Proposal for revision for the DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the establishment of common rules for certain types of combined transport of goods between Member States (92/106/EEC)
Date: 2022-11-04
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: common transport policy



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Summary Report on the Public Consultation for the Impact Assessment of the revision of the Combined Transport Directive (Council Directive 92/106/EEC)   



Disclaimer: This report is a summary of the responses to the Public Consultation received relating to the revision of the Combined Transport Directive. It should not under any circumstances be regarded as the view of the Commission or its services, or be taken to be representative of the views of the public or stakeholders more generally.   


This document summarises the responses to the online public consultation on the revision of the Combined Transport Directive
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, which was live between 7 March and 30 May 2022 on the EU’s Survey website
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. Overall, 100 responses were received. The results are presented under four categories: industry (covering responses from ‘business associations’ and ‘companies/business organisations’), public authorities, EU citizens and other respondents. The latter includes ‘NGOs’, ‘trade unions’ and those organisations that categorised themselves as ‘Other’.  


Overall, 68% of the responses came from industry representatives (see 

Figure 


1

a), with a quarter of these coming from transport operators or their associations (27%, 18 out of 68; see 

Figure 


1

b). In addition, one quarter of industry respondents indicated that they undertook activities in more than one of the sectors listed in the survey (24%, 16) and a similar proportion indicated that they were involved in another type of activity that is not explicitly mentioned in 

Figure 


1

b (26%, 18). The remaining industry respondents (including from relevant associations) were from transport organisers (12%, 8), terminal operators (7%, 5) and shippers (4%, 3).


A further 14% of responses came from local authorities, of which five (out of 14) were from national authorities or agencies, seven from regional authorities and the other two were from an agency responsible for regional waterways and a regional port authority. In addition, 10% of the responses came from EU citizens and the remaining 8% came from NGOs (3), trade unions (1) and organisations that categorised themselves as ‘Other’ (4). 


Figure 1: Breakdown of respondents to the public consultation: a) Overall; and b) Industry responses broken down by sector 









Respondents were from 20 different Member States, with those from Belgium (21), Germany (20) and France (13) together providing more than half of the total number of responses (see 

Figure 


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). The responses from Belgium included many EU level trade associations, as well as those representing national and regional interests. No responses were received from seven Member States: Bulgaria, Croatia, Cyprus, Latvia, Portugal, Romania and Slovenia. Two responses came from stakeholders based in Norway and Switzerland. All responses received were considered to be unique and so included in the analysis; there were no campaigns. 


Figure 2: Breakdown of respondents by country of origin 







Respondents were asked a series of general questions. The majority of respondents considered that it was important
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 to increase the use of rail and waterborne freight transport in order to move towards  more sustainable modal composition of the transport system that would contribute to achieving EU environmental and climate objectives (87% of respondents; 87 responses out of 100). Respondents were then asked to indicate why there had been a limited uptake of intermodal/multimodal transport. The majority felt that the inherent disadvantages of intermodal/multimodal transport (86%; 85 out of 99) was the most relevant reason, while over two thirds thought that the incomplete internalisation of external costs and an internalisation gap between the modes (72%; 71 out of 99) was also relevant (see 

Figure 


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). Respondents were also asked for other reasons and common responses included: a lack of reliability and punctuality of the rail system; that passenger transport was prioritised over freight transport on the rail network; a lack of terminal capacity at necessary locations; and the high level of direct and indirect subsidies given to road transport.


Figure 3: Responses to “How relevant are the following reasons in relation to a limited uptake of intermodal/multimodal transport (on a scale of 0-5, where 0 is not relevant and 5 is most relevant)?”







Three quarters of respondents believed that both EU and Member State policies should support the increased use of rail and waterborne transport (76%; 74 out of 98), in order to ensure a level playing field between the modes and to ensure that support was not just given to operators from a particular country. Industry respondents were least likely to be in favour of unconditional support for rail and waterborne transport from the EU and Member States, although even a majority of these still supported this option (69%; 47 out of 68). Most of the 31% (21) of industry respondents that did not unconditionally support EU and Member State support for rail and waterborne transport believed that support should only be provided in limited circumstances (14, coming from different industry sectors). Nearly three-quarters of respondents believed that the Directive should include planning and reporting obligations at both the EU and Member State level (72%; 65 out of 90). 


When making general remarks on the Directive, three industry respondents noted that the inconsistency between the approaches taken towards intermodal transport in different Member States hampered the potential of intermodal transport, while three respondents from Ireland and France called for the special circumstances of the EU’s island nations to be taken into account in the context of the Directive. In addition, six industry responses, half of which were from transport operators, called for all transport modes to be seen as complementary rather than as competing, and so called for the focus to be on greening all modes, rather than on forcing modal shift away from road transport. 


There followed a set of questions on the problem analysis. Two thirds of respondents believed that intermodal/multimodal transport was competitive with road-only transport in the EU without support only in some situations (66%; 63 out of 95). However, there was no consensus concerning the average distance of the non-road leg of an intermodal or multimodal transport trip that was needed for an intermodal or a multimodal journey to be competitive with road-only transport. The most common distance proposed for the rail leg of either an intermodal or multimodal journey was 500 km (19). For an inland waterway leg, the most common distance was between 300 km and 500 km (42,) and for short sea shipping it was 500 km. Finally, for a journey involving at least two modes other than road, the most popular distance was 1000 km (14), with values proposed ranging 10 km to 2000 km.


The majority of stakeholders (80%; 80 out of 100) implied that there were differences in the competitiveness of intermodal/multimodal transport in different Member States. The most common reasons for this were due to differences in the availability and quality of the infrastructure that could be used (e.g. terminals, railways and canals), differences in the intermodal/multimodal transport services offered in different countries and differences in the support provided (e.g. state aid, infrastructure financing). Difference in the costs and cost structures between the modes was also noted as a relevant issue. 


When presented with a list of factors that affected the lack of competitiveness of intermodal/multimodal transport compared with road-only transport, the majority highlighted six factors: transhipment costs (93%; 87 out of 94); lack of suitable terminals in the vicinity (89%; 85 out of 95); road transport being cheaper than intermodal/multimodal transport for door-to-door operations (83%; 78 out of 94); habit of using road-only transport (83%; 78 out of 94); lack of suitable service offer in terminals in the vicinity (80%; 76 out of 95) and delay/longer transit time compared with road-only transport (79%; 73 out of 92) (see 

Figure 


4

). 


Figure 4: Responses to “To what extent do the following factors affect the lack of competitiveness of intermodal/multimodal transport compared with road-only transport (on a scale of 0-5, where 0 is no impact and 5 is very strong impact)?”









There was broad support to apply policies or support measures to different actors, with transport organisers (89%; 85 out of 96) and shippers (87%; 83 out of 95) being the most popular beneficiaries to encourage them to choose intermodal/multimodal options. In addition, around three-quarters of respondents felt that providing support for road transport operators to better internalise external costs (75%; 71 out of 95), for rail and waterborne operators to improve the price-competitiveness of their services (71%; 67 out of 95) and to the final customer to inform them about, and to enable them to choose, more sustainable intermodal/multimodal options (73%; 69 out of 95) were also important.


Nearly two thirds of respondents (63%; 59 out of 93) believed that the eligibility for support should be based on new principles compared to those used in the current Directive. When asked to indicate their support for a list of mutually-exclusive pairs of principles, less than half of respondents chose to answer the respective questions. However, of those that did the majority of respondents believed that support should: apply to all operations in the EU, so both those within and between Member States (96%; 47 out of 49); have no distance limitations (96%; 44 out of 46); apply to all loading units (93%; 39 out of 42); apply to eligible operations based on avoided negative externalities as opposed to only avoided greenhouse gas emissions (91%; 39 out of 43); apply to all eligible multimodal operations (including intermodal operations) (89%; 41 out of 46); and apply to all loading units (notwithstanding whether identified with ISO or ILU code or not) (79%; 30 out of 38). There were also calls for all non-road modes to be treated the same within the Directive, rather than the current perceived preference for rail.  


Those stakeholders that were in favour of other externalities being taken into account in the context of eligibility rules were asked to indicate which should be considered. The number of respondents who answered the relevant questions was relatively low, around a third of respondents. Of those who responded, all agreed that greenhouse gas (GHG) emissions should be included (100%; 37 out of 37). For other externalities other than GHG, the majority supported the inclusion of congestion (92%; 34 out of 37); noise (81%; 30 out of 37), energy efficiency (81%; 22 out of 27); air pollution (78%; 29 out of 37); and accidents (78%; 29 out of 37). The most popular response in terms of the methodology that should be used for estimating externalities was the Handbook on the external costs of transport (79%; 26 out of 33). There was no clear consensus amongst stakeholders as to how best to calculate these external costs. 


There was also no clear view amongst stakeholders in terms of what was needed to track intermodal/multimodal consignments door-to-door. The importance of increasing digitalisation to reduce administrative burden was raised by many stakeholders, e.g. by using electronic freight transport information (eFTI) framework, while it was noted that any additional tools, such as an external cost calculator, should be made easy for SMEs to use.  


According to the majority of respondents, the most common aim of the support measures included in the Directive should be to provide support to cover the inherent disadvantages of intermodal/multimodal transport in order to make intermodal/multimodal operations price-competitive vis-a-vis road-only transport (77%; 58 out of 75; see 

Figure 


5

). 


Figure 5: Responses to “In your view, what should the support measures aim at (choose the order of importance, where 1 is most important aim)?”







The majority of respondents that had a view believed that each of the proposed support measures was important, i.e.: economic support for technological upgrades (91%; 89 out of 96); regulatory support (89%; 85 out of 96); economic support to operations (89%; 85 out of 96); and administrative support (simplification of procedures) (83%; 79 out of 95).


As regards whether measures should be harmonised across EU or not, more than half of respondents that expressed a view believed that administrative measures should be fully harmonised (55%; 52 out of 95), which was also the most common response in relation to the harmonisation of regulatory support (46%, 43 out of 94). On the other hand, the most common response in relation to economic support, both to operations and for technological upgrades, was that their harmonisation should depend on the actual measure (49%; 47 out of 96, and 41%; 40 out of 97, respectively). 


As regards whether certain support measures should be mandatory or optional for Member States to apply, more than half of respondents that expressed a view believed that the application of administrative measures should be mandatory (58%; 56 out of 96), which was also the most common response in relation to regulatory measures (43%, 40 out of 95). On the other hand, the most common response in relation to economic support, both to operations and for technological upgrades, was that their application should be mandatory with choice (53%; 51 out of 96, and 39%; 37 out of 96, respectively).


Of the current support measures in the Directive, at least two thirds of those with a view supported extending the following to all new eligible operation: tax exemptions to road hauliers for vehicles used exclusively in combined transport (Article 6.2; 78%, 57 out of 73); tax reductions or reimbursements to road hauliers of Rolling Highway combined transport operations (Article 6.1; 76%, 55 out of 72); ban on quotas for combined transport (Article 2; 68%, 49 out of 72); and the equivalence with international road transport as regards non-application of cabotage on international transport (Article 4; 66%, 39 out of 59). Interestingly, majority of public authority respondents supported removing the measures in both Articles 6.1 and 6.2 (83%; five out of six, in each case) and five out of eight replying transport operators supported maintaining the measure in Article 4 with scope as today. Other common support measures that were proposed for road transport vehicles used in combined transport included: allowing larger road transport vehicles on the road leg (e.g. an increase to a 44 tonne maximum authorised weight for all vehicles used in intermodal transport and/or the use of the EMC combination), exemptions from traffic bans and restrictions; and the reimbursement of road user charges. 


The majority of respondents believed that different types of beneficiaries could be justified for economic support measures, with transport operators as beneficiaries being supported the most (84%, 79 out of 94), followed by transport organisers (60%, 56 out of 94) and shippers (52%, 49 out of 94). The pattern was similar in the responses from different stakeholder groups. There was no consensus amongst respondents as to whether there should be a cap on economic support measures. As possible additional measures, measures to support final customers, shippers and logistic service providers to transform their economic model from road-only to intermodal transport chains were mentioned, as was the importance of making access to these measures easy, including for SMEs. Others called for support measures to be linked to their potential impacts in terms of reducing GHG emissions or other externalities.


Finally, while the majority of all respondents supported the consideration of regulatory provisions applicable to transport operators to improve efficiency of intermodal/multimodal transport (77%, 72 out of 93), interestingly 63% of transport organisers did not want such measures to be considered (five out of eight). Examples suggested included actions on the increased harmonisation of digital or technical standards, and potentially the mandatory application of these, while others called for the development of a simple, single data structure to be used by all stakeholders. It was also suggested that trucks and semi-trailers should be required to be designed so that they are cranable to make it easier for them to be moved onto rail. 






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 This document is a summary of the responses to the online public consultation that was live in the first half of 2020 and which was undertaken in the context of the revision of the Combined Transport Directive. It cannot be understood, in any circumstances, as the official view of the European Commission or its services. In addition, the views expressed in this document, and which are attributed to a particular group of individuals or organisations, cannot be considered to be representative of these groups more generally. 




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https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13010-Sustainable-transport-revision-of-Combined-Transport-Directive_en
 




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 I.e. they rated this either ‘5’, ‘4’ or ‘3’ on a scale of ‘0’ to ‘5’, where ‘5’ indicated ‘most important’