Cabotage in Europe: Rules, Pitfalls and How to Avoid Fines in Germany

  According to European Regulation (EC No. 1072/2009), applicable in Germany:

  After completing an international delivery to Germany:

• You are allowed to carry out up to 3 cabotage operations.
• These must be performed within 7 days after the unloading of the international delivery.

  Important:

• It doesn’t matter whether you do 1, 2, or all 3 deliveries in that time — the limit is 3.
• There’s no “one per day” rule — you can do all 3 on the same day.

  However: You may not start a new cabotage cycle in Germany unless:

  you have exited Germany, and
  you’ve returned with a new international delivery.

  So:

• No, you cannot perform 4 cabotage operations in 4 days — only 3 are allowed.
• You cannot restart cabotage after a 4-day break unless you’ve entered with a new international shipment.
• Cabotage is only permitted as an “extension” of an international transport.

  Example:

• Day 0: Unload international delivery in Hamburg
• Day 1: Cabotage 1 – Hamburg → Bremen
• Day 1: Cabotage 2 – Bremen → Dortmund
• Day 2: Cabotage 3 – Dortmund → Cologne

  After the third cabotage, no further domestic deliveries are allowed in Germany unless you return with a new international load.

Because many transport operators believe that checks are only done “on the road”. In reality, the authorities can inspect in two different ways, and the risk of a fine even much later is very real.

1. On-road checks (traffic inspections)

These are the most common.

They involve checking transport documents (CMR, route sheet, delivery note, tachograph records, etc.).

Authorities verify whether you are still within the 7-day limit from the international delivery and whether you haven’t exceeded the 3 allowed cabotage operations.

If you are non-compliant → on-the-spot fine and possible temporary ban.

2. Administrative inspections afterwards (at your office or at the freight forwarders)
YES, German authorities can:

Request data and documentation from the forwarding companies (those giving you the jobs).

Verify compliance with cabotage rules based on submitted documents (CMRs, invoices, transport logs).

Collaborate with the authorities in your home country (such as tax office, road authority, or police) to investigate your company, even 6–12 months after the operations.

So yes — you can receive a fine even one year later if:

You did more than 3 cabotage operations and it wasn’t caught at the time.

You didn’t keep the required documents for at least 1–2 years.

Your clients (freight forwarders) are audited and irregularities are discovered related to your transports.

Clear recommendations:

Keep all CMRs and route sheets for at least 2 years.
Record the date and place of the international unloading (start of the 7-day period).
Track the number of cabotage trips clearly (1, 2 or 3).
Request and archive all emails/contracts from the forwarders giving you jobs in Germany.
Pay attention to route codes, shipment numbers and links between loads — authorities track them.