Vehicle resricted to 40kph Tacho required?

Hi

Can anyone help, I have a 28 tonne Unit and trailer that does 30 kms a day within 5 kms of its base and restricted to 40 kph.

Does it need a Tacho installed, in my CPC books it says no

Hope you can help

vehicles with a maximum authorised speed not exceeding 40 kilometres per hour;

eur-lex.europa.eu/legal-content/ … 32006R0561
its exempt

Cheers, I thought so too. By my reconing, if he doesn’t drive for more than 4 hours he doesn’t have to keep records either.