09 November 2023

CLECAT welcomes Commission’s proposal to revise Combined Transport Directive

The European freight forwarders association, CLECAT, welcomes the European Commission’s new proposal on a revised combined transport Directive which was finally released on 7 November. Reacting to the proposal Ms van der Jagt, Director General of CLECAT said: ‘Achieving Europe’s modal shift ambitions will only be realistic if the right framework conditions are put in place. While we still need to review the proposal in further detail, it looks like the proposal is a good starting point to encourage the use of Combined Transport. This is vital for the shift of long-distance traffic from road to rail, inland waterways and maritime transport. Intermodal freight transport reduces greenhouse gas (GHG) emissions and is therefore an important mean to further decarbonise freight transport and to enable its modal optimisation.‘

CLECAT notes that the proposal includes some important elements its members have been calling for, including:

  • Clarification of the definition of an intermodal transport operation, clearly stating that road transport can be used in both the first and last leg, and removing the concept of nearest suitable loading/unloading station. The current definition is outdated and creates barriers to the effective operation of Combined Transport. 
  • Extending the scope of the Directive to all intermodal operations in the EU, thus encompassing both cross-border and national transport operations, which is welcomed by CLECAT. 
  • Empty containers used for an intermodal transport operation, which are covered by the transport contract of the CT operation, are considered an integral part of said operation, thus benefiting from support measures. CLECAT welcomes the clarification, which reflects the recent ECJ ruling.
  • CLECAT is also pleased that the Commission leaves article 4 untouched as we called for maintaining the currently applicable exemption from cabotage rules for the road legs of Combined Transport operations.
  • The proposal includes a set of new support measures for Combined Transport. Considering the increased cost of intermodal transport operations compared to monomodal road-freight transport, providing the right incentives, including financial incentives, will be a key factor. Furthermore, the non-financial measures, such as the introduction of an EU-wide exemption from temporary driving bans for the short road legs of combined transport, ensuring better use of terminal and non-road infrastructure capacity are welcomed. 

The Commission mandates Member States to draw up national policy frameworks to assess measures in support of combined transport operations in their territory and aim for a 10% cost reduction of such operations within 7.5 years which is interesting, but possibly not sufficiently ambitious.

Finally, we note the requirement for organisers of Combined Transport operations to record and publish specific transport information on an eFTI platform before the start of the Combined Transport operation concerned. This may be a good solution, but eFTI platforms will take time to come to market and to mature and are not mandatory for economic operators. With this in mind, and the extended time which will be needed to come to an agreement on the proposal in view of the European elections, economic operators will need to be patient to reap the benefits of the initiative.

For more information, please contact:

Nicolette van der Jagt
Director General CLECAT
+ 32 497484570