Bulgaria as an EU External Border – Responsibilities, Challenges and Practical Implications in Road Transport Enforcement

Violations Related to the Use of Tachographs

The relatively small territory of Bulgaria ‘tempts’ many carriers to reach the end point of their trip, thus non-observing the driving, resting and break times. Statistics shows a significantly greater number of similar violations by third country drivers compared to drivers from Bulgaria and the EU. The most common violations are:

• Failure to submit the needed records of the daily resting times and the previous 28 days, required by the regulations
• Drivers who use more than one digital tachograph card (his and another driver’s card)
• Manipulating the tachograph externally by installing various devices to manipulate the tachograph readings

Violations of Foreign-Registered Vehicles Related to Resting Times and Use of Tachographs

Source: EARTA

Technical Malfunctions of Vehicles

Most often, the violations identified by the Bulgarian road inspectors are related to technical malfunctions of the vehicles. In most cases, the following problems were established:

• Faults in the brake system, cracked brake disks
• Worn tires

Violations Related to Roadworthiness of Foreign-Registered Vehicles

        Source: EARTA

Note: Increase of the number of identified violations is due to the traffic growth and control intensification

Cargo Securing

Bulgarian authorities consider that, based on their experience, common rules for cargo securing must be established within the EU for the benefit of road safety.

Violations of Permit Regimes

• Misuse of ECMT/CEMT permits: the most common violation is failure to comply with the requirement for having the permit on board the vehicle from the point of loading to the point of unloading. In these cases, it is considered that the carrier has no valid permit and administrative measures are taken against him under the Road Transport Act.
• Misuse of one-off permits under bilateral agreements: the driver does not fill in the necessary details in the permit form in order to use it again, if not checked. When such cases are identified, control authorities apply the relevant rules for lack of a valid permit.

Language Problems

Based on the experience of its ECR partners, Bulgarian authorities seek opportunities to avoid the obstacles to the control arising from the linguistic diversity among third country transport operators.

Bulgarian road inspectors have a good experience in joint inspections and intensified cooperation with their colleagues in neighbouring countries. Based on this experience, EARTA believes that the collaboration between the inspection authorities of the EU/ECR and with third countries would overcome a lot of misunderstandings and would result in violations decrease.

Euro Contrôle Route (ECR) is a group of European Transport Inspection Services that work together to improve road safety, sustainability, fair competition and labour conditions in road transport by activities related to compliance with existing regulations. In 1994 the inspection authorities of Benelux countries set up a working group for harmonisation of the inspection procedures in order to improve road safety in Europe. Following the accession of several other countries in 1999, the working group developed into the organization of Euro Contrôle Route (ECR). ECR ​​activities are focused on training of inspectors, exchange of information and coordinated control, development of uniform inspection procedures and enforcement of harmonised legislation and best practices. Bulgaria joined the organization in 2007. ECR has currently 14 member states and 4 non-member states with observer status.