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Bulgarian ITS Association experts have commented on the draft Directive on driving licences published on the EU public consultation website.

The Bulgarian ITS Association makes the following comments on the draft directive:

  1. Art. 10, paragraph 2, provides

The period of administrative validity of driving licenses issued by Member States shall be as follows:

(a) 15 years for categories AM, A1, A2, A, B, B1 and BE;

(b) five years for categories C, CE, C1, C1E, D, DE, D1 and D1E.”

We believe that it is more appropriate to provide that the administrative validity for all driving licences should be 15 years and to limit the validity of the category held if it is C, CE, C1, C1E, D, DE, D1 and D1E. Persons holding these categories need not be restricted if they are not practicing the profession of a professional driver. Annex 1, item 11 of the driving license provides for the validity period of the category. It is sufficient to limit the period of validity of the category instead of limiting the administrative validity of the driving license. This will reduce the administrative burden for EU citizens.

  1. Paragraph 3 of the same Article states:

“3. The renewal of driving licenses when their administrative validity period has expired shall be carried out after the simultaneous fulfillment of the following two conditions: …………….

(b) habitual residence in the territory of the Member State issuing the driving license or proof that the applicant has been studying there for at least six months at the time of his application.“

We consider it appropriate to add a new sentence to point “b”:

“Where habitual residence is not in the Member State issuing the driving license and the person is not habitually resident in another Member State. This is necessary for persons whose habitual residence is outside the EU.”

Some workers are on business trips outside the EU for more than 6 months they cannot prove habitual residence if their driving license expires during the business trip.

  1. Art. 11, paragraph 1 states:

1. Where the holder of a valid national driving license issued by a Member State establishes his normal residence in another Member State, he may request the replacement of his driving license by an equivalent driving license. The Member State carrying out the exchange shall check for which category the driving license presented is still valid.„

It is appropriate to add a new sentence:

“If the administrative validity of this driving license has expired, the Member State shall replace this license with a new one of administrative validity after establishing the physical and mental conditions of the holder and if there are no other administrative impediments to this.

The holder may have missed the administrative deadline for replacement, including if he is subject to an administrative deprivation sanction, in which case he will not be able to renew his license in the Member State of an issue because of a change of normal residence, and will not be able to renew it in the State of normal residence.”

  1. In Annex IV where the requirements for examiners are defined we propose to add,

1. there has been no decision affecting the right to manage in the last two years;

  1. there has been no criminal judgment against him arising from a traffic offence in the last two years.“

It is not right for a person who blatantly violates safety rules to test applicants for licensure.