21 November 2022

CLECAT Position Paper on EU Slots Regulation

CLECAT, the European association for forwarding, transport, logistics and customs services, is the leading voice on freight forwarding and logistics at the EU level in Brussels. We represent and are supported by 24 member organisations, working to promote a sound approach to transport and logistics across Europe, in support of the competitiveness of our industry.

Freight forwarders represent a vital link between exporters/importers of goods and transport operators, such as air carriers. They have a keen interest in a modern, innovative air freight sector which guarantees choice, quality, connectivity, transparency and fair competition. 

Freight forwarders are reliant on a fair and adequate slot allocation regime for full freighter aircrafts, to ensure its customers, shippers, are being served with timely and good quality service levels, which can be expected from air freight, which represents an economically strategic transportation service for the European economy.


  • Recognising the importance of an appropriate slot allocation mechanism, as well as the drastic changes brought by the COVID-19 crisis, CLECAT considers Commission’s initiative to review the EU Slots Regulation is now timely and urgent, as the current framework for the allocation of slots at EU airports, dating back to 1993, is inadequate to address the continuously increasing congestion at EU Airports and does not effectively address the needs of the air cargo sector.

  • The EU Slot Regulation does not provide the much-needed flexibility to air freight. The reason for this is that the 80/20 “use it or lose it” rule is difficult to achieve for full freighters since passenger and cargo operate in a very different way.  The European society cannot rely on the limited freight capacity in the belly of passenger aircraft only.

  • CLECAT calls on the Commission to recognise the different needs of air freight by leaving a certain flexibility to Member States to legitimately and proportionately prioritise certain traffic segments in the determination and allocation of capacity on an objective, unambiguous and transparent manner. Air cargo is much more demand-driven than the supplier-driven passenger markets, it is imperative that air cargo needs a separate part of the capacity in order to be able to effectively respond to fast changing market situations. In particular, a dedicated number of slots for full freighter aircraft is needed at intercontinental hub airports, which connect Europe most efficiently to many regions around the globe.

  • CLECAT is of the view that a revised EU Slot Regulation should ensure a system of fair, non-discriminatory and transparent rules for the allocation of landing and take-off slots to allow optimal utilisation and fair competition. Where the demand of landing and take-off slots exceeds the airport capacity, a mechanism to allocate slots is needed. To this extent CLECAT embraces market-based mechanisms for the trading of slots between airlines, as well as the introduction of local guidelines.

  • CLECAT also calls for the extension of the ‘use it or lose it rule’, according to which currently 80% of the slots have to be used by an airline in order to keep their respective slots. An increase or the total implementation of this rule would even further increase airport capacities, whilst allowing more airlines to enter the market. This would again foster competition, ensure maximum flexibility and reduce prices.

  • The rules for New Entrants should be amended to allow for more competition.

The full position paper can be found below.