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Challenging transport penalties — by land and by sea

A fine is paid once; lost good repute or a detained ship is paid for every single day. We defend the proceedings end to end: representations, administrative appeal and judicial review.

1Who we help

Transport companies and own-account fleets

Tachograph, driving times, overweight loads, ADR, cabotage. The penalty regime of the Spanish Land Transport Act (LOTT) also reaches own-account transport — a manufacturer's own fleet is not out of harm's way.

Transport managers

The proceedings that should really worry you: loss of good repute, which can disqualify you for up to a year and drag the company down with you.

Shipowners, masters and fishing vessels

Penalties from the Spanish Harbour Master (Capitanía Marítima) and the Spanish Directorate-General for the Merchant Marine (DGMM), ship detentions by Port State Control, fisheries proceedings.

Sector insurers

Defence of policyholders in penalty proceedings with an impact on policies and fleets.

Tachograph and driving timesTachograph tampering (LIMG)Overweight loadsADRCabotageLoss of the transport manager's good reputeEarly-payment reduction (30%)Harbour Master penaltiesPSC detention of the shipFisheriesJudicial review
2What you need to know

What is loss of good repute, and why is it the most serious part of the proceedings?

Certain very serious infringements — most notably tampering with the tachograph or the speed limiter (Article 140.10 LOTT, triggered even by the mere installation of the device even if it was not in operation at the time of inspection) — carry the LIMG label: loss of the transport manager's good repute for up to one year (Article 143.5). Without a manager of good repute, the company's authorisation is on shaky ground. The good news: it is not automatic. It requires separate proceedings against the manager, it does not apply where the facts are not attributable to them, and the law requires proportionality to be assessed (the 365-day rule). It is precisely the terrain where a well-built appeal is needed.

How much overweight is penalised?

For heavy vehicles (over 12 t maximum authorised mass): a minor infringement from 2.5% over, serious from 5%, very serious from 10% — subject to particular rules.

My ship is detained (PSC) or the Harbour Master has opened proceedings against me

A ship detention costs thousands a day: the first step is to get her released — security, rectifications, negotiation with the inspectorate — and then fight the penalty proceedings calmly. The Harbour Master, the DGMM and the fisheries authorities each have their own procedures — and their own mistakes.

3How we work
4Experience

Our experience includes…

5FAQs
How long do I have to file representations?

15 days from notification of the initiation decision (Article 210 of the LOTT implementing Regulation (ROTT)) — and if no representations are filed, the initiation decision can turn directly into the proposed decision.

Do these proceedings become time-barred or lapse?

Yes: infringements are time-barred after one year (Article 145 LOTT), and the penalty decision must be notified within a maximum of one year from initiation (Article 146.2 LOTT).

Can they take away my transport authorisation?

That is the ultimate consequence of lost good repute and of certain repeat offences.

Are the labour inspectorate and the transport inspectorate the same thing?

No: they coexist and are defended separately (driving time vs working time).

I am a shipper with my own fleet — does the LOTT apply to me?

Yes — own-account transport has its own authorisation and penalty regime. Owning the fleet does not exempt you.

6Talk to us
Jordi Mayol Orga
Lawyer (Abogado) · Barcelona Bar (ICAB) No. 44.531
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