2000/410/EC: Commission Decision of 22 December 1999 on the aid scheme which France is planning to implement in favour of the French port sector (notified under document number C(1999) 5204) (Text with EEA relevance) (Only the French text is authentic)
Date: 1999-12-22
Institutions: European Commission
Subjects: France, aid for restructuring, handling, harbour installation, industrial restructuring

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COMMISSION

COMMISSION DECISION

of 22 December 1999

on the aid scheme which France is planning to implement in favour of the French port sector

(notified under document number C(1999) 5204)

(Only the French text is authentic)

(Text with EEA relevance)

(2000/410/EC)

THE COMMISSION OF THE EUROPEAN COMMUNITIES,

(4)

Having regard to the Treaty establishing the European
Community, and in particular the first subparagraph of Article
88(2) thereof,

Having regard to the Agreement on the European Economic
Area, and in particular Article 62(1)(a) thereof,

Having called on interested parties to submit their comments
pursuant to the provision(s) cited above (1), and having regard
to their comments,

(5)

Whereas:

(1)

(2)

(3)

I. PROCEDURE

By letter dated 25 May 1998, France notified the
Commission of the aid scheme in favour of the French
port sector. It furnished the Commission with supple-
mentary information by letters dated 31 July 1998, 6
November 1998, 27 November 1998, 26 January 1999,
16 February 1999 and 20 April 1999.

By letter dated 14 June 1999, the Commission informed
France of its decision to initiate the procedure laid down
in Article 88(2) of the EC Treaty in respect of this aid
scheme.

(6)

The Commission decision to initiate the procedure was
published in the Official Journal of the European Communi-
ties (2). The Commission called on interested parties to
submit their comments.

(1) OJ C 233, 14.8.1999, p. 25.
(2) See footnote 1.

The Commission has received comments from interested
parties. It has transmitted them to France, which has had
the opportunity to react. Its comments were received by
letter dated 13 October 1999.

II. DETAILED DESCRIPTION OF THE AID

The French port sector can at present be characterised
by substantial public involvement in the financing and
management particularly of the heavy port equipment,
such as gantry cranes (hereinafter
‘the equipment’),
which is operated partly by personnel employed in the
public sector. The aim of the proposed aid scheme is to
render the provision of cargo handling services more
efficient by completing the restructuring process started
through a reform whereby cargo handling
in 1992,
companies will become fully responsible for the provi-
sion of these services in the ports concerned. The means
to do so is by modernising and rationalising the organ-
isation of these services, and to this end the notified
scheme proposes a reduction of the tax base for the
French ‘taxe professionnelle’
the private cargo
handling companies.

for

As notified by France, the proposed tax reduction would
affect 23 French ports (see Annex to the present
Decision), where currently some 99 private cargo
handling (stevedoring) companies operate. The vast
these companies are SMEs. The French
majority of
authorities also expressed their wish that the proposed
scheme would attract foreign investments from non-
French companies that may be interested in establishing
themselves in these ports. The equipment is currently
owned and financed by the public (port) authorities that

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are not subject to the ‘taxe professionnelle’. The equip-
ment is usually rented to the private cargo handling
companies that carry out the loading and unloading of
cargo in the ports.

(10)

the port equipment, which is at present primarily owned
by the public.

The proposed tax reduction is
linked to the new
purchase value for equipment. For the port equipment
concerned, the investment volume to be made over the
period 2000 to 2004, amounts to FRF 2,800 million, of
which FRF 2,100 million is destined for the replacement
of existing equipment by more performant equipment,
and FRF 700 million for the acquisition of new, addi-
tional cargo-handling equipment
in the ports of Le
Havre and Dunkerque. The total amount of tax reduc-
tion to be granted through the scheme is set, following
the submissions made by the French authorities in their
letter of 20 July 1999, at FRF 368,35 million, and will
be disbursed during the period 2000 to 2006. In refer-
ence to the investment value, the French authorities
conclude that the aid intensity of the scheme, expressed
as a percentage of the first,

is 13,15 %.

III. COMMENTS FROM INTERESTED PARTIES

(11)

expressed agreement

By letter of 14 September 1999, the Government of the
United Kingdom submitted its comments, which in
essence
to the Commission's
decision to open the formal investigation procedure in
this case. The concern of the United Kingdom relates to
the proposed aid for the purchase of new, additional
equipment in Le Havre and Dunkerque, as this would
create excessive capacity that would distort competition
with other European ports.

IV. COMMENTS FROM FRANCE

(12)

The Commission had forwarded the comments of the
Government of the United Kingdom to France by letter
of 22 September 1999, and by letter of 13 October
1999, the French authorities replied thereupon.

V. ASSESSMENT OF THE AID SCHEME

1. Legal base

threatens

(13) Under Article 87(1) of the Treaty ‘any aid granted by a
Member State or through State resources in any form
whatsoever which distorts or
to distort
competition by favouring certain undertakings or the
production of certain goods shall, in so far as it affects
trade between Member States, be incompatible with the
common market’. As had been stated in the decision to
initiate the procedure, the notified aid scheme is to be
considered State aid under Article 87(1) of the Treaty, as
the scheme is financed through State resources, is attri-
butable to the State budget and is selective in its applica-
tion.

(7)

(8)

(9)

The ‘taxe professionnelle’ is a local tax payable to and
fixed by the local authorities (thus the level of the tax
may vary between different regions). The tax base is
calculated on the basis of three factors, (i) the rental
value of property (immeubles),
(ii) 16 % of the new
purchase value for equipment (valeur d'achat à neuf),
and (iii) 18 % of the gross salaries. The proposed scheme
for cargo handling companies would only concern (ii),
i.e. the purchase of equipment, in that this factor would
be excluded from the taxation base for the private cargo
handling companies. The proposed scheme envisages a
tax reduction on the one hand for the transfer and
replacement of existing equipment, and on the other
hand, for the acquisition of additional, new equipment
in the ports of Le Havre and Dunkerque.

for

The proposed scheme takes place in the context of the
reform started in 1992 whereby the dock workers, who
used to be employed by the public sector, became
employees of the private cargo handling companies. To
this avail, a social plan had been elaborated at that time.
Since the introduction of this reform, the number of
dock workers in French ports has decreased by 50 %.
According to the French authorities, the cargo handling
companies have also contributed with over 1 000
million French francs (FRF) to the financing of ‘social
plans’
the dock workers, while approximately
FRF 5 000 million still remains to be paid until year
2006. To complete this process concerning the work-
the scheme currently under examination also
force,
entails
the
the
remaining personnel, notably the crane-operators (grut-
iers)
from the
public to the private companies. The objective is for the
private cargo handling companies to take over full
and the human
responsibility for
resources needed for cargo handling operations
in
French ports.

involved in cargo handling activities,

responsibility for

transfer of

equipment

the

the

According to the French authorities, the reduction of the
burden of the ‘taxe professionnelle’
is an incentive to
progressively transfer the ownership and management of
the existing equipment from public to private, and to
encourage investments in renewing this equipment. The
transfer to individual cargo handling companies would
be carried out against payment, covering at least the net
book value (valeur net comptable), and through public
tender procedures. The tax reduction is thus linked to
the cargo handling companies' willingness to invest in

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(14) While the proposed scheme concerns a specific sector,
the public support would only benefit
those cargo
handling companies that are located in the 23 selected
ports and who take over the responsibility for the
existing equipment and its renewal. This selectivity is not
justified by ‘the nature or general scheme of the system’,
and the French authorities have not provided any
evidence that this would be the case. (See paragraphs 12
and 23 of Commission notice on the application of the
State aid rules to measures relating to direct business
taxation (1)).

the Treaty, the aid does not appear to be eligible under
the exemptions under Article 87(3)(a) and (b). Nor does
the proposed scheme aim to facilitate the development
of certain economic areas as set out in subparagraph (c),
but concerns rather a particular sector. However, the
exemption under Article 87(3)(c) concerning ‘aid to
facilitate the development of certain economic activities,
where such aid does not adversely affect trading condi-
tions to an extent contrary to the common interest...’
may be applicable in this case.

(15)

(16)

Finally, in the cargo handling sector, companies compete
with other cargo handling companies within the same
port and in other ports for trade. Depending on the final
destination of the cargo, there is often a choice between
different ports for loading and unloading. In this partic-
ular case, as the cargo handling companies in the 23
ports concerned are in many cases actually or potentially
competing for traffic with cargo handling undertakings
in other French and Community ports, there may be an
effect on trade between Member States.

The French authorities also argued that the ‘taxe profes-
sionnelle’ exists only in France and that the aid is needed
to compensate French cargo handling companies from
the disadvantage of such a tax compared with their
European counterparts. However, even if the scheme in
question would bring the costs of the cargo handling
companies concerned closer to those of its competitors
in the other Member States, which has not been demon-
strated, it does not change the fact that the financing has
the character of aid.

2. Compatibility

(17) As to the compatibility of

the State aid with the
common market, aid is prohibited unless it can benefit
from any of the specific exemptions laid down in the
Treaty. In this particular case, the aid does not appear to
be eligible for any of
the exemptions laid down in
Article 87(2) of the Treaty. Article 86 of the Treaty is
not applicable either as cargo handling services cannot
be considered as services of general economic interest.
See the Judgement of the European Court of Justice in
case C-179/90 Merci, convenzionali porto di Genova of
10 December 1991 (2). When examining Article 87(3) of

(18) As to the applicability of existing horizontal guidelines
to the proposed aid scheme, the Commission has exam-
ined those that might be applied, i.e. the guidelines for
regional (3) and restructuring (4) aid. The regional guide-
lines, however, would only cover cargo handling compa-
nies located in eligible regions and, moreover, these
guidelines explicitly exclude aid for initial investment in
mobile assets in the transport sector. The application of
the restructuring guidelines is not an option either,
since, within the understanding of these guidelines, the
private cargo handling companies, as the beneficiaries of
the aid, are not in financial difficulties. As a result, none
of
the above guidelines seem to cover as such the
proposed aid scheme.

(19)

Following the above analysis,
the Commission has
decided to examine the compatibility of the proposed
aid scheme under Article 87(3)(c) of the EC Treaty.

(20)

The proposed scheme entails a tax reduction for the
transfer and replacement of existing equipment
to
modernise and rationalise cargo handling, as well as the
acquisition of additional, new equipment in the ports of
Le Havre and Dunkerque to extend the capacity. The
Commission considers that a distinction should be made
between these two types of
investments, given their
different purpose.

With regard to the existing equipment,
the French
authorities argue that the proposed aid scheme will facil-
itate the transfer of the ownership and management
responsibilities of the equipment from public to private.
The aid scheme envisages giving an impetus to moder-
nise and rationalise the provision of cargo handling
services which affects the overall performance of the

(1) OJ C 384, 10.12.1998, p. 3.
(2) Rec. 1991 I-, p. 5889.

(3) OJ C 74, 10.3.1998, p. 4.
(4) OJ C 283, 19.9.1997, p. 2.

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ports. The emphasis on equipment is due to the fact that
the aid is linked to investments in the equipment, which
is one of the three factors determining the tax base.
Further, the expected transfer of the existing equipment
will be carried out in a transparent and non-discrimina-
tory manner on the basis of public tender procedures, to
which also competitors will be able to bid for the equip-
ment. The price paid for the transfer of the existing
equipment from the public to the private is, therefore,
likely to reflect the market price.

would be overly burdensome for the cargo handling
companies. This is notably because these companies are
mainly SMEs with limited financial resources, that more-
over need to continue to provide funding for the ‘social
plans’ of the dock workers.

(21)

Such a transfer is in line with policy developments for
the Community port sector, as explained in the Green
Paper on sea ports and maritime infrastructure (1). The
trend has been to shift the provision of commercial
cargo handling services from the public to private
service providers notably to increase efficiency. To this
end, reforms have taken place in a number of Member
States to adjust the ports to the new requirements as a
result of the technological development and intensified
competition in the sector. The Commission has consid-
ered State aid to support such reforms and the restruc-
turing of the port sector compatible with the common
market in the past. This was the case for example in
1986 concerning aid granted to certain ports for the
reduction of labour in the context of restructuring and
privatisation of the cargo handling sector. Public author-
ities are still
involved in carrying out cargo handling
services in some Community ports as the cargo handling
market has not yet been fully opened up to competition
through Community legislation. The proposed scheme
will help the private cargo handling companies to adapt
to a market that is opening up to competition without,
however, unnecessarily causing distortions, and to this
end contribute to the economic development of the
sector. In view of the above, the objective of the scheme
can be considered to be in the Community interest.

(22) As to the necessity of the proposed scheme to gradually
change the ownership and management responsibilities
of the existing equipment,
it can be argued that the
market forces alone would not secure this objective. The
private cargo handling companies are reluctant to take
over the responsibility for the equipment mainly because
they would become subject to the ‘taxe professionnelle’.
Noting that the existing equipment, which in many cases
is rather old and out-of date, would need to be renewed
through heavy investments, the Commission considers
that the ‘taxe professionnelle’, being calculated on the
the equipment,
basis of

the new purchase value of

(1) COM(97) 678 final of 10.12.1997, paragraphs 81 and 82.

(23)

The transfer of the existing equipment and its subse-
quent replacement is part of a modernisation and ratio-
nalisation exercise and needs to be seen together as part
investment endeavour, as a mere
of one coherent
transfer of mostly obsolete equipment alone would not
be meaningful. In this context, it may be recalled that
the cost of a gantry-crane, as notified by the French
authorities, is around FRF 40 million and its amortisa-
tion period is on average 20 years. Together with the
required straddle-carriers and spreaders whose utilisation
and amortisation period is some 10 years, the total
investment to be made by the companies amounts to
some FRF 50 to 60 million per crane. The cargo
handling business is capital-incentive with long-term
investments, including interest payments, that needs to
be spread out in time. A tax reduction, linked to such
heavy investments seems justified in this particular case
to encourage the cargo handling companies to invest, as
the replacement of
is not
expected to take place simultaneously with the transfer,
but within a near future, for example, depending on the
financial situation of each company.

the existing equipment

(24)

It should also be noted that the economic impact of the
aid is limited because the proposed tax reduction only
affects one element out of three used for establishing the
taxation basis. This factor amounts to 16 % of the new
purchase value for equipment, whereas the private cargo
handling companies would be fully subject to the tax
calculated on the basis of the other two factors, i.e. the
rental value of property and the gross salaries. As noti-
fied by the French authorities, the aid intensity expressed
as a percentage of the investment value is limited to
approximately 13 %. Furthermore,
in view of the fact
that crane-operators (grutiers) will become employees of
the private cargo handling companies undertaking the
investments, the amount of the tax to be paid on the
basis of the salaries provided will

in fact increase.

(25) However, it is necessary for the Commission to ensure
that the aid does not have a noticeable adverse effect on
trade and that it is proportionate to the aims that it is
supposed to achieve. Following the initiation of
the
procedure explaining the Commission's doubts about
the French authorities
the aid,
the compatibility of

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(27)

amended the originally envisaged scheme and reduced
the amount from FRF 623,6 million to FRF 368,35
million and the duration from 10 years to 7 years, i.e.
almost by half. In practice, however, not all companies
that will actually invest in the existing equipment will
benefit from the aid during the entire duration of the
scheme. Depending on the financial situation, each
company will start making the investments at different
times, and will only benefit from the aid from the time
of the investment. The aid will also put the private cargo
handling undertakings on a more equal footing with the
public entities operating in the ports. The Commission
considers that the aid will help the French port system
to adapt to a market, which is increasingly opening up
distorting
to
competition. Moreover, a mere transfer of existing
equipment is not bound to affect the balance in supply
and demand for the port services in question. The situa-
tion is rather that the private cargo handling companies
will replace the public authorities as owner and manager
of the existing equipment,
including taking over the
responsibility to make the necessary investments. The
upgrading of the equipment following the transfer is
necessary to ensure the continuous operation of the
ports.

competition, without

unnecessarily

is not

recital 24. At

the same time,

In view of the above, the affect on trade is marginal in
that the level and form of investment in replacing the
existing equipment
likely to be substantially
different from investments that the public sector would
have undertaken. This is supported by the fact that the
economic impact of the tax reduction is limited, as
explained under
the
proposed aid is important in order to increase produc-
tivity and efficiency in the French port sector through a
better organisation of the work. To this end, the aid for
the transfer of existing equipment and its replacement
may be considered to be in line with the common
transport policy and the policy on SMEs. Such aid is not
expected to distort competition in a manner that will
the trading conditions between port
palpably alter
undertakings to an extent contrary to the common
interest. It should also be noted that no objections were
made by third parties with regard to the aid for the
transfer of existing equipment following the decision to
open the procedure. The aid can, therefore, be consid-
ered to facilitate the development of certain economic
activities
compatible with the
common market.

consequently

and

(28)

The Commission considers, however, that this is not the
case for the investments in new, additional equipment in
the ports of Le Havre and Dunkerque for the extension
of capacity in these ports. In the decision to initiate the
formal investigation period, the Commission expressed
doubts particularly with regard to the proposed aid for
the purchase of new, additional equipment because of
the possible build-up of additional cargo handling
capacity, which may distort the demand and supply
balance of the port services concerned. As explained
under recitals 22 and 23, the aid should be limited, in
terms of volume and duration, to what is absolutely
necessary and be proportionate to the aim of transfer-
ring the financial responsibility from the public sector to
the private cargo handling companies.

other

through

available

(29) Data as submitted by the French authorities confirmed
information
independent
sources, as to which utilisation ratios for the existing
equipment in the two ports mentioned are considerably
below those of their competitors. Moreover, the infor-
mation submitted by the French authorities following
the opening of the procedure, shows an increase in
traffic in the ports of Le Havre and Dunkerque which is
indeed significantly inferior to the one recorded for the

(26) Most of the cargo handling companies concerned are
small enterprises with less than 50 employees and there-
fore, a parallel may be drawn here to the Guidelines for
SMEs (1), which apply to different forms of aid granted
to SMEs. The Commission has traditionally taken a
favourable attitude
towards aid granted to SMEs,
provided that such aid does not affect trade to a dispro-
portionate extent in relation to its contributions to the
achievement of Community objectives. The aid scheme
in question has the character of an incentive and is
necessary in order to secure the socio-economic benefits
and achieve the objectives which market forces alone
would not secure, which are, moreover, desirable on
grounds of Community interest. The aid will cease once
the take-over of the existing equipment and the subse-
equipment has been
quent
this
completed, and consequently bears
resemblance to
start-up aid. Such aid for the existing equipment and its
replacement may be considered proportionate to the
aim of transferring the financial responsibility from the
public sector to the private cargo handling companies.

replacement of

(1) OJ C 213, 23.7.1996, p. 4.

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other competing ports in the North Sea range. It should
also be noted that the growing container traffic renders
the competition increasingly fierce between ports in the
North Sea range where the largest European ports are
located. To this end, aid granted specifically to extend
capacity of cargo handling companies in any port in this
range to the detriment of the others, would undoubtedly
distort competition.

(30) Against this background it is emphasised, as already
stated, that public support cannot be justified to respond
to alleged changes in the supply and demand for the
provision of commercial port services, which is up to
the market forces alone. The proposed aid would put the
cargo handling companies in the two ports concerned
on a competitive footing which is more favourable than
that of their French and Community competitors in
other ports. According to the French authorities, the
transfer of the ownership and management responsi-
bility for the equipment would be based on open tender
procedures, which would enable any interested firm to
apply. Particularly with regard to the major ports of Le
Havre and Dunkerque there may well be an interest
among other firms in the Community to take over such
responsibility. Further, the need to grant aid specifically
to cargo handling companies in these two ports for the
in order to
purchase of additional, new equipment
transfer the responsibility for the equipment from the
public to the private has not been demonstrated by the
French authorities. Such aid is likely to affect the balance
in supply and demand due to build up of additional
cargo handling capacity, thus distorting competition in a
way that may affect trade flows between Member States
to an extent contrary to the common interest.

VI. CONCLUSIONS

(33)

The assessment by the Commission led to the conclu-
sion that aid for the transfer of existing equipment and
its replacement, where necessary, facilitates the develop-
ment of an economic activity and that trading condi-
tions are not affected to an extent contrary to the
common interest. Subject to certain conditions specified
below, this aid is, therefore, considered compatible with
the common market and eligible for the derogation
under Article 87(3)(c) of the EC Treaty.

(34) However,

the application of

this decision has to be
monitored by the Commission and will be a condition
of the approval of the aid. As stated by the French
authorities, the transfer of the existing equipment shall
take place on the basis of open, transparent and non-
discriminatory procedures (public tender), enabling any
undertaking to participate. The aid shall not take the
form of a permanent, automatic reduction of the ‘taxe
professionnelle’, and shall be linked to the investments
which will be made at different times during the aid
scheme. Each cargo handling company will benefit from
the aid only from the time of the investment. Aid may
be granted only once per investment. However,
the
payment of these heavy investments is spread out during
several years and the amortisation periods are long.
Compared with these, the duration of the aid scheme
may be considered limited. Aid may,
therefore, be
provided the fiscal year(s) when a private cargo handling
company in any of the 23 ports concerned takes over an
existing equipment and/or replaces this specific equip-
ment and during the subsequent amortisation of this
equipment until the expiry of the aid scheme in 2006.
Aid for investments in new, additional equipment is not
authorised.

(31) As mentioned under recital 11, the Government of the
United Kingdom supported the doubts expressed by the
Commission with regard to aid for the purchase of new,
in the ports of Le Havre and
additional equipment
Dunkerque as this would seriously distort competition
among the major ports in the North Sea range.

(35)

(32)

In view of the foregoing, the Commission takes the view
that the aid for new, additional equipment can not be
considered compatible with the common market under
Article 87(3)(c).

the transfer of

In view of the above, the French authorities shall during
the applicability of the aid scheme provide the Commis-
sion with annual reports about
the
existing equipment from the public to the private and its
replacement,
the public
including information about
tender procedure applied. This report shall notably
provide details about
the individual cargo handling
companies that take over the existing equipment, the
type and price of this equipment and the corresponding
aid granted. Data is also needed about the investments
made to replace the existing equipment and the amount
of aid granted on the basis of such investments. The first
report is to be submitted within one year from the
adoption of this decision.

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(36)

The Commission does not consider aid for purchasing
new, additional equipment in the ports of Le Havre and
Dunkerque as necessary or proportional to achieve the
objective of the scheme, i.e. the transfer of responsibility
for the equipment from the public to the private sector.
Such aid is moreover bound to affect supply and
demand of cargo handling services and its damaging
effect on competition and trade is likely to outweigh the
positive effects.

(37) As to the amounts, the total investment value for the
port equipment was estimated at FRF 2,800 million in
the notification by the French government. According to
the most accurate available data, the total amount of tax
reduction envisaged is FRF 368,05 million. As a result,
the aid intensity expressed as a percentage of the invest-
ment value, is 13,14 %. When applying this percentage
to investments for replacement of existing equipment
only, i.e. FRF 2,100 million, the amount of tax reduc-
tion that may be granted through the aid scheme is
FRF 275,94 million (13,14 % × FRF 2,100 million), to
be disbursed during the period 2000 to 2006,

The aid is compatible provided it is linked to the investment(s)
in that aid may only be granted for the fiscal year(s) when the
investments in such equipment are made and during the subse-
quent amortisation of this equipment until the expiry of the
scheme.

2.
Aid for the purpose of purchasing new, additional equip-
ment in favour of cargo handling companies in the ports of Le
Havre and Dunkerque in an amount of FRF 91,98 million is
incompatible with the common market.

As a result, this aid may not be put into effect.

Article 2

inform the Commission, within two months
France shall
following the notification of this Decision, of the measures
taken to comply with it.

The French authorities shall provide the Commission with
appropriate annual reports about the implementation of the aid
scheme, notably the public tenders,
the
amount of aid granted and its intensity. The first report is to be
submitted within one year
this
decision.

from the notification of

the investments,

HAS ADOPTED THIS DECISION:

Article 3

Article 1

This Decision is addressed to the French Republic.

Aid for the transfer of existing equipment on the basis of
1.
open and non-discriminatory procedures and the replacement
of this equipment which France is planning to implement in
favour of private cargo handling companies in the 23 French
ports specified in the Annex in an amount of FRF 275,94
million during the period 2000 to 2006 is compatible with the
common market.

Done at Brussels, 22 December 1999.

For the Commission

Loyola DE PALACIO

Vice-President

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ANNEX

The 23 French ports covered by the decision

I. Nord-Pas-de-Calais coastal area:

1.

2.

3.

Port of Calais

Port of Boulogne sur Mer

Port of Dunkirk

II. Normandy coastal area:

4. Autonomous port of Le Havre

5.

6.

7.

8.

9.

Port of Dieppe

Port of Rouen

Port of Honfleur

Port of Fécamp

Port of Caen

III. Channel coastal area:

10. Port of Cherbourg

11. Port of Granville

IV. Brittany coastal area:

12. Port of Saint-Malo

13. Port of Brest

14. Port of Lorient

V. Atlantic coastal area:

15. Port of Nantes-Saint-Nazaire

16. Port of La Rochelle

17. Port of Bordeaux

18. Port of Bayonne

VI. Mediterranean coastal area:

19. Port of Port-Vendres

20. Port of Port La Nouvelle

21. Port of Sète

22. Port of Marseille

23. Port of Toulon