It used to be three in seven. Now it's two. And that's not the only thing that changed.
Before Brexit, UK hauliers operating in EU member states under the EU cabotage rules could make up to three cabotage operations in a seven-day period after crossing into a member state on an international laden journey. The rules were the same for UK operators as for any other EU member state's haulier — because UK operators were EU operators.
That changed on 1 January 2021. The EU-UK Trade and Cooperation Agreement (TCA) set out new terms for UK hauliers in Europe, and cabotage is one of the areas where the terms are stricter. Not dramatically different in structure, but meaningfully different in count — and the consequences of getting it wrong are a turned-back load and a fine in whatever member state you're in when the enforcement officer does the maths.
I stood at Calais last spring watching a driver argue about a third collection. He was friendly, he had the CMR notes, he'd done this run three times a year for most of a decade. His dispatcher hadn't flagged the change. He went back to collect one delivery instead of two.
What the TCA allows
Under the Trade and Cooperation Agreement, a UK goods vehicle operator can make up to two cabotage operations in a single EU member state within seven days of arrival — after completing an international laden journey from the UK into that member state.
The sequence has to be:
- International laden journey from the UK, entering the EU member state
- Up to two additional (cabotage) operations within that member state, within seven days of arrival
- Leave the member state
After the two operations or after seven days — whichever comes first — the vehicle must leave. Going to another EU member state is fine. Going back to the UK is fine. Staying in the same member state and doing a third internal delivery is not fine.
The seven days runs from the date of arrival in the member state on the international journey, not from the date you start the cabotage. If you arrived on Monday and spent three days on delivery admin before your first cabotage collection, your second operation has to be completed before the end of the following Sunday, not seven days after the first cabotage operation started.
What cabotage means in practice
Cabotage is carrying goods between two points within a single country, when you're a foreign operator. An artic registered in the UK, running from Lyon to Marseille — that's cabotage in France. Running from Calais to Paris after unloading a UK shipment — that's cabotage.
If you're collecting a load in France and running it to Belgium — that's cross-trade, not cabotage. And UK operators lost their right to cross-trade in the EU post-Brexit. Cross-trade between EU member states requires an EU-established operator. A UK haulier can't take work from a French shipper to a Belgian receiver without going through an intermediary with EU establishment or without UK-EU bilateral arrangements that specifically cover that movement.
Some UK operators have set up EU subsidiaries to handle this. Others stick to UK-EU international work and avoid cabotage and cross-trade altogether. The ones who haven't adjusted their operating model since 2020 are the ones still occasionally getting caught.
The paperwork that matters at the check lane
When the check lane officer wants to see your cabotage documentation, they're looking for:
- The CMR consignment note for the international journey that brought you into the member state — this establishes the international journey that 'unlocks' your cabotage allowance
- CMR notes for each cabotage operation — confirming dates, origins, and destinations within the member state
- Proof that the operations fall within the two-in-seven limit — which means the dates need to be clear on the paperwork
- Your operator licence documentation and tachograph records
The CMR note is the key document. Without it, you can't demonstrate the sequence — international journey first, then the cabotage operations. Officers have seen the full range from impeccable paperwork to a driver handing over a phone with a screenshot. The impeccable paperwork gets waved through. The screenshot gets scrutinised.
I've covered CMR and the consignment note in the post on UK-EU haulage post-Brexit. The short version: carry the original or a clearly legible copy, for every leg. The international journey CMR especially.
Each EU member state enforces differently
France, Germany, Belgium, the Netherlands — these are the main corridors for UK operators. Each one has its own enforcement intensity. Germany has been historically strict on cabotage. France has increased enforcement since Brexit. The Netherlands moves a lot of freight and tends to run a smoother operation at the checks.
The underlying TCA right is the same across all EU member states — two cabotage operations in seven days after an international journey. But some member states have specific national implementing rules about minimum rest periods between loads, documentation formats, or overnight cabotage restrictions. Before you commit to a repeat run in a market you haven't used since Brexit, check the current rules in that specific member state — your freight association or a local legal contact can advise.
Bilateral agreements for specific countries
The TCA covers the general framework, but the UK has also negotiated bilateral agreements with some EU member states for specific movement types. Norway, Switzerland, and Ukraine have their own bilateral arrangements with the UK that are separate from the TCA and may have different rules for haulage and cabotage.
For EU member states specifically: stick to the TCA rules. Two cabotage operations in seven days after an international laden journey. That's the floor — it can't be made more restrictive by bilateral negotiation, but it also can't be made more generous unless a specific sectoral agreement exists for that country and movement type.
ECMT permits — the alternative for some movements
If your operation requires more cabotage-style flexibility than the TCA permits, ECMT (International Transport Forum) multilateral quota permits are the main mechanism. These are issued annually by the Department for Transport to UK operators and are used for international journeys — not unlimited cabotage, but they do allow transit and some bilateral movements that the TCA route doesn't cover cleanly.
ECMT permits are quota-controlled. The allocation to UK operators has been a pressure point since 2021 — if you need them for regular European work, applying early and keeping records of usage is essential. The Department for Transport publishes the annual application process on GOV.UK.
What happens when you get it wrong
The enforcement varies by country but the consequences are broadly: the load is refused, you're turned back, and a fine is issued in that member state. Some countries also record the infringement in a way that increases scrutiny on future crossings for your operator. Repeat infringements can result in the operator losing their right to operate in that member state under the TCA framework.
For the transport manager back in the UK, the liability sits with the operator. The driver might get a fine, but the operator's reputation in that country is what takes the longer-term hit.
The driver at Calais — to finish the story — went back and collected one load, ran it to the depot, and came home. His dispatcher booked two further collections for the following week as a separate trip, with a new international laden journey out of the UK as the anchor. That's the right way to do it.
Planning your European runs with the two-in-seven limit in mind from the start — not discovering it at the check lane — is the difference between a smooth run and a phone call from Calais you don't want to have. If you're managing driver availability and movements across European work, ShiftOwt tracks compliance and availability for the UK side of the operation — £5.99 a month for drivers, fleet pricing available.