Too short to be the driver's rest
Article 9(1) of Regulation 561/2006 lets a driver take a regular daily rest period on board a ferry with a sleeper cabin. The Gulf of Finland crossing is nowhere near long enough for that: it counts against the driver's working day rather than replacing part of it. It is the opposite of the Swedish lanes, where an overnight sailing is rest — and it is why the departure a load catches genuinely matters here.