As of 1 July 2026, new EU LCV tachograph rules apply to many light commercial vehicles (LCVs) used for international goods transport. Vans and commercial vehicles with a maximum permitted weight between 2.5 and 3.5 tonnes may now fall under EU driving and rest time legislation and require a smart tachograph.
The changes affect not only transport companies but also businesses that use vans for cross-border deliveries, service operations, maintenance work, construction projects, or transporting their own goods and equipment internationally.
This article is based on the latest CORTE guidance, a non-binding but authoritative document developed from established enforcement practices in the heavy vehicle sector, discussions within CORTE enforcement working groups and focus groups, European Commission clarifications, CORTE-ELA training sessions, and guidance documents such as TRACE. It explains when an LCV tachograph is required, which exemptions may apply, and what operators need to know to remain compliant.
When Is an LCV Tachograph Required?
A tachograph is mandatory when all six of the following conditions are met:
- The vehicle’s maximum permissible mass exceeds 2.5 tonnes but does not exceed 3.5 tonnes.
- The vehicle is registered in an EU Member State, an EEA country, Switzerland, or the UK.
- The vehicle is used for the transport of goods.
- The transport activity is commercial, either:
- for hire or reward, or
- on the company’s own account.
- The operation involves international transport or cabotage.
- The transport falls within the scope of Regulation (EC) No 561/2006.
If all six criteria are met, the vehicle must be equipped with a compliant smart tachograph.
International Transport: The Main Trigger
The new rules primarily target international transport operations.
An LCV tachograph is generally required when goods are loaded in one country and unloaded in another country within the EU, EEA, Switzerland, or the UK.
In these cases, the vehicle falls within scope and must be fitted with a tachograph if the other criteria are also met.
Cabotage operations are also covered. This means that a vehicle registered in one country performing domestic transport operations in another country may require a tachograph.
Domestic Transport: Usually Exempt
Vehicles used exclusively within their country of registration generally do not require a tachograph under the new LCV rules.
For example:
A French-registered van delivering goods only within France.
A German-registered vehicle operating solely within Germany.
In many cases, a journey remains domestic even if it briefly passes through another EU country, provided both the loading and unloading locations remain within the vehicle’s country of registration. Operators are advised to carry supporting transport documents, such as a CMR or transport contract, to demonstrate the nature of the journey during inspections.
Companies Transporting Their Own Goods Are Also Affected
One of the biggest misconceptions is that the new rules only apply to transport companies.
In reality, the legislation can also apply to businesses transporting their own goods, tools, equipment, or materials across borders.
Typical examples include:
- Technicians carrying tools to a customer site abroad.
- Construction companies moving equipment between countries.
- Mechanics transporting spare parts.
- Manufacturers delivering their own products to customers.
- Service engineers travelling internationally with equipment.
Whether the transport is performed for customers or for the company’s own activities, the tachograph obligation may still apply.
Important Exemption for Own-Account Transport
An important exemption exists for certain own-account operations.
A tachograph may not be required when:
- the transport is carried out on the company’s own account, and
- driving is not the driver’s main activity.
EU guidance generally considers driving not to be a driver’s principal activity when it represents less than 30% of their monthly working time.
This exemption may apply to:
- Technicians
- Installers
- Mechanics
- Engineers
- Warehouse employees
- Maintenance personnel
provided that driving is only a secondary part of their role.
Operators relying on this exemption should be able to support their position with documentation such as:
- Work schedules
- Duty rosters
- Activity records
- Job descriptions
- Other company records
Mixed Operations Require a Tachograph
Many vehicles are used for both domestic and international transport.
If a vehicle performs any in-scope international transport activities in addition to domestic operations, it should be equipped with a tachograph.
For example:
A van that usually operates within Belgium but occasionally delivers goods to the Netherlands.
A company vehicle performing domestic deliveries during the week and international trips several times per month.
In these situations, the vehicle is considered to be performing mixed operations and requires a tachograph.
Driver Cards and Operator Responsibilities
Where an LCV falls within scope, drivers must use a valid driver card to record their activities.
Operators are responsible for:
- Ensuring drivers are properly trained.
- Providing instructions on correct tachograph use.
- Monitoring compliance.
- Conducting regular checks.
- Preventing misuse of tachograph equipment.
Drivers must also be able to produce the required activity records during roadside inspections and company checks.
What Tachograph Must Be Installed?
LCVs that fall within scope must be equipped with the latest Generation 2 Version 2 (G2V2) smart tachograph, including OSNMA functionality where required.
Operators planning new installations should ensure that workshops fit the correct tachograph version to avoid future compliance issues.
Are Non-EU Registered Vehicles Covered?
The current obligation applies only to LCVs registered within:
- EU Member States
- Iceland
- Liechtenstein
- Norway
- Switzerland
- The United Kingdom
LCVs registered outside these countries are not currently subject to the new tachograph installation requirement, even when carrying out certain transport operations within the EU.
Quick Compliance Checklist
Ask yourself the following questions:
✅ Is the vehicle between 2.5 and 3.5 tonnes?
✅ Is it registered in the EU, EEA, Switzerland, or the UK?
✅ Is it carrying goods?
✅ Is the transport commercial?
✅ Does it perform international transport or cabotage?
✅ Does no exemption apply?
If the answer is yes to all six questions, the vehicle requires an LCV tachograph.
Final Thoughts
The introduction of tachograph rules for certain light commercial vehicles marks a significant expansion of EU compliance requirements.
Operators using vans for international goods transport should carefully assess their activities, vehicle usage, and driver roles. While some exemptions remain available for specific own-account operations, many businesses carrying goods across borders will now fall within the scope of the legislation.
Understanding whether an LCV tachograph is required is now an essential part of compliance. A review of vehicle operations, international activities, and driver responsibilities can help operators avoid enforcement issues and ensure they meet the requirements that have applied since 1 July 2026.
