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CLECAT has published its position paper in response to the Proposal for a Regulation establishing a framework of measures to facilitate the transport of military equipment, goods and personnel across the Union. The proposal is important to ensure fast and seamless military movements across Europe and is an important step in strengthening Europe’s defense preparedness in a rapidly changing security environment. 

CLECAT welcomes core elements of the proposal such as the introduction of harmonised cross-border permission procedures and standardised templates. The establishment of the Military Mobility Enhanced Response System (EMERS) provides a structured framework for rapid decision-making in emergency situations, including targeted derogations from certain transport rules where strictly necessary.  The proposal’s focus on identifying and upgrading strategic dual-use infrastructure is equally important. Strengthening corridors, bridges, tunnels, terminals and multimodal interfaces will benefit both military and civilian transport flows. Sustained and coordinated investment, notably under the Connecting Europe Facility (CEF), will be crucial to avoid fragmented readiness across Member States.  CLECAT also supports the creation of a Military Mobility Transport Group and the appointment of National Coordinators for Cross-Border Military Transport. However, for these structures to function effectively, they must include structured and continuous involvement of the civilian transport and logistics sector.

Despite these positive steps, CLECAT identifies several important issues that require clarification.  The proposal assigns priority to military movements under certain conditions, yet it should be clarified that the transport of military goods (EU Common Military List as well as US munitions list) when carried out by civil companies falls within the scope of this regulation. The proposal focuses primarily on military movement, not export control policy, while related cumbersome cross-border processes continue to hinder swift and harmonised movement permissions across Member States.

Also, the activation of emergency mechanisms under EMERS must be linked to clear crisis definitions and transparent escalation levels. Companies operating across borders need predictable thresholds and real-time information to understand when exceptional rules apply and how they interact with normal transport legislation.

While the proposal foresees priority access for military movements and exemptions from certain operational restrictions, it must also safeguard essential civilian supply chains. Freight forwarders coordinate critical flows, including energy, food, medical goods and industrial inputs, that cannot simply be displaced without broader economic consequences.

Finally, the Solidarity Pool mechanism and the possibility of temporary use of civilian assets raise complex questions regarding liability, war-risk insurance, driver protection and compensation. CLECAT stresses that voluntary participation, clear liability frameworks and adequate financial safeguards must be the foundation of any mobilisation of private-sector capabilities.

CLECAT’s position emphasises that military mobility must be embedded within a broader “whole-of-society” approach. Europe’s defense readiness cannot be built on emergency intervention powers alone. It depends above all on structured cooperation, advance planning and mutual trust between defence authorities, civil administrations and the logistics industry.