
133,457 
8,143 
72,269 
1,977,872 

15% 
18% 
73% 
16% 
24% 
46% 
39% 
51% 
14% 
38% 
22% 
63% 
56% 
53% 
18% 
37% 
29% 
18% 
39% 
28% 

659,731 
2,368,617 
11,025 
120,007 
7,068 
361,310 
15,794 
29,710 
2,598 
24 
25,723 
190,055 
27,066 
154,926 
11,443 
12,127 
325,030 
36,561 
112,861 
5,084,766 

85% 
82% 
27% 
84% 
76% 
54% 
61% 
49% 
86% 
62% 
78% 
37% 
44% 
47% 
82% 
63% 
71% 
82% 
61% 
72% 

6. Checks at premises 

As indicated in the  report, the total share of working days checked at premises has slightly 
risen  by  1%.  In  total,  Member  States  checked  around  663,000  drivers  during  2015-2016 
which constitutes 12% of drivers compared to 2013-2014. However, there are Member States 
who significantly increased the numbers of drivers checked at the premises (Hungary by 196 
%, Finland by 133% and Luxembourg by 70%). Other Member States covered significantly 

9 Data is not available for Denmark 
10 Data from Finland was not included to its incompleteness.  

7 

 
 
 
 
 
 
 
 
 
 
 
                                                            
 
less drivers during their checks, namely Ireland (-90%), Greece (-70%), Romania (-67%) and 
Portugal (-55%). 

At  the  same  time,  the  share  of  drivers  checked  at  the  premises  compared  to  all  drivers 
controlled at premises and roadside, continued to increase throughout the years with 10% in 
2015-2016  (9%  share  in  2013-2014  and  7%  in  2011-2013  and  5%  in  2009-2010).  Table  4 
below provides an overview of this share across Member States.  

The offence rate per undertaking was extremely high in Latvia (553 offences per undertaking 
checked),  Poland  (81  offences),  Sweden  (76  offences),  Germany  (65  offences)  and  Ireland 
(30 offences).  

Figure  4:  Share  of  working  days  checked  at  premises  checks  from  2011-2016  by 
Member States 

Overview - Share of working days checked at 
premises checks  

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

T
A

E
B

G
B

R
H

Y
C

Z
C

K
D

I

E F
E

R
F

E
D

L
E

U I
E
H

T
I

V
L

T
L

U
L

T
M

L
N

L
P

T
P

O
R

K
S

L
S

S
E

E
S

K
U

e
g
a
r
e
v
A
U
E

Share of working days checked at premises checks 2011-2012

Share of working days checked at premises checks 2013-2014

Share of working days checked at premises checks 2015-2016

7. Offences – detection rate 

Like  in  the  last  reporting  period,  it  is  almost  the  same  small  group  of  Member  States  who 
detected over two thirds (73%) of all offences detected. These countries are Germany (32% 
of  total  offences),  Poland  (16%),  Austria  (11%),  Latvia  (8%)  and  Italy  (7%).  The  average 
share  of  offences  detected  on  the  roadside  is  around  58%  and  42%  at  the  premises  of 
undertakings.  Significant  disparities  continue  to  exist  between  Member  States  as  well 
illustrated  in  Figure  5  with  offence  rates.  Almost  the  same  Member  States  are  marking  the 

8 

 
 
 
 
 
lowest  offence  rate  in  the  EU:  0.04  in  Bulgaria,  0.38  in  Hungary,  0.53  in  France,  0.99  in 
Romania, even though they are among the top seven Member Stats with the highest working 
days  checked  in  the  EU.  At  the  same  time,  the  following  Member  States  have  very  high 
offence  rates:  16.89  in  Latvia,  8.34  in  Greece,  7.59  in  Austria,  6.01  in  Poland  and  6.29  in 
Cyprus. An important increase in the offence rate can be observed in Greece11 (from 3.10 to 
8.34)  Luxembourg  (from  1.33  to  5.01)  and  Poland  (2.69  to  6.01),  whereas  a  drop  was 
reported by Lithuania (4.07 to 1.9) and Malta (3.03 to 1.61) compared to the last report. The 
table  in  Figure  5  provides  an  overview  of  the  offence  rate  development  since  2011.  Given 
these  discrepancies,  the  enforcement  practices  across  the  EU  should  be  aligned,  leading  to 
harmonised checks that have similar outcomes. The Commission is currently in the process of 
establishing  a  common  training  curriculum  for  EU  enforcers  to  ensure  that  the  initial  and 
continuing  training  enforcers  in  the  EU  adhere  to  a  minimum  standard  and  to  ensure  that 
enforcement practices are harmonised. 

8. Offences detected at roadside 

In total, 58% of the total offences were detected on the roadside in the EU, which represents a 
decrease compared  to  63%  in  the last  report. The offence rates found on the roadside were 
very  diverse12  across  the  EU.  Compared  to  the  EU  average  of  2.07  offence  rates  are  in 
particular high in Greece13 (11.17), Austria (8.69) and significantly more than the EU average 
in Slovakia (3.51) Ireland (3.38), Sweden (3.29) and Poland (3.21). Very low offence rates at 
the  roadside  were  reported  in  Bulgaria  (0.08),  Hungary  (0.32),  Latvia  (0.49),  Finland  (0.5) 
and France (0.55). A considerable increase in detection rate could be seen in Greece (4.64 to 
11.17) Romania (from 0.42 to 1.74), Poland (1.22 to 3.21) and in the Czech Republic (1.11 to 
2.59). An important decrease in the offence rate could be observed in Estonia (4.33 to 2.39), 
in Lithuania (5.77 to 2.33) and Latvia (1.68 to 0.49). 

However,  in  some  of  the  Member  States,  the  numbers  of  detected  offences  related  to  non-
national  vehicles  prevail,  namely  Luxembourg  (84%),  Slovenia  (79%)  Hungary  (68%), 
Belgium  (65%),  Austria,  Bulgaria  and  France  (64%),  Sweden  (63%)  and  Lithuania  (61%). 
This  may  be  explained  by  the  fact  that  many  Member  States  mentioned  above  performed 
more  controls  on  non-national  vehicles.  However,  as  for  Bulgaria,  Hungary,  Lithuania, 
Luxembourg,  Poland,  Romania,  Slovenia  and  Sweden,  the  offences  detected  on  foreign 
registered vehicles appear more disproportionate. 

9. Offences detected at the premises 

Offence  rates  at  the  premises  of  undertakings  in  the  EU  are  also  very  diverging.  Indeed, 
several Member States are well above the EU average of 4.19 with the highest detection rate 
in  Latvia  (29.27),  Poland  (12.04),  Germany  (11.27),  Cyprus  (10.61)  and  the  Netherlands 
(9.87). This stands in contrast with countries with a very low detection rate such as Bulgaria 
(0.02),  Croatia  (0.02),  Portugal  (0.06),  Romania  (0.27),  Greece  (0.31),  France  (0.42),  UK 

11 Greece has however only checked 0.1% instead of 3% of the number of working days required. 
12 All Member States except for Denmark has provided the number of roadside offences. 
13 Greece has not met the threshold. 

9 

 
 
                                                            
(0.48), Spain (0.63), Malta (0.65) and Hungary (0.79). The majority of these countries, except 
for Croatia and Malta had also reported very low detection rate in the last report. 

Compared  to  the  2013-2014  reporting  period,  there  is  a  significant  rise  in  detection  rates 
noted in Poland (from 5.42 to 12.04), Finland (from 3.2 to 6.13), and Luxembourg (from 1.1 
to  6.69).  In  contrast,  the  detection  rate  at  premises  has  decreased  significantly  in  Germany 
(14.01 to 11.27), Malta (4.25 to 0.65) and Sweden (5.41 to 3.89). 

Table 5: Breakdown of offences found on the roadside and premises checks in 2015-
2016 

Checks at 

Breaks 

Rest 
periods 

Driving 
time 

Driving 
time 
records 

Recording 
equipment 

Lack/availability 
of  records for 
other work 

Roadside 

16% 

26% 

16% 

Premises 

26% 

21% 

10% 

Total 

21% 

24% 

13% 

15% 

33% 

24% 

18% 

5% 

11% 

9% 

5% 

7% 

10 

 
 
 
 
Figure 514: Total offence rate at the roadside and premises checks by Member States between 2011-2016 

TOTAL offences rate (per 100 working days checked) 

e
l
t
i
T
s
i
x
A

10,00

9,00

8,00

7,00

6,00

5,00

4,00

3,00

2,00

1,00

0,00

AT BE BG HR CY

CZ DK

EE

FI

FR DE

EL HU IE

IT

LV

LT

LU MT NL

PL

PT RO SK

SL

ES

SE UK

EU
Aver
age

2015-2016 7,59 2,26 0,04 1,62 6,29 2,61 0,44 1,93 2,45 0,53 3,92 8,34 0,38 1,31 2,35 16,8 1,96 5,01 1,61 3,56 6,01 1,96 0,99 4,20 2,29 1,78 3,50 1,22 2,63

2013-2014 7,24 2,65 0,04 1,61 5,31 1,68 0,31 2,47 1,68 0,58 3,96 3,10 0,52 1,51 2,69 0,55 4,07 1,33 3,03 2,44 2,69 1,87 0,39 4,64 1,93 1,89 3,68 1,22 2,17

2011-2012 4,50 1,82 0,08

0,66 1,76 0,38 2,75 6,75 0,95 4,06 4,59 3,73 2,92 4,40 0,82 4,38 2,29 4,04 3,05 1,91 1,83 0,36 6,07 4,28 1,52 2,46 1,70 2,43

14 Denmark has not provided data on offences detected at the roadside 

 
 
 
 
                                                            
 
 
  
10. Categories of infringements detected at roadside  

The  main  types  of  infringements  detected  at  the  roadside  checked  by  Member  States15 
remained on average relatively similar to the last report in terms of share to the total offences 
detected at the roadside: breaks (decreased from 17% to 16%), rest periods (increased from 
25%  to  26%),  driving  time  (decreased  from  18%  to  16%),  driving  time  record  for  the 
preceding 28 days (decreased from 17% to 15%) as well as lack and availability of record for 
other work remained at 9%. In contrast, the offences detected regarding recording equipment 
increased  from  13%  to  around  18%  of  the  total  offences  at  the  roadside.  Offences  on  the 
recording equipment comprise offences on the incorrect functioning of the tachograph as well 
as  their  misuse  and  manipulation.  On  average  manipulation  and  misuse  of  the  tachograph 
constituted  16%  of  the  overall  offences  (11%  in  2013-2014)  at  the  roadside,  so  around 
317,600 offences between 2015-2016. In Germany (30%), Poland (33%) and the UK (33%) 
manipulation  and  misuse  of  the  tachograph  made  up  even  around  a  third  of  their  offences 
found. However, national authorities, among them the Dutch, informed the Commission, that 
tachograph fraud and manipulation techniques became increasingly sophisticated and makes 
monitoring and enforcement more difficult and take up a large amount of available inspection 
capacity, so the real number of offences is likely to be much higher. 

Looking  at  national  figures,  the  detected  infringements  on  driving  time  were  in  particular 
high  in  Luxembourg  (35%),  while  offences  on  breaks  were  high  in  Cyprus  (31%),  Ireland 
(30%),  Slovakia  (35%)  and  Sweden  (38%).  Offences  in  rest  periods  were  in  particular 
significant  in  Belgium  (36%),  Luxembourg  (37%),  Romania  (40%),  Slovakia  (38%),  Spain 
(40%)  and the  UK (42%).  In  contrast to  the low EU average  regarding the infringement  of 
providing the driving records, it constitutes a significant share in individual Member States, 
such  as  in  Bulgaria  (33%),  the  Czech  Republic  (33%),  Italy  (41%),  Latvia  (47%)  and 
Lithuania (33%).  

11. Categories of infringements detected at premises  

Compared  to  the  last  report,  offences  detected  at  the  premises16  of  undertakings  are 
decreasing, namely on driving time (14% to 10%), breaks (33% to 26%), rest period (24% to 
21%)  and  on  lack  and  availability  of  records  for  other  work  (6%  to  5%).  Offences  on 
recording equipment rose from 4% to 5% and there is a sharp increase of offences detected 
on driving time records from 19% to 33%, which have to be kept at least for one year by the 
transport  undertakings.  The  latter  offence  is  significant  in  the  Czech  Republic  (54%  of 
national  offences  detected  at  premises),  Italy  (69%)  and  Poland  (80%).  A  possible 
explanation  was  given  by  the  Italian  authorities  which  explained  that  the  low  fines  for 
missing driving records would encourage drivers and operators to claim that they are not in 
possession of driving time records rather than risking to be fined for other offences that are 
subject  to  significantly  higher  fines.  Driving  time  offences  were  also  very  high  in  Greece 
(44%)17, Lithuania (36%), Malta (57%)18, Portugal (32%) and Slovenia (35%). Offences on 

15 Finland did not provide a breakdown of offences at the road. 
16 Finland, Ireland and Latvia did not provide a full or no breakdown of total offences at the premises. 
17 Out of 176 offences at premises reported. 

12 

 
                                                            
breaks were frequently detected in Austria (56%), Belgium (41%), Finland (46%), Germany 
(45%), Ireland (55%) and Luxembourg  (41%). Infringements on rest periods constituted an 
important  share  in  Estonia  (53%),  Greece  (52%),  Hungary  (56%)  and  Romania  (54%). 
Offences on recording equipment constitute 4% and amount to around 48,800 in total during 
2015-2016. Their national share was in particular high in Croatia (22%) and the Netherlands 
(28%). Infringements on the lack and availability of records of other work were in particular 
high in Sweden where they constituted 46% of the national offences detected at the premises. 

12. Cooperation between Member States 

According to Directive 2006/22/EC, Member States are obliged to undertake not less than six 
concerted  roadside  checks  per  year  with  at  least  one  other  Member  State.  Four  Member 
States19 did not provide information on the number of concerted checks. Out of the Member 
States that did provide information on checks, 15 Member States20 met the required number 
of concerted checks per year.  

Table 6 below presents the number concerted checks and exchange of experience carried-out 
by Member States in 2015-2016. It also provides an overview of the focus of these concerted 
checks and exchange of experience and which Member States cooperated.  

Table 6: Overview of concerted checks per Member States 

Austria 

Concerted checks:  

  6 a year, ECR/TIPSOL Member States 

Exchange of experience, data, staff:  

  6 bilateral (32 staff), 4 multilateral (10 staff) 

Subject for exchange: driving time checks, manipulation of recording 
equipment, technical checks, securing of loads. ECR/TIPSOL Member 
States 
No data provided 

Belgium 

Bulgaria 

Concerted checks:  

  1 joint check with Romanian control bodies (ARR) in Romania 

and Bulgaria 

Exchange of information on detected infringements committed by Bulgarian 
drivers in Germany, Hungary, Austria, Spain, the UK, Italy, Latvia, Romania 
and Slovenia.  
No information provided 

  29 road transport inspectors at the Department of Road Transport 

and 80 members of the Cypriot traffic and transport police 
received theoretical and practical training on roadside checks. 

Croatia 

Cyprus 

18 Out of seven of offences at premises reported. 
19 Croatia, Cyprus, Finland, Greece 
20 Austria, Czech Republic, Germany, France, Hungary, Ireland, Latvia, Lithuania, Luxembourg, Netherlands, 
Romania, Slovakia, Spain, Sweden, UK. 

13 

 
                                                                                                                                                                                         
 

In December 2016, two inspectors from the Labour Inspection 
Department took part in a week-long training programme on 
tachographs and driving hours organised by the Austrian Ministry 
of Transport, in cooperation with the corresponding Austrian 
government department. 

Czech 
Republic 

2015: 
Concerted checks: 

  3 joint inspections in Czech Republic 
  5 joint inspections with Germany, 1 with Poland, 1 with Slovakia 

 

and 1 with Hungary.  
Inspections carried out in mutual cooperation with Germany’s 
BAG, Poland’s ITD, Slovakia’s NIP and Hungary’s NHK. 

Exchange of experience: 

  Multilateral exchange scheme conducted in Poland, France and 

 

the Netherlands; workshop focusing on ADR – Germany (always 
with one representative from the Czech Republic) 
Intensive cooperation within the ECR group, focused exchange of 
experienced related to checks on social legislation, detection of 
manipulation and fraud involving tachographs, ADR inspections, 
checks on the technical state of vehicles and performance of low-
speed weighing.  

2016: 
Concerted checks:  

  5 joint inspections in Czech Republic 
  5 joint inspections with Germany, 2 with Poland, 1 with Slovakia 

and 1 with Hungary.  

  The inspections were carried out in mutual cooperation with 

Germany’s BAG, Poland's ITD, Slovakia's NIP, Hungary's NHK 
and inspectors from the UK. 

Exchange of experience: 

 

  Multilateral exchange scheme conducted in Belgium, France, 
Poland and Hungary; workshop focusing on manipulation and 
fraud involving tachographs: Poland (always with one participant 
from the Czech Republic) 
Intensive cooperation within the ECR group, focusing on the 
exchange of experiences relating to ADR inspections, checks on 
social legislation and the detection of manipulation and fraud 
involving tachographs. Deployment of experts on the above 
topics. Attendance at discussions on those topics by WP.15 
representatives responsible for legislation on the carriage of 
dangerous goods (ADR). 

Denmark 

  The National Police participated in (concerted) checks arranged 

by TISPOL. No other concerted checks were recorded. 

14 

 
Exchange of experience: 

  The National Police exchanges information concerning inspection 
procedures, data, etc., with other Member States upon request. It 
also asks other Member States about their inspection procedures, 
etc., as required. 

Estonia 

2015: 

2016:  

  Estonian Police authorities carried out common road side checks 1 
time with the Latvian and Lithuanian enforcement authorities and 
1 time with the Finnish Police. 

  Estonian Police authorities initiated common road side checks 1 

time with the Latvian and Lithuanian enforcement authorities and 
1 time with the Finnish Police. 

Finland 

No information provided 

France 

In both 2015 and 2016, France participated in 7 concerted checks each year, 
as an active member of ECR.  The focus of these controls was cabotage, 
roadworthiness tests, transportation of dangerous goods, passenger transport, 
tachograph fraud and European social regulations. 
Exchange of experiences: 

  France organised in both 2015 and 2016 a bilateral cooperation 

session with Germany. 

  France participated in multilateral cooperation exchanges in 2015 
and 2016 organised by ECR members in the Netherlands, Poland, 
Hungary, and the UK 

Germany 

  Experience of ‘manipulation of digital recording equipment’ 

exchanged at national level between the police, the federal-state 
inspection authorities and the Federal Goods Transport Office 

Concerted checks: 

  Total of 14 joint checks with other ECR countries, 12 of which 

Greece 

Hungary 

involved TISPOL 
Exchange of experience: 

  The Federal Goods Transport Office was notified of three exchanges 

in total. Only Mecklenburg-Western Pomerania provided data relating 
to joint initiatives. 
No information provided 

2015: 
Concerted checks: 

  3 Hungary-Slovenia checks 
  3 Hungary-Croatia checks 
  1 Hungary-Romania checks 
  Annual regional multilateral roadside checks – 3 days in Zala, 

15 

 
Hungary with the participation of CZ, DE, SI, AT, SK, PL, RO, FI, 
BG, Ukraine, RS experts. 

2016: 
Concerted checks: 

  3 Hungary-Slovenia checks 
  4 Hungary-Croatia checks 
  2 (x 2 days) Hungary-Romania 
  Annual regional multilateral roadside checks – 3 days in Zala, 

Hungary with the participation of Ukraine, SI, CZ, SK, PL, DE, BG, 
SE, HR, RO. 

Exchange of experience:  

 

In 2016 participation at ECR exchanges in Brussels, Biarritz and 
organisation, hosting of one exchange in Budapest with 20 experts 
from 9 countries (BE, NL, LU, FR, DE, PL, RO, IE, CZ). 

Ireland 

2015:   
Concerted checks: 

Italy 

  23 checks with Northern Ireland and the United Kingdom 

2016: 
Concerted checks: 

  18 checks with Northern Ireland and the United Kingdom 

Exchange of experience: 
Attendance at exchange programmes organised through Euro Controle Route 
Working Groups.  
Apart from enforcement exchanges there were also numerous meetings 
between senior management personnel from DVSA; DVANI and RSA as 
part of a Tripartite Working Group.  
Ireland is a member of ECR and Corte and participates at working group 
meetings in relation to training, enforcement practice and interpretation of the 
regulations.  
2015: 

Traffic Police, as part of the activities organised by TISPOL actively 
participated in the joint European checking and safety campaigns on the 
carriage of goods and people, to combat offences and conduct 'thematic' 
campaigns across Europe.  

2016: 

During 2016, the Traffic Police, as part of the activities organised by 
TISPOL, the European Traffic Police Network, actively participated in joint 
European checking and safety campaigns on the carriage of goods and 
people. 

As part of the joint European 'Truck and Bus' campaign, three ‘Truck and 
Bus’ operations were carried out in Italy in 2016, in February, July and 

16 

 
October, during which 3 275 offences were detected relating to driving time, 
rest breaks and the proper functioning of tachographs in general. 

Latvia 

2015: 
Concerted checks: 

  11 roadside checks with Lithuania 
  1 road check with Estonia 

2016:  
Concerted checks: 

  9  roadside checks with Lithuania 
  1 road check with Estonia  

Lithuania 

Between 2015 and 2016, 26 joint vehicle-checking exercises were carried out 
with officials from the Polish and Latvian inspectorates. Joint checks were 
carried out with Polish officials in the Kalvarija (LT) – Budzisko (PL) border 
zone, and with officials from the Latvian inspection body in the Saločiai (LT) 
– Grenctāle (LV), Smėlynė (LT) – Medumi (LV), Obeliai (LT) – Subate 
(LV), Būtingė (LT) – Rucava (LV) and Kalviai (LT) – Meitene (LV) border 
zones. 

The Inspectorate, together with other Euro Contrôle Route (ECR) member 
countries, took part in 10 joint freight and passenger vehicle inspections 

Luxembourg  2015:  

- 2 checks in  Sterpenich with Belgium and Netherlands. 
- 5 checks in Markusberg and Kaiserslautern with Germany. 
- 1 Interregio exercise with Germany 
- 3 exercises BENEFRALUX with Belgium, Netherlands and France. 
2016 : 
- 30 checks on the Dudelange-Zoufftgen route with France. 
- 3 checks in Markusberg with Germany 
- 3 exercises BENELUX with Belgium, Netherlands and France 
- 1 operation in Hazeldonk with Belgium and Netherlands. 

Malta 

One concerted check was carried out during software training in Poland on 
the 24th November 2016 with the Polish Authority 

Netherlands  8 checks carried out with ECR/TIPSOL partnership. 

. Each year between 25 and 30 Dutch inspectors participate in international 
activities organised by the ECR, such as bilateral and multilateral exchanges 
of inspectors, workshops and master classes. 
The Netherlands also invested heavily in initiating, organising and managing 
these activities during the reporting period. 

17 

 
Poland 

In addition, the Netherlands is an active participant in the collaboration 
within CORTE, which includes work on the development of accepted 
standardised calculation rules for the calculation of driving times and rest 
periods on the basis of the applicable EU legislation. 
Road Transport Inspectorate representatives participated in the following 
coordinated inspection organised by ECR:  
2015: 
7 concerted inspections  

2016: 
7 concerted inspections 

For both years PL participated at international exchanges on tachograph 
fraud, passenger transport, secure loading, overloading, social dumping, 
technical checks of vehicles etc. 
PL has also participated at the Master Classes on tachograph as well training 
workshops on transport of dangerous goods. 
Portugal has participated in the relevant meetings organised by the competent 
bodies at Community level. 
2015: 
Concerted checks: 
7 concerted checks organised by ECR where member state authorities from 
Austria, Netherlands, France, Belgium, Poland, United Kingdom, Lithuania, 
Czech Republic, Slovenia, Germany and Romania participated. 
Exchange of experience: 
3 multilateral events in France, Poland and the Netherlands organised by 
ECR. 
3 workshops in Belgium, Netherlands and Germany. 
1 master class in Germany. 
1 regional roadside check in Hungary. 
2 bilateral roadside checks organised with Hungary. 
2016: 
Concerted checks: 
7 concerted checks organised by ECR with participants from Belgium, 
Croatia, Ireland, Germany, Netherlands, France, Spain, Austria, Poland, 
Hungary, United Kingdom, Bulgaria, Lithuania, Luxembourg, Czech 
Republic, Slovenia and Romania. 
Exchange of experience: 
4 multilateral events in France, Belgium, Poland and Hungary by ECR. 
1 workshop in Belgium organised by CORTE and CVSA USA. 
2 master classes organised in Germany by ECR. 
4 bilateral roadside checks organised between Romania and Hungary. 
Concerted checks: 
• 

7 checks with the Czech Republic. 

18 

Portugal 

Romania 

Slovakia 

 
 
 
Slovenia 

Spain 

Sweden 

United 
Kingdom 

4 checks with Hungary 
1 check with Poland. 

• 
• 
Concerted checks: 
3 concerted checks with Hungary and Croatia. 
Exchange of experience: 
Slovenia has a status of an Active observer in the ECR organisation. In 2015 
and 2016 inspectors participated in Multilateral concerted checks in other 
ECR member countries. 
Concerted checks: 
8 ECR coordinated controls (4 per year each in 2015 and 2016) 
6 ECR/TIPSOL coordinated controls (3 per year each in 2015 and 2016) 
2015: 
Concerted checks: 
7 different checks with Norway, Denmark, Poland and Romania. 
2016: 
Concerted checks: 
8 different checks with Norway, Denmark, Germany, Hungary and their 
neighbouring countries. 
2015 and 2016: 
Concerted checks: 
7 checks each year with ECR members including Ireland, Belgium, 
Luxembourg, Netherlands, France, Germany, Poland, Austria, Romania, 
Bulgaria, Hungary Lithuania, Slovenia, Czech Republic and Croatia.  
Exchange of experience: 
UK hosted an exchange in 2015 involving Great Britain and the Netherlands 
on remote enforcement and targeting. 
In 2016 UK hosted an exchange involving Great Britain, Belgium, 
Netherlands, Luxembourg, Slovenia, France, Poland and Ireland. 

13. Penalties 

Article 19 of Regulation (EC) No 561/2006 sets out that Member States shall lay down rules 
on  penalties  that  are  to  be  effective,  proportionate,  dissuasive  and  non-discriminatory. 
Member States shall notify the Commission of these measures and the rules on penalties. For 
the current report, the Commission has been notified of the following: 

Multiple  Member  States  namely  Austria,  Bulgaria,  Czech  Republic,  Denmark,  Estonia, 
Spain, Ireland, the Netherlands, Romania, Slovenia and the UK have increased fines in 2015 
and  2016  for  tachograph  related  infringements  –  such  as  fraud,  lack  of  tachograph  systems 
but also relating to the rules for driving and rest times.  Denmark for example introduced a 
general  tolerance  limit  of  5%  with  anything  beyond  this  number  being  prosecuted.  In 
addition, drivers who deviate from the maximum driving time or minimum rest time by more 
than 30% will be disqualified. Similarly, Romania introduced a system where vehicles can be 
immobilised in order to restore compliance with the driving and resting time rules. 

19 

 
 
A number of Member States raised the amount of the fines in proportion to the severity of the 
infringement.  These  Member  States  have  also  indicated  that  the  higher  fines  have  ensured 
more compliance with the rules and regulations by both undertakers and drivers.  

14. Exceptions granted by Member States 

According  to  Article  13  of  Regulation  (EC)  No  561/2006,  Member  States  may  grant 
exceptions  from  the  application  of  provisions  on  driving  times,  breaks  and  rest  periods, 
provided  that  certain  specific  conditions  are  met  and  that  the  overall  objectives  of  the 
Regulation are not prejudiced. Member States are obliged to inform the Commission of the 
exceptions granted.  

Since  the  previous  report,  Romania  added  the  exceptions  of  (f),  (g),  (h),  (j)  –  concerning 
vehicles  under  7.5t  for  gas/electricity,  circus  and  funfair  vehicles,  milk  or  animal  feed 
transportation and hub facilities.  

The same information is also available on the Commission's website21.  

21 https://ec.europa.eu/transport/sites/transport/files/national_exceptions_regulation_2006_561.pdf 

20 

 
                                                            
13.1 a: non-competing 
public authorities1 
13.1 b: agricultural etc. 
own activity < 100 km2 
13.1 c:agricultural/forestry 
tractors <100 km3 
13.1 d: <7,5 tons universal 
services <100 km4 
13.1 e: operating on islands 
<2300 square km5 
13.1 f: <7,5 t <100 km gas/ 
electricity6 
13.1 g:  
instruction/examination 
driving licence/CPC7 
13.1 h: sewerage/flood 
protection/water etc8 
13.1 i: non-comm.  
passenger transp. between 
10-17 seats9 
13.1 j: circus/funfair10 
13.1 k: mobile projects for 
education 
13.1 l: milk/animal feed 
from/to farms11 
13.1 m: transporting 
money/ valuables12 
13.1 n: animal waste or 
carcasses13 
13.1 o: hub facilities14 

13.1 p: live animals farms -
> markets and vice 
versa<100km15 

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1. The following Member State introduced additional restrictions:  

a.  The United Kingdom: a vehicle does not fall within the description specified unless the vehicle:  

(a) is being used for the provision of ambulance services- (i) by a relevant National Health Service (NHS) body, or (ii) in pursuance of arrangements made by or at the request of a relevant 
NHS body, or made with the Secretary of State or with the Welsh or Scottish Ministers; 
(b) is being used for the transport of organs, blood, equipment, medical  supplies or personnel  - (i) by a relevant NHS body, or (ii) in pursuance of arrangements of the kind  mentioned in 
paragraph (a)(ii)  
(c)  is  being  used  by  a  local  authority  to  provide,  in  exercise  of  social  services  functions  -  (i)  services  for  elderly  people,  or  (ii)  services  for  persons  to  whom  section  29  of  the  National 
Assistance Act 1948 (welfare arrangement for physically and mentally handicapped persons) applies;    
(d) is being used by Her Majesty's Coastguard, a general lighthouse authority or a local lighthouse authority;  
(e) is being used for the purpose of maintaining railways by the British Railways Board, any holder of a network licence (within the meaning of Part 1 of the Railways Act 1993) which is a 
company wholly owned by the Crown (within the meaning of that Act), Transport for London, any wholly owned subsidiary of Transport for London, a Passenger Transport Executive or a 
local authority  
(f) is being used by the British Waterways Board for the purpose of maintaining navigable waterways  

2.  The following Member States introduced additional restrictions:  

a.  Estonia - within a radius of 50 km of the place where the vehicle is usually based, including towns within this area 
b.  France - only vehicles or combinations of vehicles up to 7,5 tonnes and only within a radius of 50 km 
c.  Slovenia – within a radius of up to 50 km 
d.  Spain – agriculture etc. own activity within a range < 50 km  
e.  The United Kingdom - a vehicle which is being used by a fishery undertaking does not fall within the description specified unless the vehicle is being used: 

(a) to carry live fish, or 
(b) to carry a catch of fish from the place of landing to a place where it is to be processed 

3.  The following Member States introduced additional restrictions: 

a.  Slovenia - within a radius of up to 50 km 

4.  The following Member States introduced additional restrictions: 

a.  Belgium,  Bulgaria,  Croatia,  Cyprus,  Czech  Republic,  Finland,  France,  Hungary,  Italy,  Latvia,  Lithuania,  Luxembourg,  the  Netherlands,  Poland,  Portugal,  Slovakia,  Spain  – 

within a radius < 50km 

b.  The United Kingdom – vehicles between 3.5 - 7.5 tonnes used by universal service providers within a 50 km radius of the base of the undertaking require a tachograph 

5.  The following Member States introduced additional restrictions: 
a.  France - operating on islands <400 square km 
b.  Spain – operating on islands < 250 square km 
6.  The following Member States introduced additional restrictions: 

a.  Croatia, Cyprus, Czech Republic, Estonia, Finland, France, Hungary, Lithuania, Poland, Portugal, Slovakia, Spain – within a radius < 50km 

7.  The following Member States introduced additional restrictions: 

Italy - it refers only to the obligation of equipping and using tachograph 

a. 
b.  Luxembourg - exception only for the (learning) driver, instructor must respect Regulation (EC) No 561/20006 

8.  The following Member States introduced additional restrictions: 

a.  Austria: 

22 

 
 
 
 
 
 
 
 
 
 
(a) vehicles used by the regional authorities’ road construction offices and driven by employees of the provinces or municipalities are entirely exempted 
(b) vehicles used in connection with sewerage, flood protection, water, gas and electricity supply, telegraph and telephone services, radio and television broadcasting, and the detection of radio 
or television transmitters or receivers are entirely exempted where driving of vehicles does not constitute the driver’s main activity 
(c) vehicles used by household refuse collection authorities are exempted only from the rules on breaks under Article 7 of Regulation (EC) No 561/2006 
(d) vehicles used in winter by road construction offices, where not covered by the exemption under point 9 a.(a), are exempted only from the rules on breaks under Article 7 of Regulation (EC) 
No 561/2006  

b.  France - for door-to-door household refuse collection and disposal, only within a radius of 100 km 

9.  The following Member States introduced additional restrictions: 

a.  Estonia - owner/authorised user of a vehicle with 10-17 seats who is a parent of 4/more children, respective entry made on a registration certificate of the vehicle and the vehicle 

is used for non-commercial passenger transport 

b.  France -  not for the transport of children 

10.  The following Member State introduced additional restrictions: 

a.  Spain - only when own activity 

11.  The following Member States introduced additional restrictions: 

a.  Austria - vehicles used to collect raw milk from farms exempted only from the rules on breaks under Article 7 of Regulation (EC) No 561/2006 
b.  Estonia, Latvia and Lithuania, as of 1/01/2008, mutually apply the exception from Articles 5 to 9 to vehicles used for milk collection from farms,...etc.,  only in cases where the 

service radius does not exceed 100 km 

c.  France - within a radius of up to 150 km of the base of the undertaking 
d.  Germany – within a radius of 100km 
e.  Spain – milk/animal feed from /to farms within a range < 100 km 

12.  The following Member States introduced additional restrictions: 

a.  Austria – exception only from the rules on breaks under Article 7 of Regulation (EC) No 561/2006 
b. 

Ireland - vehicles specially designed for mobile banking, exchange and saving transactions 

13.  The following Member State introduced additional restrictions: 

a.  Germany - within a radius of up to 250 km of the base of the undertaking 

14.  The following Member State introduced additional restrictions: 

a.  The Netherlands – on or between hub facilities within a range of 5 km 

15.  The following Member State introduced additional restrictions: 

a.  Belgium, Croatia, Cyprus, Czech Republic, Estonia, Finland, France, Hungary, Latvia, Lithuania, the Netherlands, Poland, Portugal, Slovakia, Spain, Sweden – within a radius < 

50km 

23 

 
 
 
 
16. Comments and proposals  

Some  Member  States  shared  their  views  regarding  the  Commission’s  proposal  as  part  of  the  Mobility 
Package I22. Finland express its doubts regarding the amendment to Directive 2006/22/EC that would extend 
the  scope  of  the  monitoring  requirements  to  include  the  Road  Transport  Working  Time  Directive 
2002/15/EC  which  could  lead to  problems  to  coordinate  those  in  practice.  Slovakia  also  shared  its  doubts 
regarding the proposal to amend Regulation (EC) No 561/2006. This related in particular to the provisions 
on the duration for the regular weekly rest23, the total accumulated driving time during any two consecutive 
week24 Regulation (EC) No 561/2006 and in particular the provision of Article 8.2 on new daily rest period.  

Some  Member  States  referred  to  the  training  of  enforcers  at  national  level  and  the  importance  of  joint 
inspections.  The  Dutch  authorities  highlighted  that  increasingly  sophisticated  tachograph  fraud  and 
manipulation techniques make monitoring and enforcement more difficult and take up a large amount of the 
available inspection capacity. Professional development training for inspection staff and the expansion and 
renewal  of  inspection  methods  and  equipment  create  significant  pressure  on  the  available  work  force  and 
funds.  Therefore,  the  Netherlands  invests  heavily  in  sharing  and  maintaining  the  necessary  expertise  and 
information within the ECR, TISPOL and Benelux networks in order to keep abreast of developments in the 
field.  
The Czech Republic also flagged out the importance of proactive involvement of Czech representatives in 
activities on the ECR agenda and that there was desire for a constant deepening of professional knowledge 
regarding inspection procedures in all specific areas of inspection activity.  

Austria authorities also shared the fact that the training programme of their Federal Ministry of the Interior 
and the Federal Ministry of Labour, Social Affairs and Consumer Protection includes regular courses for the 
inspection bodies. The training covers social legislation and the detection of manipulation and is based on 
the TRACE project.  

It is worth noting that the Commission is planning on elaborating common criteria for training of enforcers 
across the EU which would allow for a more consistent approach to enforcement throughout the EU.  

17. Interpretation of Regulation (EC) No 561/2006 and Directive 2002/15/EC 

In  the  recent  years, the Court  of  Justice  of  the European  Union  shed  light  on  interpretation  of Regulation 
(EC) No 561/2006 by means of the following preliminary ruling:  

Judgment of the European Court of Justice of 20 December 2017 in case C-102/16 

The case relates to the ban for drivers to take their regular weekly rest period in their vehicle. Regulation 
(EC)  No  561/2006  on  the  harmonisation  of  certain  social  legislation  relating  to  road  transport  requires  
drivers    to    take    a    regular    daily   rest    period    of  at    least    11    hours    (which    may,    subject    to  certain 
conditions,  be  reduced  to  9  hours)  and  a  regular  weekly  rest  period  of  45  hours  (which  may,  subject  to 
certain conditions,be reduced to 24 hours). The regulation adds that, if a driver chooses to do so, daily rest 
periods  and  reduced  weekly  rest  periods  away  from  base  may  be  taken  in  the  vehicle,  as  long  as  it  has 
suitable sleeping facilities for each driver and the vehicle is stationary. The question at stake in this case was 
whether  Article  8(6)  and  (8)  of  Regulation  No  561/2006  must  be  interpreted  as  meaning  that  the  regular 

22 Proposal for a directive of the European Parliament and of the Council amending Directive 2006/22/EC as regards enforcement 
requirements and laying down specific rules with respect to Directive 96/71/EC and Directive 2014/67/EU for posting drivers in 
the road transport sector - COM(2017) 278 final 
23 Article 4(h) of Regulation (EC) No 561/2006 
24 Article 6.3 of Regulation (EC) No 561/2006 

24 

 
                                                            
weekly rest periods referred to in Article 8(6) of the regulation may not be spent inside the vehicle. The  ECJ 
concluded  that  the  EU  regulation  harmonising  social  legislation  in  the  road transport sector clearly 
prohibits drivers from taking their regular weekly rest periods in a vehicle 

Regarding  judicial  interpretation  by  national  courts,  none  of  the  Member  States  reported  any  significant 
national court decisions interpreting Directive 2002/15/EC during 2015-2016. 

18. Monitoring and control arrangements of Directive 2002/15/EC in Member States 

Member States indicated that they had implemented Directive 2002/15/E. The monitoring of implementation 
of  Directive  2002/15/EC  is  ensured  at  national  level  by  different  authorities  from  one  Member  State  to 
another. Overall and across the EU, the bodies responsible for the monitoring and control arrangements of 
Directive  2002/15/EC  are  the  labour  inspectorate,  road  transport  agency,  occupational  health  and  safety 
authority, road safety authorities and road transport inspections.  

19. Issues in relation to enforcement of Directive 2002/15/EC 

A  majority  of  Member  States  did  not  report  having  experienced  issues  in  relation  to  enforcement  of 
Directive 2002/15/EC. Some Member States shared specific issues they face at national level.  

In Italy, definitions on “time devoted to all road transport activities” and “periods of time during which the 
mobile worker cannot dispose freely of his time” cause interpretation issues and Italy feels a need to clarify 
those definitions. The United Kingdom noted that working time records are not checked at the roadside due 
to the fact that 17 weeks of records are not required to be held in the vehicle. In Czech Republic, a new work 
pattern  by  which  one  employee  (driver)  works  for  two  employers  (transport  undertakings)  gave  rise  to 
difficulties to implement  the Directive. Indeed, such practices were reported as being difficult to prove as 
only  a  transport  undertaking  subject  to  Regulation  (EC)  No  561/2006  is  required  to  request  a  copy  of  a 
working-time  record  from  another  employer.  Slovakia  reported  its  infrastructure  as  lagging  behind 
considering the expansion of road freight transport and that it was thus working on its motorway network 
and on building more parking areas.  

20. Statistics on working days checks at the roadside and premises 

MS 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI* 
FR 
DE 
EL 

Minimum  
checks  
(3%) for  
2015-2016 

Number of working days checked 

Total 

at roadside 

at premises 

% at 
roadside 

% at  
premises 

1,409,760 
1,620,095 
1,955,817 
666,288 
178,497 
1,200,698 
660,000 
224,400 
1,110,608 
6,704,624 
7,294,522 
4,357,200 

5,059,469 
1,626,823 
7,330,353 
1,114,909 
220,003 
3,281,320 
684,287 
310,946 
1,657,824 
26,486,976 
27,838,789 
215,290 

4,300,665 
1,120,361 
3,034,729 
740,369 
105,836 
2,366,610 
417,975 
157,490 
1,084,986 
21,627,286 
23,974,917 
159,204 

25 

758,804 
506,462 
4,295,624 
374,540 
114,167 
914,710 
266,312 
153,456 
572,838 
4,859,690 
3,863,872 
56,086 

85% 
69% 
41% 
66% 
48% 
72% 
61% 
51% 
65% 
82% 
86% 
74% 

15% 
31% 
59% 
34% 
52% 
28% 
39% 
49% 
35% 
18% 
14% 
26% 

% of 
working  
days 
checked 
10.8% 
3.0% 
11.2% 
5.0% 
3.7% 
8.2% 
3.1% 
4.2% 
4.5% 
11.9% 
11.4% 
0.1% 

 
 
 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SL 
ES 
SE 
UK 

2,042,508 
1,147,442 
8,444,124 
478,498 
860,736 
160,502 
2,304 
1,688,507 
4,291,401 
831,864 
2,294,510 
504,000 
466,860 
5,413,406 
1,029,600 
5,839,657 
TOTAL  62,878,428 

4,661,736 
1,833,426 
9,771,694 
1,627,984 
883,750 
191,020 
2,174 
1,219,695 
9,323,443 
1,853,295 
5,305,977 
605,635 
660,676 
9,965,513 
1,636,268 
6,287,639 
131,656,914 

4,072,236 
136,826 
7,669,304 
700,391 
534,045 
61,045 
1,092 
956,159 
6,364,406 
1,349,800 
2,607,248 
252,132 
427,606 
6,586,653 
1,057,713 
5,031,298 
96,898,382 

589,500 
1,696,600 
2,102,390 
927,593 
349,705 
129,975 
1,082 
263,536 
2,959,037 
503,495 
2,698,729 
353,503 
233,070 
3,378,860 
578,555 
1,256,341 
34,758,532 

87% 
7% 
78% 
43% 
60% 
32% 
50% 
78% 
68% 
73% 
49% 
42% 
65% 
66% 
65% 
80% 
74% 

13% 
93% 
22% 
57% 
40% 
68% 
50% 
22% 
32% 
27% 
51% 
58% 
35% 
34% 
35% 
20% 
26% 

6.8% 
4.8% 
3.5% 
10.2% 
3.1% 
3.6% 
2.8% 
2.2% 
6.5% 
6.7% 
6.9% 
3.6% 
4.2% 
5.5% 
4.8% 
3.2% 
6.3% 

* These working days checked in FI are in reality much higher as the numbers reported do not include days which were a driver's 
weekly rest. 

21. Statistics on number of working days checked at roadside by country of registration of the vehicle 

MS 

Nationals 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI** 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SL 
ES 
SE 
UK 
TOTAL 

92,848 
36,916 
209,717 
20,282 
6,598 
70,156 
17,858 
6,854 
no data 
301,308 
757,723 
33,479 
82,241 
8,928 
573,715 
15,177 
34,110 
1,059 
26 
14,417 
353,622 
68,077 
386,521 
6,370 
6,787 
428,135 
21,715 
82,976 
3,637,866 

non-EU nationals 

Total 

10,411 
2,317 
45,380 
7,272 
- 
4,840 
no data 
178 
no data 
12,873 
60,233 
2,769 
13,062 
4 
9,428 
2,624 
14,503 
31 
- 
817 
103,420 
16 
24,057 
1,003 
8,120 
2,661 
804 
4,779 
334,547 

264,047 
53,320 
295,896 
31,006 
6,600 
126,766 
no data 
8,028 
1,085,486 
775,348 
2,892,104 
40,808 
143,210 
9,361 
669,705 
26,052 
60,898 
3,013 
39 
32,971 
527,725 
61,666 
327,088 
13,911 
19,334 
458,487 
44,704 
185,130 
8,162,703 

Other EU 
nationals 
160,788 
54,168 
40,799 
3,742 
2 
53,236 
9769* 
996 
no data 
514,201 
548,554 
4,560 
50,134 
424 
86,619 
8,604 
17,312 
1,969 
13 
17,737 
90,616 
2,354 
29,718 
6,840 
5,288 
49,873 
16,787 
97,375 
1,873,598 

26 

 
 
 
* This figure under other EU nationals includes also figures of non-EU nationals 
** These working days checked in FI are in reality much higher as the numbers reported do not include days which were a driver's 
weekly rest 

22. Statistics on checks at roadside by the number of drivers checked, by country of registration and 
by type of carriage 

MS 

Total drivers  Nationals 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SL 
ES 
SE 
UK 
TOTAL 

264,047 
93,401 
295,896 
31,296 
6,600 
128,232 
27,627 
8,028 
4,316 
828,382 
1,366,510 
40,808 
145,437 
9,356 
669,762 
26,405 
65,925 
3,059 
39 
32,971 
547,658 
70,447 
440,296 
14,213 
20,195 
480,669 
39,306 
185,130 
5,846,011 

92,848 
36,916 
209,717 
20,282 
6,598 
70,156 
17,858 
6,854 
251 
301,308 
757,723 
33,479 
82,241 
8,928 
573,715 
15,177 
34,110 
1,059 
26 
14,417 
353,622 
68,077 
386,521 
6,370 
6,787 
428,135 
21,715 
82,976 
3,637,866 

Other EU  
nationals 
160,788 
54,168 
40,799 
3,742 
2 
53,236 
9769* 
996 
1,120 
514,201 
548,554 
4,560 
50,134 
424 
86,619 
8,604 
17,312 
1,969 
13 
17,737 
90,616 
2,354 
29,718 
6,840 
5,288 
49,873 
16,787 
97,375 
1,873,598 

Non-EU  
nationals 
10,411 
2,317 
45,380 
7,272 
- 
4,840 
- 
178 
2,945 
12,873 
60,233 
2,769 
13,062 
4 
9,428 
2,624 
14,503 
31 
- 
817 
103,420 
16 
24,057 
1,003 
8,120 
2,661 
804 
4,779 
334,547 

Carriers of  
passengers 
2,563 
7,539 
54,162 
2,957 
2,189 
6,243 
306 
306 
no data 
57,690 
35,489 
27,783 
1,746 
341 
31,349 
785 
5,086 
73 
- 
2,251 
117,079 
6,283 
137,604 
1,606 
2,084 
31,236 
982 
10,832 
546,564 

Carriers of goods 

261,484 
85,862 
241,734 
28,339 
4,411 
121,989 
26,764 
7,722 
no data 
770,692 
1,331,021 
13,025 
143,691 
9,015 
638,413 
25,620 
60,839 
2,986 
39 
30,720 
430,579 
64,164 
302,692 
12,607 
18,111 
449,433 
38,324 
174,298 
5,294,574 

* DK: also includes figures of non-EU nationals 

23. Statistics on checks at roadside by the number of vehicles stopped by country of registration and 
type of tachograph 

MS  
 AT  
 BE  
 BG  
 HR  
 CY  
 CZ  
 DK  

 Nationals  

 Third  
nationals  

 Non- 
nationals  
 Total  
    264,047           92,848         160,788         10,411           23,568    
      53,320           18,300           33,157          1,863           14,449    
    295,896         209,718           40,799         45,379           70,375    
      31,006           20,220             3,643          7,143           18,864    
        6,600             6,598                   2               -      
        4,759    
    126,766           69,780           52,285          4,701           37,287    

 Analogue  
tacho  

 %  
Analogue  
9% 
27% 
24% 
61% 
72% 
29% 

 Digital  
tacho  
     240,479    
       38,871    
     225,521    
       12,020    
        1,841    
       89,479    

 %  
Digital  
91% 
73% 
76% 
39% 
28% 
71% 

 No data  

27 

 
 
 
  
  
  
  
  
  
  
 EE  
 FI  
 FR  
 DE  
 EL  
 HU  
 IE  
 IT  
 LV  
 LT  
 LU  
 MT  
 NL  
 PL  
 PT  
 RO  
 SK  
 SL  
 ES  
 SE  
 UK  

        8,028             6,853               996             179             3,934    
  1,085,486    
        3,382    
    775,348         297,480         466,650         11,218          115,617    
  2,892,104       1,744,896      1,001,779       145,429          523,487    
      40,808           33,479             4,560          2,769           29,783    
    143,210           80,734           47,355         15,121           23,203    
        9,361             8,928               429                 4             2,293    
    669,705         573,669           86,613          9,423          308,395    
      26,052           14,824             8,604          2,624           10,258    
      60,898           27,926           20,115         12,857           31,188    
        3,013             1,045             1,938               30                415    
            39    
             15    
      32,971           14,417           17,737             817             7,248    
    527,725         346,020           82,127         99,578          319,046    
      61,666           59,527             2,125               14           34,600    
    327,088         270,466           33,130         23,492          172,162    
      13,911             6,228             6,674          1,009             2,468    
      19,334             5,713             5,391          8,230             7,207    
    458,487         408,722           47,313          2,452          133,457    
      44,704           25,231           18,549             924             8,143    
    185,130           82,976           97,375          4,779           72,269    

            13               -      

            26    

49% 
81% 
15% 
18% 
73% 
16% 
24% 
46% 
39% 
51% 
14% 
38% 
22% 
63% 
56% 
53% 
18% 
37% 
29% 
18% 
39% 

        4,094    
           785    
     659,731    
  2,368,617    
       11,025    
     120,007    
        7,068    
     361,310    
       15,794    
       29,710    
        2,598    
             24    
       25,723    
     190,055    
       27,066    
     154,926    
       11,443    
       12,127    
     325,030    
       36,561    
     112,861    

51% 
19% 
85% 
82% 
27% 
84% 
76% 
54% 
61% 
49% 
86% 
62% 
78% 
37% 
44% 
47% 
82% 
63% 
71% 
82% 
61% 

TOTAL     8,162,703       4,426,624      2,240,147       410,446       1,977,872    

28% 

  5,084,766    

72% 

24. Statistics on checks at premises by the number of drivers, undertakings and working days checked 

MS 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SL 

Number 
of drivers 
checked 

Number of 
undertakings 
checked 

Number of 
working 
 days 
checked 

11,900 
22,538 
153,415 
3,636 
1,808 
7,545 
17,734 
3,296 
14,672 
95,671 
59,609 
1,739 
21,052 
925 
25,716 
4,222 
9,210 
3,909 
4 
9,412 
33,150 
6,382 
17,009 
6,211 
1,541 

1,633 
4,208 
10,332 
716 
796 
952 
1,910 
249 
2,257 
6,921 
6,697 
632 
844 
653 
8,013 
491 
895 
221 
3 
962 
4,421 
954 
50,229 
868 
330 

28 

758,804 
506,462 
4,295,624 
374,540 
114,167 
914,710 
266,312 
153,456 
572,838 
4,859,690 
3,863,872 
56,086 
589,500 
1,696,600 
2,102,390 
927,593 
349,705 
129,975 
1,082 
263,536 
2,959,037 
503,495 
2,698,729 
353,503 
233,070 

 
 
 
 
 
 
ES 
SE 
UK 
TOTAL 

117,390 
11,534 
1,795 
663,025 

21,537 
296 
19,577 
147,597 

3,378,860 
578,555 
1,256,341 
34,758,532 

25. Statistic on types of offences at roadside 

MS 

Driving 
 time 

Breaks  Rest  

periods 

28 days 
 record 
 sheet 

Lack/ 
availability 
 of 
records  
for other 
work  

Incorrect  
functioning 

Misuse and 
manipulation 

Total  
offences 

70229 
AT 
3612 
BE 
146 
BG 
808 
HR 
111 
CY 
6178 
CZ 
0 
DK 
258 
EE 
154 
FI 
18623 
FR 
107027 
DE 
2416 
EL 
1463 
HU 
434 
IE 
14650 
IT 
343 
LV 
1426 
LT 
308 
LU 
2 
MT 
2941 
NL 
23014 
PL 
4254 
PT 
10573 
RO 
1369 
SK 
1371 
SL 
29948 
ES 
6283 
SE 
4141 
UK 
TOTAL  312082 

2101 
417 
1568 
527 
9970 
0 
896 
131 
9702 

96841  106648 
5634 
803 
3145 
299 
13468 
0 
1100 
61 
38507 
92051  122780 
4989 
3406 
863 
20226 
972 
3361 
330 
8 
6082 
56230 
6189 
18041 
3401 
3936 
60341 
14698 
18629 
320133  514147 

4798 
2430 
1396 
14010 
439 
1298 
157 
8 
3630 
17919 
5614 
10804 
3101 
3094 
18903 
13274 
5054 

54543 
696 
814 
1961 
222 
28155 
0 
408 
87 
19397 
58170 
3310 
1179 
195 
50426 
1594 
4070 
1 
0 
131 
17862 
9940 
3859 
750 
738 
33087 
149 
14362 
306106 

37650 
239 
172 
198 
25 
1985 
0 
376 
0 
16381 
75845 
356 
1272 
143 
18035 
0 
1170 
31 
2 
2 
14318 
2642 
142 
39 
365 
0 
164 
4032 
175584 

3212 
540 
47 
49 
532 
815 
0 
245 
33 
15715 
0 
694 
2466 
1327 
3251 
30 
789 
6 
8 
2211 
6643 
2096 
1198 
128 
641 
8364 
95 
41 
51176 

4531 
2683 
63 
2044 
0 
842 
0 
488 
8 
1206 
198963 
1215 
900 
273 
1698 
45 
303 
50 
0 
2378 
68410 
5367 
839 
73 
880 
1010 
122 
23183 

373654 
15505 
2462 
9773 
1716 
61413 
0 
3771 
5461 
119530 
654836 
17778 
13116 
4631 
122296 
3423 
12417 
883 
28 
17375 
204396 
36102 
45456 
8861 
11025 
151653 
34785 
69442 
317574  2001788 

26. Statistics on types of offences at premises 

MS 

AT 
BE 
BG 

driving  
time 

breaks 

rest 
periods 

driving 
time  
records 

incorrect  
functioning or 
recording 
equipment 

Manipulation  
of  recording 
equipment 

1414 
4189 
239 

5783 
8802 
91 

2571 
7231 
169 

11 
745 
256 

444 
90 
14 

29 

18 
220 
31 

Lack/ 
availability 
of records 
for other 
work 
0 
0 
7 

Total of  
offences 

10241 
21277 
807 

 
 
 
 
HR 
CY 
CZ 
DK 
EE 
FI* 
FR 
DE 
EL 
HU 
IE* 
IT 
LV* 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SL 
ES 
SE 
UK 
TOTA
L 

526 
554 
2269 
214 
439 
4058 
2491 
71087 
77 
300 
1736 
5619 

1781 
1612 
4 
4648 
6529 
98 
792 
3004 
1410 
6917 
980 
474 

2035 
4167 
3572 
1123 
483 
16257 
4195 
197839 
4 
701 
10619 
14299 

767 
3533 
1 
6094 
9285 
54 
1631 
5513 
718 
3705 
4406 
1540 

3467 
5662 
3779 
1348 
1180 
12202 
9911 
124338 
91 
2605 
5520 
11588 

1524 
3473 
2 
4800 
21538 
125 
3992 
7754 
1352 
9901 
3597 
1198 

30 
82 
13071 
291 
122 
273 
1078 
0 
4 
101 
164 
74204 
No details 
603 
4 
0 
2420 
285654 
5 
841 
161 
342 
4705 
2693 
0 

123461 

307217 

250918 

387860 

* no full breakdown of offences provided. 

2 
1176 
68 
3 
0 
144 
73 
0 
0 
608 
562 
722 

0 
6 
0 
741 
193 
0 
28 
98 
42 
343 
551 
3564 

9472 

1820 
0 
1054 
0 
0 
756 
1701 
22086 
0 
207 
58 
874 

252 
28 
0 
7306 
11719 
4 
54 
34 
133 
222 
0 
153 

48730 

454 
477 
550 
0 
0 
230 
785 
20213 
0 
159 
42 
230 

13 
39 
0 
0 
21407 
16 
0 
7 
82 
84 
10279 
128 

8342 
12118 
24363 
2979 
2224 
33981 
22776 
441759 
204 
5314 
19351 
111064 
271505 
5601 
8712 
7 
26014 
362373 
313 
7343 
16973 
4079 
25877 
7063 
22506 

55202 

1475166 

22. Stakeholders' views on implementation of Directive 2002/15/EC in Member States 

Only  ten  Member  States  clearly  indicated  that  stakeholders  were  consulted  in  the  framework  of  this 
reporting  exercise25.  This  number  is  stable  compared  to  the  last  report  but  still  low  compared  to  previous 
years26.  In  all  Member  States,  this  consultation  consisted  in  getting  the  views  of  representatives  of 
employers and trade unions. In six out of ten Member States, social partners were consulted but their views 
did not give rise to a separate section27. They were rather incorporated throughout the document or, in a few 
cases,  it  was  indicated  that  social  partners  did  not  have  any  comments.  Therefore,  opinions  from  social 
partners cannot be analysed as this does not constitute a representative sample28. 

25 Cyprus, Estonia, Finland, France, Ireland, Italy, Lithuania, Poland, Slovenia and Slovakia 
26 Ten Member States consulted stakeholders for the last reporting period and 16 the reporting period 2011-2012.  
27 Cyprus, Estonia, Finland, France, Lithuania, Poland,  
28 Ireland, Italy, Slovenia and Slovakia 

30