Opinion of the Economic and Social Committee on the 'Draft Council Regulation (EC) on statistical returns in respect of carriage of goods by road` () (98/C 95/09)

On 2 October 1997 the Council of the European Union decided to consult the Economic and Social Committee, under Article 198 of the Treaty establishing the European Community, on the above-mentioned draft regulation.

The Section for Transport and Communications, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 16 December 1997. The rapporteur was Mr de Norre.

At its 351st plenary session (meeting of 28 January 1998), the Committee adopted the following opinion by 82 votes to two.

1. Content and scope of the draft

1.1. This draft regulation is the culmination of six years of discussions within the European Commission and Eurostat (task force set up at the suggestion of the Coordinating Committee on Transport Statistics) and consultations with certain relevant professional organizations.

1.2. According to the Commission, the draft should contribute towards the production of harmonized statistics at EU level on the carriage of goods by road 'and ensure the availability of information necessary for the framing, monitoring, controlling and evaluation of the common policy` in the field of transport.

1.3.1. For this purpose, the draft obliges Member States' statistical offices to supply Eurostat with the results of statistical surveys by specified deadlines. These surveys will cover firms operating commercial vehicles with a maximum permissible laden weight of at least 6 tonnes and a payload of at least 3,5 tonnes, since smaller vehicles 'are not crucial to the common transport policy.`

1.3.2. This draft therefore involves national offices liaising with Eurostat.

1.3.3. Nevertheless, the obligations which it imposes will also have an effect on the content of the statistical information which the firms in question are required to supply.

1.3.4. This being so, the Commission is anxious not to impose an additional administrative burden on these firms.

1.4.1. It also states at various points in the draft that the directives in force which govern statistical information about the transport operations in question [78/546/EEC (), as amended by 89/462/EEC ()] do not permit the collection of information required for the quantification of certain activities, in particular:

- the rates of utilization of the vehicles performing the transport operations, and

- domestic transport operations performed by non-residents (cabotage), which were not authorized at the time of these directives' entry into force but which will be completely liberalized as of 1 July 1998,

and supply different information for domestic and international transport.

1.4.2. The Commission also stresses the need for reliable information on:

- transport operations between member states and third countries,

- interregional transport operations within the EU,

- the journeys made by the vehicles performing these transport operations,

- the types of vehicle used for these transport operations,

- the nature and type of risk resulting from the transport of products subject to the Agreement concerning the international carriage of dangerous goods by road (ADR).

2. General considerations

2.1.1. Economic operators, scientific bodies and public authorities constantly need reliable statistical information, comparable over time and space, which enable trends in transport and goods movements to be gauged.

2.1.2. To answer this need, it is necessary to take account of:

- the international dimension of the relevant markets, which are no longer broken up into separate national markets;

- the need to limit the administrative workload and cost involved in collecting and processing the data, by aiming for an optimum cost-benefit ratio.

2.1.3. It is also vital to:

- quantify the transport operations performed within the EU's territory by vehicles registered in third countries; this will involve the exchange of data between Member States on the transport operations performed by vehicles passing through their territory in transit. The Committee therefore thinks provisions regulating the exchange of data between statistical offices must be adopted on the basis of Council Regulation (EC) No 322/97 ();

- use in connection with the processing of statistics - apart from the tonne-kilometre - other parameters for appraising the space taken up by consignments, the compactness of loads and their value.

2.1.4. The Committee approves the Commission's decision to replace the existing directives with a regulation which will be directly applicable in all Member States and which will therefore not permit any divergences in interpretation.

2.2.1. The European Commission seems above all to be anxious to set up statistical machinery in support of the common transport policy which should help to observe the markets, traffic flows and level of activity in the transport-for-hire-or-reward sector. The Committee welcomes the Commission's decision to create within Eurostat a unit specializing in the processing of transport statistics.

2.2.2. The Committee thinks that it should be possible to make use as soon as possible of the statistics collected. Therefore the 5- and 8-month deadlines indicated in Article 7(3) should be the maximum deadlines, bearing in mind the technology available.

2.2.3. In the Committee's opinion, the approach chosen must also tally more and more with the trend towards intermodality and the integrated logistical management of goods movements. This trend requires a 'functional` approach to transport activity, in support of trade in a global economy.

A distinction should also be made between road transport for hire or reward and own-account road transport, especially in vehicle registration records.

3. Specific comments

3.1. With regard to the decision in Article 1 to compile Community statistics on motor vehicles, the Committee would refer to its comment 2.1.1 in its opinion on the amendment to Directive 78/546/EEC (), viz. that this decision could have the serious drawback of not taking the whole of a multimodal transport operation into account when the traction unit does not accompany the trailer unit on the non-road leg of a journey.

3.2. Article 2 and Annex A1 give definitions for statistical purposes of various technical terms and types of vehicles used in applying the regulation. The Committee would ask that care be taken to align these definitions on the ones already applied, especially in the directives harmonizing vehicle weights and dimensions.

3.3. Article 2(2) lays down derogations which may or must be applied to certain categories of vehicles, according to their technical characteristics or use.

3.3.1. As regards vehicles whose permitted weights or dimensions exceed the 'normal permitted limits`, in other words special convoys, the Committee would note that these transport operations are of considerable value for the EU economy in terms of trade.

3.3.1.1. Their exclusion would therefore be regrettable, insofar as it is necessary to assess and pinpoint the trend in demand in this area, which is rather misconstrued by the authorities and public opinion. This trend will determine the need to adjust routes.

3.3.2. There is also no reason to exclude vehicles used by 'public services`. The transport operations performed by these vehicles are part of the general economic activity of EU Member States. They are responsible for goods movements which may be in competition with transport operations covered by the draft regulation.

3.3.3. On the other hand, the Committee approves the option to exclude vehicles with a payload of less than 3,5 tonnes or a maximum permissible laden weight of less than 6 tonnes.

3.3.3.1. However, there are grounds for asking whether the maximum permissible laden weight should not be 3,5 tonnes, in keeping with the limit chosen by the Council of Transport Ministers on 9 October 1997 in the common position on the new directive on admission to the occupation of road transport operator () and the limit applicable to class C driving licences. This choice should be based on a cost/benefit analysis, bearing in mind the extra administrative workload for the firms in question.

3.4. Article 10 of the regulation makes provision for a financial contribution from the Community towards Member States' costs. The Economic and Social Committee would query whether the Community budget ought to bear Member States' administrative costs.

3.5. The Committee would like the relevant socio-economic interest groups in each Member State to be closely involved in the consultations on how to implement the regulation.

4. Conclusions

In the light of the above comments, the Committee would recommend that:

- the objective of the regulation should be to improve the reliability in time and space of the data collected and their comparability with the data for other transport modes;

- attempts to achieve this objective should be based on a 'functional` intermodal approach to goods transport;

- socio-economic interests in the Member States should be consulted on how to implement the regulation;

- the data which road haulage firms are asked to provide should be limited to the data which are necessary and apposite for attaining the objective set, namely to ensure the availability of information necessary for the framing, monitoring, controlling and evaluation of the common transport policy.

Brussels, 28 January 1998.

The President of the Economic and Social Committee

Tom JENKINS

() OJ C 341, 11.11.1997, p. 9.

() Council Directive of 12 June 1978 on statistical returns in respect of carriage of goods by road, as part of regional statistics (OJ L 168, 26.6.1978, p. 29); ESC opinion: OJ C 181, 31.7.1978, p. 27.

() Council Directive of 18 July 1989 amending Directive 78/546/EEC on statistical returns in respect of carriage of goods by road, as part of regional statistics (OJ L 226, 3.8.1989, p. 8).

() Council Regulation (EC) No 322/97 of 17 February 1997 on Community statistics (OJ L 52, 22.2.1997, p. 1).

() ESC opinion: OJ C 134, 24.5.1988, p. 7.

() ESC opinion: OJ C 287, 22.9.1997, p. 21.