20. 12. 85 Official Journal of the European Communities No C 330/5 
trade. These measures benefit the Community's exter­
nal trade directly and indirectly. The possibilities of 
coordinating and improving these measures in the Com­
munity interest can of course be purposefully pursued. 5.7. A precondition for this is perceptible progress 
in the harmonization of motor vehicle and mineral oil 
taxes, provisions on working hours and driving hours 
including checks, and weights and measures, and in 
measures to facilitate customs clearance. 
Done at Brussels. 30 October 1985. 
The Chairman 
of the Economic and Social Committee 
Gerd MUHR 
Opinion on the proposal for a Council Directive amending Directive 76/130/EEC on the 
establishment of common rules for certain types of combined transport of goods between 
Member States (j) 
(85/C 330/02) 
On 14 June 1985 the Council decided to consult the Economic and Social Committee, 
under Article 75 to the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Committee instructed its Section for Transport and Communications to prepare its work 
on the matter. The Section adopted its opinion on 9 October 1985 on the basis of the report 
made by the rapporteur, Mr Querleux. 
At its 230th plenary session (meeting of 30 October 1985) the Economic and Social Committee 
adopted the following opinion unanimously: 
1. Preliminary remark 
The draft Directive concerns four distinct issues: 
— expanding the scope of Community rules for inland-
waterway combined transport, the present rules 
applying only to the transport or containers of 20 
feet or more, 
— the extension (from a radius of 50 km to one of 
150 km) of the liberalization zone around inland 
waterway ports for initial or final road sections of 
combined inland-waterway transport operations, 
— the facilitation of final road-haulage operations in 
own-account combined transport, 
— the exemption of the initial and final road haulage 
journeys of combined transport operations from the 
bans on movement on certain days and at certain 
periods applicable to conventional road transport., As these four issues are distinct, the Committee will 
give separate opinions on each of them in the following 
paragraphs. 
(') OJ NoC 139,7. 6. 1985, p. 2. 
(2) OJ No 310, 30. 11. 1981, point 1.1.5. 2. Expanding the scope of Community rules for 
inland-waterway combined transport 
2.1. The Committee welcomes the proposed exten­
sion of the scope of the rules on 'combined transport 
by inland-waterway', so that these cover not only con­
tainers of 20 feet or more but also lorries, semi-trailers 
(with or without tractor), trailers and swap bodies. The 
current restriction to large containers is impeding the 
development of combined transport by inland water 
for reasons which are incomprehensible from both a 
technical and economic point of view. In its unani­
mously adopted opinion dated 23 September 1981 (2) 
No C 330/6 Official Journal of the European Communities 20. 12. 85 
the Committee urged the Commission to consider such 
an extension as a matter of urgency. 
2.2. The Committee thinks that once this measure 
has entered into force, a close eye will have to be kept 
on how it fares: 
— from a technical angle (capacity of transhipment 
facilities, reliability of road and waterway traffic, 
security of persons and goods), 
— from an economic angle (scale of switch in traffic 
to combined transport, profitability of investments, 
trends in transport rates), 
— from a social angle (possible effects on haulage 
personnel and number of jobs), 
— from an environmental angle. 
3. Extension of the liberalization zone around inland 
waterway ports for initial and final road sections 
of combined inland waterway transport operations 
3.1. The Commission proposes that the radius of the 
liberalization zone (the zone in which initial and final 
road sections of combined transport operations by 
inland-waterway are exempted from all quotas and 
prior authorization arrangements) be increased from 50 
km to 150 km. The Commission is of the opinion that 
the enlarged zone would enable this form of combined 
transport to be managed on an optimum economic 
basis. 
3.2. The Committee readily agrees that combined 
transport by inland-waterway has, in a number of spec­
ific cases, proved to be very satisfactory as regards 
deadlines, reliability and regularity. This form of trans­
port provides a range of well-differentiated services, 
has a low energy input and is economically competitive. 
3.3. However, as the Commission acknowledges in 
its explanatory memorandum, the recession has led to 
transport overcapacity at a time when conditions of 
competition are very difficult. The measure providing 
for a 50 km liberalization zone was adopted just three 
years ago (Directive 82/603/EEC of 28 July 1982). The 
Committee considers that the liberalization of a vastly 
increased area (150 km zone) could seriously disrupt 
the development of the transport market from both an 
economic and social point of view. A less drastic change would be preferable with the liberalization zone being 
set at a radius of 100 km for a new period of several 
years. 
4. Facilitation of the final road-haulage operations in 
own-account combined transport 
4.1. The Commission proposes that the own-account 
transport regime be extended to cover combined trans­
port in which one of the two final haulage operations 
is carried out by a tractor belonging to a firm sending or 
receiving goods in an own-account transport operation. 
4.2. The Commission has already put forward such 
a proposal in 1980. In its unanimously adopted opinion 
dated 23 September 1981 (!), the Committee urged that 
final road haulage operations in combined transport 
be carried out without affecting the legal distinction 
between transport on own account and transport for 
hire or reward. This request was based in particular on 
the observation that the bulk of long distance road 
transport (the only form of transport from which an 
increase in combined transport could be derived) was 
carried out by professional hauliers and the view that 
the proposed relaxation of the provisions could lead 
to the transfer of long-distance freight from railway 
companies or professional road hauliers to 'own-
account combined transport', which benefited from the 
various specific advantages of own-account transport. 
4.3. The Committee remains of the opinion that 
however much the Commission may wish to see an 
extension of combined transport, such an extension 
must not be brought about by making fundamental 
changes to the definition of own-account transport at 
the expense of professional hauliers. The Committee 
therefore suggests that the Commission proposal be 
confined to cases where the initial and final stages by 
road are carried out (a) by tractors operated by one 
firm and personnel working for one firm or (b) by two 
firms belonging to the same economic entity (i.e. the 
majority of the authorized capital is held by the same 
natural or legal person). 
5. Exemption of the initial and final road haulage 
journeys of combined transport operations from the 
bans on movement (on certain days and at certain 
periods) applicable to conventional road transport 
5.1. The Committee would point out that in actual 
fact the very large majority of dispatch and reception 
departments of firms are closed on Saturdays, Sundays 
and public holidays, i.e. the days on which conventional 
(') OJ No C 310, 30. 11. 1981, points 1.1.3, 1.1.4 and 1.2.4. 
20. 12. 85 Official Journal of the European Communities No C 330/7 
road transport may be banned. The Committee is there­
fore of the opinion that these driving bans are of little 
practical significance. 
5.2. The Committee recognizes, however, that unco­
ordinated national bans on driving on certain days are 
detrimental to the optimum organization of inter­
national goods transport, and it would welcome Com­
munity action to avoid these adverse effects as far as 
possible. 
5.3. The Committee thinks, with regard to combined 
transport, that 
— given the reasons for the bans, there is no difference 
1. At is has already declared on several occasions, 
the Committee wholeheartedly supports measures to 
improve maritime safety and to prevent marine and 
coastal pollution. It therefore approves the present pro­
posal for extending the deadline for the completion of 
the COST 301 research programme and providing it 
with extra money in furtherance of the aforementioned 
objective. The Committee would also recall that in its between the road haulage legs of combined trans­
port operations and other road haulage journeys, 
— the costs of combined transport operators could be 
adversely affected and there might also be unfore­
seen social consequences, 
— the exceptions made for combined transport could 
lead to an increase in the number of days on which 
driving is banned; this could have unforeseen 
adverse effects on those forms of road haulage 
which are not suitable for combined transport work. 
5.4. The Committee therefore rejects this Com­
mission proposal. 
opinion of 25 November 1981 (2) it came out unani­
mously in favour of the implementation of the COST 
301 programme. 
2. At the same time, however, the Committee would 
reiterate the reservations expressed by it in 1981, when 
it considered that the work carried out under the Done at Brussels, 30 October 1985. 
The Chairman 
of the Economic and Social Committee 
Gerd MUHR 
Opinion on the proposal for a Council Decision amending Decision 82/887/EEC adopting a 
concerted action project for the European Economic Community in the field of shore-based 
marine navigation aid systems^) 
(85/C 330/03) 
On 24 July 1985 the Council decided to consult the Economic and Social Committee, 
under Article 198 of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Transport and Communications, which was responsible for preparing the 
Committee's work on the subject, adopted its opinion on 9 October 1985, in the light of the 
oral report by Mr Bonety. 
At its 230th plenary session (meeting of 30 October 1985) the Economic and Social Committee 
adopted the following opinion unanimously: 
(') OJ No C 182, 20. 7. 8.5, p. 7. (2) OJ No C 348, 31. 12. 1981, p. 24.