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• Does the directive require training centres to be independent from the driver's employer? May, for example, a company employing drivers be approved as a training centre and thus organise training for its own drivers?
• Does the directive allow for a trainee driver to follow different parts of the training programme at several approved training centres?
• Can Member States’ competent authorities confer approval upon training centres only covering a limited proportion of the subjects listed in Annex 1, section 1 - or does a training centre need to cover all subjects listed to receive approval?

• Is it possible to combine professional drivers' training under Directive 2003/59 with other trainings (ADR, demerit points ...)?
• Do all subject areas listed in Annex I have to be included within the periodic training? Can the approved training centres set focal points concerning the selection of topics?
• Does the Commission consider it to be in conformity with the directive that training centres – under the training and testing approach pursuant to article 3, no. 1 littera a) – carry out parts of 280/140 hours courses through distance learning?

• Nature of initial qualification examinations that must be taken in a country by persons holding a driving licence issued by another country, when these countries have opted for different options: in countries such as the UK and the Netherlands which have redesigned their driving licence tests, so that they are recognised as part of the exams for the CPC initial qualification, which exams should a resident take when he holds a driving licence issued by another Member State?
• Nature of initial qualification examinations that must be taken by persons having completed option 1 (training but no test) and then wishing to gain CPC certification by taking the test in an option 2 country: does the applicant need to take the full CPC driving test, or does he just need to take the normal licence test, in order to gain CPC certification?

• If a driver attends his 35 hours periodic training in more than one country, who (which country’s authorities) issues the Driver Qualification Card or adds the qualification to the licence?
• Is it allowed that a person takes an exam for the initial qualification (article 3, paragraph 1, littera a) or the accelerated initial qualification (article 3, paragraph 2), without holding a valid driving licence?

• Does the directive require training centres to be independent from the driver's employer? May, for example, a company employing drivers be approved as a training centre and thus organise training for its own drivers?

  There is no specific requirement on this issue in the directive. A company employing drivers may organise training subject to the condition that it has been approved by the competent authorities of the Member State in which the training is provided and as long as it meets the course requirements which are set up in the directive.

  In some Member States, i.e. France and Sweden, companies and private training centres provide training to professional drivers under contracts signed with the government.

• Does the directive allow for a trainee driver to follow different parts of the training programme at several approved training centres?

  The directive does not prevent trainee drivers from taking different parts of their training at different approved training centres. However, it may be difficult to coordinate and combine different parts from different programmes.

• Can Member States’ competent authorities confer approval upon training centres only covering a limited proportion of the subjects listed in Annex 1, section 1 - or does a training centre need to cover all subjects listed to receive approval?

  The directive does not prohibit approvals of training centres only covering a limited proportion of the subjects listed in Annex 1. However, for consistency and efficiency purposes, approvals of training centres covering all subjects are recommended.

• Is it possible to combine professional drivers' training under Directive 2003/59 with other trainings (ADR, demerit points ...)?

  Professional training, ADR or demerit points recovery training... have different purposes and different objectives which must all be achieved. Common courses can be provided when subjects overlap, but specific tests must be organised.

• Do all subject areas listed in Annex I have to be included within the periodic training? Can the approved training centres set focal points concerning the selection of topics?

  According to Article 7, periodic training shall enable holders of a CPC to update the knowledge which is essential for their work. It shall be designed to expand on, and to revise, some of the subjects referred in section 1 of Annex I. Article 7 also requires specific emphasis on road safety and rationalisation of fuel consumption.

• Does the Commission consider it to be in conformity with the directive that training centres – under the training and testing approach pursuant to article 3, no. 1 littera a) – carry out parts of 280/140 hours courses through distance learning?

  Parts of the training courses can be carried out through e-learning. However, such methods should be complementary to courses provided by trainers. Training should not be provided exclusively on the basis of e-learning.

• Nature of initial qualification examinations that must be taken in a country by persons holding a driving licence issued by another country, when these countries have opted for different options: in countries such as the UK and the Netherlands which have redesigned their driving licence tests, so that they are recognised as part of the exams for the CPC initial qualification, which exams should a resident take when he holds a driving licence issued by another Member State?

  the complete set (because the driving licence tests he passed may not cover the same syllabus) or just the top-up items (because he already holds a full driving licence and there must be equality of treatment with the holder of a domestic licence)?

  The driver may be allowed to take a test only covering the top-up items, subject to the agreement of the national authorities.

• Nature of initial qualification examinations that must be taken by persons having completed option 1 (training but no test) and then wishing to gain CPC certification by taking the test in an option 2 country: does the applicant need to take the full CPC driving test, or does he just need to take the normal licence test, in order to gain CPC certification?

  He may be allowed to take just the normal licence test, subject to the agreement of the national authorities.

• If a driver attends his 35 hours periodic training in more than one country, who (which country’s authorities) issues the Driver Qualification Card or adds the qualification to the licence?

  For consistency and efficiency purposes, attending the 35 hours of periodic training in more than one country is not recommended. The country or authority in charge of issuing the CPC has to be agreed by the Member States concerned.

  There is no standard form of certification following periodic training. If drivers take all or part of their periodic training in another EU Member State, there will be problems regarding recognition of these certificates (possible fraud and greater administrative burden on competent authorities).

  A harmonised Community code is provided for in Article 10 of the Directive: "95. Driver holding a CPC complying with the obligation of professional competence referred to in Article 3 until… (e.g. 95. 01.01.2012)". This code will be included in the list of harmonised Community codes as laid down in Annexes I and Ia to Directive 91/439/EEC. It shall be marked either on the driving licence or on the driver qualification card drawn up in accordance with the model shown in Annex II.

• Is it allowed that a person takes an exam for the initial qualification (article 3, paragraph 1, littera a) or the accelerated initial qualification (article 3, paragraph 2), without holding a valid driving licence?

  It is allowed to take the initial qualification test before being issued a valid driving licence. However, the holder will not be allowed to make use of his CPC before being issued a valid driving licence.