COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 92/106/EEC on the establishment of common rules for certain types of combined transport of goods between Member States
Date: 2017-11-08
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: air quality, carriage of goods, clean technology, combined transport, greenhouse gas, motor vehicle pollution, pollution control measures, reduction of gas emissions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.11.2017  SWD(2017) 362 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 92/106/EEC on the establishment of common rules for certain types of combined transport of goods between Member States {COM(2017) 648 final}  - {SWD(2017) 363 final}  
 
 
TABLE OF CONTENTS 

Table of contents ........................................................................................................................ 2 

Glossary of definitions, acronyms and abbreviations ................................................................ 4 

1. 

INTRODUCTION AND CONTEXT ................................................................... 6 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

1.1. 

1.2. 

1.3. 

2.1. 

2.2. 

3.1. 

3.2. 

3.3. 

5.1. 

5.2. 

6.1. 

6.2. 

6.3. 

7.1. 

7.2. 

7.3. 

7.4. 

7.5. 

9.1. 

9.2. 

9.3. 

9.4. 

Policy context ........................................................................................................ 6 

Rationale for the Combined Transport Directive .................................................. 9 

Outcome of REFIT evaluation ............................................................................ 10 

WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM .......................... 11 

The general problem: low uptake of intermodal transport .................................. 11 

The Specific problems and problem drivers of the current Directive ................. 24 

TACKLING THE PROBLEM ............................................................................ 33 

Evolution of the problem all things being equal (baseline scenario) .................. 33 

Why should the problem be tackled now ............................................................ 37 

Why should the EU act? ...................................................................................... 38 

WHAT SHOULD BE ACHIEVED? .................................................................. 39 

WHAT ARE THE VARIOUS OPTIONS TO ACHIEVE THE OBJECTIVE .. 41 

Overview of retained policy measures ................................................................ 41 

Selection of policy options (and discarded options) ........................................... 43 

WHAT ARE THE IMPACTS OF DIFFERENT POLICY OPTIONS............... 49 

Economic impacts ............................................................................................... 50 

Environmental impacts: reduction of external costs through modal shift .......... 59 

Social impacts ..................................................................................................... 60 

HOW DO THE OPTIONS COMPARE? ............................................................ 62 

Key economic, social and environmental impacts .............................................. 62 

Effectiveness ....................................................................................................... 65 

Efficiency ............................................................................................................ 65 

Coherence ............................................................................................................ 66 

Proportionality .................................................................................................... 66 

CONCLUSION – PREFERRED POLICY OPTION ......................................... 67 

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED ... 67 

Review of the reporting obligation ..................................................................... 67 

Data to be gathered ............................................................................................. 68 

Indicators for assessment .................................................................................... 68 

Operational objectives ......................................................................................... 69 

ANNEXES ............................................................................................................................... 70 

Annex 1: Procedural information ............................................................................................. 70 

1. Organisation and timing ................................................................................................... 70 

2 

 
2. Consultation of the RSB ................................................................................................... 70 

Annex 2: Stakeholder consultation synopsis report ................................................................. 74 

1. Consultation strategy ........................................................................................................ 74 

2. Results of open public consultation ................................................................................. 74 

3. Results of the targeted consultation ................................................................................. 74 

4. Results of the stakeholder meetings ................................................................................. 74 

5. Conclusions and use of results ......................................................................................... 74 

Annex 3. Who is affected by the initiative and how ................................................................ 78 

Annex 4: Analytical models and external expertise used ........................................................ 80 

1.1. 

1.2. 

1.3. 

Models used ........................................................................................................ 80 

Data ..................................................................................................................... 82 

Basis for scenarios .............................................................................................. 84 

Annex  5:  Price  components  of  rail  and  inland  waterways  transport  per  distance  groups  in 
Western and Central Europe .................................................................................................... 91 

Annex 6: Map of rail-road combined transport terminals in EU ............................................. 92 

Annex 7: Extended problem tree .............................................................................................. 94 

Annex 8: Discarded policy measures and relevant justifications ............................................. 95 

3 

 
 
 
 
GLOSSARY OF DEFINITIONS, ACRONYMS AND ABBREVIATIONS 

Multimodal transport1   carriage of goods or passengers by at least two different 

modes of transport 

Intermodal transport2  movement of goods (in one and the same loading unit or a 
vehicle) by successive modes of transport without handling 
of the goods themselves when changing modes. It is hence a 
type of multimodal transport 

Combined transport 

CMR 

e-CMR 

CIM 

CT 

HGV 

CJEU 

EU 

GDP 

GHG 

IWW 

SSS 

According to OECD glossary : "intermodal transport where 
the major part of the journey is by rail, inland waterways or 
sea and any initial and/or final leg carried out by road are as 
short as possible"; however "combined transport" through 
the text is defined by the Combined Transport Directive 

" Convention relative au contrat de transport international de 
marchandises par route" - Convention on the Contract for 
the International Carriage of Goods by Road 

electronic-CMR3 

"Convention Internationale concernant le Transport des 
Marchandises par Chemins de Fer" - Uniform Rules 
Concerning the Contract of International Carriage of Goods 
by Rail  

combined transport 

heavy duty vehicle 

Court of Justice of European Union 

European Union 

Gross domestic product 

Greenhouse gas 

inland waterways 

short sea shipping 

1   OECD  Glossary  of  Statistical  Terminology,  referring  to  original  definition  by  European  Conference  of  Transport 

Ministers, https://stats.oecd.org/glossary/detail.asp?ID=4303  

2   OECD Glossary of Statistical Terminology – see above 

3  

https://www.unece.org/fileadmin/DAM/trans/conventn/e-CMRe.pdf  

4 

 
                                                 
tkm 

bn 

ro-ro 

lo-lo 

tonne-kilometres 

billion 

Roll-on / roll-off 

Lift on / Lift off 

5 

 
 
 
1. 

INTRODUCTION AND CONTEXT 

The reduction of the negative impact of transport activities remains one of the main goals of 
EU  transport  policy  supported  by  a  range  of  different  EU  actions  aimed  at  optimising  the 
transport  system  and  improving  its  efficiency,  at  scaling  up  the  use  of  low-emission 
alternative energy for transport and moving towards zero-emission vehicles4. Incentivising a 
shift  towards  lower  emission  transport  modes  such  as  inland  waterways,  short-sea  shipping 
and rail is one of those actions and the 2011 White Paper5 on transport already defined, as part 
of its general strategy for more sustainable transport, a target for shifting 30% of the projected 
volumes of road freight transport above 300 km to other modes of transport by 2030.  

For such a modal shift in the freight sector, the main alternative to road transport for non-bulk 
items  is  constituted  by  intermodal  transport,  where  load  units  such  as  containers  are 
transhipped between the modes as opposed to manual un- and reloading of goods. Despite the 
potential of intermodal transport especially over longer distance journeys, road only transport 
however remains the first choice of shippers even over longer distances above 300km : 56% 
of  road  freight  transport  still  takes  place  on  long  distances.  Under  the  right  conditions  (i.e. 
available 
level  of  services  and 
competitiveness of intermodal transport) this volume could be shifted away to other modes of 
transport leaving only the last mile for road transport. Unfortunately, this is not the case today 

transport,  sufficient 

infrastructure 

intermodal 

for 

While other complementary measures at EU or Member States level aim at improving specific 
aspects  of  negative  externalities  through  regulation,  obligations  and  taxation,  the  current 
initiative  is  about  updating  the  Combined  Transport  Directive6,  the  only  legal  instrument 
directly supporting intermodal transport: adopted in 1992 it focuses on a portion of intermodal 
transport with limited road legs, and specifically defines it with the term combined transport 
(CT).  The  Directive  originally  aimed  at  removing  certain  regulatory  obstacles  and  making 
intermodal  freight  transport  more  attractive  compared  to  road  transport  in  a  situation  where 
the  market  is  not  providing  price  signals  that  correspond  to  socially  desirable  outcomes7. 
While the Directive does not create any obligations on economic operators, it provides since 
1992  a  framework  and  the  conditions  for  authorities  to  simulate  the  uptake  of  combined 
transport. However  some of these conditions, e.g. the use of paper  transport  documents  and 
stamps as a proof of eligibility for Combined Transport, and the freight market environment 
have evolved quite substantially in the last 25 years : some of the provisions of the Directive 
can no longer be applied and need to be updated.  

1.1.  Policy context 

The  priorities  of  the  current  Commission  reiterate  the  importance  of  sustainable  growth. 
Transport activities continue to generate large negative side effects such as local air pollution, 
greenhouse gas emissions, accidents, noise and congestion. These are largely ‘external costs’ 
or ‘negative externalities’ since they cause considerable costs for society, estimated at 4% of 

4   COM(2016) 501 final (Low-Emission Mobility Strategy)  

5   COM(2011) 144 final (2011 White Paper) 

6   Council Directive 92/106/EEC 

7  

Indeed, many of the negative impacts that are generated by road transport can be qualified as ‘negative externalities’, 
which gives road-only transport an undue advantage over more sustainable choices 

6 

 
                                                 
EU  GDP  in  20088,  but  only  in  part  are  borne  by  the  users.  The  large  majority  of  these 
externalities9 are caused by the road sector which dominates the freight transport market (49% 
of overall freight volume in the EU and 75% of inland freight transport are carried on road).  

As  already  underlined  in  the  2011  White  Paper,  and  reminded  in  the  EU  Low-Emission 
Mobility  Strategy,  reducing  the  negative  impact  of  transport  activities  requires  a  mix  of 
complementary  measures  and  joint  efforts  and  support  by  all  stakeholders.  Existing  EU 
policies for sustainable transport were notably adopted in the context of the 2020 Energy and 
Climate  Policy  Framework  (e.g.  the  revised  Directive  on  the  European  Emissions  Trading 
System) and the 2011 Transport White Paper. They cover mainly the following three areas:  

(1)  "low  emission  vehicles":  with  European  Regulations  setting  CO2  targets  for  new 
passenger cars and vans10, with the Car Labelling Directive11, the Clean Vehicles Directive12 
or the Weights and Dimensions Directive13, 

(2) "switching towards low emission alternative energy for transport" : with legal instruments 
such  as  the  Renewable  Energy  Directive  (RED)14;  the  Fuel  Quality  Directive  (FQD)15,  the 
Directive  on  the  deployment  of  alternative  fuels  infrastructure16  or  the  Electricity  Market 
Directive17; and 

 (3)  "efficiency  of  the  transport  system":  with  legal  instruments  notably  addressing  the 
internalisation  of  external  costs,  such  as  the  Eurovignette  Directive18,  or  aiming  to  optimise 
the traffic management and traffic flows such as the ITS Directive19, or directly supporting the 
shift from road freight transport to other modes of transport such as the Combined Transport 
Directive20 or the Marco Polo Programme21.  

Other  existing  policies  and  measures  aiming  at  building  a  Single  European  Transport  Area 
and  completing  a  competitive  and  resource  efficient  European  transport  system  have 
important co-benefits in terms of reduction of externalities, and most notably to promote the 
shift  to  more  sustainable  modes  of  transport.  These  include  notably  the  Regulations22 
providing  for  the  market  access  to  the  international  road  freight  and  passenger  market;  the 

8   CE  Delft  et  al.  (2011),  External  Costs  of  Transport  in  Europe  –  Update  Study  for  2008,  available  at 

http://www.cedelft.eu/publicatie/external_costs_of_transport_in_europe/1259  

9  

72% of GHG emissions, 97% of accidents 

10   Regulation (EC) 443/2009 and Regulation '(EU) 510/2011  

11   Directive 1999/94/EC 

12   Directive 2009/33/EC 

13   Directive 96/53/EC amended by Directive 2015/719/EU 

14   Directive 2009/28/EC 

15   Directive 2009/30/EC 

16   Directive 2014/94/EU 

17   Directive 2009/72/EC 

18   Directive 2011/76/EU amending Directive 1999/62/EC 

19   Directive 2010/40/EU 

20   Directive 92/106/EEC 

21   Regulation (EC) No 1692/2006 

22   Regulations (EC) No 1072/2009 and (EC) No 1073/2009 

7 

 
                                                 
Regulation  for  the  establishment  and  organization  of  international  Rail  Freight  Corridors23 
and  the  Directive  on  the  Single  European  Rail  Area24;  the  River  Information  Service  (RIS) 
Directive25 aiming to support to support inland waterway transport and to facilitate interfaces 
with other transport modes; the Regulation26 setting Union guidelines for the development of 
the  trans-European  transport  network  setting  Trans-European  Transport  Network  (TEN-T) 
policy implementation.  

Finally EU financing and related instruments such as the Connecting Europe Facilities (CEF) 
27, the European Structural and Investment Funds (ESIF), or the European Investment Bank 
(EIB) play an important role in for the development of the European transport infrastructure.  

In this context, while technology and all these EU policies and legislation on transport, energy 
and climate have achieved a reduction of emissions per tonne-kilometre, the road externalities 
remain higher than in other modes and congestion continues to increase and a greater use of 
alternatives to road transport is therefore also necessary.  

A specific target for such modal shift has been set in the 2011 White Paper on Transport: to 
shift by 2030 30% of long distance road freight (over 300 km) to rail or waterborne transport, 
and more than 50% by 2050. This would inter alia contribute to the achievement of the target 
aiming  at  reducing  greenhouse  gas emissions  from  transport  by  mid-century to  a  level  60% 
lower than that in  1990, reconfirmed recently in the EU Low-Emission  Mobility Strategy28. 
The  latter  also  concluded  that  the  reduction  of  air  pollution  from  the  transport  sector  is  an 
important  factor  for  achieving  the  commitments  under  the  Paris  Agreement  on  climate 
change29 and in line with the 2030 Agenda on Sustainable Development30.  

More recently, the "Europe on the Move  Communication"31 presented the road contribution 
for  "a  socially  fair  transition  towards  clean,  competitive  and  connected  mobility  for  all".  It 
was  accompanied  by  a  series  of  measures  and  proposals  (e.g.  revision  of  Eurovignette 
Directive,  recast  of  the  Directive  on  interoperability  of  electronic  toll  system,  revision  of 
regulations on market access and on working conditions for the road haulage sector, as well as 
steps  to  lay  the  ground  for  cooperative,  connected  and  automated  mobility)  and  will  be 
complemented  by  other  proposals,  including  the  amendment  of  the  Combined  Transport 
Directive.  

The Combined Transport Directive is not considered as a standalone instrument that supports 
modal  shift  in  freight  transport  through  the  promotion  and  development  of  combined 
transport.  As  explained  above,  it  is  one  of  the  key  elements  in  a  package  of  EU  measures 

23   Regulation (EU) No 913/2010 

24   Directive 2012/34/EU 

25   Directive 2005/44/EC 

26   Union guidelines for the development of the trans-European transport network 

27   Regulation (EU) No 1316/2013 

28   A 

European 

COM(2016) 
https://ec.europa.eu/transport/sites/transport/files/themes/strategies/news/doc/2016-07-20-
decarbonisation/com%282016%29501_en.pdf  

Low-Emission 

Mobility, 

Strategy 

for 

501, 

available 

at 

29   http://unfccc.int/paris_agreement/items/9485.php  

30   https://sustainabledevelopment.un.org/post2015/transformingourworld  

31   COM(2017) 283 final 

8 

 
                                                 
aimed at the development of multimodal transport and hence contributes to the reduction of 
externalities, in particular reduction of GHG emissions, air pollution, energy consumption and 
congestion. 

From  a  road  transport  regulation  viewpoint,  and  as  reminded  above,  it  is  worth  noting  the 
direct  interaction  of  the  Combined  Transport  Directive  with  the  Weight  &  Dimension 
Directive  and  with  the  Regulation  (EC)  1072/2009  on  access  to  international  road  transport 
market:  

- 

- 

the Weights and Dimension Directive complements the Combined Transport Directive by 
allowing heavier loads for combined transport to counterbalance the disadvantage of the 
weight of the transferrable load unit 
the  Combined  Transport  Directive  includes  an  exemption  from  the  cabotage  restrictions 
provided for in Regulation (EC) 1072/2009. .  

In addition, when considering financing investment in transport infrastructure, it is important 
to  remind  that  the  EU  Competition  rules  and  most  notably  State  Aid  rules  remain  of 
application,  especially  when  Member  States  decide  to  support  unilaterally,  through  national 
programmes,  combined  transport,  in  the  absence  of  dedicated  regulatory  framework  for 
support.  

1.2.  Legal context: rationale for the Combined Transport Directive 

The Council Directive 92/106/EEC on the establishment of common rules for certain types of 
combined  transport  (known  as  the  Combined  Transport  Directive)  was  adopted  on  7 
December with the original intention to improve the sustainability of the EU transport system 
through  modal  shift  from  road  to  rail  and  waterborne  transport.  It  was  meant  to  do  so  by 
lifting  existing  regulatory  obstacles  and  increasing  the  competitiveness  of  international 
intermodal (and more specifically "combined") transport vis-à-vis road only freight transport. 

As the only EU legal instrument in place that directly supports intermodal freight transport, 
the Directive did not impose obligations on economic operators but rather introduced support 
measures for strictly defined ("combined") intermodal transport operations32. Those measures 
were split between:  

- 

"regulatory" support measures : measures a) safeguarding the freedom to provide the 
cross-border  service,  i.e.  preserving  combined  transport  from  possible  national 
protectionist  restrictions  (authorisation  schemes,  regulated  tariffs  and  quotas),  b) 
exempting  the  road  legs  of  international  combined  transport  from  the  road  cabotage 
limitations  under  Regulation  (EU)  and  c)  allowing,  through  cross-reference  with  the 
Weights  and  Dimensions  Directive  (53/96/EC),  heavier  loads  for  vehicles  used  in 
intermodal transport   road legs to  compensate for the tare weight of the load  unit as 
well as use of 45 foot containers;  

32   The non-road legs have to be at least 100km, while the road legs are limited to distances to nearest suitable station when 
connecting to rail or 150 km when connecting to waterborne transport. It also includes a closed list of eligible load units 
and conditions on proof of eligibility (transport documents). 

9 

 
 
                                                 
- 

"economic" support measures: providing selected fiscal incentives and an extension of 
the definition of the own-account transport. These were meant to partially correct the 
unbalance  between  combined  transport  and  road-only  transport  caused  by  the 
existence of negative externalities not fully reflected in the price of road freight. 

Historically  the  1992  Combined  Transport  Directive  built  on,  and  extended  to  road/ 
waterborne  the  original  1975  road/rail  combined  transport  legal  instrument33.  In  1998,  and 
building  on  report  by  the  Commission,  the  Commission  adopted  a  proposal34  to  amend  the 
Combined  Transport  Directive  and  the  Weights  &  Dimension  Directive.  The  proposal 
focused,  already  at  that  time,  on  the  need  to  simplify  the  Directive,  and  most  notably  the 
definition of Combined Transport and related conditions for eligibility. Despite the relevance 
of  the  proposal,  it  was  withdrawn35  in  December  2001  due  to  a  negative  opinion  of  the 
European  Parliament,  mainly  concerning  the  proposal  to  amend  the  Weights  &  Dimension 
one.  Since  then  however,  the  European  transport  policy  has  evolved  notably  fuelled  by  the 
2011 White paper, and notably a specific target for modal shift of road freight transport above 
300  km.  In  parallel,  and  notably  under  the  Paris  Climate  agenda,  environmental 
considerations  have  pushed  a  drive  towards  even  more  low  emission  mobility.  Finally  with 
the advent of new technologies, notably the growing pervasiveness of modern ICT tools and 
the  digitalisation  of  business  processes,  some  of  the  provisions  of  the  1992  (e.g.  the  use  of 
paper  and  stamps  to  certify  transport  documents)  have  become  outdated  and  need  to  be 
reviewed.  

1.3.  Outcome of REFIT evaluation 

A REFIT evaluation36 of the Directive was carried out in 2014-2016 and concluded that the 
Directive  continues  to  be  a  relevant  instrument  for  supporting  combined  transport.  It  was 
established that without EU action, cross-border Combined Transport services would likely be 
faced  with  barriers  resulting  from  different  legal  systems,  making  Combined  Transport 
services  less  attractive  and  possibly  unfeasible.  The  evaluation  underlined  that  Combined 
Transport  helps  to  reduce  negative  externalities  through  modal  shift:  as  illustrated  in  table 
below37  it  was  estimated  that  the  shift  from  road  to  intermodal  transport  induced  by  the 
Combined  Transport  Directive  has  brought  along  an  annual  saving  of  up  to  €2.1  billion  in 
external costs. More specifically the evaluation reported that the shift from road to rail/road 
combined transport saved in 2011 (compared to road only) 7.3 Mt of CO2, while the shift to 
inland waterways saved 0.96 Mt of CO2 in the same year.  

Heavy goods vehicles  

External costs  

Accidents 

Noise 

Congestion 

Air Pollution 

33   Directive 75/130/EEC 

34   COM(1998) 0414/1 and COM(1998) 0414/2 

35   COM(2001) 763 final/2 

36   SWD(2016) 140 

37   From REFIT evaluation Report (see above) 

Inter-urban 

410 

73 

661 

607 

10 

 
 
                                                 
  
Climate change 

366 

Total external costs 
Table 1. Total external cost savings for CT non-road legs otherwise being carried out by HGV (million EUR, in 
2010 constant prices - Source: REFIT evaluation – based on PRIMES-TREMOVE Transport Model 

2118 

As pointed out in the evaluation, the freight transport market has evolved significantly since 
1992  with  the  globalisation  of  the  world  economy  and  in  particular  the  spread  of  global 
supply chains which has generated a considerable increase in freight transport volumes in the 
world  and  in  the  EU.  The  enlargement  of  the  EU  from  12  to  28  Member  States  has  also 
further influenced the trade flows and therefore the transport market of the EU. These trends 
have supported the continuous growth of the transport volumes in the EU, including growth of 
Combined Transport. In addition some technical developments during the last 25 years can be 
assumed  to  have  influenced  multimodal  transport  more  than  single  modal  transport.  In 
particular  the  widespread  use  of  containerized  transport  can  be  seen  as  having  supported 
intermodal  transport,  while  the  greater  use  of  ICT  have  made  it  easier  to  plan  and  execute 
multimodal journeys.  

Considering the benefits of the Combined Transport Directive and the freight transport market 
development  since  1992,  the  evaluation  showed  that  there  is  significant  margin  for  further 
improving the effectiveness of the Directive, owing to the fact that some of its provisions are 
outdated, its language is sometimes ambiguous, and its scope is limited. The shortcomings 
relate in particular to the definition of Combined Transport, the limitations of fiscal incentives 
and the outdated provisions relating to transport documents. 

In  addition,  the  transposition  and  implementation  of  the  Directive  has  been  somewhat 
problematic.  While  the  Directive  has  been  transposed  into  national  legislation  by  most 
Member  States,  the  quality  of  transposition  is  not  homogenous.  Both  the  analysis  by  the 
Combined  Transport  Study  as  well  as  the  public  consultation  highlighted  that  considerable 
differences exist in the implementation of the Combined Transport Directive. Some Member 
States' legislation seems to miss parts of the measures, while in others the chosen language is 
not  in  full  conformity  with  the  Combined  Transport  Directive  or  allows  contradictory  or 
interpretation.  The  Commission  has  started  several  EU-Pilots  and  one 
misleading 
infringement case, both where complaints have been launched by industry as well as to clarify 
the state of play of the transposition.  

2.  WHAT IS THE PROBLEM AND WHY IS IT A PROBLEM 

2.1.  The general problem: limited and slow ow uptake of intermodal transport 

The White Paper on Transport in 2011 set a clear target for modal shift of long distance road 
freight with an aim to reduce effectively the negative externalities of the transport sector. It 
also  concluded,  similar  to  the  conclusions  of  the  1992  White  Paper  on  Transport,  that 
adequate interventions are needed to create conditions in which the industry could and would 
use intermodal transport instead of road only transport : investment into intermodal networks, 
regulatory intervention to ensure the internalisation of external costs as well as fair treatment 
of  intermodal  transport,  and  direct  support  to  intermodal  transport  to  counterbalance  the 
inherent cost disadvantages of the complex intermodal transport chain. 

11 

 
 
 
As  explained  in  the  REFIT  Evaluation  Report38,  intermodal  freight  transport  has  grown 
significantly between 1990 and 2011, with a doubling of volumes in TEU, and a significant 
increase (55%) between 1990 and 1994, notably due to the adoption and implementation of 
the  Combined  Transport  Directive.  In  the  recent  "CT  Update  Study"39,  the  figures  on  the 
evolution of intermodal freight transport from 2011 and 2015, calculated based on an updated 
methodology, seem to demonstrate a higher share of intermodal transport as compared to the 
2015 CT Study40 used for REFIT, but nonetheless confirm the estimated annual growth rate of 
intermodal freight transport of 3.5% provided in the REFIT Evaluation report. Table 2 below 
illustrates  the  relative  importance of the various  intermodal transport types,  i.e.  road/rail  Vs 
road/IWW and road/SSS as provided in that same study. 

However, despite this evolution, the modal shift observed in European freight transport does 
not  seem  to  evolve  fast  enough  in  the  desired  direction,  i.e.  towards  most  environmental 
friendly  modes,  as  illustrated  in  the  recent  EUROSTAT  figure  for  the  years  2011  to  2015.  
This evolution seems to be confirmed by the projections of the transport reference scenario41 
which show that the modal shift target set in the 2011 White Paper will not be met by 2030 
(see more detail in Section 3.1. Baseline). 

Table 2. Split, per modes) of Intermodal Transport and of CT as covered by the CT Directive in 2015 - Source: 
CT Update Study 2017 

38   SWD(2016) 140 final, section 4.2, Figure 4 and Annex V and VI 

39  

ISL+KombiConsult (2017), Updating EU combined transport data – Final Report)  

40   KombiConsult 

et 

al 

(2015), 

Analysis 

of 

EU 

Combined 

Transport 

market, 

http://ec.europa.eu/transport/sites/transport/files/themes/strategies/studies/doc/2015-01-freight-logistics-lot2-combined-
transport.pdf 

41   EU  Reference 

Trends 
https://ec.europa.eu/energy/sites/ener/files/documents/20160713%20draft_publication_REF2016_v13.pdf  

and  GHG 

emissions, 

Transport 

Scenario 

Energy, 

2016, 

to 

2050, 

12 

Total%Total%Rail/Road CT (a)163                              26%98                                          38%IWW/Road CT 16                                 3%11                                          4%Shortsea/Road CT436                              71%147                                        58%Total614                              100%256                                        100%CT involving more than two modes44                                    7%15                                             6%t moved (bn tkm)CT in EU as covered by directive 92/106/EECt moved (bn tkm)2015Intermodal Transport 
 
                                                 
Figure 1 : Freight transport in the EU-28: modal split based on five transport modes (% of total tonne-kilometres 

A  fundamental  reason  for  the  relatively  limited  uptake  of  intermodal  transport,  and  hence 
slower  than  expected  modal  shift,  is  that  the  framework  conditions  for  intermodal  transport 
are  and  remain  considerably  less  advantageous  than  those  for  road-alone  transport  (see 
problem tree in figure 2 and Section 2.1.1). This makes intermodal transport less competitive 
than road only transport, especially on shorter distances, as explained in the REFIT report.42 
The  main  challenge,  as  regards  cost  competitiveness,  is,  for  each  types  of  intermodal 
transport, to bring down that "break-even" minimal distance.  

The low uptake of intermodal transport is also due to the insufficient density and capacity of 
the needed intermodal infrastructure . The effects of the Combined Transport Directive have 
been modest and could be improved.  

42   SWD(2016) 140 final – Section 5.3 "According to the CT Study, the minimal transport distance in order to be able to 
compete with road transport (without support measures) is: inland navigation 50 km, rail 250 km and short sea 350 km" 

13 

freight transport performance - million tkm20102015Road51.2%Road50.6%Rail11.8%Rail12.3%Inland waterways4.7%Inland waterways4.3%Air0.1%Air0.1%Maritime32.3%Maritime32.7%Note: Air and maritime cover only intra-EU transport (transport to/from countries of the EU) and exclude extra-EU transportSource: Eurostat (online data codes: rail_go_typeall (rail), iww_go_atygo (inland waterways), road_go_ta_tott (national road transport), road_go_ca_c (road cabotage transport); Eurostat computations (international road transport, air and maritime transport).Road, 51.2%Rail, 11.8%Inland waterways, 4.7%Air, 0.1%Maritime, 32.3%2010Road, 50.6%Rail, 12.3%Inland waterways, 4.3%Air, 0.1%Maritime, 32.7%2015 
 
                                                 
Figure 2: Problem tree 

As further explained below, and despite the TEN-T Guidelines and related CEF funding for 
the European transport infrastructure, the required level of interventions has been insufficient 
so far for achieving equal footing for intermodal transport with unimodal road transport and 
thus for ensuring sufficient modal shift.  

After  25  years,  the  infrastructure  considered  necessary  to  ensure  intermodal  transport  is 
lacking  in  many  parts  of  Europe,  or  does  not  have  sufficient  capacity;  intermodal  transport 
services  remain  non-competitive  with  road  only  transport  due  to  inherent  disadvantages  of 
intermodal  transport,  limits  in  the  full  internalisation  of  external  costs,  and  there  are  still 
barriers hindering operations between Member States for non-road transport legs that reduce 
efficiency of intermodal transport. In short, the conditions for intermodal transport in the EU 
do not support modal shift.  

2.1.1.  Non-competitive framework conditions for Intermodal transport services 

Intermodal  transport  services  often  remain  non-competitive,  in  terms  of  price,  efficient 
operation  or  reliability  compared  to  road  transport  despite  the  measures  taken  through  both 
the Combined Transport Directive and other EU legislations (e.g. Eurovignette Directive) to 
support  the  needed  modal  shift  and  address  other  causes  discussed  in  detail  below.  These 
measures  have  not  always  been  as  effective  as  they  could  have  been  due  to  their  technical 
complexity or because of political sensitivities. 

14 

 
 
 
 
2.1.1.1.  Higher inherent cost of Intermodal Transport  

There are several factors inherent to intermodal transport that can be translated into additional 
costs for the operators and users, or other disadvantages for intermodal transport in terms of 
e.g.  delivery  times  or  reliability.  These  disadvantages  are  addressed  partly  through  the 
Combined  Transport  Directive’s  economic  support  (that  is  currently  ineffective,  see  section 
2.2.2.) and partly through other EU measures as described below.  

Thus  the  majority  of  root  causes  of  uncompetitive  intermodal  transport,  discussed  in  detail 
below, continue to aggravate the problem resulting in intermodal transport being considerably 
more  expensive  for  the  shippers.  Figure  3  below  illustrates,  based  on  cost  figures  from  the 
2017 Survey study43, the costs incurred by shippers when choosing for intermodal (rail-road) 
transport  (without  the  benefits  from  Combined  Transport  Directive)  (i.e.  respective  parts  of 
cost from road part, non-road part, transhipment, reduced load capacity, cabotage restrictions 
and additional costs) compared to road transport only. 

Reduced loading 
capacity; 10 

Intermodal transport without CTD

Road; 29 

Non-road; 39  Transhipment 

30 

Cabotage; 8 

Unimodal road transport

Road; 100 

Additional costs 
(implementation, 
delays, transaction 
costs etc); 40 

0

20

40

60

80

100

120

140

160

180

Figure 3. Cost comparison of road only and intermodal transport, percentage of cost components (without CT 
Directive, based on medium to long rail-road transport)  

Transhipment 

In  an  intermodal transport operation, the load unit needs to  change  the transport  modes  and 
thus  necessitates  transhipment.  In  2015,  there  were  estimated  66.8  million  transhipments  in 
the  EU  with  an  average  2.2  transhipments  during  rail-road  intermodal  transport  operations, 
1.7  transhipments  during  inland  waterways-road  intermodal  transport  operations  and  2 
transhipments  during  short-sea-shipping 
(excluding 
transhipments  to  and  from  ocean  going  vessels  and  Combined  Transport  operations).  The 
transhipment costs vary considerably between Member States and modes of transport with the 
average  cost  being  around  50€  per  lift44.  However,  an  additional  important  element  to 
remember  is  the  fact  that,  for  transhipment  to  be  possible  there  is  an  underlying  high  fixed 
cost due to required initial transhipment equipment in the intermodal terminal. This high fixed 
cost of transhipment will have to  be compensated by lower costs per ton-km. This  in  effect 
explains the limitations of the modal shift potential for long haulage transport: as illustrated 
on table 4 below, the average non-road leg of e.g. rail/road intermodal transport is 615 km.  

transport  operations 

intermodal 

Additional costs and delays due to multiparty operation 

43   TRT (2017)  – Gathering additional data on EU combined transport – Final report 

44   TRT  (2107)    -  Gathering  additional  data  on  EU  combined  transport  –  Final  Report  –  NOTE  :  all  cost  figures  in  this 

section come from this study 

15 

 
 
                                                 
An intermodal operation includes by definition a considerably more complex transport chain 
than  any  single  mode  transport  operation.  The  disadvantages  deriving  from  a  complex 
operation include contractual and transaction costs for organising and carrying out multiparty 
operations (estimated at 85€/shipment), costs of delays resulting from the need to transfer the 
load  units  between  modes,  difficulties  in  tracking  and  tracing  the  shipment  between  the 
various  modes  and  responsible  operators  (estimated  at  10€/shipment)  and  costs  from  other 
external  factors45.  The  main  cost  factor  for  shippers  and  Combined  Transport  organisers 
(logistics  companies,  freight  forwarders,  Combined  Transport  operators  etc.)  is  the  longer 
delivery times (caused by longer routes, transhipment related delays and other delays caused 
by  multiparty  operations,  average  150€/shipment)  followed  by  transhipment  costs  (average 
100€/shipment)46.  The  industry  stakeholders  responding  to  the  targeted  consultation47  also 
identified journey time and price as two of the top-three impediments for the use of intermodal 
transport, with no suitable services (connection or terminal) as the most crucial of the three.  

Cost and weight of the load unit 

An additional disadvantage and cost factor for intermodal transport is the fact that a separate 
load  unit  is  used.  First,  the  load  units  itself  require  either  an  investment  or  involve  leasing 
costs. Secondly, as the maximum weights and dimensions are regulated in the EU for the road 
leg and a load unit has its own empty weight on top of that of the lorry and goods, the load 
capacity  of  intermodal  transport  is  ca  10%  lower.  This  problem  is  partly  addressed  through 
the higher weights allowed for containerised intermodal transport in the Directive 96/53/EEC 
(Weights and Dimensions)48 allowing additional 2 or 4 tonnes depending on the vehicle. This 
extra weight does not create a real benefit as for most load units the additional allowance does 
not cover or barely covers the weight of the empty load unit and no extra weight  is allowed 
for other intermodal load units. Thus this benefit rather compensates for the weight of the load 
unit  allowing  comparable  loading  capacity,  while  not  creating  the  damage  to  infrastructure 
connected  to  mega-trucks  as  on  short  road  leg  distances  the  10%  additional  weight  creates 
little problems.  

The  definition  used  in  the  Weights  and  Dimensions  Directive  refers  directly  to  Combined 
Transport  Directive  and  thus  any  change  in  the  definition  of  combined  transport  in  the 
Combined  Transport  Directive  will  also  change  the  eligibility  of  operations  as  regards  the 
increased  weights  and  dimensions.  Similarly,  a  new  restrictive  definition  in  the  Combined 
Transport Directive would exclude large parts of intermodal transport from this compensatory 
additional weight. The industry stakeholders raised the latter as their major concern in regard 
to the currently planned amendment of the initiative.  

Broken transport operation with different regulation applying to different parts 

An intermodal transport operation is subject to different modal rules on different parts of the 
operation. In particular, for international "combined" transport, the Directive also ensures that 
no additional layer of authorisation or quantitative restrictions is applied as such. A particular 

45   Such  as  terminal  capacity,  transhipment  time,  frequency  of  trains  or  sailings  (depending  on  non-road  operators 

preferences) etc. 

46   TRT (2017)  – Gathering additional data on EU combined transport – Final report 

47   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

48   Directive (EU) 2015/719 

16 

 
                                                 
problem  relates  to  the  existing  cabotage  restrictions49  for  national  road  transport:  some 
stakeholders  perceive  the  road  legs of  intermodal  transport,  though  parts  of  an  international 
operation,  as  being  national  operation.  However  the  Combined  Transport  Directive 
establishes that the road legs of an international Combined Transport operation can be carried 
out by non-resident hauliers even when the road legs do not cross a border, setting it at bar 
with  international  road  transport  that  is  the  competitor  for  this  type  of  operation.  This  has 
been confirmed several times by CJEU rulings50. According to the open public consultation, 
in  case  of  removal  of  this  expressis  verbis  confirmation  from  the  Directive,  large  parts  of 
combined transport would reverse back to road only international transport as the inability to 
use the subcontractor freely would increase the cost by 3-15%.  
Figure 4 below further details, based on the cost figures of the referred 2017 study51, the split 
of  average  additional  cost  incurred  when  operating  intermodal  transport  because  of 
organisational  issues,  longer  delivery  times,  transhipment  costs,  traceability  difficulties,  or 
lack of harmonisation of procedures or documents. 

Problems of non-
harmonisation of 
procedures/document
s 
11% 

Problems with 
traceability of cargo 
3% 

Longer delivery times 
39% 

Transhipment cost 
26% 

Organising/managing 
a CT operation 
21% 

Figure 4: Estimated additional average cost proportion for an intermodal transport per shipment as compared to 
road only transport 

All these costs components vary based on the non-road mode of the intermodal operation, and 
on its total length as illustrated in Annex 5.  

49   Regulation (EC) No 1072/2009 

50   Between 1989 and 1994, the CJEU has ruled in 3 consecutive cases that a Combined Transport operation has to be seen 
as  one  single international  transport  operation  and  thus  the  road legs, even  if  not  crossing  a  border  cannot  be  seen  as 
national transport, and hence cabotage limitations cannot be applied to CT road legs. However, industry faces problems 
to  this  date.  Several  additional  CJ  EU  cases  deal  with  additional  licensing  requirements  established  on  combined 
transport, with the location of suitable terminal and transit issues etc. 

51   TRT (2017)  – Gathering additional data on EU combined transport – Final report 

17 

 
 
 
                                                 
2.1.1.2.  Lack of full internalisation of external costs in the road sector 

The  competitive  position  of  intermodal  transport  is  further  jeopardized  by  the  fact  that 
transport prices today do not  reflect the full extent of external costs and thus  road transport 
can offer low prices with high cost to society.  

A detailed inventory on internalisation of external costs in the transport sector established that 
the  costs  of  the  road  sector  are  covered  to  38%  by  different  internalisation  measures  (not 
including congestion costs). The level is very different in different Member States (see Figure 
5).  

Figure 5: Indicative cost coverage ratios for road transport52  

The  EU  has  supported  the  implementation  of  the  "polluter  pays"  principle  for  a  while.  It  is 
argued  that  if  the  prices  of  different  modes  would  reflect  the  external  cost  to  society,  the 
competitive position of road against the other modes would change and it would become more 
economical to use rail, inland waterways or short sea shipping transport instead.  

The  main instrument  is the so-called "Eurovignette" Directive 1999/62/EC, as  last amended 
by Directive 2011/76/EU53. It provides a legal framework for road charging systems for heavy 
goods  vehicles  (HGV)  and  contains  specific  provisions  on  the  calculation  and  allocation  of 
infrastructure and environmental costs. However, the current Eurovignette Directive provides 
only  a  possibility  for  and  not  an  obligation  to  introduce  such  charging  schemes  and 
furthermore  does  not  foresee  charging  for  congestion  and  accident  costs.  As  part  of  the 
"Europe  on  the  Move"  communication  adopted  in  May  2017,  the  Commission  adopted  a 
proposal54  for  amending  the  Eurovignette  Directive  which  includes  ambitious  measures. 
However, according to the impact assessment, it is expected to mostly influence the choice of 
vehicles and not so much the choice of transport mode and the actual modal shift from road to 

52   An inventory of measures for internalising external costs in transport, 2012, Transport & Mobility, TNO, CE Delft and 
TRT,  available  at  http://ec.europa.eu/transport/sites/transport/files/themes/sustainable/studies/doc/2012-11-inventory-
measures-internalising-external-costs.pdf  

53   Directive 1999/62/EC of the European Parliament and of the Council of 17 June 1999 on the charging of heavy goods 

vehicles for the use of certain infrastructures 

54   COM(2017) 275 final - Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

amending Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain infrastructures 

18 

 
 
                                                 
other  modes  is  expected  to  be  limited  to  0.1-0.2  percentage  points  by  2030  relative  to  the 
baseline scenario55.  
The  internalisation  of  external  environmental  costs  of  transport  is  also  supported  by  fuel 
taxation. The Energy Taxation Directive 2003/96/EC56 lays down the rules on the taxation of 
electricity  and  energy  products.  The  minimum  tax  rates  set  in  the  Directive  are  aimed  at 
supporting  the  reduction  of  negative  externalities  of  the  transport  sector.  However,  in  its 
current  form,  the  Directive  does  not  create  sufficient  incentives  for  energy  efficiency  and 
reductions of CO2 emissions. The Commission adopted a proposal to review the Directive on 
13  April  201157  aiming  at  aligning  energy  taxation  policies  to  reflect  the  environmental 
impact  of  fuels  and  other  energy  products.  Due  to  lack  of  agreement  in  the  Council,  the 
Commission withdrew the proposal in March 2015.  

Taking  into account  the widespread use  of road transport, the  internalisation of the external 
costs of road transport – partial or full - is politically and economically difficult as it would 
impact a large category of operators and citizens. In the short term it will not be possible to 
achieve full internalisation of external costs and partial internalisation is unlikely to achieve 
the desired modal shift results alone. 

The latter is supported by the data from Member States who have introduced road charging 
with an aim to support modal shift. In Germany, no significant evidence was found on effects 
on  modal  shift  from  road  charging.  At  the  same  time,  in  Austria,  where  the  distance  based 
tolls  on  HGVs  were  complemented  by  a  handful  of  other  policy  measures  (notably  fiscal, 
financial  and  regulatory  measures  in  support  of  rail  and  combined  transport),  a  clear  modal 
shift has been noted since 2004 when the tolls were introduced.  

2.1.1.3.  Regulatory disadvantages and other issues hindering Intermodal Operations  

Road sector 

As already explained above, despite the specific extension to 45' long containers for combined 
transport, the Weight & Dimension Directive limits the size and weight of the load unit that 
can be used in road freight transport, de facto also limiting the capacity that can be transported 
in an intermodal operation.  

Unequal  liberalisation  and  evolution  of  rail,  IWW,  SS  compared  to  international  road 
transport 

As underlined in the REFIT evaluation Report, the liberalisation of road and rail transport, the 
improvement  of  interoperability  of  modes  and  state  aid  rules  have  had  an  impact  on  the 
intermodal  transport  in  the  EU.  Because  it  was  liberalised  in  1990s,  road  transport  enjoyed 

55   SWD(2017) 180 final - COMMISSION STAFF WORKING DOCUMENT - IMPACT ASSESSMENT -Accompanying 
the document Proposal for a Directive of the European Parliament and of the Council amending Directive 1999/62/EC 
on  the  charging  of  heavy  goods  vehicles  for  the  use  of  certain  infrastructures  and  Proposal  for  a  Council  Directive 
amending  Directive  1999/62/EC  on  the  charging  of  heavy  goods  vehicles  for  the  use  of  certain  infrastructures,  as 
regards certain provisions on vehicle taxation 

56   Council Directive 2003/96/EC of 27 October 2003 restructuring the Community  framework for the taxation of energy 

products and electricity 

57   COM(2011)  169/3,  Proposal  for  a  Council  Directive  amending  Directive  2003/96/EC  restructuring  the  Community 

framework for the taxation of energy products and electricity 

19 

 
 
                                                 
greater  competitiveness  than  other  modes  of  transport,  while  e.g.  railways  continued  to  be 
protected from competition for many years. This can be seen as having negatively influenced 
the  comparative  advantage  of  intermodal  transport.  The  complete  liberalisation  of  the  rail 
freight operations occurred only on 1 January 2007 with the Second Railway Package58, for 
both national and international services. Despite the increased competition and new operators 
entering the market, there are still issues and the effects of full liberalisation will take time to 
fully manifest themselves. For waterborne transport, there have number of initiatives to open 
up the market and facilitate inland waterway transport and short sea shipping, but additional 
legal instruments are needed to complement the existing ones (e.g. revision of the Reporting 
Formalities Directive59). 

Different standards and regulations in non-road modes 

There are also specific technical issues or regulatory obstacles affecting the non-road modes, 
and  in  particular  the  rail  sector,  the  original  non-road  mode  affected  by  the  Combined 
Transport Directive. Infrastructure requirements for the rail freight lines to complete the TEN-
T rail freight core network by 2030 have been defined in the TEN-T Guidelines60 : "at least 
22,5 t axle load, 100 km/h line speed and the possibility of running trains with a length of 740 
m".  This  has  been  complemented  by  the  Regulation61  on  rail  freight  corridors  aimed  to 
develop  coordinated  capacity  for  rail  freight  along  the  corridors.  This  has  contributed  to 
ensure that overall, less than 1% of the total rail network was congested in 2014, as explained 
in the 5th Rail Market Monitoring Report62. However, despite those objectives and advances, 
technical 
the  present 
harmonisation,  including  gauge  differences  between  different  part  of  the  Europe  (Eastern 
Europe and Central and Western Europe) continue to negatively influence the functioning of 
the  EU  rail  market  and  through  that  the  development  of  Combined  Transport  and  other 
multimodal services. Furthermore, the European Court of Auditors noted in its report  63‘Rail 
freight  transport  in  the  EU:  still  not  on  the  right  track’  that  the  performance  of  rail  freight 
transport  in  the  EU  remains  unsatisfactory.  Finally  it  should  also  be  noted  that  in  the 
European  rail  system,  with  few  exceptions,  passenger  traffic  has  priority  over  freight  and 
international  over  domestic;  this  can  have  an  impact  on  delivery  and  reliability  of  freight 
transport. Similar consequences in terms of speed and reliability are even more important and 
even inherent of waterborne transport operations and infrastructure.  

infrastructure  and  problems  relating 

lack  of  connections, 

to 

2.1.2.  Low  density  and  limited  capacity  of  Intermodal  Infrastructure  (including 

terminals)  

The  way  transport  infrastructure  is  shaped  has  a  decisive  impact  on  the  achievement  of  the 
modal shift and decarbonisation objectives of transport. The White Papers on Transport both 

58  

Including, among others, Directive 2004/49/EC 

59   Directive 2010/65/EU 

60   Regulation (EU) No 1315/2013 

61   Regulation (EU) No 913/2010 

62   https://ec.europa.eu/transport/modes/rail/market/market_monitoring_en 

63   http://www.eca.europa.eu/en/Pages/NewsItem.aspx?nid=6971 

20 

 
 
                                                 
from  200164  as  well  as  from  201165  acknowledged  insufficient  availability  of  multimodal 
infrastructure to be the main problem for achieving modal shift. This was also underlined in 
the European Parliament resolution66 of 9 September 2015 on the implementation of the 2011 
White Paper on Transport which pointed that "the modal shift policy has not so far delivered 
satisfactory  results"  and  which  highlighted  that  appropriate  transport  infrastructure  was  a 
precondition  for  a  sustainable  multimodal  transport  system  and  also  stressed  the  need  to 
prioritise  investment  on  notably  the  completion  of  missing  links  and  the  development  of 
multimodal terminals.  

Looking  at  the  EU  transport  infrastructure,  the  completion  of  the  TEN-T  Core  and 
Comprehensive Networks, especially as regards the non-road modes, is critical. The revised 
TEN-T  Guidelines67  set  a  range  of  binding  standards  for  infrastructure  development  and 
multimodal  infrastructure,  and  a  second  generation  of  TEN-T  corridors  work  plans  is  being 
prepared,  under  the  supervision  of  Coordinators,  further  refining  the  initial  analysis  of  the 
infrastructure  needs  and  relevant  projects,  in  particular  to  remove  bottlenecks  and  complete 
cross-border section. The efficient completion of this network may however be impacted by 
complex  regulatory  and  administrative  arrangements,  which  may  contribute  to  increased 
costs, delay and uncertainty for infrastructure projects.  

From a network capacity viewpoint, rail, inland waterways and short seas shipping have today 
the theoretical necessary capacity to absorb freight traffic shifted from road:  

- for rail, capacity limits vary significantly between various parts of the rail network, but, as 
explained above, capacity is and will be coordinated in the context of the implementation of 
Regulation (EU) No 913/2010 and the Rail Freight Corridors;  

- for short-sea-shipping, the EU has large available capacity in  terms of  sea-ports in 22 EU 
maritime Member States and there are 329 key seaports which belong to the trans-European 
transport network  and that are key nodal points for handling both  international freight  trade 
and intra-EU freight flows;  

- for inland waterways, the EU inland waterway network spans 20 Member States with about 
37000  kilometres  and  has  ample  capacity  availability  to  absorb  heavy  freight  traffic  across 
main  industrial  areas,  in  particular  over  the  cross-border  regions  linked  by  the  Rhine,  the 
Danube  and  other  important  waterways  connections  (e.g.  Seine-Scheldt,  Rhone,  Po,  Elbe, 
etc.).  

The  main  infrastructure  bottleneck  hampering  the  shift  from  road  freight  to  other  modes 
transport  is  at  the  terminal  level:  on  the  one  hand,  a  minimum  density  of  transhipment 
terminals is required to facilitate the shift from road to other modes in different areas of the 
EU;  on  the  other  hand,  the  capacity  of  existing  transhipment  terminal  needs  to  cope  with 
overall freight traffic growth. These issues affect primarily the road/rail intermodal transport 
and the situation is different from one country to the other:  

64   COM(2001) 370 final 

65  

"Investments  to  modernise  the  rail  network  and  the  transhipment  facilities  have  been  insufficient  to  address  the 
bottlenecks in multimodal transport." - SEC(2011) 358 final – Impact Assessment of the 2011 White Paper  

66   http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+TA+P8-TA-2015-

0310+0+DOC+PDF+V0//EN 

67   REGULATION (EU) No 1315/2013 

21 

 
                                                 
- 

from  a  density  of  terminal  viewpoint,  and  as  illustrated  in  Annex  668  ,  the  distances 
between rail/road terminals on the EU TEN-T Core and Comprehensive networks are still 
well above 300km in many regions; limiting the possibility of short (> 150km) road legs 
in case intermodal transport would be selected by a shipper or freight forwarder. As can 
be observed on the map, the density of terminals is quite high and currently sufficient in 
Benelux, Germany, Austria and Northern Italy; it is also the case in Czech Republic and 
Slovakia; however, in certain specific regions (North of Sweden or Finland) cases, the low 
terminal density is such that it is not possible to use intermodal transport; as indicated by 
the International Union for Road-Rail Combined Transport (UIRR) 69 some countries have 
an appropriate overall capacity but inadequate capacity e.g. Hungary, where there are 4 
terminals in Budapest, but none in the countryside, or France where certain regions are 
better  covered  than  others,  or  Romania,  where  only  Western  Transylvania  is  well 
supplied.  :In  addition,  a  recent  study70  on  last  mile  in  rail  infrastructure  identified  that, 
while  last-mile  infrastructure  and  rail  freight  production  systems  will  undergo  further 
concentration  and  the  total  number  of  rail  access  points  in  Europe  will  decrease,  under 
three different scenarios regarding rail freight traffic evolution from 2015 to 2030 (minus, 
trend,  plus),  the  current  number  of  road/rail  intermodal  terminals  (~730  in  2015)  would 
need to increase between 2% and 10 %, with the 5% value for the trend scenario. 

NOTE: It should be noted that the network density of non-road modes is unlikely to ever 
be comparable to that of road. In some countries with low population density, the volumes 
of freight transport are not enough to make investments in intermodal terminals profitable 
for private sector. In some areas the problem is not lack of terminals but lack of non-road 
alternative in general.  

- 

from a terminal capacity viewpoint, there are also differences between regions: there are 
countries with appropriate density, but insufficient capacity already today (e.g. Germany, 
Austria,  and  Northern  Italy).  However,  looking  at  the  2030  time  horizon,  the  above 
mentioned  "last-mile"  study  also  indicated  that  "In  order  to  cope  with  the  forecasted 
volume  growth  of  intermodal  transport,  the  capacity  of  the  existing  terminals  shall  be 
increased ". 

Insufficient investment in Intermodal Infrastructure  

Investment into terminals and connections to provide efficient alternatives to road transport is 
cost  intensive  and  it  is  not  always  considered  a  priority  even  when  supporting  instruments, 
e.g.  TEN-T,  exist.  The  expected  investment  needs  for  building  new  and  increasing  the 
capacity  of  old  intermodal  terminals  for  rail  connections  alone  is  assessed  to  be  4.5  billion 
EUR  until  2030,  according  to  the  pre-cited  last-mile  Study71.  The  investment  needs  are 
heavier  in  some Member States; in particular those  who joined the EU after 2004 and have 
hence had shorter time to implement previous EU initiatives on multimodal transport. 

68   According to TENtec interactive maps -  http://ec.europa.eu/transport/infrastructure/tentec/tentec-portal/map/maps.html 

69   http://www.uirr.com/ 

70   Design features for support programmes for investments in last-mile infrastructure (2016), PWC, CER, HaCon, Panteia, 
http://ec.europa.eu/transport/sites/transport/files/2016-06-rail-final-report-design-features-for-lm-

at 

available 
investments.pdf 

71   Design features for support programmes for investments in last-mile infrastructure (2016), PWC, CER, HaCon, Panteia, 
http://ec.europa.eu/transport/sites/transport/files/2016-06-rail-final-report-design-features-for-lm-

at 

available 
investments.pdf 

22 

 
                                                 
Public  support  from  EU  and  Member  States  funding  mechanisms,  to  drive  investment  into 
sustainable  transport  modes  remains  nonetheless  essential,  and  the  interaction  within  such 
funding mechanism between infrastructure policies objectives and EU climate goals needs to 
be clearly recognised72.  

As further detailed in the REFIT report73, the EU has supported the investment into rail and 
waterborne transport and multimodal terminals through several EU programs including some 
dedicated  ones  (such  as  the  Pilot  Action  for  Combined  Transport/PACT,  1997-2001,  the 
Marco  Polo  programmes,  2003-2013)  and  TEN-T.  Such  support  is  currently  made  possible 
through general multipurpose programmes such as the Multiannual Financial Framework, the 
European  Fund  for  Strategic  Investment  and  the  Connecting  Europe  Facility,  although  not 
dedicated to the development of multimodal infrastructure.  

Some  Member  States  have  introduced  or  renewed  national  support  programs  for  different 
modes  of  supply  as  well  as  for  terminal  building  in  accordance  with  EU  competition  law. 
However, investing in intermodal transport does not feature prominently among the priorities 
of (all) Member States and may not be sufficiently prioritised for MFF, EFSI or CEF funds, 
nor  are  all  Member  States  willing  to  go  through  the  state-aid  notification  procedure  for 
national programs.  

AT  Support for construction of terminals and rail sidings 

2013-2017 

CZ  Aid scheme for the modernisation and construction of CT terminals 

2015-2020 

DE  Support for construction of terminals 

SK  Investment support for equipment 

UK  Freight facilities grant,  Waterborne freight facilities grant 

Table 3. Dedicated national support schemes for intermodal terminals  

2017-2021 

not limited 

2013-2017 

The  previously  referred  "last  mile"  study74  compared  the  effectiveness  of  dedicated 
programmes  and  non-dedicated  programmes  and  concluded  that  dedicated  programmes  are 
more suitable for the development of terminals both in terms of effectiveness and efficiency 
and  ensure  greater  impact.  The  study  notably  pointed  at  the  positive  results  of  the  German 
funding programme for intermodal transport : based on the finding that terminals, which have 
been  financed  completely  privately,  are  not  competitive  to  road  transport,  the  programme 
provided a relatively high funding rate (up to 80%) for intermodal terminals, in order to cope 
with the high initial construction costs required for the terminals, obliging the private terminal 
operators  to  charge  high  transhipment  fees,  and  in  turn  endangering  the  competitiveness  of 
intermodal services, especially in transport distances below 400 km. Thanks to the investment 
support, a significant reduction of transhipment costs in inland facilities up to 22 € per loading 
unit could be observed.  

72   EU Strategy for Low-Carbon Mobility, COM (2016) 501 final 

73   SWD(2016) 140 final 

74   Design features for support programmes for investments in last-mile infrastructure (2016), PWC, CER, HaCon, Panteia, 
http://ec.europa.eu/transport/sites/transport/files/2016-06-rail-final-report-design-features-for-lm-

available 
at 
investments.pdf  

23 

 
                                                 
Having  dedicated  financial  support  for  intermodal  infrastructure,  complemented  by  other 
support  measures  in  the  Directive  and  by  the  package  of  other  measures  required  and 
undertaken  (e.g.  review  of  Eurovignette  Directive,  further  implementation  of  rail  freight 
corridors, etc...) to support modal shift would be very helpful to address the general problem. 

Obviously, any infrastructure investment to address terminal capacity shortage or to build new 
terminals needs to be based on a detailed analysis of the market needs and conditions and an 
ex-ante assessment of the impacts75, both locally and at European level, taking into account 
the  effects  of  complementary  measures.  This  would  imply  and  require  coordination  at 
European  level  to  notably  avoid  that  unused  capacity  would  be  built.  Such  coordination 
should be included to any new investment support measures for transhipment terminals. This 
would ensure such additional investment would not result in unused terminal capacity. 

While  the  Combined  Transport  Directive  does  not  contain  any  specific  measures  for 
infrastructure development, a majority76 of stakeholders have notably called for making use of 
the opportunity offered by the amendment of the Combined Transport Directive to make this 
concrete.  It  should  also be  noted  and  reminded  that  the  original  proposal  for  the  Combined 
Transport  Directive  was  accompanied  by  a  proposal  for  targeted  investments  into  the 
intermodal network and terminals; but this proposal was never agreed 

2.1.3.  Modest impact of the Combined Transport Directive 

Combined  transport,  as  defined  in  the  Combined  Transport  Directive,  is  a  specific  type  of 
intermodal  transport  benefitting  from  regulatory  and  economic  incentives.  Despite  the 
absolute  growth  of  "Combined  Transport"  and  intermodal  transport,  its  relative  importance 
compared  to  road  transport  has  been  limited  and,  as  explained  further  below,  specific 
problems  related  to  the  Combined  Transport  Directive  have  been  highlighted  in  the  recent 
2016 REFIT evaluation, that need to be tackled.  

2.2.  The Specific problems and problem drivers of the current Directive  

The  REFIT  evaluation  established  that  the  Directive  does  not  harness  its  full  potential. 
Combined transport has been supported for 25 years and its volume, in terms of tonnes km, 
has indeed grown at twice the speed of road transport, however, problems still exist with the 
implementation  of  the  Directive  and  the  effectiveness  of  its  measures  has  diminished  over 
time.  The  stakeholders  consulted  in  the  open  public  consultation  agreed  that  while  the 
Combined  Transport  Directive  has  been  a  useful  tool  to  improve  the  competitiveness  of 
intermodal transport, it does  not  provide  sufficient  support to  allow equal footing with  road 
transport and does not even allow using the benefits foreseen to the full degree.  

The specific drivers for this modest impact of the Combined Transport Directive are further 
explained below. 

75  

In  its  report  on  the  Marco  Polo  Programme,  the  European  Court  of  Auditors  recommended  that  any  new  funding 
programme "... would require a detailed market analysis of the potential demand from the operators and the taking into 
account 
schemes." 
http://www.eca.europa.eu/Lists/ECADocuments/SR13_03/SR13_03_EN.PDF 

practices 

national 

support 

similar 

best 

of 

of 

76   80% of the respondents of the targeted consultation supported "maximum" infrastructure investment  measure 

24 

 
 
                                                 
2.2.1. 

Ineffective implementation of the Combined Transport Directive  

As  pointed  out  in  the  REFIT  evaluation,  the  implementation  of  the  Combined  Transport 
Directive has proved difficult for all stakeholders due to a number of issues.  

As  already  explained  in  section  2.1.1.1  above,  one  of  the  controversial  issues  in  the 
implementation  of  the  Directive  has  been  the  perception  by  some  Member  States  and  their 
national  road  associations  that  the  "cabotage"  exemption  as  provided  for  in  Article 4  of  the 
Directive  has  been  "abused"  by  road  operators  to  circumvent  the  cabotage  restrictions  of 
Regulation (EC) 1079/2012. The lack of clarity of the definition of the Combined Transport, 
leading to different interpretations between operators and Member States, associated with the 
limited and rudimentary enforcement conditions provided by the Directive, may have indeed 
caused  a  number  of  situations  of  conflictual  appreciation  of  the  cabotage  exemptions.  As 
underlined in the REFIT evaluation, and confirmed in the rulings of the CEUJ, the cabotage 
exemption  of  the  Combined  Transport  Directive  have  fulfilled  their  role  of  promoting 
international intermodal transport and should be maintained. This was also supported by the 
majority77 of stakeholders in the Open Public Consultation. Yet it is also equally important to 
address  the  concerns  of  those  Member  States  and  national  road  associations  to  ensure  the 
most  effective  enforcement  and  hence  avoid  possible  situation  of  circumvention  of  the 
cabotage rules.  

2.2.1.1.  Complex and narrow eligibility criteria 

The  definition  of  Combined  Transport  in  Article  1  establishes  the  eligibility  criteria  for  the 
beneficial regime created by the Combined Transport Directive :  

- 

- 

it covers the transport of goods between Member States where the lorry, trailer, semi-
trailer, with or without tractor unit, swap body or container of 20 feet or more, uses the 
road on the initial  and/or  final  leg of the journey and,  on the  other leg, rail  or inland 
waterway or maritime services. 

the length of the road leg is limited in distance to ensure that long-distance road 
transport is limited. Road leg(s) combined with a maritime/inland waterway leg have to 
be each shorter than 150 km as the crow flies (in direct line). In case of rail-road 
combined transport, the road leg is limited to transport to the nearest suitable rail 
loading and unloading station. 

-  A minimum length of the non-road leg (rail/sea/inland waterway) is also provided. The 

non-road leg has to be longer than 100 km as the crow flies. 

-  The  definition  does  not  cover  CT  operations  within  one  Member  State,  or  between 

one Member State and a third country 

Those criteria were adopted in 1992 as an extension to the ones in the definition of the 1975 
original legal act78 and were meant to focus on and support multimodal transport operations 
with  shortest  possible  road  legs.  The  "nearest  suitable"  part  of  the  definition  was  originally 
and literally meant to limit the use of road to the minimum inevitable. It however proved not 
be very operational and raised since 1992 the most discussions, litigations and uncertainty.  

77   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

78   Council Directive 75/130/EEC 

25 

 
                                                 
As  mentioned  in  the  REFIT  evaluation,  transposition  and  implementation  by  the  Member 
States  is  still  inconsistent  after  25  years.  This  leads  to  practical  problems  that  reduce  the 
effectiveness of the Combined Transport Directive.  

In  particular,  various  modifications  of  the  Combined  Transport  definition  by  the  Member 
States in their national transpositions have led to different ways in which Combined Transport 
operations are treated in the Member States. While the transposition of a directive allows for a 
certain level of flexibility, this should not result in the reduction of the rights provided for in 
the directive nor in the discrimination of service providers. However, it seems that this has not 
been  the  case  with  the  Combined  Transport  Directive  in  some  Member  States.  The 
Commission  has  received  in  recent  years  several  complaints  from  the  industry  facing 
problems  with  national  authorities  causing  delays  and  fines  due  to  non-compliant 
transposition, interpretation and/or enforcement of the Combined Transport definition in the 
Directive. The problem caused by slightly different definitions, even if compliant with EU law, 
was expressly raised in the public consultation by stakeholders.  

Too narrow definition 

The  above  referred  study  carried  out  in  2014  on  the  EU  Combined  Transport  market  (The 
Combined Transport study)79 estimated that two thirds (58.3%) of what Member States and/or 
industry consider as Combined Transport is actually not covered by the Combined Transport 
Directive. This relates to geographic scope as well as limitations on road and non-road legs 
and load units. It should notably be noted that the transport of intermodal load units by ocean 
going vessels or to third countries where there is only road transport in the EU is not normally 
considered intermodal transport by the industry.  

100%

80%

60%

40%

20%

0%

Rail

IWW

SSS

CT covered by CTD

CT in EU not covered by CTD

CT EU-3rd countries

Figure 6 : Combined Transport Directive’s coverage of actual CT volumes 

The geographical coverage applied by Member States varies considerably. According to that 
same study, half of the Member States have extended the intended geographical scope. Some 
have  extended  it  to  national  Combined  Transport  operations,  some  to  any  international 
Combined  Transport  operations  (including  those  only  between  1  Member  State  and  a  3rd 
country). 

The  Directive  currently  covers  only  operations  between  Member  States  and  not  within 
Member States or with third countries. Actors in the Combined Transport industry (between 

79   KombiConsult 

et 

al, 

2015, 

Analysis 

of 

EU 

Combined 

Transport 

market,  

http://ec.europa.eu/transport/sites/transport/files/themes/strategies/studies/doc/2015-01-freight-logistics-lot2-combined-
transport.pdf  

26 

 
 
                                                 
65 and 80%)80 have emphasized that the scope of the Combined Transport Directive should 
not  be  constrained  to  operations  between  Member  States  as  different  definitions  create 
additional legal costs for the industry. This concerns in particular national combined transport 
operations (19.3% of all combined transport in EU) that are currently not covered and thus do 
not  benefit  from  the  support  measures  foreseen  by  the  Directive,  while  the  negative 
externalities  such  as  greenhouse  gases  impact  the  EU  beyond  national  borders.    Note  :  an 
extension  of  the  Combined  Transport  Directive’s  scope  to  transport  within  a  Member  State 
and with third countries was also included in a 1998 amendment proposal.  

Different distance limitations for different modal combinations 
About 60% of respondents to the targeted consultation81 considered it a practical problem that 
different  limitations  on  distances  per  mode  apply  to  rail-road  combined  transport  and 
waterborne  combined  transport  and  favoured  modifications  to  these  limitations.  It  has  also 
created problems in certain Member States for the enforcement as controlling officers apply 
the  more  restrictive  limitation  on  all  combinations.  In  certain  cases  where  the  combined 
transport operation involves both, rail and waterborne transport, it is unclear which limitations 
should apply.  

As  illustrated  in  table  4  below,  the  average  and  mean  distances  in  different  modes  diverge 
quite significantly between different modal connections82:  

-  For  inland  waterways,  both  the  non-road  and  the  road  legs  tend  to  be  rather  short 
meaning  that  it  is  the  limit  on  the  non-road  leg  (i.e.  min  100  km)  in  Combined 
Transport Directive that excludes the operations from receiving support. Considering 
also that 50% of IWW/road operations are intra-MS, only 36% of the total IWW/road 
freight transport on EU territory is eligible under the CTD definition. 

It is noted that a limit of 150 km83 for rail-road Combined Transport, would cover both 
the average and mean road legs.  

For short-sea shipping, the mean road leg distances fall within the Combined Transport 
directive, but the average distance is almost two times longer than the current limit. This 
relates mostly to long road legs in combination to feeder traffic for ocean going vessels, 
in  particular  in  areas  where  there  are  little  possibilities  to  carry  the  longer  continental 
distances by rail to the port.  

- 

- 

Intermodal transport  

Non-road leg within the EU (km) 

Road leg, one-side (km) 

sector /                           

Intermodal Transport  
market segment 

Average 
length 

Median 
length 

Longest 
identified 

Average 
length 

Median 
length 

Longest 
identified 

Rail/Road CT 

Barge/Road CT 

Shortsea/Road CT 

615 

222 

760 

580 

140 

1 280 

2 500 

1 400 

7 000 

51 

21 

257 

40 

10 

98 

375 

360 

900 

80   Between  65  and  80%  of  respondents  to  the  Open  Consultation  consider  that  extending  the  geographic  scope  of  the 

Combined Transport Directive would provide a positive impact 

81   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

82  

ISL+KombiConsult (2017), Updating EU combined transport data – Final Report 

83   An intermodal transport usually involves transportation of empty load unit before and after the road leg (to and from a 
depot). There is no information that the transport of empty load units is counted into these limits in any of the Member 
States currently, though problems on the road have been occasionally reported. 

27 

 
                                                 
Table 4. Average and median distances of intermodal transport 

It  should  be  noted  that,  as  reflected  in  the  stakeholder  meeting  of  30  March  2017,  an 
inflexible limit would most likely result in reverse shift, that is to say the transport organiser, 
being unable to use the beneficial regime of combined transport (in particular the additional 
weight allowed) due to some kilometres too many, would use road only transport to make the 
ends meet.  

Limitations on the number of road legs 

First, some Member States interpret the Directive differently from the common understanding 
when it comes to the number of road legs included. The language in the definition in English 
says "… initial or final leg”. Some Member States interpret this as allowing only one road leg 
per  full  journey  (exclusive  or),  while  others  require  that  there  have  to  be  two  road  legs 
(excluding container hinterland transport). The 1998 amendment proposal suggested that the 
problem  is  one  of  translation  as  in  the  French  version  the  question  does  not  arise.  The 
Combined  Transport  Directive  itself  uses  also  “and”  and  “and/or”  in  other  parts  of  the 
Directive. Taking into account the objectives of the Combined Transport Directive, there is no 
justification  for  limiting  the  Combined  Transport  operation  to  one  road  leg  or  requiring 
always two legs.  

The definition further introduces limits on road legs, and for the rail-road combined transport 
it uses the term "nearest suitable rail loading station" that has caused considerable problems to 
the industry. While most stakeholders agree that “nearest suitable” would be the best available 
definition if it would be left to the businesses to decide what is suitable. However this is not 
the case and as much as 60% of the stakeholders indicated in the public consultation that it 
causes  them  and  national  authorities  practical  problems  as  it  is  hard  to  enforce  and  often 
leaves large discretion to the police officer carrying out the road side checks. Furthermore the 
transposition  and  implementation  of  this  term  varies  between  Member  States  and  the 
difficulty to enforce creates problems resulting in confusion particularly in relation to the road 
cabotage  rules  and  the  weights  and  dimensions  rules.  At  least  6  Member  States  have 
established  criteria  to  define  'suitability'  that  do  not  derive  from  the  Combined  Transport 
Directive and some of which are clearly discriminatory (such as requirements that the station 
has  to  be  on  the  territory  of  the  Member  State  or  approved  by  the  Member  State)  or 
impractical  (such  as  not  taking  into  account  whether  services  towards  the  desired  transport 
destination exist in the nearest terminal). The question on "suitability" was addressed to the 
CJEU in case C-305/06, however the court did not deliberate on that question as it reached its 
decision based on the "cabotage" question.  

Minimum distance requirements for the non-road leg 

As  regards  the  requirement  of  a  minimum  distance  of  100km  for  the  non-road  leg,  the 
majority  of  operations  run  on  considerably  longer  distances,  in  particular  due  to  fact  that 
combined  transport  only  makes  economic  sense  due  to  the additional  transhipment  costs  on 
longer distances. 99.5% of rail-road operations are on distances longer than 100km, 99.94% 
of  container  short-sea  shipping  and  95%  of  inland  waterways  operations  between  Member 
States.  

However, only 69.655 of roro short-sea shipping is on distances longer than 100 km, as are 
many (mostly national) Inland Waterways operations. Thus a range of waterborne Combined 
Transport  services  operate  over  significantly  shorter  distances.  In  principal  two  types  of 
operations have shorter non-road legs: first, the barge services feeding containers between the 
ports  such  as  of  Antwerp  or  Rotterdam  and  terminals  in  the  immediate  hinterland.  Those 
operations  contribute  greatly  to  decongesting  the  road  networks  in  sea  ports  and  in  the 
immediate  hinterland  and  to  reducing  environmental  burdens  in  agglomerations.  Secondly 

28 

 
island connections and some ferry crossings by short-sea shipping such as Calais-Dover and 
Puttgarden-Rødby.  While  the  latter  option  would  normally  be  used  with  or  without  support 
and it doesn’t bring along modal shift, the short IWW services around ports and in and around 
agglomerations contribute considerably to the objectives of reducing negative externalities.  

Dimensions and identification of load units 

With regard to load units, the definition covers the vast majority of intermodal load units in 
use today84. However, the restriction of the Combined Transport Directive to load units of 20-
feet (6m) length hinders the opportunity to introduce smaller Combined Transport load units 
that  are  used  in  some  parts  of  the  world,  mostly  in  urban  environments  and  environments 
where  bigger  vehicles/barges  cannot  approach.  With  growing  urbanisation,  these  load  units 
can  become  increasingly  important  in  the  future  in  the  EU.  Making  Combined  Transport 
services  more  flexible  and  allowing  smaller  load  units  (which  can  be  combined  and 
redistributed at hubs) could potentially encourage more users to shift freight away from road. 
This view was supported by the respondents85 of the public consultation who claimed that the 
legislation should allow new innovations to benefit from the Combined Transport Directive in 
order not to shift these load units to the road.  

Another issue raised notably by operators of road/rail combined transport relates to the fact 
that  not  all load  units  are  identified in  standardised  ways  slowing  down  the  handling  of  the 
load  units  in  terminals  as  well  as  not  allowing  or  reducing  the  possibilities  to  implement 
technological solutions to follow the identified load unit throughout the operation, to gather 
data  on  load  units  and  thus  intermodal  transport  in  general.  Furthermore,  standardised 
identification  of  load  units  would  also  simplify  the  control  of  eligibility  for  the  combined 
transport  support  measures  as  it  would  be  easier  to  identify  the  load  unit  through  different 
modes of supply, in particular when using information technology means. 

2.2.1.2.  Lack of effective enforcement conditions 

Conditions  for  proof  of  eligibility  are  particularly  important  for  the  regulatory  benefits  in 
Articles  2,  4,  7  and  9  of  the  directive  as  well  for  the  additional  weights  and  dimensions 
allowed on the road leg from the Weights and Dimensions Directive. As mentioned above, it 
is particularly important for justifying the exemption from cabotage restrictions as provided in 
Article  4,  and  which  has  given  rise  to  many  complaints  and  sometimes  infringements  cases 
related to the potential abuse of such Article by "pseudo" Combined Transport operators. The 
requirements on the transport documents used for proof of eligibility are established in Article 
3 in turn refers to Council Regulation Nr 11 from 1960.  

Information to be provided for control 

In  order  to  check  the  eligibility  for  support  from  the  Combined  Transport  Directive,  the 
controlling authorities should be able to check that the operation involves at least 2 Member 
States, that the load unit is one of those listed in Article 1, that the non-road leg is more than 
100  km,  and  the  road  leg  in  question  is  less  than  150  km  as  the  crow  flies  in  case  of  a 
connection with waterborne transport or to the nearest suitable rail loading station in case of a 
combination  with  rail  transport.  However,  the  required  information  in  the  current  Directive 
covers only half of this information since it is related only with the road leg. No information 

84   TRT (2017)  – Gathering additional data on EU combined transport – Final report  

85   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

29 

 
 
                                                 
is required on non-road legs nor whether the operation is at least between two Member States. 
Furthermore, the controller has to establish the length of the legs as the crow flies. This results 
in confrontations and delays on the road due to different interpretations86.  
A vast majority (80%) of public consultation respondents consider it very important that the 
operators  are  able  to  prove  that  they  are  engaged  in  Combined  Transport  operations.  While 
agreeing  with  the  need  to  be  able  to  establish  eligibility,  many  operators  claim  to  have 
encountered  problems  linked  to  documentation  requirements,  mostly  causing  delays  and 
additional  costs  and  during  the  stakeholder  meeting  of  30  March  217,  stakeholders 
unanimously  concluded  that  paper  documents  and  stamps  as  proof  of  eligibility  were 
outdated. The road hauliers claim it to be difficult to acquire documentation from a Combined 
Transport manager showing also the other legs of the journey. The respondents to the targeted 
consultation  agreed  that  being  able  to  prove  the  eligibility  is  important  for  an  effective 
enforcement  and  for  avoiding  problems.  Member  States  in  particular  pointed  out  that  it  is 
important  that  the  data  required  corresponds  to  the  eligibility  criteria  established  in  the 
definition.  

Format of information provided 

With regard to the format of the information provided, the only condition in the Directive is 
that is has to be a paper document stamped on the final leg and available in the vehicle. The 
stamp requirement has been identified87 by all stakeholders in the stakeholder meeting of 30 
March 2017 to be a particular problem as stamps are no longer used in many countries and 
hence prove impossible to acquire. 
The choice of transport document type is expressis verbis left to the operators88 and there are 
a multitude of formats available. It should be recalled that under international transport law, 
transport documents constitute a civil contract between the shipper and the transport operator, 
and as the conditions for operation in different modes are  different, the standard documents 
are  also.  This  means  that  the  industry  can  use  for  example  a  CMR89,  a  CIM90,  a  national 
transport  document,  a  company-related  consignment  note,  a  bill  of  lading  or  a  multimodal 
document etc., and Member States are not allowed to request a specific format as long as the 
information referred to in Article 3 of the Combined Transport Directive and in Article 6(1) of 
Regulation  No  11  of  1960  is  given.  However  in  reality  several  Member  States  have 
established requirements on types of documents accepted, which is not in compliance with the 
Directive. 

It  should  be  noted  that  some  operators  as  well  as  public  authorities  would  prefer  to  have  a 
harmonised  Combined  Transport  or  multimodal  transport  document  made  mandatory. 
However as the transport document is also a civil contract, harmonisation would require also 

86  

Industry has launched several complaints on this issue; however there has been only one infringement case, Commission 
v.  Greece  (C-305/06).  The  court  considered  that  the  Greek  authorities  were  not  able  to  determine  that  it  was  a  CT 
operation based on the documents provided and hence their action for illegal cabotage was justified 

87   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

88   Article 6(3) of Regulation No 11 of 1960 as last amended by Regulation (EC) No 569/2008 states that "Where existing 
documents such as consignment notes or any other transport document give all the details specified /…/ carriers shall 
not be required to introduce new documents". 

89   Convention on the Contract for the International Carriage of Goods by Road is a United Nations convention signed in 
Geneva on 19 May 1956. Based on the CMR, the International Road Union (IRU) developed a standard CMR waybill 

90   Uniform Rules concerning the Contract of International Carriage of Goods by Rail (CIM) - Appendix B to Convention 

concerning International Carriage by Rail, 9 June 1999, applicable with effect from 1 July 2006 

30 

 
                                                 
harmonisation of civil liability regimes, and any new liability regimes would need to take into 
account  the  contractual  nuances  needed  for  different  modes  of  transport.  The  issue  of 
simplifying  the  contacts  with/controls  by  the  authorities  can  be  solved  easier  through  the 
introduction  of  harmonised  electronic  data  exchange  formats/electronic  documents,  while 
allowing  the  industry  the  contractual  freedom  in  civil  law  matters.  The  ability  to  use 
electronic documents/data for control purposes is widely supported by the industry. A specific 
recommendation  in  this  sense  has  been  made  in  the  context  of  the  Digital  Transport  and 
Logistics  Forum91,  an  expert  group  set  up  by  the  Commission  with  a  view  to  assist  it  in 
supporting  digitalisation  processes  in  the  transport  and  logistics  sector.  The  Commission  is 
currently  in  the  process  of  formally  launching  a  new  initiative  aimed  at  ensuring  the 
acceptance  of  the  electronic  transport  documents  (for  all  transport  modes)  by  the  Member 
States authorities92.  
2.2.2. 

Ineffective and insufficient economic support 

While the industry perceives economic support and notably fiscal stimulation as an effective 
way  of  reducing  heavy  costs  borne  by  intermodal  operators  and  consequently  as  a  way  for 
allowing  intermodal  services  to  compete  with  long  distance  road  transport  on  price,  the 
Directive  did  not  allow  to  generate  the  full  expected  benefit  from  such  measures  due  to 
several reasons. 

2.2.2.1.  Narrow scope of the support measures 

The main problem with the current support measures, as defined in the Directive, is the very 
limited  scope  they  have.  Article  6.1  obliges  Member  States  to  reduce  or  reimburse  taxes 
charged to road vehicles either by a standard amount or in proportion to the journeys that such 
vehicles undertake by rail, i.e. where the vehicles (and not containers) are loaded on a train 
(also called "rolling road" operations). This means that Article 6.1 support is in principle only 
applicable  to  ca  2%  of  intermodal  operations  in  the  EU.  Furthermore,  these  rebates  are 
granted by the Member State in which the vehicles are registered on the basis of rail journeys 
carried  out  only  within  this  Member  State.  Other  kinds  of  Combined  Transport  involving 
inland waterways or short sea transport or rail-road transport of containers do not benefit from 
Article 6.1. In the open consultation93, stakeholders confirmed the problem and suggested a 
wider  range of  economic support measures to make the Combined Transport industry more 
attractive, ranging from dedicated grants for combined transport terminals to a tax reduction 
on scheme extension to all sectors and types of operations, or incentives for the introduction 
of innovative ICT solutions and technologies to reduce CO2 emissions such as cleaner trucks.  

2.2.2.2. 

Insufficient economic support 

The  transposition  and  implementation  of  the  support  for  combined  transport  is  far  from 
homogeneous.  Merely  17  Member  States  have  adopted  schemes  for  the  reimbursement  of 
vehicle taxes (and only 14 actually implement them), however often with conditions different 
from Article 6.1. This means that half the Member States do not actually provide economic 
support foreseen in the Directive.  

91   http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3280  

92   The 

inception 

impact  assessment  was  published  by 

the  Commission 

:  https://ec.europa.eu/info/law/better-

regulation/initiatives/ares-2017-2546864_en  

93   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC). 

31 

 
                                                 
As  the  Combined  Transport  Directive  is  not  very  clear  on  the  methodology  to  be  used, 
Member States have adopted various approaches some quite far from the Directive’s text. For 
example, though the calculation basis is given in the Combined Transport Directive to be the 
length of the rail journey, various Member States are using different criteria, e.g. number of 
performed journeys, time of rail services' usage, driven distances, number of transhipments or 
operating periods. Some Member States have schemes in place that go beyond the measures 
foreseen in the Directive mostly by covering all rail operations as well as inland waterways 
operations94 and several Member States have measures in place not foreseen in the Directive. 
8  Member  States  have  implemented  no  support  measures  for  Combined  Transport  at  all. 
Figure 7 below illustrates how many Member States are applying the listed types of support 
measures.   

Exemptions from road tolls

1 

Reduction of rail track access charges

2 

Investment grants

4 

Exemptions from driving bans

Operational support

Road tax reductions

6 

8 

14 

0

2

4

6

8

10

12

14

16

Figure 7 . Number of Member States applying different types of support measures  

An additional issue are the very wide differences of the levels of support between the Member 
States  as  Article  6  does  not  harmonise  the  reimbursement  levels.  The  tax  reductions  range 
from  10%  to  100%,  are  applied  on  already  varying  vehicle  tax  levels,  amounting  to  fixed 
amount support from €1 to €50 per operation. To put this into perspective, the main additional 
cost element when comparing to road transport, the transhipment cost is on average €50 per 
handling  and  there  are  on  average  2  transhipments  per  operation.  In  countries  with  lower 
reimbursement  levels  or  a  lower  vehicle  tax,  the  actual  benefit  per  shipment  is  therefore 
minimal  (less  than  1%  of  costs).  This  was  supported  by  several  respondents  (mainly 
operators) to the public consultation, who pointed out that the levels of incentives of Article 
6.1  are  insufficient  today.  In  the  targeted  consultation,  stakeholders  (Combined  Transport 
operators)  suggested  on  average  that  an  increase  of  the  economic  benefit  of  27  %  was 
required to achieve to achieve a cost-neutral alternative to road based service.   

As  regards  the  possibility  offered  by  Article  6.2  to  fully  exempt  road  vehicles  engaged  in 
Combined  Transport  operations  from  vehicle  taxes,  it  applies  only  to  road  vehicles  used 
exclusively  in  Combined  Transport  operations.  Respondents  to  the  public  consultation  had 
signalled95 that it is economically not viable to use some vehicles exclusively for Combined 
Transport  (or  to  prove  it).  In  any  case,  according  to  the  so-called  Combined  Transport 
Study96, only three Member States make use of this provision. 

94   Any such support in so far as it involves State resources, is imputable to the State, grants a selective economic advantage 
to  its  recipient,  affects  competition  and  trade  between  MS  (cf.  Article  107(1)  TFEU),  should  be  subject  to  State  aid 
control 

95   SWD(2016) 140 final - REFIT ex-post evaluation 

96   KombiConsult 

et 

al 

(2015), 

Analysis 

of 

EU 

Combined 

Transport 

market, 

http://ec.europa.eu/transport/sites/transport/files/themes/strategies/studies/doc/2015-01-freight-logistics-lot2-combined-
transport.pdf  

32 

 
 
                                                 
2.2.2.3.  Limited monitoring and lack of review mechanism 

The current Directive does not foresee an automatic review mechanism for economic support 
creating a situation where support measures will get outdated and end up being either too low, 
as now, or potentially also too high if the framework conditions change. This is in addition to 
the  difficulties  in  the  currently  foreseen  monitoring  and  reporting  mechanism:  while  the 
Commission is due to report based on data provided by the Member States, this has not been 
possible because of the lack of systematic data collection on Combined Transport, resulting in 
difficulties  to  adequately  assess  the  effectiveness  and  efficiency  of  measures  on  a  regular 
basis  (for  further  details  see  chapter  9).  Almost  all  respondents  to  the  open  public 
consultation97 considered that it was important to collect and publish regularly all Combined 
Transport data.  

3.  TACKLING THE PROBLEM 

3.1.  Evolution of the problem all things being equal (baseline scenario) 

According  to  the  baseline  scenario  (see  Annex  4  for  details)98,  under  current  trends  and 
adopted  policies,  road  freight  activity  (measured  in  tonne-km)  is  projected  to  increase  by 
about  35%  between  2010  and  2030  (56%  for  2010-2050).  CO2  emissions  from  road  freight 
transport  would  increase  by  6%  by  2030  compared  to  2010  (11%  for  2010-2050).  Without 
intervention,  this  would  not  allow  to  achieve  the  2030  emission  reduction  targets99,  would 
cause high levels of air pollution and congestion and negative effects to the wider economy 
through several direct and indirect effects. These  effects are assessed to be in  2030 roughly 
€27 billion for air pollution and over €100 billion for accidents, while costs from noise would 
increase by 17% and congestion costs by 24%. More details on the projections under current 
trends and adopted policies (i.e. the baseline scenario) of the different modes in terms of e.g. 
energy  consumption,  GHG  emissions  or  congestion can  be  found  in  Annex  4  of  the  Impact 
Assessment accompanying the review of the Eurovignette Directive100. 
In particular, under the baseline scenario, and without additional intervention, i.e. notably the 
review  of  the  Eurovignette  Directive,  the  application  of  the  "polluter  pays  principle"  would 
not be completed and there would not be a fair and efficient level playing field across modes 

97   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

98   The  baseline  scenario  builds  on  the  EU  Reference  scenario  2016  but  additionally  includes  some  updates  in  the 
technology costs assumptions (i.e. for light duty vehicles) and few policy measures adopted after its cut-off date (end of 
2014) like the Directive on Weights and Dimensions, the 4th Railways Package, the NAIADES II Package, the Ports 
Package, the replacement of the New European Driving Cycle (NEDC) test cycle by the new Worldwide harmonized 
Light-vehicles  Test  Procedure  (WLTP).  It  has  been  developed  with  the  PRIMES-TREMOVE  model  (i.e.  the  same 
model used for the EU Reference scenario 2016) by ICCS-E3MLab. A detailed description of this scenario is available 
in the Impact Assessment accompanying the Proposal for a Directive amending Directive 1999/62/EC on the charging 
of heavy goods vehicles for the use of certain infrastructures, SWD (2017) 180 

99   The  Energy  Union  and  the  Energy  and  Climate  Policy  Framework  for  2030  establish  ambitious  EU  commitments  to 
further reduce greenhouse gas emissions (by at least 40% by 2030 compared to 1990). Transport will need to contribute 
towards the 40% greenhouse gas emissions reduction target for 2030 and in particular to the 30% emissions reduction 
effort set for the non-Emission Trading Scheme sectors. In this context, the analytical work underpinning the European 
Strategy  for  Low-Emission  Mobility  showed  cost-effective  emissions  reductions  of  18-19%  for  transport  by  2030 
relative to 2005. For road transport, this translates into a cut of about 206-221 million tonnes of CO2 by 2030 relative to 
2005 

100   SWD(2017) 180 final -in particular Chapter 2.1 and Annex 4 thereof 

33 

 
                                                 
of  transport  :  financial  support  measures  will  be  needed  in  the  support  of  sustainable  and 
socially equitable transport to address the "unfair pricing" between modes.  

3.1.1.  Competitiveness of intermodal transport 

As regards the competitiveness of intermodal transport (>300km) compared to road transport, 
it  should  first  be  noted  that  the  proposal  for  an  amendment  of  the  Eurovignette  Directive 
would  have  a  slight  influence  depending  on  the  final  option  adopted.  In  the  accompanying 
Impact Assessment101 the road transport costs are projected to increase between 0.2% and 2% 
(1.1%-1.5%  for  the  two  preferred  options).  This  however  does  not  sufficiently  address  the 
price difference between intermodal transport and road transport as will be outlined below.  

As  explained  above,  the  current  regulatory  support  provided  by  the  Combined  Transport 
Directive  applies  to  less  than  half  (41.7%102)  and  economic  support  to  less  than  2%  of 
intermodal transport operations and is too low to have an effect.  
Under current conditions, and based on average market prices103 the intermodal transport as 
a whole remains on average 23% more expensive for shippers to use than unimodal road 
transport. According to same market prices, the operations that are covered by the Directive 
and benefit from regulatory and limited economic support (i.e. "Combined Transport") remain 
13% more expensive on average than road only transport.  

As  explained  in  section  2.1.1.1  above,  it  is  also  important  to  remember  that,  besides  these 
market prices differences, the shippers  are facing "additional" costs from delays, transaction 
and legal costs, which are not all fully reflected in the market prices.  

Figure 8 below illustrates the estimated additional cost of intra-EU intermodal transport (all 
and Combined Transport only), compared to road transport (based on referred 2017 Study104). 
This  means  that,  economically,  shippers,  freight  forwarders  and  logistics  service  providers 
would, in the absence of supporting measures, have little motivation to shift from road only 
transport to intermodal transport.  

Baseline IM ( all)

Road; 29 

Non-road; 39 

Transhipment; 30 

Reduced loading 
capacity; 6 

Cabotage; 4 

Baseline IM (CT portion of it)

Road; 29 

Non-road; 39 

Transhipment; 30 

Unimodal road transport

Road; 100 

Additional costs 
(implementation, 
delays, transaction 
costs etc); 40 

0

20

40

60

80

100

120

140

160

Figure 8  .  The  competitiveness  of  intermodal  transport  (all and  Combined  transport only)  in baseline scenario 
based on comparing costs and cost components, in percentages 

101   SWD(2017) 180 final 

102   ISL+KombiConsult (2017), Updating EU combined transport data – Final Report  (256 bn tkm intra-EU CT Vs 614 bn 

tkm of intermodal transport) 

103   KombiConsult-Hacon (2015), Gutachten zur Evaluierung des Förderprogramms für Umschlaganlagen des Kombinierten 

Verkehrs Aktenzeichen Z30/SeV/288.3/1440/G22 

104   TRT (2017)  – Gathering additional data on EU combined transport – Final report 

34 

 
 
                                                 
To increase the competitiveness of combined transport can be translated in bringing down for 
each of the sub-modes, the break-even distance under which the combined transport operation 
becomes "competitive" compared to road only transport. Measures having an effect on all the 
above mentioned cost components should be explored, including the public support measures. 
As an example, the CT Cost Study105 estimates that for rail/road intermodal, "the effect of the 
public sector support is to reduce the average breakeven distance by 70 - 90 km or about 13-
14% of the breakeven distance without any support". 

3.1.2.  Achieving modal shift target 

The projection for achieving the modal shift target set in the 2011 White Paper is somewhat 
difficult  as  Eurostat  is  only  starting  to  gather  detailed  data  on  freight  transport  distances  in 
different modes106. Eurostat does however gather data on road transport distances and recent 
data  shows  that  during  the  last  5  years  there  has  been  no  progress  in  reducing  the  long-
distance  road  transport's  share  which  is  for  all  years  around  56%  of  total  road  freight 
transport. 

Taking  into  account  that  the  modal  shift  in  freight  transport  essentially  means  shift  to 
intermodal  transport,  the  growth  projections  of  intermodal  transport  in  the  EU  are  used  as 
proxy  for  modal  shift  calculations.  Based  on  the  projections  established  in  the  Combined 
Transport  Study107  and  its  update108,  two  scenarios  were  developed  to  reflect  the  possible 
developments  of  the  intermodal  market  and  combined  transport  uptake  until  2030.  The 
analysis takes into account the developments that  took place during the economic crisis and 
the  following  recovery  as  well  as  developments  regarding  the  road  transport  market,  in 
particular  as  regards  fuel  price  and  possible  regulatory  developments  (e.g.  the  proposal  for 
amendment  of  Eurovignette  Directive).  The  latter’s  impact  assessment  projects  a  limited 
modal shift, i.e. decrease of 0.1-0.2 percentages points in road transport modal share in 2030, 
equal to 3.5-7 bn tkm. This does not eliminate the gap between the White Paper target and the 
current projections for 2030.  

The  optimistic  scenario  is  based  on  the  assumption  that  sectoral  legislation  in  rail,  inland 
waterways and short sea shipping will follow the path of further liberalisation and facilitation 
of  cross-border  operations,  including  harmonisation  or  mutual  recognition  of  standards  and 
qualifications as well as removal of main technical barriers still existing. The trend scenario 
assumes small-to-moderate progress in tackling the technical barriers.  

105   TRT (2017)  – Gathering additional data on EU combined transport – Final report 

106   The implementation report of the 2011 Transport White Paper, SWD(2016) 226 final, suggested that the EU modal shift 
target can be expressed as percentage points decrease in the modal share of road freight over 300 km in the total freight 
transport over 300 km. More specifically, this implies a 4 percentage points decrease by 2030 and 9 percentage points 
decrease  by  2050  relative  to  the  2005  shares  based  on  the  modelling  scenarios  carried  out  to  support  the  impact 
assessment  of  the  Transport  White  Paper.  According  to  the  data  currently  available,  72%  of  transport  activity  is 
performed  on  distances  above  300km.  In  road  transport,  the  share  of  long  distance  activity  is  56%.  For  maritime 
shipping,  most  activity  is  long  distance.  Rail  transport  constitutes  13%  of  long  distance  freight  transport  in  EU  and 
inland waterways transport represents 3% of long distance freight transport in EU 

107   KombiConsult 

et 

al 

(2015), 

Analysis 

of 

EU 

Combined 

Transport 

market, 

http://ec.europa.eu/transport/sites/transport/files/themes/strategies/studies/doc/2015-01-freight-logistics-lot2-combined-
transport.pdf  

108   ISL+KombiConsult (2017), Updating EU combined transport data – Final Report 

35 

 
                                                 
3000

2500

2000

1500

1000

500

0
2005

Road freight

Total intermodal
transport (road and
non-road)

Non-road legs more
than 300 km

CT covered by
Directive (road and
non-road)

2015

2030

Figure 9 . Projected growth of road freight, intermodal and combined transport on average, 2030, bn. tkm 

Based  on  the  trend  scenario,  current  conditions  and  adopted  policies,  intermodal  transport 
would increase between 2015 and 2030 with an average growth rate between 2.2% and 2.8% 
(cumulative  rate  28.5%)  reaching  a  level  whereby  intermodal  transport  would  account  for 
32% of road freight transport volume. The operations covered by the Directive would increase 
in this baseline scenario to a volume constituting 14% of road freight transport. Based on the 
optimistic  scenario,  the  growth  rates  of  different  modal  combinations  would  be  between 
2.2% and 4% and the cumulative growth rate of all intermodal transport in the EU would be 
36.4%  for  15  years.  In  this  optimistic  scenario,  intermodal  transport  would  reach  a  share 
34.5%  while  combined  transport  covered  by  the  Directive  would  reach  a  share  of  16%.  An 
average  annual  modal  shift  is  envisaged  to  be  8.8-11.2  bn  tkm  (including  shift  to  non-road 
transport shorter than 300 km).  

According to these projections, the EU will not achieve its modal shift target of shifting 30% 
of long distance road freight transport (301 bn tkm) away from road. The modal shift from 
2005  to  2015  amounted  to  145  bn  tkm.  Intermodal  transport  is  projected  to  grow  slightly 
slower on average between 2015 and 2030 with an additional modal shift of 104 bn tkm. The 
currently  estimated  total  modal  shift  between  2005  and  2030  is  thus  projected  to  reach  on 
average 249 bn tkm. A gap of 52 bn tkm to be shifted remains.  

3000,0

2500,0

2000,0

1500,0

1000,0

500,0

0,0

2005

2015

2030

36 

Road transport <300km, incl CT
road legs

Road freight >300km

Intermodal transport non-road
legs >300km

 
 
 
Figure  10.  Freight  volume  projections  for  long  distance  road  transport  in  relation  to  intermodal  transport,  CT  Study  (+ 
update) in bn. tkm  

3.1.3.  Savings of external costs 

Using the PRIMES-TREMOVE Transport Model and the methodology of the Handbook  on 
External  Cost  of  Transport109  the  external  costs  (air  pollutants,  noise,  congestion,  accidents 
and infrastructure costs) saved by baseline growth of intermodal transport between 2005 and 
2030 amounts  to €5.8 bn. As illustrated in table 5 below the gap of not reaching the modal 
shift target set in the White Paper corresponds to a loss of €1.2 bn in external cost savings and 
in particular to 4.4 Mtons of CO2 emissions that were aimed to be saved.  

Baseline: External cost savings (MEuro'13) 

Modal shift, 2005-2030, bn. tkm 
Accidents 
Noise 
Congestion 
Air Pollution: NOx 
Air Pollution: PM 
Climate change 
Total External costs 

2030 

optimistic  average 
249 
608 
164 
4006 
313 
17 
705 
5813 

252 
615 
166 
4054 
317 
17 
714 
5883 

Trend 
247 
603 
163 
3974 
310,4 
16,5 
699,6 
5766 

Modal 
shift gap 

52 
127 
34 
837 
65 
3 
147 
1214 

Table 5. External costs savings of the baseline development, PRIMES-TREMOVE Transport Model  

3.2.  Why should the problem be tackled now 

The current Commission has set sustainable development as one of its main objectives. The 
agreement  of  the  ambitious  goals  in  the  Paris  Agreement  on  climate  change  and  the 
subsequent policy aims set in the Low-Emission Mobility Strategy have set clear targets for 
the coming years. The latter concludes that comparing developments under the current trends 
and adopted policies (i.e. EU Reference Scenario 2016) with the central scenarios that were 
developed to  achieve  all  the  2030  targets agreed  by  the  October  2014 European  Council110, 
additional policy actions are necessary, especially post-2020, in order to close the gap of 6-7 
percentage points between the desired emission reduction and expected trend scenario results. 
One  of  the  identified  areas  of  action;  i.e.  increasing  the  efficiency  of  the  transport  system, 
comprises  also  the  efficiency  increases  resulting  from  modal  shift.  The  amendment  of  the 
Combined  Transport  Directive  is  thus  listed  as  one  of  the  actions  in  the  Low-Emission 
Mobility Strategy.  

The stakeholder consultations both in 2014 and in 2017 confirm that there is unused potential 
for further modal shift. Furthermore, according to Eurostat, 85.1 million tonnes of freight was 
transported  by  road  already  in  containers  (2014).  Shifting  these  load  units  to  intermodal 
transport would result in a 13% increase of the intermodal transport volume, but the current 
framework has not motivated the shippers to do that.  

109   Update 

External 
http://ec.europa.eu/transport/themes/sustainable/studies/doc/2014-handbook-external-costs-transport.pdf  

Handbook 

Transport, 

Ricardo-AEA, 

Costs 

the 

on 

of 

of 

8.1.2014, 

110   European 

Council 

conclusions, 

24.10.2014, 

http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/ec/145397.pdf  

37 

 
 
                                                 
3.3.  Why should the EU act? 

Negative  externalities,  in  particular  those  relating  to  climate  change  are  trans-boundary 
problems  which  cannot be  solved  by  national  or  local  action  alone.  The  EU  has  worked  on 
reducing negative externalities of the transport sector for more than a quarter of a century as 
one  of  the  objectives  of  the  Common  Transport  Policy  is  to  ensure  the  sustainable 
development of the transport sector. Coordinated EU action is necessary to achieve the goals 
set  in  the  Transport  White  paper  2011,  the  Low-Emission  Mobility  Strategy  and  other  EU 
policies in the area.   

In  addition  to  sustainable  development  issues,  it  is  clear  that  transport  has  an  international 
character (47% of intermodal freight transport is between Member States) and thus the added 
value  of  EU  action  is  obvious  as  the  existence  of  different  regulatory  environments  of 
Member  States  would  create  barriers  and/or  additional  costs  for  economic  operators.  The 
impact assessment accompanying the 2011 White Paper (p24) elaborates at length on reasons 
why the Member States per se are not able individually to meet the challenges of creating an 
EU-wide sustainable and integrated transport system.   

The  Combined  Transport  Directive's  aim  is  the  promotion  of  modal  shift  across  the  EU 
through  support  measures  based  on  common  ground.  A  common  definition  and  common 
criteria are needed to ensure that the benefits foreseen in the Directive are applicable the same 
way throughout the EU, notably considering that from all intermodal transport operations in 
the EU, 81% are cross-border operations. If Member States use different definitions, it means 
that  the  operator  might  not  be  able  to  benefit  from  the  incentives  throughout  the  transport 
chain. Some differences do not create serious problems though they make it more costly for 
operators,  who  would  have  to  be  familiar  with  all  legal  systems  along  the  itinerary.  Others, 
such  as  differences  in  the  load  units  or  transport  documents  allowed,  would  make  it 
impossible to carry out operations or require an additional reloading at the border (which is 
economically not viable).  

The  importance  of  EU  action  is  illustrated  by  the  high  number  of  EU-Pilots  and  the 
infringement  procedures  launched  by  the  Commission  based  on  complaints  by  stakeholders 
who  in  cases  of  incorrect  transposition  or  implementation  have  experienced  first-hand  the 
problems, as described in several sections above.  

As  regards  economic  support,  there  seems  to  be  a  general  consensus  among  the  Combined 
Transport  operators  and  users  that  without  any  support  measures  and  common  EU  rules  in 
place, the majority of current cross-border EU Combined Transport would have been carried 
by single-mode road transport due to inherent disadvantages of Combined Transport such as 
lower loading capacity due to weight of load units, additional cost of transhipment, delay etc. 
It  should  be  noted  in  this  context  that  stakeholders  participating  in  the  public  consultation 
perceived  (55%)  that  without  the  support  of  the  Combined  Transport  Directive,  Combined 
Transport  services  in  the  EU  would  not  have  grown  at  such  a  fast  pace  within  the  last  two 
decades as many operations, in particular in the medium length, would not be economically 
viable111.  
Last but not least, considering the lack of investment in terminal capacity, which is the main 
bottleneck  for  effective modal  shift,  the limited number  of  national  investment  programmes 
have proved useful, but in order to create a necessary EU network of transhipment facilities 
with  sufficient  density,  coordinated  investments  at  EU  level  are  likely  to  be  much  more 

111   29%  of  respondents  considered  CT  also  viable  without  the  CT  Directive;  however  these  were  mostly  the  largest 

companies. 90% of SMEs considered it not viable without support. 16% did not answer that question 

38 

 
                                                 
effective than isolated national interventions. In addition, such new EU investment measures, 
if defined at EU level, could simplify the burden related to the abiding to competition rules, 
notably as regards state aid rules, which would be much simpler. The Commission Notice112 
on the notion of State aid as referred to in Article 107(1) of the Treaty on the Functioning of 
the  European  Union  (2016/C  262/01)  indeed  states  that  "A  measure  is  not  imputable  to  a 
Member  State  if  the  Member  State  is  under  an  obligation  to  implement  it  under  Union  law 
without any discretion. In that case, the measure stems from an act of the Union legislature 
and is not imputable to the State".  

4.  WHAT SHOULD BE ACHIEVED?  

The general objective of the current initiative is to support modal shift by further encouraging 
the  use  of  non-road  transport  modes  on  long  distance  freight  transport  operations,  while 
maintaining  and  reinforcing  the  necessary  regulatory  and  market  measures  for  international 
transport  (e.g.  exemption  from  cabotage  restrictions  and  weight  and  dimension  rules).  By 
aiming at the specific target for modal shift set in the 2011 White Paper, i.e. to shift by 2030 
30%  of  long  distance  road  freight  (over  300  km)  to  rail  or  waterborne  transport,  and  more 
than 50% by 2050, the initiative will in turn reduce the negative externalities of the transport 
system,  such  as  emissions,  noise,  accidents  and  fatalities,  road  congestion  as  well  as  to 
improve  the  efficiency  of  use  of  transport  resources.  A  move  towards  a  more  sustainable 
economic activity is a general objective of the current Commission113. Furthermore, reduction 
of emissions and in particular of greenhouse gases is a key objective of the EU in the light of 
the recent Paris climate deal and supporting modal shift through increased  use  of combined 
transport is included in the Low-Emission Strategy of the European Union.  

The desired modal shift induced by this initiative should take place due to deliberate decisions 
made  by  the  market  operators.  This  means  that  the  amendment  should  improve  the 
competitiveness of combined transport as an alternative to road only transport through simpler 
use  of  the  beneficial  regulatory  regime  and  higher  effectiveness  of  the  economic  support 
measures.  

The specific objectives relate to the identified problems and their drivers, aiming at alleviating 
the underlying root causes as follows : 

1.  Clarify the definition of CT eligibility conditions (SO1).  

The  aim  of  this  simplification  is  to  reduce  the  practical  problems  faced  by  both  the 
industry as well as the authorities. A simpler regime should also motivate the take up of 
combined transport by further market operators. This specific objective should be reached 
by addressing the following specific drivers:  

-  Complex  and  narrow  eligibility  criteria  :  the  definition  of  CT  should  be  reviewed  to 

specify and clarify : 

o 
o 

the geographical coverage;  
the road legs;  

112   http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52016XC0719(05)&from=EN 

113   The  initiative  contributes  to  the  Commission  general  objectives  No.2  "A  Connected  Digital  Single  Market",  No.3  "A 
Resilient  Energy  Union  with  a  Forward-Looking  Climate  Change  Policy"  and  No.4  "A  Deeper  and  Fairer  Internal 
Market with a Strengthened Industrial Base". 

39 

 
 
                                                 
o 
o 

the non-road legs;   
the load units 

-  Lack  of  effective  enforcement  conditions  :  the  elements  required  for  proof  of 

eligibility should be specified and clarified :  

o  Required data 
o  The data presentation format 
o  The place of control 

2.  Further stimulate the competitiveness of combined transport (SO2).   

This  objective  addresses  the  market  failures  and  inherent  disadvantages  of  intermodal 
transport as well as infrastructure problems with an aim to increase the competitiveness of 
combined  transport  by  reducing  end-user  prices.  To  ensure  that  the  measures  remain 
effective  and  efficient,  regular  analysis  and  review  is  necessary.  This  specific  objective 
should be reached by addressing the following specific drivers:  

-  Narrow  scope  of  support  measures  :  extending  the  current  operational  support  (road 

tax deduction for rail/road CT to all modes) should be assessed 

-  Limited monitoring and no review mechanism : measures to reinforce the monitoring 
of  CTD  uptake  and  how  to  review  support  measures  should  be  specified  and/or 
clarified :  

o  Data collection of CTD uptake 
o  Transparency of measures adopted at MS level 
o  Cooperation between MS 
o  Review mechanism of support measures 

3.  Increase the investment in and the capacity of intermodal terminals (SO3) 

This objective addresses directly the problem of lack of intermodal infrastructure and in 
particular the lack of and limited capacity of terminals.  

These  specific  objectives  are  complementary  and  need  to  be  addressed  at  the  same  time. 
Improving  access  and  availability  of  intermodal  infrastructure  is  a  precondition  for  the 
development of intermodal transport. While the simplification of the eligibility criteria may, 
depending on the selected option, result in a change of eligibility as compared to the current 
Directive and thus exclude some of the current beneficiaries, a reduction of practical problems 
is highly desired by both industry and Member States. Simplification of eligibility criteria and 
controls  thereof  is  particularly  important  for  the  use  of  the  regulatory  beneficial  regime 
foreseen in the Directive as it is difficult to ensure correct application of complex definitions 
during road side checks. Furthermore, achieving this will also help to better enforce the EU 
road transport regulations; in particular as regards weights and dimensions and cabotage rules 
as  both  these  EU  instruments  have  a  direct  relation  to  the  Combined  Transport  Directive 
creating a further beneficial regulatory regime. Thus the objectives of the current initiative are 
consistent with the objectives of the other transport initiatives currently pursued.  

The specific objectives were explicitly supported by stakeholders in the consultations taking 
place in the run up to this amendment (open public consultations in 2014 and 2017, targeted 
consultation in 2017 and three dedicated stakeholder meetings between 2014 and 2017).  

40 

 
 
5.  WHAT ARE THE VARIOUS OPTIONS TO ACHIEVE THE OBJECTIVE  

As preparatory work for this impact assessment, the Commission carried out several studies 
and  evaluations  focusing  on  different  aspects  of  the  intermodal  transport  market  as  well  as 
two open public consultations, one targeted consultation and 3 consultation meetings followed 
by literature review and in-house analysis.  

Based on this analysis, the Commission has identified policy measures addressing the specific 
objectives,  and  more  specifically  the  main  drivers  as  listed  above,  and  combined  these  in 
policy packages (options).  

The  policy  measures  addressing  various  root  causes  and  drivers  were  considered  after 
extensive consultations with the stakeholders.  

5.1.  Overview of retained policy measures  

After  a  preliminary  assessment  of  different  policy  measures,  the  following  policy  measures 
where retained for reasons explained below:  

Current measures 

Geographical 
scope 

CT between MS 

Definition 

Road legs 

For rail-road CT, until 
nearest suitable train 
loading station, suitable 
not defined. For 
waterborne connection 
max 150 km. 

in 

of 

the 

reduction 

Measures proposed for analysis 
Extend to national only CT as supporting CT also 
in  national  context  supports  modal  shift  and 
results 
negative 
externalities114. 
For all modal connections allow max 150 km for 
each road leg. Change (negative impact) only on 
rail-road  CT.  Ensures  that  road  legs  are  clearly 
limited  while  allowing  reasonable  catchment 
area. 
For all modal connections limit each road leg to 
150  km  or  20%  of  total  door-to-door  distance, 
whichever  is  longer.  Allows  longer  road  legs  for 
long  CT  operations  (more  than  750km)  to 
alleviate the problem of low-density of terminals 
in  several  regions,  while  at  the  same  time 
allowing 
in  areas  where  due  to  congestion 
shorter CT trips make economic sense to retain a 
reasonable catchment area.  
For  all  modal  connections  limit  road  leg  to 
nearest  suitable  terminal,  if  Member  States  so 
decide.  Combines  the  use  of  "nearest  suitable" 
term  from  the  current  Directive  (applies  to  rail) 
and  from  Weights  and  Dimension  Directive 
(applies  to  waterborne  intermodal  transport). 
The  need  for  longer  road  legs  depends  on 
terminal  density  and  circumstances  of  the 
country.  

114   This proposed measure notably builds on the experience in countries such as Germany or Austria, in which extending 
support to intermodal transport, including at national level, increased uptake. Note: Article 4 (cabotage exemption) has 
its  “own”  geographical  scope  established  in  the  article  ensuring  that  this  exemption  only  applies  to  international 
transport. A change of the definition in Article 1 would thus not impact the scope of application of Article 4.  

41 

 
  
  
                                                 
Non-road legs  Min 100 km 

Load units 

Fixed list, incl. containers  
20 feet+ 

Required data 

Operators choose type of 
transport documents. 
Minimum data 
requirements in 
Regulation 1 from 1960 

Eligibility 
control 

Data 
presentation 

Stamped paper 
documents only. 

Place of 
control 

Document has to be in 
the vehicle for road side 
controls 

Economic 
support 
measures 

Investment 
support 

None in the Directive 

its 

its 

on 

leg 

leg 

data 

is  always  used  to 

is  always  used  to 

No  limitation. Assumes  that profit  maximisation 
by private  economic  operators  ensures  that  the 
non-road 
longest 
possible  length  to  pay  for  the  unit  costs  and 
transhipment costs.  
No  limit  for  non-road  leg  but  for  short  sea 
shipping, exclude island connections as no modal 
shift takes place. 
No  limitation. Assumes  that profit  maximisation 
by private  economic  operators  ensures  that  the 
non-road 
longest 
possible  length  to  pay  for  the  unit  costs  and 
transhipment costs.  
Remove  the  minimum  size  limit  to  allow  future 
innovation (urban transport, e-commerce) 
Limit the application to ISO/CEN standard based 
identified  load  units.  Speeds  the  handling  in 
terminals  and  supports  the  use  of  digitalised 
data.  
No  data  requirement,  operators  can  choose 
their  transport  documents  and  data  on  them. 
International 
transport 
conventions 
documents continue to apply. 
Establish 
that 
new 
correspond  to  eligibility  criteria  to  facilitate 
eligibility  checks.  Operators  can  still  choose  the 
type  of  transport  document  but  have  to  fill 
additional fields. 
Paper + electronic documents. MSs accept both 
for  CT  road  legs,  incl.  pdf/jpg  (operators  to 
decide  on  type  and  format).  Does  not  allow 
digital reuse of data, but is easiest and fastest to 
implement.  
Paper  +  electronic  structured  data:  MSs  accept 
both,  EU  agreed  requirements,  data  standards 
and  architecture  (data  not  centralised,  but 
retrieved on request, applications either private 
or public). 
Paper  in  vehicle  or  electronic  in  vehicles  at 
roadside 
inspection  retrieved  upon  request 
(carrier can contact HQ/shipper/client or app or 
database  and  retrieve 
it  for  presentation). 
Allows  reuse  of  digital data.  Data  can  be  stored 
at  shippers  own  location.  Creates  a  market  for 
new applications.  
Grants  for  building  CT  terminals.  Terminal 
density needs to be increased in several parts of 
the  EU,  while  in  other  areas  terminals  are 
reaching  their  maximum  capacity.  Without 
terminals there is no intermodal transport.  

requirements 

Possibility  to  provide  grants  for  shipper  side 
handling  equipment  investments.  Needed  for 
new  take-up  of  combined  transport  for  those 
shippers  who  would  continue  using  road  only 
transport to avoid high initial investment costs. 

42 

 
Reimbursement  of  road  vehicle  tax  for  all  load 
units in all CT, based on non-road leg distances, 
level of support up to the MS. Paid by MS where 
vehicles  are  registered  on  transport  operations 
in  that  MS.  Extension  of  the  current  scheme  to 
connections  with  all  non-road  modes.  Aim  is  to 
motivate  road  operators  to  switch  to  short 
distance road transport. 
Grant per load unit shipped on CT, based on km 
of non-road transport, level of support up to the 
MS. Paid by MS where the transport organiser is 
established.  Aimed  directly  at  those  choosing 
between  road  and  CT  transport.  Basis  on  non-
road-km  motivates  to  use  most  of  non-road 
transport. 
Reimbursement 
costs, 
harmonised percentage level. Paid by MS where 
the  transport  chain  organiser  is  established. 
Aimed  directly  at  those  operators  choosing 
between  road  and  CT  transport.  Addresses  the 
additional cost of transhipment that is the main 
cost  difference  between  road  only  and  CT 
transport.  

transhipment 

of 

Operational 
support 

Reimbursement of road 
vehicle tax based on rail 
distance for roro rail 
transport. Paid by MS 
where vehicles are 
registered on transport 
in that MS (mandatory). 
Exemption from vehicle 
tax for vehicles used 
exclusively for CT 
(optional) 

Reimbursement  of  road  rail  and  port  (access) 
charges  with  harmonised  percentage  level.115. 
Paid by MS where the transport chain organiser 
is  established.  Addresses  the  issue  of  higher 
infrastructure costs compared to road transport. 
Review  of  economic  support  measures  every  5 
years  at  national  level.  Aims  at  ensuring  that 
support measures are up to date and correspond 
to the needs of the sector.  
Establish  stronger  obligations  for  MS  to  gather 
the  data  and  share  it  with  the  Commission  for 
reporting purposes. 
Establish  a  contact  network  between  Member 
States authorities. 

Establish an obligation to publish rules and 
support measures in a single place.  

Review 

None 

Administrative 
measures 

Data collection 

MS to assist the 
Commission 

Cooperation 
between MS 

None 

Transparency  None 

Table 6: Retained new measures 

The list of discarded policy measures and the underlying justifications are given in Annex 8.  

5.2.  Selection of policy options (and discarded options)  

The  retained  policy  measures  were  combined  into  four  policy  options  (in  addition  to  the 
baseline  scenario),  addressing  each  policy  objective  and  problem  driver,  but  with  different 
levels  of  ambition.  The  precise  measures  and  level  of  ambition  of  each  policy  option  is 
described below. 

Baseline scenario: 

115   Such support measure could be complemented by higher reimbursement for the usage of zero emission vehicles on the 

road leg 

43 

 
                                                 
In  the  baseline  scenario,  the  Combined  Transport  Directive  would  continue  to  apply  in  its 
current form, providing regulatory support to operations covered by current eligibility criteria, 
relying on Regulation 11 from 1961 for information to be provided at road side checks and 
providing  limited  economic  support  to  accompanied  rail-road  combined  transport.  The 
development of this scenario is analysed in section 3.1.  

It  should  be  noted  that  this  option  has  no  support  among  stakeholders.  The  majority  of 
respondents to the public consultation considered that continuing with the baseline scenario 
would have no or a negative impact on their operations (64%), on working conditions in the 
sector (53%) and in particular on the society and the environment (73%).  

Policy option 1: Minimal amendment with focus on simplification.  

Under the policy option PO1 the main aim is to improve the transposition and implementation 
of the existing Directive.:  

-  The geographical coverage remains unchanged (PM1);  

-  Minimal  amendments  will  be  proposed  to  simplify  the  complexity  of  the  eligibility 
criteria  in  particular  as  regards  the  limitation  on  road  legs,  i.e.  single  distance  limit 
(150km) for all modes of transport covered by the Combined Transport (PM8), while 
the non-road leg remains unchanged (min 100km) (PM8); it should be noted that only 
12% of respondents in the targeted consultations supported a fixed limit for all road 
legs.116 

-  List  of  load  units  unchanged  (PM11);  in  the  targeted  consultation,  a  majority  of 
respondents considering that no changes to the load units would have no or negative 
impacts on the volumes of Combined Transport 117 

-  The  choice  of  data  required  for  proof  of  eligibility  would  be  left  to  the  operators 
(PM15)  and  electronic  documents  (in  addition  to  paper)  for  the  road  legs  would  be 
acceptable for Member States (PM18, PM21); 

-  The  economic  support  measures  will  not  be  changed  except  extending  the  current 
support  (reimbursement  of  road  vehicle  tax)  to  all  modal  combinations  and  all  load 
units (PM25); extending the existing support to all modal combinations was supported 
by  most  stakeholders  (especially  those  engaged  in  waterborne  operations)  ,but  this 
was deemed not sufficient (more economic support expected118)  

-  Finally  the  conditions  for  reporting  and  monitoring  would  be  reviewed  in  order  to 
make them more effective. (PM29 to PM32); this was supported by a large majority 
(90%) of respondents in the open public consultation119 

Policy  option  2.  Simplification  of  the  eligibility  criteria  (definition)  and  the  control 
thereof and providing more effective economic support.  

116   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

117   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC)– figure 45 

118   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

119   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) – figure 33 

44 

 
                                                 
Policy  option  PO2  focuses  on  the  clarification  and  simplification  of  the  eligibility  criteria 
(definition of Combined Transport) and the conditions for eligibility control while opening up 
the option for more effective economic support. Two sub-options have been identified under 
this  option,  differing  slightly  in  their  ambition  of  extending  the  scope  and  the  support 
measures:  

a) Under policy option PO2A :  

- 

-  

the geographical coverage of Combined Transport is extended to intra-MS (PM2); in 
the  targeted  consultation,  more  than  two  third  of  respondents  (mostly  from  private 
sector) viewed a geographical extension as very positive. It should also be noted that 
this  measure,  i.e.  extending  the  scope  of  possible  support  measures  to  "national" 
combined  transport  operations  is  already  applied,  on  a  voluntary  basis,  in  some 
Member States  

the principle that the road legs need to be effectively and numerically limited (in km or 
%)  in  order  to  support  modal  shift  is  confirmed  (PM5);  from  the  consultations,  and 
notably the stakeholder meetings, it appeared that the limitation of the road leg was 
the  most  discussed  point,  with  a  minority  of  operators  wanting  to  remove  any 
limitation on the road leg; however Member States expressed that such limitation of 
the road leg is essential;120 

- 

for the non-road leg, the limitation of minimum 100 km is lifted, while the eligibility 
is  restricted  for  SSS  connections  with/to  islands  as  well  as  short  ferry  connections 
(PM9) 

-  

the  load  unit  is  limited  to  ISO/ILU  identified  ones  (PM12);  from  the  consultations, 
existing121 road/rail operators are strongly supporting this measure 

-   for  support  measures,  the  current  support  (reimbursement  of  road  vehicle  tax  for 
rail/road CT) (PM24) is complemented by the possibility for Member States to adopt 
additional  (on  an  optional  basis)  economic  support  measures  covering  e.g. 
reimbursement of taxes or charges for vehicles or of (part of) transhipment cost of or 
of  rail/port  charges,  (PM22,  PM23,  PM25,  PM26,  PM27,  PM28);  Member  States, 
especially  those  supporting  Combined  Transport,  were  not  keen  to  have  additional 
mandatory support but were open to optional flexible support122 

b) Under policy option PO2B:  

- 

the geographical coverage of Combined Transport is extended to intra-MS (PM2), as 
in PO2A; 

-   Member  States  are  allowed  to  extend  the  road  legs  beyond  the  allowed  numerical 
limit in option PO2A  up to the nearest suitable transhipment point in case this is 

120   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

121   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

122   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

45 

 
                                                 
further than the numerical limit; this is meant to reduce the possible contradiction with 
the  Weights  and  Dimensions  Directive  as  well  as  for  addressing  the  particular 
difficulties  in  some  Member  States  due  to  their  geographic  circumstances  (PM5, 
PM6).  Several  Member  States,  notably  the  ones  making  use  of  the  Directive  are 
supporting to maintain this notion of "up to the nearest suitable transhipment point".  

-   for the non-load leg, it is the same as in PO2A (PM9); 

-   as  regards  load  units,  only  ISO/ILU  identified  units  are  permitted,  but  the  list  is  no 
longer limiting their sizes (PM13); allowing any type of load unit was supported in the 
targeted consultation by 2/3 of respondents123;  

-   for support measures, there is an obligation for Member States to ensure that measures 
for  investment  support  (i.e.  for  terminals)  are  put  in  place,  without  however 
prescribing or harmonising those measures; the other support measures are similar to 
the  option  PO2A  (PM22,  PM25);  as  mentioned  in  the  stakeholder  meeting  of  30 
March, many operators are in favour of direct support for terminals124 

For both PO2 options, as for PO1 and PO3, the conditions for reporting and monitoring would 
be reviewed in order to make them more effective 

Policy  option  3:  Changing  the  eligibility  criteria  (definition)  to  cover  all  intermodal 
transport with mandatory support measures 

Under the policy option PO3, there would be no limits on road and non-road legs or on load 
units allowing all intermodal transport to benefit from a beneficial regime. It is assumed that 
the economic market forces will ensure that the main part of the journey is carried by the non-
road  leg.  As  for  the  economic  support  measures,  they  are  the  same  as  in  PO2B  with  the 
difference that the Member States will be obliged to adopt take such support measures. As for 
PO2B  however,  the  measures  will  not  be  prescribed  in  the  amended  Combined  Transport 
Directive,  and  hence  Member  States  will  have  the  liberty  to  choose  their  type.  It  should  be 
noted that several Member States, and most notably those who are actively making use of the 
Combined Transport Directive and supporting Combined Transport in their countries, have 
expressed their strong opposition of any additional mandatory economic support measures. 

Table  6  below  summarises  for  each  option  the  choice  of  different  measures,  per  specific 
objective  and  problem  driver.  The  marked  cells  show  the  chosen  measure.  For  economic 
support  measures,  "O"  denotes  optional  measures,  while  "M"  denotes  mandatory  measures. 
"NH" refers to non-harmonised levels of support, i.e. that Member States can choose the level 
of  support  depending  on  national  circumstances.  All  optional  measures  are  also  non-
harmonised 

Measures 

BL 

PO1  PO2A  PO2B  PO3 

Specific objective : Simplification of eligibility criteria and the controls thereof  (SO1) 

123   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

124   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

46 

 
 
  
                                                 
Problem driver: complex eligibility criteria 
Geographical 
coverage 

PM1: Only between MS (intra-EU) 
PM2: Intra-EU and national CT 
PM3: 150 km each for water, nearest suitable for 
rail 
PM4: 150 km each for all 
PM5: 150 km each or 20% whichever is longer 
PM6: MS to allow to extent to nearest suitable for 
all 
PM7: No limitation 
PM8: Min 100 km 
PM9: Excluding those SSS not having a road-
alternative (island transport) and short roro SSS 
PM10: No limitation 
PM11: List of unit as currently 

Road legs 

Non-road 
legs 

Load units 

PM12: Only ISO/ILU identified 

PM13: List without size limit 
Problem driver: ineffective conditions for implementation 

Required 
data 

Data 
presentation 

Place of 
control 

PM14: Data requirements based on Regulation 11 
from 1960 
PM15:No data requirement nor requirements on 
documents 

PM16: Establish new data requirements 
corresponding to eligibility criteria 
PM17: Only paper documents and stamp 
requirement 
PM18:Paper + MS to accept existing electronic 
documents for CT road legs, incl pdf/jpg (operators 
to decide on type and format) 

PM19:Paper + MS to accept electronic data, EU 
agreed requirements, data standards and 
architecture (data not centralised, but retrieved on 
request, applications either private or public) 

PM20: In vehicles at roadside inspection (proof has 
to be present at all times) 
PM21: Paper in vehicle or electronic in vehicles at 
roadside inspection retrieved upon request (carrier 
can contact HQ/shipper/client or app or database 
and retrieve it for presentation) 

Specific objective : Foresee dedicated investment support for intermodal investments 
Problem driver : No measures for infrastructure development  

Investment 
support 

PM22: Measures for building CT terminals 
PM23: Grants for shipper side handling equipment 
investments 

O 

O 

M, 
NH 

O 

M, 
NH 
M, 
NH 

Specific objective : Increase the effectiveness and efficiency of the economic support measures  
Problem drivers : too narrow and too low economic support  
PM24: Reimbursement of road vehicle tax for 
routed vehicles on train 

Operational 

47 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
PM25: Reimbursement of road vehicle tax for all 
load units in CT 
PM26: Grant per load unit shipped on CT, lump-sum 
based on tkm 
PM27: Reimbursement of transhipment costs 

O 

O 

O 

O 

M, 
NH 

PM28: Reimbursement of road, rail or port charges 

Problem driver : ineffective conditions for reporting and monitoring 

Review 

Data 
Cooperation 

Transparency 

PM29: Review of economic support measures at 
national level 
PM30: Updated data gathering obligation on MS 
PM31: Creation of contact network 
PM32: Single place for all rules and support 
measures per MS 

Table 6: Summary of policy options and measures therein.  

It  should  be  however  mentioned  that  two  options  that  were  originally  considered  in  the 
inception impact assessment have been discarded:  

in 

the 

-  An  option  to  address  the  issues  only  through  soft  law  measures  (guidelines, 
Communication  with 
Impact 
recommendations),  described 
Assessment, was discarded as the specific problems relating to proof of eligibility (in 
particular the current provision allowing only (stamped) paper documents) cannot be 
addressed with soft law. Furthermore, the current scope of economic support covering 
only  a  minor  part  of  rail-road  transport  is  giving  disproportional  benefit  to  6 
companies carrying out roro accompanied rail Combined Transport services, while not 
benefitting the majority of combined transport operators (as explained above only 2% 
of  Intermodal  Transport  benefits  from  Combined  Transport economic  support).  As a 
consequence,  this  option  is  replaced  by  an  option  with  minimum  amendment  and 
accompanied by soft law. 

Inception 

-  An  option  of  using  the  definition  of  "intermodal  transport"  used  in  the  Weights  and 
Dimensions Directive as well as applying the regulatory regime of road transport on 
the  road  legs  (for  cabotage  restrictions),  also  described  in  the  Inception  Impact 
Assessment,  was  also  discarded:  on  the  one  hand,  the  definition  of  "intermodal 
transport" from the Weights and Dimensions Directive indeed covers also road legs of 
ocean going maritime transport, although in such specific operation there is no modal 
shift  in  the  EU;  on  the  other  hand,  as  regards  the  application  of  the  road  transport 
regime on the combined transport road legs (e.g. no more cabotage exemption), almost 
all stakeholders in the 2014 public consultation125 agreed that the specific regulatory 
benefits  (e.g.  cabotage  exemption,  and  higher  weight  through  the  W&D  Directive) 
foreseen  in  the  Combined  Transport  Directive  are  the  most  important  part  of  the 
support provided to Combined Transport and necessary to ensure a level playing field 
with  long-distance  road  transport.  It  has  been  assessed  to  reduce  the  combined 
transport operation price up to 17.5%.  Furthermore, as regards the provision on non-

125   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

48 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
                                                 
application  of  the  road  cabotage  limitation  on  the  combined  transport  road  legs,  as 
explained  above,  the  CJEU  has  decided  on  several  occasions  that  this  "exemption" 
derives  directly  from  the  fact  that  Combined  Transport  operations  between  Member 
States  is  an  international  transport  operation  and  cabotage  limitations  cannot  be 
applied to international transport, even if the road leg does not cross a border. Taking 
this  into  account,  the  option  to  review  (withdraw)  the  regulatory  benefits  has  been 
discarded as contrary to objectives of the Directive.  

6.  WHAT ARE THE IMPACTS OF DIFFERENT POLICY OPTIONS  

The economic, social and environmental impacts of various policy options are assessed either 
as initial cost of implementation or within the timeframe of the Transport White Paper modal 
shift target for road above 300km, that is by 2030.   

The  methodology  used  to  assess the  impacts  the  various  options  is  to  quantify  the resulting 
modal  shift  for  each  option  and  to  derive  the  related  economic,  social  and  environmental 
impacts  for  each  option,  on  the  basis  of  the  modal  shift.  To  achieve  this,  the  impact 
assessment builds on the baseline scenario, projecting developments under current trends and 
adopted  policies126  and  makes  use  of  an  in-house  model  for  analysing  the  impacts  on 
intermodal and combined transport (see Annex 4 for further details) with various modelling 
assumptions  on  the  importance  of  different  types  of  measures  on  the  actions  of  economic 
operators  (see  Annex  4  for  further  details  on  the  modelling  assumptions).  Where  necessary 
due  to  the  character  of  measures  or  the  lack  of  data,  the  quantitative  assessment  is 
supplemented by a qualitative assessment.   

The in-house model takes into consideration  the  expected  evolution  of  road  freight  above 
300km, the expected evolution of intermodal freight and the geographical coverage covered 
by the definition of Combined Transport in the Directive. For each option, the impact on the 
cost  of  the  chosen  simplification  measures  and/or  of  the  new/updated  support  measures  is 
applied to the various freight traffic types (i.e. intermodal freight traffic covered the CTD, i.e. 
the actual "combined transport"; intermodal freight traffic not covered by the CTD; the new 
shifted (from road) freight traffic). In the model, the volume of "modal shift" is also used as 
the  basis  for  calculating  the  cost  of  externalities,  and  to  derive  the  savings  achieved  by 
through the "modal shift". 

General  modelling  assumptions  (and  limitations)  (see  Annex  4  section  1.2)  include  the 
following:   

-  For  policy  measures  that  are  not  mandatory  (economic  support  measures)  an  average 

impact is assessed based on existing similar measures and their established impacts. 

-  The  behaviour  of  economic  operators  is  modelled  based  on  existing  experience  from 

similar past and current measures. 

126   The  Baseline  scenario  builds  on  the  EU  Reference  scenario  2016  but  additionally  includes  some  updates  in  the 
technology costs assumptions (i.e. for light duty vehicles) and few policy measures adopted after its cut-off date (end of 
2014) like the Directive on Weights and Dimensions, the 4th Railways Package, the NAIADES II Package, the Ports 
Package, the replacement of the New European Driving Cycle (NEDC) test cycle by the new Worldwide harmonized 
Light-vehicles  Test  Procedure  (WLTP).  It  has  been  developed  with  the  PRIMES-TREMOVE  model  (i.e.  the  same 
model used for the EU Reference scenario 2016) by ICCS-E3MLab. A detailed description of this scenario is available 
in the Impact Assessment accompanying the Proposal for a Directive amending Directive 1999/62/EC on the charging 
of heavy goods vehicles for the use of certain infrastructures, SWD (2017) 180 

49 

 
 
                                                 
-  Quantifying the impacts of optional measures requires making assumptions on the uptake 
of  these  support  measures  by  Member  States.  For  this  reason,  quantification,  including 
modelling results, is only used to indicate the scale of expected impacts rather than their 
exact estimation.  

-  Member States that already have economic support measures in place that go beyond the 
current Directive, but are covered by any of the options, will keep these measures even if 
they are optional. This assumption has been used as modelling input.  

-  The impact on Member States budgetary burden is assessed based on examples from some 

Member States who have already used similar measures to support modal shift 

Specific additional assumptions are provided in Annex 4 section 1.2. 

Impacts of policy options are compared against the results of the baseline scenario in 2030, 
unless stated otherwise. Impacts of separate policy measures are explained at first occurrence.  

6.1.  Economic impacts 

The economic impacts brought along with the amendment of this Directive are reflected in the 
changes  of  the  costs  of  intermodal  transport  (market  price  as  well  as  additional  costs  to 
shippers) and in resulting increased competitiveness of combined transport vis-à-vis unimodal 
road transport. This increased competitiveness induces from one hand modal shift and from 
other hand increases the profitability of existing intermodal transport which frees up assets for 
further  investments  in  the  sector.  Thus,  for  each  option,  the  impacts  are  assessed  for 
operations  already  covered  by  the  Directive,  and  for  intermodal  operations  currently  not 
covered by the Directive and thus not eligible for support (extension of the scope), as well as 
in terms of potential modal shift from road to combined transport resulting.  

6.1.1.  Competitiveness of combined transport and modal shift 

Option PO1 has limited impact on competitiveness of the combined transport as well as on 
modal shift:  

-  While  the  amendment  would  simplify  implementation  and  extend  somewhat  the 
support,  the  150  km  “hard” limit  on  road legs (PM2)  would  reduce  the  eligibility  to 
the  benefits  as  compared  to  the  current  Directive  (from  41.7%  to  37.4%).  The 
reduction would affect rail-road transport where up to 25% of operations are expected 
to be excluded. For total combined transport, this would mean a reduction of eligibility 
of  10.72%.  The  Combined  Transport  operators  who  would  be  excluded  would  not 
only  no  longer  benefit  from  the  economic  support  but  also  not  benefit  from  the 
regulatory measures including from the (e.g. added weight allowance and the cabotage 
exemption) resulting in an increase of up to 17.5% of costs for these operators. At the 
same  time,  the  clear  limit  would  considerably  reduce  the  cost  of  problems  resulting 
from non-homogenous transposition and implementation currently experiences by the 
industry. The industry has assessed these problems to create a cost up to 4.36% of total 
price per shipment for operations covered by the Directive. 

-  The  extension  of  tax  reimbursements  of  road  vehicle  tax  to  all  Combined  Transport 
operations  covered  by  the  Directive  (PM25)  would  result  in  small  reduction  in  the 
price  of  Combined  Transport  operations  (0.14%  for  operations  covered  by  Directive 
and 0.05% for intermodal operations on average). 

-  The impact of the introduction of mandatory acceptance of electronic documents such 
as  e-CMR  (PM18)  is  expected  to  lead  to  significant  cost  savings  as  analysed  in  the 

50 

 
impact assessment for amending the Regulation (EU) 1072/2009127. The total savings 
due to this measure are estimated to be on average 5€ per shipment128 and would apply 
to all intermodal transport operations as it is unlikely that electronic documents would 
not be accepted by Member States for operations not covered by the Directive if they 
are  accepted  for  those  covered.  As  in  this  option  all  types  of  electronic  formats  are 
allowed, no initial investment is considered necessary. However, this option also does 
not foresee specific data requirements and thus the effectiveness of road side checks 
cannot be improved.  

PO1 IM (all)

Road; 29 

Non-road; 39 

Transhipment; 30 

Reduced loading 
capacity; 6 

Cabotage; 5 

PO1 IM (CT portion of it)

Road; 29 

Non-road; 39 

Transhipment; 30 

Unimodal road transport

Road; 100 

Additional costs 
(implementation, 
delays, transaction 
costs etc); 38 

0

20

40

60

80

100

120

140

160

Figure 11. PO1 : Cost components for shippers of intermodal (total) and combined transport (only), percentages 

While Figure 11 illustrates the effect of PO1 measures on the relative (%) cost components 
(and notably the additional costs) of intermodal transport and Combined Transport compared 
to  road  only  transport,  the  total  (absolute)  cost  reduction  for  existing  intermodal  (non 
combined  transport)  operations  from  the  measures  under  PO1  is  assessed  to  be  1.72%.  For 
new combined transport operations, such cost reduction will be 1.89%.  

As  a  result,  it  can  be  expected  that  the  overall  cost  reduction  impact  of  the  PO1  measures 
would  directly  impact  the  marker  prices  of  intermodal  transport,  which  would  remain  more 
expensive than road transport on average by 21.1%.  

Policy option PO1 1 is expected to result in :  

 - additional modal shift in 2030 of 2.31 bn tkm. Considering that the gap to reach the modal 
shift target is 52 bn tkm, the modal shift target would not be reached neither in the trend nor 
in the optimistic scenario 

- total economic savings for the industry (compared to current situation) would nevertheless 
be €8.57 billion between 2022129 and 2030.  

Implementing  policy  option  PO2A  is  expected  to  bring  along  a  considerably  larger  impact 
than option PO1:  

-  While  it  will,  similarly  to  option  PO1,  reduce  the  eligibility  for  existing  rail-road 
Combined Transport (up to 18% of operations) through a strict limitation on the road 
leg (PM5), this reduction would be offset in total by an increase of eligibility for the 

127   SWD (2017) 194 final 

128   SWD (2017) 194 final 

129   Date of estimated entry into force of the amended Directive 

51 

 
 
 
                                                 
short sea shipping, where average non-road legs are longer than 750 km and thus a the 
suggested 20% limit for each road leg would allow to overcome the current 150 km. 
Furthermore, under this option, national combined transport would also be included in 
the definition130. To ensure a more targeted impact, the eligibility is also restricted for 
short sea operations with to islands as well as short ferry connections. As a result, the 
eligibility to the benefits as compared to the current Directive would be increased from 
41.7% to 66.9%. The impact of the definition combining a 150km minimum level with 
a  20%  relative  limitation  allows  including  both  very  short  operations  in  highly 
congested/urbanised  areas  as  well  as  longer  road  legs  for  very  long  operations,  but 
some remaining problems have to be presumed for in relation to the calculation of the 
percentages from the total trip. 

- 

the  introduction  of  the  mandatory  acceptance  of  electronic  data  for  control 
purposes  in  the  form  of  structured  electronic  data  (PM19)  along  with  clearly 
defined  data  requirements  for  proof  of  eligibility  (PM16)  is  assessed  to  deliver 
between  2.7  and  2.8%  of  cost  reduction.  Using  structured  data  instead  of  scanned 
documents  considerably  improves  the  efficiency  allowing  companies  to  directly 
integrate the relevant data applications into their accounting systems.. 

-  Option PO2A also foresees considerably amended economic support consisting from 
of  investment  support  (PM22-PM23)  to  build  and  extend  the  terminals  as  well  as 
operational  support  (PM24-PM28).  Both  support  measures  are  optional  under  this 
policy  option.  The  impact  on  price  of  these  measures  is  assessed  to  be  ca.  -4.5%.  It 
should  be  noted  that  the  terminal  support  measures  will  have  a  delay  in  bringing 
positive impacts as planning and approval processes take time, as does building itself. 
The  current  analysis  assesses  the  impact  by  2030  in  line  with  the  Transport  White 
Paper target, but positive impacts can be foreseen to continue well after 2030.  

PO2A IM (all)

Road; 29 

Non-road; 39 

Transhipment; 29 

Reduced loading 
capacity; 3 

Cabotage; 2 

PO2A IM (CT portion of it)

Road; 29 

Non-road; 39 

Transhipment; 28 

Unimodal road transport

Road; 100 

Additional costs 
(implementation, 
delays, transaction 
costs etc); 39 

0

20

40

60

80

100

120

140

160

Figure  12  .  Cost  components  for  users  of  intermodal  (all)  and  combined  transport  (only)  under  option  PO2A, 
percentages 

While Figure 12 illustrates the effect of PO2A measures on the relative (%) cost components 
(and notably the additional costs) of intermodal transport and Combined Transport compared 
to  road  only  transport,  the  cost  reduction  for  existing  operations  from  the  measures  under 
PO2A is assessed to be respectively 8.7% and 7.9% for existing operations covered under the 
Combined Transport directive and operations newly covered under the amended regime.  

130   This extension would not apply to Article 4 (cabotage exemption) as explained in Table 4/footnote 42 

52 

 
 
                                                 
As a result, it can be expected that the overall cost reduction impact of the PO2A measures 
would  directly  impact  the  marker  prices  of  intermodal  transport,  which  would  remain  more 
expensive than road transport on average by 15.6. 

Policy option PO2A is expected to result in:  

- additional modal shift in 2030 of 44.45 bn tkm (still falling short of the modal shift target of 
52 bn tkm)  

- the total economic savings for the industry €44 billion between 2022 and 2030.  

Under option PO2B:  

- 

- 

the  eligibility  of  Combined  transport  would  be  slightly  increased  to  72.7%  of  all 
intermodal operations.. The difference from PO2A comes from the possibility given to 
Member States to allow road transport to the nearest suitable terminal (PM6) beyond 
150km or 20% whichever is longer (PM5). In some countries it may be necessary to 
allow  longer  road  legs  when  the  terminal  density  is  not  enough  too  low  to  allow 
intermodal transport to benefit from the support measures. Road legs until the nearest 
suitable loading station are allowed currently for rail-road Combined Transport, so no 
negative impact is foreseen expected for this type of Combined Transport. 

Impacts  can  however  be  expected,  for  inland  waterways  and  short  sea  shipping 
Combined  Transport  where  currently  the  hard  limit  of  150  km  applies.  In  terms  of 
inland waterways essentially all operations are covered within the 150km limit already 
today limit; in terms of short sea shipping however an estimated 12.5% of additional 
operations are expected to  benefit  from the regulatory  regime as compared to option 
PO2A  

-  The  inclusion  of  the  possibility  to  extend  the  road  legs  until  the  nearest  suitable 
terminal has an impact on the effectiveness of control of eligibility as controlling the 
suitability does create practical problems today.  It should be noted that as the Weights 
and Dimensions Directive already allows Member States to extend the eligibility to the 
nearest  suitable  terminal  for  waterborne  transport,  the  impact  is  limited  to  those 
Member States who would not like to extend the weights and dimensions rules to all 
intermodal  transport  as  defined  in  the  Weights  and  Dimensions  Directive  (including 
combination road plus ocean going maritime transport), but would like to extend it to 
combined transport where road legs are limited and modal shift takes place within the 
EU.  

-  A further cost reduction in price is brought along by economic support measures. The 
main difference compared to Option PO2A is that the investment support for building 
terminals  (PM22)  is  mandatory  though  not  harmonised  across  Member  States.  This 
measure is expected to further decrease by ca 4% the cost of operations compared to 
Option PO2A. .  

53 

 
Reduced loading 
capacity; 3 

Cabotage; 2 

PO2B IM (all)

Road; 29 

Non-road; 39 

Transhipment; 27 

PO2B IM (CT portion of it)

Road; 29 

Non-road; 39 

Transhipment; 26 

Additional costs 
(implementation, 
delays, transaction 
costs etc); 37 

Unimodal road transport

Road; 100 

0

20

40

60

80

100

120

140

160

Figure 13. Cost components for users of intermodal and combined transport under option PO2B, percentages. 

While Figure 13 illustrates the effect of PO2B measures on the relative (%) cost components 
(and notably the additional costs) of intermodal transport and Combined Transport compared 
to  road  only  transport,  the  cost  reduction  due  all  economic  support  measures  is  assessed  to 
reach 8.7%, resulting in a total cost reduction of 12.5% for existing operators covered by the 
Combined  Transport  directive  and  11.9%  for  operations  newly  covered  under  the  amended 
regime 

As  a  result,  it  can  be  expected  that  the  marker  prices  of  intermodal  transport  under  PO2B 
would remain more expensive than road transport on average by 11%.  

Policy option PO2B is expected to result in : 

-an additional modal shift in 2030 of 69.6 bn tkm and thus exceeding the target modal shift of 
52 bn tkm 

-  the  total  economic  savings  for  the  industry  would  be  around  €64.6  billion  for  the  period 
between 2022 and 2030.  

Policy option PO3 is an option for supporting EU intermodal transport to the largest extent 
possible. 

-  The  extension  of  the  scope  (no  road  limits,  no  unit  limits,  no  data  requirements) 
(PM13,  PM7,  PM10,  PM15)  would  be  considerable  as  the  overall  eligibility  would 
reach 100% (70% more intermodal transport operations would be eligible). NOTE : It 
is  strongly  supported  by  industry  stakeholders  but  does  not  receive  the  support  of 
several Member States.  

-  The cost reduction resulting from the removal of administrative measures because of 
the  absence  of  limits  and  the  needs  to  verify  them  would  reach  around  4%  and  the 
mandatory  nature  of  economic  measures  would  also  further  influence  the  cost  of 
operations.  

54 

 
 
PO3

Road; 29 

Non-road; 39 

Transhipment; 26 

Additional costs 
(implementation, 
delays, transaction 
costs etc); 36 

Unimodal road transport

Road; 100 

0

20

40

60

80

100

120

140

Figure 14 . Cost components for users of intermodal and combined transport under option PO3, percentages. 

While Figure 14 illustrates the effect of PO3 measures on the relative (%) cost components 
(and notably the additional costs) of intermodal transport and Combined Transport compared 
to  road  only  transport,  the  overall  cost  reduction  is  expected  to  be  17.5%  for  existing 
operations covered  by the CT directive  and 14.5%  for new operations newly covered under 
the amended regime  

As  a  result,  it  can  be  expected  that  the  marker  prices  of  intermodal  transport  under  PO2B 
would remain more expensive than road transport on average by 8.5%.  

Policy option PO3 is expected to result in : 

- an additional modal shift in 2030 of 176.5 bn tkm, largely exceeding the modal shift target 
of the 2011 White Paper target 

-  the  total  economic  saving  for  the  EU  industry  would  be  up  to  €101  billion  for  the  period 
until 2030.  

6.1.2. 

Impact on SMEs 

Every  intermodal  transport  operation  involves  many  different  operators.  While  operators  in 
the area of rail transport and shipping tend to be big- medium or large companies, operators in 
road transport and inland waterways are often SMEs. According to Eurostat, in particular in 
the  road  transport  sector,  close  to  100%  of  companies  are  with  employ  fewer  than  250 
employees,  while  90%  are  micro-enterprises.    Among  logistics  operators  and  freight 
forwarders,  the  EU  has  some  of  the  world  largest  operators,  but  also  a  large  part  of  the 
business is handled by SMEs, in particular as regards national operations.  

The  SMEs  in  particular  benefit  from  the  support  of  the  Combined  Transport  directive  to 
compete with the cheaper long distance road transport as they do not usually neither benefit 
from economies of scale available to large enterprises who carry out all parts of the combined 
transport operation (organising, transport, transhipment) nor can they cross-subsidise between 
different activities as they usually only carry out one type of activity.   

An increase of combined transport operations will have a positive economic effect on SMEs 
focusing on short distance combined transport road legs as more road legs need to be carried 
out.  As  opposed  to  long-distance  road  transport,  a  combined  transport  operation  usually 
involves two different road transport operators at each end of the operation. Furthermore, the 
price per kilometre of short distance haulage is higher than on long distance operations and 
thus profitability per kilometre is higher, and there are less losses due to inability to fill empty 
trucks on the long distance return.   

55 

 
 
As regards SMEs who act as freight forwarders and logistics operators engaged in organising 
combined  transport  operations,  or  as  combined  transport  operators,  rail  and  waterways 
undertakings carrying out combined transport operations, the effect is expected to be positive 
if the business opportunities increase. 

As policy option PO1 will bring along a reduction in the eligibility in of the rail-road sector 
in particular for road legs, the impact on SMEs carrying out these road legs is negative as a 
through loss of business can be expected. However, the introduction of the possibility to use 
electronic  documents,  in  particular  if  this  does  not  entail  any  particular  investment  as  all 
types, including photos and pdf files are allowed would reduce the cost for SMEs for whom 
the investment into new technology can be a high burden.  

The impacts on SMEs of policy options PO2A and PO2B are expected to be comparable to 
each  other,  with  policy  option  PO2B  expected  to  bring  along  a  higher  shift  to  intermodal 
transport  thanks  to  wider  definition  of  the  eligibility  criteria.  However,  the  introduction  of 
electronic  structured  data  for  control  purposes  may  bring  along  relatively  high  investment 
costs  for  SMEs  engaged  in  organising  the  transport  operation  and  preparing  the  data. 
According  to  operators,  the  cost  of  investment  would  be  in  correlation  with  the  size  of 
companies,  with  expected  additional  one-time  cost  for  introducing  electronic  reporting  was 
assessed  to  be  in  the  range  of  137.250€  per  company  (companies  with  less  than  200.000 
shipments  a  year)131.  This  cost  would  however  be  offset  by  the  savings  that  the  use  of 
electronic data provides, estimated to be €145.000 per company per year. The impact for SME 
operators using the new systems should thus be small and positive.  

For  Option  PO3,  the  main  difference,  as  compared  to  Option  PO2B,  relates  to  the 
considerable  extension  of  the  scope  of  the  Directive  that  would  have  a  temporary  negative 
effect  on  the  long  distance  road  transport  operators  while  some  of  them  switch  into  short 
distance  intermodal  road  legs  operations.  It  may  also  have  a  small  negative  effect  on  the 
SMEs in the road transport sector especially those active in national transport operations as a 
wider range of transport operations would not be subject to quantitative limitations under the 
Regulation 1072/2009/EC. 

6.1.3.  Compliance costs 

As  this  Directive  is  not  a  regulatory  Directive  and  does  not  foresee  any  obligations  on 
economic  operators,  there  are  also  no  compliance  costs  as  such.  It  is  up  to  the  operator  to 
decide  if  they  want  to  benefit  from  the  beneficial  regime  or  not.  If  the  operator  wishes  to 
benefit from the regime, two types of costs can occur: 

  The  one-time  costs  deriving  from  changing  the  transport  operation  so  that  it  fulfils  the 
eligibility criteria are assessed by industry to be in the range of 200-1000€ depending on 
the complexity of the operation. This is equal to the cost of organising a new combined 
transport route to a new destination; 

  Cost of using the transport documents/electronic data solution that fulfils the conditions of 
Article 3. As mentioned above, the one-time cost for introducing electronic data solutions 
is assessed to be in the range of 137.250€ (companies with less than 200.000 shipments a 
year) and up to 1 million for companies with more than 200.000 shipments a year. This is 
however quickly offset by the savings that the use of electronic data provides, estimated to 
be €145.000 per company per year. 

131   TRT (2017)  – Gathering additional data on EU combined transport – Final report 

56 

 
                                                 
6.1.4.  Member States budgets 

The economic support to modal shift induces considerable costs for Member States. The level 
of  additional  budget  burden  depends  largely  on  the  support  measures  chosen  by  Member 
States and on whether support measures already exist.  

Option  PO1  amends  the  economic  support  measures  by  extending  the  current  tax 
reimbursement to all modes and all eligible load units. The expected cost of this measure for 
the period until 2030 is assessed to be €228 million for the whole of the EU. The costs do not 
distribute evenly between Member States. 

The mandatory acceptance of electronic transport documents (PM18) by enforcers could lead 
to estimated savings of €14.4 million assuming that total time needed to carry out checks is 
reduced by 10%132. The set-up costs of this measure are considered to be limited, given that 
most of the necessary infrastructure is already in place133. 

Total costs to Member States under option PO1 are expected to be €228 million for the EU 28 
(€214 million in case of acceptance of e-documents), or €28.3 million a year.  

Option  PO2A  foresees  optional  support  measures  both  for  terminal  building  as  well  as  for 
operations  support  (PM22-28).  Several  Member  States  already  have  one  or  several  of  these 
measures in force (19 Member States for operational support, including those relating to taxes 
and  charges  and  5  for  investment  support).  Including  optional  support  measures  in  the 
Directive is expected mainly to increase the likelihood that Member States would to continue 
with  these  programs  as  well  as  somewhat  increase  the  likelihood  for  the  uptake  of  these 
support measures by other Member States through the publicity of reporting. Increase of the 
budgetary burden is up to the Member States to decide.  

Under  option  PO2A,  it  is  expected  that  33%  Member  States  will  select  one  or  more 
operational support while 50% of Member States. This difference is based on the assumption 
that, when given the choice, Member States would rather opt for investment support, as it is 
more efficient.  

Thanks to these measures, the terminal capacity is expected to increase by 4 percent between 
2022  (expected  time  of  application  of  support  measures)  and  2030.  Extrapolating  from  the 
experience  of  Germany,  in  which  the  average  marginal  cost  of  adding  one  load  unit  of 
capacity was 172€, from which the public support was 121€ (70%), the total cost for EU for 
4%  increase  in  loading  capacity  is  thus  €528.6  million,  from  which  public  support  is  up  to 
€370 million (with an assumption of 70% public support). This public support can originate 
inter alia from EU funds. Operational support is expected to amount on average 1.5% of the 
Combined Transport market price and be taken up by a third of Member States. Under these 
assumptions, the cost to Member States until 2030 is €1.7 billion over 9 years.  

As regards acceptance of electronic documents (PM19), the option does not foresee a public 
investment for setting up an infrastructure for data exchange, but rather assumes that this will 

132   Assumption from SWD(107) 194 final – see below 

133   SWD(2017) 194,final  Impact assessment accompanying the Proposal for a Regulation of the European Parliament and 
of the Council amending Regulation (EC) No 1071/2009 and Regulation (EC) No 1072/2009 with a view to adapting 
them to developments in the sector 

57 

 
                                                 
be  provided  by  third  party  private  operators.  As  pointed  out  earlier,  the  Commission  is 
working on a separate initiative and its impact assessment on introducing detailed rules on the 
acceptance  of  electronic  documents  by  Member  States  authorities.  It  is  assumed  that  the 
conditions foreseen in the ensuing policy measure(s) would also apply to intermodal transport. 
This  impact  analysis,  which  is  still  in  a  preliminary  stage,  does  not  yet  provide  cost 
calculations.  

Total cost to Member States is thus expected to be around €1.7 bn 2022-2030.  

In option PO2B the terminal support is mandatory, but operational support is optional. 

Option PO3 establishes an obligation to take measures for terminal support as well as one or 
several  measures  for  operational  support.  Including  mandatory  support  measures  in  the 
Directive may lead to a reduction of administrative burden for Member States as regards the 
state-aid notification (including for renewal of measures every 5 years) and thus increase the 
likelihood  that  Member  States  would  to  continue  their  existing  programs.  The  level  and 
conditions of the terminal  building support,  including  co-financing through other  EU funds, 
depends on the Member State.  

In both options the terminal capacity is expected to increase by 8%, bringing along a cost of 
€2.23  bn  2022-2030,  from  which  public  spending  is  bn.  €1.56  or  €80.75  million  a  year.  In 
option  PO2B  the  operational  support  is  expected  to  amount  to  a  total  cost  of  €2  bn  and  in 
option  PO3  to  €7bn.  The  relative  division  of  support  between  Member  States  is  shown  on 
graph 11 based on above assumptions.  

AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK UK

Figure 15. The relative division of support between MS, based on relative share of operations and transhipments 
in 2015 

Total cost to Member States of option PO2B is expected to be €2.96 bn and of option PO3 
€8.2 billion between 2022 and 2030. 

6.1.5.  Regional distribution of impacts 

High  road  transport  volumes  affect  central  and  peripheral  regions  differently  and  thus  the 
relative  benefit  of  modal  shift  is  more  important  in  central  regions  where  transit  traffic 
volumes  are  high.  However,  due  to  higher  transport  volumes,  the  need  for  investment  in 
terminal capacity is also higher in these regions, as well is as in regions connecting European 
transport  with  international  operations  (large  ports).  These  regions  have  already  relatively 
high  intermodal  transport  volumes  as  compared  to  peripheral  regions.  They  also  have  well 

58 

 
 
established  national  support  programmes  and  different  negative  measures  (tolls,  congestion 
charges etc.) in place to motivate the modal shift, however due to high transport volumes in 
general, the potential for modal shift remains high also in these regions.  

The largest regional differences relate to terminal density. Peripheral regions in particular in 
north and east have currently low terminal density (see map in Annex 6 for a map) and any 
increase  in  terminals  coupled  with  operational  support  in  these  regions  has  the  potential  of 
improving the modal shift drastically.  

Additional distributional effects can also be foreseen in PO3 as regards the considerably wider 
use  of  cabotage  exemptions,  shifting  profits  from  North/Western  Member  States  to 
East/Southern Member States134.  

6.1.6. 

Impact on third countries 

The  third  country  operators  can  only  benefit  from  the  Directive  through  the  regulatory 
measures if they are legally carrying out combined transport road legs in the EU or crossing 
the  EU  external  border  (governed  under  respective  bilateral  agreements).  The  third  country 
logistics companies, freight forwarders and other CT operation managers can benefit from the 
Directive's  regulatory  benefits  if  the  operations fulfil  the  eligibility  criteria  of  the  Directive. 
The  impacts  of  this  amendment  as  regards  economic  benefits  would  be  the  same  as  for  EU 
operators.  

6.2.  Environmental impacts: reduction of external costs through modal shift 

The  reduction  of  negative  environmental  impacts  is  the  main  general  objective  of  this 
Directive  and  the  options  were  designed  so  as  to  ensure  additional  positive  environmental 
impacts. Depending  on the options of the impact assessment, it is expected that between an 
additional  0.09%  and  7.25%    of  the  road  freight  volume  would  be  shifted  by  2030  to  other 
modes of transport, amounting to 36000 long distance lorries less on the roads daily.  

The positive environmental impacts of the policy options result from modal shift away from 
unimodal road transport by 2030. The impacts have  been  derived drawing on the PRIMES-
TREMOVE  model  and  are  reflected  in  the  below  table  in  millions  of  euros  of  costs  saved. 
The below table does not show the total external cost savings of intermodal transport, but only 
additional savings thanks to the implementation of the options) 

million euro in 2013 prices for 2030 
Accidents 
Noise 
Congestion 

Air Pollution 

Climate change 
Total additional external costs savings 

NOx 
PM 

PO1 

6 
2 
37 
3 
0,1 
7 
54 

PO2A 
107 
29 
703 
55 
3 
2 
1020 

PO2B 
170 
46 
1119 
87 
5 
197 
1624 

PO3 

431 
116 
2839 
222 
12 
500 
4120 

134   SWD(2017) 194 final - According to the impact assessment on the amendment of Regulation (EC) 1072/2009, 80% of 
cabotage operations take place in 5 Member States and there is virtually no cabotage in EU-13 Member States (i.e. 13 
Member States which joined the EU in 2004, 2007 and 2013 ). 

59 

 
  
 
  
 
  
 
  
 
 
 
  
 
  
 
                                                 
Table 6. Additional external costs savings by 2030 thanks due to the modal shift induced by the proposed policy 
options, PRIMES-TREMOVE Transport Model compared to the Baseline 

The  savings  from  the  shift  to  intermodal  transport  are  considerable.  The  total  savings  from 
intermodal transport (baseline plus additional savings from relevant options) were calculated 
for the trend and optimistic scenario and for the average growth scenario. The average total 
external  costs  savings  ranges  from  €13.7bn  (PO1)  to  €16.7bn  (PO3)  in  2030.  The  savings 
from particular options increase in correlation with the modal shift they induce (Table 6) and 
thus the difference between the PO1 and PO3 is very large (76 times). 

As regards CO2 emissions in particular, the savings increase with modal shift and thus options 
2 and 3 involve a considerable saving reduction of CO2 emissions. As shown in the analytical 
work  underpinning  the  European  Strategy  for  Low-Emission  Mobility,  cost-effective 
emission  reductions  of  18-19%  are  needed  for  transport  by  2030  relative  to  2005135.  This 
would require an additional reduction of CO2 emission levels of about 206-221 Mtonnes by 
2030  relative  to  2005136,  52  to  67  Mtonnes  additional  to  the  EU  reference  scenario  2016. 
While  other  EU  instruments  under  the  European  Strategy  for  Low-Emission  Mobility  will 
also contribute to this target, the amendment of Combined Transport Directive can add 0.3 to 
25% of the additional emission reductions needed depending on the chosen option (see table 
7).  

Changes  to  the  air  quality  are  also  driven  by  the  modal  shift  induced  and  thus  vary 
considerably under the different options (see Table 7). The impacts can be significant ranging 
from 2.9% to 13.1 % in savings compared to the baseline scenario. These emission reductions 
from  modal  shift  would  be  on  top  of  emission  reductions  brought  along  by  other  EU 
instruments, such as the amendments of the Eurovignette Directive137.  

CO2 savings (ktons of CO2) 
Air pollutants savings (tons)  NOx 
PM 

BL 

PO1 

0,0 
0,0 
0,0 

195 
222 
4 

PO2A 
3693 
4203 
82 

PO2B 
5881 
6694 
130 

O3 
14921 
16984 
330 

Table 7. Additional emission savings by 2030 by the proposed policy options PRIMES-TREMOVE Transport 
Model compared to Baseline 

Additional  benefits  for  the  environment  result  in  the  reduction  of  noise  levels,  in  particular 
thanks to the shift to waterborne transport and the economic benefits of positive impacts on 
climate  change.  Finally,  in  the  medium  and  long  term,  impacts  on  land  use  create  costs  in 
terms of habitat loss and fragmentation. Modal shift and the reduction of congestion on roads 
lead  to  reduce  the  need  to  build  new  or  expand  existing  road  infrastructure  and  thus  has  a 
positive effect on land use as compared to baseline scenario.  

6.3.  Social impacts 

All options will benefit the general public through the reduction of negative externalities such 
as pollution, congestion and traffic casualties, the magnitude of impact of each option depends 
on its ability to foster modal shift, thus options PO2A, PO2B and PO3 would have impacts 
in  growing  order.  The  modal  shift  and  the  increase  of  combined  transport  operations  will 

135   This outcome is in line with the 2011 White Paper which established a milestone of 20% emissions reductions by 2030 
relative  to  2008  levels,  equivalent  to  19%  emissions  reduction  compared  to  2005  levels,  and  with  the  2050 
decarbonisation objectives 

136   SWD(2016) 244 final 

137   SWD(2017) 180 final - Impact Assessment of the amendment of the Eurovignette Directive 

60 

 
 
  
  
  
                                                 
certainly  create  some  short  term  disturbances  as  jobs  will  shift  from  long  distance  road 
transport  to  short  distance  road  transport.  Based  on  the  literature,  it  can  be  estimated  that 
under the baseline scenario, ca 31 000 long-distance lorries are shifted to intermodal transport 
daily.  

First,  modal  shift  to  intermodal  transport  will  create  more  jobs  in  total.  One  combined 
transport  operation  requires  the  involvement  of  several  modes  of  transport  (short  distance 
road  transport  and  long  distance  transport  by  other  modes  of  transport)  as  well  as 
transhipment  and  terminal  services  to  be  provided  as  compared  to  only  one  driver  in  long 
distance road operations.  On average partial employment of up to 10 people (e.g. 2 drivers 
for  each  road  leg,  2  train  drivers  in  case  of  rail/road,  up  to  3  workers  at  each  transhipment 
terminal) will be needed for combined transport as compared to one long distance driver (with 
varying share of occupation per one shipment). Increase in full time equivalent employment is 
assessed  to  be  up  to  25%,  including  the  job  creation  in  and  around  terminals.  Furthermore, 
this shift will create "jobs" with relatively better quality of life, i.e. "local" jobs, compared to 
jobs in long distance road transport, requiring long hours, and physical and time distance from 
home.  

Despite  this  assessed  relative  increase  and  transformation  of  jobs,  it  is  expected  that  in  the 
short  term,  shifting  freight  from  long  distance  road  transport  to  more  sustainable  modes  of 
transport, the direct impact in terms of jobs for road operators will be negative. However, in 
the  medium  and  long  term,  the  road  operators  (long-distance)  can  re-focus  and  adapt  to 
operating  the  increasing  number  of  road-legs  of  combined  transport  operations,  which  are 
relatively more profitable.  

The impact of terminal support on the job creation will be positive. The Impact Assessment 
accompanying the proposal on the TEN-T guidelines138 included the job creating potential of 
public  spending  on  transport  infrastructure.  According  to  a  conservative  estimate,  the 
investment of EUR 1 billion would generate 21,260 new direct, indirect and induced jobs.139 
More specifically, the support program of terminal building in Germany (1998-2015) with an 
investment  value  of  €828.7  million  was  assessed  to  have  had  a  large  and  positive  social 
impact, with a creation of 4413 direct and indirect additional jobs and an additional value of 
€57.4 million per year and €1.15 billion for a 20 year operation of a terminal. With the jobs 
for the construction of the terminals also counted in, the result was 6431 jobs created and the 
value added for 20 year operations €1.17 billion140.  

For the investments assumed for under the different policy options, the increase in the direct 
and  indirect  jobs  is  assessed  to  be  between  1428  and  4759  for  the  9-year  period,  and  the 
resulting economic benefit is between €108.42 and €361.41 million.  

BL 

PO1 

PO2A 

PO2B 

PO3 

138   Impact  Assessment  accompanying  the  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  on 

Union Guidelines for the development of the Trans-European Transport Network, SEC(2011) 1212 final 

139   First  round  effects  concern  direct  employment  in  construction  and  materials  supplying  industries.  A  second  round  of 
employment and income effects occurs in the production sector in response to the demand for additional inputs required 
by  construction  materials  supplying  industries.  A  third  round  employment  and  income  benefits  occur  in  the  guise  of 
what is termed “induced” employment and reflects producers’ response to an increase in the demand for all goods and 
services. Source: OECD, Impact of Transport Infrastructure Investment on Regional Development, 2002 

140   Hacon, Kombiconsult (2015) 

61 

 
  
                                                 
Benefit from job creation (terminal 
support) M€ 

0 

0 

108.42 

361.41 

361.41 

Table 8. Economic value of the potential of the policy options to create jobs compared to baseline scenario by 
2030 

Shift  away  from  road  also  brings  along  social  impacts  as  related  to  public  health.  These 
impacts  are  directly  related  to  the  foreseen  reduction  in  emissions  of  air  pollutants,  any 
possible noise level and the risk of accidents. The positive impact deriving from policy option 
PO1 is negligible, but impacts from options PO2 and PO3 are small and but positive leading 
to savings of up to €390 million by 2030.   

7.  HOW DO THE OPTIONS COMPARE? 

The  impacts  induced  by  this  amendment  derive  from  two  effects.  On  the  one  hand,  the 
reduction  of  cost  inducing  difficulties  brings  along  modal  shift  from  road  to  intermodal 
transport  thus  having  an  effect  on  the  modal  composition  of  transport  and  on  the  negative 
externalities  caused  by  it.  This  effect  contributes  directly  to  the  main  objective  of  the 
Directive to bring along modal shift and the resulting reduction of negative externalities. On 
the  other  hand,  the  amendment  also  brings  along  simplification  of  operations  resulting  in 
reduction  of  cost  for  existing  intermodal  and  combined  transport  operations.  This  makes  it 
more competitive vis-à-vis unimodal road transport and allows the operators to use the freed 
up  assets  for  investments  into  the  sector  in  the  long  term.  The  policy  options  have  been 
analysed for both effects and the results combined.  

As regards the modal shift and resulting reduction of external costs, the options clearly have 
different  levels  of  impact  and  thus  fulfil  the  objective  of  the  Directive  and  the  amendment 
differently.  Policy  options  PO2B  and  PO3  are  the  only  ones  allowing  the  EU  to  reach  its 
target  set  in  the  2011  Transport  White  Paper  for  modal  shift  (30%  of  long  distance  road 
freight to be shifted to more sustainable means by 2030)141. The Option PO3 has clearly the 
largest impact on modal shift, however it also brings along high cost.   

2030 

BL 

PO1 

PO2A 

PO2B 

PO3 

Modal shift induced by the option, 
percentage points of road freight 
Modal shift induced by the option, bn 
tkm 
Additional growth of intermodal 
transport due to modal shift, percentage 
points 
Modal shift target achievement (bn tkm) 
Table 9. Modal shift under different options, tkm. 

0 

0 

0.09 

1.79 

2.86 

7.25 

2.31 

43.68 

69.56 

176.5 

0 
249 

0.28 
251 

5.37 
292 

8.55 
319 

21.7 
426 

7.1.  Key economic, social and environmental impacts 

The analysis of economic impacts shows the most important differences. The main trade-off 
is  between  reduced  price/costs  and  resulting  savings  for  intermodal  transport  operators  and 
costs to Member States authorities as well as costs to competitors.  

BL 

PO1 

PO2A 

PO2B 

PO3 

141   Based on the 2005 road transport data, this amounts to 301 bn tkm 

62 

 
  
                                                 
Expected impact on intermodal 
transport market prices 
Market price difference compared to 
road transport 
Table 10. Expected impact of different options on market price evolution of intermodal transport 

-1.89% 

15.2% 

21.1% 

-7,8% 

0,0% 

23% 

11.1% 

-11.9%  -14.5% 

8,5% 

Table 10 above illustrate the impact on expected market price for intermodal transport of the 
various options, and notably the expected cost reduction expected in each option.   

Table  11  illustrates  the  impact  (%)  of  the  various  cost  reductions  of  each  option  on  the 
additional  cost  of  combined  transport  and  intermodal  transport  compared  to  road  only 
transport operations.  

BL 

PO1 

PO2A 

PO2B 

PO3 

Additional cost (including cost 
components not reflected in market 
price) for CTD operations compared to 
road transport operations  
Additional cost (including cost 
components not reflected in market 
price) for all intermodal operations 
compared to rood transport  
37% 
Table 11. Impacts of various options on cost competitiveness of intermodal and combined transport 

34% 

41% 

33% 

47% 

48% 

38% 

30% 

30% 

30% 

All  the  options  improve  the  competitiveness  of  intermodal  transport  but  differences  are 
considerable. In all options, the intermodal transport remains more expensive than unimodal 
road transport on average distances.  

The price reduction however results in reducing the breakeven distance allowing medium and 
long distance combined transport to compete better with long distance road transport. It is not 
economically  efficient  to  endeavour  to  make  the  short  distance  combined  transport 
economical. 

PO3

PO2B

PO2A

PO1

BL

Intermodal transport without CTD

Unimodal road transport

0

20

40

60

80

100

120

140

160

180

Figure  16.  Summary  of  comparison  of  road  and  intermodal  transport  costs,  all  options,  average  distances,  in 
percentages 

In  terms  of  environmental  impacts,  while  option  PO3  gives  the  highest  absolute  total 
savings  in  external  costs,  it  should  be  noted  that  PO3  would  also  result  in  an  increase  of 
heavier  vehicles  on  the  road  (due  to  the  large  extension  of  the  weights  and  dimensions 
exemption for intermodal transport) , and hence cause substantial additional costs on the road 
infrastructure.  That  is  why,  when  comparing  to  the  costs  to  Members  States  with  the 

63 

 
  
 
environmental  benefits,  option  PO2A  and  option  PO2B  are  the  more  environmentally 
efficient. 

External 
saving 
cost 
through  additional  modal 
shift (2022-2030) (bn €) 

Total  cost  for  authorities 
(bn €) 

BL 

PO1 

PO2A  PO2B 

PO3 

0 

0.054 

1.02 

1.624 

4.12 

0.23 

1.7 

2.9 

8.2 

B/C 

0.234783  0.6 

0.56 

0.502439 

Table 12. Environmental efficiency 

In terms of social impacts, all options will make a positive contribution, however due to large 
distributional  effect  in  option  PO3  on  road  operators  (through  the  extension  of  cabotage 
exemption to unlimited road legs), the option PO2B is more efficient.  

compared to Baseline 
2030 

Achieving modal shift 
target 
Intermodal operations in 
EU covered by the 
Directive 

Increase of price 
competitiveness vis-à-vis 
road transport 

BL 

NO 

PO1 

NO 

PO2A 

PO2B 

NO 

YES 

PO3 

YES 

41.7% 

37.4% 

66.9% 

72.7% 

100% 

Economic benefit  

0 

2% 

11% 

16% 

23% 

Very 
limited 
impact as 
less than 
2% of total 
operations 
benefit and 
this is only 
partially  
transferred 
to end-
consumer, 
€0.005 bn 

0 

0 

Limited 
impact as less 
than 40% of 
total 
operations 
benefit and 
this is only 
partially  
transferred to 
end-
consumer, 
€0.01 bn 

Small positive 
impact as 
support is 
optional and 
not 
harmonised, 
 €0.15 bn  

Small positive 
impact as 
support is 
optional and 
not 
harmonised, 
€0.16 bn 

Positive impact 
€0.74 bn 

€0.93 bn 

€4.73 bn 

€7.02 bn 

€10.6 bn 

Ca 0,1% of 
road hauliers 
loose the 
eligibility 

1.9-2.8% of road hauliers are affected by the 
extension of eligibility for regulatory support, 
mostly through distributional effect and switch 
from long-distance to short-distance operations.  

€0.01bn 

€0.025 bn 

€0.19 bn 

€0.33 bn 

€0.9 bn 

Environmental and social benefit  

0 

54 

1020 

1624 

4120 

64 

Direct annual benefit from 
operational subsidies to 
industry 
Benefit from reduced costs 
(annual) 
Effect of extension of 
eligibility for regulatory 
measures on road hauliers  

Budgetary implications 
(annual) 

External cost saving 
through additional modal 
shift (2022-2030) 

 
  
 
  
  
 
Additional reduction of 
CO2 emissions (kton) 
NOx savings (tons)  

PM savings (tons)  

0 

0 
0 

195 

222 
4 

Impact on jobs € bn 
Table 12. Main economic, environmental and social impacts. 

3693 

4203 
82 
108.42 

5881 

6694 
130 
361.41 

14921 

16984 
330 
361.41 

7.2.  Effectiveness 

The effectiveness of the options depends on their ability to deliver the specific objectives set 
for this amendment. This is analysed in table X.  

compared to Baseline  

PO1 

PO2A 

PO2B 

PO3 

General objective: Increase the competitiveness of intermodal transport vis-à-vis unimodal 
road transport 

Increase  of  price  competitiveness  vis-
à-vis road transport 

+ 

++ 

++ 

++ 

Specific objective 1 : Simplification of eligibility criteria and the controls thereof (SO1) 

Problem  driver:  complex  and  narrow 
eligibility criteria  

Problem  driver: 
enforcement conditions 

lack  of  effective 

+++ 

++ 

++ 

+++ 

+ 

+++ 

+++ 

+++ 

Specific  objective  2:  Increase  the  effectiveness  and  efficiency  of  the  economic  support 
measures  (SO2) 

Problem  driver  :  narrow  scope  of 
support measures 

+ 

Problem  driver:  limited  monitoring 
and no review mechanism 

++ 

++ 

++ 

++ 

++ 

+++ 

++ 

Specific  objective  3  :  Foresee  dedicated  investment  support  for  intermodal  investments 
(SO3) 

Problem  driver:  lack  of  intermodal 
infrastructure (lack of terminals) 

0 

Table 12. Effectiveness of policy options 

7.3.  Efficiency 

+ 

+++ 

+++ 

Efficiency shows the relation of achieved results and the necessary costs to do so. The major 
costs  for  the  policy  options  come  from  the  economic  support  schemes,  in  particular  the 
operational support. The investment support has a delay in application as described above but 
at  the  same  time  a  cumulative  effect  as  terminals  can  be  used  for  many  years  beyond  the 
analysed period (ca 20 years without serious upgrade).  

compared to Baseline, (2022-2030) 

PO1 

PO2A 

PO2B 

PO3 

Total cost for authorities  

€0.23 bn 

€1.7 bn 

€2.9 bn 

€8.2 bn 

Total benefit for society 

€8.6 bn 

€44.7 bn 

€66.3 bn 

€104.2 bn 

Return on investment  

38 

26 

22 

12 

65 

 
 
 
 
7.4.  Coherence 

The objectives of the amendment are in coherence with EU transport policy in general as well 
as EU policy on reducing the negative externalities and in particular reducing the emissions 
from the transport sector as discussed above. The results of the amendment contribute to the 
objectives  of  EU  transport,  environmental  and  climate  policy.  Only  options  PO2B  and  PO3 
support the achievement of the target set in the EU transport policy White paper of 2011.  

As regards increasing the competitiveness of intermodal transport, other previous and current 
initiatives address the same problems in a complementary manner. In particular, the Weights 
and  Dimensions  Directive  foresees  support  for  intermodal  transport  with  an  aim  to 
compensate the additional weight of the empty load unit. The initiative complements also the 
EU initiatives for liberalisation and improved functioning on rail, inland waterways and short 
sea shipping also complement as well as the EU initiatives to support Corridor development 
and EU investment instruments.  

None  of  the  options  foresee  a  contradiction  with  the  road  regulation.  International  road 
transport,  the  competitor  of  international  intermodal  transport  is  fully  liberalised  in  the  EU. 
The rules applying to road legs of combined transport between Member States further stress 
that road legs, even if not crossing the border, are an integral part of the international transport 
operation  and  cannot  be  seen  as  national  transport.  This  has  been  confirmed  by  the  CJEU 
several  times.  The  national  road  transport  is  subject  to  rules  established  in  Regulation  (EC) 
1072/2009.  None  of  the  options  foresees  to  liberalise  the  road  cabotage  rules  for  purely 
national combined transport operations.  

7.5.  Proportionality 

None of the options go per se beyond what is necessary to achieve the objective.  

The  choice of  instrument  (amendment  of  the  Directive)  is  adequate  as it  allows satisfactory 
achievement  of  the  objectives  that  soft  law  would  not  be  able  to  target  as  discussed  in  the 
section Baseline.  

The  scope  of  the  options  is  limited  so  that  the  options  do  not  impose  mandatory  levels  of 
economic support leaving the level and methodology of support to national competence. It is 
thus up to the implementers to ensure that support, in particular operational support, is limited 
to those operations that need the support. Costs to Member States, businesses and citizens are 
limited as compared to potential benefits. In particular terminal support will continue to yield 
benefits beyond the analysed period.  

As a matter of fact, none of the options eliminate totally the price gap between road transport 
and intermodal transport. Option PO3 reduces the gap most, but comes with heavy price tag.  

7.6.  Subsidiarity 

The  objective  of  the  amendment  of  the  Directive  is  to  further  promote  the  shift  from  road 
freight  to  more  environmental  friendly  modes  of  transport,  and  hence  further  reduce  the 
negative  externalities  of  EU  transport  system.  This  objective  is  pursued  by  extending  the 
framework  of  measures  in  support  of  combined  transport  and  by  simplifying  and  clarifying 
the  Directive.  This  objective  cannot  be  sufficiently  achieved  at  Member  State  level 
considering because the majority of freight combined transport is of cross border nature and 
relies on an intermodal infrastructure across member States.  

66 

 
 
Considering  that  close  to  20%  of  European  intermodal  transport  is  national  (intra-Member 
State)  and  currently  not  covered  in  the  Directive,  extending  the  geographical  extension  of 
national combined transport operations will therefore enlarge the scope of support measures 
applicable  to  promote  modal  shift,  moving  an  additional  portion  of  road  freight  to  other 
transport  modes.  This  would  reduce  overall  externalities,  and  notably  greenhouse  gas 
emissions  and  congestion,  which  have  an  impact  beyond  national  borders.  Congestion  at 
regional  or  national  level  directly  affects  all  road  users,  including  those  engaged  in 
international freight transport.  In addition, road congestion, at least until it is managed, tend 
to propagate and produce spill-over effects potentially affecting more than one Member State 
in  cross-border  areas.  Likewise  greenhouse  gas  emissions  and  air  pollution  caused  by  road 
transport do not remain restricted to purely local areas and have a European dimension. 

In  addition,  it  is  justified  also  to  specify  common  support  measures  to  be  taken  by  the 
Member  States  as  it  will  ensure  that  possibly  divergent  measures  in  support  of  combined 
transport would be taken at national level, if taken at all. In particular, as regards investment 
support measures for terminals, a common target, in terms of terminal density, is necessary to 
avoid that over capacity is built, especially along European main freight corridors. 

8.  CONCLUSION – PREFERRED POLICY OPTION 

Based on the above assessment, it can be concluded that while the policy option PO3 would 
bring along the largest absolute economic benefits, its cost to Member States, and hence the 
overall  return  on  investment,  makes  it  less  appealing  than  the  other  options,  which  have  a 
higher return on investment ratio. Option PO3 is also less environmentally efficient than the 
options PO2A and PO2B. Policy option PO1 and PO2A do not deliver as regards the modal 
shift  target  of  the  2011  White  Paper  for  2030.  Furthermore,  the  policy  option  PO1  actually 
reduces the eligibility by 11% and thus causes reverse shift to unimodal road transport. Policy 
option PO2A reduced the eligibility of rail-road combined transport operations and does not 
ensure terminal support (optional) thus limiting its long-term benefits for the EU. Considering 
that Policy Option 2B ensures that the modal shift target for 2030 is reached, delivers a higher 
return on investment and environmental efficiency than Option PO3, Policy option PO2B is 
therefore the preferred option.  

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED 

Taking  into  account  the  character  of  this  Directive,  it  is  of  utmost  important  to  regularly 
assess the impacts of the amended Directive and when necessary review the economic support 
measures  so  that  they  would  reflect  the  market  developments.  Such  review  might  mean 
reducing or increasing the support.  

9.1.  Review of the reporting obligation 

An  effective  monitoring  mechanism  is  particularly  important  as  the  current  monitoring 
mechanism  was  concluded  by  REFIT  evaluation  to  be  ineffective  by  REFIT  evaluation.  
Article 5 of the Directive establishes a biannual reporting obligation on the Commission with 
an aim to analyse regularly the need for further support. However, only two reports covering 
the years up to 1999 were ever published. The gap was filled with the wide-scope CT Study 
and its update covering the years until 2015.  

The reason for not drawing up the reports was the fact that no comparable data is available 
from statistical sources. Most Member States who are supposed to assist the Commission in 
the exercise do not in reality gather or provide the data referred to in Article 5.3, but rather 

67 

 
gathered transport statistics based on four regulations that follow the logic of different modes 
of transport142.  
Thus  the  reporting  obligation  in  the  Directive  needs  to  be  strengthened  in  order  to  allow  a 
systematic  analysis  of  the  market.  The  Directive  needs  to  make  clear  what  data  (definition) 
needs to be gathered and reported as well as what kind of analysis/report is produced by the 
Commission.  The  obligation  to  produce  a report  every two years could also  be  reviewed  as 
developments on the market are usually slower.  

9.2.  Data to be gathered  

The following data on market developments is necessary and should be gathered by Member 
States for effective analysis and reported to the Commission every 3 years:  

  The evolution of the volumes of intermodal transport in general and combined transport as 
covered by the Directive, in TEU and tonne-kilometres, by different modal combinations 
and by different geographic scope. 

  The distance matrixes of intermodal transport road and non-road legs 
  The use of load units (types, shares) 
  Number and average cost of transhipments 
  Share of different cost components in the price of intermodal transport 
  The total volume of economic support provided to combined transport, by type of support 
  Number  of  intermodal  terminals  existing  and  their  capacity  as  well  as  number  of 
intermodal terminals built or extended with public support as well as by private funding 
and  the  added  capacity  during  the  reporting  period.  Average  share  of  public  funding  in 
projects.  

  Distance matrix for terminal locations 
  Changes  in  the  labour  market  such  as  jobs  added  or  shifted  from  road  transport  to 

intermodal transport, working conditions etc. 

  Number of infringements relating to intermodal transport (circumvention of road transport 

regulation through the CT regulatory regime) 

  Other  factors  (regulatory,  economic,  political)  having  had  major  impacts  on  intermodal 

transport during the reporting period 

9.3.  Indicators for assessment 

The following indicators should be monitored during the assessment of the effectiveness and 
efficiency of policy measure: 

a)  Share  of  intermodal  transport  and  combined  transport  (as  covered  by  CTD)  in  road 
freight  transport  and  in  total  freight  transport  in  EU  (including  shipping  in  and 
between Member States), and its evolution 

b)  Modal  shift  from  road  transport  and  in  particular  from  long  distance  road  transport 
(more  than  300  km)  to  intermodal  transport  and  combined  transport,  in  tonne 
kilometres,  

c)  Savings of external costs. 
d)  Increase of intermodal transport volume per 1€ of support provided 
e)  Increase of loading capacity of intermodal load units 

142   Regulation (EU) 70/2012 (road transport), Regulation (EC) 91/2003 (rail transport, Regulation (EC) 1365/2006 (IWW 
transport)  and  Regulation  (EU)  42/2009  (maritime  transport).  Eurostat  publishes  road/rail  CT  data  by  UIRR;  using, 
however, different definition from the CT Directive and covering only 15-20% of the total CT volume in EU 

68 

 
                                                 
f)  Reduction of average distance between intermodal terminals (by transport mode) 
g)  Return of investment (ROI) of economic support to intermodal transport 
h)  Cost  comparison  and  development  of  road  only  transport  and  same  distance 
intermodal  transport  (not  eligible  for  support)  and  combined  transport  (eligible  for 
support) 

The  benchmark  for  these  indicators  are  partly  (a,  b)  the  baseline  developments  of  this 
assessment and  partly (c, d)  will be established in  the first report after all  the changes have 
been phased in.  

A first report should be published 27 months after the new framework enters into force, and 
then every 5 years .  

9.4.  Operational objectives 

Based on preferred option the following operational objectives have been identified: 

Indicator 

Objectives and targets 

Modal  shift  from  road  transport  and  in 
particular  from  long  distance  road  transport 
(more  than  300  km)  to  intermodal  transport 
and combined transport 
Savings of external costs 
Increase  of  loading  capacity  of  intermodal 
load units 
Reduction  of  average  distance  between 
intermodal terminals 
Cost  difference  between  medium  distance 
(300-650  km) 
transport  and 
road  only 
intermodal transport per km 

301 tkm (30% of long distance road transport 
in  2005)  of 
to 
transport  shifted 
intermodal transport as compared to 2005 

road 

€4.04 bn between 2005 and 2030 
9000 loading units per million euros of aid 

Reduction  of  20%  of  areas  where  distances 
between terminals are more than 300 km 
Less than 15% on average 

69 

 
 
 
 
ANNEXES  

ANNEX  1:  PROCEDURAL  INFORMATION  CONCERNING  THE  PROCESS  TO  PREPARE  THE 

IMPACT ASSESSMENT REPORT AND THE RELATED INITIATIVE 

1. Organisation and timing 

The Directorate-General for Mobility and Transport (DG MOVE) was leading the preparation 
of  this  initiative  and  the  work  on  the  impact  assessment  in  the  European  Commission.  The 
agenda planning reference is 2017-MOVE-006 "Amendment of the Directive 92/106/EEC on 
Combined Transport". The initiative was validated on 26 October 2016. 

An  inter-service  steering  group  (ISG),  chaired  by  the  Secretariat-General  with  close 
involvement by DG MOVE, was established in November 2016 in view of the preparation of 
this  initiative.  The  following  Directorates-General  (DGs)  participated  in  the  work  of  the 
group: Secretariat-General (SG), Legal Service (SJ), DG EMPL, DG RTD, DG COMP, DG 
ESTAT, JRC and DG CLIMA. 

The  ISG  met  three  times  on  15  November  2016  and  on  24  May  2017  and  15  September, 
discussing the inception impact assessment, the outcome of the support studies and the draft 
impact assessment. 

2. Consultation of the RSB 

The  Regulatory  Scrutiny  Board  received  the  draft  version  of  the  present  impact  assessment 
report  on  7  June  2017  and  following  the  Board  meeting  on  5  July  2017  issued  a  positive 
opinion  with  reservations  on  7  July  2017.  The  Board  made  recommendations.  Those  were 
addressed in the revised IA report as follows 

RSB recommendations 

Modification of the IA report 

1.  The  description  of  the  context  does  not 
sufficiently  explain  how  this  initiative  fits  in  the 
overall EU acquis for transport of goods and how 
it  forms  part  of  complementary  modal  shift 
efforts.; 

for  different 

2.  The  report  lacks  a  clear  identification  of  the 
investment  needs 
types  of 
infrastructure  and  other  bottlenecks  to  combined 
transport.  It  does  not  sufficiently  make  the  case 
for transhipment terminals as a critical bottleneck 
further  development  of  combined 
to 

the 

Explanations  on  how  the  initiative  fits  in  the 
overall  EU  acquis  for  transport  of  goods  and 
on the complementarity with existing existing 
initiaves 
the  promotion  of 
mutlimodality  and  the  support  to  modal  shift) 
were  added  in  the  introduction,  in  section  1.1 
on policy context and are further described, as 
needed, in various parts of the text.  

(to  address 

Further  explanations  on 
infrastructure 
bottlenecks  and  how  they  affect  the  overall 
problems that this initiative is addressing have 
been added in section 2.1.2. 

the 

Specific 

relevant 

references,  notably  as 

70 

 
 
 
 
 
 
transport.; 

regards  the  existing  limitations  and  needs  in 
terms  of  terminals  of  the  rail  infrastructure, 
to  help  quantify  such 
have  been  added 
bottlenecks 
required 
the 
investments. 

expected 

and 

3.  The  subsidiarity  argument  for  this  initiative  is 
not  sufficiently  developed,  especially  for  the 
inclusion of strictly domestic transport.; 

Section 3.3 explaining why the EU should act 
has  been  expanded  to  further  cover  the  EU 
dimension of the capacity bottleneck.  

Further  explanation  on 
the  subsidiarity, 
notably  as  regards  the  inclusion  of  national 
combined  transport  in  the  definition,  but  also 
infrastructure 
regarding 
investemnet  measures  has  been  introduced  in 
in new section 7.6. 

the  adoption  of 

Further considerations on the need to act at EU 
level,  and  not  to  limit  the  intervention  at 
national  level, are justified in various parts of 
the text, and notably as regards the need for a 
minimum  density  of  infrastructure  in  section 
2.1.2. 

4.  The  impact  analysis  does  not  sufficiently 
explain  the  underlying  basis  for  and  possible 
uncertainties  of  the  benefits  of  this  initiative.  Its 
conclusions, therefore, may be overly optimistic; 

A  more  detailed  description  of  the  baseline 
scneario,  together  with  an  explanation  of  the 
used  in-house  analytical  model,  have  been 
added in section 6 and Annex 4.  

Further 
recommendations 

considerations 

and 

adjustment 

(1) Context 

The  report  should  clearly  place  this  initiative  in 
the broader context of EU policy for the transport 
of  goods.  It  should  emphasise  complementarities 
between this proposal and other initiatives aimed 
transport  or 
at  disincentivising 
road-only 
encouraging  other  modes  of 
transport.  A 
presentation  of  the  acquis  should  also  include 
relevant  competition  rules  (e.g.  on  state  aid)  and 
how they affect Member States' current ability to 
support  shifts  in  modes  of  transport.  The  report 
should  point  out  the  importance  of  combined 
transport for climate policy commitments.. 

The  description  of  the  in-house  model  in 
the  underlying 
Annex  4  also  explain 
assumptions,  as  well  as  the  modelisation  to 
derive the imapcts for each model.  

. 

The  place  of  the  initiative  in  the  broader 
context  of  EU  policy  for  transport  of  goods 
has  further  described  with  a  description  in 
section 1.1 of the interaction of the Combined 
Transport  Directive  with  the  Weights  and 
Dimension  Directive  and  with  the  Regulation 
(EC)  1072/2009  notably  establishing 
the 
caboatge rules.  

A  description  and  reference  to  the  measures 
under  the  Low-Emission  Mobility  Strategy 
and  the  related  proposals  under  the  Mobility 
Pacakage  ("Europe  on  the  Move")  has  been 
added  in  section  1.1.  The  importance  of  the 
initiative  for  climate  policy  commitments  is 
also underlined under section 1.1  

71 

 
 
 
 
(2) Problem definition  

for 

further 

Before  calling 
in 
transhipment  terminal  capacity,  the  report  needs 
to  further  demonstrate  that  this  is  the  decisive 
bottleneck  that  restricts  modal  shift  potential  in 
the EU.  

investment 

Building  on  a  revised  context  description,  the 
report should clarify why such investments would 
not  take  place  in  isolation,  but  would  in  synergy 
with  a  package  of  existing  and  upcoming 
measures,  including  the  further  internalisation  of 
external costs of road transport. By doing so, the 
report  should  provide  reassurances 
that  this 
initiative  does  not  risk  creating  unused  terminal 
capacity. 

 The  problem  definition  should  also  better 
segment the definition of the needs, strengths and 
weaknesses of different sub-modes with a view to 
later  demonstrate  how  the  proposed  measures 
would  lead  to  a  credible  and  feasible  shift  in  the 
distribution of transport modes for freight.  

In  the  case  of  rail  transport,  this  entails  a 
description of how issues such as speed, capacity 
and  reliability  are  being  managed  to  make  it  an 
appealing alternative to road transport.. 

(3) Subsidiarity  

the 

Further  explanations  on 
infrastructure 
bottlenecks  have  been  added  in  section  2.1.2, 
pointing  at  the  needs  in  term  of  terminal 
infrastructure,  especially  as  regards  rail/raod 
combined transport.  

A  clarification  on  the  complementary  of 
measures  and  the  need  of  coordination  at 
European level to avoid the creation of unused 
capacity.has been added in Section 2.1.2. 

Elements pointing at the respective regulatory 
and  technical  evolutions  of  the  sub-modes, 
with  their  limits  and  constraints  have  been 
added  in  Section  2.1.1.3.  Further  explanation 
on  the  capacity  situation  and  evolution  of  the 
sub-modes has also been added section 2.1.2. 

In  particular,  a  description  of  the  specific 
issues related to rail transport has been  added 
in  section  2.1.1,  pointing  notably  at  the  work 
(EU)  No 
conducted  under 
913/2010 on rail freight corridors, and the rail 
priorities set in the TEN-T Guidelines.  

  Regulation 

The  report  should  strengthen  the  need  for  EU 
action by providing further evidence that national 
initiatives  will  not  sufficiently  develop  on  their 
own, and that the scale of operations requires EU-
level  intervention.  The  report  should  include 
additional  arguments  on  the  cross-border  nature 
of the problem and its solutions, such as the long 
break-even  distance 
for  combined 
transport  to  become  cost  effective.  Substantiated 
arguments  are  especially  relevant  because  the 
scope  of  the  revised  directive  includes  strictly 
domestic transport. 

required 

Section 3.3 explaining why the EU should act 
has  been  expanded  to  further  cover  the  EU 
dimension of the capacity bottleneck.  

The cross-border nature of most of the inititve 
has been  underlined in several sections of the 
report,  and  notably  pointing  at  the  network 
capacity  dimension  (section  2.1.2).  Further 
explanation  as  regards  the  justification  of  the 
inclusion of national combined transport in the 
definition,  but  also  regarding  the  adoption  of 
infrastructure  investemnet  measures  has  been 
introduced in in new section 7.6. 

(4) Impacts 

should 

impacts 

analysis  of 

further 
The 
substantiate,  and  qualify  as  necessary,  optimistic 
forecasts  in  terms  of  modal  shift  resulting  from 
this initiative. At present, limited transparency on 
the  assumptions  and  specifications  of  the  model 
used to quantify impacts makes it hard to appraise 
the validity of the estimates provided. The report 

The  in-house  model  used  derive  the  expected 
modal  shift  figures  and  resulting  beenfits,  for 
each option, is further described in Annex 4 of 
this 
the 
IA.  This  description  provides 
methodology,  basic  assumptions  and  other 
specification of the model.  

Additional considerations and clarifications on 

72 

 
 
 
 
 
 
 
 
 
 
 
 
the social imapcts have been added in section 
6.3.  As  regards  the  concerns  of  operators  on 
the  effects  of  cabotage  rules, 
these  are 
explained  in  various  sections  of  the  report 
(notably  2.2.1)  :  notably  by  reinforcing  the 
means  to  verify  the  eligibility  conditions, 
existing  concenrs  notably  as  regards  possible 
abuses  from  the  cabotage  exmeptions  will  be 
addressed.  

should be more explicit on the methods used, the 
limitations  faced  and  the  assumptions  made  (e.g. 
in 
terms  of  elasticity  between  modes  of 
transports,  combined  effect  with  complementary 
support  measures).  This  should  ensure  that  the 
calculations can be replicated and would enhance 
their  credibility.  The  expected  social  impacts,  in 
particular the ambitious estimates in terms of job 
creation,  should  be  put  into  perspective,  given 
stakeholders'  concerns  about  massive  distortions 
of  competition,  loss  of  jobs,  deterioration  of  job 
quality  and  a  possible  decline  of  employment  in 
substantial 
some  Member  States  due 
differences  in  wages  and  social  standards.  The 
report  should  also  better  address  stakeholder 
concerns  about  the  effects  of  cabotage  rules  on 
the national combined transport operators. 

to 

3. External Expertise 

External contractors were used in preparation of the Impact Assessment with:  

- 
- 

- 

a study on the collection of cost related data143, concluded in March 2017; 
a  study  for  the  update  of  the  combined  transport  market  overview144,  concluded  in 
March 2017; 
a  study  summarising  the  consultations  in  support  of  the  Impact  Assessment145, 
concluded in July 2017 

143   TRT (2017)  – Gathering additional data on EU combined transport 

144   ISL+KombiConsult (2017), Updating EU combined transport data – Final Report 

145   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

73 

 
 
 
 
                                                 
ANNEX 2: STAKEHOLDER CONSULTATION SYNOPSIS REPORT 

1. Consultation strategy 

Consultations were carried out with an aim to get feedback on the proposed policy measures 
and the likely impacts of those measures. The stakeholders were consulted on the issues that 
were not addressed in previous public consultation (REFIT). The consultations were expected 
to give an overview on how different stakeholder groups view the proposed policy measures 
and options, how these are expected to influence them as well as to establish the stakeholders 
preferred option. 

The consultation activities included: 

1.  A  public  consultation  was  carried  out  in  the  form  of  an  open  internet-based  public 
consultation running for 12 weeks. The consultation was held from 23/01/2017 to 23/04/2017 
via EUSurvey tool and via DG MOVE's consultation page. 

2.  A  targeted  (more  technical)  stakeholder  consultation  was  held  from  10/03/2017  to 
31/03/2017  with  the  help  of  an  external  consultant.  The  main  focus  of  the  targeted 
consultation  was  on  the  definition  and  the  economic  incentives  and  will  be  customised  for 
different  groups  of  stakeholders (industry,  Member  States,  social  partners  and  other  interest 
groups). 

3. A stakeholder meeting was organised on 30 March 2017, allowing stakeholder groups who 
participate in the targeted consultation to exchange views. 

4. An additional Member States" meeting was held on 10 April 2017.  

2. Results of open public consultation 

See Consultation Report146 

3. Results of the targeted consultation 

See Consultation Report 

4. Results of the stakeholder meetings 

See Consultation Report 

5. Conclusions and use of results 

Both the transport and logistics sector and the authorities urgently call for an amendment of 
the CT Directive 92/106/EEC. The existing legislation is considered outdated, the regulatory 
and economic support for CT operations inadequate and the conditions for eligible operations 
not appropriate with regard to modern supply chain solutions and the competitive situation of 
CT services. The strong interest of stakeholders in the amendment process clearly is reflected 
in the high rate of participation to each consultation. It is particularly encouraging that a clear 

146   KombiConsult-Intermodality (2017), Consultations and related analysis in the framework of impact assessment for the 

amendment of Combined Transport Directive (92/106/EEC) 

74 

 
                                                 
majority  of  respondents  to  the  open  and  the  targeted  consultation  were  transport  business 
associations and private enterprises, most of them involved in CT operations on the demand 
or supply side or, in a few cases, on both. 

The main conclusions that can be drawn from the wide range of stakeholders’ opinions and 
recommendations submitted to the consultations are presented below. 

CT definition 

The huge majority of stakeholders advocate an  extension of  the  geographical  scope  of the 
Directive  to  purely  national  transports  and  operations  with  non-EU  countries.  They  expect 
substantial  positive  impacts  on  CT  volumes  and  environment.  Despite  that  clear  vote  some 
concerns should be taken into account. If, in these cases, CT operations were exempted from 
the cabotage rules of road-only haulage the differences in wages and social conditions among 
Member  States  and  with  third  countries  might  cause  distortions  of  competition.  In  addition, 
the Commission is asked to examine if the extension to national operations might infringe the 
principle of subsidiarity.  

The  future  definition  of  CT  and  possible  changes  to  restrictions  of  the  road  leg  in  CT 
operations raised the largest amount of statements and comments, often controversial. Many 
stakeholders prefer to maintain the current limitations of the road leg or make them slightly 
more  flexible  but  emphasise  that  it  should  be  as  short  as  possible.  In  contrast,  the  private 
sector in particular made out a strong case for not restricting the road leg at all. Interestingly, 
across  all  stakeholder  groups,  positive  impacts  on  CT  volumes  are  rather  expected  from  an 
increased flexibility than from the existing definition.  

In spite of obvious differences of stakeholders’ interests a possible consensus model emerged 
from the consultations. The existing CT definition could be retained including distinguishing 
between  rail  and  waterborne  CT  operations.  Representatives  of  ports,  inland  waterway  and 
rail transport delivered reasonable arguments for keeping the 150 km limit in place to prevent 
a reverse modal shift. As concerns CT rail/road operations it is suggested to not focusing on 
the “nearest” but on the most “suitable” transhipment point. The Directive should include EU-
wide harmonised guidelines for determining the “suitability” of a facility by more “technical” 
criteria  such  as  the  availability  of  appropriate  handling  facilities  and  capacities  or  regular 
(daily) service on the relevant route. Logistics and economic criteria may also be taken into 
account, for example, the operator’s ability to catch return loads, minimise empty runs and the 
total  length of the round  trip  to  and from the transhipment facility. If an operator  could  not 
provide proof of eligibility at road-side checks he should have the opportunity to deliver it at a 
later date.   

On the non-road leg, there was little support for any of the proposed options. The current 100 
km threshold is virtually not important for CT rail/road. Stakeholders with an interest in this 
CT  sector  therefore  may  be  indifferent  to  a  change  of  the  definition.  It  is,  however, 
recommended  to  consider  that  this  limitation  is  counter-productive  for  CT  operations  by 
inland  waterway.  These  services  contribute  to  decongest  the  road  network  especially  in  the 
hinterland of major EU sea ports. 

All stakeholder groups propose to retain the existing scope of load units. Opinions, however, 
were  somewhat  divided  about  the  need  for  a  minimum  unit  length  of  20  feet.  In  terms  of 
efficient  and  competitive  CT  services  it  is  strongly  recommended  to  keep  this  threshold  in 
place  as  it  enables  standardised,  “industrialised”  CT  operations  as  well  as  fast  and  efficient 
transhipment services. 

75 

 
Stakeholders agreed that the transhipment point between modes of transport should be defined 
in  the  amended  Directive  by  “intermodal  terminal”  or  “CT  terminal”  and  thus  replace  the 
current terms “rail loading station” and “port”.  

Support measures 

The support offered under the current CT Directive is insufficient and often disproportionate 
to  promote  CT  operations  in  the  EU  except  for  the  free  cabotage,  which,  however,  has  not 
been  transposed  in  national  law  in  each  EU  Member  State.  Almost  every  stakeholder 
therefore suggested to creating a more beneficial framework of incentives. The most popular 
option is for fully harmonized measures: mandatory, based on the same methodology and at 
the same level in each Member State.  

As  concerns  regulatory  support  measures  two  instruments  are  considered  particularly 
effective in terms of modal shift and environmental benefits and are also advocated by a huge 
majority of stakeholders: 

  The exemption of intra-EU CT operations from road-only cabotage provisions should 
be retained. The initial and final road legs are implicit components of the cross-border 
operation  and  hence  cannot  be  considered  as  domestic  haulages  according  to 
Regulation  1072/2009.  Albeit,  an  unrestricted  cabotage  might  cause  distortions  of 
competition  on  national  transport  markets  owing  to  different  social  standards  among 
Member States. An amended CT Directive therefore may have a link with the posting 
of workers Directive; 

  The  44  tonnes  derogation  from  the  40  tonnes  limit  for  CT  operations  according  to 
Directive  (EU)  2015/719  should  be  extended  to  each  CT  load  unit  defined  in  an 
amended CT Directive. This particularly applies to semi-trailers, which are considered 
by stakeholders as key to boost continental CT rail/road volumes.  

Whilst  all  stakeholder  groups  basically  agree  on  a  free  cabotage  for  intra-EU  goods  flows, 
opinions  are  clearly  divided  on  applying  this  measure  if  the  scope  of  the  Directive  were 
extended  to  national  and  third  country  transports.  When  amending  the  Directive  the 
Commission  should  take  due  account  of  concerns  about  massive  distortions  of  competition 
and  a  decline  of  employment  in  respective  Member  States  due  to  substantial  differences  in 
wages and social standards. 

Member States tabled very interesting ideas. They called for simplifying and accelerating the 
notification  procedure  for  state  aids  or  even  incorporating  the  CT  sector  in  the  block 
exemption regulation. Member States would get more flexibility in setting up incentives and 
thus the support would be faster “to the market”. 

In terms of direct economic incentives under the CT Directive, the consultations suggested 
general support for extending the support to all CT movements in each modal combination. 
Stakeholders provided a wide range of proposals to make the CT industry more competitive 
and encourage the use of CT services. The following measures are considered delivering the 
strongest positive impacts on CT volumes: 

  Private  investors  should  receive  grants  for  investments  in  open-access CT  terminals. 
By reducing the transhipment costs they facilitate the market access both for suppliers 
and users of CT services. It was also suggested to earmark an EU budget, for example 
in CEF, in addition to national funds; 

76 

 
 
 

  As  an  alternative  or  a  complimentary  measure  to  terminal  investment  grants  CT 
services  could  be  supported  by  a  financial  contribution  per  load  unit  moved  or 
transhipped; 
Incentives should be granted for CT-related IT investment and the implementation of 
innovative  CT  solutions  and  technologies  such  as  the  deployment  of  cleaner  trucks, 
measures to reduce CO2 emissions, or the investment in "craneable" semi-trailers; 
  As concerns CT operations involving rail, a reduction and harmonisation of rail access 
charges  across  Member  States  would  enhance  the  competitiveness  of  respective  CT 
services and foster modal shift.  

Overall negative impacts are anticipated if two other economic incentives were implemented 
and  are  therefore  not  recommended.  Experience  from  earlier  support  programmes  tells  that 
subsidies  to  support  the  start-up  of  new  CT  services  tend  to  cause  discriminatory  effects  in 
relation to existing operations. The reduction or reimbursement of road tolls for CT operations 
might imply a cross-subsidization from road to CT. In addition, this measure appears to be not 
consistent with the “user pays principle”.  

Proof of eligibility 

Road hauliers who carry out CT operations eligible for any support should be able to provide 
a proof of eligibility. Virtually all stakeholders agree on this requirement. They also demand 
for introducing a system based on electronic documents or information, which can replace the 
outdated  paper  document  and  stamp  system.  Member  States  should  be  required  to  accept 
electronic data as proof of eligibility, based on requirements and data standards as agreed on 
EU level. In a second step, a single document, for example, an intermodal e-CMR could be 
introduced,  which  all  Member  States  accept.  The  contents  of  the  documentation  should  be 
limited to the information required for demonstrating compliance with the CT definition. 

The consultations did not produce a conclusive answer where or when the proof of eligibility 
should be delivered to authorities. Whilst 80% of the respondents to the public consultation 
agreed that it is important to verify the eligibility of operations at road-side checks, the most 
popular choices of respondents to the targeted consultation were “On request at a later date”, 
“At  company  premises”  and  “At  transhipment  points.”  Consensus  among  the  majority  of 
stakeholders may be reached if operators were allowed to supply proof not only at road-side 
checks but also at a later stage, for example, after a defined period of days.   

Monitoring and review   

The  consultations  displayed  a  strong  interest  of  most  stakeholders  in  regularly  receiving 
information  on  the  state  of  CT  operations.  CT-related  data  should  be  collected  based  on  a 
common  EU  definition  and  published  regularly.  More  comprehensive  reports  should  be 
prepared, for example biannually.  

It is further suggested to reviewing the amended Directive within a certain period of time, e.g. 
every 5 years, to keep it updated with changes in logistics and other legal framework. 

77 

 
 
 
 
 
ANNEX 3. WHO IS AFFECTED BY THE INITIATIVE AND HOW 

Society as a whole 

Negative  externalities  affect  the  society  in  general  though  some  impacts  are  more  of  global 
and some of local nature.  CO2 emissions from transport contribute to climate change, which 
is a global issue as greenhouse gases emitted anywhere contribute to global warming, rising 
sea  levels,  extreme  weather  conditions  or  desertification,  with  poorer  world  regions  being 
most  vulnerable.  Mitigation  measures  have  to  be  taken  at  all  levels  of  governance  and 
budgetary implications affect the entire population. 

Air pollution generated by road traffic, road congestion and accidents on the other hand are 
primarily  local  externalities,  affecting  communities  living  where  the  externalities  occur. 
Congestion  on  the  interurban  and  suburban  networks,  in  particular  on  road  axes  of 
international 
the  TEN-T  network,  also  negatively  affects 
international traffic and logistics sector and thus production.  

importance  belonging 

to 

The  direct  benefits  for  the  society  grow  in  correlation  with  the  modal  shift  induced  by 
respective options. However the most ambitious option, policy option PO3 also brings along 
most of negative impacts on industry and Member States.  

Economic operators 

Logistics operators, freight forwarders and shippers are impacted by having less choices for 
their  transport  needs,  or  in  case  of  choosing  intermodal  transport,  higher  transport  cost 
potentially  making  the  transported  goods  less  competitive.    The  specific  problems  with  the 
current  Directive  are  in  practical  terms  mostly  felt  by  those  who  organise  the  combined 
transport chains and who have to take into account the different definitions used in different 
Member  States  for  the  regulatory  benefits  when  finding  subcontractors,  choosing  terminals, 
preparing transport documents or in order to plan the loading (weight) of the load unit.  

The lack of equal footing for non-road transport impacts in particular the operators in those 
sectors  making  their  businesses  less  competitive.  The  road  sector  itself  is  impacted  as  long 
distance road transport brings along social costs due to lower quality jobs, impacts on family 
and social life etc. The specific problems of the current Directive are practically felt often by 
road hauliers as they encounter the problems and confrontations at the road side checks when 
being  unable  to  prove  their  operations  to  be  combined  transport.  It  is  their  vehicles  are 
confiscated, their drivers who have to face the police, they who face fines for claimed illegal 
cabotage, and in case of SMEs, it is the hauliers doing the CT road legs that face the highest 
risk  of  going  bankrupt  due  to  disruptions  caused  by  ineffective  definition  and  control 
mechanisms of this Directive.  

Options PO1 and PO2A impact negatively rail-road combined transport operators and  users 
(logistics  operators,  freight  forwarders,  shippers),  while  having  least  impact  on current  road 
transport  operators  (as  modal  shift  is  limited).  The  short  sea  shipping  combined  transport 
sector wins somewhat. The policy option PO2B and PO3 have larger positive impact on all 
economic  operators.  The  CT  operators  win  from  reduced  price  and  increased  access  to 
terminals;  this  reduction  is  carried  over  to  users  and  thus  has  widest  positive  impact  on 
economy.  Road  transport  operators  will,  in  particular  in  option  PO3  be  to  certain  degree 

78 

 
 
(2.9%  and  8.3%  respectively)  adapt  and  shift  from  long  distance  road  transport  to  short 
distance road legs. The latter shift brings along an increase in the quality of jobs in the road 
sector.  

Member States 

Member  States  are  affected  through  various  channels.  From  one  hand,  inefficient 
infrastructure usage creates additional investment and maintenance cost in road sector, from 
the  other  hand,  negative  externalities  cause  health  problems  and  increase  public  health 
expenditure.  Finally,  climate  change  can  create  various  problems  for  society  and  economy 
leading to potentially very high expenditure in the future.  

Different options bring along different costs for Member States mostly through the economic 
support  measures.  The  economic  support  is  limited  but  mandatory  in  policy  option  PO1, 
optional in policy option PO2A and optional for operational support and mandatory (but not 
harmonised) for terminal support in PO2B and mandatory (but not harmonised) in PO3.  

Furthermore,  all  options  foresee  the  mandatory  acceptance  of  electronic  documents/data, 
simplifying  the  control  of  eligibility  for  regulatory  support  measures  and  thus  reducing  the 
time spent on it. This brings along cost savings for controlling authorities.  

All  options  also  foresee  improved  data  gathering  and  reporting  obligations  as  well  as 
transparency and cooperation provisions. These will bring on initial administrative burden (in 
particular  as  regards  data  gathering)  but  are  essential  to  ensure  that  the  economic  support 
measures could be reviewed in the future as necessary.  

79 

 
 
 
 
ANNEX 4: ANALYTICAL MODELS AND EXTERNAL EXPERTISE USED 

The analytical work for this impact assessment is based on the PRIMES-TREMOVE transport 
model  and  on  a  model  for  intermodal  transport  developed  in-house,  based  on  data  gathered 
and  projections  by  external  consultants.  The  analytical  work  has  been  mostly  carried  out  at 
EU level and for certain questions (e.g. number and cost of transhipments) at Member State 
level.  

  Geographical coverage: EU level, for certain questions all Member States separately.  
  Time horizon: 2005 to 2030 (5-year time steps).   
  Transport modes covered: road freight, rail freight, freight inland navigation and short 
sea  shipping  freight  in  intermodal  loading  units  (container,  swap-body,  trailer  or 
semitrailer, and for accompanied transport lorry).  

1. Description of analytical models used 

1.1 PRIMES-TREMOVE 

PRIMES-TREMOVE transport model is a building block of the modelling framework used for 
developing  the  EU  Reference  scenario  2016,  and  has  a  successful  record  of  use  in  the 
Commission's transport, climate and energy policy analytical work – it is the same model as 
used for the 2011 White Paper on Transport and the 2016 European strategy on low-emission 
mobility.  In  this  impact  assessment,  it  has  been  used  to  define  the  Baseline  scenario  and 
external  cost  impacts,  having  as  a  starting  point  the  EU  Reference  scenario  2016  but 
additionally including few policy measures that have been adopted after its cut-off date (end 
of 2014), and external cos impacts.  

The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  transport  demand  by 
transport mode and  transport  mean. It does  not  include specifically intermodal or  combined 
transport. It is essentially a dynamic system of multi-agent choices under several constraints, 
which are not necessarily binding simultaneously. The projections include details for a large 
number  of  transport  means,  technologies  and  fuels,  including  conventional  and  alternative 
types, and their penetration in various transport market segments for each EU Member State. 
They  also  include  details  about  greenhouse  gas  and  air  pollution  emissions  (e.g.  NOx,  PM, 
SOx, CO), as well as impacts on external costs of congestion, noise and accidents. 

In  the  transport  field,  PRIMES-TREMOVE  is  suitable  for  modelling  different  types  of 
measures  including  economic  measures (e.g.  subsidies  and pricing  measures  of  externalities 
such as air pollution, accidents and noise). Used as a module which contributes to a broader 
PRIMES scenario, it can show how policies and trends in the field of transport contribute to 
economy  wide  trends  in  energy  use  and  emissions.  Using  data  disaggregated  per  Member 
State, it can show differentiated trends across Member States.  

The  PRIMES-TREMOVE  is  a  private  model  that  has  been  developed  and  is  maintained  by 
E3MLab/ICCS  of  National  Technical  University  of  Athens147,  based  on,  but  extending 

147   Source: http://www.e3mlab.National Technical University of Athens.gr/e3mlab/  

80 

 
 
                                                 
features  of  the  open  source  TREMOVE  model  developed  by  the  TREMOVE148  modelling 
community.  

1.2 Specific in-house model on Combined Transport  

As none of the more commonly used models in EU transport policy development includes a 
specific  feature  for  intermodal/combined  transport,  a  specific  model  was  built  in-house  for 
analysing  the  trends  of  intermodal  and  combined  transport.  It  assesses  the  evolution  of 
different  scenarios  based  on  assumptions  used  in  the  baseline  scenario  developed  with  the 
PRIMES-TREMOVE  model,  in  the  2015  CT Study  (and  its  2017  Update)  and the  CT  Cost 
Study. The impacts are shown at EU level, with some impacts also modelled at Member State 
level.  

The model considers:  

- 

- 

the  evolution  of  road  freight  above  300km;  the  evolution  of  intermodal  freight;  the 
geographical coverage covered by the definition of Combined Transport in the Directive;  
(for  each  of  the  option),  the  impact  of  cost  reduction  (obtained  through  simplification 
measures and/or though new/updated support measures) on  

o 

o 
o 

the portion of intermodal freight traffic covered the CTD, i.e. the actual "combined 
transport";  
the portion of intermodal freight traffic not covered by the CTD  
the shift from road freight traffic to intermodal or "combined" freight (through cost 
reduction) 

- 

in  addition,  as  regards  the  external  cost,  the  "shifted  amount"  is  used  as  the  basis  for 
calculation of externalities, and hence the savings achieved by this "modal shift" 

As  regards  the  modal  shift  "gap"  to  fill  in,  the  following  figures/assumption  are  taken  :  the 
portion of road freight above 300km is 56%; so the target shift target (of 30% of road traffic 
over 300km) by or 2030 is calculated to be 301 Bn tkm.  
The current model (EU 2016 reference scenario) for the baseline is projecting a total modal 
shift  of  249  Bn  tkm  by  2030  (for  road  freight  above  300  km).  The  gap,  in  terms  of  modal 
shift, that remains to be filled is 52 (i.e. 301 – 249) Bn tkm.  

For each option, the average cost reduction (in €/km) on the average price of CT/IM (€/km) is 
calculated  based  on  the  measures  applied  in  that  option.  Extrapolating  from  the  impact  of 
price  reduction  on  modal  shift  from  the  German  study149,  the  affected  modal  shift  is  then 
calculated.  

General modelling assumptions:  

-  For policy measures that are not mandatory (economic support measures) in some options 
an average impact is assessed based on existing similar measures and their established 
impacts. 

148   Source: http://www.tmleuven.be/methode/tremove/home.htm  

149   KombiConsult-Hacon (2015), Gutachten zur Evaluierung des Förderprogramms für Umschlaganlagen des Kombinierten 

Verkehrs Aktenzeichen Z30/SeV/288.3/1440/G22 

81 

 
 
 
 
 
                                                 
-  The Combined Transport Directive does not create any obligations to economic operators 
to follow its definition. The definition is purely an eligibility criterion to receive support 
from  the  directive  and  operators  are  free  to  provide  intermodal  operations  that  are  not 
eligible for support measures. The behaviour of economic operators is modelled based on 
existing experience from similar past and current measures. 

-  The  current  Combined  Transport  Directive  includes  one  mandatory  and  one  optional 
economic  support  measure.  Options  2  and  3  foresee  wider  economic  support,  but  they 
leave specific decisions including the choice of type of operational support totally to the 
Member States. Quantifying the impacts of such options requires making assumptions on 
the  uptake  of  these  support  measures  by  Member  States.  For  example,  the  optional 
measure in the current Directive is only used by 3 Member States, and even the mandatory 
one  is  not  implemented  by  9  Member  States.  For  this  reason  quantification,  including 
modelling results will only be used to indicate the scale of foreseeable impacts rather than 
their exact estimation.  
It is assumed that Member States who already have economic support measures in place 
that go beyond the current Directive, but are covered by any of the options will keep these 
measures even if they are optional. This assumption has been used as modelling input.  
-  The impact on Member States budgetary burden is assessed based on examples from some 

- 

Member States who have already used similar measures to support modal shift 

Additional specific assumptions (from industry):  

- 

- 

- 

estimated  saving  of  using  electronic  documents  (such  as  eCMR):  on  average  5€  per 
shipment 
cost of non-homogenous transposition/implementation of CTD : 4.36% of total shipment 
price; 
cost of organising a new combined transport route : between 200 and 1000€, depending on 
operations;  

-  uptake of (optional) operational support measures by Member States : 30% 
-  uptake take of (optional) investment support measures by Member States : 50% 
- 

estimated  overall  (max)  impact  on  cost  of  operational  support  measures  (if  all  measures 
are mandatory) : 1.5% reduction  

2. Data  

As comparable data on intermodal transport is not readily available from statistical sources, 3 
studies were carried out to gather the specific data (one in 2013-2014 and two in 2016-2017). 
The data specifications, sources and definitions used are explained below. 

The  statistical  data  on  CT  rail/road in  the  EU  are  overwhelmingly  based  on  the  results of  a 
survey among primary sources in 2016. The survey included, first of all, the collection of data 
from nearly 130 CT service providers, the UIRR statistics, Eurostat, Member States statistical 
authorities and KombiConsult’s permanent database.  

82 

 
 
 
 
 
Rail-road CT intra-MS and intra-EU CT volumes only relate to continental shipments of CT 
load units. Intra-MS internationally connected CT and intra-EU internationally connected CT 
operations comprise of a range of maritime CT and continental CT volumes.  

The  data  on  inland  waterways  is  based  on  Eurostat  national  statistics  mirror  checking  and 
specialised  national  statistics  as  well  as  modal  split  data  of  seaports  Rotterdam,  Antwerp, 
Hamburg,  Bremerhaven  and  Zeebrugge.  For  the  aforementioned  four  countries,  the  results 
from the North European Container Traffic Model (NECTM) were used.  

CT  inland  waterway/road  only  consists  of  container  traffic  (ISO  plus  domestic  containers). 
More  than  99 %  of  the  traffic  has  origins  or  destinations  in  the  Netherlands,  Belgium, 
Germany  or  France.  The  share  of  CT  inland  waterway/road  not  connected  to  seaborne 
transport  is  very  small  and  in  most  cases  relates  to  the  repositioning  of  empty  containers 
between import and export regions.  

For short sea shipping, data was based on Eurostat and port statistics mirror checking and ISL 
database.  Origin/destination  matrices  (countries  and  coastal  areas)  of  container  traffic  in 
tonnes and TEU as well as of ro-ro shortsea traffic in tonnes were generated. For ro-ro traffic, 
the TEU figures were estimated based on a sample of ports providing both the  tonnage and 
the  number  of  units  in  this  traffic  segment.  The  tonnage  figures  provided  by  the  ports  to 
Eurostat exclude the tare weight of load units so these were estimated based on the number of 
units.  In  order  to  estimate  the  share  of  internationally  connected  shortsea  traffic  (feeder 
traffic), the services behind the major port pairs were analysed with regard to their potential 
feeder share.  

The  road  leg  (pre-/post-carriage)  was  based  on  data  reported  by  the  liner  operators  for  the 
seaports.  For  rail-road,  intra-MS  and  intra-EU  operations  include  2  road  legs,  while 
internationally  connected  operations  only  include  a  single  road  leg  in  the  EU.  In  CT 
operations involving a container, the road transport includes transportation of empty container 
to and from depot. 

Transhipment  and  cost  data  is  based  on  the  specialised  survey  conducted  in  the  CT  Cost 
Study150  among  intermodal  transport  managers.  More  than  1000  companies  and  120 
associations were invited to participate in the survey. 103 replies were received covering all 
modal combinations.  

Any remaining gaps and the validation of the estimates is based other sources, including TRT 
and  MDS  in-house  expertise  and  data  provided  by  ISL  and  KombiConsult.  In  order  to 
estimate the number of transhipments in each EU Member State (i.e. to provide a breakdown 
of the totals by modal combination), the consultancy team estimated the proportion handled in 
each  Member  State  for  the  rail/road,  IWW/road  and  SSS/road  combinations  using  different 
sources  and  combining  Eurostat  data  (for  the  IWW-road  and  SSS/road  combinations)  and 
KombiConsult data (for rail/road).  

Definitions 

 

 

Intra-MS intermodal transport/CT: combined transport within one EU Member State, not 
connected to additional international transport (continental CT within one MS) 

Intra-MS  internationally  connected  intermodal  transport/CT:  combined  transport  within 
one  EU  Member  State.  This  combined  transport  operation  is  further  connecting  to  an 

150   TRT (2017)  – Gathering additional data on EU combined transport – Final report 

83 

 
                                                 
 

 

 

international  transport  operation  with  3rd  country  (container  hinterland  transport  or 
continental rail transport with connection to 3rd countries) 

Intra-EU  intermodal  transport/CT:  combined  transport  operation  between  at  least  2  EU 
Member States, not connected to additional international transport (continental CT within 
EU) 

Intra-EU internationally connected intermodal transport/CT: combined transport operation 
between  at  least  2  EU  Member  States  connection  with  3rd  country.  This  combined 
transport  operation  is  further  connecting  to  an  international  transport  operation  with  3rd 
country (container hinterland transport or continental rail transport with connection to 3rd 
countries) 

International  intermodal  transport/CT:  combined  transport  operation  from  which  in  EU 
only  one  mode  of  transport  is  used  (no  CT  operation  within  EU).  The  transhipment  to 
other mode takes place at border or in the 3rd country. The leg in EU can involve one or 
several Member States. 

  Maritime/container  hinterland  intermodal  transport/CT:  a  combined  transport  operation, 
mostly of containers, that feeds to or delivers from maritime transport (short sea or ocean 
going) 

  Continental  intermodal  transport/CT:  a  combined  transport  operation  that  does  not 

connect to maritime transport (rail-road or inland waterway-road). 

3. Baseline scenarios 

The  Baseline  scenario  used  in  this  impact  assessment  builds  on  the  EU  Reference  scenario 
2016  but  additionally  includes  few  policy  measures  adopted  after  its  cut-off  date  (end  of 
2014).  Building  an  EU  Reference  scenario  is  a  regular  exercise  by  the  Commission.  It  is 
coordinated  by  DGs  ENER,  CLIMA  and  MOVE  in  association  with  the  JRC,  and  the 
involvement of other services via a specific inter-service group.  

For  the  EU  Reference  scenario  2016,  Member  States  were  consulted  throughout  the 
development  process  through  a  specific  Reference  scenario  expert  group  which  met  three 
times  during  its  development.  Member  States  provided  information  about  adopted  national 
policies  via  a  specific  questionnaire,  key  assumptions  have  been  discussed  and  in  each 
modelling step, draft Member State specific results were sent for consultation. Comments of 
Member  States  were  addressed  to  the  extent  possible,  keeping  in  mind  the  need  for  overall 
comparability  and  consistency  of  the  results.  Quality  of  modelling  results  was  assured  by 
using  state  of  the  art  modelling  tools,  detailed  checks  of  assumptions  and  results  by  the 
coordinating Commission  services as well as  by the country specific  comments by Member 
States. 

The EU Reference scenario 2016 projects EU and Member States energy, transport and GHG 
emission-related  developments  up  to  2050,  given  current  global  and  EU  market  trends  and 
adopted  EU  and  Member  States'  energy,  transport,  climate  and  related  relevant  policies. 
"Adopted policies" refer to those that have been cast in legislation in the EU or in MS (with a 

84 

 
 
cut-off date end of 2014151). Therefore, the binding 2020 targets are assumed to be reached in 
the projection. This concerns greenhouse gas emission reduction targets as well as renewables 
targets, including renewables energy in transport. The EU Reference scenario 2016 provides 
projections,  not  forecasts.  Unlike  forecasts,  projections  do  not  make  predictions  about  what 
the future will be. They rather indicate what would happen if the assumptions which underpin 
the  projection  actually  occur.  Still,  the  scenario  allows  for  a  consistent  approach  in  the 
assessment of energy and climate trends across the EU and its Member States.   

The  report  "EU  Reference  Scenario  2016:  Energy,  transport  and  GHG  emissions-Trends  to 
2050"152  describe  the  inputs  and  results  in  detail.  In  addition,  its  main  messages  are 
summarised in the impact assessments accompanying the Effort Sharing Regulation153 and the 
revision  of  the  Energy  Efficiency  Directive154,  and  the  analytical  work  accompanying  the 
European strategy on low-emission mobility155.  

PRIMES-TREMOVE  is  one  of  the  core  models  of  the  modelling  framework  used  for 
developing  the  EU  Reference  scenario  2016  and  has  also  been  used  for  developing  the 
Baseline  scenario  of  this  impact  assessment.  The  model  was  calibrated  on  transport  and 
energy data up to year 2013 from Eurostat and other sources 

Main assumptions of the Baseline scenario 

The  projections  are  based  on  a  set  of  assumptions,  including  on  population  growth, 
macroeconomic and oil price developments, technology improvements, and policies.  

Macroeconomic assumptions 

The  Baseline  scenario  uses  the  same  macroeconomic  assumptions  as  the  EU  Reference 
scenario  2016.  The  population  projections  draw  on  the  European  Population  Projections 
(EUROPOP  2013)  by  Eurostat.  The  key  drivers  for  demographic  change  are:  higher  life 
expectancy,  convergence  in  the  fertility  rates  across  Member  States  in  the  long  term,  and 
inward migration. The EU28 population is expected to grow by 0.2% per year during 2010-
2030  (0.1%  for  2010-2050),  to  516  million  in  2030  (522  million  by  2050).  Elderly  people, 
aged 65 or more, would account for 24% of the total population by 2030 (28% by 2050) as 
opposed to 18% today.  

GDP projections  mirror the joint  work of DG  ECFIN and  the Economic Policy Committee, 
presented  in  the  2015  Ageing  Report156.  The  average  EU  GDP  growth  rate  is  projected  to 
remain relatively low at 1.2% per year for 2010-2020, down from 1.9% per year during 1995-
2010. In the medium to long term, higher expected growth rates (1.4% per year for 2020-2030 
and 1.5% per year for 2030-2050) are taking account of the catching up potential of countries 
with  relatively  low  GDP  per  capita,  assuming  convergence  to  a  total  factor  productivity 
growth rate of 1% in the long run.  

151   In addition, amendments to two Directives only adopted in the beginning of 2015 were also considered. This concerns 
notably  the  ILUC  amendment  to  the  Renewables  Directive  and  the  Market  Stability  Reserve  Decision  amending  the 
ETS Directive 

152   ICCS-E3MLab et al. (2016), EU Reference Scenario 2016: Energy, transport and GHG emissions - Trends to 2050 

153   SWD(2016) 247 

154   SWD(2016) 405 

155   SWD(2016) 244 

156  European  Commission/DG  ECFIN  (2014),  The  2015  Ageing  Report:  Underlying  Assumptions  and  Projection 

Methodologies, European Economy 8/2014. 

85 

 
                                                 
Fossil fuel price assumptions 

Oil prices used in the Baseline scenario are the same with those of the EU Reference scenario 
2016.  Following  a  gradual  adjustment  process  with  reduced  investments  in  upstream 
productive capacities by non-OPEC157 countries, the quota discipline is assumed to gradually 
improve  among  OPEC  members  and  thus  the  oil  price  is  projected  to  reach  87  $/barrel  in 
2020  (in  year  2013-prices).  Beyond  2020,  as  a  result  of  persistent  demand  growth  in  non-
OECD countries driven by economic growth and the increasing number of passenger cars, oil 
price would rise to 113 $/barrel by 2030 and 130 $/barrel by 2050.  

No specific sensitivities were prepared with respect to oil price developments. Still, it can be 
recalled  that  lower  oil  price  assumptions  tend  to  increase  energy  consumption  and  CO2 
emissions not covered by the ETS. The magnitude of the change would depend on the price 
elasticities and on the share of taxation, like excise duties, in consumer prices. For transport, 
the high share of excise duties in the consumer prices act as a limiting factor for the increase 
in energy consumption and CO2 emissions.  

Techno-economic assumptions 

For  all  transport  means,  except  for  light  duty  vehicles  (i.e.  passenger  cars  and  light 
commercial  vehicles),  the  Baseline  scenario  uses  the  same  technology  costs  assumptions  as 
the EU Reference scenario 2016.  

For light duty vehicles, the data for technology costs and emissions savings has been updated 
based on a recent study commissioned by DG CLIMA158. Battery costs for electric vehicles 
are  assumed  to  go  down  to  205  euro/kWh  by  2030  and  160  euro/kWh  by  2050;  further 
reductions  in  the  cost  of  both  spark  ignition  gasoline  and  compression  ignition  diesel  are 
assumed to take place. Technology cost assumptions are based on extensive literature review, 
modelling and simulation, consultation with relevant stakeholders, and further assessment by 
the Joint Research Centre (JRC) of the European Commission. 

Specific policy assumptions 

The  key  policies  included  in  the  Baseline  scenario,  similarly  to  the  EU  Reference  scenario 
2016, are159:   

  CO2 standards for cars and vans regulations (Regulation (EC) No 443/2009, amended by 
Regulation (EU) No 333/2014 and Regulation (EU) No 510/2011, amended by Regulation 
(EU) No 253/2014); CO2 standards for cars are assumed to be 95gCO2/km as of 2021 and 
for  vans  147gCO2/km  as  of  2020,  based  on  the  NEDC  test  cycle,  in  line  with  current 
legislation.  No  policy  action  to  strengthen  the  stringency  of  the  target  is  assumed  after 
2020/2021. 

  The  Renewable  Energy  Directive  (Directive  2009/28/EC)  and  Fuel  Quality  Directive 
(Directive  2009/30/EC) 
(Directive  2015/1513/EU): 
achievement of the legally binding RES target for 2020 (10% RES in transport target) for 
each Member State, taking into account the use of flexibility mechanisms when relevant as 
well  as  of  the  cap  on  the  amount  of  food  or  feed  based  biofuels  (7%).  Member  States' 

ILUC  amendment 

including 

157  OPEC stands for Organization of Petroleum Exporting Countries. 
158  Source: https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/technology_results_web.xlsx  
159  For a comprehensive discussion see the Reference scenario report: “EU Reference Scenario 2016: Energy, transport and 

GHG emissions - Trends to 2050”  

86 

 
                                                 
specific  renewable  energy  policies  for  the  heating  and  cooling  sector  are  also  reflected 
where relevant. 

  Directive on the deployment of alternative fuels infrastructure (Directive 2014/94/EU). 

  Directive  on  the  charging  of  heavy  goods  vehicles  for  the  use  of  certain  infrastructures 

(Directive 2011/76/EU amending Directive 1999/62/EC).  

  Relevant national policies, for instance on the promotion of renewable energy, on fuel and 

vehicle taxation, are taken into account.  

In addition, a few policy measures adopted after the cut-off date of the EU Reference scenario 
2016 at both EU and Member State level, have been included in the Baseline scenario: 

  Directive on weights & dimensions (Directive 2015/719/EU); 

  Directive as regards the opening of the market for domestic passenger transport services by 

rail and the governance of the railway infrastructure (Directive 2016/2370/EU); 

  Directive  on 

for 
2016/1629/EU), part of the Naiades II package; 

requirements 

technical 

inland  waterway  vessels 

(Directive 

  Regulation  establishing  a  framework  on  market  access  to  port  services  and  financial 

transparency of ports160; 

  The  replacement  of  the  New  European  Driving  Cycle  (NEDC)  test  cycle  by  the  new 
Worldwide  harmonized  Light-vehicles  Test  Procedure  (WLTP)  has  been  implemented  in 
the  Baseline  scenario,  drawing  on  work  by  JRC.  Estimates  by  JRC  show  a  WLTP  to 
NEDC  CO2  emissions  ratio  of  approximately  1.21  when  comparing  the  sales-weighted 
fleet-wide average CO2 emissions. WLTP to NEDC conversion factors are considered by 
individual vehicle segments, representing different vehicle and technology categories161.  

  For  Germany,  an  extension  of  the  toll  network  by  roughly  40,000  kilometres  of  federal 

trunk road from 2018 onwards for all heavy goods vehicles over 7.5t.162  

  For  Austria,  the  incorporation  of  exhaust  emissions  and  noise  pollution  in  the  distance 
based charges. All federal highways and motorways, totalling around 2,200 km, are subject 
to distance based charges.  

  For  Belgium,  a  distance  based  system  replaced  the  former  Eurovignette  for  heavy  goods 
vehicles over 3.5t from April 2016. The system applies to all inter-urban motorways, main 
(national) roads163 and all urban roads in Brussels.  

  For Latvia, the introduction of a vignette system applied for goods vehicles below 3.5t on 
the motorways, starting with 1 January 2017. In addition, for all heavy goods vehicles over 

160  Awaiting signature of act (Source : 

http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2013/0157(COD)&l=en)  

161  Simulation at individual vehicle level is combined with fleet composition data, retrieved from the official European CO2 
emissions  monitoring  database,  and  publicly  available  data  regarding  individual  vehicle  characteristics,  in  order  to 
calculate  vehicle  CO2  emissions  and  fuel  consumption  over  different  conditions.  Vehicle  CO2  emissions  are  initially 
simulated over the present test protocol (NEDC) for the 2015 passenger car fleet; the accuracy of the method is validated 
against officially monitored CO2 values and experimental data. 

162  Currently, 15,000 kilometres of federal trunk road and motorways are subject to tolls. 
163  E.g. http://www.viapass.be/fileadmin/viapass/documents/download/VlaanderenE.JPG  

87 

 
                                                 
3.5t  the  vignette  rates  applied  on  motorways  for  the  EURO  0,  EURO  I,  EURO  II  are 
increased by 10% starting with 1 January 2017. 

Summary of main results of the Baseline scenario 

EU  transport  activity  is  expected  to  continue  growing  under  current  trends  and  adopted 
policies  beyond  2015,  albeit  at  a  slower  pace  than  in  the  past.  Freight  transport  activity  for 
inland  modes  is  projected  to  increase  by  36%  between  2010  and  2030  (1.5%  per  year)  and 
60% for 2010-2050 (1.2% per year). The annual growth rates by mode, for freight transport, 
are provided in Figure 17164. 

Road transport would maintain its dominant role within the EU. The share of road transport in 
inland freight is expected to slightly decrease at 70% by 2030 and 69% by 2050. The activity 
of heavy goods vehicles expressed in tonnes kilometres is projected to grow by 35% between 
2010  and  2030  (56%  for  2010-2050)  in  the  Baseline  scenario,  while  light  goods  vehicles 
activity would go up by 27% during 2010-2030 (50% for 2010-2050).  

Figure 17: Freight transport projections (average growth rate per year) 

Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab) 

Rail freight transport activity is projected to grow significantly faster than for road, driven in 
particular  by  the  effective  implementation  of  the  TEN-T  guidelines,  supported  by  the  CEF 
funding,  leading  to  the  completion  of  the  TEN-T  core  network  by  2030  and  of  the 
comprehensive network by 2050. Rail freight activity grows by 51% by 2030 and 90% during 
2010-2050, resulting in 2 percentage points increase in modal share by 2030 and an additional 
percentage point by 2050. 

Transport  activity  of  freight  inland  navigation165  also  benefits  from  the  completion  of  the 
TEN-T core and comprehensive network, the promotion of inland waterway transport and the 
recovery in the economic activity and would grow by 26% by 2030 (1.2% per year) and by 
46% during 2010-2050 (0.9% per year).  

International maritime transport activity is projected to continue growing strongly with rising 
demand  for  oil,  coal,  steel  and  other  primary  resources  –  which  would  be  more  distantly 
sourced – increasing by 37% by 2030 and by 71% during 2010-2050.  

164  Projections for international maritime are presented separately and not included in the total freight transport activity to 

preserve comparability with statistics for the historical period. 
165  Inland navigation covers inland waterways and national maritime.  

88 

-1.0%-0.5%0.0%0.5%1.0%1.5%2.0%2.5%3.0%RoadRailInland navigationFreight transport'95-'10'10-'30'30-'50 
 
 
 
                                                 
Transport accounts today for about one third of final energy consumption. In the context of 
growing  activity,  energy  use  in  transport  is  projected  to  decrease  by  5%  between  2010  and 
2030 and to stabilise post-2030. These developments are mainly driven by the implementation 
of the Regulations setting emission performance standards for new light duty vehicles. At the 
same time, heavy goods vehicles are projected to increase their share in final energy demand 
from 2010 onwards, continuing the historic trend from 1995. Energy demand by heavy goods 
vehicles would grow by 14% between 2010 and 2030 (23% for 2010-2050).   

Bunker fuels for maritime transport are projected to increase significantly: by 24% by 2030 
(42% for 2010-2050). 

LNG becomes a candidate energy carrier for road freight and waterborne transport, especially 
in the medium to long term, driven by the implementation of the Directive on the deployment 
of alternative fuels infrastructure and the revised TEN-T guidelines which represent important 
drivers  for  the  higher  penetration  of  alternative  fuels  in  the  transport  mix.  In  the  Baseline 
scenario, the share of LNG is projected to go up to 3% by 2030 (8% by 2050) for road freight 
and  4%  by  2030  (7%  by  2050)  for  inland  navigation.  LNG  would  provide  about  4%  of 
maritime  bunker  fuels  by  2030  and  10%  by  2050  –  especially  in  the  segment  of  short  sea 
shipping.  

Biofuels uptake is driven by the legally binding target of 10% renewable energy in transport 
(Renewables Directive), as amended by the ILUC Directive, and by the requirement for fuel 
suppliers to reduce the GHG intensity of road transport fuel by 6% (Fuel Quality Directive). 
Beyond  2020,  biofuel  levels  would  remain  relatively  stable  at  around  6%  in  the  Baseline 
scenario.  The  Baseline  scenario  does  not  take  into  account  the  recent  proposal  by  the 
Commission for a recast of the Renewables Energy Directive.  

In the Baseline scenario, oil products would still represent about 90% of the EU transport 
sector needs in 2030 and 85% in 2050, despite the renewables policies and the deployment of 
alternative  fuels  infrastructure  which  support  some  substitution  effects  towards  biofuels, 
electricity, hydrogen and natural gas. 

The declining trend in transport emissions is expected to continue, leading to 13% lower 
emissions by 2030 compared to 2005, and 15% by 2050.166 However, relative to 1990 levels, 
emissions would still be 13% higher by 2030 and 10% by 2050, owing to the fast rise in the 
transport  emissions  during  the  1990s.  The  share  of  transport  in  total  GHG  emissions  would 
continue increasing, going up from 23% currently (excluding international maritime) to 25% 
in  2030  and  31%  in  2050,  following  a  relatively  lower  decline  of  emissions  from  transport 
compared  to  power  generation  and  other  sectors.  Maritime  bunker  fuel  emissions  are  also 
projected to grow strongly, increasing by 22% during 2010-2030 (38% for 2010-2050). 

CO2  emissions  from  road  freight  transport  (heavy  goods  and  light  goods  vehicles)  are 
projected  to  increase  by  6%  between  2010  and  2030  (11%  for  2010-2050)  in  the  Baseline 
scenario. For heavy goods vehicles, the increase would be somewhat higher (10% for 2010-
2030  and  17%  for  2010-2050),  in  lack  of  specific  measures  in  place.  At  the  same  time, 
emissions from passenger cars and passenger vans are projected to decrease by 22% between 
2010 and 2030 (32% for 2010-2050) thanks to the CO2 standards in place and the uptake of 
electromobility.  

166  Including international aviation but excluding international maritime and other transportation.  

89 

 
                                                 
NOx  emissions  would  drop  by  about  56%  by  2030  (64%  by  2050)  with  respect  to  2010 
levels. The decline in particulate matter (PM2.5) would be less pronounced by 2030 at 51% 
(65% by 2050). Overall, external costs related to air pollutants would decrease by about 56% 
by 2030 (65% by 2050).167  

High  congestion  levels  are  expected  to  seriously  affect  road  transport  in  several  Member 
States  by  2030  in  the  absence  of  effective  countervailing  measures  such  as  road  pricing. 
While  urban  congestion  will  mainly  depend  on  car  ownership  levels,  urban  sprawl  and  the 
availability of public  transport  alternatives, congestion on the inter-urban network would be 
the  result  of  growing  freight  transport  activity  along  specific  corridors,  in  particular  where 
these corridors cross urban areas with heavy local traffic. Estimating the costs of congestion is 
not straightforward, because it occurs mostly during certain times of the day, often caused by 
specific bottlenecks in the network. In the Baseline scenario, total congestion costs for urban 
and  inter-urban  network  are  projected  to  increase  by  about  24%  by  2030  and  43%  by 
2050, relative to 2010. 

Noise  related  external  costs  of  transport  would  continue to  increase, by  about  17%  during 
2010-2030  (24%  for  2010-2050),  driven  by  the  rise  in  traffic.  Thanks  to  policies  in  place, 
external costs of accidents are projected to go down by about 46% by 2030 (-42% for 2010-
2050)  –  but  still  remain  high  at  over  €100  billion  in  2050.  Overall,  external  costs168  are 
projected to decrease by about 10% by 2030 and to increase post-2030; by 2050 they stabilise 
around levels observed in 2010 

Further details on the Baseline scenario are available in the Impact Assessment accompanying 
Directive.169.
the 

Eurovignette 

review 

the 

of 

167  External costs are expressed in 2013 prices. They cover NOx, PM2.5 and SOx emissions. 
168  External costs cover here air pollution, congestion, noise and accidents. 

90 

 
                                                 
 
ANNEX 5: PRICE COMPONENTS OF RAIL AND INLAND WATERWAYS TRANSPORT PER DISTANCE GROUPS IN WESTERN AND CENTRAL EUROPE

170 

Market price components, % 

non-
road 
legs 
23-32 
45-62 
34-42 
41-70 
56-71 

Tranship-
ment 
21-26 
8-18 
24-27 
5-11 
5,3-8,2 

Load 
Unit 
costs 
0 
0-3 
0 
0-4 
0-4,51 

Difference 
with road, 
charges 
% 
7,6-9,8  10-33 

6,7-8,7 

9-16 
-13->+13 
-16->+6 
-20->+2 

Average door-to-
door price, € 

CT, 
per 
km 

road only 
transport, 
per km 

1,71 
1,5 
1,22 
1,09 
1,01 

1,52 
1,30 
1,30 
1,14 
1,06 

Additional 
disadvantage 
without WDD 
and 
cabotage, % 
32 
35 
10 
12 
11 

Additional shippers' disadvantage (not 
fully reflected in price), % 

Longer 
delivery 
times, % 

Organising/
managing 
CT chain, % 

Problems of 
non-
harmonisation 

10-30% 

5-20% 

2-10% 

road 
legs 

type  distance 
IWW 
RR 
IWW  300+ 
RR 
RR 

-300  28-43 
300-639  26-33 
25-33 
640-798  21-30 
800+ 
18-33 

170   Based on figures from TRT (2017)  – Gathering additional data on EU combined transport 

91 

 
 
  
  
  
                                                 
ANNEX 6: MAP OF RAIL-ROAD COMBINED TRANSPORT TERMINALS ON TEN-T NETWORK 

92 

 
 
93 

 
 
 
 
ANNEX 7: EXTENDED PROBLEM TREE 

94 

 
 
 
 
ANNEX 8: DISCARDED POLICY MEASURES AND RELEVANT JUSTIFICATIONS  

This list of policy measures was subsequently screened on the basis of the following criteria: 

  Legal feasibility: Options must respect the principle of conferral. They should also respect any obligation arising from the EU Treaties and 
ensure respect of fundamental rights. Legal obligations incorporated in existing primary or secondary EU legislation may also rule out certain 
options. 

  Technical  feasibility:  Technological  and  technical  constraints  may  not  allow  for  the  implementation,  monitoring  and/or  enforcement  of 

theoretical options. 

  Effectiveness  and  efficiency:  It  may  already  be  possible  to  show  that  some  options  would  uncontrovertibly  achieve  a  worse  cost-benefit 

balance than some alternatives. 

  Political feasibility: Options that would clearly fail to garner the necessary political support for legislative adoption and/or implementation 

can also be discarded. 

  Proportionality: Options may clearly restrict the scope for national decision making over and above what is needed to achieve the objectives 

satisfactorily. 

Specific objective 1: simplify eligibility criteria and the controls thereof 
Problem driver: complex eligibility criteria 

Geographic scope 

Discarded policy measure 
Extend scope to all CT with 3rd countries (including when 
only one mode in EU) 

Definition/eligibility 
criteria 

Road legs 

Nearest suitable for all modal connections, suitable to be 
defined by the operators 

95 

Reason for discarding 

Does not support modal shift in EU 

While being a perfect measure from industry's point of 
view, it is impossible to enforce satisfactorily and has 
already created considerable problems for rail 
transport as described in the problem definition. It 
would also increase the total road legs of CT as would 
increase the eligible length for short sea shipping, 
where road legs are longest anyway 

 
 
 
  
  
  
  
For all modal connections limit road leg to nearest 
suitable terminal, where suitable is defined through 
available connections, equipment, quality of service and 
price.  

No limitation 

load units 

Only standardized load units 

Problem driver: ineffective conditions for implementation 

Any load unit included without defining load unit 

Only paper documents without stamp requirement 

Proof of eligibility 

Data presentation 

Paper + MS to accept electronic data, national 
requirements 

New type of mandatory transport document for CT (paper 
and electronic) 

Paper + central database at national level 

Control of eligibility 

Paper + central database at EU level 
Ex-post registration of CT operations 

Ex-ante control in premises only 

Specific objective 2: improve effectiveness of support measures 
Problem driver: ineffective levels of economic support 

96 

The four conditions were identified by industry as 
main factors for choosing a terminal. Controlling these 
conditions is difficult if not impossible at road side 
checks making eligibility controls more difficult than 
now (as it would apply to all modes) 

No limitation on road leg would increase the total 
length of road legs in EU, even more than for "nearest 
suitable" for each mode. The option is also strongly 
opposed by most Member States  
Allowing only standardised load units would reduce 
the possibility for innovation. 
Not defining eligible load units would allow the 
interpretation that pallets, big-bags etc. are also 
intermodal load units as they can be transhipped.  

Allowing digital documents is a major request by the 
industry.  
Transport document is understood by industry as a 
civil contract with a particular liability regime. The 
scope of this Directive does not cover issues relating 
to contractual law and civil liability.  
Allowing all MS to establish national requirements 
would create additional barriers for the functioning of 
internal market 

A centralised database raises questions of data 
ownership as well as who will run the database. There 
is no need for a centralised database with today’s 
technology, neither at national nor at EU level.  
Overly burdensome requirement.  
Alone does not allow effective eligibility control for 
regulatory benefits. 

 
  
  
  
  
Investment support 

Investment support for load units 

Investment support for IT solutions 

Economic support 
measures 

Start-up support 

Start-up of new non-road services 

Operational support 

Harmonised lump-sum grant per load unit shipped on CT 

Reimbursement of transhipment costs, harmonised 
percentage level. Paid by MS where the transhipment 
takes place 

Data gathering obligation on COM 

Reporting  

Reporting by Member States 

Monitoring and 
cooperation 

Development plans by Member States 

Targets 

Review 

Targets for modal shift for each Member State 

Review of the Directive every 5 years 

97 

Can distort competition as several operators have 
invested heavily in load units, in particular those who 
specialise in renting the load units. Load units are also 
easily displaceable allowing use outside EU and thus 
not supporting the modal shift in EU. 
Can distort competition as difficult to ensure that 
investment is limited to CT aspects.  
Start-up phase of non-road services is very expensive 
and with high risk. The assessment by the Court of 
Auditors on the Marco Polo program considered this 
support not efficient. It would also not be possible to 
separate the CT operation from other non-road 
operations on the service. 
A harmonised lump-sum level does not reflect the 
market realities that transhipment costs vary widely 
between the different regions of EU. It would also not 
take into account possible price fluctuations. 
Transhipment numbers in different MS vary more 
considerably and have clustered more into some MS 
due to location and availability of terminals. It would 
not be desirable to those Member States. 
MS carry out statistics gathering. Putting the 
obligation on Commission would require regular 
outside studies to be carried out.  

Some MS already carry out reporting on national level; 
however this does not allow the assessment of EU 
wide policy impacts. 
While development plans would focus MS policy 
planning, this is considered an issue of subsidiarity.  
Taking into account the difficulties with statistics, it 
would be difficult to check the achievement of the 
targets. 
Unpractical, modal shift policies will take longer time 
to show impact 

 
Cooperation 

Sunset clause 
Creating a comitology committee 
Establishing a cooperation network 

Repeal of the directive should base on analysis and the 
needs and is possible without a sunset clause.  
Not necessary. 
Not necessary at this stage.  

98