16 February 2024

CLECAT PUBLISHES POSITION ON REVISED COMBINED TRANSPORT DIRECTIVE

On 13 February, CLECAT published its position paper on the Commission’s proposal for amendments to the Combined Transport Directive 92/106/EEC. CLECAT and its members welcomed the proposal amending Directive 92/106/EEC on the establishment of common rules for certain types of combined transport of goods between Member States as the current rules are outdated, ambiguous and create barriers to the effective operation of combined transport. The ambition of the European Commission to remedy the legal ambiguities of the existing Directive and to increase the share of intermodal transport that qualifies as combined transport is supported.

The objective of the Commission’s initiative is to refocus the support framework of the current Directive and to increase the competitiveness of intermodal transport compared to long-distance road transport to stimulate the shift from road freight to other modes of transport to reduce external costs.

Whereas CLECAT welcomes a new definition of combined transport operations to ensure a common understanding and application across the EU, leaving no room for interpretation, we consider that the new definition remains far too complex. There are a lot of unanswered questions on how the 40% external cost reduction as the minimum to be eligible for support compared to road operations is calculated. Also, while acknowledging the positive aspect of using eFTI platforms to digitally record and publish specific transport information, their functionality remains unclear due to their current unavailability. CLECAT argues that the use of eFTI platforms should remain voluntary until they have matured. Making the use of eFTI platforms mandatory could delay the much-needed uptake of combined transport operations.

On a positive note, CLECAT supports the extension of the scope to include all intermodal operations within and between Member States. The inclusion of empty containers is also welcomed but we propose an important amendment to make operations more efficient. CLECAT furthermore supports the retention of the current cabotage exemption (Article 4), as it serves as a crucial non-financial incentive for the promotion of combined transport.

The full position paper can be accessed via this link.