Opinion of the Economic and Social Committee on the 'Draft Council Regulation (EC) on statistical returns in respect of carriage of goods by road'
Date: 1998-01-28
Institutions: European Economic and Social Committee
Subjects: EU statistics, carriage of goods, data collection, road transport, statistical nomenclature

30.3.98

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Official Journal of the European Communities

C 95/33

Opinion of the Economic and Social Committee on the ‘Draft Council Regulation (EC) on
statistical returns in respect of carriage of goods by road’ (1)

(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 organ-
izations.

According to the Commission, the draft should
1.2.
contribute towards the production of harmonized stat-
istics 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.
liaising with Eurostat.

This draft therefore involves national offices

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.
the directives

It also states at various points in the draft that
in force which govern statistical

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

information about the transport operations in question
[78/546/EEC (2), as amended by 89/462/EEC (3)] 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.
reliable information on:

The Commission also stresses the need for

— 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 oper-

ations,

— 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) 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.

(3) Council Directive of 18 July 1989 amending Direc-
tive 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).

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Official Journal of the European Communities

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2. General considerations

Article 7(3) should be the maximum deadlines, bearing
in mind the technology available.

2.1.1.
Economic operators, scientific bodies and pub-
lic authorities constantly need reliable statistical infor-
mation, comparable over time and space, which enable
trends in transport and goods movements to be gauged.

2.1.2.
account of:

To answer this need, it is necessary to take

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.

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

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

— 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 pro-
visions regulating the exchange of data between
statistical offices must be adopted on the basis of
Council Regulation (EC) No 322/97 (1);

— 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.

The Committee approves the Commission’s
2.1.4.
decision to replace the existing directives with a regu-
lation which will be directly applicable in all Member
States and which will therefore not permit any diver-
gences 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

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 (2), 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 regret-
table, 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.

(1) Council Regulation (EC) No 322/97 of 17 February 1997

on Community statistics (OJ L 52, 22.2.1997, p. 1).

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

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C 95/35

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.

there are grounds for asking
3.3.3.1. However,
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 oper-
ator (1) 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 Com-

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

Brussels, 28 January 1998.

mittee would query whether the Community budget
ought to bear Member States’ administrative costs.

The Committee would like the relevant socio-
3.5.
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
intermodal approach to goods

on a ‘functional’
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.

The President

of the Economic and Social Committee

Tom JENKINS