Transportation of goods under cabotage regime

Frequently Asked Questions about Cabotage in Spain

What is cabotage and when does it apply to road transport within Spain?

Cabotage = internal transport in one country performed by a carrier from another EU country. EU Regulation 1072/2009: maximum 3 cabotage operations in 7 days after an international unloading. So a French carrier delivering in Madrid can make up to 3 internal Spanish deliveries before leaving. For Spanish businesses hiring transport, it’s important to know whether your cargo is moved by a Spanish or foreign carrier (it affects insurance, liability and compliance).

What documentation does cabotage require and who must present it?

Mandatory cabotage documentation: 1) CMR from the previous international operation (proving legal entry into Spain). 2) LCTTM consignment note for each cabotage operation. 3) Valid EU transport licence of the carrier. 4) Digital tachograph with correct rest periods. Documentary responsibility lies with the carrier, but the shipper (your business) is jointly liable if it engages cabotage with an undocumented carrier. Inspectors carry out roadside checks.

Why do some Spanish businesses use cabotage and what risks does it carry?

Attraction: cabotage rates are typically 15-25% cheaper than a pure Spanish carrier (they monetise the return trip). Risks: 1) Foreign carrier’s CMR insurance may have lower cover. 2) Claims are governed by the carrier’s country law (lawsuit abroad). 3) Communication in a different language. 4) Penalties if you exceed 3 operations / 7 days. For serious B2B businesses, the saving doesn’t justify the risks. Prefer a Spanish carrier or a consolidated agency.

How does the EU Mobility Package affect cabotage in Spain from 2022?

The Mobility Package (EU Regulation 2020/1054 + 2020/1055) introduced key changes: 1) 4-day “cooling off” period between cabotages (previously it was immediate). 2) Obligation to return to the carrier's country of origin every 8 weeks (vehicle-to-base return). 3) Salaries of the destination country for drivers (posting rules). 4) Mandatory smart tachograph on all new vehicles. Result: cabotage remains legal but more expensive and bureaucratic. Reduces competitive advantage of foreign carriers.

Is non-EU cabotage legal (Moroccan or British carrier in Spain)?

Extra-EU cabotage: stricter regulation. 1) Post-Brexit UK carrier: cabotage in the EU is prohibited (EU-UK TCA agreement does not allow it). 2) Moroccan carrier: only under TIR Convention for transit, not internal cabotage. 3) Swiss carrier: CH-EU bilateral agreement allows very limited. If an agency offers you a "very low" rate with a UK or Moroccan carrier, it is failing to comply and the joint liability of the shipper can generate a fine of €4,000-€18,000.

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