CLECAT Position Paper on the Revision of the Combined Transport Directive
CLECAT has adopted its position paper on the revision of the 1992 Combined Transport Directive.
CLECAT has long supported a revision of Directive 92/106/EEC, which is outdated, ambiguous and creates barriers to the effective operation of combined transport. The review is an opportunity to make the legislative preconditions realistic, transparent and up to date. Overall the Directive should be lighter, simpler and less costly to implement.
The Directive currently discourages some combined transport operations by imposing an arbitrary limit on the road leg. The proposed revision goes some way to overcoming these failings of the current Directive, which is welcome, but would also require improvement in places.
- CLECAT welcomes the extension of the scope of application of ‘combined transport’ to all operations in the Union, and all modes of transport. The provisions on operations with an element outside the Union need to be drafted with greater clarity.
- CLECAT welcomes removal of the specification of “nearest suitable terminal” and the flexibility offered in determining the length of the road leg (150km/20% of total distance, whichever is longest), as well as the removal of the restriction of the minimum length of 100km as the crow flies on the non-road leg.
- While the possibility to extend the road leg in order to reach the nearest terminal with appropriate facilities is a good innovation, this must be applied to all CT operations and not just road/rail. Furthermore, the proposal lacks clarity and certainty as to how such authorisations will be granted and on what basis.
- The authorisation of heavier loads for vehicles used in intermodal transport road legs is appropriate, but Member States should also allow an exemption for EMS vehicles.
- We support the continued inclusion of the cabotage exemption (Article 4).
- For reporting purposes, CLECAT supports the introduction of a system based on electronic documents, which could replace the outdated paper document and stamp system. The proposal makes good steps in this direction, but nonetheless opens the door to continued use of stamps and signatures, and must concentrate on the electronic provision of data, rather than documentation.
- It is vital that the measures to provide financial support for terminal investment are subject to proper ex-ante scrutiny, and coordination in order to avoid possible overlapping investment between Member States in close proximity.
The position paper may be found via the below link.