1.      Posting of Workers

The official state point of Bulgarian road industry, which we also support is that the road haulage sector should be excluded from the scope of the Posting of Workers Directive due to the extremely high mobility and transnational nature of their business activities.

We fully agree with CLECAT official Press Realese on the Mobility Package published on 31 May 2017, as stated here bellow, and appeal the same position to be protected and deffended:

“Our members are most negatively affected by the administrative burden of different minimum wage laws across the European Union. From this perspective, a European solution is indeed better than the current patchwork of regulations. But it is disappointing that the European Commission does not recognise  the sector’s highly mobile workforce and transnational character.  Applying local labour rules and minimum wages to international transport after only 3 days will burden many SME’s in Europe, and this is not what we expect from a Commission seeking to create a real internal market, having only recently confirmed its intention to stand behind the ambitions of the Commission’s White Paper on Transport seeking to create a real internal market whilst respecting the principle of freedom to provide services, the free movement of goods, and having regard to the principle of proportionality”.


2.       Cabotage

It is necessary to apply a balanced approach to the EU road transport market. The current restrictions on cabotage operations were introduced as a temporary measure to address the gap between social standards and market access rules.

We welcome the abolition of the limitation of the number of cabotage operations within the given period because it is difficult to control it without having a significant effect.


3.       Regulation 561/2006 on driving and rest times 

  • European Commission proposals for introducing a ban throughout the EU on the use of weekly rest breaks of 45 hours or more (normal or compensated) in the vehicle.

Bulgarian road haulage sector strongly disagrees with a total ban on the use of normal weekly breaks outside the cabin, since Europe is not prepared for it due to the lack of adequate infrastructure, high-security freight car parks and enough driver-occupied accommodation or hotels with secure parking lots for trucks. Rest outside the vehicle contradicts to CMR convention and especially the requirement of art. 17 for the liability of the carrier for the total or partial loss of the goods occurring between the time when he takes over the goods and the time of delivery.  Rest outside the vehicle is immediate justification for the insurance companies to withdraw cover for total or partial loss of cargo as well as for other damages occurred while the driver left the vehicle unattended.

• Introduction of a compulsory return of drivers at home at least once every 3 weeks

Bulgarian road haulage sector strongly disagrees with the introduction of compulsory return of drivers home at least once every 3 weeks.

While for Central European countries the organization of such a return may be acceptable, for carriers from the peripheral countries of the EU such as Bulgaria, due to considerably longer distances, it will be much more difficult and more expensive with the increase of empty courses. There is no such requirement in any other profession.

Moreover, why should someone have to return home when he may not want to do it. The normative determination of where drivers spend their breaks and when to return home is a violation of their human rights.

4.      Eurovignette directive: We believe that each Member State should have the freedom to choose the type of road toll system.

Bulgarian road haulage sector consider all measures taken by some member states with requirements for minimum wages, requirement for weekly rest out of the truck, the administrative burden that is associated with those newly established restrictions have nothing to do with social improvement of the work/life of the driver. Such restrictions are either pure national protectionism or inspired by transport sectors different from road haulage.

Those measures will lead to worse life for many driver as their “trading area” will be considerably narrowed which will naturally lead to areas with extra supply and worse income for all participants owner of company, vehicle and driver.

For us is astonishing why the European Commission agreed to play this game with “socially motivated” market restrictions.

As a conclusion:  the national markets should be opened as much as possible because this will lead to a reduction of empty shipments and consequently less environmental  pollution that is in line with the objectives of the 2011 White Paper on Transport and is fully in line with the European Mobility Strategy for low emissions.


Sofia, 26th June 2017                                                  BoD of NSBS