COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Council Directive 96/53/EC laying down for certain road vehicles circulating within the Community the maximum authorised dimensions in national and international traffic and the maximum authorised weights in international traffic
Date: 2023-07-11
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: common transport policy, international transport, large vehicle, national transport, road safety, road transport, sustainable mobility, technical standard, weight and size, weights and measures

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 11.7.2023  SWD(2023) 447 final  COMMISSION STAFF WORKING DOCUMENT EVALUATION Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Council Directive 96/53/EC laying down for certain road vehicles circulating within the Community the maximum authorised dimensions in national and international traffic and the maximum authorised weights in international traffic {COM(2023) 445 final} - {SEC(2023) 445 final} - {SWD(2023) 445 final} - {SWD(2023) 446 final}  
 
 
Table of contents 

1 

INTRODUCTION ................................................................................................................................ 3 

1.1. Purpose and scope of the evaluation ................................................................................... 3 

1.2. Evaluation methodology ...................................................................................................... 4 

2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ....................................... 5 

2.1. Description of the intervention and its objectives ............................................................... 5 

2.2. Relation of the intervention to the United Nations Sustainable Development Goals ......... 7 

2.3. Points of comparison ............................................................................................................ 8 

3 

HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ......................... 9 

3.1. Internal market ..................................................................................................................... 9 

3.2. GHG emission and energy performance ............................................................................ 17 

3.3. Intermodal transport .......................................................................................................... 19 

3.4. Road safety and protection of the infrastructure .............................................................. 20 

3.5. Enforcement of the rules on maximum weights and dimensions ..................................... 22 

4 

EVALUATION FINDINGS ............................................................................................................... 24 

4.1. 

To what extent was the intervention successful and why? .......................................... 24 

4.1.1. 

Effectiveness .............................................................................................................. 24 

4.1.2. 

Efficiency ................................................................................................................... 32 

4.1.3. 

Coherence ................................................................................................................. 37 

4.2. 

How did the EU intervention make a difference? ......................................................... 39 

4.3. 

Is the intervention still relevant? .................................................................................. 41 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ................................................. 42 

5.1. 

Conclusions .................................................................................................................... 42 

5.2. 

Lessons learned ............................................................................................................. 45 

ANNEX I:  PROCEDURAL INFORMATION............................................................................................ 47 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ................................................... 49 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 

TO THE EVALUATION QUESTIONS (BY CRITERION) ............................................................. 53 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ........................................................................... 71 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................................. 77 

ANNEX VI. LETTER FROM FORMER VICE-PRESIDENT SIM KALLAS, 13 JUNE 2012 ................. 92 

 
 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

BEV 

BPG 

EMS 

GDP 

GHG 

HCV 

HDV 

HFCV 

HGV 

ICE 

IWW 

MSP 

OBW 

SDG 

TCO 

TEU 

W&D 

WIM 

ZEV 

Battery-electric Vehicle 

Best Practice Guidelines (for Abnormal Road 
Transports) 

European Modular System 

Gross Domestic Product 

Green House Gas 

High Capacity Vehicle 

Heavy-Duty Vehicle 

Hydrogen Fuel-Cell Vehicle 

Heavy Goods Vehicle 

Internal Combustion Engine 

Inland Waterway 

Modal Shift Potential 

On-Board Weighing 

Sustainable Development Goal 

Total cost of ownership 

Twenty-Foot Equivalent Unit 

Weights and Dimensions 

Weight in Motion 

Zero Emission Heavy Duty Vehicle 

 
 
1  INTRODUCTION 

This report presents the findings of the evaluation of Council Directive 96/53/EC on the 
maximum  dimensions  of  certain  road  vehicles  authorised  for  national  and 
international  traffic  and  the  maximum  weight  authorized  in  international  traffic 
(hereinafter  “the  Weights  and  Dimensions  Directive”,  or  “the  W&D  Directive”  or  “the 
Directive”)1.  

Road  transport  is  a  vital  component  of  the  EU  economy,  supporting  employment, 
facilitating  trade,  commerce,  and  mobility.  It  accounts  for  a  significant  portion  of  the 
total  amount  of  goods  transported  in  the  EU.  In  2020,  the  activity  of  freight  road 
transport  reached  1,700  billion  tonne-kilometres  (tkm),  representing  more  than  53%  of 
the goods transported within the EU and 77.4 % of the total inland freight transport 2. The 
sector  employs  5  million  people  in  the  EU3  and  together  with  other  transport  modes  it 
contributes 5% to GDP in the EU. 

While  commercial  road  transport  is  an  important  contributor  to  the  EU’s  economy  and 
society it may also have negative impacts on environment, public health, and road safety. 
It is important to balance the benefits of the commercial road transport with the efforts to 
reduce  its  negative  impacts  through,  inter  alia,  the  policies  that  promote  sustainability 
and safety. The W&D Directive is one of the regulatory tools that aim at mitigating the 
negative impacts  of the road transport operations by Heavy Duty Vehicles (HDV)4 and 
ensuring fair, safe, and sustainable road transport in the EU. It does so by setting limits 
on the size and weight of commercial HDVs used for transport of goods or passengers in 
national and international (intra-EU) traffic. This common regulatory framework aims at 
contributing to the well-functioning of the internal market, ensuring equal conditions of 
competition,  and  the  freedom  of  movement  of  goods  and  passengers.  The  Directive 
works 
the 
the  right  balance  between 
sustainability  of  commercial  road  transport,  road  safety  and  the  protection  of  the 
infrastructure.  

those  objectives  and 

towards  achieving 

1.1. Purpose and scope of the evaluation 

The  W&D  Directive  was  adopted  in  1996  and  amended  four  times  since  then,  to  reflect 
technological  and  market  developments  and  adapt  to  growing  environmental  ambitions  of 
EU  policies.  However,  it  has  never  been  subject  to  a  full-fledged  ex-post  evaluation.  The 
subsequent amendments were made in 2002 by Directive 2002/7/EC, in 2015 by Directive 
(EU) 2015/719 and in 2019 by Regulation (EU) 2019/1242 and Decision (EU) 2019/894. In 

1 Current consolidated version: 14/08/2019. 
2 European Commission: 2022 Statistical pocketbook: EU transport in figures. 
3 Ib. 
4 Heavy-duty vehicles are defined for the purpose of this legislation as freight motor vehicles and trailers 
with a technically permissible maximum laden mass of more of more than 3.5 tonnes (lorries) or passenger 
transport vehicles of more than 9 seats including the driver (buses and coaches). 

3 

 
 
                                                           
addition, the Commission adopted Implementing Regulation (EU) 2019/1916, laying down 
detailed  provisions  as  regards  the  use  of  rear  aerodynamic  devices,  and  Implementing 
Regulation (EU) 2019/1213 under the Directive. All the amendments to the Directive and the 
complementary implementing measures are covered by this evaluation analysis. 

In 2020, the Commission adopted the Communication on a Sustainable and Smart Mobility 
Strategy, setting out the EU vision for the transport system of the future, in which it announced 
the review of the W&D Directive.5 The review is done by the ex-post evaluation performed 
“back-to-back” with an impact assessment for a potential revision of the Directive. 

The purpose of the evaluation is an assessment of the performance of all substantive provisions 
of the Directive (Articles 1 to 13) across the EU. The evaluation examines the effects that the 
Directive  has  had  in  terms  of  ensuring  the  free  movement  of  goods,  improving  energy 
efficiency,  reducing  greenhouse  emissions  (GHG)6  and  mitigating  road  safety  risks  and 
assesses  which  provisions  worked  well  and  which  did  not,  and  why.  The  evaluation  period 
spans from September 1997 (deadline for transposition of the Directive adopted in 1996) until 
31  December  2021.  The  evaluation  covers  the  full  geographical  scope  of  the  Directive  and 
assesses its effects in all Member States of the EU, and the United Kingdom. 

1.2. Evaluation methodology 

The  evaluation  follows  the  Commission’s  Better  Regulation  Guidelines,  structuring  the 
analysis around the evaluation criteria of effectiveness, efficiency, relevance, coherence, 
and EU added value.  

  Effectiveness assesses the actual changes the Directive has triggered—in particular, 
how  successful  the  EU  action  has  been  in  achieving  or  progressing  towards  its 
objectives. It examines how Member States implemented the Directive and how the 
road transport market benefited from the Directive’s provisions. 

  Efficiency  assesses  the  actual  costs  relative  to  the  actual  benefits  of  the 
implementation of the Directive, and whether there is potential for simplification and 
increasing cost-efficiency. 

  Coherence assesses whether the Directive is internally consistence and whether it is 

coherent with other key legislation and relevant policy initiatives at EU level. 

  Relevance assesses whether the overall problem analysis and related objectives are 
still  adequate  and  how  the  policy  context  has  evolved.  It  analyses  whether  the 
Directive  matches  the  current  and  future  needs  and  whether  its  scope  is  fit  for 
purpose, given technological and policy developments. 

5 COM(2020) 789 final  - Sustainable and Smart Mobility  Strategy  – putting European transport on track 
for the future; FLAGSHIP 1 – Boosting the uptake of zero-emission vehicles, renewable & low-carbon 
fuels and related infrastructure, point 15. 

6  Reducing  greenhouse  emissions  (GHG):  Improved  energy  efficiency  leading  to  a  reduction  in  fuel  use 
would  generally  also  have  benefits  in  the  form  of  reduced  emissions  of  air  pollutants,  which  cause 
damage  to  the  environment  and  human  health.  As  previous  amendments  of  the  Directive  that  are 
evaluated here were not motivated on grounds of reduced air pollution, such benefits are not captured 
in the analysis. 

4 

 
 
 
                                                           
  EU  added  value  assesses  impacts  of  the  implementation  of  the  Directive  beyond 
what reasonably could have been achieved by national actions by the Member States 
and within bilateral or international cooperation between them.  

The following sources of information were used for this evaluation: 

-  Stakeholder  consultation  activities,  including  an  online  open  public  consultation 
(OPC),  targeted  surveys  and  interviews,  to  gather  information  about  public  and 
private stakeholders’ perception of the Directive,  

-  Commission  report  on  the  implementation  of  amendments  introduced  by 

Directive (EU) 2015/719, 

-  Member  States  reports  on  controls  and  their  results  in  terms  of  a  detection  of 

overloaded HDV, 

-  External support study to the ex-post evaluation of the W&D Directive. 

The methodology used in the evaluation is detailed in Annex II to this report. An evaluation 
matrix  (provided  in  Annex  III)  was  elaborated  based  on  the  methodology  to  answer  the 
evaluation questions. It identified operational questions, indicators, and data sources, as well 
as the approach to answer the questions. The length of the evaluation period (over 25 years) 
posed  a  challenge  in  terms  of  the  availability  and  comparability  of  quantitative  data,  in 
particular  for  data  related  to  passenger  transport  and  for  data  before  2004  when  the 
categorisation of HDV changed in official statistical series and when twelve new European 
countries joined the EU7. The lack of quantitative data has been compensated to the extent 
possible with desk research and qualitative input from stakeholders.  

2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. Description of the intervention and its objectives 

The establishment of a border-free internal market on 1 January 1993, with the abolition 
of  border  controls,  and  the  introduction  of  a  cabotage  regimen8  within  the  EC  required  to 
harmonise the European rules on maximum weights and dimensions for HDV and to extend 
those  common  rules  to  cover  national  transport  in  order  to  equalise  conditions  of 
competition9.  As  indicated  in  recital  (3)  of  the  Directive,  it  was  considered  that  the 
differences between the standards in force in the Member States with regards to the weights 

7 Enlargements of the EU during the lifetime of the W&D Directive: in 1996 Belgium (BE), France (FR), 
Germany  (DE),  Italy  (IT),  Luxembourg  (LU),  Netherlands  (NL),  UK,  Greece  (GR),  Spain  (ES), 
Portugal  (PT),  Austria  (AT),  Finland  (FI),  Denmark  (DK),  Ireland  (IE),  Sweden  (SE),  (15  Member 
States);  in  2004  Czech  Republic  (CZ),  Estonia  (EE),  Cyprus  (CY),  Latvia  (LV),  Lithuania  (LT), 
Hungary  (HU),  Malta  (MT),  Poland  (PL),  Slovakia  (SK)and  Slovenia  (SI)  (25  Member  States);  in 
2007  Bulgaria  (BG)  and  Romania  (RO)  (27  Member  States);  in  2013  Croatia  (HR)  (28  Member 
States). In 2020 the UK left the UE (27 Member States). 

8  Council  Regulation  (EEC)  No  4059/89 of  21  December  1989  laying  down  the  conditions  under  which 
non-resident  carriers  may  operate  national  road  haulage  services  within  a  Member  State  (OJ  L  390 

30.12.1989, p. 3. ELI: http://data.europa.eu/eli/reg/1989/4059/oj). 

9 Commission proposal for a Council Directive laying down maximum authorised weights and dimensions 
for road vehicles over 3.5 tonnes circulating within the Community of 15 December 1993, COM(93) 
679 final. 

5 

 
                                                           
and dimensions of commercial road vehicles could have an adverse effect on the conditions 
of competition and could constitute an obstacle to traffic between Member States.  

The preceding Council Directive 85/3/ECC10 allowed Member States to prohibit vehicles 
registered  in  another  country  that  exceeded  the  Directive’s  standards  for  weights  and 
dimensions despite the same excesses have been allowed for vehicles registered in their 
territory. The extension of the European rules to national transport by Council Directive 
96/53/EC was limited to those issues of major importance for the well-functioning of the 
internal  market  and  equal  competition.  The  Directive  maintained  the  prerogative  of 
Member  States  to  adopt  national  rules  on  maximum  weights  for  national  transport  to 
satisfy  local  circumstances  and  requirements  in  a  non-discriminatory  way  (e.g.,  via  the 
use  of  longer  and  heavier  HDV  for  local  activities  or  allowing  modular  systems11  with 
equivalent cargo capacity in national transport). 

The W&D Directive 96/53/EC is the recast of Directive 85/3/ECC and Council Directive 
86/364/EEC12 to simplify and clarify the Community law to make it more accessible, 
transparent, and easier to implement and control. The W&D Directive was amended by 
Directive 2002/7/EC13 which harmonised the maximum  authorised dimensions of buses 
in national and international traffic to enable their free circulation within the EU and  to 
ensure efficient cabotage operations for passenger transport. 

The  evolving  market,  emerging  technological  developments,  and  gradually  more 
ambitious  greenhouse  gas  emissions  targets14  demanded  a  revision  of  the  Directive  in 
2015  to  improve  the  energy  performance  of  commercial  road  transport  operations  by 
HDVs.  Amending  Directive  (EU)  2015/719  provided  for  certain  derogations  from  the 
maximum authorised weights and dimensions of vehicles and vehicle combinations laid 
down  in  the  W&D  Directive,  to  facilitate  the  use  of  alternatively  fuelled  vehicles 
(including  zero-emission  heavy-duty  vehicles),  improve  vehicles’  aerodynamics  and 
support  intermodal  transport15  operations.  The  objective  of  reducing  greenhouse  gas 
emissions was the main driver for these amendments, together with improving working 

10  Council  Directive  85/3/EEC  of  19  December  1984  on  the  weights,  dimensions  and  certain  other 

technical characteristics of certain road vehicles (OJ L 2, 3.1.1985, p. 14–18). 

11 European Modular Systems or “EMS” are regulated in article 4.4(b) of the W&D Directive. According 
to  this  article  Member  States  may  allow  longer  and/or  wider  vehicles  or  vehicle  combinations  in 
national transport under the condition that they also allow the circulation of standard vehicles (motor 
vehicles, trailer and semitrailer) in such combinations as to reach the same loading length authorised in 
the given Member State. 

12 Council Directive 86/364/EEC of 24 July 1968 relating to proof of compliance of vehicles with Directive 
85/3/EEC  on  the  weights,  dimensions  and  certain  other  technical  characteristics  of  certain  road 
vehicles (OJ L 221, 7.8.1986, p. 48–50). 

13 Directive 2002/7/EC (OJ L 67, 9.3.2002, p. 47–49). 
14  The  Kyoto  Protocol,  adopted  in  Kyoto,  Japan,  in  1997,  commits  37  industrialized  countries  and  the 
European  Union  to  the  so-called  Kyoto  target  of  reducing  their  greenhouse  gas  emissions  by  an 
average of 5% against 1990 levels, over the 2008-2012 period. At the 2012 United Nations  Climate 
Change Conference there was an agreement to extend the life of the Kyoto Protocol until 2020. 

15 Intermodal transport is a type of multimodal transport where the goods are not handled between different 
modes of transport. Instead, the full (unopened) loading unit (e.g., a container) is transhipped from one 
vehicle (e.g., truck) to another (e.g., rail wagon or vessel). Intermodal freight transport is possible in 
many combinations and typically involves one or two road legs connecting the starting  and/or ending 
point to the non-road leg. 

6 

 
                                                           
conditions  of  drivers  (by  allowing  safer,  more  spacious  cabs)  in  commercial  (freight) 
transport. The amendment also strengthened the enforcement tools and control measures 
to ensure undistorted competition and road safety. 

The Weights and Dimensions Directive was modified again in 2019 by a Decision (EU) 
2019/984 to bring forward the date of application set up in the Weights and Dimensions 
Directive to allow more aerodynamic, efficient, and safer cabs to be placed on the market 
from  1st  September  202016.  Driven  by  the  commitments  of  the  Paris  Agreement  on 
Climate Change17, Regulation (EU) 2019/1242 introduced the notion of “zero-emission” 
vehicles and allowed for additional weight derogations for such vehicles to promote their 
deployment in commercial road transport operations. 

A diagram representing the intervention logic of the W&D Directive and its amendments 
is  presented in  Annex  VI.  It  summarises the links and causal  relationships  between the 
problems  and  needs.  It  takes  into  consideration  the  general,  specific,  and  operational 
objectives  that  the  legislative  framework  was  designed  to  address  and  presents  the 
specific  actions  (inputs)  for  addressing  those  problems  and  needs,  as  well  as  expected 
outputs, results and impacts. 

2.2.  Relation  of  the  intervention  to  the  United  Nations  Sustainable  Development 
Goals 

While  the  WDD  itself  has  not  explicitly  addressed  the  United  Nations  Sustainable 
Development  Goals  (SDGs),  it  indirectly  contributes  to  several  of  them.  Following  the 
2015 and 2019 amendments, the WDD is  directly  incentivizing the use of alternatively 
fuelled  HDVs  including  zero-emission  vehicles,  containerised  transport  to  use  more 
sustainable  modes  of  transport  like  rail  or  maritime,  the  deployment  of  aerodynamic 
devices  and  elongated  cabins  to  reduce  air  drag  and  thus  increasing  fuel  efficiency,  as 
well as improving road safety and working conditions.  

Thus, several goals are being supported:  

Goal 3: Good Health and Wellbeing – the WDD contributes to this goal by ensuring that 
the HDVs are not overloaded, which may result in accidents and injuries. By enforcing 
weight and dimensions limits, the Directive helps to improve road safety. Moreover, by 
facilitating  the  deployment  of  alternatively  fuelled,  and  in  particular  zero-emission 
vehicles, the Directive can mitigate potentially hazardous effects from HDV’s emissions 
on human beings.  

Goal 13: Climate Action — the Greening Transport Package, which the WDD is a part 
of,  will  allow  for  a  synergistic  effect  that  will  make  road  transport  more  sustainable, 
make road vehicles more compatible with other modes of transportation, and increase rail 

16 The initial date of enter into application of article 9a.3 of Council Directive 96/53/EC was 2 December 

2022. 

17 United Nations / Framework Convention on Climate Change (2015) Adoption of the Paris Agreement, 
21st Conference of the Parties, Paris: United Nations [Paris Agreement (Dec. 13, 2015), in UNFCCC, 
COP Report No. 21, Addendum, at 21, U.N. Doc. FCCC/CP/2015/10/Add, 1 (Jan. 29, 2016)]. 

7 

 
                                                           
capacity  thus  allowing  for  growth  of  intermodal  transport,  is  where  the  WDD  most 
significantly contributes to climate action. 

Overall,  the  WDD  contributes  to  the  objectives  of  the  SDGs  through  the  promotion  of 
safer, more efficient, and more sustainable transportation practices within the Union.  

2.3. Points of comparison  

Before  the  adoption  of  the  W&D  Directive  in  1996,  and  despite  that  its  predecessor 
(Council Directive 85/3/ECC) set out certain maximum weights and dimensions for certain 
categories  of  HDVs,  there  were  significant  differences  between  the  standards  in  force  in 
Member  States.  The  requirements  to  apply  for  national  permits  for  vehicles  carrying 
indivisible  load  were  unclear  as  there  was  no  uniform  definition  of  the  concept  of 
‘indivisible load’. In addition, certain rules established by the Council Directive 85/3/ECC, 
were  not  adapted  to  the  progress  in  technical  developments  causing  inefficiencies  in 
transport operations. For instance, the allowed width of 2.5 m for goods vehicles has not 
allowed  for  the  efficient  loading  of  pallets.  Hence,  Member  States  applied  different 
tolerances beyond the limit in the legislation. This created uncertainty and difficulties for 
road  transport  companies  operating  across  borders,  as  they  had  to  comply  with  different 
regulations in different Member States. These diverging rules had an adverse effect on the 
conditions of competition and constituted an obstacle to traffic between Member States.  

Without  the  EU  intervention,  it  was  expected  that  the  situation  would  continue  to  be 
fragmented, with each country enforcing its own regulations, creating significant barriers 
to trade, and increasing transportation costs for operations across national borders within 
the EU. The W&D Directive was designed to address and mitigate the problems resulting 
from  diverging  and/or  inadequate  rules  that  is  fragmentation  of  the  market,  legal 
uncertainty,  and inefficiencies of cross-border operations as well as  risks to road safety 
and of damage to infrastructure caused by overloaded and/or oversized vehicles. 

The  performance  of  the  Directive  is  assessed  against  the  expected  impacts  of  the 
intervention.  

The Directive was expected to bring the following results: 

-  Harmonised  national  and  international  rules  and  enabled  cabotage  operations 
bringing a reduction in freight and in passenger18 transport costs. It was estimated 
that simplifying the possibilities for cabotage under harmonised fair competition 
conditions, would consequently reduce passenger transport costs, helping to make 
public  transport  more  attractive.  The  level  of  harmonisation  between  the 
standards set in the Directive and the national rules, the evolution in time of the 
share  of  national  and  international  transport,  including  cross-trade  and 
cabotage,  over  the  lifetime  of  the  Directive  would  provide  an  indication  of  the 
degree of integration of the internal market for road transport services. 

18 Rules related to passenger transport would only produce effects from 08.03.2004 (data of transposition 

of Directive 2002/7/EC). 

8 

 
                                                           
-  A reduction in  the number of road journeys for passenger19 transport bringing 
positive economic and environmental effects. It was estimated that increasing the 
maximum length of buses in some of the Member States will result in fewer buses 
being  required  to  transport  the  same  number  of  passengers.  Such  an  effect, 
journeys,  would  be  both  environmentally  and 
resulting 
economically beneficial. 

in  fewer  road 

-  A  significant  increase  in  the  share  of  long-distance  trailers  equipped  with  rear 
aerodynamic  devices  (75%)  and  aerodynamic,  safer  and  more  comfortable 
cabins (50%) by 2030, 

-  An  improved  energy  efficiency  and  environmental  performance  of  HDV 
leading  to  a  reduction  of  CO2  emissions  from  the  HDV  sector  in  line  with  the 
requirements of EU climate policy and the Paris Agreement. These savings were 
expected  mainly  as  a  result  of  reducing  aerodynamic  drag  thanks  to  different 
aerodynamic  devices,  allowance  of  longer/heavier  vehicles,  including  modular 
systems,  that  would  reduce  number  of  trips  as  well  as  anticipated  uptake  of 
alternatively fuelled vehicles; 

-  A doubled use of 45 ft containers transported as part of a combined/intermodal 
transport operation: by 2030, 75% of the containers transported over more than 
300 km inside the EU should use at least two modes of transport20, 

-  A reduction in operating costs for transport operators (great majority of which 
are  SMEs)  due  to  energy  saving  devices  and  possibility  of  use  in  national 
transport of longer/heavier vehicles; 

-  An increased effectiveness of manual checks (number of infringements detected/ 
number of checks performed). It was expected that the Directive’s provisions, in 
particular  those  on  overload  detection  devices,  would  improve  the  reliability  of 
checks and at the same time avoid annually 100,000 unnecessary checks by 2020; 

-  A  reduced  number  of  fatalities  in  road  accidents  where  a  HDV  has  been 

involved, thanks to safer vehicles equipment. 

These changes which were expected as a result of the implementation of the Directive 
and its amendments, serve as the point of reference for comparing the expectations with 
current situation and actual effects of the W&D Directive. 

3  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

This section explains the state of play in implementing the Directive and presents what 
has happened over the evaluation period in connexion with the general objectives of the 
Directive. 

3.1. Internal market 

19 Rules related to passenger transport will only produce effects from 08.03.2004 (data of transposition of 

Directive 2002/7/EC). 

20 Rules related to intermodal transport of 45-foot containers only produce effects from 07.05.2017 (data of 

transposition of Directive (EU) 2015/719). 

9 

 
                                                           
Council  Directive  96/53/EC  took  a  step  forward  in  the  establishment  of  a  border-free 
internal  market  initiated  by  its  predecessors  contributing  to  increase  in  cross-border 
operations and enabling cabotage operations. As shown in Figure 1 (and details in Table 
1),  international  road  freight  transport,  including  cross-trade  and  cabotage  operations, 
steadily  increased  its  share  in  the  total  road  transport  activity  from  22.7%  in  1995  to 
38.5%  in  2020  for  the  EU27,  showing  a  progressive  integration  of  the  road  freight 
transport market. 

Figure 1: Road freight transport by HDV in the EU, 1995-2020. 

(*) including cross-trade and cabotage 
Source: Eurostat [road_go_ta_tott]; International Transport Forum (IS, TR), national statistics (CH  - until 
2007, MK); own calculations and representation. 

Table 1: Road freight transport by HDV in the EU, 1995-2020. 

Total 
transport(*) 

International 
transport(*)(**) 

National 
transport(*) 

% of 
international 
transport 

EU-
27 
EU-
28 
EU-
27 
EU-
28 
EU-
27 
EU-
28 
EU-
27 
EU-
28 

1995 

2000 

2005 

2010 

2015 

2020 

1 127.2 

1 343.9 

1 633.3 

1 609.7 

1 615.1 

1 803.4 

1 288.7 

1 509.5 

1 794.6 

1 756.4 

1 765.2 

255.3461  406.295  558.706  574.259  612.572  695.178 

270.1321  421.579  568.773  583.191  619.805 

845.0 

936.1 

1 074.6 

1 035.4 

1 002.6 

1 108.3 

991.8 

1 086.4 

1 225.8 

1 173.2 

1 145.4 

22.7 

30.2 

34.2 

35.7 

37.9 

38.5 

21.0 

27.9 

31.7 

33.2 

35.1 

(*) billion tkm. 
(**) including cross-trade and cabotage 

10 

 
 
 
 
 
 
 
 
 
 
Source: Eurostat [road_go_ta_tott]; International Transport Forum (IS, TR), national statistics (CH - until 
2007, MK); own calculations. 

However,  some  barriers  to  the  cross-border  transport  remain.  The  Directive  does  not 
harmonise  the  rules  concerning  the  maximum  overhang  of  loads  used  e.g.,  in  vehicle 
transporters,  “as  hauliers  were  able  to  adapt  their  loading  methods  to  satisfy  local 
prescriptions”21.  Currently,  all  Member  States  but  one22  have  increased  the  maximum 
length  of  vehicle  transporters  via  the  use  of  front  and/or  rear  overhangs  from  at  least 
20.35  m  to  an  unlimited  length.  Figure  2  illustrates  these  overhangs  and  the  resulting 
possibility  to  transport  nine  (20.75  m  length  of  overhangs)  instead  of  seven  passenger 
cars (18.75 m).  

Figure 2: Number of passenger vehicles transported by a vehicle carrier with lengths of 
18.75 m and 20.75 m. 

Source: ECG. 

A geographical overview of the different rules concerning overhangs’ lengths is shown in 
Figure 3, indicating the great variety among the Member States. There are also variations 
as regards the permitted extra length to the front and to the rear of the vehicle. The fact 
that the maximum overhang of loads is not regulated in the W&D Directive triggers the 
question of the lawfulness of cross-border transport of vehicles with overhangs exceeding 
the maximum length of the vehicle. In practice, the cross-border transport of car carriers 
exceeding the maximum length  is  consented by  Member States if national  standards of 
the territories crossed are met.  

The Directive also does not harmonise the rules and procedures for the national permits 
for the transport of indivisible loads.23 It was considered that permits should remain the 
competence of local  or  national  authorities as they  are in  the best  position to  judge the 

21  Explanatory  memorandum  of  Commission  proposal  for  a  Council  Directive  laying  down  maximum 
authorised weights and dimensions for road vehicles over 3.5 tonnes circulating within the Community 
of 15 December 1993. COM(93) 679 final. 

22 Malta does not allow overhangs. 
23 Indivisible load is defined by article 2 of the W&D Directive as “a load that cannot, for the purpose of 
carriage  by  road,  be  divided  into  two  or  more  loads  without  undue  expense  or  risk  of  damage  and 
which  owing  to  its  dimensions  or  mass  cannot  be  carried  by  a  motor  vehicle,  trailer,  road  train  or 
articulated  vehicle  complying  with  this  Directive  in  all  respects”.  According  to  article  4(3)  of  the 
W&D Directive the international transport of indivisible loads is subject to a national permit. 

11 

 
 
                                                           
need  for  such  permits,  and  that  the  need  for  further  streamlining  of  these  procedures 
should be considered in the future.24  

Figure 3: Maximum loaded length (via front and/or rear overhangs) of car transporters 
in the EU based on national legislation, in meters 

Source: ECG. 

The  only  common  requirement  introduced  by  the  Directive  in  this  respect  was  the 
principle  of  non-discrimination  in  granting  the  authorisation  for  the  carriage  of 
indivisible  loads,  with  regard  to  the  country  of  registration  of  the  vehicle  and/or 
establishment  of  the  operator.  In  effect,  the  national  rules  vary  significantly  between 
Member  States  in  terms  of  the  conditions  assigned  to  each  type  of  permit  (long-term 
permits and/or one-time/one-route permits), the number of authorities to be consulted by 
the applicant, the time needed to issue permits25 and the route selection and check26. To 
address  the  challenges  faced  by  abnormal  transport,  the  Commission  Expert  Group 
elaborated  and  adopted  in  2008  the  European  Best  Practice  Guidelines  for  Abnormal 
Road Transports (BPG).27  Although the BPG offered a list  of rules and procedures  that 
could  help  harmonised  approach,  safer  operations  and  improved  transparency,  and 

24 COM(93) 679 final. 
25 According to the road transport operators the time for issuing a national permit varies from 1-2 weeks to 
up  to  12  weeks  depending  on  the  Member  State  issuing  the  authorisation,  the  selected  route  or  the 
period of validity of the permit. 

26  Whenever  predefined  corridors  have  not  been  identified,  routes  must  be  selected  by  the  applicant  to 
apply  for  the  authorisation  of  a  given  abnormal  transport.  Furthermore,  some  countries  also  require 
outlining at least one alternative path. 

27  The  Commission  Expert  Group,  in  2008,  established  the  European  Best  Practice  Guidelines  for 
Abnormal  Road  Transports  (BPG),  with  the  positive  opinion  of  the  Road  Safety  High  Level  Group, 
which were primarily addressed to the public authorities in the Member States: European Commission, 
Directorate-General  for  Energy  and  Transport,  Abnormal  Road  Transports:  European  best  practice 
guidelines, Publications Office, 2008.  

12 

 
 
                                                           
despite the consensus reached by Member States at the time of their adoption, the BPG 
have barely been followed by Member States. No progress has been made regarding the 
implementation of the SERT document,28 nor the abnormal transport corridors and only a 
few Member States have fully implemented the one-stop-shop principle. 

In  search  of  improving  the  economic  and  environmental  efficiency  of  transport  and  to 
address  national  specificities,  many  Member  States  granted  national  derogations,  as 
allowed  by  the  Directive,  authorizing  the  circulation  in  their  territories  of  HDV 
exceeding the maximum weights and/or maximum dimensions set in the Directive. While 
derogations  from  weight  limits  have  no  prescribed  restrictions,  the  derogations  from 
dimension standards are allowed in specific cases, namely: specialised vehicles, such as 
the  ones  used  in  the  forestry  industry;  European  Modular  System  (EMS);  and  trial 
schemes with vehicles incorporating new technologies or new concepts.  

Figure 4: Typical EMS combinations used in European freight transport. 

Type 1 consists of a traditional lorry (N3) in combination with a dolly and a semitrailer. The total length is up to 25.25 
m, and the total weight up to 60 tons with 8 axles. 
Type 2 consists of a tractor, a semitrailer and a trailer. Again, with up to 8 axles, up to 25.25 m length and 60 tons of 
total weight. 

28 The Special European Registration of Trucks and Trailers (SERT) document is a single document that covers 
the needs of the different national authorities as regards detailed vehicle information that is not available on 
the registration certificate. Most countries have developed their own information documents (the majority 
not recognising the validity of the documents emitted in a different Member State). The BPG proposed a 
concrete  format  for  the  SERT  document,  with  the  aim  to  harmonise  the  technical  vehicle  information 
needed both for trailers and tractive units (tractors and lorries). This document would ideally develop into an 
electronic format making the information available on-line for the national authorities. The SERT document 
is only issued by the Netherlands, and is recognised in other 5 Member States. 

13 

 
 
                                                           
Type 3 consists of a tractor, a shorter link trailer and a traditional semitrailer. Again, up to 25.25 m and 60 tons. 
Type 4 consists of a long truck and a long trailer (both units up to 12 m) with a total length of 24 m. Equipped with 
only 6 axles, the total weight is up to 48/50 tons. 

The  EMS  is  a  type  of  high-capacity  vehicle  (HCV)  designed  to  increase  the  vehicles 
loading  capacity  in  order  to  improve  energy  and  operational  efficiency  of  the  transport 
operation. The EMS is a vehicle combination consisting of standard units (tractor, trailer 
and semi-trailer; type-approved) that fully comply with the limits of the W&D Directive, 
only the combination of these units exceeds the prescribed limits. Figure 4 demonstrates 
the different  combinations arising  from the EMS systems,  resulting in  different lengths 
and weights. 

The  W&D  Directive  does  not  explicitly  allow  heavier  and/or  longer  vehicles  in  cross-
border  transport.  However,  based  on  broad  interpretation  of  the  Directive,  it  was 
established that operations by longer (not heavier) vehicles crossing one border between 
two neighbouring Member States that allow the same length values is lawful.29 Moreover, 
Member States  considered that the Directive does not  prevent  them from allowing also 
heavier HDVs crossing a common border if both Member States agree to it.  

Figure 5: Maximum national permissible lengths of HDVs and allowed cross-border 
transport in the EU. 

18 m 

Sources: ITF-OECD, Volvo, and CEDR and road authorities’ webpages and consultation activities. 

29  The  explanation  provided  by  former  Vice-President  Siim  Kallas  in  his  letter  of  13  June  2012  to  MEP 
Brian  Simpson,  Chairman  of  the  TRAN  Committee  of  the  European  Parliament  (attached  as  Annex 
VI). 

14 

 
 
                                                           
Currently, as shown in Figure 5, the use of the European Modular Systems (EMS) of at 
least 25.25 m long is allowed in Finland and Sweden, and is being trialled in Denmark, 
the Netherlands, Belgium, Spain, Portugal, Czech Republic, and Germany, while Finland 
allows up to 34.5 m. Italy authorises longer semitrailers to allow for a maximum length 
of the vehicle combination of 18 m. Latvia is planning to introduce legislative changes to 
allow  EMS  in  the  short  term,  while  France  is  evaluating  the  opportunity  to  start  trials 
with EMS too. Cross-border transport of EMS is allowed between Finland and Sweden, 
Sweden  and  Denmark,  Belgium  and  the  Netherlands,  and  between  Germany  and  the 
Netherlands. Additional bilateral agreements are in the pipeline to authorise cross-border 
transport  of  EMS  between  Germany  and  Denmark,  Germany  and  the  Czech  Republic, 
and Portugal and Spain. 

All Member States authorising the circulation of EMS allow them with a maximum gross 
vehicle combination weight of at least 60 t, except from Germany where it is limited to 
40 t (44 t in intermodal transport).  

Figure 6: Maximum national permissible weights of HDVs and allowed cross-border 
transport in the EU 

Sources: ITF-OECD, Volvo, and CEDR and road authorities’ webpages and consultation activities. 

In  addition,  Belgium,  Czech  Republic,  France,  Ireland,  Italy,  Luxembourg,  the 
Netherlands,  Portugal,  Sweden,  Denmark,  and  Finland  allow  the  circulation  in  national 

15 

 
 
 
transport of five and/or six-axle vehicle combinations (standard articulated vehicles and 
road trains) with a maximum weight of 44 tonnes or more30, as shown in Figure 6. There 
is  a  particular  situation  applicable  to  the  Benelux  countries,  originating  in  the  Treaty 
Establishing  the  Benelux  Economic  Union31,  which  was  recognised  by  article  350 
TFEU32. Based on this Treaty, Belgium, Luxembourg, and the Netherlands, allow cross-
border operations between them with heavier and longer HDV of up to 44 t. 

Amending  Directive  2002/7/EC  harmonised  the  maximum  authorised  dimensions  of 
buses in  national  and international  traffic to  enable their free circulation  within the EU 
and  to  ensure  that  cabotage  operations  for  passenger  transport  worked  efficiently. 
Amending  Directive  2015/719  increased  the  maximum  authorised  weight  for  two-axle 
buses to compensate the substantial increase in the average weight of bus passengers and 
their luggage, since the approval of Directive 96/53/EC and the weight of the vehicle’s 
equipment  needed  to  meet  the  new  technical  requirements.  This  increased  weight 
threshold helped to prevent a reduction of a number of passengers carried by collective 
road transport. 

Figure 7: Evolution of passenger transport by buses and coaches by type of transport 
(national and international). 

Source: Eurostat [ROAD_PA_BUSCOA__custom_5166990]; own calculations. 

30 Czech Republic allows a maximum weight of up to 48 t, the Netherlands of up to 50 t and Italy allows a 

maximum weight of up to 56 t for the transport of excavation and mining materials. 

31  Consolidated  version  of  the  Treaty  Establishing  the  Benelux  Economic  Union  available  in 

https://wetten.overheid.nl/BWBV0005047/2012-01-01. 

32 Article 350 of the TFEU: “The provisions of the Treaties shall not preclude the existence or completion 
of  regional  unions  between  Belgium  and  Luxembourg,  or  between  Belgium,  Luxembourg  and  the 
Netherlands, to the extent that the objectives of these regional unions are not attained by application of 
the Treaties.” 

16 

201320142015201620172018201920202021Total national trasport (8 MS)76,71781,03684,07883,42371,69870,20373,70745,80449,056Total international transport (8 MS)15,50415,85418,67317,96015,25815,72316,8474,2654,272Share of International transport (%)16.81        16.36        18.17        17.71        17.55        18.30        18.60        8.52          8.01           
 
  
                                                           
The statistical data on the evolution of national and international transport is very limited. 
It  covers  the  period  2013-2021  and  the  full  data  series  on  national  and  international 
transport for those years is only available for eight Member States33. With this caveat, the 
data in Figure 7 shows a progressive integration of the passenger transport market. The 
share of international transport over the whole passenger transport by buses and coaches 
grows over the period 2013-2019, showing an abrupt decline in the years 2020 and 2021, 
which can be directly attributed to the impact of the national measures adopted during the 
Covid-19 pandemic to contain the spread of the virus.  

 3.2. GHG emission and energy performance  

The  amendments  introduced  in  2015  (Directive  (EU)  2015/71934)  provided  for  certain 
derogations  from  the  maximum  authorised  weights  and  dimensions  of  HDV  to 
incentivise  the  uptake  of  “greening”  technologies  and  of  more  sustainable  transport 
schemes, in particular the use of alternatively fuelled vehicles, including zero-emission 
vehicles,  the  improvement  of  vehicles’  aerodynamics  and  the  support  to  intermodal 
containerised transport. 

Despite  that,  the  proportion  of  low-  and  zero-emission  vehicles  within  the  commercial 
vehicles’  fleet,  is  very  low.  According  to  the  most  recent  available  figures  from  the 
European  Automobiles  Manufacturers  Association  (ACEA,  2022),  the  number  of 
alternatively  fuelled  medium  and  heavy-duty  vehicles  (yearly  registration  figures)  have 
grown from 0.5% in 2016 to 6.6% in 202035. Figure 8 presents the share of alternatively 
fuelled buses, trucks, vans (light commercial vehicles) and cars in the EU fleet in 2020. 

Figure 8: Share of alternatively powered vehicles in the EU fleet in 2020. 

Source: ACEA Vehicles in Use Report, 2022 

33 Data available from Belgium, Bulgaria, Estonia, Croatia, Hungary, Poland, Portugal, and Romania.  
34 OJ L 115, 6.5.2015, p. 1–10. 
35 https://www.acea.auto/files/ACEA-report-vehicles-in-use-europe-2022.pdf  

17 

 
 
                                                           
Also, regarding new registrations, diesel trucks continue to account for the majority, only 
with  a  slight  decrease  from  98.5%  in  2018  to  95.8%  in  2021,  and  only  0.5%  of 
electrically chargeable HDVs in the same year (see Figure 9 for further details).  

Figure 9: New trucks in the EU by fuel type, market share, 2018-2021. 

Source: ACEA. 

A different trend can be observed in the field of buses. Figure 10 shows that the share of 
newly registered electrically chargeable buses went from 1.6% in 2018 to 10.6% in 2021, 
and similar trends for hybrid electric and alternatively fuelled buses. 

Figure 1010: New Buses in the EU by fuel type, market share, 2018-2021. 

Source: ACEA. 

18 

 
 
 
The 2015 amendments to the W&D Directive also supported the improvement of vehicles’ 
aerodynamics by allowing extra length for HDV equipped with rear aerodynamic devices 
and for HDV equipped with elongated cabs improving the aerodynamics and safety of the 
vehicle,  as  well  as  the  visibility,  safety  and  comfort  of  drivers.  According  to  the  impact 
assessment that served as basis to the proposal amending the W&D Directive in 201336, the 
use of rear aerodynamic devices could lead to a reduction in fuel consumption in the range of 
5-8%,  while the  energy  performance  was  expected to improve between 3.2  %  and 8.9 %, 
depending on the length of the extension, with more aerodynamic cabs. 

The  type-approval  legal  framework  necessary  for  the  introduction  of  aerodynamic 
devices and cabs, and the complementary rules to ensure uniform operational conditions 
of  rear  flaps37  apply  since  December  201938.  In  addition,  the  length  derogation  for  the 
new cabs applies only from 1 September 2020.39 Based on the information available, the 
first and the only truck model equipped with an elongated cab so far was placed on the 
market in June 202140. 

 3.3. Intermodal transport 

transport  operations  are  considered  a  substantial  element 

the 
Intermodal 
decarbonisation  of  freight  transport  in  the  EU.  It  combines  the  better  environmental 
performance  and  energy  efficiency  of  non-road  transport  with  the  accessibility  and 
flexibility of road transport in the ‘first and last mile” operations.  

in 

Directive (EU) 2015/719 introduced new provisions to support containerised intermodal 
transport  operations  granting  additional  length  (15  cm)  and  weight  (4  t)  for  5-  and  6- 
axles HDV combinations involved in transporting containers or swap bodies of up to 45 
ft (13.72 m) as part of intermodal transport operations. The objective was to eliminate the 
need for chamfered corners (extra length) and compensating the unladen weight of such 
containers  or  swap  bodies  (extra  weight).  However,  these  advantages  to  promote 
intermodal transport have been partially cancelled out in twelve Member States41, where 
the weight limit for HDVs used in road-only national operations was increased to at least 
44 t. As a result, shippers and operators involved in (containerised) intermodal transport 
in those Member States are disadvantaged due to lower loading capacity as compared to 
only-road transport in national traffic by 44 t HDVs. 

36 SWD (2013) 108 final. 
37  Commission  Implementing  Regulation  (EU)  2019/1916  of  15  November  2019  laying  down  detailed 
provisions as regards the use of rear aerodynamic devices pursuant to Council Directive 96/53/EC. It 
has been amended by Implementing Regulation 2020/349. 

38 Commission Regulation (EU) 2019/1892 of 31 October 2019 amending Regulation (EU) No 1230/2012 
as  regards  type-approval  requirements  for  certain  motor  vehicles  fitted  with  elongated  cabs  and  for 
aerodynamic devices and equipment for motor vehicles and their trailers. OJ L 291, 12.11.2019, p. 17. 

39 Article 9a(3) of the Weights and Dimensions Directive. 
40 Next Generation DAF truck launched on the 9th June 2021. https://youtu.be/4wLUrs4 tmQE  
41  Belgium,  Czech  Republic,  France,  Ireland,  Italy,  Luxembourg,  the  Netherlands,  Portugal,  Sweden, 
Denmark and Finland allow the circulation in  national transport of 5 or 6-axle vehicle combinations 
with a  maximum  weight of 44 tonnes. Czech  Republic allows a  maximum  weight of up to 48 t,  the 
Netherlands  of  up  to  50  t  and  Italy  allows  a  maximum  weight  of  up  to  56  t  for  the  transport  of 
excavation and mining materials. 

19 

 
                                                           
Intermodal transport has been growing for the last ten years (as shown in Figure 11), both 
before  and  after  the  implementation  of  Directive  (EC)  2015/719.  The  use  of  45-foot 
containers and swap bodies, which account  for 19% of the  ISO-container category, has 
been increasing during this period as they are considered the most efficient  cargo units 
for intermodal transport.  

Figure 11: Development in transport of loaded and unloaded containers in the EU, 
quarterly 

Source: Eurostat 

 3.4. Road safety and protection of the infrastructure  

The  W&D  Directive  aimed  at  safeguarding  road  safety  by  establishing  common 
standards for weights, dimensions and certain other characteristics of vehicles that would 
meet the requirements of the road infrastructure. At the same time the Directive allowed 
for  national  derogations  from  those  limits,  subject  to  Member  States’  specificities  and 
their  assessment  of  the  adequacy  of  the  road  infrastructure.  The  overview  of  national 
derogations  allowing  to  exceed  weights  and/or  dimensions  is  provided  in  the  previous 
section.  

On the one hand, the Directive allowed Member States to limit (lower) the weight and/or 
dimensions of HDV in certain civil engineering structures or areas, such as city centres, 
small villages, or places of special natural interest (Art. 7). On the other hand, Member 
States could allow higher weight limits for national transport and higher dimensions for 
certain transport that would not significantly affect international competition or as part of 
trials  incorporating  new  technologies  or  new  concepts  (Art.  4.2,  4.4  and  4.5).  The  key 
aspects  in  assessing  the  need  and  feasibility  of  such  derogations  were  road  safety  and 
adequacy of road infrastructure. 

20 

 
 
 
 
 
Figure 12: Trend in number of fatalities from all road crash types for the countries 
currently forming the EU-27. 

s
e
i
t
i
l

a
t
a
f

f
o
r
e
b
m
u
N

60.000

50.000

40.000

30.000

20.000

10.000

0

Source: Eurostat. 

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

Year

Over  the  evaluation  period,  the  positive  evolution  has  been  observed  as  regards  road 
safety  level  in  general,  with  the  total  number  of  fatalities  from  all  crash  types  having 
declined, as presented in Figure 12. However, notable differences among Member States 
appear  when  observing  the  number  of  fatalities  per  million  inhabitants,  as  shown  in 
Figure 13. 

Figure 13: Number of road fatalities per million inhabitants by country, 2021. 

Source: CARE (EU Road accidents database) and Commission estimates. Population data from Eurostat. 

The steepest decline occurred in the years 2007-2010, with a slowing rate of decline to 
2013  and  then  a  stagnation  until  the  most  recent  data,  excluding  2020  due  to  Covid 

21 

 
 
 
 
 
effects. ITF (2015) reviews what is a globally observed phenomenon, where road safety 
improves  during  economic  recessions  which  often  leads  to  a  correction  afterwards  as 
behaviour reverts more towards the normal trend. In the case of the 2008 financial crisis, 
this  has  subsequently  turned  to  relative  stagnation  in  road  safety  progress  at  EU  level. 
This  stagnation  is  often  attributed  to  cutbacks  in  ambition  in  the  wake  of  the  financial 
crisis, for example with abandonment or reduced funding for safety targets, less visible 
roads policing, declining investment in rural roads where many fatalities occur, combined 
with  other  changes,  such  as  increases  in  more  vulnerable  modes  of  travel  (cycling, 
walking)  (Agilysis,  2020).  Although  vehicle  safety  improvements  have  continued  and 
would  have  been  expected  to  have  resulted  in  greater  fatality  reduction,  distraction  has 
also  been  on  the  rise,  with  smartphones  becoming  ubiquitous  and  cars  themselves 
introducing smartphone-like technology directly in the cabin. It should be noted that no 
single  factor  can  fully  explain  the  trend  in  fatalities  because  road  safety  involves  a 
complex interplay of all these and other factors. 

The available data on the number of fatalities in collisions where an HGV is involved is 
limited to the period 2010 to 202142. This data shows an even stronger decreasing trend 
of -27% as compared to the reduction in the overall number of road fatalities in all traffic 
accidents  during  the  same  period  (-23%).  However,  the  proportion  of  fatalities  in 
collisions involving HGVs, which has stayed constant at around 14-15%, is higher than 
the share of HGVs in terms of vehicle km, as becoming visible from Figure 14. 

Figure 14: Trend in the number of fatalities from collisions involving HGVs and the 
share of all fatalities for the countries currently forming the EU-27, 2021. 

Source: ERSO, 2021. 

 3.5. Enforcement of the rules on maximum weights and dimensions 

In order to  avoid  distortions  of competition  and to  ensure road safety, it  was  necessary 
that  Member  States  adequately  addressed  the  infringements  in  relation  to  overloaded 
vehicles.  This  was  tackled  in  Directive  (EU)  2015/719  by  improving  the  means  for 
controls  by  using  Weigh-In-Motion  (WIM)  systems,  or  on-board  weighting  equipment 

42 Source: CARE database. 

22 

 
 
                                                           
(OBW)  to  be  installed  in  vehicles.43  The  2015  amendment  has  also  introduced  the 
principle  of  co-liability  of  shippers  and  hauliers  for  infringements  that  aimed  at  better 
compliance with the rules. Some Member States have been using detectors in the road for 
quite  a  long  time  (prior  to  27  May  2021),  with  all  of  them  having  opted  for  the 
deployment of WIM systems in the infrastructure. However, information on the number 
and  type  of  WIM  systems  deployed  so  far  is  not  available.  The  alternative  solution  of 
installing on-board weighting equipment (OBW) has generally been assessed as putting 
too much (economic) burden on the users. In addition, some manufacturers offer a non-
certified  solution  in  HDV  with  automatic  gear  change  which  helps  operators  to  better 
manage  their  fleets,  to  always  ensure  compliance  with  the  weight  limits  and  to  charge 
adequately customers in particular in case of bulk cargo. 

Every  year,  Member  States  should  perform  an  appropriate  number  of  vehicle  weight 
checks  (Art.  10d,  para.  2)  proportionate  to  the  total  number  of  vehicles  inspected  each 
year in the Member State concerned. Moreover, Art. 10g of the W&D Directive requires 
Member  States  to  report  to  the  Commission  every  two  years  the  number  of  checks 
carried out in the previous two  years and the number of overloaded vehicles or vehicle 
combinations  detected.  Several  Member  States  have  not  complied  with  this  obligation: 
only seventeen Member States have provided information for the reporting periods 2017-
2018 and nineteen Member States for 2019-2020. According to the data  available from 
nineteen  Member  States  on  the  results  of  controls  carried  out  in  2019-2020,  seventeen 
million  vehicles  and  vehicle  combinations  have  been  checked,  3.3%  of  which  were 
reported  overloaded.  Ireland  performed  the  highest  number  of  controls  (around  12.6 
million controls), followed by far by Poland (around 3 million controls) and Italy (almost 
600,000 controls). The high level of controls performed in Ireland can be attributed to the 
use of automatic weighting systems. 

In  addition,  the  variety  and  complexity  of  national  rules,  bilateral  agreements  and 
international rules and the lack of legal certainty have led to inefficient and inconsistent 
enforcement  in  cross-border  transport.  With  very  few  exceptions,  when  national  rules 
differ,  Member  States  do  not  enforce  them  for  the  cross-border  transport  if  the  HDV 
involved  comply  with  their  own  national  regulations.  The  rules  under  bilateral 
agreements are also enforced partially, affecting the competitiveness of the sector. This 
issue  has  been  reported  regarding  the  cross-border  transport  between  France  and 
Belgium. Both Member States allow a maximum weight of 44 t in national transport and 
for  many  years  the  cross-border  transport  at  44  t  was  tolerated,  even  if  not  explicitly 

43 Member States were required (article 10d) to take specific measures, by 27 May 2021, to automatically 
identify  vehicles  or  vehicle  combinations  in  circulation  that  are  likely  to  have  exceeded  the  relevant 
weight  limits  and  that  should  therefore  be  checked.  Such  pre-identification  may  be  carried  out  by 
means  of  weighting  mechanisms  built  into  the  road  infrastructure,  the  so-called  "Weight  In  Motion 
(WIM)” system, or by means of on-board weighting equipment (OBW) to be installed in vehicles that 
communicate  data  remotely  to  the  relevant  authorities.  Commission  Implementing  Regulation  (EU) 
2019/1213  established  the  uniform  conditions  for  the  implementation  of  interoperability  and 
compatibility  of  on-board  weighing  equipment  pursuant  to  Council  Directive  96/53/EC  (OJ  L  192, 
18.7.2019, p. 1–22). 

23 

 
                                                           
allowed by the W&D Directive44. At the  beginning of 2022,45 France started enforcing 
the EU provision not allowing the cross-border transport by 44 t HDVs, while Belgium 
did  not.  According  to  operator’s  complaints,  French  controls  are  only  targeting  the 
incoming  transport,  which  is  more  likely  to  affect  foreign  operators  and  lead  to 
discriminatory control practices. The situation is aggravated by the fact that the Benelux 
countries  enjoy  the  possibility  to  cross  borders  with  heavier  HDV.  The  partial 
enforcement and the different regimen of the Benelux results in a competitive advantage 
for international transport operators and providers transporting goods from France to the 
Benelux (potentially crossing 3 borders), which is estimated in a reduction of 10-15% of 
operational  costs,46  as  compared  to  their  counterpart  competitors  serving  the  French 
territory. 

4  EVALUATION FINDINGS  

This  section  presents  the  results  of  analysis  of  the  Directive  regarding  five  evaluation 
criteria,  being  effectiveness,  efficiency,  relevance,  coherence,  and  EU  added  value.  It 
also  identifies  factors  of success/failure  and provides an outlook in  the  form of lessons 
learned and suggestions for improvement.  

4.1.To what extent was the intervention successful and why?  

The success of the Directive over the evaluation period is assessed in terms of the extent 
to which it achieved its objectives of ensuring fair competitions on the internal market, 
improving  energy  and  operational  efficiency  of  transport  operations,  protecting  road 
infrastructure and safeguarding road safety in  an  effective,  efficient,  and  coherent way. 
The  evidence  provided  is  based  on  the  detailed  analysis  by  criterion  in  the  evaluation 
matrix and answers to the evaluation questions documented in Annex III. 

4.1.1.  Effectiveness 

4.1.1.1. Internal market 
The international transport, as presented in Chapter 3, increased its share in the total road 
transport  activity  (national  and  international)  by  15.8  percentage  points  for  freight 
transport47  and  1.8  percentage  points  for  passenger  transport48,  showing  a  progressive 
integration of the road transport market. 

44 National legislation can allow for trucks beyond the 40 t of the Directive in national territory, but those 
trucks are not allowed to cross the border with a gross vehicle weight above 40 t, even when the same 
national rules exist in the neighbouring Member State. 

45 Décret n° 2021-1006 du 29 juillet 2021 relatif aux poids et dimensions des véhicules terrestres à moteur 

et modifiant le code de la route. 
https://www.legifrance.gouv.fr/eli/decret/2021/7/29/TRAT2109942D/jo/texte  

JORF n°0176 du 31 juillet 2021. Texte n° 58. 
46 According to estimations by ArcelorMittal and Tereos.  
47 From a 22.7% in 1995 to 38.5% in 2020 of international transport, including cabotage and cross-trade, 

for the EU27. 

48 From a 16.81% in 2013 to 18.6% in 2019 in the eight Member States for which complete series of data 

on national and international passenger transport by buses and coaches was available. 

24 

 
                                                           
Figure 1515: Transport costs developments 1998-2022. 

Source: Panteia cost developments in the European road haulage sector (1998-2022).49 

While a reduction in road freight transport costs was also expected as a consequence of 
the integration of MS in a border-free internal market, the available data from the period 
1998-2022 in Figure 15 depicting a sample of nine Member States and the UK (see graph 
below) indicates that road transport costs50 have steadily increased during that period for 
the  EU  haulage  sector.  A  steeper  increase  can  be  observed  in  2022,  which  can  be 
attributed to  the dynamic demand  with  the reopening of the post-Covid  economies,  the 
rising  fuel  prices,  the  pressure  on  capacities  and  the  driver  shortages,  exacerbated  by 
Russia’s invasion of Ukraine.51 

Transport costs are strongly influenced by a range of economic circumstances external to 
the regulatory framework: economic growth and economic crisis, inflation, variations in 
fuel prices and in labour costs, as well as geopolitical events. 

Despite the expected higher level of regulatory harmonisation that the Directive promised 
to  bring,  the  patchwork  of  national  and  bilateral  derogations,  administrative,  technical 
and  safety  requirements  regarding  the  operations  by  heavier  and/or  longer  vehicles  has 
emerged. Member States, to improve efficiency, have exploited all possibilities given by 
the  Directive  to  allow  increased  weights  and  dimensions,  which  was  done  in  an 
uncoordinated  manner.  This  has  resulted  in  a  complex  regulatory  framework  of  rules, 
differing  in  content  and  in  scope  at  all  geographical  levels  (international,  bilateral,  and 
national),  which  counters  the  positive  effects  of  the  pursued  simplification  and 
harmonization  by  the  EU  Directive  and  hampers  the  well-functioning  of  the  internal 
market. 

49 The freight cost index elaborated by Panteia is obtained from surveys to road transport operators carried 

out on a yearly basis. 

50 Transport costs include capital, labour, fuel, taxes, operational, maintenance and insurance costs. 
51 IRU newsletter “European road freight rates index up 4.3 point sin Q1, hitting a new record”, 28 April 
2022, and “European Road Freight Rate Benchmark Q4 2022: Spot index down 2.4 points in Q4, first 
fall since Q1 2020”, 8 February 2023. 

25 

 
 
                                                           
The results of the OPC revealed that those who benefit from national derogations within 
and between Member States (based on bilateral agreements or broad interpretation of the 
Directive)  consider  the  Directive  effective  in  ensuring  the  free  movement  of  goods. 
Those  respondents  compose  the  majority  of  all  who  responded,  namely  70  out  of  124 
respondents, where 63 out of those 70 representing so-called “allowing Member States” 
(i.e.,  MS  that  make  use  of  the  national  derogations  to  allow  higher  weight/dimension 
limits than those set in the Directive). Only 19 respondents consider that the intervention 
was ineffective, where 9 of those were from allowing Member States. The main barriers 
to  the  free  movement  of  goods  alleged  by  the  respondents  that  consider  the  Directive 
ineffective were precisely the fragmentation of the rules and the barriers to cross-border 
transport of heavier or longer HDV. This is considered as a lost opportunity to reduce the 
number of trips by road transport and the externalities linked to it, as well as to improve 
road transport efficiency. One of the most recurrent issues raised by stakeholders during 
the  consultation  activities  is  that,  while  HDVs  are  allowed  to  circulate  at  a  maximum 
gross  weight  of  44  t  in  national  transport  in  11  Member  States52,  the  cross-border 
transport  by  those  vehicles  among  those  Member  States  is  not  possible  (except  for  the 
Benelux), leading to unnecessary efficiency losses and environmental negativities53.  

Fair competition, the key component of the internal market, is negatively affected by the 
diversity  of  rules  resulting  in  legal  uncertainty  and  weak  enforcement,  as  described  in 
Chapter 3. Hauliers operating at the edge of the EU and/or national rules, benefiting from 
their loopholes and ineffective controls, by maximising their load, can gain a substantial 
competitive  advantage  to  the  detriment  of  the  others.  According  to  the  consultation 
activities  among  public  authorities,  exceeding  the  maximum  allowed  masses  and  axle 
loads is the main infraction committed with HDVs.  

4.1.1.2. GHG emissions reduction and energy saving technologies and schemes 

The attempts to improve the energy efficiency of road transport and to reduce the GHG 
emissions via the deployment of alternatively fuelled HDV and improved aerodynamics 
have not brought the expected effects yet.  

The targets suggested in the impact assessment accompanying the legislative proposal to 
amend  the  W&D  Directive  in  201354  advocated  achieving  a  significant  share  of  long-
distance trailers equipped with rear aerodynamic devices (75%) and aerodynamic, 
safer,  and  more  comfortable  cabins  (50%)  by  2030.  However,  due  to  the  delay  in 

52  Belgium,  Czech  Republic,  France,  Greece,  Ireland,  Italy,  Luxembourg,  the  Netherlands,  Portugal, 

Sweden, Denmark and Finland. 

53 This problem has been highlighted very prominently in the Call for Evidence. Out of 224 contributors, 
174  were  companies  and  business  associations,  80%  of  which  demanded  the  allowance  of  44  t  in 
international transport (mainly road transport and logistic operators, truck manufacturers, construction 
businesses,  agricultural  producers  and  chemical  industry),  while  companies  in  the  sector  of  rail  and 
intermodal transport only supported the measure as long as their sectors were the main beneficiaries.  

The  targeted  survey  complements  this  finding.  Respondents  indicated  that  a  strict  application  of  cross-
border rules has in fact hindered the implementation of the internal market, as rules that are valid for 
domestic transport on both sides of a border cannot be applied to cross-border transport. Transport at 
44 tonnes between Belgium and France is often cited by operators as an example. 

54 SWD(2013) 108 final. 

26 

 
                                                           
adoption  of  type-approval  legislation  and  rather  limited  return  on  investment  for  those 
devices,  as  explained  in  Chapter  3,  the  uptake  is  insignificant  putting  at  risk  the 
achievement of targets set for 2030. Technology suppliers and manufacturers confirmed 
that there was no increase in the demand for rear devices, and trucks manufacturers are 
only starting to place aerodynamic cabs in the EU market55.  

Manufacturers have also indicated that their efforts were dedicated to the development of 
alternatively  fuelled powertrains  as their preferred way to  improve energy  efficiency in 
the transport sector56. Yet, the EU truck fleet (> 3.5 t gross vehicle weight) continues to 
be strongly dominated by fossil fuel engines. Freight transport relies predominantly on 
diesel (95.8% of all trucks in the European Union run on diesel) with only  4.1 % of all 
trucks  being  alternatively  fuelled  (including  natural  gas  and  LPG)  and  0.5%  being 
electrically  chargeable  vehicles,  including  zero-emission  vehicles.  Passenger  transport 
appears to make more use of alternative fuels than freight transport vehicles, with 31.2% 
of all fleet being alternatively fuelled.  The figures show an incipient presence of electric 
buses,  both  hybrid  electric  (10.1%%)  and  electrically  chargeable  (10.6%%),  mostly  in 
urban transport. Overall, the uptake of zero-emission vehicles in the HDV market is still 
limited.  This  shows  that  the  Directive  has  not  been  effective  in  deploying  ‘green’ 
powertrains, in particular in the haulage sector.  

The consultation activities reveal that the existing provisions are insufficient to  provide 
equal  conditions  of  competition  to  zero-emission  HDVs  in  freight  sector.  To  reach  the 
same  distance  range  as  a  diesel  vehicle  (or  other  fossil  fuel  vehicles),  zero-emission 
vehicles  typically  have  to  have  a  higher  mass  (battery-electric  trucks)  and/or  volume 
(fuel-cell  electric  trucks).  While  the  W&D  Directive  increases  the  maximum  weight  of 
ZEV with up to 2 extra tonnes, this is not sufficient. Additional weight and axle-weight is 
needed, in particular for long-haul freight transport where batteries need to be bigger and 
heavier.57  Battery-Electric  Vehicles  (BEV)  and  Hydrogen  Fuel-Cell  Vehicles  (HFCV) 
require space to store the batteries and the tanks58 which are commonly installed behind 
the cab. Current rules do not allow for extra length to compensate for the space needed 
for those types of energy storage. This means that investment in such vehicles under the 
current  rules  would  lead  to  the  reduction  of  the  loading  length  capacity  of  the  vehicle 
combination,  or  the  reduction  of  the  space  inside  the  cabin.  In  the  first  case,  the 
competitiveness  of  these  HDVs  is  affected  as  they  could  not  offer  the  same  payload 
capacity as an Internal Combustion Engine (ICE) truck. In the second case, the driver’s 
comfort pursued via the introduction of new elongated cabs might be negatively affected.  

The  measures  introduced  by  Directive  (EU)  2015/719  to  support  intermodal  transport, 
transported  as  part  of  a 
aimed  at  doubling 

the  use  of  45-foot  containers 

55 The  first  and  only  aerodynamic  cab  was  placed  on  the  market  on  9 June  2021:  Next Generation  DAF 

truck launched on the 9th June 2021. https://youtu.be/4wLUrs4 tmQE  

56 COWI, TRT, 2021. 
57 ACEA position paper on the “Review of the Weights & Dimensions”, December 2022. 
58 ACEA position paper on the “Revision of the Weights & Dimensions”, 1 Feb 2021. 

27 

 
                                                           
combined/intermodal transport operation; by 2030, 75 % of the containers transported 
over more than 300 km inside the EU should use at least two modes of transport59.  

The use of 45-foot containers and swap bodies has increased during the evaluation period 
as they are considered the most efficient cargo units for intermodal transport. According 
to  the  2014  Combined  Transport60  report  (UIC,  2014)  transport  of  45-foot  containers 
represents  1%  of  domestic  combined  transport  and  3%  of  international  combined 
transport.  By  2017,  according  to  2018  publications  (BSL,  UIC,  2019)  the  percentage 
grew  to  10%  and  11%  in  national  and  international  combined  transport,  respectively. 
Two  years  later  (UIRR,  UIC,  2020),  45-foot  containers  represented  12%  of  the  market 
(domestic/international  combined).  This  major  increase  around  2015  suggests  that  the 
W&D  Directive  contributed  to  the  growth  of  intermodal  containerised  transport.  The 
2020  Combined  Transport  Report  also  informs  that  international  combined  transport 
grows at a higher pace than domestic. While there are no figures available about the road 
legs  that  cross  borders  within  combined  transport  operations  the  higher  growth  in 
international operations could suggest that the Directive has contributed to it.  

The  modal  shift  potential61  of  the  EU  transport  system  for  transferring  long-distance 
transport of containers from road to other more sustainable modes of transport has shown 
the  reduction  in  the  number  of  containers  and  swap  bodies  transported  by  road  over 
distances above 300km in favour of rail or water-based transport, by 7.6% for the period 
between  201762  and  202163,  i.e.  developing  from  42,561  million  container-tonne 
kilometres in 2017 to 39,295 million containers-tonne kilometres in 2020 for the EU27. 
This modal shift accounts for 3,266 million tonne kilometres. The modal shift potential, 
however,  still  represents  a  40.5%  of  the  total  in  2020  for  the  EU27  (42.1%  in  2017)64. 
This development suggests that the amendments introduced by Directive 2015/719 have 
contributed to facilitating the growth of intermodal transport operations. Enabling the use 
of  standard  45-foot  containers  and  swap  bodies  was  highly  welcomed  by  the  market 

59 Rules related to intermodal transport of 45-foot containers only produce effects from 07.05.2017 (data of 

transposition of Directive (EU) 2015/719). 

60 The  W&D  Directive  targets  intermodal  transport,  whereas  the  Combined  Transport  reports  only  cover 
combined transport, which is a (large) submarket of intermodal transport. The difference between the 
two is that in combined transport, the  main leg is done by rail or inland waterways and the pre- and 
post-haulage  by  road  is  restricted  to  the  shortest  distance  to  an  intermodal  terminal.  There  are  also 
minimum  distances  for  the  rail/IWW  leg  and  maximum  distances  for  the  road  legs  for  intermodal 
transport  to  be  classified  as  combined  transport.  However,  there  is  a  strong  correlation  between  the 
volumes  of  both.  Eurostat  does  not  contain  figures  for  combined  transport  volumes,  but  only  for 
intermodal transport. 

61 The  modal shift potential  is  an indicator elaborated by Eurostat that relates  the  transport of containers 
over  longer  distances  (more  than  300  kilometres)  to  total  road  Intermodal  Transport  Unit  (ITU) 
transport  and  to  total  road  goods  transport,  providing  information  for  analysis  of  the  potential  for 
transferring  such  long-distance  transport  of  containers  from  road  to  other  modes  of  transport.  This 
indicator  does  not  take  into  account  other  elements,  such  as  the  respective  road,  rail  or  inland 
waterways infrastructure or capacity limitations.  Eurostat  Modal shift potential of long-distance road 
freight in containers - tonne-kilometre. 

62 The provisions of Directive (EU) 2015/719 aimed at promoting intermodal transport were applicable as 

from 7 May 2017. 

63 From 42 561 million container-tonne kilometre in 2017 to 39 295 million containers-tonne kilometre in 

2020 for the EU27. 

64 Eurostat. Modal shift potential of long-distance road freight in containers - tonne-kilometre. 

28 

 
                                                           
operators, signalling that the use of large containers (45-foot and high-cube containers) 
will increase their market share gradually of containerised transport in the future.  

Article  4.5  of  the  W&D  Directive  allowed  Member  States  to  conduct  local  trials  with 
HDV  incorporating  new  technologies  or  new  concepts  and  which  cannot  comply  with 
one  or  more  technical  standards  of  this  Directive.  This  possibility  was  used  so  far  by 
seven Member States65 who started national trials with EMS using them for commercial 
operations on dedicated routes. The trials have been successful and after the assessment 
of  their  impacts  in  terms  of  operational  efficiency,  environmental  impacts,  road  safety, 
infrastructure investments and increasing sustainability of transport as a whole, all those 
Member States have either renewed their trials or taken them further allowing increased 
capacity (in length and weight) and/or allowing the cross-border transport of EMS based 
on bilateral agreements. 

According to COWI, TRT, 2021 the use of EMS, both as part of trials and as generally 
authorised  in  Finland  and  Sweden,  accounts  for  €2.5  billion  in  operation  costs  savings 
(mainly linked to the reduction in labour costs due to less drivers needed for carrying the 
same  amount  of  cargo)  and  €93  million  in  external  costs  savings  (around  900,000  t  of 
CO2) in 2018.  

Figure 16: Ratio of potential savings of EMS as compared to standard trucks 

One of the most cited sources of information to quantify the potential savings of EMS is 
the study Cider L, Larsson L, HCT DUO2-project Gothenburg-Malmö in Sweden, 2019. 
The potential savings are based on the ratio of standard trucks that could be replaced by 
longer EMS. According to the HCT DUO2-project study the number of standard trucks 
can be replaced by HCVs at a ratio of 3:2 (for 25.25m long - EMS1) or 2:1 (for 32m long 

65 EMS trials in Denmark, Netherlands, Belgium, Spain, Portugal, Czech Republic, Germany. 

29 

 
 
                                                           
-  EMS2),  which  thus  gives  the  ratio  of  vehicle  kilometres  needed  to  move  the  same 
amount of goods (i.e., the number of tonne-kilometres remains unchanged). 

Figure  16  demonstrates  how  these  systems  (EMS1  and  EMS2)  may  contribute  to 
transport  efficiency  by  reductions  in  diesel  use,  CO2  emissions,  road  use,  and  drivers 
required. 

The reduction in the number of trucks needed to move the same amount of cargo can also 
be exemplified using a calculation of the number of pallets that can be accommodated by 
a standard 18.75 m vehicles and a 25.25 m HCV. The HCV can load 50 pallets, whereas 
the standard vehicle can carry only 32 pallets. This also corresponds to a 3:2 reduction in 
the number of trips that must be undertaken to move the same number of pallets. 

It can be concluded that these derogation possibilities provided under the Directive, were 
effective  in  increasing  operational  and  energy  efficiency  of  road  transport  operations, 
although  these  gains  were  limited  to  nine66  Member  States  where  the  derogations  were 
put in use.  

The increase of HDV payload, and in particular the authorisation of EMS, have triggered 
concerns of reverse modal shift. It was considered by some Member States and part of 
the  industry  that  a  more  efficient  road  transport  would  lead  to  more  competitive  prices 
and,  therefore,  to  an  undesired  shift  of  freight  transport  from  more  sustainable  modes, 
such  as  rail  and  inland  waterways,  resulting  in  overall  increase  of  the  environmental 
externalities of transport as a whole. However, the results of trials and experiences with 
EMS  in  several  Member  States  disprove  those  allegations.  The  evolution  of  the  modal 
shift  potential  (MSP)  illustrated  in  Figure  17  during  the  period  2010-2020  shows  very 
similar favourable reductions in this indicator between those Member States that do not 
allow  any  excesses  in  weights  and  dimensions  of  HDV67  (-13.5%)  and  those  allowing 
EMS  and/or  additional  weight  for  standard  HDV68  (-13.3%).  When  analysing  the 
evolution  in  5-years  periods  the  results  confirm  that  while  the  first  group  of  Member 
States improved more between 2010 and 2015 (-11.2% as compared to -10%), Member 
States allowing EMS reduced their MSP more significantly in the second period (-3.6%) 
than those of the first category (-2.5%). Given the fact that the penetration of EMS and 
its use in national and cross-border transport have increased in the last years, it suggests 
at least that they do not induce modal shift from other modes of transport.  

66 7 MS with trials plus Finland and Sweden 
67  These  are  Austria,  Bulgaria,  Greece,  Croatia,  Latvia,  Lithuania,  Hungary,  Poland,  Romania,  Slovenia, 
and  Slovakia.  Data  from  Greece,  Croatia,  Latvia,  and  Poland  is  partial,  but  it  has  been  considered 
given that the data is presented in percentages. Although Malta and Cyprus have not adopted national 
derogations, there is no data from them, thus they have not been considered. 

68 These are: Belgium, the Netherlands, Sweden, Finland, Czech Republic, Germany, Spain, Portugal, and 

Denmark. 

30 

 
 
 
  
                                                           
Figure 1717: Evolution of average modal shift potential during the period 2010-2020.    

70
60
50
40
30
20
10
0

)

%

(

l
a
i
t
n
e
t
o
P
t
f
i
h
S
l
a
d
o
M

2010

2011

2012

2013

2014

2015
Year

2016

2017

2018

2019

2020

MS with no derogations

MS allowing EMS

Source: Eurostat data on modal shift potential; own calculations. 

4.1.1.3. Road safety and protection of the infrastructure  
It is not possible to estimate to what extent the Directive has contributed to the positive 
evolution of road safety in the last 25 years. Road safety is sensitive to economic growth 
that impacts mobility patterns and volumes. It has been addressed by many European and 
national  safety  initiatives  and  long-term  policies,  including  the  most  recent  EU  Road 
Safety Policy Framework 2021-2030 aiming at realising the “Vision Zero”69 in the EU. In 
addition, the human error is traditionally considered as the main factor in the production 
of accidents over the vehicle and infrastructure failure, so it has been more prominently 
analysed and addressed by national interventions.  

The  amendments  adopted  in  2015  to  allow  the  introduction  of  aerodynamic  cabs, 
required those cabs to be safer and provide more space for drivers. New cab profiles were 
estimated  to  contribute  to  improve  road  safety  by  reducing  blind  spots  in  the  driver’s 
vision,  including  those  under  the  windscreen,  and  incorporating  energy  absorption 
structures  in  the  event  of  a  collision.  It  was  estimated  that  changing  the  cabin  design 
could save 300 to 500 lives per year, i.e., a reduction of 10% of the current fatalities in 
accidents involving trucks. As the new cabs have only started to enter the EU market, the 
safety impacts linked to them have not brought any effects yet. 

During the OPC, 57 out of 122 respondents considered the Directive effective in ensuring 
road safety, while 26 considered it ineffective. 

69  Vision  Zero  is  a  philosophy  of  road  safety  that  eventually  no  one  will  be  killed  or  seriously  injured 

within the road transport system. 

31 

20102011201220132014201520162017201820192020MSP (%)66.39    58.64    59.18    57.76  56.19 58.93   54.96  58.88    54.39 52.77   57.44     Annual change (%)-11.670.93-2.40-2.734.88-6.737.13-7.63-2.978.85Change every 5 years (%)-11.24-2.52Change 2010-2010 (%)-13.47MSP (%)45.10    44.28    43.40    43.51  42.39 40.60   40.77  40.29    37.04 37.67   39.12     Annual change (%)-1.81-1.990.26-2.59-4.210.42-1.19-8.051.703.84Change every 5 years (%)-9.98-3.65Change 2010-2010 (%)-13.27MS with no derogationsMS allowign EMSModal shift potential (MSP) 
 
 
                                                           
 
 
 
4.1.1.4. Enforcement of the rules of weights and dimensions  

As  a  consequence  of  the  introduction  of  automatic  systems  to  identify  those  HDV  that 
were likely to circulate exceeding the maximum weight and axle weight, Directive (EU) 
2015/719  was  expected  “to  increase  the  effectiveness  of  manual  checks,  understood  as 
the  amount  of  infringements  /  number  of  checks.  Such  an  increase  will  improve  the 
reliability of checks and at the same time avoid annually 100,000 unnecessary checks by 
2020”.70 

According  to  the  available  data  on  the  results  of  controls  carried  out  in  2019-202071, 
important  differences  are  observed  in  the  efficiency  of  controls  measured  as  the 
percentage of infractions detected per controls carried out. Overall, 3.3% of the vehicles 
or  vehicle  combinations  controlled  were  overloaded.  This  percentage  varies  from 
4.9% in 2019 to 2.5% in 2020, which could suggest, given the similar number of controls 
performed in those two years, that controls are less effective in some Member States than 
in others; it could however also be linked to a higher level of compliance with the weight 
rules. The figures on controls and their effectiveness vary greatly among Member States. 
There are many other circumstances, such as the locations, days and times chosen for the 
roadside controls and the experience/training of the enforcement officers performing the 
controls that can significantly influence the effectiveness of such controls, according to 
the information provided by the Member States. As an example of the variations among 
Member States,  Estonia  reports 2,166 infractions  detected out of  2,929 controls  carried 
out  (72.2%  effectiveness),  while  Poland  reports  7,217  infractions  detected  out  of 
3,050,851 controls carried out (0.2% effectiveness). 

Given that WIM systems were be implemented in all Member States from 27 May 2021, 
future data analysis and comparison with the current sets of data will be crucial to draw 
conclusions on the performance and efficiency of these automatic systems, in particular 
where automatic detection systems were not in use before May 2021. 

4.1.2.  Efficiency  

The analysis of efficiency of the W&D Directive has been performed by comparing the 
costs of implementing the Directive with the benefits it provides (cost-benefit analysis).  

The costs produced by the Directive can be divided into the following categories72: 

-  Adjustment  costs:  These  include  the  costs  incurred  to  adjust  stakeholder 
activities to the requirements of the Directive. These costs are borne partially by 
operators who need to adjust their business models to the rules (EU and national) 
and  partially  by  road  infrastructure  managers  to  adjust  the  development  and 
maintenance costs of roads that are used for operations by heavier HDVs. 

70 SWD(2013) 108 final. 
71 Article 10g of the W&D Directive requires Member States to report to the Commission every two years 
the number of checks carried out in the previous two years and the number of overloaded vehicles or 
vehicle  combinations  detected.  As  indicated  in  chapter  3,  only  seventeen  Member  States  have  provided 
information for the reporting periods 2017-2018 and nineteen MS for 2019-2020. 

72 As defined in the Better Regulation Toolbox: Tool #56 Typology of costs and benefits. 

32 

 
                                                           
-  Administrative  costs:  These  are  costs  borne  as  a  result  of  administrative 
activities  performed  to  comply  with  administrative  obligations  included  in  legal 
rules,  e.g.,  costs  of  transposition  by  Member  States  who  need  to  adapt  their 
national  acquis  to  incorporate  the  EU  rules.  Costs  of  obtaining  national  permits 
for abnormal transport/indivisible load are borne partially by operators who have 
to  apply,  provide  forms  and  prove  compliance  with  all  requirements  of  the 
authorisation,  and  partially  by  authorising  authorities  who  create 
the 
requirements, forms and procedures and verify the applications. 

-  Enforcement costs: These are costs of activities linked to the implementation of 
an  initiative  such  as  monitoring,  verification,  and  prosecution.  They  are  borne 
mainly by public authorities and concern mainly costs of roadside inspections and 
of  installation  WIMs  in  the  road  infrastructure.  Road  operators  also  bear  some 
costs  related  to  enforcement,  including  costs  of  time  lost  during  roadside 
inspections or costs of non-compliance.  

Member  States  and  infrastructure  managers  supported  the  adjustment  costs  of  a  higher 
wear  and  tear  (maintenance  costs)  of  the  road  infrastructure  and  the  reinforcement  of 
engineering  structures  linked  to  the  extra  weight  of  low-emission  and  zero-emission 
HDV  and  of  HDV  involved  in  intermodal  transport.  These  costs  were  limited  to  the 
Member States that authorise heavier vehicles in national transport, mitigated by the fact 
that  no  extra  axle-weight  was  allowed.  (Breemersch  et  al.,  2021)  reported  on  a  study 
performed by Cluster et. al. which estimated that a 10% increase in the maximum total 
weight (i.e., 44t instead of 40t on 5-axle HDVs) with a market share of 25% would lead 
to  an  annual  additional  pavement  maintenance  cost  of  EUR  1.7  billion  in  the  EU-27, 
representing an increase of just over 10%.  The similar increase in  maintenance costs is 
linked with the circulation by overloaded vehicles due to weak enforcement. According 
to a study from CE Delft (CE Delft, 2019), the EU-28 spent about EUR 38 billion on the 
operation and maintenance of their road networks, which was slightly lower than in 1995.  

Some  Member  States  assessed  the  infrastructure  investments  necessary  to  allow  the 
circulation of EMS in their network. According to (COWI, TRT, 2021), in Denmark, the 
costs  of  adapting  the  infrastructure  (some  roundabouts  and  intersections  leading  to  and 
from ports and other terminals) amounted to approximately EUR 20 million. A German 
study indicated even lower adaptation costs of EUR 4-to 8 million, which was mainly for 
strengthening bridges and expanding parking areas. However, Rapp (2011) calculated the 
costs of adapting the national road network in Switzerland to accommodate HCVs of up 
to 60 tons. The assessment led to significantly higher costs in the range of EUR 144 to 
450 million. Most of the costs went to the reinforcement of bridges.  

As  regards  enforcement  costs,  Member  States  were  faced  with  those  related  to  the 
installation  of  WIM  systems  to  detect  overloaded  HDV  and  to  the  performance  of 
controls.  Prices  from  technology  providers  are  in  the  range  of  120,000  €  for  a  double 
carriageway road and 60,000€ for a single lane. The lack of information on the number of 
systems deployed in every Member State does not allow to quantity the costs incurred.  

33 

 
No Member State opted for the alternative equipment of vehicles with on-board weighing 
(OBW)  equipment,  where  the  costs  of  installation  would  have  been  shared  between 
manufacturers, transport operators and public authorities (costs related to  motor vehicle 
and trailer units,  for the remote early detection communication reader, certification and 
periodic inspection of the systems as required by Commission Implementing Regulation 
(EU)  2019/121373).  In  order  to  choose  between  the  two  options  some  Member  States 
conducted cost-benefit analysis of the different options showing a clear recommendation 
for systems  installed in  the road infrastructure over OBW for reasons  of  societal  costs, 
transport  efficiency,  fair  competition  and  technology  uncertainties.  The  Swedish 
Transport  Agency  concluded  in  2020  that  mandating  OBW  systems  have  greater  costs 
than  the  expected  benefits  (societal  economic  cost  of  SEK  7.8  billion)74.  This  is  also 
confirmed by truck manufacturers which resort to alternative systems of mass estimation 
for HDV equipped with automatic gear shifting to facilitate information to the transport 
operators at  a much lower cost. One Member State referred to extra costs linked to the 
performance of roadside inspections and to the IT systems linked to the authorisation of 
indivisible and abnormal transport. However, no quantification was provided.  

The costs for authorities and the level of administrative burden arising from the Directive 
are rather limited and appear to be justified by the benefits yielded in implementing the 
internal  market,  improving  the  environmental  performance  of  road  transport,  and 
ensuring  road  safety.  Eight  Member  State  authorities  (out  of  14  interviewed)  indicated 
that no change associated with costs have been observed.  

Road  transport  operators  bear  the  cost  of  requesting  and  obtaining  national  permits  as 
well as of complying with the conditions imposed to abnormal transport and the transport 
of indivisible loads. It must be noted, however, that such conditions were not modified or 
affected by the W&D Directive. While transport operators would be faced with the costs 
of acquiring aerodynamic devices and aerodynamic safer cabs, as well as benefiting from 
their potential of energy savings, these effects did not materialise due to lack of uptake of 
the  new  technologies.  Operators  also  faced  indirect  costs  from  delays  due  to  more 
checks/controls, which, based on anecdotal evidence from the survey, could take “a few 
days per truck”. No costs were referred by the rail or intermodal operators nor by truck 
manufacturers. 

The initiative did not impose administrative burden on citizens.  

The benefits of the Directive are related to increase in transport efficiency, reductions 
in  emissions  of  GHG  and  air  pollutants,  energy  consumption,  traffic  congestion, 
HDV-related  accidents,  and  in  road  maintenance  costs  due  to  less  damage  to 
infrastructure as well as mitigation of the shortage of drivers. Many of these benefits 
are attributed  mainly  to  the authorisation  of operations  by  heavier  and/or longer  HDVs 
allowing to reduce the number of trips necessary for the transport of a given amount of 

73 Commission Implementing Regulation (EU) 2019/1213 of 12 July 2019 laying down detailed provisions 
ensuring uniform conditions for the implementation of interoperability and compatibility of on-board 
weighing equipment pursuant to Council Directive 96/53/EC (OJ L 192, 18.7.2019, p. 1–22). 

74 “Scales in the infrastructure or in the vehicles?”. 

34 

 
                                                           
goods, involving less but more experienced drivers (in particular, in operations by EMS), 
encouraging the renewal of the fleet equipped with most recent safety features and using 
the dedicated part of the road network.  

The  benefits  perceived  by  Member  States  and  operators  making  use  of  national 
derogations or trials with EMS, point to the reduction in energy consumption in the range 
of  15-30%  on  average  and  the  reduction  of  the  demand  for  long-haul  drivers  by  one-
third.75 76   

During  the  consultation  activities  vehicle  manufacturers,  operators,  and  other  road 
transport stakeholders  signalled additional  environmental  positive impacts linked to  the 
use  of  new  technologies  and  the  mass  allowance  of  2  extra  tonnes  for  zero  emission 
HDV.  One  Member  State  considered  that  the  higher  infrastructure  costs  (higher 
maintenance  costs  for  repair  work  on  bridges  and  road  surfaces)  outweigh  the  positive 
impacts of (heavier) zero-emission vehicles.  

Due to the lack of data, it was not possible to quantify the costs and the benefits so that 
they can be compared mathematically. The qualitative analysis shows that the Directive 
was only partially efficient in achieving its objectives. On the one hand, by establishing 
uniform  safe  weights  and  dimensions  limits  for  HDVs,  the  Directive  has  improved 
efficiency  in  cross-border  road  transport  operations  and  prevented  distortions  of 
competition and risks to road safety. On the other hand, the legislative loopholes in the 
Directive  and  numerous  possibilities  for  national  derogations  brought  inefficiencies  as 
regards  cross-border  traffic  by  heavier/longer  vehicles  and  limited  competitiveness  of 
hauliers  in  Member  States.  For  instance,  hauliers  involved  in  intermodal  operations 
where disadvantaged in Member States allowing 44t HDVs for road-only operations, and 
hauliers  from  Member  States  not  allowing  any  weight/length  excesses  were 

75 According to the Finish Transport traffic volume would be 64% higher without the use of EMS, 10.000 
additional drivers would be needed and GHG emission would increase by around 17%. The Swedish 
Transport Administration refers an overall reduction of energy consumption in the range of 4-6% (up 
to  30%  for  each  transport)  and  socioeconomic  benefits  in  the  range  of  1-1.4  billion  euros.  The 
conclusions  form  the  studies  conducted  by  the  Ministry  of  Transport,  Public  Works  and  Water 
Management in the Netherlands [“Longer and Heavier Vehicles in the Netherlands Facts, figures and 
experiences in the period 1995-2010” and “Monitoring Modal Shift Longer and heavier vehicles. The 
follow-up  measurement  (2011)”]  concluded  that  road  safety  was  not  negatively  affected  (no  major 
accidents during the period 2004-2006 and eleven accidents from 2007 to mid-2009 only with material 
damage),  that  “CO2-emissions  per  transported  tonne  can  be  lowered  by  11%  based  on  a 
transportation distance of more than 150 km, that NOx-emissions can be reduced by 14%”, “that no 
reverse modal shift effects have occurred (by the introduction of longer and heavier vehicles or EMS) 
and these effects will not occur within the foreseeable future either”. The main findings published by 
the German Federal Highway Research Institute after the first 5-year trial (2012-2016) with EMS that 
were  allowed  to  be  longer,  but  not  heavier  were  that  “2  long  truck  trips  replace  3  trips  with 
conventional trucks; energy gains and fuel savings between 15-25%; no increased maintenance costs 
for the infrastructure; and no shifting effects from rail to road”. (Liimatainen, Pöllanen, & Nykänen, 
2020) reports that the due to the use of high-capacity vehicles or EMS in Finland “225 million km has 
been avoided from October 2013 until the end of 2017 (…) which equals around EUR 126  million in 
cost savings in 2017 and 0.1 Mt of CO2 emissions reduction in road freight”. Similarly, two (out of 
seven)  infrastructure  managers  mentioned  positive  impacts  linked  to  “higher  volume  and  masses  for 
more effective and CO2 friendly transport”. 

76 The Danish Transport and Logistics Association (DTL) refer an overall reduction of CO2 emissions in 

Denmark of 1% linked to the use of EMS. 

35 

 
                                                           
disadvantaged compared with hauliers from allowing MS who could use heavier/longer 
vehicles in cross-border operations based on bilateral agreements.  

Most  stakeholders  that  replied  to  the  question  on  efficiency  within  the  OPC  do  not 
consider  that  the  Directive  has  been  efficient  in  pursuing  its  objectives.  54  out  of  123 
respondents  considered  that  the  costs  caused  by  the  Directive  outweigh  the  benefits, 
while  46  had  not  witnessed  significant  costs  or  considered  the  costs  to  be  reasonable. 
This proportion has been generally observed across all the categories of stakeholders that 
participated  in  the  consultations.  The  costs  may  include  but  were  not  limited  to 
installation/maintenance/certification  of  weight  in  motion  systems,  administrative  costs 
of national permits for transporting indivisible loads,  and installation/maintenance costs 
for aerodynamic devices). 

Figure 18: Results of open public consultation as regards to costs caused by the 
Directive’s application (Q13: What do you think about the costs caused by the 
application of the Directive?). 

27

35

19

27

15

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Costs are reasonable and proportional to the benefits

Costs significantly outweigh the benefits

Costs slightly outweigh the benefits

I don’t know

I have not witnessed significant costs

Source: TML, Ramboll (2023), Evaluation support study, based on open public consultation results. 

Potential to reduce inefficiencies 

Restrictions to cross-border transport of heavier and/or longer HDV was considered the 
main source of inefficiencies and unnecessary costs by road transport operators, shippers, 
and  producers.  In  particular,  the  limitation  of  cross-border  transport  to  40-tonnes-HDV 
between Member States that allow 44 t-HDV nationally was prominently signalled in all 
consultation activities. As an example, 80% of the companies and business associations 
contributing to the Call for Evidence77 demanded the allowance of 44 t in  international 
transport (mainly road transport and logistic operators, truck manufacturers, construction 
businesses, agricultural producers and chemical industry). Some of them indicated that if 
cross-border  transport  of  44  t-HDV  was  allowed  between  France  and  Belgium78,  the 
volume of trucks would be reduced by 11-12%.  

77  A  call  for  evidence  was  open  for  feedback  from  1  January  2022  to  21  February  2022:  Commercial 
vehicles  –  weights  and  dimensions  (evaluation)  (europa.eu).  The  Call  for  Evidence  gathered  224 
contributions, out of which 174 of the respondents were companies and business associations. 

78 ArcelorMittal, Tereos, among others. 

36 

 
 
 
                                                           
Similarly, the lack of harmonisation  at  EU level  of rules on the  maximum  overhang of 
loads is estimated to increase the environmental impact on the market of vehicle carriers 
in more than 1.12 million t of CO2 annually.79 

Figure 19: Results of open public consultation as regards to cost reduction ability (Q14: 
Do you think it is possible to reduce costs caused by the Directive?). 

46

33

43

0%

10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Source: TML, Ramboll (2023) Evaluation support study, based on open public consultation results. 

Yes

No

I don't know

According  to  the  European  association  of  abnormal  road  transport  and  mobile  cranes 
(ESTA), operators are forced to comply with diverging national rules, procedures and 
requirements  to  obtain  national  permits.  Seven  respondents  to  the  OPC  (one  trade 
union, one environmental organisation and five business associations) considered that a 
simplification  of  the  procedures  around  abnormal  transport  would  reduce  costs  and 
improve  the  efficiency  of  abnormal  transport.  While  cost  analysis  differ  in  the 
quantification of the losses,80 they agree on the fact that harmonisation of procedures and 
rules would bring important economic benefits  to  the sector. The results from  the OPC 
indicate that 46 respondents out of 122 saw that there are possibilities to reduce the costs, 
while 33 did not, as shown in Figure 19. 

The stakeholders see the possibilities to reduce costs through: 

1)  harmonisation of the rules, especially for exceptional transport, 

2)  simplification of administrative procedures by digitalisation, 

3)  increase  of  the  use  of  high-capacity  vehicles  to  optimise  the  loading  capacity, 

reduce fuel consumption and emissions, 

4)  allowing bilateral  agreements for cross-border transport with HDV exceeding in 

weights and dimensions.  

4.1.3.  Coherence 

The  analysis  has  revealed  certain  internal  inconsistencies  among  the  provisions  of  the 
W&D  Directive.  These  are  mainly  due  to  that  the  Directive  tries  to  balance  various 

79  According  to  the  study  commissioned  by  the  Association  of  European  Vehicles  Logistics  (ECG)  to 

Friends of the Earth, Italy. ECG Paper on loaded length of vehicle transporters. 

80 ESTA conducted an Economic Impact Assessment in 2011 and concluded that, if all recommendations 
of the European Best Practice Guidelines for Abnormal Road Transports were followed, particularly in 
terms of simplification and harmonisation of the rules and procedures to obtain the special permits, the 
savings  could  amount  to  €800  million  every  year.  This  amount  was  desegregated  as  follows:  1) 
Efficiency  improvement:  €  50  million;  2)  Corridors:  €  30  million;  3)  Introduction  of  SERT:  €  270 
million; 4) Private escorts replacing police effort: € 450 million. A more conservative figure of €45.3 
million per year was estimated by COWI, TRT, 2021. 

37 

 
 
 
 
 
                                                           
objectives  pursued  simultaneously  as  well  as  recognise  differences  between  Member 
States as regards infrastructure standards and operational conditions.  

While the uniform limits for weights and dimensions contribute to harmonisation of the 
rules  and  deepening  the  internal  market,  the  numerous  possibilities  for  national 
derogations  and  diverging  interpretations  of  the  Directive  result  in  a  patchwork  of 
different national and EU requirements leading to fragmentation of the market. Similarly, 
the  possibility  given  by  the  Directive  to  Member  States  to  allow  heavier  vehicles  in 
national  transport  undermine  the  Directive’s  provision  allowing  extra  4  tonnes  to 
compensate the weight of empty container (to avoid loss of payload), aiming to promote 
the  intermodal  operations.  During  the  stakeholder  consultation,  the  respondents  mainly 
pointed towards contradictions between the different national rules across the EU and to 
the  complexity  of  the  overall  legal  framework.  They  consider  that,  as  a  result  of 
excessive  scope  for  domestic  deviations,  the  W&D  Directive  does  not  achieve  a 
sufficient level of harmonisation across the EU.  

In  terms  of  external  coherence,  the  Directive  is  generally  coherent  with  other  EU 
legislation and EU policies in the field of internal market, sustainability of transport and 
road  safety.  In  particular,  multiple  EU  legal  acts  relate  to  the  objectives  of  the  W&D 
Directive.  The  Combined  Transport  Directive81  (CTD),  with  its  main  objective  to 
facilitate an increase in the share of rail, short sea shipping and inland waterways in total 
freight transport in order to contribute to reducing GHG emissions and other externalities 
from transport such as congestion and accidents. Moreover, the W&D Directive, through 
the  specific  weight  and  dimension  allowances,  also  promotes  the  uptake  of  energy 
efficient solutions  and provides additional support to  combined/intermodal  transport by 
eliminating the disadvantages of the road legs of HDV involved in intermodal transport 
operations in terms of loading capacity and compatibility of the intermodal loading units 
with rail transport.  

However, one external incoherence has been identified during the evaluation. The scope 
of the W&D Directive as regards the provisions applicable to intermodal transport is not 
fully  aligned with  the scope of the CTD,  as the  W&D Directive focuses  on intermodal 
“containerised” transport. While this is a consequence of the particular needs in terms of 
weights  and  dimensions  of  the  HDV  transporting  containers  or  swap  bodies,  the  other 
types  of  transport  loading  units  used  in  combined  transport,  such  as  trailers  and 
semitrailers,  do  not  fall  under  the  definition  of  intermodal  operation  under  the  W&D 
Directive. A better alignment with the scope of the Combined Transport Directive would 
support  the  whole  range  of  intermodal  transport  operations,  such  as  the  transport  of 
semitrailer and HDVs themselves.   

81  Council  Directive  92/106/EEC  of  7  December  1992 on  the  establishment  of  common  rules  for  certain 
types  of  combined  transport  of  goods  between  Member  States  (OJ  L  368,  17.12.1992,  p.  38–42). 
Consolidated version available at EUR-Lex - 01992L0106-20130701 - EN - EUR-Lex (europa.eu). 

38 

 
                                                           
The  HDV  CO2  Emission  Standards  Regulation82  addresses  the  supply  of  more  fuel-
efficient  heavy-duty  vehicles,  including  zero-emission  vehicles,  setting  CO2  emissions 
requirements  to  manufacturers  on  their  new  vehicles’  fleets.83  The  measures  envisaged 
by  the  HDV  CO2  Emission  Standards  are  complemented  with  those  envisaged  in  the 
W&D  Directive  targeting  the  demand  side  and  providing  a  level  playing  field  for 
zero/emission HDV (same payload as internal combustion engine HDV).  

The Eurovignette Directive84 addresses the need to internalise road transport’s external 
costs, applying “the polluter pays” and “the user pays” principles and narrowing the gap 
with  other  modes  of  transport.  The  W&D  Directive  provides  a  level  playing  field  for 
zero-emission  road  transport  and  road  legs  that  are  part  of  an  intermodal  transport 
operation as compared to conventional diesel HDV and only-road transport.  

Consultation activities show that stakeholders generally consider the W&D Directive to 
be consistent with other EU policies and international initiatives.  

4.2. How did the EU intervention make a difference? 

The EU added value was recognized when this Directive was adopted and the arguments, 
which substantiate this added value, remain valid. These arguments are predicated upon 
the ever-increasing transnational dimension of road transport sector in the EU. A baseline 
scenario against which to compare the actual performance of the Directive has not been 
defined. However, the analysis of the effectiveness criteria allows to infer to what extent 
the  W&D  Directive  was  of  added  value  in  achieving  its  objectives  compared  to  what 
could have been achieved by Members States at national level and through bilateral and 
international cooperation.  

The Directive provided a level playing field to road transport operators. On the one hand, 
without the intervention, Member States would have been able to discriminate between 
HDV  registered  in  their  territory  and  those  registered  in  another  country85  reducing  the 
attractiveness  of  cabotage  and  negatively  influencing  the  market  forces.  On  the  other 
hand, Member States were free to authorise in national transport HDV exceeding the EU 
standards  set  at  the  time  for  weights  and/or  dimensions  without  any  limitation  without 
having  to  allow  equivalent  EMS.  In  effect,  the  concept  of  EMS  was  born  to  avoid  the 
distortion of competition. Member States could operate larger vehicles and trailers with 

82 Regulation  (EU) 2019/1242, setting  CO2 emission performance  standards for new heavy-duty  vehicles 
and amending Regulations (EC) No 595/2009 and (EU) 2018/956 and Council Directive 96/53/EC (OJ 
L 198, 25.7.2019, p. 202–240). 

83 The legislative proposal for a regulation amending Regulation (EU) 2019/1242 (the HDV CO2 Emission 
Standards  Regulation)  –  COM(2023)88strengthens  the  2030  CO2  emissions  reduction  targets  from 
30% to 45% and proposes new reduction targets: 65% by 2035 and 90% by 2040. For city buses it is 
proposed a 100% zero-emission vehicle mandate on new registrations as from 2030. 

84 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 (OJ L 187, 20.7.1999). Consolidated text in 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01999L0062-20220324  

85  Directive  85/3/ECC  allowed  Member  States  to  prohibit  vehicles  registered  in  another  country  that 
exceeded  the  Directive’s  weights  and  dimensions  despite  those  same  excesses  been  allowed  for 
vehicles registered in their territory. 

39 

 
                                                           
deviating dimensions on their territory if operators from a different Member States could 
compose competitive vehicle combinations with standard European equipment. Without 
this  condition  hauliers  from  another  Member  State,  that  would  not  have  the  necessary 
dedicated equipment, would have been disadvantaged as compared to national hauliers. 
The limitation of this vehicle combinations to standardised units allowed the progressive 
implementation  of  this  new  concept  in  a  harmonised  way,  also  allowing  manufacturers 
and operators benefit from the economies of scale. This has not prevented Member States 
from  imposing  additional  conditions  to  the  circulation  of  EMS  and  some  of  these 
requirements may pose a barrier to international transport. While this has been partially 
solved by  resorting to  bilateral  agreements  for the cross-border transport  of EMS, such 
solution  also  makes  evident  the  need  for  a  European  approach  that  prevents  from  the 
fragmentation of the market for longer and heavier HGV. Given the recent rules adopted 
or  in  the  pipeline  in  several  Member  States,  it  can  be  expected  that  the  lack  of  action 
from the EU would lead to a greater proliferation of diverging rules. 

As  from  2015,  the  sustainability  objective  of  the  W&D  Directive  gained  prominence. 
Without  the  amendments  introduced  by  Directive  (EU)  2015/719,  Regulation  (EU) 
2019/1242 and Decision (EU) 2019/984, complemented by the necessary type-approval 
legal  framework,  it  is  very  unlikely  that  new  aerodynamic  safer  cabs  would  have  been 
placed on the market at all. The W&D Directive supported the intermodal operations in 
two  ways:  by  ensuring  the  compatibility  of  aerodynamic  devices  with  intermodal 
transport  and  by  providing  a  level  playing  field  to  containerised  transport  eliminating 
unnecessary  costs  (chamfered  corners)  and  allowing  equal  payload  (weight  of  empty 
containers  or  swap  bodies).  Although  equal  payload  was  only  fully  guaranteed  for 
international  (intra-EU)  transport,  the  reduction  in  transport  costs  derived  from  it 
contributed  to  the  growth  of  intermodal  transport  at  EU  level.  Moreover,  before  the 
approval  of  Directive  (EU)  2015/719,  no  Member  State  had  adopted  compensatory 
measures for the loss payload of containerised transport and, among the Member States 
that  have  reduced  the  effectiveness  of  the  Directive  by  raising  their  weight  limits  in 
national transport, only one has adopted compensatory measures86.  

The opinions gathered during the open public consultation support that the Directive is of 
high value added to the achievement of its objectives, in particular as regards the well-
functioning of the internal market and the sustainability of road transport, as presented in 
Figure 20.  

86 France adopted Décret n° 2022-1045 in July 2022 increasing the maximum weight of trucks involved in 

combined transport from 44 t to 46 t as part of an 18 months experiment. 

40 

 
 
 
 
 
                                                           
Figure 20: Results of open public consultation on the extent to which the Directive has 
added value (Q11: To what extent do you agree with the following statements: EU action 
is essential?). 

Source: Ramboll, TML (2023) Evaluation support study 

4.3. Is the intervention still relevant? 

The  W&D  Directive  remains  relevant  today.  Its  objectives  of  increasing  energy  and 
operational efficiency of transport operations, facilitating intermodal transport, ensuring 
fair competition while guaranteeing, road safety and protection of infrastructure continue 
to  reflect  current  and  future  needs  and  fit  well  in  the  policy  goal  of  creating  fair,  safe, 
sustainable, and resilient transportation system in the EU.  

The current and future ambitious targets for decarbonisation of the road transport and the 
needs for smoothly functioning internal transport market call, however, for more efficient 
measures and better adapted provisions to ensure higher effectiveness  and efficiency of 
the Directive in achieving its objectives and contributing meaningfully to broader policy 
objectives.  The  analysis  confirmed  that  current  performance  of  the  Directive  in  this 
regard  is  insufficient  due  to  unclear,  lacking,  or  inadequate  provisions.  For  example, 
some stakeholders argue that the current limits on vehicles weights and dimensions may 
not be sufficient to accommodate and incentivise new vehicle technologies, such as zero-
emission powertrains. In the context of emerging technological developments within the 
automotive  industry,  and  new  EU  targets  on  decarbonisation  of  transport  sector,  the 
Directive  could  play  an  important  role  in  boosting  the  deployment  of  zero-emission 
HDVs and promoting modal cooperation. While the Directive represents a step forward 
in the process of harmonisation of certain technical standards of the HDVs circulating on 
the  EU  roads,  it  has  not  prevented  the  emergence  of  diverging  interpretations  and 
applications  of  the  rules  and  inefficient  and  inconsistent  controls  of  compliance 
performed by Member States. A growing patchwork of national technical, administrative 
and  control  requirements  go  against  the  policy  goal  of  achieving  a  Single  European 

41 

 
 
Transport Area that should ease the movements of citizens and freight, reduce costs, and 
enhance the sustainability of European transport.  

Despite  the  positive  trend  in  reducing  the  number  of  fatalities,  road  safety  remains  a 
major concern with the W&D Directive having potential to better address this issue. In 
2018, the EU has set itself a 50% reduction target for road deaths–and, for the first time, 
also  serious  injuries–by  2030.  This  was  set  out  in  the  Commission’s Strategic  Action 
Plan on Road Safety and EU road safety policy framework 2021-2030 which also lay out 
road safety plans aiming to reach zero road deaths by 2050 (‘Vision Zero’). Road safety 
has  also  been  a  core  element  of  recent  EU  mobility  policy  initiatives  including 
the Sustainable and Smart Mobility Strategy.  

The  OPC  revealed  that  80  to  93  respondents  out  of  125  fully  agreed  that  EU  action  is 
essential  to  the  effective  cross-border  cooperation,  to  ensure  the  smooth  functioning  of 
the  internal  market,  to  improve  the  environmental  performance  of  the  transport  sector 
objectives  and  to  ensure  road  safety  as  shown  in  Figure  21.  Only  20  out  of  126 
respondents found that at least one of these objectives is no longer relevant. 

Figure 21: Results of open public consultation as regards the relevance of the general 
objectives of the Directive (Q7: In your view, are the Directive’s objectives still relevant 
in addressing current and emerging needs and challenges?). 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1. Conclusions 

The  Weights  and  Dimensions  Directive  has  been  in  effect  since  the  1990s  and  has 
undergone  several  revisions  over  the  years.  It  has  expanded  its  scope  of  geographical 
application (EU enlargements) and it has refocused its priorities from the key objective of 
advancing  the  internal  market  for  road  freight  transport  to  the  sustainability  and 
multimodality  objectives.  The  cross-cutting  objectives  of  safeguarding  road  safety  and 
the protection of infrastructure remained the priority. Based on the available information 
and bearing in mind limitations as to the availability and reliability of relevant data, the 

42 

 
 
 
evaluation  of  the  W&D  Directive  has  assessed  its  performance  in  terms  of  its 
effectiveness, efficiency, coherence, EU value added and relevance. 

5.1.1.  Effectiveness  

The evaluation has shown that the Directive was only partially effective in achieving its 
objectives.  As  to  the  internal  market  objective,  by  harmonising  maximum  authorised 
limits  for  weights  and  dimensions  of  HDVs  used  in  cross-border  operations,  the 
Directive  provided  level  playing  field  among  operators,  removed  technical  barriers  to 
carrying  out  cabotage  operations  and  facilitated  transport  operations.  However,  due  to 
various derogations allowed under the Directive and ambiguities of certain provisions, a 
patchwork of diverging national rules, technical and administrative requirements as well 
as bilateral arrangements emerged, fragmenting the internal market integrity. More than 
half of Member States have adopted national derogations and/or run trials with vehicles 
exceeding  the  weights  and/or  dimensions  set  in  the  Directive  with  positive  impacts  at 
national  level  but  affecting  cross-border  competition.  Hence,  the  expected  level  of 
harmonisation has not been achieved.  

The Directive facilitated the use of road vehicles in intermodal transport which increased 
slightly  in  the  evaluation  period,  but  the  positive  effects  of  the  relevant  provision 
(allowing extra weight of up to 4 t to compensate the weight of empty containers) have 
been partially annulled by the  uncoordinated national measures allowing for circulation 
of 44 t HDVs in road-only operations. The uniform safe limits for weight and dimensions 
of  HDVs  also  helped  safeguard  road  safety  and  reduce  road  wear  and  tear.  The  road 
safety and protection of road infrastructure was also enhanced by the provisions allowing 
Member  States  further  reduce  the  limits  for  vehicles  operating  in  certain  areas 
characterised  by  vulnerable  infrastructure  and/or  the  presence  of  vulnerable  road  users. 
The  derogations  allowing  heavier  and/or  longer  HDVs,  including  EMS,  incentivised 
interested Member States to assess the adequacy of their road network and upgrade the 
infrastructure to ensure safe operations by larger vehicles. 

The effectiveness of the Directive in improving energy efficiency of transport operations 
and reducing greenhouse gas emissions (and in parallel air pollution) by encouraging the 
use of more fuel-efficient and environmentally friendly vehicles (i.e., vehicles equipped 
with aerodynamic devices and/or alternatively fuelled powertrains) turned out to be very 
low. The share of alternatively fuelled HDVs (trucks and buses) in the total HDV fleet is 
hardly  at  4.1%. Only one manufacturer started production of trucks with elongated cab 
and the demand for rear flaps was inexistent.  This  law uptake  is  the result of delays  in 
adopting and start of application of the type-approval legislation for aerodynamic devices 
(regulatory failure)87, lack of demand for aerodynamic devices due to limited operations 
in  which they can bring a meaningful return on  investment  and insufficient  weight  and 
length provisions to encourage the use of zero-emission powertrains. Public and private 
stakeholders agree that additional allowance in  terms of weight  and length is  necessary 

87 Regulation (EU) 2019/1242 entered into force on 14 August 2019, the type approval legal framework for 
rear devices and aerodynamic cabs entered into force on 2 December 2019 and elongated cabs could 
not be placed on the market before 1 September 2020.  

43 

 
                                                           
for zero-emission long haul trucks to have at least the same loading capacity and be as 
competitive as internal combustion engine trucks. 

On  the  other  hand,  the Directive  improved  to  certain  extent  the  energy  and  operational 
efficiency  of  operations  by  enabling  Member  States  the  use  of  heavier  and/or  longer 
vehicles  in  national  transport,  which  then  has  been  extended  to  cross-border  bilateral 
operations  based  on  agreements  between  two  ‘allowing’  Member  States.  The  positive 
effects  have  been,  however,  limited  to  the  national  and  bilateral  operations  in  nine 
‘allowing’  Member  States.  The  current  Directive  prevents  to  take  advantage  of  the  full 
potential of these solutions (namely 44 t-HDV and EMS) used in freight transport and to 
do  it  in  a  harmonised  way.  Weak  enforcement  has  also  undermined  the  Directive’s 
effectiveness in some cases. The variety of rules and the lack of legal certainty have led 
to inefficient and inconsistent enforcement of the rules in cross border transport, as well 
as  to  discriminatory  practices  in  cases  where  the  rules  are  only  enforced  by  one  of  the 
two neighbouring countries involved. 

5.1.2.  Efficiency 

Scarcity of data related to costs and benefits that the changes triggered by the Directive 
generated, made it impossible to assess cost-effectiveness of the intervention.  Based on 
the  qualitative  analysis  it  can  be  concluded  that  the  Directive  reduced  administrative 
burden  by  providing  a  level  playing  field  for  transport  companies,  as  all  vehicles  must 
comply, in principle, with the same standards in cross-border traffic. On the other hand, 
the  Directive  enabled  the  development  of  national  weight/dimension  standards  and 
administrative and technical requirements for the circulation of longer vehicles on their 
territories,  rendering  certain  operations  more  costly  and  procedures  more  time-
consuming. 

By  enabling  the  use  of  EMS,  which  can  be  composed  of  conventional  vehicles  (motor 
vehicle,  trailers  and  semitrailers),  the  Directive  helped  road  transport  operators  enjoy 
operational  costs  savings  (fuel  savings,  less  drivers  needed)  without  the  necessity  to 
invest  in  new  vehicles.  These  operational  and  energy  efficiency  gains  contribute  to 
reducing GHG  emissions and traffic congestion (less  vehicles on the roads to  carry the 
same  amount  of  cargo)  without  any  significant  investments  in  the  upgrade  or 
maintenance  of  road  infrastructure,  as  the  axle  weight,  being  critical  for  infrastructure, 
has not been increased in the case of EMS.  

5.1.3.  Coherence 

The  Directive  has  been  coherent  with  other  EU  laws  and  policies,  such  as  the  Single 
Market,  the  European  Green  Deal,  the  Fit  for  55  Package,  the  Combined  Transport 
Directive,  the  Eurovignette  Directive,  or  CO2  Standards  for  HDVs.  It  has  also  been 
aligned  with  international  standards  and  conventions,  such  as  the  United  Nations 
Economic Commission  for Europe (UNECE) regulations on the maximum  weights  and 
dimensions of commercial vehicles.  However, the evaluation confirmed certain internal 
inconsistencies  of  the  Directive,  which  are  the  reason  for  its  low  effectiveness,  in 

44 

 
particular  in  achieving  the  internal  market  objectives  and  the  growth  of  intermodal 
transport operations. 

5.1.4.  EU added value 

The  evaluation  found  that  the  Directive  has  achieved  more  than  would  have  been 
achievable,  had  action  only  been  taken  at  national,  regional,  or  international  level. 
Without the intervention, Member States would have been able to discriminate between 
HDV  registered  in  their  territory  and  those  registered  in  another  country  hampering 
efficient  cross-border  operations,  reducing  attractiveness  of  cabotage,  and  negatively 
influencing  the  market  forces.  The  Directive  has  added  value  to  the  EU  by  promoting, 
harmonization  and  standardization  of  road  transport  technical  requirements  across 
Member  States,  which  has  facilitated  cross-border  trade  and  contributed,  to  certain 
extent, to the integration of the EU Single Market. It has also a potential to contribute to 
achieving the EU’s environmental and sustainability goals.  

5.1.5.  Relevance 

The needs  and problems identified in  1996 and  prior to  the subsequent  amendments  of 
the  Directive  recognised  in  the  intervention  logic  persist.  The  internal  market  for  road 
transport  services  has  not  been  completed  yet  and  the  environmental  and  social 
negativities of road transport need to be addressed more decisively and comprehensively 
to meet the carbon neutrality goal and zero-pollution ambition set in the European Green 
Deal, while transport demand and services keep growing. The Directive remains relevant 
today,  as  it  continues  to  address  key  challenges  in  the  transport  sector,  such  as  road 
safety, environmental protection, and fair competition. However, there may be a need to 
update  and  adapt  certain  provisions  to  new  technologies  and  emerging  trends,  such  as 
zero-emission technologies, multimodality, automation, and digitalisation.  

5.2. Lessons learned 

The evaluation of the Directive has highlighted several key lessons learned. One of the 
main  lessons  is  the  importance  of  monitoring  and  regular  reviews/updates  of  the 
provisions  and  technical  standards  set  in  the  Directive  to  ensure  that  it  reflects  the 
technological  and policy  developments  and does not  hamper the progress, but  provides 
meaningful contribution to the policy goals. This is particularly important given the rapid 
pace  of  technological  change  in  the  transport  industry  and  increasingly  ambitious 
decarbonisation targets. 

The  evaluation  found  that  there  is  a  need  for  greater  harmonisation  of  weights  and 
dimensions standards, in particular for heavier and/or longer HDVs (e.g. loaded length of 
car  transporters,  EMS),  as  well  as  of  administrative  requirements  and  procedures  for 
different  types  of  operations  (e.g.,  permits  for  abnormal/indivisible  load  carriage).  This 
would help to reduce the administrative burden for transport operators and ensure a level 
playing field for competition on the internal market. 

Another  lesson  learned  consists  of  the  need  for  greater  enforcement  of  the  Directive, 
particularly  in  relation  to  the  use  of  ‘non-compliant’  vehicles  (overloaded  and/or 
oversized). This is an ongoing challenge for regulatory authorities, but there is a need to 

45 

 
ensure  that  non-compliant  vehicles  do  not  put  other  road  users  at  risk  or  damage 
infrastructure, and that they do not lead to distortions of competition.  

There is also the need for guidance for Member States’ authorities and for operators as 
regards the interpretation of the provisions of the Directive. This is important to prevent 
the diverging interpretations of the common rules in force and ensure that the Directive is 
applied and enforced consistently across the EU.  

Overall, the evaluation of the Weights and Dimensions Directive has provided valuable 
insights into its performance in achieving its objectives and identification of the elements 
of  the  Directive  that  worked  and  those  that  did  not  or  worked  only  partially.  The 
expected  growth  of  the  European  transport  market  over  the  next  decades  calls  for 
measures aimed at making road transport as efficient and sustainable as possible. Efforts 
should  continue  to  adapt  the  legal  framework  to  the  technological  developments, 
demands and capability of the market, and to meet the greening and safety objectives in 
the transport system as a whole. 

46 

 
ANNEX I:  PROCEDURAL INFORMATION 

Lead DG, Decide Planning and CWP References 

Lead DG: Directorate-General for Mobility and Transport (DG MOVE), Unit C1: Road 
Transport. 

DECIDE reference number: PLAN/2021/11805. 

CWP:  Item  8.b)  in  Annex  I  to  Commission  Work  Programme  2023,  headline  ‘A 
European Green Deal’, part of the Greening freight package88. 

Organisation and timing 

The Call for Evidence was opened on 21 January 2022, the Open Public Consultation on 
April 26 2022. A workshop with industry and MS stakeholders was held on December 15 
and 16 2022, respectively. 

This  evaluation  was  coordinated  by  an  Inter-Service  Steering  Group  (ISSG),  involving 
the  following  Commission  Services:  Secretariat  General,  Legal  Service,  Directorate-
General  for  the  Internal  Market,  Industry,  Entrepreneurship  and  SMEs  (GROW), 
Directorate-General  for  Climate  Action  (CLIMA),  and  Directorate-General  for 
Environment (ENV). 

The  Inter-Service  Steering  Group  met  5  times:  November  30  2021,  June  3  2022, 
November 15 2022, March 9 2023, and March 31 2023. It was consulted throughout the 
different  steps  of  the  impact  assessment  process,  notably  on  the  draft  staff  working 
document. 

The adoption of the legislative proposal for the revision of the Weights and Dimensions 
Directive was planned as part of the Greening Freight Package. 

Consultation of the RSB 

The draft report was submitted to the RSB on 26 April 2023 and discussed by the Board 
on 24 May 2023. 

Evidence, Sources and Quality 

The  impact  assessment  and  the  evaluation  are  based  on  several  sources,  using  both 
quantitative and qualitative data, collected both from Member States and road transport 
sector stakeholders. This includes 

-  The Commission Report on the implementation  

88 COM (2022) 548 final of 18 October 2022. 

47 

 
 
                                                           
-  The ex-post evaluation of the WDD 
-  Stakeholder Consultation Activities (see Synopsis Report), 
-  External support study by external consultants 
-  Commission’s  experience  in  monitoring  and  implementing  the  Weights  and 

Dimensions Directive  
Industry and MS workshop 

- 

48 

 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

Methodology and sources of information 

The  evaluation  process  started  in  2022,  following  the  Commission’s  Better  Regulation 
Guidelines.  As  part  of  the  evaluation,  the  lead  DG  consulted  an  Inter-Service  Steering 
Group (ISSG) for advice and monitoring reasons during the development of the task. As 
the  ISSG  included  representatives  from  the  Commission  services:  CLIMA,  ENV, 
GROW, SG and SJ, a beneficial constellation of diverging backgrounds, experiences and 
insights could be gathered, allowing to provide the input necessary in order to assess the 
impact  in  areas  beyond  the  scope  of  the  lead  DG,  especially  regarding  environmental 
effects.  In  addition,  the  external  contractor  was  commissioned  to  support  the  data 
collection and analyses necessary to evaluate the performance of the Directive. 

The intervention logic presented in Figure A was the starting point for the evaluation of 
the Directive in  terms of its effectiveness,  efficiency, relevance, internal  coherence  and 
EU added value.  

The following sources of information were used for this evaluation: 

-  Stakeholder consultation activities to gather information about public and private 

stakeholders’ perception of the Directive: 

o 

 an online open public consultation (OPC), executed on the Commission’s 
Have your say website, 

o  Call for Evidence, executed on the Commission’s Have your say website 

o  Targeted Survey 

o  Workshops 

-  Commission  report  on  the  implementation  of  amendments  introduced  by 

Directive (EU) 2015/719 (SWD(2023) 70 final), 

-  Member  States  reports  on  controls  and  their  results  in  terms  of  a  detection  of 

overloaded HDV, 

-  External  support  studies  to  the  ex-post  evaluation  of  the  W&D  Directive, 
conducted  by  Transport  &  Mobility  Leuven,  Ramboll,  Panteia,  Apollo  Vehicle 
Safety, LNEC, Bernard Jacob, Alan McKinnon, and Ben Van Houtte. 

The consultation activities had the following three main objectives: 

  To gather experiences and views from EU citizens regarding the WDD,  
  To  provide  the  concerned  public  and  private  stakeholders  an  opportunity  to 
express  their  views  and  positions  regarding  the  key  elements  of  the  impact 
assessment and cost-benefit analysis, 

49 

 
 
 
  To gather specialised input (data and factual information, expert views) from key 
stakeholders  on  their  views  and  positions  regarding  the  potential  impacts  of  the 
various measures considered in the impact assessment and cost-benefit analysis. 

The final synopsis report on the stakeholder consultation of the support study for the ex-
post evaluation of the WDD has been carried out by  Ramboll Management Consulting, 
see also Annex III and the factual summary report. 

Methods and tools used for the evaluation 

In order to provide the evaluation with factual information, desk research was performed, 
mainly  aiming  at  identifying relevant  secondary  literature.  It  included sources provided 
by  the  Commission  in  the  Terms  of  Reference  for  the  evaluation  support  study, 
publications/position papers/trial reports from countries having extensive experience with 
longer/heavier vehicles, general publications on infrastructure and enforcement as well as 
driver safety and comfort, and statistical evidence such as uptake of vehicle technologies, 
or  road  accident  statistics.  All  available  findings  and  insights  were  compared  and 
synthesised to create evidence-based results for the evaluation aims. The topics treated by 
this desk research varied,  however mainly focusing on  technological  developments, the 
major  impacts  of  longer  and  heavier  HDV,  legal  aspects,  alternative  fuels,  safety,  and 
infrastructure effects, achieving a total EU Member States coverage in most cases. 

Moreover, the analysis was structured according to an evaluation matrix as presented in 
Annex  III,  operationalising  a  set  of  evaluation  questions  including  sub-questions, 
indicators, as well as judgement criteria that would be used in order to achieve insights. 
Data sources and the analytical approach are also laid down in the evaluation matrix. The 
matrix  was  developed  on  the  basis  of  an  extensive  in-depth  understanding  of  the 
Directive’s  intervention logic and approach, with  regards to  the aims and achievements 
as laid down in the intervention logic. 

Field research 

Call for Evidence (CfE) was conducted between 21 January 2022 and 21 February 2022, 
followed by the Open Public Consultation (OPC) 26 April 2022 to 19 July 2022), as well 
as  two  additional  workshops,  one  targeted  at  industry  stakeholders,  one  targeted  at 
Member  States  (15  December  2022  and  16  December  2022).  More  information  on  the 
stakeholder consultation activities in presented in Annex V. 

The  goal  of  the  field  research,  which  included  targeted  stakeholder  interviews  and 
surveys, was to supplement the body of information gathered through desk research and 
public consultation. Based on what  was necessary from the Evaluation  Matrix, the data 
received  from  the  desk  review  and  the  Open  Public  Consultation  allowed  for  the 
identification of gaps in the themes that needed to be studied and the data that needed to 
be  collected.  Evidence  gaps  mainly  occurred  in  certain  details,  such  as  road  safety, 
impact  on  international  traffic,  implementation  measures  and  efficiency  effects. 
Additionally, the previous research allowed for the identification of the stakeholders who 
needed to be specifically targeted through surveys because there were either insufficient 
responses from these groups in the Open Public Consultation (for example, infrastructure 
managers)  or  because  there  was  a  lack  of  data  available  in  some  regions  (for  example, 

50 

 
countries  in  Southern,  Central,  and  Eastern  Europe).  As  a  result,  the  surveys’ 
development  was  based  on  the  gaps  found  in  the  data  from  earlier  study.  Different 
stakeholder groups were part of the surveys conducted between 19 September 2022 to 13 
October  2022,  including  infrastructure  managers,  operators,  national  authorities  and 
manufacturers.  A complete overview of  responses,  including the survey  questionnaires, 
are provided in the Stakeholder Consultation Report. 

The  data  collected  was  used  to  respond  to  the  evaluation  dimensions,  constituting  the 
basis  for  the  evaluation  on  how  the  Directive  performed  regarding  the  categories 
mentioned  above,  and  in  Chapter  4.  Each  of  the  evaluation  criteria  was  addressed  to 
tailored evaluation questions, as laid down in the evaluation matrix. 

Limitations and robustness of findings 

Even  though  the  evaluation  process  as  a  whole  was  designed  to  ensure  the  evidence’s 
robustness, limitations to the findings and thus also the robustness of the results must be 
taken into account. 

The  length  of  the  evaluation  period  (over  25  years)  posed  a  challenge  in  terms  of  the 
availability  and  comparability  of  quantitative  data,  in  particular  for  data  related  to 
passenger transport and for data before 2004 when the categorisation of HDV changed in 
official  statistical  series  and  when  twelve  new  European  countries  joined  the  EU.  The 
lack of quantitative data has been compensated to the extent possible with desk research 
and  qualitative  input  from  stakeholders.  The  long  timespan  thus  had  important 
implications in terms of data availability for defining the baseline scenarios, resulting in 
limitations  regarding  the  measurement  of  effects,  outcomes,  and  costs  and  benefits 
resulting from the Directive. This scarce data availability was partly cushioned by desk 
research and stakeholder consultation. 

It  was  also  rather  difficult  to  assess  the  WDD  effectiveness  in  term  of  improving  road 
safety  due  to  the  long  period  evaluated  and  parallel  developments  through  other  road 
safety strategies and measures, as it cannot always be determined to which extent certain 
policies contributed to increased road safety. As with other Directives and Regulations, 
the road safety can be affected by many factors like legislative, policy, or technological 
factors;  the  statistical  modelling  for  road  accident  facilities  has  limitations  in  itself,  as 
these  developments  cannot  be  accurately  included  in  statistical  models.  Similarly,  the 
effect on harmonisation of cross-border transport, statistical data is either not available or 
is also considering effects of other initiatives. 

Moreover, the general macroeconomic development in the EU has a direct effect on road 
freight transport activity. Also, the evaluation period covered enlargements of the Union, 
meaning that the Member States taken into account changed over different base years. 

For  the  sake  of  completeness,  it  should  be  mentioned  that  the  OPC  and  CfE  received 
contributions from different Member States, but especially from Belgium, Germany, and 
France, thus the total number of responses does not constitute a representative sample of 
EU stakeholders, meaning that the results of the  consultation  may not  be interpreted to 
necessarily represent views of all EU stakeholders. 

51 

 
Figure A: Intervention Logic 

52 

 
 
ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

Effectiveness 

Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

·    Analytical 
approach 

EQ 1: From a general 
perspective, to what 
extent has the Directive 
contributed to or 
hindered the 
achievement of its 
different objectives? 
EQ 2: Has the Directive 
helped implementing 
the internal market for 
road transport? 

question 
This 
combines  the  other 
evaluation  questions 
on  the  effectiveness 
criterion 

To  what  extent  has 
Directive 
the 
to 
contributed 
obstacles 
removing 
(HDV) 
related 
traffic 
between 
Member States? 

to 

  Relative  volumes 
international  and 
and 
trips 

for 
domestic 
evolution over time 

  Vkms 

national 
international 
MS 

for 
and 
trips  per 

 

 

 

 
 

Statistics: For freight transport the 
sections 2.2.4.a to c of the Statistical 
pocketbook 2021 provide with the 
relevant data. 
https://op.europa.eu/en/publication-
detail/-/publication/14d7e768-1b50-
11ec-b4fe-01aa75ed71a1 
Surveys and interviews 
Public consultation 

  Quantitative: 

statistics  comparing 
of 
evolution 
domestic 
vs 
international 
transport 
vkm, tkm) 
  Qualitative 

(tonnes, 

of 

(opinions 
stakeholders), 
supported 
by 
quantified  indicators 
and  examples  of 
past 
present 
or 
obstacles 

Increase of the 
importance of 
international traffic 
indicates that there 
are fewer restrictions 
to crossing border 
with HDVs. 
Road transport 
operators experience 
in daily practice if 
W&D Directive has 
contributed to 
smoother cross-
border transport. 

53 

 
 
 
  
 
 
 
  
·    Analytical 
approach 
Quantitative  (number  of 
derogations,  total  and 
per  MS,  number  and 
results  of  enforcement 
actions)  and  qualitative 
(lists  of  derogations, 
characteristics, 
policy 
behind them) 

Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

  Desk research: literature and national 
legislation 
Surveys  and  Interviews  with  MS  and 
 
relevant 
(enforcement 
bodies  and  associations:  CORTE,  ECR, 
etc.). 

stakeholders 

ensure 

To  what  extent  has 
the  Directive  helped 
equal 
to 
of 
conditions 
competition  (in 
the 
sense  of  harmonised 
EU  rules  on  W&D)  in 
heavy road transport?  

  Nr  of  MS  adopting 
national 
W&D 
post-
derogations 
implementation  of  the 
Directive 
  Number  and 
type 
(weight,  length,  width, 
additional 
height, 
vehicle  properties)  of 
national  derogations,  of 
national  trials  and  of 
bilateral  agreements  for 
cross-border 
the 
of 
transport 
HDV 
exceeding 
the  W&D 
Directive standards. 
  Reasons  for  adoption 
of  derogations, 
trials 
and 
bilateral 
agreements 

to 

are 

Full 

trial 

from 

harmonisation 
 
implies 100% compliance 
with W&D Directive rules. 
The  number 
of  MS 
adopting derogations and 
the  diversity  of  these 
derogations 
a 
measure for the (lack of) 
harmonisation. 
In 
addition, any evolution in 
the  rules  over  the  25 
years  (e.g.,  derogations 
go 
full 
adoption)  can  indicate  if 
the  Directive  has  helped 
move  to  more  or  less 
harmonised rules. 
  High 
compliance 
equal 
competition.  
  Number  of  vehicles 
during 
checked 
actions 
enforcement 
(absolute 
a 
as 
fraction of total vehicles) 
Level  of  compliance 
 
(number  and  severity  of 
infractions)  measured  by 
enforcement actions. 

of 
guarantees 
of 

conditions 

degree 

and 

54 

 
  
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

  Desk research: trial reports 
 

Surveys 
national/regional road authorities 

interviews 

and 

with 

 

Nature  of  trials  and 
evolution  over  time, 
and  their  objectives 
(and reported results) 
that  are  linked  with 
the  objectives  of  the 
Directive 

·    Analytical 
approach 

  Qualitative: 
description  of  trials  in 
different MS 
  Quantitative:  impact 
of  trials on road safety, 
infrastructure 
costs, 
modal shift 

EQ 3: Has the Directive 
helped protecting the 
infrastructure and 
ensure road safety ? 

To  what  extent  has 
profit  to  be  drawn 
technical 
from 
progress  materialised 
and  Member  States 
been allowed to adapt 
road 
the 
from 
infrastructure 
the 
of 
possibility 
conducting  trials  with 
vehicles 
equipped 
with new technologies 
and/or concepts?  
To  what  extent  has 
the 
Directive 
prevented  excessive 
damage, 
road 
ensured  the  integrity 
of  the  infrastructure 
the 
and 
of 
manoeuvrability 
vehicles?  

 

Number  and  extent 
for  new 
of 
trials 
and/or 
concepts 
technologies 
and 
their 
outcomes, 
extensions  (in  time 
and  content),  effects 
on  the  adoption  of 
new 
technologies 
and on infrastructure 
adaptations) 

infrastructure 
  Road 
to 
expenditure relative 
HDV 
volumes 
(accounting  for  vehicle 
weight)  and  road  length 
(e.g.  road  infrastructure 
expenses  per  km  of 
primary  road  network 
and  per  HDV  vkm), 
evolution over time 
Adaptations  to  roads 
 
and  bridges  for  heavy 
transport  
road 
Trials 
explicit 
objectives 
regarding 
infrastructure impact 

with 

Studies and reviews 

 
link W&D Directive to 
changes in road 
infrastructure 
expenditures (including 
trials) 

  Desk research 
 
authorities and infrastructure managers 

Surveys  and  interviews  with  road 

  Quantitative (€), if 
needed supported by 
qualitative evidence 
(trial reports) 

55 

 
·    Analytical 
approach 
  Quantitative:  trends 
and 

time 

countries 
different 

over 
comparison 
between 
with 
national rules  
Supplemented  with 
insight 
qualitative 
underlying 
into 
factors 
explaining 
differences 

 

Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

  DG Move provision of subset of CARE 
data on collisions involving HDVs 
since 1996. 
EuroStat traffic and freight data 
 
  Desk research: in-depth collision 
studies, specific W&D studies, 
published national data 
Surveys/Interviews with MS to 
identify additional casualty or traffic 
data or specific W&D studies as well 
as qualitative insight into underlying 
factors 

 

for 

rates  per 

in  HDV 
casualties 

Reduction 
involved 
over time  
Casualty 
HDV km reducing. 
Casualty 
rates  per 
tonne  km  are  lower 
larger  vehicles 
for 
than 
smaller 
vehicles  (with  each 
MS) 
of 
Proportion 
pedestrians 
in  HDV 
involved  collision  that 
are killed is reducing. 
Causation 
data 
infrequently  identifies 
factors 
contributory 
related 
vehicle 
to 
mass,  length,  height, 
aero  devices  or  HDV 
induced infrastructure 
damage 

To  what  extent  has 
the 
Directive 
improved road safety, 
from  the  perspective 
of  other  road  users 
and 
the 
infrastructure?  

 

 

 

 

 

 

 

 

to  which 

Road  safety  impacts 
as assessed in trials 
rates 
Collision 
compared 
to 
standard  of  different 
size/weight 
HGVs 
and  changes  over 
time. 
Extent 
damaged 
infrastructure 
to 
contributes 
involving 
collisions 
any  vehicle 
type. 
Distribution  of  road 
users  KSI  in collision 
involving  an  HDV 
and  evolution  over 
time 
Change in proportion 
in 
of  pedestrians 
collision  involving  an 
HGV  that  are  killed 
(related to elongated 
cab 
objective) 
Common  causes  of 
collisions 
involving 
HDV 
HDV 
safety 
road 
impacts  in  MS  that 
joined  the  EU  after 
1996,  i.e.,  pre-  and 
post-application 
of 
96/53 rules 

56 

 
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

EQ 4: Has the Directive 
helped to ensure road 
safety and improve 
working conditions of 
HDV drivers? 

To  what  extent  has 
the  Directive  enabled 
of 
market 
more comfortable and 
safer trucks? 

uptake 

Sales  of  ‘better’  cabs 

 
or prospects of sales 
  Degree  of  alignment 
of  type  approval  and 
other 
regulation  with 
this objective. 
  Opinion 
transport workers 
  Opinion  of  OEMs/cab 
designers 

road 

of 

To  what  extent  has 
the 
Directive 
improved  the  safety 
of 
transport 
workers (drivers)? 

road 

 

 

and 
Frequency 
severity 
of  HDV 
occupant  casualties 
over  time  and  as 
rates  per  km  and 
tonne km. 
Comparison of above 
between  vehicles  at 
standard  Directive 
weights  and  where 
those  are  exceeded 
(using 
or 
derogations) 

trials 

Statistics 
 
Surveys  and  interviews  with  HDV 
 
manufacturers  to  understand  how  much 
additional  comfort  the  elongation  has 
permitted,  transport  operators to  assess 
the  demand  for  those  cabs,  and  HDV 
drivers  to  understand  if  they  feel  the 
benefit 

EuroStat traffic and freight data 

  DG Move provision of subset of CARE 
data on collisions involving HDVs since 
1996. 
 
Desk research: in-depth collision studies, 
specific W&D studies, published national 
data 
 
identify additional casualty or traffic data 
or specific W&D studies as well as 
qualitative insight into underlying factors 

Surveys/Interviews with MS to 

  Other  regulations  do 
not represent a barrier to 
the 
implementation  of 
Directive. 
Other  regulations  do  not 
place 
competing 
demands  on  HDV  design 
that  erode  the  additional 
space  available  for driver 
comfort. 
  Market  attractiveness 
by 
assessed 
is 
sales and/or 
development  plans  of 
for 
OEMs,  accounting 
provisions 
the 
in 
regarding 
Directive 
timing  and  developments 
in  the  implementation  of 
Type Approval Directive 
and/or 
 
reducing. 
severity 
frequency, 
Casualty 
severity  or 
rate  not 
higher  where  heavier 
vehicles are permitted 

Frequency 

57 

·    Analytical 
approach 
  Quantitative, 
supported 
stakeholder opinions 

by 

  Quantitative:  trends 
and 
over 
time 
comparison 
between 
countries  with  different 
national rules  
Supplemented  with 
 
qualitative  insight  into 
underlying 
factors 
explaining differences 

 
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

Statistics 
Surveys 

 
 
OEMs/vehicle manufacturers 

and 

interviews 

with 

·    Analytical 
approach 

Supported 

  Quantitative 
by 
 
qualitative  analysis  of 
trends 
from 
OEMs/manufacturers 

EQ 5: Has the Directive 
helped to facilitate 
energy efficiency of road 
transport and reduce 
GHG emissions? 

To  what  extent  has 
the  Directive  enabled 
the  market  uptake  of 
alternatively 
fuelled 
and  ZEV  for  freight 
and 
passengers 
transport? 

To  what  extent  has 
the  Directive  enabled 
uptake 
market 
of 
more 
aerodynamic 
HDVs?  

Sales  of  alternatively 

 
Fuelled vehicles 
Sales of ZEV 
 
  OEM 
programmes AFV/ZEV 

development 

Sales  of  elongated 

Sales of aerodynamic 

 
devices. 
 
cabs 
  Development 
for 
programs 
aerodynamic  devices  at 
OEMs. 
  Degree 
to  which 
type-approval  and  other 
regulation  aligns  with 
this  objective  of 
the 
Directive. 
  Degree  to  which  the 
of 
benefits 
aerodynamics  accrue  to 
the  economic  operator 
who bears the costs. 

  Market  attractiveness 
is 
by 
assessed 
sales and/or 
development  plans  of 
for 
OEMs,  accounting 
in 
provisions 
the 
Directive 
regarding 
timing  and  developments 
in  the  implementation  of 
Type  Approval  Directive 
Assessment  of  technical 
appropriateness  of  W&D 
allowances  for  AFV/ZEV 
(are  weight  allowances 
sufficient?) 
  Other  Regulations  do 
not represent a barrier to 
implementation  of 
the 
Directive. 
Other  regulations  do  not 
competing 
place 
demands  on  the  space 
envisaged  to  be  used  for 
additional safety. 
incentives 
  Market 
for 
compensate 
situations  where 
the 
organisation  bearing  the 
costs of measures do not 
gain the benefits. 
  Market  attractiveness 
is 
by 
assessed 
sales and/or 
development  plans  of 
for 
OEMs,  accounting 
the 
provisions 

in 

58 

Statistics  (sales  and  ownership  of 

 
tractor/trailer) 
  Regulatory 
Surveys 
and 
OEMs/vehicle manufacturers 

interviews 

review 
with 

  Quantitative  
by 
Supported 
 
qualitative  analysis  of 
trends 
from 
OEMs/manufacturers 

 
 
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

·    Analytical 
approach 

Directive 
regarding 
timing  and  developments 
in  the  implementation  of 
Type  Approval  Directive 
Assessment 
of 
appropriateness  of  W&D 
allowances 
for 
aerodynamic 
improvements 
  Contribution 
additional 
allowance 
efficiency 

of 
weight 
energy 

to 

  Derogations  on  W&D 
for  intermodal  transport 
are used  

  Desk Research 
 
transport  operators,  bus  & 
manufacturers 

Surveys  and  interviews  with  road 
coach 

Supported 

  Quantitative 
by 
 
qualitative reviews from 
bus & coach builders 

  Desk research: statistics 
Surveys 
 
intermodal 
shippers 

and 

with 
interviews 
transport  operators  and 

  Quantitative:  use  of 
45  ft  containers  and 
in 
40-44 
intermodal 
road 
transport 

t  vehicles 

 

Reported  results  on 
GHG  emissions  (and 
other 
possibly 
environmental 

vehicle 

New 
transport 
tested  during 
may 

or 
concepts 
trials 
improve 

  Desk research (trial reports) 
 

Survey/interviews with MS 

  Quantitative: 

measured impact on 
GHG emissions 

59 

To  what  extent  has 
Directive 
the 
to 
contributed 
increasing  the  energy 
efficiency of  collective 
transport 
of 
passengers? 

To  what  extent  has 
Directive 
the 
facilitated  intermodal 
transport?  

To  what  extent  have 
trials 
had 
environmental 
impacts  (particularly 

Fuel 

(buses 
at 

efficiency 
 
measurements 
(l/km, 
litre per passengerkm or 
similar) 
heavy 
for 
transport 
passenger 
and 
vehicles 
coaches) 
higher 
weight as allowed by the 
Directive 
  Uptake 
of 
aerodynamic  devices  for 
passenger 
heavy 
transport vehicles 
  Uptake of ZEV/AFV in 
buses and coaches 
 

Volumes 
of 
intermodal  transport 
of 45 ft containers 
Evolution 
of 
intermodal  transport 
compared 
tonnage 
to TEU 

 

 

 
  
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

·    Analytical 
approach 

GHG emissions)?  

impacts) 

 

List 
of 
measures 

national 

 

environmental 
performance  of  HDV 
transport 
Number and extent of 
relevant measures 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities 

  Qualitative, 

link 
between  objectives 
and measures 

EQ 6: What 
implementation 
measures have Member 
States introduced in 
order to ensure the 
effectiveness of the 
Directive? Are there any 
significant differences in 
implementation 
measures and 
effectiveness across 
Member States?  

to 
Which  measures 
implement 
the 
Directive  have  been 
to 
taken  by  MS 
the 
support 
realisation 
the 
of 
internal market? 
to 
Which  measures 
the 
implement 
Directive  have  been 
taken  by  MS 
to 
improve road safety? 

to 
Which  measures 
implement 
the 
Directive  have  been 
to 
taken  by  MS 
preserve 
road 
infrastructure? 

to 
Which  measures 
implement 
the 
Directive  have  been 
taken  by  MS 
to 
driver’s 
improve 
conditions? 

 

List 
of 
measures 

national 

 

Number and extent of 
relevant measures 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities 

  Qualitative, 

link 
between  objectives 
and measures 

 

List 
of 
measures 

national 

 

Number and extent of 
relevant measures 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities 

  Qualitative, 

link 
between  objectives 
and measures 

 

of 
List 
measures 

national 

 

Number and extent of 
relevant measures 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities 

  Qualitative, 

link 
between  objectives 
and measures 

60 

 
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

·    Analytical 
approach 

 

List 
of 
measures 

national 

 

Number and extent of 
relevant measures 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities 

  Qualitative, 

link 
between  objectives 
and measures 

 

to 

Legislation 
introduced 
install/improve 
automated  detection 
overweight 
of 
vehicles, 
with 
distinction  between 
for  pre-
systems 
identification 
or 
direct enforcement 

 

 

Number and extent of 
relevant measures 
Number  of  vehicles 
controlled,  number  of 
infractions  detected, 
number  of  infractions 
penalised. 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities 

  Qualitative, 

link 
between  objectives 
and measures 

  Quantitative 

to 
Which  measures 
implement 
the 
Directive  have  been 
to 
taken  by  MS 
improve 
the 
environmental 
performance  of 
the 
heavy  road  transport 
sector? 
MS 
How 
implemented 
article 
10d of the Directive in 
practice?  

have 

EQ 7: Article 10d of the 
weights and dimensions 
Directive imposes 
Member States the 
obligation to implement 
measures to pre-identify 
automatically vehicles 
that circulate over the 
maximum authorised 
weight. To what extent 
has the Directive been 
effective in terms of 
ensuring that such 
infringements to the 
Directive have been 
automatically detected, 
made punishable by 
effective, non-
discriminatory, 
proportionate and 

61 

 
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities and enforcement agencies 

 

 

 

a 

of 
properties 
to 
certain 

Assessment 
system 
Arguments  used 
choose 
system 
Assessment 
of 
practical  application 
for 
system 
of 
detection/ 
enforcement 
of 
Comparison 
vs 
effectiveness 
traditional 
(non-
automated) systems 

·    Analytical 
approach 

  Qualitative: 
description 
detection systems 

of 

  Quantitative 
(number 
and 
location  of  systems, 
number  of  checks, 
of 
number 
infractions,  severity 
of infractions) 

  Detection 

systems 
installed  by  MS  and 
type 
their 
(WIM/OBW;  certified 
or 
not)  
Date of installation 
Location/  number  of 
systems, 
detection 
relative  to  HDV  vkm 
of 
and 
length 
primary 
road 
network  
Number  of  checks 
performed 
+ 
evolution 
Number 
infractions 
reported + evolution 
Severity 
of 
infractions 
reported 
+ evolution 

of 

 

 

 

 

 

dissuasive penalties? 

Which  systems  have 
been  implemented  by 
MS to make detection 
of 
overweight 
possible,  and  how 
long  have  these  been 
active? 

Which 
penalty 
systems  have  been 
put  in  place  by  MS  to 
dissuade  overweight 
they 
vehicles?  Are 
effective, 
non-
discriminatory, 
proportionate 
sufficiently 
dissuasive? 

and 

Penalty  systems  for 
overweight  vehicles 
in different MS 

 

 

Penalties  are  high 
enough 
is 
Penalty 
(higher 
progressive 
exceedance  means 
higher penalty) 

level 

  Modalities of the 

penalty system 

  Desk research 
 

Surveys  and  interviews  with  national 
authorities and enforcement agencies 

  Quantitative: 
penalty 
levels, 
evolution  of  number 
of penalties 
  Qualitative: 

modalities  of 
penalty system 

the 

62 

 
  
  
  
 
  
  
Evaluation Questions 

Sub questions 

·    Indicators 

Judgment criteria 

·    Data sources 

To  which  extent  has 
on-board 
weighing 
been  implemented  by 
the 
transport 
industry? How are the 
data being used? 

road 

 

 

Number of operators 
indicating the use of 
OBW 
Type of application 
(operational 
planning, vehicle 
management, 
compliance) 

  OBW used on 

voluntary basis in 
business processes 

 

Surveys and interviews with road 
transport operators 

·    Analytical 
approach 

  Qualitative: 
being 
used 
company level 

OBW 
at 

63 

 
 

· Analytical 
approach 

 

Cost/benefit analysis 
(quantitative and where 
not possible, 
qualitative) 

·    Data 
sources 

  Desk 

 

 
 
 

research  
National 
and EU 
statistical 
data 
TCO-tools 
PC 
Survey 
and 
interviews 
with 
stakehold
ers  

Efficiency 

Evaluation Questions 

Subquestions 

·    Indicators 

Judgment criteria 

EQ 8: To what extent has the 
Directive generated costs and 
benefits for each relevant 
stakeholder and for national 
authorities?  

Provide quantitative 
information on the costs 
and benefits consequence 
of the implementation of 
the Directive.  

Cost/benefit 
analysis results 
are positive 

Direct costs 

 

 

 

 

 

 

Costs to ensure the enforcement of 
the Directive (for public authorities)                     
Costs for new equipment, costs for 
new vehicles (road transport 
operators, shippers and logistics 
companies, truck manufacturers) 
that comply with the Directive. Costs 
and for installation and maintenance 
of aerodynamic devices 
Administrative costs (planning of 
loads, weight monitoring for road 
transport operators, shippers and 
logistics companies and enforcement 
costs for national authorities. 
Authorisation (permits) and 
standardisation costs to comply with 
the Directive (road transport 
operators, shippers and logistics 
companies)-  
Taxes and permits for transporting 
indivisible loads (shippers, road 
operators 
Costs for installation/maintenance of 
aerodynamic devices 

Indirect costs  
 

Costs incurred by delays, waiting 
times etc. (transport operators, 
shippers and logistics companies) 

Direct benefits 

64 

 
 
 
 
 

 

Benefits from fuel saving and from 
transport efficiency. (Road transport 
operators, shippers and logistics 
companies)-Income for authorisation 
and standardisation processes 
(national authorities) 

Indirect benefits 
Road safety, better infrastructure 
(all road infrastructure users) 

 

  HR costs (i.e., additional personnel) 
to enforce the Directive (public 
authorities) 
Administrative costs on HR for 
transport companies to comply with 
Directive (planning of loads, weight 
monitoring) 
Costs on equipment to ensure 
compliance with the Directive (road 
transport operators, shippers and 
logistics companies) 

 

 

 

Cost/benefit 
analysis results 
are positive.  
Cost-effective 
manner to 
implement the 
Directive 

  Human resources costs  
 

Implementation related costs 

 

Cost/benefit 
analysis results 
are positive 

EQ 9: What is the 
administrative burden for 
Member States and transport 
stakeholders generated by the 
Directive? 

EQ 10: Are there excessive 
implementation costs 
generated by the Directive? 

What are the costs in 
human resources, 
compliance related and 
enforcement related costs 
with the Directive? 
Could effective application 
of the Directive be ensured 
in a more cost-effective 
manner? 

Are there quantified 
examples where the 
application of the Directive 
clearly led to 
unproportionate or 
excessive implementation 
costs? Of which 
magnitude? 

 

 

 
 
 

 

Cost/benefit analysis 
(quantitative and where 
not possible, 
qualitative) 

Surveys 
and 
interviews 
with 
stakehold
ers 

 

Cost/benefit analysis 
(quantitative and, 
where not possible, 
qualitative) 

National 
and EU 
statistical 
data 
TCO-tools 
PC 
Surveys 
and 
interviews 
with 
stakehold
ers 

EQ 11: How do any identified 
positive impacts (in terms of 
CO2 emissions reduction, 

How do the actual positive 
and negative impacts of 
the Directive compare? 

  Monetary 
 
 

human resources 
accident statistics 

 

Cost/benefit 
analysis results 
are positive 

  Desk 

 

research 
National 

 

Cost/benefit analysis 
(quantitative and, 
where not possible, 

65 

 
 
likelihood of accidents, 
improvement of infrastructure 
maintenance, etc.) compared 
to the actual costs and 
negative impacts in terms of 
orders of magnitude/in size 
over the evaluation period? 

EQ 12: Is there room to 
simplify in order to reduce the 
regulatory burden, either on 
administrations, businesses 
and citizens, caused by the 
intervention? 

 

environmental impact 

  Human resources 
 

Implementation costs 

 

Are there any quantified 
examples where the 
administrative burden 
caused by the Directive is 
excessive in comparison 
with the expected added 
value and where these 
could be reduced? Which 
magnitude? 

 
 

 
 
 

and EU 
statistical 
data 
TCO-tools 
Surveys 
and 
interviews 
with 
stakehold
ers 

TCO-tool 
PC 
Surveys 
and 
interviews 
with 
stakehold
ers 

Cost/benefit 
analysis results 
are positive. 
Arguments used 
to simplify and 
therefore reduce 
the regulatory 
burden 

qualitative) 

 

Cost/benefit analysis 
(quantitative and, 
where not possible, 
qualitative) 

66 

 
 
 
 
Relevance 

Evaluation Questions 

Subquestions 

EQ 13: To what extent are the (original) objectives 
of the Directive, as stated in its recitals, still 
relevant to the needs of stakeholders? 

Does  the  Directive  still  have  relevance  today 
for  stakeholders  in  relation  to  road  safety, 
infrastructure wear and tear, logistics cost and 
performance and environmental performance? 

Indicators 

Evidence 

 
provided 
stakeholder 
description 
benefits 

Judgment 
criteria 
Performance  is 
assessed 
positive 

Data sources 

PC 
 
Surveys  and 
 
interviews  with 
stakeholders 

by 

of 

Analytical 
approach 
Qualitative, 
tally  

by 
text 

Evidence 
provided 
free 
stakeholder 
assessment 
New 
identified 
stakeholders 

needs 
by 

Performance  is 
assessed 
positive 

Qualitative, 
tally 

 

Surveys and 
interviews 
with 
stakeholder
s 
  Desk 

research 

EQ 14: To what extent will the objectives of the 
Directive still be relevant going forward, also 
considering the EU wider policy goals and priorities 
of EU citizens (e.g. European Green Deal, carbon 
neutrality and zero-pollution ambition, realisation 
of the internal market, European road safety goals, 
etc.)? 

What will be the relevance of the objectives of 
the  Directive  going  forward  for  road  safety, 
infrastructure wear and tear, logistics cost and 
performance and environmental performance? 

 

 

Will  EU  wider  policy  goals  and  priorities  of  EU 
citizens  (e.g.,  European  Green  Deal,  carbon 
neutrality 
ambition, 
realisation  of  the  internal  market,  European 
road  safety  goals,  etc.)  change  the  relevance 
of the objectives of the Directive? If so, how? 

zero-pollution 

and 

67 

 
 
 
 
Data sources  Analytical 
approach 
  Qualitative 
 

Surveys.  
Interviews 

 
 

Supported  with 
quantitative 
estimate of any 
opportunity 
cost 
possible 

where 

  Qualitative 

 

Surveys 
Interviews 

  Desk 

research 

Coherence 

Evaluation Questions 

Subquestions 

Indicators 

Judgment criteria 

in 

factor 

The  presence  or 
absence  of  Member 
States citing  this  as 
a 
their 
decisions  in  relation 
the 
to 
implementation  of 
the Directive 
The presence or 
absence of relevant 
overlaps and/or 
synergies 

 

 

EQ 15: To what extent is the 
Directive internally coherent? (i.e. 
are the measures mutually 
reinforcing in achieving the 
objectives?)  

To  what  extent  do  the  different  objectives  of 
the Directive overlap/interfere with each other? 
Are 
explore? 
synergies 
Are there any incompatibilities? 

there  any 

to 

  Opinions  of  MS  on 
practical 
the 
implementation  of 
the Directive 

Evidence provided 
by free text 
stakeholder 
assessment 
Evidence on the 
effects of the 
national regimens 
and bilateral 
agreements 
adopted by MS as 
regards W&D of 
HDV 

EQ 16: How does the Directive 
interact with other interventions 
at the EU/national /international 
level which have similar 
objectives? 

Are  there  any  inconsistencies/overlaps/gaps 
between  the  Directive  and  other  EU  policies 
and  general  principles  (e.g.,  European  Green 
Deal,  an  Economy  that  works  for  people,  The 
White  Paper  on  Transport, 
the  “do  not 
significant harm” principle)? 
Are there any synergies to explore? 

 

 

Are  there  any  inconsistencies/overlaps/gaps 
between  the  Directive  and  other  interventions 
at  the  EU  level  (e.g.,  the  Combined  Transport 
Directive, the type-approval legal framework)? 
Are there any synergies to explore? 

Are  there  any  inconsistencies/overlaps/gaps 
between  the  Directive  and  other  interventions 
at  the  international  level  (e.g.,  Sustainable 
Development Goals)?  
Are there any synergies to explore? 

68 

 
Evaluation Questions 

Subquestions 

Indicators 

Judgment criteria 

Data sources  Analytical 
approach 

o  Are there any inconsistencies/overlaps/gaps 
between the Directive and national policies at 
the MS level?  
o  Are there any synergies to explore? 

Will  EU  wider  policy  goals  and  priorities  of  EU 
citizens  (e.g.,  European  Green  Deal,  carbon 
neutrality 
ambition, 
realisation  of  the  internal  market,  European 
road  safety  goals,  etc.)  change  the  relevance 
of the objectives of the Directive? If so, how? 

zero-pollution 

and 

EU added value 

Evaluation Questions 

Subquestions 

Indicators 

Judgment criteria 

Data sources 

Analytical approach 

Evidence  provided  by 
text stakeholder assessment. 

free 

The  presence  or  absence  of 
relevant evidence 

 
 

PC 
Surveys  & 
with MS 

Qualitative 

interviews 

EQ 17: What is the 
additional value of the EU 
Directive compared to 
what could have been 
achieved by Members 
States at national and 
/or regional and 
international level?  

the 

Could 
different 
objectives  of  the  Directive 
safety, 
(i.e., 
road 
and 
infrastructure  wear 
cost  and 
tear, 
logistics 
performance 
and 
environmental  performance) 
be  attained  in  the  same 
manner  in  the  absence  of  a 
regulatory framework?  
Would 
regulatory 
a 
framework  at  national  or 
regional  level  work  equally 
well,  or  better,  as  an  EU 
framework?  

69 

 
EQ 18: To what extent 
would it have been 
possible to reach the 
same results without the 
EU Directive? 

(i.e. 

Could  the  different  goals  of 
the  Directive 
road 
safety,  infrastructure  wear 
and  tear,  logistics  cost  and 
and 
performance 
environmental  performance) 
be  equally  well  attained  by 
means  of  a  different  kind  of 
EU  intervention  (e.g.,  by  a 
non-binding framework)? 

Evidence  provided  by 
text stakeholder assessment 

free 

The  presence  or  absence  of 
relevant evidence 

 
 

PC 
Surveys  & 
with MS 

Qualitative 

interviews 

70 

 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

Table 1: Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

Quantitative   Comment 

Quantitative  

Comment 

Quantitative  Comment  

COSTS 

Fees permit range  

€40 - € 1000   

No 
quantitative 
evidence   

Not known 
whether and to 
what extent the 
cost of permit is 
passed on the client 

Direct compliance 
costs (adjustment costs, 
administrative costs, 
regulatory charges) 

Permits for 
abnormal 
transport 

No 
quantitative 
evidence 

National requirements for 
a permit and 
administrative procedures 
related to assessing an 
application and issuing the 
permits differ significantly 
between MS.  

The costs of national 
permits for abnormal 
transport diverge 
significantly between MS 
depending on many 
factors (duration of 
permit, type of load, 
vehicle, etc.) The time of 
administrative procedures 
to get the permit ranges 
from 1 to 12 weeks.  

Transposition 
costs 

No costs for 
citizens 

No quantitative 
evidence 

Operators have not 
claimed any specific 
changes in their business 
models and related costs 

No 
quantitative 
evidence 

No information available 
from MS to estimate the 
time dedicated to 
preparing and adopting 

71 

 
 
 
 
 
 
  
 
 
 
 
No evidence 
of costs for 
citizens 

No evidence of 
costs 

Road 
infrastructure 
costs due to 
increase of 
weight to 44t 

No evidence 
of costs for 
citizens 

Costs of 
Weigh-In-
Motion 
systems 

to implement the 
Directive’s provisions 

It is not known whether 
and to what extent the 
cost of upgrade and 
maintenaceof 
infrastructure is passed 
on road transport 
operators using 44t 
HDVs 

transposing measures and 
to dealing with 
infringement  procedures 
launched by the 
Commission for delays in 
transposition or non-
conformity 

Not known what share of 
costs of upgrade and 
maintenance of 
infrastructure can be   

There is no available 
information on a number 
of WIMs deployed in MS 
and the costs incurred 

Estimates 1.7 
bln for EU-27 
that is 

Increase by 
10%  

DK €20 mln  

DE €4-8 mln 

Price of 
technology 
ranges 
between 
€60.000-
120.000 

Inspections   No costs for 

Fines for 

Costs of non-compliance  Equivalent of  Costs of inspections 

72 

Enforcement costs:  
(costs associated with 
activities linked to the 
implementation of an 
initiative such as 
monitoring, inspections 
and 
adjudication/litigation) 

 
 
 
 
 
 
 
citizens 

12.6 mln 
controls in 
2019-2020  in 
19 MS who 
submitted data 

difficult to estimate as 
roadside controls of 
vehicles’ weight are 
typically combined with 
controls of compliance 
with other rules such as 
roadworthiness or social 
rules (e.g. driving time and 
rest periods of drivers).  

and of delays in operation 
due to the roadside 
controls are difficult to 
estimate. Roadside 
controls of vehicles’ 
weight are usually 
combined with controls 
of compliance with other 
rules such as 
roadworthiness or social 
rules (e.g. driving time 
and rest periods of 
drivers). It is thus not 
possible to estimate how 
much time of a roadside 
control is dedicated 
specifically to controlling 
weight.  

No evidence of the total 
amount of fines issued 
for overloaded vehicles.  

overloaded 
vehicles range 
from € 200 to 
7.500 

17 mln vehicles 
stopped for 
controls in 2019-
2020 (in 19 MS 
who reported) 
where 3% 
overloaded. 

Based on the 
above estimated 
cost of non-
compliance in 
2019-2020 ranges 
between €100mln 
and €3.8 bln 

BENEFITS 

Direct benefits (such as 
improved well being: 
changes  in pollution 
levels, safety, health, 

Traffic 
congestion and 
road 

No 
quantitative 
evidence 

Less HDVs on the 
roads in MS 
allowing for High 
Capacity Vehicles 

No quantitative 
evidence 

Less time lost in traffic 
jams in MS where the 
traffic of HDVs reduced 

No 
quantitative 
evidence 

Possible less maintenance 
costs due to the 
harmonised limits for total 
weight and weight per 

73 

 
 
 
 
 
 
employment; market 
efficiency) 

infrastructure 

(HCVs). 

due to the use of HCVs  

axle.  

Better road 
infrastructure in the 
MS who upgraded 
it for HCV traffic 

No information 
whether the cost 
savings resulting 
from less fuel 
consumption have 
led to lower 
transport price for 
consumers 

No information 
whether the cost 
savings resulting 
from less fuel 
consumption have 
led to lower 
transport price for 
consumers 

No evidence 
of economic 
benefits for 
citizens  

More Energy 
consumption 
reduction 

No evidence 
of economic 
benefits for 
citizens 

Operational 
cost savings 

Energy consumption 
savings reported in nine 
MS that allow EMS 

Reduction in 
energy 
consumption 
by 15-30% 

Reported in nine MS 
allowing EMS 

Reduction in 
energy 
consumption by 
15-30% leading 
to less 
operational costs 

One-third less 
driver needed in 
MS allowing 
EMS. 

Savings reported only in 
MS allowing for HCVs in 
their territories and for 
operators using HCVs 

No evidence 
of economic 
benefits 

FI estimates 126 
mln in cost 
savings due to 
225 mln km 
avoided (in 2013-
2017) thanks to 
the use of EMS 

74 

 
 
 
 
 
 
 
 
Increase of 
alternatively 
fuelled medium 
and heavy duty 
vehicles (yearly 
registration 
figures) from 
0.5% in 2016 to 
6.6% in 2020 

No quantitative 
evidence 

11% less 
CO2 
emissions per 
transported 
tonne 

14% less 
NOx-
emissions 

No 
quantitative 
evidence 

Air pollution 
reduction 

Less risks to 
road safety  

These estimated 
reductions concern 
the  use of HCVs 
in MS that allow 
them on their 
territories 

Less road safety 
risks due to 
uniform maximum 
weight and 
dimension limits 
and the use of 
HCVs on dedicated 
parts of road 
network (no 
exposure of 
vulnerable road 
users, etc)  

Less risk also 
linked with less 
traffic by HDVs in 
MS allowing HCV  
and more 
experienced drivers 

75 

Difficult to assess savings 
linked to the avoidance of 
potential accidents and 
increases in insurance 
costs; 

No 
quantitative 
evidence of 
lives and 
accident costs 
saved due to 
avoidance of 
accidents  

Not possible to 
disaggregate the general 
road safety statistics to this 
level granularity so as to 
assign certain part of 
savingst o the WDD 
directive 

 
 
 
 
 
 
 
and newer/safer 
vehicles  

No 
quantitative 
evidence  

Growth of 
intermodal 
transport 

Indirect benefits (such 
as wider economic 
benefits, 
macroeconomic 
benefits, social 
impacts, 
environmental 
impacts) 

Reduction in 
Modal Shift 
Potential by -
13% 

Growth in 
transport of 
loaded and 
unloaded 
containers from 
15mln TEU in 
2009 to 24 mln 
TEU in 2019. 

Increase  in 
transport of 45-
foot containers 
from 1% of 
domestic 
combined 
transport and 3% 
of international 
combined 
transport in 2017 
to 10% and 11%, 
respectively 

76 

 
 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

Synopsis Report — Weights and Dimensions Directive Evaluation SWD 

This annex provides a summary of the outcomes of the consultation activities carried out 
for  the  review  of  the  WDD,  including  in  the  context  of  the  external  support  study.  It 
notes the range of stakeholders consulted, describes the main consultation activities, and 
provides a succinct analysis of the stakeholders’ views and the main issues they raised. 
The full  analysis of the  consultation  results is  presented in  the stakeholder consultation 
report annexed to the final report of the support study. 

In  the  context  of  the  preparation  of  a  back-to-back  ex-post  evaluation  and  impact 
assessment, four types of consultation activities were performed. The purposes of these 
activities were: 

 

 

 

to collect information and opinions of stakeholders on the main issues related to 
the implementation of the WDD, key problems and their drivers as well as on the 
desirable changes to the regulatory framework; 
to  gather  specialized  input  (data  and  information,  expert  views)  on  specific 
aspects of the regulatory framework;  
to gather information and views on potential impacts of different policy measures. 

1.  OVERVIEW OF CONSULTATION ACTIVITIES 

Consultation activities took place in 2022 with the following activities carried out: 

  A consultation on the Call for Evidence89 (CfE) (21 January 2022 to 21 February 

2022), 

  An open public consultation90 (OPC) (26 April 2022 to 19 July 2022) 
  A  survey  targeted  to  different  stakeholder  groups  (19  September  2022  to  13 

October 2022), 

  Two  workshops,  one  targeted  at  industry  stakeholders,  one  targeted  at  Member 

States (15 December 2022 and 16 December 2022). 

In  addition,  a  number  of  bilateral  and  multilateral  meetings  with  different  stakeholders 
(from road, rail, combined transport sectors, truck manufacturers, business associations, 
road infrastructure authorities, national authorities)  have taken place and several position 
papers received and analysed throughout the year 2022 and in the first quarter of 2023.  

89 

90 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13278-Commercial-vehicles-

weights-and-dimensions-evaluation-/feedback_en?p_id=27827305 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13278-Commercial-vehicles-

weights-and-dimensions-evaluation-/public-consultation_en 

77 

 
 
 
 
 
                                                           
2. 

STAKEHOLDER GROUPS CONSULTED 

The following stakeholder groups were targeted by the consultation strategy, which was 
created by the Commission services at the outset of the process: 

High-level 
stakeholder group 

Description 

Road infrastructure 
authorities 

Infrastructure  managers  are  responsible  for 
directing  traffic  flows,  ensuring  the  maintenance 
of  existing  and 
the  development  of  new 
infrastructure.  They  also  gather  data  for  official 
statistics  or  conduct  analyses  in  relevant  areas, 
particularly  with 
infrastructure 
regards 
protection and development, intermodal transport 
and road safety. 

to 

Road transport 
undertakings (freight 
and passenger 
transport operators)  

Road  transport  undertakings  are  responsible 
for  providing  actual 
transportation  services 
(carriage  of  goods  or  of  passengers).  Their 
responsibilities 
their 
vehicles  are  roadworthy  and  complying  with  the 
applicable  regulations  and  providing  reliable  and 
their 
efficient 
customers.  

include  ensuring 

transportation 

services 

that 

to 

combination  of  both.  Road 

Business associations   Business  organisations  represent  the  interests  of 
their  members  who  are  usually  companies 
engaged in transportation of goods by road, rail or 
a 
transport 
associations  represent  companies  that  operate 
HDVs  for  transporting  goods  or  passengers  by 
road.  Rail 
represent 
companies  that  operate  trains  for  transporting 
goods  by  rail.  Combined  transport  associations 
represent  companies  that  provide  transportation 
services using a combination of road and rails. All 
those  associations  advocate  for  the  interests  of 
their  members  by  lobbying  for  better  regulatory 
framework, infrastructure , fair competition.   

transport  associations 

Stakeholder 
engagement 
activity 

CfE 

OPC 

Survey  

CfE 

OPC 

Survey 

Workshop 

CfE 

OPC 

Survey 

Workshop 

Shippers  

the 
Shippers  are  responsible  for  arranging 
transportation  of  goods  by  road.  They  are, 
usually,  the  ones  who  contract  with  the  road 
transport  undertakings  to  transport  their  goods. 
Shippers’  responsibilities  include  packing  goods, 
providing  accurate  information  about  the  goods 
and  ensuring  that  all  the  documentation  is  in 
order. 

CfE 

OPC 

Survey 

78 

 
 
High-level 
stakeholder group 

Description 

Forwarders; 

EU  Member  States 
national authorities  

and 

Forwarders  are  responsible  for  managing  the 
transportation  of  goods  by  road  on  behalf  of 
shippers.  They  act  as  intermediaries  between 
shippers 
transport  undertakings, 
coordinating  the  transportation  of  goods  from 
start  to  finish.  Their  responsibilities  include 
negotiating rates with road transport undertakings 
arranging  for  the  pickup  and  delivery  of  goods 
and managing all necessary documentation. 

road 

are 

responsible 

National  authorities 
for 
transposing,  implementing  and  enforcing  WDD. 
The  national  authorities’  responsibilities  include 
managing  national  registries    of  road  transport 
undertakings and of commercial vehicles, issuing 
permits,  authorisations,  granting  derogations, 
the  safety  measures  and  ensuring 
adopting 
compliance with all the relevant EU and national 
legislation  applicable  to  the  commercial  road 
transport sector.   

Stakeholder 
engagement 
activity 

CfE 

OPC 

Survey 

CfE 

OPC 

Survey 

Workshop 

HDV manufacturers 
and OEMs (Original 
Equipment 
Manufacturers)  

Other 
stakeholders 
society, 
academia) 

relevant 
(civil 
NGOs, 

Manufacturers  of  HDV  and  manufacturers  of 
their  equipment  (components,  systems  needed 
tobuild  a  complete  vehicle),  supplying  road 
transport  operators  with  the  needed  machinery 
and  being  bound  by  the  WDD  regarding  the 
design of their products. 

organisations, 

Other  relevant  stakeholder  groups  include 
consumer 
non-governmental 
organisations  (NGOs)  and  academic  experts/ 
research  and  knowledge  partners  (public  and 
private  organisations).  They  provide  additional 
sectoral  viewpoints  and  help  us  understand  the 
details  of  the  measures  and  policy  options, 
including  in  terms  of  achieving  environmental 
policy  objectives,  and  what  impacts  could  affect 
the industry, the consumers and the environment. 

CfE 

OPC 

Survey 

CfE 

OPC 

Survey 

Citizens 

Although  representing  a  rather  small  group  of 
stakeholders,  Citizens  of  the  EU  were  able  to 
provide their contribution during the evaluation. 

CfE 

OPC 

3.  CONSULTATION ACTIVITIES—METHODOLOGY AND TOOLS 

The Call for Evidence focused on collecting information and views to support the work 
on the evaluation of the WDDand the impact assessment for its revision. More than 98% 

79 

 
 
 
 
 
of  respondents  were  the  stakeholders  from  the  EU  Member  States,  and  4  contributions 
were  received  from  the  stakeholders  from  non-EU  countries.  The  big  part  of 
contributions came from Germany and Belgium (25% and 21% respectively). 

Stakeholder category 

Number of responses  % of responses* 

Companies and businesses 
Business associations 
EU citizens 
Public authorities 
NGOs 
Trade Unions 
Other 
TOTAL 
*Does not add up to 100% due to rounding 

88 
84 
28 
7 
5 
3 
9 
224 

39.3% 
37.5% 
12.5% 
3.1% 
2.2% 
1.3% 
4.0% 
100% 

The OPC focused on collecting views and information in order to identify problems and 
their  drivers,  define  objectives  of  the  revision  and  identify  potential  solutions  to  the 
problems. The OPC questions were prepared in order to identify gaps, which would then 
be addressed in the following survey and workshops. 

In total, 132 participants responded to the OPC, representing a rather high response rate 
considering  that  more  specialized  consultation  activities  were  also  conducted.  Not  all 
respondents answered every question, which is why the number of respondents is lower 
than 132 in all cases, with commonly around 125 answers to each question. The majority 
of  the  respondents  are  professionally  related  to  road  transport,  including  the  citizens. 
More  details  about  the  results  of  the  OPC  are  available  in  the  Factual  Summary  report 
available  on  the  Commission’s  Have  your  Say  website,  and  the  consultation  report 
forming part of the impact assessment support study. 

Stakeholder category 

Number of responses  % of responses 

Business associations 
Companies/Business associations 
Public authorities 
EU Citizens 
NGOs 
Trade unions 
Consumer organizations 
Non-EU citizens 
TOTAL 
*Does not add up to 100% due to rounding 

58 
53 
9 
3 
3 
3 
1 
1 
132 

44.0% 
40.1% 
6.9% 
2.3% 
2.3% 
2.3% 
.75% 
.75 
100% 

The  online  stakeholder  survey  was  developed  to  gather  information  to  validate  the 
problem  definition  and  the  objectives  of  the  policy  intervention,  and  to  obtain  input  to 
further define the policy measures and options. Major parts of the survey were focused 
on  obtaining  the  data  needed  to  support  the  assessment  of  impacts  of  measures  and 
expected costs. The survey addressed mainly to infrastructure managers, manufacturers, 

80 

 
national  authorities  and  enforcement  agencies,  transport  operators,  and  other  road 
(transport) stakeholders. 

Stakeholder category 

Number of responses  % of responses 

Operators  
National authorities and enforcement agencies  
Infrastructure managers 
Manufacturers 
Other road stakeholders 
TOTAL 
*Does not add up to 100% due to rounding 

24 
21 
14 
9 
63 
131 

18.3% 
16.0% 
10.7% 
6.9% 
48.0% 
100% 

Subsequently,  two  stakeholder  workshops  were  organised,  separately  for  industry 
stakeholders and for Member States’ administrations. The industry stakeholder workshop 
was attended by 171 participants representing: EU road hauliers, passenger road transport 
operators, shippers, rail industry, transport and trade associations, transport trade unions, 
automotive  industry,  road  authorities,  homologation  bodies,  tachograph  manufactures 
and others. The Member States workshop was attended by 53 participants representing: 
transport  and  infrastructure  ministries,  road  authorities,  transport  agencies  from  21 
Member  States.  The  participants  provided  answers  to  questions  posed  via  an  online 
polling tool following the presentation  of the WDD’s  policy  context  and aspects  of the 
revision to achieve the policy objectives. 

The stated objectives of the WDDwere:  

  Ensuring the free movement of goods 
  Ensuring equal conditions of competition in the internal (intra-EU) road transport 

market 

  Protecting the road infrastructure 
  Ensuring road safety 
 
 

Improving working conditions for HDV drivers 
Improving energy efficiency and reducing GHG emissions in road transport 

4.  LIMITATIONS OF THE STAKEHOLDER CONSULTATION 

It was particularly difficult to gather robust data on the direct and indirect costs arising 
from the WDD. Stakeholders were asked to comment on how they might be impacted by 
the  various  proposed  measures,  but  they  were  rarely  able  to  provide  estimates  on  the 
monetised  costs  and  benefits.  The  limitations  regarding  data  availability  affected 
somewhat a robustness of certain conclusions.  

The policy measures were further refined after they were presented to some stakeholder 
groups. Therefore, not all stakeholder groups were consulted on the wording used in the 
impact assessment. Nevertheless, the nature of the measures and their essential elements 
did not change. 

5.  FEEDBACK RECEIVED 

The  key  themes  explored  in  the  first  three  stakeholder  consultation  activities  largely 
the  evaluation  matrix,  namely  effectiveness 
followed 

the  various  elements  of 

81 

 
 
(specifically,  implementation  of  the  internal  market,  road  safety  and  protection  of 
infrastructure, energy efficiency and emissions, compliance, and derogations), efficiency, 
relevance, coherence, and EU-added value. 

Problem definition and objectives 

The key objectives of the WDD revision were grouped into three areas: 

  Decarbonisation:    Boost  uptake  of  ZEV  &  energy-saving  technologies  and 

incentivise intermodal transport 

  Harmonisation:  Remove  barriers  to  cross-border  operations  while  ensuring  fair 

competition in the internal market 

  Enforcement:  Improve  compliance  with  the  EU  rules  to  ensure  road  safety  and 

fair competition 

While  the  CfE  and  OPC  focused  on  the  problem  at  a  broader  level,  the  survey  and 
workshops took a more detailed and systematic approach to specifying the problems and 
associated objectives for the revision of the WDD.  

A common theme in the feedback to the CfE was a lack of uniform EU rules regarding 
cross-border transport between Member States allowing longer and heavier HDVs under 
the current Weights and Dimensions Directive. The need for harmonisation of this issue 
was mentioned more than 80 times in the 224 submissions. Respondents also raised the 
issue of missing alignment with other EU directives and regulations. 

Coherence. In the OPC, the respondents were asked detailed questions about perceived 
problems. One major issue identified by respondents was lacking coherence: 65 out of 
123 stakeholders (53%) perceived problems with internal coherence and in particular the 
inconsistency in the rules applicable to cross-border traffic of 44 t HDVs (see below).  

Public consultation: Q9: In your view, are there any contradictions or inconsistencies between the different 
rules of the Directive? (N = 123) 

Source: W&D Directive OPC, 2022 

The issue most often mentioned by the stakeholders in the qualitative follow-up question 
relates  to  the  fact  that  the  current  Directive  has  not  achieved  a  sufficient  level  of 
harmonisation across Member States because of excessive scope for national derogations. 
While  64  out  of  122  participants  assessed  that  the  WDD  is  coherent  with  other  EU 
policies  (external  coherence),  49  respondents  (out  of  122)  claimed  the  opposite, 
especially  regarding  the  relations  to  European  Green  Deal,  the  Combined  Transport 
Directive, EU-type approval and driving time and rest periods (see below). One concern 

82 

 
 
stressed  was  that  the  WDD  would  put  other,  more  sustainable  modes  of  transport  in  a 
competitive disadvantage, ultimately contributing to reverse modal shift.  

Public  consultation: Q 10: In your view, is the Directive consistent with other EU  policies and objectives (e.g. 
European Green Deal, sustainable and smart mobility strategy, the EU road safety policy framework 2021-2030, 
legislation  on  the  type  approval  of  road  vehicles,  Combined  Transport  Directive)  and  other  international 
initiatives (e.g. Sustainable Development Goals)? (N = 122) 

Source: W&D Directive OPC, 2022 

Effectiveness.  Respondents  also  identified  the  WDD’s  failure  to  effectively  address 
energy  efficiency  of  road  transport.  Many  respondents  (80  of  131)  answered  that  the 
Directive  is  ‘ineffective’  or  ‘very  ineffective’  in  this  respect.  A  majority  of  the 
infrastructure  managers,  manufacturers,  national  authorities  and  enforcement  agencies 
and operators consider that the WDD helped to ensure fair conditions of competition in 
the  provision  of  transport  services  in  the  EU.  They  often  referred  to  the  need  to  have 
common market rules for heavy goods transport. However, some respondents disagreed, 
e.g. one authority arguing that the WDD was inimical to abnormal sized indivisible load 
transports. Three national authorities responding to the OPC referred to the risk of modal 
shift towards road transport from more sustainable modes and to the specific allowances 
for  zero-emission  vehicles  that  they  still  considered  insufficient.  9  of  63  (14%)  road 
stakeholders  believed  that  the  WDD  facilitated  the  development  of  alternative-fuel  and 
zero-emission technologies for HDV moderately (6) or very much (3), whereas 4 think it 
hindered  it  slightly  (3)  or  even  very  much  (1).  8  other  road  stakeholders  (13%  of  all 
stakeholders)  think  that  the  WDD  has  not  facilitated  nor  hindered  the  development  of 
alternative-fuel and zero-emission technologies. Road transport operators seemed not to 
have  extensive  experience  with  ZEV,  as  only  one  reported  the  on-going  pilot  projects. 
Two  manufacturers  consider  that  the  WDD  has  supported  the  development  of  zero-
emission  HDVs  by  granting  them  an  extra-weight  allowance.  However,  the  lack  of 
flexibility on axle-loading is limiting potential vehicle designs. The length limits are also 
creating issues for fuel cell electric trucks that require space for hydrogen storage. With 
today’s directive, fuel cell trucks need to use shorter trailers or to reduce cargo space and 
payload to accommodate hydrogen tanks.  

As regards the impacts  of WDD on promoting intermodal  transport, 17 stakeholders of 
24  (71%)  who  expressed  an  opinion  (2  infrastructure  managers,  1  manufacturer,  1 
national authority, 3 operators and 10 other road stakeholders) responded that the WDD 
facilitated  intermodal  transport  at  least  moderately,  while  the  remaining  7  of  24  (29%) 
stated that the WDD has hindered intermodal transport at least slightly. The remaining 95 
participants from all stakeholder categories did not express any opinion. 

83 

 
 
In terms of effectiveness in general, the OPC respondents mostly perceived the WDD’s 
standards  “effective”  or  “very  effective”  in  the  dimensions  of  the  free  movement  of 
goods,  road  infrastructure  and  road  safety,  and  to  a  lesser  extent  in  equal  competition, 
working conditions, and energy and emissions (see below). 

Public consultation: Q3: In your view, how effective are the standards set out under the Directive in achieving 
the following objectives? 

Source: W&D Directive OPC, 2022 

Efficiency. As to the efficiency of the Directive, 27 out of 123 (22%) respondents in the 
OPC  considered  the  costs  of  implementation  of  the  Directive  as  reasonable  and 
proportional to the benefits. 35 out of 123 respondents found that the costs of applying 
the  Directive  significantly  outweigh  the  benefits.  However,  most  of  the  surveyed 
stakeholders did not express their opinion about  the efficiency criterion. Four operators 
(out  of  24  who  responded)  referred  to  the  administrative  burden  that  is  related  to  the 
different  authorisations  required  to  operate  vehicles  in  different  Member  States  and 
sometimes  within  Member  States,  in  particular  for  EMS  combinations  and  abnormal 
transport.  

Public consultation: Q5: What do you think about the costs caused by the application of the Directive? (n=125) 

27

35

19

27

15

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Costs are reasonable and proportional to the benefits

Costs significantly outweigh the benefits

Costs slightly outweigh the benefits

I don’t know

I have not witnessed significant costs

Source: W&D Directive OPC, 2022 

Moreover, 38% of respondents (46 of 122) perceived a potential for a reduction of costs 
arising  from  the Directive, while 27% disagreed  and 35% could  not  provide an answer 
(see  below).  The  main  aspects  mentioned  for  these  costs  reductions  concerned  the 
harmonisation  of  rules/set  of  common  rules,  especially  for  exceptional  transport,  as  all 

84 

 
 
 
differences  imply  additional  bureaucracy  and  costs;  administrative  simplification  by 
digitising the processes for both carriers and the competent authorities; increased use of 
high  capacity  vehicles  will  optimise  load  capacity,  reduce  fuel  consumption  and 
emissions; and allowing bilateral agreements for cross-border allowing higher weights. 

Public consultation: Q6: Do you think it is possible to reduce costs caused by the Directive? (n=124) 

46

33

43

0%

10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Yes

No

I don't know

Source: W&D Directive OPC, 2022 

Relevance.  Regarding  the  relevance  criterion,  the  respondents  were  asked  concerning 
the stated objectives of the WDD, being: 

  Ensuring the free movement of goods 
  Ensuring equal conditions of competition in the internal (intra-EU) road transport 

market 

  Protecting the road infrastructure 
  Ensuring road safety 
 
 

Improving working conditions for HDV drivers 
Improving energy efficiency and reducing GHG emissions in road transport 
Most of the respondents found the objectives of the WDD still very relevant, whilst no 
more than 20 out of the 126 respondents found at least one of the objectives mentioned 
above  no  longer  relevant,  with  the  lowest  relevance  acknowledged  for  working 
conditions (see below). The main topics that should be addressed by a revised Directive 
are  new  technologies  and  innovations,  intermodality  of  transport  (especially  rail  and 
road), sustainability (especially alternatively fuelled vehicles) and the cross-border aspect 
of road transport.  

Public  consultation:  Q7:  In  your  view,  are  the  Directive’s  objectives  still  relevant  in  addressing  current  and 
emerging needs and challenges? 

Source: W&D Directive OPC, 2022 

EU  added  value.  Regarding  the  EU  added  value  criterion,  the  OPC  results  show  that 
most  respondents  fully  agreed  on  EU  action  is  being  essential  for  the  dimensions  of 
effective cross-border  cooperation, reduction of  GHG emissions in  the transport sector, 

85 

 
 
 
 
improving environmental performance of road transport, results in the context of weights 
and dimensions for HDV, as well as road safety, with only a maximum 8 out of 124 of 
the respondents fully disagreed for any of the topics. Most fully agreeing opinions were 
expressed  regarding  the  essentialness  of  effective  cross-border  cooperation,  lowest  on 
road safety (see below). 

Public consultation: Q11: To what extent do you agree with the following statements: EU action is essential: 

Source: W&D Directive OPC, 2022 

The survey, following the OPC, revealed more detailed insights. Regarding the design of 
truck cabins, 3 manufacturers confirmed having introduced more aerodynamic, safer, and 
more  comfortable  cabs,  with  one  underlining  that  the  2015  amendments  to  WDD  were 
crucial for this development, also regarding the higher weight of battery electric trucks. 
One  road  transport  operator  mentioned  that,  even  though  the  WDD  did  integrate 
aerodynamic  devices,  in  practice,  such  devices  have  not  been  taken  up  by  the  market. 
Most  vehicles  have  not  been  retrofitted  while  main  producers  of  semi-trailers  have  not 
integrated this device as standard equipment in their production. One manufacturer does 
not  notice  any  increase  of  market  uptake  of  aerodynamic  devices  and  indicates  that  no 
quantitative information is available yet.  In terms of alternative powertrains, 9 of 63 road 
stakeholders (14%) believe that the WDD has facilitated the development of alternative-
fuel and zero-emission technologies for HDV moderately (6) or very much (3), whereas 
4 think it hindered it slightly (3) or even very much (1). 8 other road stakeholders think 
that  the  WDD  neither  facilitated  nor  hindered  the  development  of  alternative-fuel  and 
zero-emission  technologies.  42  respondents  of  these  63  did  not  provide  any  opinion 
(66%). Only one operator confirmed the usage of ZEV, while another stated that ZEV are 
not available.  

Most of the infrastructure managers, manufacturers, national authorities and enforcement 
agencies  and  operators  consider  that  the  WDD  helped  to  ensure  fair  conditions  of 
competition in the provision of transport services in the EU. They often refer to the need 
to  have  common  market  rules  for  heavy  goods  transport.  However,  some  respondents 
disagree,  e.g.  one  authority  arguing  that  the  WDD  was  inimical  to  abnormal  sized 
indivisible  load  transports.  Regarding  enforcement,  4  manufacturers  state  that  OBW  is 
not preferred as automated control via infrastructure sensor technology is more efficient. 

86 

 
 
 
Lastly, none of the participating operators stated that national weight derogations and/or 
trials of EMS resulted in modal shifts. They pointed out that their experience showed that 
longer and heavier trucks mainly replace conventional trucks (i.e., reducing the number 
of trucks used rather than substituting other modes), or the recourse to other modes not 
being possible due to  the type of good being transported. 4 operators stated that longer 
and  heavier  vehicles  are  more  environmentally  efficient,  and  4  national  authorities 
reported  successful  trials  at  improving  road  energy  efficiency  and  reducing  GHG 
emissions from transport. 8 other road stakeholders agreed on that observation.  

The workshops revealed that the majority of participants are mainly concerned about the 
legal uncertainty on the rules applicable to cross-border transport and diverging level of 
enforcement, which should be addressed by the revision (3.60 points out of 5 in polling 
system).  

Overall,  the  stakeholders  confirmed  the  identified  problems  and  their  European 
dimension and supported broadly the objectives for the revision of the WDD. 

Potential solutions 

The stakeholder consultations also suggested potential solutions to the identified problems.  

The CfE responses focused on the measures needed to facilitate cross-border operations 
and  the  usage  of  the  EMS.  Most  respondents  expressed  support  for  the  initiative 
(especially  business  associations  and  companies).  Moreover,  support  for  weight 
adjustments and incentives for ZEV were generally agreed upon. Stakeholders called for 
more  than  the  currently  allowed  additional  2  tons  to  accommodate  ZE  powertrains, 
reminding  about  the  battery  placement  in  relation  to  the  truck’s  cabin.  The  need  for 
additional measures to promote intermodal transport (e.g. by allowing increased loading 
capacity),  and  ensuring  interoperability  of  HDV  was  acknowledged.  However,  some 
stakeholders  argued  against  a  possible  increase  to  the  allowed  weight  to  44  t  as  this 
would  eliminate  the  exemption  that  is  provided  so  far  for  combined  transport.  Others 
suggested that the WDD should focus on additional weight and/or length allowances for 
ZEV  to  accommodate  the  technology  needed.  In  the  survey,  5  manufacturers  indicated 
that flexibility to axle loads, additional weight allowances and length derogations should 
be provided to better accommodate the new powertrain technologies.  

Agreement  prevailed  regarding  the  need  for  harmonisation  of  the  rules  between 
Member  States.  Most  stakeholders  seem  to  support  the  principle  that  transport  across 
borders  should  be  allowed  automatically  if  the  vehicle  weights  or  dimensions  do  not 
exceed the smallest of the values that are applicable in the individual Member States.  

Regarding the alignment of maximum weights and dimensions to the most common limits 
currently  allowed,  the  stakeholders  presented  different  levels  of  agreement.  Some 
stakeholders supported an increase of the maximum weight to 44 t for the traffic on the entire 
EU road transport network, or at least along the TEN-T core and comprehensive network. 
Moreover, some stakeholders advocated an extension of the maximum permissible weight to 
60  t  and/or  an  extension  of  the  permitted  length  to  25.25  m,  while  others  opposed  this 
increase mainly due to the risk of reverse modal shift. Moreover, a few stakeholders indicate 
that the use of high-capacity vehicles should not be tied to alternative fuels or zero emissions 
as  it  could  lead  to  negative  effects  otherwise.  Some  suggestions  for  additional  measures 
could  not  be  taken  into  consideration,  as  they  are  being  addressed  by  other  Commission 
initiatives, or are not within the scope of the WDD revision. 

87 

 
All  manufacturers  acknowledged  the  need  for  a  further  extension  of  the  WDD’s 
provisions  regarding  cab  design.  Implementing  the  flexibilities  provided  by  the  2015 
revision of the WDD is, according to the manufacturers, instrumental for development of 
future  generation  of  trucks.  Manufacturers  stated  that  aerodynamic  components  and 
packages  improve  transport  energy  efficiency,  and  the  required  robustness  of  such 
systems brings with it an additional mass which, given the investment required to acquire 
it, should not also have a negative impact on payload. 

Two  manufacturers  further  referred  to  the  obligation  resulting  from  the  WDD  that 
Member States should take specific measures to identify vehicles that are likely to have 
exceeded weight limits, i.e. weighing mechanisms in the road infrastructure (WIM). 

The  poll  launched  within  the  two  workshops  after  the  presentation  revealed  the  most 
supported  policy  measures  in  different  dimensions  perceived  by  industry  and  Member 
States stakeholders. The following figures explore the direct comparison of the workshop 
polls and the assessment of the policy measures through the stakeholders  

Addressing decarbonisation measures, Member States stakeholders supported to allow 
44t if ZEV (4/5 points), extra length/weight to accommodate for ZE technologies (3.9/5 
points), and extra weight for ZE technologies in all vehicles and units (trailers, dollies, all 
trucks and buses) (3.7/5 points) the most. A similar picture emerged from the poll among 
industry  stakeholders,  who  also  supported  extra  length/weight  to  accommodate  for  ZE 
technologies  (3.64  points  out  of  5)  and  to  allow  44  t  for  ZEV  (3.17/5),  though  valuing 
extra  weight  to  accommodate  for  ZE  technologies  regardless  the  weight  of  the 
technology  higher  (3.28/5  points)  than  Member  States.  The  remaining  policy  measures 
were rated comparably. 

Ratings  of  Industry  Stakeholders  and  Member  States  Stakeholders  regarding 
decarbonisation policy measures, 0 = less effective, 5 = more effective. 

Decarbonisation Policy Measures

Extra length/weight to accommodate for ZE technologies

Extra weight regardless of ZE technology weight*

Allow 44t if ZEV

Allow EMS1 in TEN-T network for ZEV

Allow EMS2 in TEN-T network for ZEV

Extra weight for ZE technologies in all vehicles and units

Extra height to accommodate high-cube containers

Mandatory aerodynamic devices

Allow EMS1 in TEN-T network for IT

Allow EMS2 in TEN-T network for IT

0

0,5

1

1,5

2

2,5

3

3,5

4

4,5

MS Stakeholder

Industry Stakeholder

*Extra weight to accommodate for ZE technologies regardless the weight of the technology 

Source: W&D Directive Workshop Poll, 2022 

88 

 
 
 
Regarding  possible  harmonisation  policy  measures,  Member  States  and  industry 
stakeholders  rate  almost  every  measure  similarly,  only  Member  States  express 
considerably higher support for allowing 40 t for all 5- and 6-axle HDV (3/5 points vs. 
2.2/5 points) and, to a lesser extent, for cross-border transport of 44 t in TEN-T, whereas 
industry stakeholders expressed the highest support for cross-border transport of 44 t and 
EMS in allowing EMS (3.9/5 points). 

Ratings  of  Industry  Stakeholders  and  Member  States  Stakeholders  regarding 
harmonisation policy measures, 0 = less effective, 5 = more effective. 

Harmonisation Policy Measures

40t for all 5/6 axle HDV

Cross-border transport of 44t and EMS in allowing MS

Vehicle carrier loaded length of 20.75m

Common minimum requirements for indivisble load transport

Cross-border transport of 44t in TEN-T

Cross-border transport of EMS in TEN-T

Abnormal transport corridors for indivisible loads

0

0,5

1

1,5

2

2,5

3

3,5

4

4,5

MS Stakeholder

Industry Stakeholder

Source: W&D Directive Workshop Poll, 2022 

In  terms  of  enforcement  policy  measures,  both  Member  States  and  industry 
stakeholders  rated  the  minimum  level  of  weight  checks  at  2.8/5  points,  making  it  the 
second-most  supported  policy  options  through  both  stakeholders  after  the  measures  of 
having EMS to comply with latest safety standards, which is much more preferred by the 
Member  States  (3.9/5  points)  than  by  the  industry  (3/5  points).  Compared  to  industry 
stakeholders,  Member  States  also  signalized  more  support  for  higher  safety  standards 
than  foreseen  in  the  GSR  (2.9/5  points  in  contrast  to  2.1/5  points).  With  regard  to  the 
other  measures,  however,  the  assessments  of  industry  and  Member  States  stakeholders 
are on similar levels. 

89 

 
 
 
 
 
 
 
 
Ratings  of  Industry  Stakeholders  and  Member  States  Stakeholders  regarding 
enforcement policy measures, 0 = less effective, 5 = more effective. 

Enforcement Policy Measures

Minimum level of weight checks by MS

WIM for targeting controls every 300km in TEN-T

EMS to comply with latest safety standards

Voluntary implementation of intelligent access policies

Mandating heavier HDV with OBW

Professional requirements for EMS drivers

WIM for direct enforcement every 300km in TEN-T

EMS to comply with higher safety  standards than GSR*

0

1

2

3

4

5

MS Stakeholders

Industry Stakeholders

*GSR = General Safety Regulation 

Source: W&D Directive Workshop Poll, 2022 

Overall,  most  support  was  received  for  the  measures  related  to  increased  weight  limits 
for  ZEV  (e.g.  +2  tons  for  the  e-motor  vehicle  and  +2  tons  for  the  e-trailer),  the 
harmonisation of rules for cross-border traffic by longer/heavier HDVs among Member 
States  who  allow  such  vehicles  on  their  territories  and  the  harmonisation  of  the  rules 
related  to  the  abnormal  transport.  Less  support  was  shown  for  a  measure  on  a  general 
increase of the maximum authorised weight to 44 t, as this would eliminate the incentive 
that is provided for combined transport in the form of extra weight of 4t. To sum up, the 
workshop confirmed the need and broad support for accelerating the uptake of ZE HDV 
and  other  solutions  improving  operational  and  energy  efficiency  and  safety  of  road 
freight transport as well as enabling/increasing modal cooperation. 

6.  USE OF CONSULTATION RESULTS 

The results of the consultation activities were profoundly used as a source of information 
for the ex-post evaluation regarding issues perceived by stakeholders as problematic. In a 
similar  manner,  the  policy  measures  included  in  the  Impact  Assessment  for  analysis 
directly  reflect  the  suggestions  and  opinions  expressed  by  the  stakeholders  in  the 
consultation activities. Finally, the open public consultation was mostly used to validate 
the  Commission’s  understanding  of  the  problems  at  stake  and  of  the  most  adequate 
solutions thereto. The results overwhelmingly confirmed the Commission’s initial views 
and approach to the ex-post analysis and to the Impact Assessment. 

While  the  absolute  numbers  of  responses  to  each  of  the  consultation  activities  are 
varying,  they  must  be  seen  in  the  context  of  the  heterogeneous  road  transport  sector, 
which  provides  a  wide  range  of  specialized  transport  operations  and  is  divided  into  a 
number of, sometimes very small, transport market segments. Many stakeholders did not 

90 

 
 
 
decide to answer individually but contributed to the drafting of co-ordinated positions of 
industry representative organisations.  

Obviously, there were differences in the positions expressed in individual contributions, 
but  a  general  consensus  emerged  as  to  the  assessment  of  the  current  situation  and  the 
changes  to  be  made  to  the  legislation.  This  is  particularly  visible  in  the  answers  to  the 
open public consultation, where a clear majority opted for the same or similar answers to 
each question, e.g. regarding the WDD’s relevance for  addressing energy and emission 
issues, the added value for cross-border transport, or the existence of inconsistencies. 

This consensus is less clearly visible – at first sight – in the other consultation activities, 
but this is only because they allowed for free text answers. Detailed analysis of the latter 
confirmed,  however,  the  trend  of  answers  converging  to  common  positions  of  all 
stakeholder  groups.  This  convergence  is  certainly  the  result  of  a  high  degree  of 
organisation of the industry. 

91 

 
 
 
ANNEX VI. LETTER FROM FORMER VICE-PRESIDENT SIM KALLAS, 13 JUNE 2012  

92 

 
 
 
93 

 
 
94