TPM or TPPC: Which Usage Declaration for a Fleet?

Key facts

• French law splits road freight into two statuses: public carriage (TPM, transport public de marchandises — carrying goods owned by third parties, for hire) and own-account carriage (TPPC, transport pour compte propre), defined by exclusion in article L. 1000-3 of the French Code des transports.
• Only public carriage requires registration on the carriers' register and financial and professional capacity conditions (article L. 3211-1 of the Code des transports).
• The usage declared to the insurer (TPM or TPPC) is stated in the fleet insurance policy and directly drives the risk rating.
• An intentional false declaration that changes the nature of the risk voids the policy, even without any link to the claim (article L. 113-8 of the Code des assurances).
• A good-faith inaccurate declaration leads to a proportional reduction of the indemnity, not to voidance (article L. 113-9 of the Code des assurances).

This article describes French law and is intended for readers evaluating a road freight fleet operating under French regulation.

What are TPM and TPPC in fleet insurance?

TPM (transport public de marchandises) designates a business that carries, for payment, goods owned by third parties. TPPC (transport pour compte propre) designates the carriage by a business of goods it owns, or has sold, bought, produced, extracted, processed or repaired, using its own vehicles and drivers or rented vehicles, where the carriage remains ancillary to its main activity.

The Code des transports frames the distinction negatively: public carriage is "any carriage of persons or goods, except that organised for its own account by a public or private person" (article L. 1000-3 of the Code des transports). Own-account carriage (TPPC) is the exception; anything that does not meet it defaults to public carriage (TPM).

This administrative distinction is not a minor regulatory detail: insurers use the same classification to rate fleet risk, under the commercial labels TPM and TPPC. For a broader overview of fleet coverage, see the heavy-goods fleet insurance hub (French-language page).

Does own-account carriage require a transport licence?

No. Own-account carriage (TPPC) is not subject to registration on the carriers' register, to the domestic transport licence (licence de transport intérieur), or to financial and professional capacity requirements. These obligations apply only to public carriage.

Article L. 3211-1 of the Code des transports subjects the profession of public road freight carrier to "conditions of establishment, professional good repute, financial capacity and professional capacity, as well as registration on a register held by state authorities." A construction company that moves only its own equipment and supplies between sites, using its own vehicles and without charging a third party for a carriage service, falls outside this regime: it operates on an own-account basis, without a licence.

This administrative status does not remove the compulsory motor third-party liability cover. It does change the scope of the risk declared to the insurer: a business operating on an own-account basis does not expose its fleet to the contractual risk tied to carrying third-party goods (damage, delay, value of goods carried).

Does a TPPC business stay covered if it invoices a one-off carriage job to a client?

Not necessarily, under the same terms. As soon as a business declared as own-account (TPPC) carries, even occasionally, goods owned by a third party for payment, the operation no longer meets the own-account definition under article L. 1000-3 of the Code des transports.

That operation then falls under public carriage, with the related regulatory obligations (register, licence) and a risk profile different from the one declared to the insurer. A policy underwritten on a TPPC basis was rated on a risk that excludes carriage for third parties; a TPM operation carried out under that declaration is a change in the insured risk, distinct from the original declaration, and should be reported to the insurer.

What happens if a business declares TPPC while actually operating as TPM?

Two sanction regimes coexist, depending on whether the insured's bad faith is established. If the false declaration is intentional and changes the nature of the risk or lessens the insurer's assessment of it, the policy is void, even where the misdeclaration had no bearing on the claim (article L. 113-8 of the Code des assurances). Premiums already paid remain the insurer's, who may also claim payment of premiums due as damages.

If bad faith is not established, the policy is not void. If discovered before any claim, the insurer may either maintain the policy against a premium increase accepted by the insured, or cancel it with ten days' notice, refunding the portion of premium corresponding to the period no longer covered. If discovered after a claim, the indemnity is reduced under the proportional premium rule: in proportion to the premium rate paid relative to the rate that should have been paid had the risk been fully and accurately declared (article L. 113-9 of the Code des assurances).

How does the declared usage affect the fleet insurance premium?

The TPM or TPPC declaration is a core element of the insurer's risk assessment, alongside tonnage, the type of goods carried, or claims history. A TPM usage structurally exposes the insured to cover and risks that TPPC does not carry: goods belonging to third parties, standard contracts or international conventions governing indemnification, and multiple principals.

This risk is also assessed against the fleet's claims history, which can itself trigger cancellation after a claim under the conditions set out in the Code des assurances.

The table below summarises the main differences between the two regimes:

Criterion	TPM (public carriage / for-hire)	TPPC (own-account carriage)
Legal basis	Default regime (art. L. 1000-3, Code des transports)	Exception defined by the same article
Registration on the carriers' register	Mandatory (art. L. 3211-1, Code des transports)	Not required
Domestic transport licence	Required	Not required
Goods carried	Owned by third parties, for payment	Owned by the business itself
Risk covered by the fleet insurer	Motor liability, plus carrier's goods-in-transit liability where applicable	Motor liability, without third-party goods risk
Sanction for a false usage declaration	Voidance if bad faith (art. L. 113-8) or reduced indemnity if good faith (art. L. 113-9)	Same, in reverse

How should a business check and correct its fleet's declared usage?

The check starts from the vehicles' actual activity over the last twelve months, not from the business's stated main activity alone. A construction company may operate on an own-account basis for most of its fleet and, occasionally, on a for-hire basis for one vehicle dedicated to deliveries invoiced to clients.

Where there is doubt or a change in activity, the insured is better off reporting the change in risk to the insurer before renewal rather than at the time of a claim: this allows the business to fall under article L. 113-9 (premium increase or ten-day cancellation) rather than risk a reduced indemnity, or voidance if bad faith were established.

Frequently asked questions

What is TPM in fleet insurance?

TPM (transport public de marchandises) designates carriage, for payment, of goods owned by third parties. It falls under public carriage within the meaning of article L. 1000-3 of the Code des transports and requires registration on the carriers' register and a domestic transport licence (article L. 3211-1).

What is TPPC?

TPPC (transport pour compte propre) designates carriage by a business of goods it owns, using its own vehicles, where the carriage remains ancillary to its main activity. It is exempt from the registration and licensing obligations that apply to public carriage.

Is a TPM/TPPC misdeclaration automatically punished by voidance of the policy?

No. Voidance (article L. 113-8 of the Code des assurances) requires an intentional false declaration that changes the nature of the risk. If bad faith is not established, article L. 113-9 applies instead: premium increase, ten-day cancellation, or a proportional reduction of the indemnity after a claim.

Does own-account carriage require a domestic transport licence?

No. Article L. 3211-1 of the Code des transports subjects only public road freight carriage to register entry and licensing. Own-account carriage is excluded from this regime by definition.

What happens if an own-account business invoices a one-off carriage job to a client?

That operation falls under public carriage within the meaning of article L. 1000-3 of the Code des transports, with the related regulatory obligations. It also constitutes a change in the insured risk that should be reported to the insurer if the policy was underwritten on a TPPC basis.

What McLer does

McLer is an insurance brokerage specialised in corporate risk for road freight and construction businesses. Based in the Paris region, McLer supports French SMEs and mid-sized companies in structuring, negotiating and managing their insurance programmes. On fleet usage declarations, McLer helps assess the risk actually covered and formalise activity changes with the insurer, depending on each business's situation.

Unsure how your heavy-goods fleet's usage is declared? Talk to a McLer broker to review your situation.