Trade plates - tacho / digi cards

i was asked this yesterday & i thought it was a bit of a grey area so i thought i’d ask you chaps in forum land .

Q
when drivers move chassis cabs around or any commercial vehicle with trade plates , are they subject to tacho regs & have to use cards or charts ?
as the units are not being used for hire or reward , would be just like me hireing a 7.5t for my own house clearance & so i wouldn’t need to use one … or would i ?
but if someone was to shunt vehicles to & from different premises for business reasons although not carring a cargo ie; delivering a truck from a garage back to the customer would he need to have a card/chart in ?

if not, could they drive from southampton to glasgow in one hit like you could if you were in a car ?

Chassis cabs would come under the exemption from EU drivers hours for;

‘new or rebuilt vehicles not yet put into service.’

So the Tacho does not have to be used. The vehicle would fall under the GB domestic hours rules but records do not need to be kept because the vehicle falls outside the scope of Operator Licensing.

The movement of vehicles from an operators base back to the lease company at the beginning or end of lease falls under EU hours and Tacho records will need to be kept (unless brand new vehicle being taken to first operator).

Just because you can use trade plates does not make your journey EU hours exempt.

Would a fitter, who was road testing a vehicle after a major repair and running on trade plates because the tax had expired, need to use a tachograph and adhere to the regulations?

We sometime bring vehicles back to our main depot from our Warrington yard on trade plates because they were untaxed and out of service. I don’t seem to remember having a card in the tacho but it was a while ago.

road testing after service or repair is tacho exempt.

The only thing a set of trade plates replace is the road fund licence or tax disc. They are not a magic spanner, a universal MOT certificate or an exemption from holding a driving licence.

Drivers hours regulations have absolutely nothing to do with road tax