tachograph:
I still think analysis software would probably also count it as the break though, but I could be wrong 
Youâre not. I regularly (and I mean a lot) do 13+ hour shifts with only one juicy break in the middle and I never get an infringement for it.
tachograph:
edit:Technically I suppose youâre right the 3 hours rest is not part of the total breaks it part of the daily rest period, I still think analysis software would probably also count it as the break though, but I could be wrong 
I have 3 different analysis packages and they all count the 3 hour rest as break. The software just sees the bed symbol and thatâs all it knows. And of course the 3 hours is interrupting work as far as the software sees it so it meets the requirement.