VOSA have confirmed that the 100km radius is exactly "as the crow flies" from the vehicle's operating base. According to VOSA distance by road should not be used to determine if the exemption is applicable.
Some enforcement agencies have, however, taken the view that if a vehicle has travelled more than 100km to reach its destination, it falls under tachograph legislation, irrespective of whether the vehicle's base is within the 100km radius.
The correct approach is that so as long as the destination point is within 100km of base, that vehicle is exempt.
It is therefore important that operators ensure that a radius limit from the operating base is clearly established for each specialised breakdown vehicle. Once this is exceeded, the vehicle will immediately fall under the tachograph legislation. It will require a working tachograph, that has been calibrated, inspected and the driver will need to be able to produce or download the appropriate record.
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