This question is discussed in the Federación de Servicios Privados del Sindicato Comisiones Obreras case brought before the European Court of Justice (ECJ).
The claimants in this case worked as technicians for two security system installation and maintenance companies in Spain. Whilst the companies’ main offices were based in Madrid, the claimants were assigned to other geographical areas where they were required to travel to client’s homes by company car. The claimants were given instructions about the route they needed to follow each day by mobile phone. The travel time to the first assignment for the day and from the last assignment back home was not regarded as ‘working time’ but as ‘rest time’ by their employers. The claimants argued that such time should have been included in the ‘working time’ for the purpose of Working Time Directive.
The Advocate General agreed that the travel time to the first customer and from the last is part of the claimants ‘working time’, as they do not have a permanent place of work but instead travel to different sites each day.
However the Advocate General’s recommendation is not binding, although in most cases is followed by the ECJ.