Topic: Bulgaria as an EU External Border - Responsibilities, Challenges and Practical Implications in Road Transport Enforcement
Venue: Sheraton Hotel Balkan, Sofia, Bulgaria
Date: 18th June 2014 from 9.00 to 17.00

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

Trips of third country transport operators through the European Union territory is the highest growth segment of the road freight transport market over the past decade (80% in the period 2004-2014). According to an European Commission report from April 2014, 80 percent of all international transport activities within the Union were performed by vehicles registered either in the Member State of loading, or in the Member State of unloading. 20% of transport operations were performed by trucks registered in a third country (i.e. trips between third countries) compared to 12% in 2004. The share of transport operations between third countries out of allroad freight transport activities has increased from four to seven percent in the past decade.

Control over the increasing flow of goods vehicles registered in third countries represents a major challenge for Bulgaria (a member of Euro Contrôle Route since 2007) because of its status of a border country of the Union. This is the reason for the relatively higher flow of carriages of goods from and to third countries together with the specific consequential problems. About 1.1 million trucks pass through the country annually. Nearly half of them are from third countries.

Passages of buses and trucks through the territory of Bulgaria in 2012 and 2013

Registration of vehicles Trucks Buses
In Out In Out
Bulgaria 374 179 323 121 5 171 13 556
EU 197 915 192 614 6 552 9 278
Third countries 503 605 498 274 8 984 14 949
TOTAL 1 075 699 1 014 009 20 707 23 933

Registration of vehicles Trucks Buses
In Out In Out
Bulgaria 424 838 298 213 6 056 10 782
EU 254 230 198 870 9 031 8 692
Third countries 495 459 478 775 9 400 13 334
TOTAL 1 174 527 975 858 24 487 32 808

Source: Customs Agency

  • This report does not include the data on  Kulata border crossing point up to 09.08.2013 and on the Danube Bridge II Vidin
  • Term ‘truck’ includes: trucks with two axles, trucks with three or more axles, trucks with a total gross weight less than or equal to 3.5 tons including the trailer, and NATO vehicles
  • Croatia has been reported within EU for both periods.

Experience of road inspectors shows that the larger truck flow by third countries is a challenge to the control in several areas:
  • Violations related to the use of tachographs
  • Technical malfunctions of vehicles
  • Cargo securing
  • Violations of permit regimes
  • Language problems

Violations Related to the Use of Tachographs

The relatively small territory of Bulgaria ‘tempts’ many driversto reach the end point of the journey faster, 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 necessary 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 placing various devices to manipulate the tachograph readings

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

Year EU Third countries Total number of committed violations
2007  203  760 963
2008  265  756 1021
2009  353  1394 1747
2010  505  1687 2192
2011  593  1503 2096
2012  575  1099 1674
2013  482  1208 1690

Source: Executive Agency Road Transport Administration  (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

Year EU Third countries Total number of violations found
2007  93  166 259
2008  76  198 274
2009  127  353 480
2010  107  388 495
2011  198  434 632
2012  334  792 1126
2013  339  718 1057

Source: Executive Agency Road Transport Administration (EARTA)

Increase of the number of identified violations is due to traffic growth and control strengthening

Cargo Securing

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

Violations of Permit Regimes

  • Misuse of ECMT/CEMT licenses: the most common violation is failure to comply with the requirement for having the licence on board the vehicle from the point of loading to the point of unloading. In these cases, it is considered that the haulier has no valid license and administrative measures are taken against him under the Road Transport Act.
  • Misuse of permits under bilateral agreements: the driver does not fill in the necessary details on 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 validpermit.

Language Problems

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

Performed Roadside Checks and Constituted Acts for Committed Violations in the Period 2007 - 2013

Year Number of roadside checks Number of roadside checks
 2007  296 419  20 763
 2008  321 916  33 762
 2009  326 871  21 523
 2010  298 659  11 678
 2011  268 942  18 459
 2012  272 639  19 576
 2013  233 215  16 505

Source: Executive Agency Road Transport Administration  (EARTA)

Bulgarian road inspectors have good experience in joint inspections and intensified cooperation with colleagues from neighbouring countries. Based on this experience, EARTA believes that collaboration between the inspection services of the EU/ECR and third countries would clarify a number of misunderstandings and would lead to fewer violations.

Euro Contrôle Route (ECR) is a group of European Road 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 the 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 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 currently has 14 member states and 4 observer countries.

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