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DTCO 4.1

Frequently asked questions about and around the new 2nd version Smart Tachograph.

When entering the vehicle registration number and the country of registration with the company card on a DTCO 4.1, the following effects will occur:

  1. When downloading the technical data block, calibration purpose 5 is missing. In addition, an inconsistent signature is provided for this block of data. This can cause issues with some of the download tools available in the market.
  2. When printing the technical data for the first time, the warning message 25 will occur. In the printout, warning message 25 corresponds to event 15. Warning message 25 only occurs on DTCO 4.1 and only if the vehicle registration number and country of registration have been entered with a company card. Warning message 25 does not occur if the vehicle registration number and the country of registration have been entered with the workshop card.

The message does not affect the functioning of the device. All data is stored in the device.

When entering the vehicle registration number and the country of registration with the company card on a DTCO 4.1, the following effects will occur:

  1. When downloading the technical data block, calibration purpose 5 is missing. In addition, an inconsistent signature is provided for this block of data. This can cause issues with some of the download tools available in the market.
  2. When printing the technical data for the first time, the warning message 25 will occur. In the printout, warning message 25 corresponds to event 15. Warning message 25 only occurs on DTCO 4.1 and only if the vehicle registration number and country of registration have been entered with a company card. Warning message 25 does not occur if the vehicle registration number and the country of registration have been entered with the workshop card.

The message does not affect the functioning of the device. All data is stored in the device.

When entering the vehicle registration number and the country of registration with the company card on a DTCO 4.1, the following effect will occur:

When downloading the technical data block, calibration purpose 5 is missing. In addition, an inconsistent signature is provided for this block of data. This can cause issues with some of the download tools available in the market.

All VDO download tools and archiving solutions will perform the download of the complete data despite this inconsistency in the signature.

Under certain circumstances, a fleet may experience interference when using the download tools of other providers. Download tools from other providers will sometimes refuse the download of data from the mass storage completely. Continental/VDO has informed the manufacturers of download solutions as far as they are known. In case of malfunctions, please contact the provider of your download tool.

Important to know: By downloading the overview block, the license plate number and the country of registration are still included in the downloaded data. Thanks to the signature of the overview block, it is still possible to unambiguously assign the tachograph to the vehicle.

If the vehicle registration number and the country of registration are entered with a workshop card before the DTCO is put into operation for the first time, the issue with the inconsistent signature of the technical data block will not occur. In this case, there are no consequences whatsoever.

If the end customer entered information on vehicle registration number and country of registration using a company card:

Printing of the tachograph technical data should be avoided
for the time being to avoid warning message 25.

Important: In day-to-day fleet operations, a printout of the technical data is not necessary and is not required by law. The occurring of warning message 25 is only produced once through the printout.

It is important for you as the driver of a vehicle with an affected tachograph to know:

  • The warning message does not have any serious consequences.
  • The message does not affect the functioning of the device. The DTCO does not need to be replaced. The issue also does not render the tachograph applicable for a complaint.
  • In principle, all data is stored in the device. The technical data can be printed out in full. There are only restrictions in the download of the technical data. The tachograph continues to meet the legal requirements.
  • All driving and rest periods are duly stored.

In summary: Apart from the fact that warning message 25 and event 15 are stored and can be viewed, there are no effects.

It is important for you as the driver of a vehicle with an affected tachograph to know:

  • The warning message does not have any serious consequences.
  • The message does not affect the functioning of the device. The DTCO does not need to be replaced. The issue also does not render the tachograph applicable for a complaint.
  • In principle, all data is stored in the device. The technical data can be printed out in full. There are only restrictions in the download of the technical data. The tachograph continues to meet the legal requirements.
  • All driving and rest periods are duly stored.

In summary: Apart from the fact that warning message 25 and event 15 are stored and can be viewed, there are no effects.

In the case of checks by authorities, drivers do not have to fear a penalty for a violation. It is purely a device anomaly, not a driver error.

The control authorities were informed by Continental/VDO about the anomaly and its cause.

Continental/VDO will develop appropriate solutions for this issue in the foreseeable future. You will receive more information from your VDO partner as soon as it becomes available.

The warning message itself does not have any problematic effects for fleets, as all data is still correctly available in the mass storage and can be retrieved in principle.

However, depending on how a download tool is set up by the manufacturer, it can happen that the download tool completely blocks the download of data from the tachograph's mass storage due to the warning message 25.

Providers of download tools can remedy this by increasing the error tolerance during the download and thus allowing the data from the mass storage to be downloaded despite the warning message 25.

A more detailed description and further information for programmers has been summarized by Continental/VDO in a technical information.

The warning message 25 will be downloaded and archived. However, this has no concrete impact on everyday fleet life. The control authorities were also informed by Continental/VDO about this issue and its origin.

When entering the vehicle registration number and the country of registration with the company card on a DTCO 4.1, the following effects will occur:

  1. When downloading the technical data block, calibration purpose 5 is missing. In addition, an inconsistent signature is provided for this block of data. This can cause issues with some of the download tools available in the market.
  2. When printing the technical data for the first time, the warning message 25 will occur. In the printout, warning message 25 corresponds to event 15. Warning message 25 only occurs on DTCO 4.1 and only if the vehicle registration number and country of registration have been entered with a company card. Warning message 25 does not occur if the vehicle registration number and the country of registration have been entered with the workshop card.

The message does not affect the functioning of the device. All data is stored in the device.

When entering the vehicle registration number and the country of registration with the company card on a DTCO 4.1, the following effects will occur:

  1. When downloading the technical data block, calibration purpose 5 is missing. In addition, an inconsistent signature is provided for this block of data. This can cause issues with some of the download tools available in the market.
  2. When printing the technical data for the first time, the warning message 25 will occur. In the printout, warning message 25 corresponds to event 15. Warning message 25 only occurs on DTCO 4.1 and only if the vehicle registration number and country of registration have been entered with a company card. Warning message 25 does not occur if the vehicle registration number and the country of registration have been entered with the workshop card.

The message does not affect the functioning of the device. All data is stored in the device.

What are the main differences between the current tachograph DTCO 4.0 and the new tachograph DTCO 4.1, that will be installed in new vehicles from August 21, 2023?

The two tachograph versions look almost identical in terms of design. However, the new DTCO 4.1 has a direct identifying feature. A small Bluetooth icon on the top right of the display identifies the new device.

Direct access to the DTCO 4.1 via the VDO Fleet App (available Q4 2024) is possible via this Bluetooth interface. The VDO Fleet App can be downloaded for Android or iOS devices via the following links (paste the links here). With the DTCO 4.1, no additional hardware such as the DTCO SmartLink Pro is required for access. Bluetooth connectivity brings improvements for both drivers and companies.

Even if the DTCO 4.1 is almost unchanged in terms of design and adopts all the improvements that were introduced with the DTCO 4.0(e), almost all hardware and software components have been redesigned or changed compared to the DTCO 4.0(e). The DTCO 4.1 has stored a digital map and automatically records border crossings. The regulations newly introduced with the EU mobility package 1 have been taken into account, for example the special rule in cross-border freight transport, which makes it possible to take two reduced weekly rest periods in a row.

There is also a so-called “Ex variant” of the DTCO 4.1, which is intended for vehicles that transport dangerous goods in accordance with the ADR agreement. Tachographs that meet the special requirements for the transport of potentially explosive goods or in potentially explosive environments can be identified by the "Ex symbol" above the tachograph display.

The driver must enter a country at the beginning and end of his activity and at every border crossing. What will change in this context with the DTCO 4.1?

The DTCO 4.1 will detect and store border crossings fully automatically. A digital map is stored in the device and the signals from the satellite positioning system are automatically used to detect the crossing of a state border. The new tachograph therefore relieves the driver of this task.

However, the driver also has to enter the land manually at the beginning and end of the daily working time with the DTCO 4.1. These entries may be made via the tachograph input menu or as part of the entries made when the driver card is inserted and removed. The DTCO 4.1 suggests a country for the manual entry of the country based on the current location of the vehicle, which allows the entry to be made more quickly.

I download the mass memory and driver card data with a VDO download key. Can I use it to read out the new DTCO 4.1 and the new driver cards that will be issued from July 21, 2023?

The mass memory from the DTCO 4.0 and the corresponding driver cards can be downloaded with a DLK Pro S. There will be a software update for the DLK Pro S for the DTCO 4.1, which we will make available via our VDO portal. This software update enables the mass storage device to be downloaded from the DTCO 4.1 and Generation 2 Version 2 (G2V2) maps.

Older DLK Pro (without S), which have not yet been "upgraded" for Smart Tachographs, need a "DLK Pro License Card Smart TCO ready" in addition to the software update for DTCO 4.1 in order to be compatible with the DTCO 4.1 and G2V2 cards. This DLK Pro License Card Smart TCO ready must be inserted once into the DLK Pro.

In addition, VDO will launch a DLK Smart Download Key at the end of Q3/beginning of Q4 2023, which can already download DTCO 4.1 mass storage devices and G2V2 cards and all previous generations of the DTCO.

As an alternative to downloading via the 6-pin interface on the DTCO, the DLK Smart Download Key can also download the data from the DTCO 4.1 via the Bluetooth interface.

I have heard that the satellite navigation data on Galileo, which is used by the new tachograph DTCO 4.1, will not be fully available until the market launch in August 2023. How does it affect me?

The EU legislator has stipulated that the DTCO 4.1 must work with the position and time data of the Galileo satellite system. This system offers the so-called OSNMA (Open Service Navigation Message Authentication) service, which has the function of "testifying" the authenticity of the position and time data, thereby establishing a high level of protection against manipulation.

At the time of the market launch of the DTCO 4.1, this system will not yet be available in the final expansion stage. Instead, it is expected that there will only be a test signal until the first quarter of 2024, with which the new tachographs will also largely fulfil the legally prescribed functions.

For drivers and companies, this deviation has no effect on day-to-day operations. After the OSNMA service is fully available, it will be possible to upgrade the so-called "transitional tachographs" to full OSNMA functionality via an update. This update will not be mandatory - however, due to legal requirements, it may be necessary to make an update, e.g. if the map material changes. Software updates can be made in connection with a planned workshop visit

A DTCO 4.1 is installed in my vehicle, which cannot process the OSNMA data and has not yet received an update. With this tachograph, does the driver still have to record border crossings manually, or is the border crossing automatically recorded by the tachograph?

The devices known as transition tachographs also record border crossings fully automatically. The driver, with a DTCO 4.1, only has to enter the country manually at the beginning and end of the daily working time and create the supplements for the times away from the vehicle.

Even if only an "OSNMA test signal" is available during the transitional period, the transitional tachograph will mark the data as secure. This can be seen, for example, on a printout via the pictogram that symbolizes a closed padlock.

I have ordered a truck that will be produced in July 2023. Since the vehicle has a special structure, the first registration will not be until October 2023. Do I then have to have a new tachograph installed when the truck is registered?

Unfortunately, the date on which a vehicle is first registered on the road alone decides which tachograph is to be installed in it. The production date of the vehicle or the date on which the tachograph was installed in the vehicle on the production line is irrelevant for this.

That is why there will be numerous vehicles that have had a second-generation version 1 tachograph (e.g. a DTCO 4.0e) installed during production and then have to be retrofitted with version 2 (e.g. the DTCO 4.1).

This unpleasant situation for those affected already occurred when the smart tachograph was introduced in June 2019.

Is it correct that drivers who record via a DTCO 4.1 must record every load and every unloading or every entry or exit of a passenger via the tachograph? If so, how does it work?

It is true that, due to legal requirements, the DTCO 4.1 must be able to record loading and unloading operations as well as simultaneous loading and unloading operations in freight transport and, in the same way, the boarding and/or disembarking of passengers. With DTCO 4.1, these events can be entered by the driver using the following steps:

  1. Press the "Up Arrow" button or the "Down Arrow" button to enter the menu
  2. Use the arrow keys to go to the sub-item "Enter vehicle" and confirm with "OK"
  3. Use the arrow keys to go to the sub-item "Loading/unloading" and confirm with "OK"
  4. Either confirm "Load" with the "OK" button or select "Unload" or "Load/Unload" using the arrow keys and confirm the entry with "OK".

In the case of tachographs installed in vehicles used for the carriage of passengers, the entry and/or exit of persons in the tachograph shall be carried out in the same way.

 

Will there be new driver cards and will I possibly have to replace my driver card that is still valid until 2027?

Since the tachographs (G2V2) installed in new vehicles from August 21, 2023 must also be able to store an increased amount of additional or extended information on the driver card, new driver cards will be issued with the deadline of July 21, 2023 for new or replacement applications. Like the new tachographs, these are referred to as G2V2 cards, i.e. Generation 2 Version 2, and can, for example, store up to 1,624 loading and/or unloading processes as well as many other data sets that cannot be recorded at all on G2V1 driver cards. G2V2 driver cards are downward compatible with older digital tachographs and therefore also work in a DTCO 2.2a or 3.0(a) for example.

A mandatory exchange of valid driver cards is not required by law in Germany. An existing driver card can therefore be used until the end of its validity. The new tachograph version from August 21, 2023 can also "work" with older driver cards (G1 or G2V1 driver card).

If, as of December 31, 2024, the period of time that must be documented or carried is extended to the current and preceding 56 calendar days, you as a driver should not forget that after the expiry date you should not use your old driver card for a further 28 days, as before, but for a further 56 days to carry.

I only received a new workshop card in April 2023. Do I have to apply for a new card before the expiry date in April 2024 to be able to work on a DTCO 4.1?

The DTCO 4.1 or all G2V2 tachographs only accept second-generation workshop cards. Since these G2 workshop cards were introduced a few years ago and the workshop cards have to be renewed annually, there are no longer any valid G1 workshop cards in the EU member states. This means that you can use the existing workshop card until the end of its validity.

With the DTCO 4.1, when inserting or removing the driver card, are you automatically asked about loading or unloading or whether passengers are getting on or off?

The legal basis does not result in an obligation to integrate this query into the registration and deregistration process when inserting and removing the driver card. With the DTCO 4.1, this information is not "automatically" requested each time the driver card is entered or removed, since it cannot be assumed for every driver at this point in time that loading or unloading or the boarding or alighting of passengers will be involved.

The requirements for Gen1 and Gen2 V1 driver cards were set some years ago and at that time it was not foreseen to store border crossings on these cards. Therefore, border crossing information is not available on the daily printout of these driver cards. However, the DTCO 4.1 stores border crossings in the mass memory, so they can be displayed on the vehicle's daily printout.

The border crossings are stored on the new Gen2 V2 driver cards and are therefore visible on the daily printout. In addition, border crossings are also be visible on the vehicle's daily print out.

  • The Gen1 driver card was issued in conjunction with the DTCO 3.0 digital tachograph or earlier.
  • The driver card Gen2 V1 was issued in conjunction with the first version of the smart tachograph, namely DTCO 4.0 and DTCO 4.0e.
  • The driver card Gen2 V2 is the current driver card in Europe, issued since the introduction of version 2.

Changes on the driver card

Changes:

  • Only “G2” has been added between G1 and G2V1
  • Signature field is optional since G2V1
  • No changes between G2V1 and G2V2

Notes:

  • “Driver card” in the official languages printed in background has been removed in G2 regulation. But many countries kept it for G2V1
  • Many countries are using the same artwork since G1 (just adding the “G2” since G2V1)

Driver Cards

Overview of the features

Feature name

Feature description

GEN1

GEN2 V2

GEN2 V2

EF Application_Identification Read only file used by the VU to get some information about the file size x x x
EF CardMA_Certificate Read only file containing card mutual authentication certificate, used during mutual authentication process x x x
EF CardSignCertificate Read only file containing card sign certificate, used during card download to sign file content   x x
EF CA_Certificate Read only file containing country issuing authority certificate, used in both mutual authentication and signature operations x x x
EF Link_Certificate Read only file containing link certificate between ERCA public key values (currently unused)   x x
EF Identification Read only file containing card number, issuing authority name, driver names,… x x x
EF Card_Download File containing date when the last card download has been performed x x x
EF Driving_Licence_Info Read only file containing driving license number of the driver x x x
EF Events_Data Information related to an event associated to the cardholder G1: 6 types of events defined. G2Vx: 11 types of events defined. x x x
EF Faults_Data Information related to a fault associated to the cardholder
G1 and G2Vx: 2 types of faults defined.
x x x
EF Driver_Activity_Data Information related to driver activity (driving,work,break,…) x x x
EF Vehicles_Used Information related to the vehicle (odometer, registration number, date of use…) x x x
EF Places Information related to a place where a daily work period begins or ends x x x
EF Current_Usage Information related on the vehicle in which the card is currently inserted x x x
EF Control_Activity_Data Information related to the previous control performed x x x
EF Specific_Conditions Information on specific condition like ferry or train crossing x x x
EF VehicleUnits_Used Information related to the VU (device ID, software version,…)   x x
EF GNSS_Places Information on GNSS position automatically stored by the VU every 3 hours of continues driving   x x
EF Application_Identification_V2 Read only file used by the VU to get some information about the G2V2 file size     x
EF Places_Authentication Complements ‘EF Places’ and contains the authentication status of the vehicle positions stored in ‘EF Places’     x
EF GNSS_Places_Authentication Complements ‘EF GNSS_Places’ and contains the authentication status of the vehicle positions stored in ‘EF GNSS_Places’     x
EF Border_Crossings Used to automatically record border crossings     x
EF Load_Unload_Operations Used to store Load and Unload operation by the driver     x
EF Load_Type_Entries Used to store the distinction of carrying goods or passengers     x
EF Vu_Configuration File reserved for future use and should not be currently used     x

Are there any changes in DTCO 4.1 relating to the subject of DSRC, i.e. remote data queries by inspectors?

The data record, which is generated once per calendar minute by the tachograph for the DSRC (Dedicated Short Range Communication) query, is extended by some information in a DTCO 4.1 compared to a DTCO 4.0(e). With the EU Mobility Package I, the EU legislator has included the "time of availability of the last authenticated vehicle position" as additional information. In addition, it was decided to expand the DSRC data set to include personal data of the driver. Specifically, this is the following data:

  • Uninterrupted driving time (duration of the current block of driving time since the last rest period or break in driving totaling at least 45 minutes)
  • Driver's longest daily driving time in the current and previous 24-hour period
  • Longest daily driving time of the driver within the current calendar week
  • Driver's weekly driving time
  • Driver's fortnight's driving time

Due to the legal requirements for calculating these driving times for the DSRC data set, there may be a (slight) deviation between the actual driving time values of the respective driver and the values specified in the DSRC data set. As before, administrative offense or fine proceedings cannot be initiated solely on the basis of a DSRC query. This can be done solely as a result of an actual control of the vehicle or driver.

What improvements will the DTCO 4.1 bring for me as a fleet operator?

For fleet operators, communication via Bluetooth, which is introduced for the first time in the DTCO 4.1, offers many advantages. It is particularly important that, apart from the VDO Fleet App (available Q4 2023) and a device with a Bluetooth interface, such as a smartphone or tablet, no further hardware is required to connect to the DTCO 4.1. No need of purchasing the DTCO SmartLink Pro with the DTCO 4.1. The VDO Fleet App will be soon available for Android and iOS.

If a terminal device is connected via Bluetooth and you have inserted your company card into the tachograph, both the mass storage data and the data of an inserted driver card can be downloaded via Bluetooth.

The ITS interface of the DTCO 4.1 can be used to query and process data from the tachograph for telematics systems, regardless of whether the vehicle's ignition is on or off. The amount of data that can be queried cyclically or dynamically depends on the telematics system used and whether the driver has consented to the transfer of personal data.

This data is particularly interesting for the optimization of driver and vehicle management. But they also help with compliance. Since the DTCO 4.1 can provide data in a verifiable format, this data can be used for legally compliant documentation. If violations do occur, the reports and scorecards created in our cloud solution VDO Fleet will help you to take targeted measures to prevent further violations and to document your actions.

By the way, the VDO Link, which will be available soon, is of course compatible with the DTCO 4.1. This allows you to automate tachograph downloads without installation and retrieve various data such as position and remaining driving times in real time.

 

In addition, the DTCO 4.1 is already well equipped for the future, as it can be updated. If there are legal changes or new features, for example simplifying operation by the driver or generating additional data for driver, vehicle and trailer management, an update will be sufficient in the future to benefit from these improvements.

What advantages do I have as a driver of the DTCO 4.1?

A major improvement for drivers carrying out cross-border transport is the fully automatic detection and storage of border crossings. This eliminates the need to stop at a suitable stopping place and manually enter the country via the tachograph menu.

Since the DTCO 4.1 can communicate via Bluetooth, it is possible to make entries or view evaluations via the VDO Fleet App (available Q3 2023). For example, manual supplements can be created more conveniently and a quick overview of the working and driving times already worked or the driving breaks and rest periods still to be taken can be obtained. The connection between the smartphone and the tachograph no longer requires additional hardware such as the DTCO SmartLink Pro. The scope of services and information provided by the app depends on whether you, as the driver, have consented to the transfer of personal data or not.

When you remove your driver card, the Bluetooth connection is disconnected. When the driver card is reinserted, the connection is re-established.

The special rules and innovations introduced by the EU Mobility Package I are integrated into DTCO 4.1. This applies, for example, to the special rule in international freight transport, which makes it possible to take two reduced weekly rest periods in succession, or to extend driving time by up to two hours at the end of the working week in order to spend a weekly rest period at the place of residence or business location. If a weekly rest period is taken during transport in accompanied combined transport (ferry/train regulation), DTCO 4.1 also recognises this change from the EU Mobility Package I. In addition, all the improvements introduced with the DTCO 4.0e update will be carried over.

The DTCO 4.1 gives the driver a warning if the preset maximum speed is exceeded (usually 90 km/h). A warning is also shown on the display if the maximum permissible working time per day or per week is exceeded (>10 h/>60 h) or if a driver card expires about to expire.

The set UTC time is regularly compared with the time transmitted by the satellite positioning system and an adjustment is automatically made in case of minor deviations.

What are the requirements for retrofitting? Will soon all vehicles over 3.5 t permissible maximum mass and all buses be equipped with the DTCO 4.1?

Compared to the retrofitting deadlines contained in the original version of Regulation (EU) No. 165/2014, Regulation (EU) 2020/1054 has set significantly shorter deadlines. Only those vehicles that are used for cross-border freight or passenger transport and with which journeys subject to recording are carried out are affected by the obligation to retrofit. If the vehicle is only used within the Member State of establishment, a functioning tachograph (regardless of generation or version) does not have to be replaced on a general date.

If the vehicle is used across borders and no exemption from the driving and rest time regulations can be claimed, the following conversion periods apply:

By 30.12.2024 at the latest, all vehicles in which an analogue tachograph (with speedometer disc/record sheet) or a first-generation digital tachograph (all DTCO up to and including version 3.0a) is installed must have been converted. From 31.12.2024, these vehicles must be equipped with a second-generation version 2 tachograph, for example the DTCO 4.1. With regard to the date of first registration, all vehicles registered up to and including 14.6.2019 are affected. For vehicles registered in Q2 2019, it should be checked which tachograph version is actually installed. The background to this is that some vehicle manufacturers have already equipped vehicles with a G2V1 tachograph before 15.6.2019. In this case, the retrofitting period shown below applies.

In addition to the tachograph itself, the motion sensor (KITAS) must be replaced and a DSRC antenna installed.

By 18.8.2025 at the latest, all vehicles already equipped with an intelligent tachograph (G2V1, for example DTCO 4.0 and 4.0e) must have been converted to the latest version, for example DTCO 4.1, as the conversion period for these vehicles expired on 19.8.2025. In relation to the date of first registration, these are all vehicles registered from 15.6.2019. In addition to the tachograph itself, the motion sensor (KITAS) must also be replaced.

As of 1.7.2026, those vehicles with which cross-border journeys are carried out and which are subject to recording and which have a maximum permissible mass between more than 2.5 t and not more than 3.5 t will follow. If these vehicles are already equipped with a tachograph, the installed device can be operated until 30 June 2026 at the latest, regardless of the date of first registration of the vehicle, as a second-generation tachograph version 2, for example a DTCO 4.1, must be installed from 1.7.2026. If a tachograph is not yet installed, the same requirements and date apply.

Companies that transport their own goods for their own purposes in so-called own account transport in accordance with Article 1 (5) (d) of Regulation (EC) No. 1072/2009 with vehicles between more than 2.5 and not more than 3.5 tonnes maximum permissible mass may be subject to an exception for cross-border journeys, depending on the individual circumstances, which is described in detail directly afterwards.

From July 1, 2026, the EU social regulations will apply and thus also the recording by tachograph for vehicles for the transport of goods with a maximum permissible mass of more than 2.5 t. What does that mean for me as a service provider, dealer or craftsman?

Anyone who only transports their own goods for the company's own purposes operates so-called works transport. The exact requirements that must be met for company transport are described in Article 1 Paragraph 5 Letter d) of Regulation (EC) No. 1072/2009.

If these companies use vehicles or tractor-trailer combinations with a maximum permissible mass of more than 2.5 t and no more than 3.5 t for cross-border goods transport or for own-account cabotage, the following applies from 01.07.2026 in accordance with Article 3 letter, depending on the individual case ha) in conjunction with Article 2 Paragraph 1 Letter aa) of Regulation (EC) No. 561/2006, an exemption from the driving and rest time regulations and thus also from the obligation to have a tachograph installed in the vehicle.

The prerequisite for the exception, however, is that "driving is not the main activity of the person driving the vehicle". What exactly that means, i.e. the extent of steering activities, for example, from which these steering activities are to be regarded as the main activity, depends primarily on this how the respective national authorities responsible for the implementation of the driving and rest time regulations interpret this legal issue. Companies in Germany can obtain information from the supervisory authority responsible for the company headquarters (e.g. trade supervisory authority) on how this situation is interpreted in Germany .

In Germany, as of May 2023, it is still unclear which wording will be used to adapt the national legal basis (driving personnel law and driving personnel ordinance) to the EU law amended by the EU Mobility Package I. Only after these legal bases have been adjusted will it become clear whether companies that meet the requirements formulated in EU law can also benefit from the exception for purely national transport. As of May 2023, journeys in company traffic in Germany with a maximum permissible mass of more than 2.8 t must be recorded (by "daily control sheet" or by tachograph, if one is installed), unless an exception under paragraph 1 or 18 of the Drivers' Ordinance applies.

If the above or any other exception is not applicable to the company's carriage, international (and where applicable also national) carriage on own account or on own-account cabotage involving vehicles or towing vehicle-trailer combinations with a maximum permissible mass of more than 2.5 t from July 1, 2026, a second-generation version 2 tachograph, for example a DTCO 4.1, must be installed in the vehicle. Vehicles that cannot be equipped or retrofitted with a corresponding tachograph may not (from July 1, 2026) be used (any longer) for such transport.

The term own-account cabotage hides a carriage carried out by an own-account transport company within a country in which it is not established. For example, a German construction company that carries out construction work in Paris, France, and procures building material itself from building material suppliers within the Paris city area and transports it to the construction site with its own vehicles.

From July 1, 2026, the EU social regulations will apply and thus also the recording by tachograph for vehicles for the transport of goods with a maximum permissible mass of more than 2.5 t. What does this mean for me as a carrier?

Since May 21, 2022, anyone who transports goods across borders for a fee with vehicles or towing vehicle-trailer combinations with a maximum permissible mass of more than 2.5 t or who carries out cabotage transport has required a permit under road haulage law, the so-called EU license.

From July 1st, 2026, the obligation to have a version 2 tachograph of the second generation, for example a DTCO 4.1, installed in the vehicle will also apply from the "more than 2.5 t limit" for cross-border transport and cabotage transport. Vehicles that cannot be equipped or retrofitted with a corresponding tachograph may not be used for such transport (from July 1, 2026).

In Germany, as of May 2023, it is still unclear which wording will be used to adapt the national legal basis (driving personnel law and driving personnel ordinance) to the EU law amended by the EU Mobility Package I. Only after the amendment of these legal bases will it become clear whether freight carriers based in Germany will also use tachographs to record carriage that takes place exclusively on the territory of the Federal Republic of Germany with vehicles between more than 2.5 t and no more than 3.5 t maximum permissible mass have to make. As of May 2023, goods transport for third parties for a fee in Germany with a maximum permissible mass of more than 2.8 t must be recorded (by "daily control sheet" or by tachograph, if one is installed), unless an exception under paragraph 1 or 18 of the driving personnel ordinance applies.

Cabotage carriage is carriage carried out within a country in which the carrier has no place of business. For example, a transport by a German carrier between Warsaw and Gdansk in Poland.

The new DTCO 4.1 will have a Bluetooth interface. What are the advantages for me as a driver or fleet operator?

For the company, an advantage of communication via Bluetooth is that no additional hardware is needed to connect to the smartphone, tablet or other devices. The expense of purchasing the DTCO SmartLink Pro is eliminated with the DTCO 4.1.

In addition, it is possible to download both the mass storage data and the data of an inserted driver card via Bluetooth when the company card is inserted. The VDO Fleet App (available Q3 2024)  can be used for this purpose. If the data is transferred in this way, a separate download key is no longer required.

The ITS interface of the DTCO 4.1 can be used to query and process data from the tachograph for telematics systems, regardless of whether the vehicle's ignition is on or off. The amount of data that can be queried cyclically or dynamically depends on the telematics system used and whether the driver has consented to the transfer of personal data.

Drivers also benefit from the fact that the DTCO 4.1 can communicate via Bluetooth. Via the VDO Fleet App (available Q3 2023), entries can be made or evaluations can be viewed. For example, manual supplements can be created more conveniently and a quick overview of the working and driving times already worked or the driving breaks and rest periods still to be taken can be obtained. The connection between the smartphone and the tachograph no longer requires additional hardware such as the DTCO SmartLink Pro. If you do not consent to the transfer of personal data, the scope of services of the app or other applications may be limited.

The regulations are becoming more and more complicated. Can I use the tachograph data to check and document compliance?

The processing and evaluation of the data stored by the tachograph offers fleet operators numerous opportunities to document legally compliant behavior or to react precisely in violations occur. The key to this is the VDO Fleet cloud solution. The data, which you either upload manually to our security servers or which is downloaded fully automatically from the tachograph's mass memory and driver cards via remote download, goes through an analysis process at the end of which compliance with numerous requirements has been checked. You receive vehicle and personal evaluations and can use the scorecards provided to see at a glance whether the regulations have been complied with or whether there is potential for improvement in driver or vehicle management. All data, documents and information are archived via the installation-free cloud solution.

Legally compliant transport handling is so important because the risk classification system means that a transport manager and, if necessary, other responsible persons in the company lose their personal reliability if too many or serious violations are committed during the execution of the transports. If personal reliability is in doubt or "revoked", there is a high risk of the continuation of the Community licence (EU licence).

For this reason, the reports and scorecards made available to you via the cloud platform VDO Fleet Tachograph Management not only show violations for driving, working and rest times, but also non-compliance with cabotage regulations and, in the future, also with posting regulations.

These services will also be available to fleets with older tachograph versions via the VDO Link, our plug-and-play device that will be launched in December 2023 and will be connected via the front interface of the tachographs.

With VDO Fleet and VDO Link,  you take care of your business, we take care of your compliance.

With the many different tachograph versions, I'm slowly losing track. Can you give me a clear explanation of that?

Analogue tachographs

In vehicles that were registered for the first time on the road before 30.4.2006, analogue tachographs are installed, which record on record sheets (also called speedometer discs).

Digital tachographs - Generation 1

From 1.5.2006, for the first time, registered vehicles used for journeys subject to recording had to be equipped with a digital tachograph. These are referred to as the first generation (G1) of digital tachographs. Since some technical adjustments have had to be made over the years, for example to improve the tamper-proofing of the devices, to record a second motion signal or to integrate the so-called one-minute rule, there are a total of three versions of the first-generation digital tachographs. The first version (G1V1) was installed until 30.9.2011, the second version (G1V2) between 1.10.2011 and 30.9.2012 and the third version (G1V3) between 1.10.2012 and 14.6.2019.

In the case of VDO's DTCOs, release versions 1.0 to 3.0a belong to the first generation.

Digital tachographs - Generation 2

Vehicles registered for the first time on or after 15.6.2019 must have the so-called "intelligent" digital tachograph, which, for example, can transfer fleet management data to the company via the so-called ITS interface (Intelligent Transportation System), is connected to a global satellite navigation system and provides a data set for DSRC remote query (Dedicated Short Range Communication). These devices are called second generation (G2) digital tachographs. Since the 2nd quarter of 2019, the first version (G2V1) of these tachographs has been installed. These are, for example, the DTCO 4.0 and the DTCO 4.0e, which has received some improvements and additional features via update and, for example, supports the driver when entering the country when crossing the border.

From 21.8.2023, the second version of the smart tachograph will be installed in new vehicles. The general abbreviation G2V2 has been established for this. VDO sells this tachograph under the designation DTCO 4.1.

For more information, read our magazine article:

The DTCO 4.1 will be able to be supplied with updates via the workshops. In which areas or functions will it be possible to update the software?

In principle, all software-based functions of the G2V2 tachograph can be adapted or changed via updates, for which this is not prohibited by law. Examples of this would be an update of the digital map, the adaptation of the structures in a submenu or additional information for the driver in the VDO counter. We are therefore particularly interested in feedback from drivers and companies about existing potential for improvement. There are limits to adjustments made by an update, for example, in the case of functions whose modification would negatively affect protection against manipulation.

A good example of software-based adaptations, which mean an improvement, especially for the drivers, is the update from DTCO 4.0 to version 4.0e. The update provides the driver with suggestions for entering the country when crossing the border and additional information in the VDO counter that makes it easier to comply with working time regulations. In addition, the DTCO 4.0e simply ejects the driver card ten minutes after insertion if no entries are made, instead of reading the card after one minute without manual additions, as is the case with the DTCO 4.0.

Where can I book training for the DTCO 4.1? Who is my contact person for the topic?

VDO and our VDO partners offer various training courses for drivers, fleet operators and workshops:

How do I avoid the movement conflict message on ferries or train journeys?

As of DTCO 4.1, the ferry/train setting must generally be activated for every ferry/train crossing (even for short crossings) in order to avoid the movement conflict message;

This amendment corresponds to the currently valid version of Regulation (EU) 2016/799  (21/08/2023).

The ferry/train recording will be finished soon:

  • Ferry/train is deactivated in the menu
  • the driver card is removed
  • or the vehicle drives for at least one calendar minute.

It is therefore essential that you check at your final position during shipment whether the ferry/train is active or whether the ferry/train pictogram is visible in the DTCO display.

If the DTCO 4.1x has already been activated and the vehicle is being towed or transported, Ferry/Train must be set. This is necessary to avoid the movement conflict message.

DTCO

For legal and technical reasons, a software update of the older devices that would enable them to accept manual entries in the same way as the current devices is unfortunately not possible.

The EU regulation states that all driving times of a driver must be documented without gaps – preferably on the driver’s card. If this is not possible, a driver must carry a confirmation (EU form) from the company covering the last 28 days before he starts the trip.

The calculation of the times is done using fixed parameters, which are defined in the EU regulation – irrespective of the digital tachograph’s manufacturer.

Article 34 (7) of the EU regulation No. 165/2014 stipulates the following: “The driver shall enter in the digital tachograph the symbols of the countries in which the daily working period started and finished.” So yes, it’s necessary to enter the country symbol at the start and end of your daily work period even if the country has not changed and/or the driver card remained in the device overnight. The legal requirements do not suggest any rule according to which a country symbol only has to be entered if the country has changed.

A driver card with an expired validity date will no longer be accepted by the tachograph. The “Card invalid” error message will appear in the display and the card will be ejected. This also means that no further data will be saved on the expired card. In this case, the driver or the company must apply for or purchase a new card from the card-issuing body which is responsible.

This message means that the driver card or mass memory download is due, hence the “0 days” in the display.

An authorised workshop can program the DTCO so that this message appears in the display a few days beforehand.

So you must read out the driver card and/or the mass memory of the digital tachograph.

The driver card must be read out at least every 28 days and the mass memory data at least every 90 days.

You’ll need a company card and a driver card to operate the tachograph properly.

You can apply for these cards either at your local trade office or at vehicle registration and technical inspection authority offices.

The first step is to register the tachograph with the company card.

Make sure you have enough printer paper rolls in the vehicle.

You must also comply with the regular intervals that are prescribed for checking the device, meaning you must visit an authorised tachograph specialist workshop every 2 years.

Tachograph repairs and calibrations may only be carried out by authorised specialist workshops.

You can usually find relevant information in the operating manual, which must always be in the vehicle. If you don’t have this manual, we recommend that you purchase one from our dealers or a specialist workshop.

For reading out the driver cards (every 28 days at the latest) and the mass memory of the digital tachograph (every 90 days at the latest), we recommend our current DLK Pro Downloadkey with the article number A2C59515252. It contains an integrated card reader for reading out driver cards. If you have this key, you don’t need a licence card to unlock the integrated card reader.

However, the key only reads out and archives the data – you can’t display and evaluate any data with it.

Our TIS-Web Data Management online solution is ideal for evaluating driver and vehicle data.

The monthly fees for this depend on the number of vehicles and users recorded and the range of functions used, which can be flexibly selected in various user levels.

All you have to do is transfer the vehicle and driver card data to the TIS-Web platform. The data is then backed up in a professional data centre.

We do not offer access to TIS-Web in our webshop. We recommend that you contact one of our specialist dealers for this.

We can offer you our DLK Pro TIS-Compact (article number A2C59515262) as an alternative here. It’s almost like the DLK Pro Download Key, because if you have it, you don’t need a licence card to activate the integrated card reader. However, the difference is that the DLK Pro TIS-Compact is restricted to a fleet of up to 5 vehicles and up to 10 drivers. This key also differs from the normal DLK Pro in that it contains software you can install on your PC or laptop. This means you can store the data locally on your computer and also display and evaluate it. If you decide to use the DLK Pro TIS-Compact, you don’t need additional TIS-Web access.

The buffer batteries in the digital tachographs must be replaced every 2 years as part of the periodic DTCO tests.

This ensures that the digital tachograph is not damaged. The DTCO must continue to safely store the data for 1 year after disconnection from an external supply voltage (e.g. the vehicle battery).

If the buffer batteries are not replaced every 2 years, there is a risk that they will discharge. This means that the data stored in the DTCO will be irrevocably lost and the DTCO will no longer function.

The only thing you can do then is to replace the device.

One special feature of the DTCO 1381 Release 2.1 is the integrated VDO counter, which shows the remaining driving and rest times in real time on the device’s display.

Please note that the VDO counter function of the DTCO Rel. 2.1, which is directly installed by the vehicle manufacturer ex works, must be activated with an additional DTCO VDO Counter Update card.

The VDO counter is already enabled in our “DTCO 1381 Rel. 2.1 active” retrofit devices. If you have this release, you don’t need an update card.

“Out of Scope” mode means that the vehicle is travelling outside the scope of the regulation. This is possible for trips outside EU countries, for example, and may also be possible for trips on non-public roads. However, it may be open to interpretation and it is sometimes evaluated differently from state to state. As the manufacturer of the tachographs, we cannot make any legally binding statements in this case. We highly recommend that you contact your trade supervisory authority.

It is of course possible to replace the DTCO in your vehicle with a new device. Depending on the vehicle type, a vehicle-specific version can be used if necessary, or alternatively, you can use a “Universal DTCO”, which is then parameterised accordingly.

In any case, this work must be done by an authorised tachograph specialist workshop.

You can find suitable specialist workshops here


Download Tools

For more information on the DTCO error message 25, see above.

Learn More

The DLK Pro Download Key S will remain in the VDO portfolio alongside the DLK Smart Download Key. The DLK Pro Download Key S is the basic version of the download tools. The DLK Smart Download Key is the premium version.

No. The DLK Smart Download Key is already "ready" for the DTCO 4.1 and the corresponding tachograph cards.

All versions of the DTCO from version 1.x to 4.1 can be downloaded with the DLK Smart Download Key. This also includes the tachograph cards of the various generations (Gen. 1, Gen. 2V1 and Gen. 2V2). In addition, the DLK Smart Download Key is also compatible with authorised digital and intelligent tachographs from competitors.

The DLK Smart Download Key can automatically transfer the downloaded data via Bluetooth to the VDO Fleet App on the mobile phone*. From there, it is possible to transfer the data to the customer's VDO Fleet account, where it can be archived and analysed. The VDO Fleet App will be available in January 2024.

It is also possible to automatically upload the data to the VDO Fleet Portal* using the PC application KeyTools via the "DLK Automatic Uploader" of the DLK Smart Download Key.

* A VDO Fleet Tachograph Management licence is required for automatic data processing and archiving.

The DLK Smart Download Key is not limited to a specific number of drivers or vehicles. The available memory is also sufficient for several thousand downloads.

If you already have a DLK Pro Download Key S, you can download free updates from our customer portal myVDO to keep your DLK compatible with the latest tachographs: Dashboard (vdo.com)

Since the interface of the digital tachograph is technically defined by EU regulation, the speed of the data download can only be influenced to a limited extent, as this interface does not generally permit fast data transmission.

Question:
I have no data from the truck during a certain period, but the driver card data is read out correctly. I use the DLK Pro. Why?

Answer:
1) Do you also regularly load the mass memory from your digital tachograph into your archiving software? If not, then it’s possible that only certain sections are taken from the mass memory data for reporting purposes, depending on the archiving software. If only data from the driver card is downloaded, that is insufficient and does not comply with the legal requirements.

2) If only some of the vehicle data is missing (gaps), then this may be due to the following reasons: Because the download key is set to “Since the last download” by default, only the (vehicle) data that has been added since the last download is downloaded. If the (vehicle) download is now interrupted for any reason (accidental removal, etc.) then the download key notes the date of the download but the interruption prevents it from downloading any data – so data will be missing. When data is downloaded again, then only the most recent data is requested (since the last download, even if this was defective). However, the old, missing data will no longer be downloaded.

The solution:
Set DLK Pro to “entire mass memory” (Workplace/Keytools/Start.exe) and repeat the download. When the download has completed, all the data should be available again. You can then set the DLK Pro back to “Since the last download”. It also downloads more quickly with this setting.

Question:
We’re interested in the DLK Pro Download Key. Is there any limitation on the number of vehicles and drivers that can be downloaded? Eight vehicles and 14 drivers can currently be downloaded. At present, we use an older VDO download stick + card reader to send our data in ddd format to an external company for evaluation and archiving. Can we carry on doing this with the DLK Pro?

Answer:
The DLK Pro Downloadkey has no limitation in terms of drivers and vehicles, it’s only the amount of memory that’s limited. You can use the “new” Downloadkey in the same way as the older one, but a card reader is already integrated into the newer version. Only the DLK Pro TIS Compact is limited – but only in the evaluation function (5 vehicles, 10 drivers), not with the download itself. If you want to send the driver’s card or vehicle data automatically, we recommend our Remote Download Device DLD. The DLD system gets the data into the office 100% automatically, so you won’t have to chase after your drivers or vehicles for information if you use this system.

Question:
I have several trucks. In the case of one vehicle, it’s vital that I get all the tachograph data. The truck has been with me since September 2014, but the UN card was apparently not inserted until February 2016. Right now I can only read the data from today to February 2016. Is there any way to get the “missing” data (September 2014 - February 2016)?

Answer:
If your company card was inserted into the digital tachograph for the first time in February 2016, the data should also be downloadable before the company lock was set in February 2016 (free data). However, from the information you’ve given us, we believe that another company must have already been registered before that – so you can’t download this data with your company card. An authorised workshop can download all the data using its workshop card, but it’s only allowed to release the free data (without a company lock) and the data protected with your company lock to you.

Question:
I have the VDO Download Key DLK Pro to read out the tachograph data. When I plug the DLK into the tachograph in the truck, it takes about 15 minutes, then it lights up green. So far, so good. But when I insert the driver’s card in the DLK, I get a “No Authorization” message. I also can’t view driver activity on my PC. I can see that something has taken place on this date, but nothing more. Do I need additional software for this and is it mandatory? Is this readout process correct and sufficient?

Answer:
You obviously have a download key that hasn’t been unlocked yet. It was not automatically included from the outset, but was activated via an additional activation card. The current versions already have this included. From March on, there will probably be an update in which the DLK Pro card readers that have not yet been activated will be activated free of charge. However, it’s mandatory to read out the driver card as well. Depending on the archiving software, this can also be downloaded using an additional card reader (external USB). Alternatively, the download key can also download the driver card while downloading the mass memory (here the driver card must also be inserted in the digital tachograph and the driver card download must be enabled in the DLK settings). In all cases, the data is archived and evaluated using archiving software (e.g. TIS-Web). Simply downloading the data does not comply with legal requirements.


APPS

With the app, drivers benefit in particular from functions such as the VDO Counter (driving and rest times), the remote control of the DTCO via smartphone, the retrieval of the vehicle status and the calendar view.

To use the app, a DTCO® version 2.0a or higher, the DTCO SmartLink Pro and a smartphone with Android or iOS are required.

The use of the app is free of charge, as long as the necessary hardware is available. The VDO SmartLink Pro can be ordered on DTCO® SmartLink Pro (Android + iOS) |VDO online shop (vdo-shop.com).

The connection is made via Bluetooth. After successful pairing, the main menu (the three dashes in the upper left corner of the image) will take you to the option "Connect SmartLink" This requires the six-digit PIN, which is visible on the label of the SmartLink. After that, only the DTCO token (visible on the DTCO display) has to be entered.

It is recommended to eject the driver card in advance by remote control. Then, all corresponding activities can be entered in the menu via the "Manual supplement" option. As soon as the tachograph is ready to receive the data, it switches to transmission mode.

The calendar is downloaded via the "Driver activity" function and shows driving times, rest times, other activities, on-call times as well as distances traveled.

The upper half of the screen of the main menu shows the remaining driving time until the next break. The "VDO Counter" function provides more details.

The last activities can be seen in the sub-tabs of the VDO counter: these are driving time, rest time and history. Driving data and a rest time register are also available. Under "History" you will find daily and weekly data.

In the VDO Counter menu, the desired activity can be set under "Daily" and then under "Change activity".

First, the connection to the DTCO must be allowed under "Driver entry" and "Remote/remote control". The current connection status can be viewed in the app under "Setting" and then under "Diagnostics".

Under VDO Fleet - Downloads you will find a detailed description in different languages.

The app support email address is app-support@continental.com.


Miscellaneous

You can order VDO printer paper in our VDO Webshop or from one of our partner dealers.

Or you can order the printer paper from one of our specialist dealers.


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