Found this online......
The question...
We have a number of employees who have a reporting base, but who in reality are mobile. They have company vans and leave home in the morning to go straight to their first job, usually without needing to physically go into their reporting base.
The answer...
A commute between home and offices would not count towards working time for the purposes of calculating normal working time.
However, where there is a requirement to travel as 'part and parcel' of the job, such as where your drivers travel from home to their first delivery and then back again after the last, then the travelling time would have to be included for the purposes of calculating their working time.
The Working Time Regulations 1998 - Reg. 2(1), define working time as "…any period during which [they are] working at [their] employer's disposal and carrying out [their] activity or duties." Therefore, as the drivers would be under your 'control' / 'in the course of their employment', their working time would be from the moment they left home until they returned.
Now basically the question is the EXACT position I am in....