Drivers and warehouse in one system, with the right rules
In the warehouse the Working Time Act applies as everywhere. Behind the wheel section 21a applies with its own limits and its own compensation period. MetronHR keeps the two apart.
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- Its own compensation period for driving personnel
- Standby time kept separate from working time
- Recording under section 17 MiLoG for the whole business
In shortDrivers fall under section 21a ArbZG: at most 48 hours a week on average, up to 60 hours if the average holds over four months. Because logistics is listed in section 2a SchwarzArbG, the working time of all employees has to be recorded within seven days. MetronHR calculates drivers under section 21a and the warehouse under section 3 ArbZG, each separately.
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Two sets of rules in one business
Anyone picking in the warehouse works under section 3 ArbZG. Anyone driving works under section 21a ArbZG. The limits differ, so does the compensation period, and the two have to be kept separate.
- Driving personnel: weekly average
- 48 hours
- Driving personnel: peak
- up to 60 hours
- Compensation within
- 4 months or 16 weeks
- Recording under MiLoG
- 7 days, 2 years
Driving personnel have their own compensation period
Working time may not exceed 48 hours a week. It can be extended to up to 60 hours if an average of 48 hours is not exceeded within four calendar months or 16 weeks.
That is what section 21a (4) ArbZG says. For all other employees section 3 ArbZG applies with eight hours per working day and a compensation period of six calendar months or 24 weeks. Anyone keeping both groups in the same report gets one of them wrong.
Standby time is not working time under certain conditions
Periods in which driving personnel have to hold themselves ready do not count as working time if the period and its expected duration are known in advance. The same applies to time spent next to the driver or in the sleeper cab while the vehicle is moving.
Governed by section 21a (3) ArbZG. The condition is the decisive part: without prior knowledge of the period and duration it remains working time. Anyone deducting standby across the board without announcing it beforehand understates actual working time.
Driving time is not working time
The driving and rest periods under Regulation (EC) No 561/2006 and working time law are two separate systems. One limits driving, the other limits working.
The tachograph documents driving time, standby, other work and rest. For section 21a ArbZG what counts is the sum of driving time and other work, not driving time alone. Loading and unloading, maintenance and paperwork are working time, even when the vehicle is stationary.
Freight forwarding, transport and logistics is named in section 2a SchwarzArbG
The recording duty under section 17 (1) MiLoG therefore applies to every employee in the business, from the driver to dispatch, within seven calendar days and retained for two years.
Set out in section 2a (1) no. 4 SchwarzArbG, which expressly includes platform-based delivery services. The tachograph alone does not meet the duty: it records driving times, not the start, end and duration of working time within the meaning of the Minimum Wage Act.
The key duties and how they are met day to day
| Duty | Source | With paper or Excel | With MetronHR |
|---|---|---|---|
| 48 hours on average over 4 months | Section 21a(4) ArbZG | drivers and warehouse in one spreadsheet | Rules per group of people |
| Stand-by deductible only if announced | Section 21a(3) ArbZG | deducted as a flat amount | a time type of its own, with period and announced duration |
| Record within 7 days | Section 17(1) MiLoG | the tachograph records driving time only | start, end, breaks, loading and unloading in the app, also offline |
48 hours on average over 4 months
- Source
- Section 21a(4) ArbZG
- With paper or Excel
- drivers and warehouse in one spreadsheet
- With MetronHR
- Rules per group of people
Stand-by deductible only if announced
- Source
- Section 21a(3) ArbZG
- With paper or Excel
- deducted as a flat amount
- With MetronHR
- a time type of its own, with period and announced duration
Record within 7 days
- Source
- Section 17(1) MiLoG
- With paper or Excel
- the tachograph records driving time only
- With MetronHR
- start, end, breaks, loading and unloading in the app, also offline
Further reading: Section 21a (3) and (4) ArbZG, section 3 ArbZG · Section 2a (1) no. 4 SchwarzArbG, section 17 (1) MiLoG · Regulation (EC) No 561/2006, German Driving Personnel Act
In detail, with examples: Working hours in logistics: what applies to warehouse staff and drivers
As at: November 2026. This is not legal advice; for a specific case in your business it is better to ask someone with a licence to practise.
The tachograph does not know everything
The digital tachograph is built for driving times. For records under the Minimum Wage Act and for the hours account it is not enough.
- Problem
Two limits, one report
Drivers and warehouse have different maximum working times and different compensation periods. In a shared spreadsheet neither of them comes out right.
- Problem
Work outside driving time disappears
Loading and unloading, waiting at the ramp, handing in paperwork. That is working time, but it does not appear as such in the driving time report.
- Problem
Standby is deducted across the board
Section 21a (3) ArbZG only allows this if the period and expected duration were known in advance. Without documenting that announcement, the basis is missing.
Separate rules, shared reporting
Driving personnel and office staff each run under their own limits. Driving time, other work and standby are separate time types, and the announcement of standby is recorded.
Two sets of rules, one reportEach group is calculated under its own rules, and reporting still happens together.
Features for freight forwarders and logistics companies
Built for separate rule sets, mobile recording and shift operation in the warehouse.
- Time
Rules per group of people
Section 21a for drivers, section 3 for everyone else
Maximum working time and the compensation period depend on the group, not on the business. Four months for driving personnel, six for everyone else.
- Time
Standby as its own time type
Deduct only what is genuinely deductible
Standby time is recorded with its period and announced duration. If the announcement is missing, the time counts as working time.
- Mobile
Recording from the cab
Working time even where there is no office
Start, end, breaks and secondary tasks such as loading and unloading are booked in the app, possible offline and synchronised later.
- Planning
Shift roster for the warehouse
Early, late and night with rest period checks
The warehouse plan follows sections 3 and 5 ArbZG, with checks on rest periods and maximum working time on every assignment.
- Overview
Records under section 17 MiLoG
What the tachograph does not provide
Start, end and duration per working day for every employee, complete within seven days, retrievable for two years.
For dispatch and driving personnel
One plans the routes, the other drives them. Both need the same time basis.
- Dispatch
See who still has hours left
- The route is there, but who can still drive it without breaching the 48-hour average?
- The current average in the running compensation period is shown next to every name, together with the outstanding rest period.
- Driving personnel
Book working time without paper
- Waiting at the ramp, helping with loading, paperwork. None of that appears in the tachograph as working time.
- Secondary tasks are booked in the app, even without a network, and feed into your own hours account.
Frequently asked questions from logistics
What freight forwarders and transport companies ask about working time.
Question not answered here? Every step is explained in the help centre.
Send us a messageWhat weekly working time applies to driving personnel?
48 hours on average. An extension to up to 60 hours is permitted if an average of 48 hours is not exceeded within four calendar months or 16 weeks (section 21a (4) ArbZG).
Can we raise the licence count for the Christmas season and lower it again afterwards?
Yes, monthly and self-service, in both directions and with no minimum term. The lower limit is the number of seats currently occupied. Temporary staff for the peak therefore only cost money in the months in which they drive or pick.
When does standby time not count as working time?
Under section 21a (3) ArbZG, when the period and its expected duration are known in advance. Without that prior knowledge it remains working time. The same applies to time next to the driver or in the sleeper cab with a multi-driver crew.
Is the digital tachograph enough as a record under section 17 MiLoG?
No. It records driving, standby, working and rest times for driving time enforcement. Section 17 MiLoG requires the start, end and duration of daily working time, and that for all employees of the business, not just drivers.
Is waiting at the ramp working time?
As a rule yes, because the free use of that time is restricted. It is different only where the conditions of section 21a (3) ArbZG are met, that is where the period and expected duration were known in advance.
Do the same limits apply to our warehouse staff as to the drivers?
No. For the warehouse and administration section 3 ArbZG applies, with eight hours per working day and ten with compensation within six calendar months or 24 weeks. Section 21a concerns only employees in road transport.
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Two sets of rules, one system
Driving personnel under section 21a, warehouse and administration under section 3, both with inspection-proof records under section 17 MiLoG. Try it free for 14 days.
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