"In Germany flight duty time regulations also apply to employed pilots flying without AOC. There is no exemption for that"
Granted - but have you ever heard of ANY action regarding FDT against a non-AOC pilot in Germany? I havenīt...Iīd guess JAROPS 2 or however it will be called then will change that. Maybe. Or not.
Correct me if Iīm wrong, but they were just about to begin their second leg, werenīt they? So they just had done some 5,5-6 hrs of flying...or maybe 8 hrs of duty IF they came from EDDF to pick the pax up. Hardly over the FDR. The second leg would have been, granted.