Road Cabotage in the EU in 2026: The 3-in-7 Rule, Cooling-Off Period and Documentation

Cabotage allows a road haulage operator to carry out domestic transport operations in another EU Member State after completing an international transport operation. It can reduce empty mileage and improve vehicle utilisation, but only when the operation is planned and documented correctly.

In 2026, the rules set out in Regulation (EC) No 1072/2009, as amended by the Mobility Package, remain in force. Carriers must monitor not only the limit of three cabotage operations within seven days, but also the four-day cooling-off period that applies to a specific vehicle in a specific Member State.

Most problems do not result from a lack of awareness of the 3-in-7 rule itself. They arise when the rule has to be applied to an actual route. The place where the international transport ends, the time of the final unloading, the way the vehicle enters another Member State and the vehicle’s activity during the previous days all matter.

Key cabotage rules

• Cabotage must be preceded by a genuine international transport operation.
• The same vehicle may carry out no more than three cabotage operations within seven days.
• Where cabotage is performed in a Member State other than the one in which the international transport ended, only one operation may be carried out in that country.
• After completing cabotage in a Member State, the same vehicle may not perform further cabotage there for four days.
• During an inspection, the carrier must provide evidence of the preceding international transport and each subsequent cabotage operation.
• Cabotage also involves obligations relating to the posting of drivers.

The main rules are set out in Article 8 of Regulation (EC) No 1072/2009. The four-day cooling-off period has applied since 21 February 2022. These limits remain unchanged in 2026.

What is cabotage?

Cabotage is the temporary domestic carriage of goods within one EU Member State by a carrier established in another Member State.

For example, a Polish carrier delivers goods from Poland to Germany and then carries another load from Hamburg to Munich. The second journey takes place entirely within Germany, so it is a cabotage operation.

As a general rule, cabotage may be performed by a carrier holding a Community licence. Where the driver is a national of a non-EU country, an appropriate driver attestation may also be required.

A carrier cannot legally begin a cabotage operation simply because the vehicle is already abroad and a domestic load becomes available. The vehicle must first complete an inbound international transport operation, and all goods carried under that operation must be delivered.

The 3-in-7 rule

After the final unloading of the inbound international transport operation, the carrier may perform a maximum of three cabotage operations with the same vehicle.

The final unloading under the last cabotage operation must take place before the seven-day period expires.

Where the international transport includes several unloading points, the seven-day period starts after the final unloading. The same rule applies where the last cabotage operation includes more than one unloading point: the time of the final unloading is decisive.

Example

A vehicle completes the unloading of an international transport operation in Germany on Monday.

The seven-day period starts at 00:00 on Tuesday. The final unloading under the last cabotage operation must take place no later than 23:59 on the following Monday.

During this period, the vehicle may perform no more than three cabotage operations, provided that all other conditions are also met.

The deadline should not be counted from the loading of the first cabotage operation or from the moment the vehicle crosses the border. The reference point is the final unloading of the inbound international transport operation.

Cabotage in a Member State other than the country of international unloading

The carrier does not have to perform all cabotage operations in the Member State where the international transport ended.

Some of the permitted operations may be carried out in other Member States, but only one cabotage operation is allowed in each of those countries. It must be completed within three days of the vehicle entering that Member State unladen and within the overall seven-day period. The total number of cabotage operations must still not exceed three.

For example, after completing an international delivery in Germany, the vehicle may:

• perform two cabotage operations in Germany,
• enter Belgium unladen,
• perform one cabotage operation in Belgium.

The Belgian operation must take place within three days of the vehicle entering Belgium unladen and before the general seven-day period expires.

This does not mean that one international transport operation gives the carrier the right to perform three cabotage operations in every country visited. The limit of three applies to the entire cabotage period.

The four-day cooling-off period

After completing cabotage in a Member State, the same vehicle may not perform another cabotage operation in that country for four days.

The cooling-off period applies:

• to a specific vehicle,
• in a specific Member State.

It does not apply to the entire company or across the whole European Union.

Importantly, the four-day cooling-off period may apply even where the carrier has performed only one cabotage operation. The full limit of three operations does not have to be used first.

The cooling-off period starts at 00:00 on the day following the completion of the last cabotage operation in that Member State and ends at 23:59 on the fourth consecutive day.

If the last cabotage operation ends on Monday, the cooling-off period runs from Tuesday to Friday. A new cabotage operation in the same country may begin no earlier than 00:00 on Saturday.

During the cooling-off period, the vehicle may:

• perform international transport operations to or from that Member State,
• transit through its territory,
• perform cabotage in another Member State, provided that the applicable conditions are met.

It may not, however, begin another cabotage operation in the Member State covered by the cooling-off period.

The cooling-off period applies to the vehicle, but using another truck does not solve everything

Another vehicle operated by the same carrier is not automatically covered by the cooling-off period of the first vehicle.

This does not mean that it may simply enter the country and begin a domestic transport operation. The second vehicle must independently meet all conditions for starting cabotage, including completing a preceding international transport operation.

For a combination of vehicles, the rules apply to the motor vehicle that performed the international transport. The semi-trailer may be changed, but the tractor unit performing the cabotage operation should be the same motor vehicle that carried out the preceding international transport.

What documents must be presented during an inspection?

The carrier must be able to provide clear evidence of:

• the preceding international transport operation,
• each subsequent cabotage operation.

A properly completed CMR consignment note is usually the main form of evidence. However, the rules do not limit proof to one specific document and do not require a separate form called a “cabotage document”.

The documentation should make it possible to establish, among other things:

• the name, address and signature of the sender,
• the name, address and signature of the carrier,
• the name and address of the consignee, together with their signature and the delivery date,
• the place and date on which the goods were taken over,
• the place of delivery,
• the nature of the goods and the method of packaging,
• the number of packages,
• the gross weight or other quantity of the goods,
• the registration numbers of the motor vehicle and the trailer or semi-trailer.

For dangerous goods, the generally recognised description of the goods is also required.

The consistency of the entire set of information is crucial. The documents should make it possible to reconstruct the sequence of operations, loading and unloading locations, dates and the vehicle used.

A company stamp alone does not determine whether a document is valid. Missing key information, the consignee’s signature or the unloading date may make it difficult to prove that the applicable deadlines were respected.

Can documents be provided electronically?

Yes. Evidence may be presented or transmitted electronically, including in the form of an e-CMR.

The documents must be provided at the request of the inspecting officer during the roadside inspection. The driver may contact the company’s head office, the transport manager or another authorised party so that missing evidence can be sent before the inspection is completed.

This does not mean that the documentation may be created only after the vehicle has been stopped. The information must reflect the actual transport operation and provide reliable evidence of how it was carried out.

Additional evidence from the previous four days

Where a vehicle was present in a Member State during the four days preceding a new international transport operation and then performs cabotage there, the carrier may be required to provide evidence of all operations carried out during that earlier period.

This allows the authorities to verify whether the same vehicle has breached the four-day cooling-off period. Tachograph data, including information on the vehicle’s presence and border crossings, may also be used during the assessment.

For this reason, documentation should not be archived only on a job-by-job basis. The dispatcher should be able to reconstruct the complete recent history of a specific vehicle without delay.

Cabotage and the posting of drivers

Complying with the cabotage rules is not the only obligation that must be checked.

A driver performing a cabotage operation is generally regarded as a posted worker. Before the posting begins, the carrier should submit the required declaration through the public interface connected to the Internal Market Information System, or IMI.

During an inspection, the driver should have access to:

• a copy of the posting declaration,
• evidence of the transport operation,
• relevant tachograph records.

Compliance with the 3-in-7 rule does not replace the driver-posting declaration. These are two separate areas of responsibility.

Common mistakes when planning cabotage

Counting the seven-day period from the wrong moment

The period does not start with the first cabotage operation or when the vehicle enters the country. It starts after the final unloading of the inbound international transport.

Treating the limit as three operations in every country

The overall limit is three operations. In a Member State other than the country where the international transport ended, no more than one operation may be performed after entering the country unladen.

Starting new cabotage after another international transport despite the cooling-off period

A new international transport operation does not automatically cancel the four-day cooling-off period for the same vehicle in the same Member State.

Assuming the cooling-off period applies only after three operations

The cooling-off period may also apply after only one cabotage operation.

Being unable to provide documents quickly

Documents may be transmitted during an inspection, but the carrier should have an organised system for storing and sharing them.

Inconsistent dates and locations

The information in CMRs, transport orders, telematics systems and tachograph records should tell the same story.

Failing to submit a posting declaration

A correctly planned cabotage operation may still result in an infringement if the carrier has not met its obligations relating to the driver.

How can carriers reduce the risk?

Carriers should maintain a separate cabotage record for each vehicle and each Member State.

A reliable procedure should include:

1. recording the date and time of the final unloading under the international transport operation,
2. identifying the Member State where the international transport ended,
3. recording each cabotage operation and the time of its final unloading,
4. monitoring the overall limit of three operations,
5. monitoring the three-day deadline after entering another Member State unladen,
6. calculating the four-day cooling-off period for the specific vehicle and country,
7. checking the documentation before the next transport leg begins,
8. verifying the driver-posting declaration,
9. ensuring that the dispatcher and driver have access to the same documents.

Manually tracking deadlines through messages or separate notes increases the risk of errors. With a larger fleet, one consistent system is needed to monitor all operations.

Inspections and consequences of unlawful cabotage

The level of sanctions depends on the Member State in which the infringement is identified. In addition to a financial penalty, the carrier may face vehicle downtime, a requirement to provide a financial guarantee and delivery delays.

In 2026, the Polish Road Transport Inspection reported cases of unlawful cabotage in which foreign carriers were required to provide security deposits of PLN 12,000 against the expected penalty. In some cases, the vehicle could not continue the transport operation under the existing arrangements.

Breaches involving cabotage limits, cooling-off periods and missing evidence are also included in the EU classification of serious road transport infringements.

Repeated infringements may be taken into account when assessing whether a carrier continues to meet the good repute requirement. This does not mean that a single violation automatically results in the loss of an operating licence. The frequency and seriousness of the infringements, as well as the scale of the carrier’s operations, are among the factors considered.

eXportsy’s view

In cabotage, mistakes often begin long before a roadside inspection.

They may result from manually calculated deadlines, incomplete document flows or poor communication between the dispatcher and the driver. Cabotage documentation should therefore be handled with the same level of care as customs documents or transport operations requiring additional permits.

It is not enough for one individual transport operation to appear correct. The complete history of the vehicle, the sequence of operations and the information contained in the documents must form one consistent record.

FAQ

Did the cabotage limit change in 2026?

No. The limit remains a maximum of three operations within seven days. The four-day cooling-off period has applied since 21 February 2022.

When does the seven-day period begin?

It begins at 00:00 on the day following the final unloading of the inbound international transport operation. The final cabotage operation must be completed before the period expires.

Can three cabotage operations be carried out in several Member States?

Yes, but the total limit remains three. In each Member State other than the country where the international transport ended, only one operation may be performed. It must take place within three days of entering the country unladen and before the overall seven-day period expires.

Does the cooling-off period apply after only one operation?

Yes. The full limit of three operations does not have to be used. The cooling-off period applies to the same vehicle in the same Member State.

Can another vehicle from the same company perform cabotage?

The cooling-off period of the first vehicle does not automatically apply to the entire fleet. However, the second vehicle must independently meet all cabotage conditions, including the requirement to complete a preceding international transport operation.

What documents are required?

The carrier must provide evidence of the preceding international transport operation and each cabotage operation. Properly completed CMR consignment notes are most commonly used. The documents may also be provided electronically.

Does cabotage require a driver-posting declaration?

As a general rule, yes. A driver performing cabotage is treated as a posted worker, so the carrier should verify and complete the required declaration through the IMI system.

This article is for information purposes only and does not constitute legal advice. Before beginning a transport operation, carriers should check the current EU rules and any additional requirements that apply in the Member State where the cabotage operation will be performed.