The improvement of road safety for all road users is an important aim of the regulations that lay down rules on the requirement for tachograph in the road transport sector. These regulations are Regulation (EU) No 165/2014, Commission Implementing Regulation (EU) 2016/799 and Commission Implementing Regulation (EU) 2018/502, which states the following:
(3) In accordance with Articles 8, 9 and 10 of Regulation (EU) No 165/2014, tachographs installed in vehicles registered for the first time on or after 15 June 2019 shall be smart tachographs. Implementing Regulation (EU) 2016/799 must therefore be amended so that the technical provisions laid down therein apply from that date.
The smart tachograph must be fitted to all vehicles in scope that are registered from 15 June 2019 onwards. There are no provisions for any derogations in the Regulations as they stand, to allow for any exceptions to this rule. As Commission Regulations, these have direct effect throughout the EU and any question of a derogation would require consideration at European rather than national level.
I trust this clarifies the position in this regard.