COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT [ ] 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) 445 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  […] 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) 446 final} - {SWD(2023) 447 final}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 1 

PROBLEM DEFINITION .................................................................................................................... 6 

3.  WHY SHOULD THE EU ACT? .........................................................................................................24 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................25 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .....................................................................26 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................36 

7.  HOW DO THE OPTIONS COMPARE? .............................................................................................53 

8. 

PREFERRED OPTION .......................................................................................................................57 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?...................................60 

ANNEX 1: PROCEDURAL INFORMATION .............................................................................................62 

1. 

LEAD DG, DECIDE PLANNING/CWP REFERENCES ...................................................................62 

2.  ORGANISATION AND TIMING.......................................................................................................62 

3. 

4. 

CONSULTATION OF THE RSB .......................................................................................................62 

EVIDENCE, SOURCES AND QUALITY..........................................................................................64 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................................65 

ANNEX 3: WHO IS AFFECTED AND HOW? ...........................................................................................80 

1. 

2. 

3. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE .....................................................................80 

SUMMARY OF COSTS AND BENEFITS ........................................................................................81 

RELEVANT SUSTAINABLE DEVELOPMENT GOALS ................................................................84 

ANNEX 4: ANALYTICAL METHODS ......................................................................................................85 

ANNEX 5: COMPETITIVENESS CHECK ...............................................................................................140 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS ..................................................................140 

2. 

SYNTHETIC ASSESSMENT ...........................................................................................................140 

ANNEX 6: DETAILED DESCRIPTION OF POLICY MEASURES ........................................................142 

ANNEX 7: RULES ON WEIGHTS AND DIMENSIONS OF HDVS .......................................................151 

ANNEX 8: DISCARDED POLICY MEASURES ......................................................................................156 

ANNEX 9: CONCLUSIONS OF THE EVALUATION .............................................................................159 

ANNEX 10: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS ...........................................161 

ANNEX 11: SME TEST .............................................................................................................................169 

ANNEX 12: LETTER FROM FORMER VICE-PRESIDENT SIIM KALLAS, 13 JUNE 2012 ...............171 

ANNEX 13: MONITORING ......................................................................................................................174 

ANNEX 14: VISUALS FOR CONCEPT UNDERSTANDING .................................................................175 

ANNEX 15: EVALUATION REPORT (SEPARATE DOCUMENT) .......................................................179 

I 

 
 
 
 
 
 
Glossary1 

Term  

45-foot container 

Axle weight 

Definition 

Shipping  container  designed  according  to  ISO  6682 
standardised dimensions with a length of 13.72 meters, 
compatible with intermodal transportation systems. 

Weight  supported  by  a  laden  axle  or  group  of  axles, 
including the weight of the vehicle itself and any load it 
is carrying.  

Containerised Transport 

Intermodal  freight  transport  where  the  goods  are 
transported in standardized containers or swap bodies. 

High-Capacity Vehicle 

Powertrain 

Rear Flaps 

Swap body 

Swap body trailer 

TEN-T network 

A  High-Capacity  Vehicle  (HCV)  refers  to  heavy-duty 
vehicles  or  vehicles  combinations  exceeding 
the 
maximum  weights  and/or  dimensions  set  in  Council 
including  European  Modular 
Directive  96/53/EC, 
Systems.  HCV  are  designed  to  transport  a  larger 
volume  or  weight  of  goods  compared  to  standard 
vehicles. 

The  integrated  system  in  a  truck  that  comprises  the 
engine, transmission, and other components responsible 
for  generating  and  transmitting  power  to  the  wheels, 
enabling the vehicle’s movement. 

Devices  installed  on  trucks  and  trailers  to  optimize 
airflow and reduce aerodynamic drag, positioned on the 
rear end of the vehicle. 

Type  of  freight  container  suitable  for  its  transhipment 
between road and rail transport. 

Specialised trailer consisting of a rigid frame or chassis 
for the transport of swap bodies or containers by road 

Trans-European  transport  network  of  roads,  railways, 
inland waterways, airports,  and seaports across Europe 

1 See Annex 15 for accompanying visuals for the terms. 
2 Current version: ISO 668:2020-01, Series 1 freight containers — Classification, dimensions and ratings. 

II 

 
 
 
                                                 
identified  in  the  maps  contained  in  Annex  I  of 
Regulation  (EU)  1315/20133  and  strategically  planned 
and  developed  to  strengthen  the  social,  economic  and 
territorial  cohesion  of  the  Union  and  contribute  to  the 
creation of a single European transport area.  

Abbreviations 

Term or acronym 

Full name 

AFIR 

BEV 

BPG 

EMS 

GDP 

GHG 

GVW 

GVCW 

HCV 

HDV 

FCEV 

Alternative Fuel Infrastructure Regulation 

Battery Electric Vehicle 

European  Best  Practice  Guidelines  for  Abnormal  Road 
Transports 

European Modular System 

Gross Domestic Product 

Greenhouse gases 

Gross Vehicle Weight 

Maximum Gross Vehicle Combination Weight 

High-Capacity Vehicle 

Heavy-Duty Vehicle 

Fuel Cell Electric Vehicle 

3  Regulation  (EU)  No  1315/2013  of  the  European  Parliament  and  of  the  Council  of  11  December  2013  on  Union 
guidelines for the development of the trans-European transport network and repealing Decision No 661/2010/EU Text 
with EEA relevance (OJ L 348, 20.12.2013, p. 1–128). 

III 

 
 
 
                                                 
 
HGV 

ICE 

OBW 

PM 

PO 

SO 

TCO 

TEN-T 

W&D 

WIM 

ZE 

ZEV 

Heavy Goods Vehicle 

Internal Combustion Engine 

On-Board Weighing 

Policy Measure 

Policy Option 

Specific Objective 

Total Cost of Ownership 

Trans-European Transport Network 

Weights and Dimensions 

Weighin-Motion 

Zero-Emission 

Zero-Emission Vehicle 

IV 

 
 
1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

This Impact Assessment accompanies a legislative proposal for a revision 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”).  

1.1.  Political context 

Road  transport  plays  a  vital  role  in  connecting  businesses  and  consumers  across  the  EU,  facilitating 
trade,  and supporting  economic  growth  and  employment.  It  facilitates mobility  of  people  and supports 
many industries, such as manufacturing, construction and retail, by providing the means for the transport 
of goods. It also plays a critical role in emergency response.  

In  2020,  road  freight  transport  represented  53.3%  (1,745  billion  tonne-kilometres)  of  all  the  goods 
transported within the EU and more than three-quarters (77.4%) of the total inland freight transport (based 
on tonne-kilometres performed)4. The bus and coach transport activity amounted to 294 billion passenger-
kilometres,  representing  6.6%  of  total  passenger  transport  activity  in  2020.  The  road  transport  sector 
employs more than 5 million people in the EU, of which 3.3 million work in freight and almost 2 million 
in  passenger  transport4.  Road  freight  transport  has  proven  critical  in  ensuring  the  delivery  of  essential 
products and the transport of humanitarian aid in emergency situations, such as the COVID-19 pandemic 
and the unprovoked invasion of Ukraine by Russia5. 

While  the  road  transport  sector  brings  substantial  economic  and  social  benefits,  it  also  has  negative 
impacts  on  the  environment,  including  air  pollution  and  greenhouse  gas  emissions  (GHG),  as  well  as 
noise. Too much road traffic can generate congestion and increase wear and tear of infrastructure. It can 
also lead to accidents and injuries. For example, it is estimated that heavy-duty vehicles were involved in 
road  accidents  causing  around  3,000  out  of  the  22,800  fatalities  on  the  EU  roads  in  20196  (i.e. 
approximately 13% of the total). 

Transport7 accounted for 26% of all EU greenhouse gas emissions (GHG) emissions in 2020, with road 
transport  alone  representing  20%  of  the  total.  Around  28%  of  road  transport  emissions  originate  from 
heavy-duty vehicles, such as lorries and buses (6% of EU’s total GHG emissions)8. Road transport is the 
principal source of nitrogen oxides, responsible for 37% of emissions in 2020, and  also accounts for a 
significant  share  of  emissions  of  other  main  air  pollutants  (except  for  SOx)9.  Road  transport  was 
responsible  for  77%  of  total  energy  consumption  in  transport10  in  2020.  Heavy-duty  vehicles  (HDV) 
account for 38% of the EU’s diesel consumption in road transport11.  

4 Statistical pocketbook 2022 (europa.eu) 
5 The Solidarity Lanes are currently the only option for Ukraine for all their imports and for exports of non-agricultural 
goods (e.g. iron, steel, animal products). 
6 Source: CARE database. Figures from 2019 are considered more representative given that the decline in the number 
of fatalities registered in 2020 is affected by the overall reduction in the mobility during the COVID-19 pandemic.    
7 Including international aviation and maritime.  
8 Statistical pocketbook 2022 (europa.eu) 
9 Sources and emissions of air pollutants in Europe — European Environment Agency (europa.eu) 
10 Including international aviation and maritime.  
11 European Union (Convention). 2022 Common Reporting Format (CRF) Table | UNFCCC 

1 

 
 
                                                 
The  European  Green  Deal  Communication12  adopted  in  2019  sets  the  long-term  goal  of  achieving 
climate neutrality by 2050, showing the need for reducing GHG emissions from transport by 90% until 
that date. The European Climate Law13 enshrines in legislation the EU’s commitment to reach climate 
neutrality by 2050 and sets a target of at least 55% net GHG emissions reduction by 2030 compared to 
1990.  To  achieve  this  target  the  Commission  adopted  in  2021  the  Fit  for  5514  package  of  measures 
focusing, among others, on reducing the reliance on fossil fuels, expanding the use of renewable energy 
sources, accelerating the deployment of alternative fuels infrastructure and revising the CO2 standards for 
new cars and vans. In response to the hardships and global energy market disruption caused by Russia's 
invasion of Ukraine, the European Commission has presented in May 2022 the REPowerEU Plan15. The 
key objective of the Plan is to end the EU's dependence on Russian fossil fuels, improve energy efficiency 
and fast forward green transition, including towards zero-emission vehicles. In addition, on 14 February 
2023 the Commission proposed to revise the CO2 standards for new HDVs to ensure that they are in line 
with the increased climate ambition of the European Green Deal and to contribute to reducing the EU’s 
energy dependency. 

To  operationalise  the  green  and  digital  transformation  of  the  transport  system  and  contribute  to  the 
achievement  of  Green  Deal  objectives,  the  Commission  adopted  in  2020  the  Sustainable  and  Smart 
Mobility Strategy16 together with an Action Plan of 82 initiatives. The initiatives under the Strategy are 
based  on  three  strands:  making  all  transport  modes  more  sustainable,  making  sustainable  alternatives 
widely available in a multimodal system, and putting in place the right incentives to drive the transition. 
The revision of the W&D Directive will contribute to the Strategy’s objectives of boosting the uptake of 
zero-emission  vehicles,  renewable  &  low-carbon  fuels  and  related  infrastructure  (flagship  1)  and 
greening freight transport (flagship 4). In this context, it forms part of the Greening freight package, a 
set of initiatives catering for more sustainable solutions to improve the operational and system efficiency 
of the transport sector.  

The initiative fits under the broader objectives of the green and digital transformation of the EU economy, 
including the Zero Pollution Action Plan17. Finally, the revision of the W&D Directive also contributes 
towards the Sustainable Development Goal SDG 13 (“Take urgent action to combat climate change and 
its impacts”) and SDG 3 (“Ensure healthy lives and promote well-being for all at all ages”). 

1.2.  Legal context 

The  Council  Directive  96/53/EC  sets  out  the  maximum  permitted  weights  and  dimensions  for 
commercial heavy-duty vehicles18 (HDV) that circulate on EU roads carrying goods or passengers. The 
Directive specifies the maximum weight and dimensions of those vehicles including their length, width, 
height and axle loads. Annex 7 provides additional information on the current legal framework. These 
common  standards  aim  to  ensure  that  HDVs  do  not  exceed  limits  that  can  compromise  road  safety, 
infrastructure and the environment. The rules also aim to facilitate cross-border transport and ensure that 

12 COM(2019) 640 final. 
13 Regulation (EU) 2021/1119. 
14 COM(2021) 550 final. 
15 COM(2022) 230 final. 
16 COM(2020) 789 final.    
17 COM(2021) 400 final. 
18  Heavy-duty  vehicles  are  defined  for  the  purpose  of  this  Directive  as  freight  motor  vehicles  and  trailers  with  a 
technically permissible maximum laden mass of more than 3.5 tonnes (lorries) or passenger transport vehicles of more 
than 9 seats including the driver (buses and coaches). 

2 

 
 
                                                 
road  transport  operators  can  compete  on  equal  footing  in  the  internal  market  in  terms  of  the  loading 
capacity of their vehicles.    

The original Directive adopted in 1996 was subsequently amended in 2002 by Directive 2002/7/EC, and 
in  2015  by  Directive  (EU)  2015/71919.  The  2002  revision  harmonised  the  maximum  authorised 
dimensions of buses in national and international traffic, to enable seamless passenger transport by road 
within the EU. The 2015 revision provided for certain derogations from the maximum authorised weights 
and dimensions of vehicles and vehicle combinations, in order to encourage the uptake of alternatively 
fuelled powertrains, to improve vehicles’ aerodynamics and to ensure interoperability with other modes of 
transport. The reduction of GHG emissions, improving road safety and driver’s comfort in commercial 
(freight) transport were the main driving purpose of these derogations. 

In  addition,  following  the  commitments  of  the  Paris  Agreement  on  climate  change,  Regulation  (EU) 
2019/124220 setting CO2 performance standards for HDV introduced the notion of “zero-emission heavy-
duty  vehicle”  promoting  its  use  by  the  introduction  of  additional  weight  derogations  applicable  to  this 
vehicle  kind,  and  Decision  (EU)  2019/98421  brought  forward  the  initial  deadline  for  placing  more 
aerodynamic cabs in the market from 2 December 2022 to 1 September 2020. 

1.3.  Synergies with other EU policy instruments 

The revision of the W&D Directive is complementary to other initiatives that aim at reducing emissions 
from  transport,  improve  energy  and  operational  efficiency  of  cross-border  operations  and  promote 
intermodal cooperation. In particular, it offers synergies with three initiatives put forward as part of the 
Greening freight package, namely:   

  The revision of the Combined Transport Directive, aimed at incentivising the uptake of intermodal 

transport; 

  The  CountEmissions  EU  initiative,  aimed  at  establishing  a  harmonised  methodology  to  measure 
door-to-door GHG emissions of transport operations, which could be used by transport companies to 
monitor and benchmark their transport services; 

  The  initiative  on  rail  capacity  planning  and  management  aimed  at  improving  the  reliability, 
punctuality and availability of rail services by optimising the use of rail infrastructure and improving 
their multimodal integration. 

Although these initiatives cover different modal and cross-modal aspects of the regulatory framework for 
land transport, they complement each other in delivering a more efficient and sustainable land transport 
system. There are particularly strong connections with the revision of the Combined Transport Directive 
whose main objective is to incentivise the uptake of freight intermodal transport in order to contribute to 
reducing GHG emissions and other externalities from transport such as air pollutant emissions, congestion 
and  accidents.  The  W&D  Directive  aims  to  provide  additional  incentives  to  intermodal  transport,  by 
eliminating  the  disadvantages  of  the  road  legs  by  HDV  involved  in  intermodal  transport  operations  in 
terms of loading capacity and by extending the support of the Directive to non-containerised intermodal 
transport.  

19 Directive 2002/7/EC.  
20 Regulation (EU) 2019/1242. 
21 Decision (EU) 2019/984 of the European Parliament and of the Council. 

3 

 
 
                                                 
There  are  also  clear  synergies  between  this  initiative  and  the  Regulation  setting  HDV  CO2  emission 
performance standards22, which sets requirements on vehicle manufacturers as to the supply of more 
fuel-efficient  and  zero-emission  heavy-duty  vehicles.  The  proposal  for  the  revision  of  the  Regulation, 
adopted by the Commission on 14 February 2023, extends the scope to almost all newly registered HDVs 
with  certified  CO2  emissions  and  sets  new  CO2  emission  targets  from  2030  onwards23.  To  effectively 
reach its targets and achieve the greening objectives as swiftly as possible, the CO2 standards for HDVs 
need to  be  complemented  by  enabling  measures targeting  the  demand  side.  The  revision of  the  W&D 
Directive aims to put in place the right incentives for the transport operators to invest in cleaner HDV, 
contributing to the uptake of ZEV and the achievement of the GHG emission reduction target set in the 
European Green Deal and the Sustainable and Smart Mobility Strategy. 

The Eurovignette Directive24 addresses the need to internalise road transport’s external costs, applying 
“the polluter pays” and “the user pays" principles. In addition, a recent legislative proposal to revise the 
Eurovignette Directive takes account of the environmental performance of trailers and semitrailers in the 
calculation of road charges25. This will further reinforce the incentives provided by the W&D Directive to 
boost  the  uptake  of  zero-emission  HDVs  and  to  encourage  the  use  of  energy  efficient  trailers  and 
semitrailers.  As  part  of  the  Fit  for  55  package,  the  Commission  also  put  forward  a  proposal  for  the 
revision  of  the  Energy  Taxation  Directive26  that  promotes  clean  technologies  and  remove  outdated 
exemptions and reduced rates that currently encourage the use of fossil fuels. In addition, road transport 
will be covered by emissions trading27, putting a price on pollution, stimulating cleaner fuel use, and re-
investing in clean technologies. 

On the infrastructure side, the most relevant initiatives that could strengthen the effects of W&D Directive 
are: the EU Action Plan on Military Mobility28 and the Alternative Fuel Infrastructure Regulation 
(AFIR)29. The EU Action Plan on Military Mobility aims to remove the obstacles that hamper military 
mobility  in  the  EU.  A  key  part  of  the  Action  Plan  is  to  identify  the  infrastructure  capable  of 
accommodating bigger and heavier vehicles than those within the limits of the W&D Directive. A gap 
analysis conducted to this end30 concluded that 91% of the road TEN-T network would be suitable for 
military transport needs, which either match or (mostly) exceed the standards set in the W&D Directive. 
AFIR sets mandatory minimum targets for the roll-out of recharging and refuelling infrastructure across 
the TEN-T core and comprehensive network and thus strengthening the W&D objectives to facilitate the 
uptake of ZEV.  

The  Cross-Border  Enforcement  (CBE)  Directive  aims  to  improve  road  safety  and  to  ensure  equal 
treatment of drivers, namely resident and non-resident offenders. In March 2023 the Commission adopted 
a legislative proposal31 to amend the CBE Directive, extending its scope to other road safety related traffic 

22 Regulation (EU) 2019/1242. 
23 COM(2023) 88 final. 
24 Directive 1999/62/EC.  
25 The amendment to the Eurovignette Directive relies on the optimisation of trailers with regard to their aerodynamic 
performance, rolling resistance and weight. It does not cover electric trailers and semitrailers. 
26 COM/2021/563 final. 
27 COM/2021/551 final; 
28  Joint  Communication  to  the  European  Parliament  and  the  Council  on  the  Action  Plan  on  Military  Mobility  JOIN 
(2018)05 final, referred to as the "Action Plan". 
29  The  proposal  for  the  revised  AFIR  (COM  (2021)559)  was  part  of  the  Fit  for  55  package.  The  political  agreement 
between the European Parliament and the Council, regarding the revised AFIR, was reached on 28 March 2023.   
30 SWD(2020) 144 final. 
31 COM (2023)126.  

4 

 
 
                                                 
offences. The “use of an overloaded vehicle” is one of them. Hence, the mechanism provided by the CBE 
Directive  could  be  used  to  identify  the  offenders  and  facilitate  their  prosecution  for  infringing  the 
provisions of the W&D Directive. 

1.4.  Evaluation of the Directive  

An evaluation of the W&D Directive has been carried out ‘back-to-back’ (i.e. at the same time) with the 
impact assessment. The evaluation of the W&D Directive is annexed to this report.  

The main conclusion of the evaluation is that the Directive was only partially successful in achieving its 
objectives  of  strengthening  the  internal  market,  improving  energy  and  operational  efficiency  of  road 
transport operations, contributing to road safety and to the protection of road infrastructure. On the one 
hand,  the  common  technical  standards  for  HDVs  enabled  more  effective,  safe  and  fair  cross-border 
operations within the EU internal market, and on the other hand, the variety of national derogations and 
requirements  established  by  Member  States  in  line  with  the  Directive,  led  to  fragmentation  of  certain 
segments of the market and to operational inefficiencies. 

While the Directive helped to increase the share of containerised intermodal transport and to improve the 
energy and operational performance of operations in the Member States allowing for longer and heavier 
vehicles,  its  overall  contribution  to  the  energy  efficiency  of  freight  transport  operations  in  the  EU, 
including through the uptake of aerodynamic devices and of alternatively fuelled powertrains (including 
zero-emission ones), has been very limited. The Directive is considered effective in promoting road safety 
and in reducing infrastructure wear and tear.  

The partial ineffectiveness and inconsistency of the Directive has been attributed in the evaluation to a 
combination of factors, including a lack of clarity in the Directive's provisions and a lack of enforcement 
by  Member  States.  Both  of  these  aspects  contribute  to  the  challenges  in  achieving  harmonisation  and 
correct implementation of the Directive. 

As to the lack of clarity, the evaluation confirmed that the Directive contains provisions that are open to 
interpretation or lack specificity in certain areas, in particular as regards the use of longer/heavier vehicles 
in cross-border operations and requirements for authorisations for abnormal transport. This led to varying 
interpretations  and  inconsistent  application  across  Member  States,  resulting  in  a  fragmentation  of  the 
market  (its  segments  such as: longer/heavier HDVs, including  European Modular Systems  (EMS),  car 
transporters,  indivisible  load  transport).  The  lack  of  clear  provisions  and  common  standards  created 
confusion and hindered the full achievement of the harmonisation objective of the Directive. 

Ineffective and inconsistent enforcement by Member States, including inadequate or insufficient checks, 
penalties, and monitoring, undermined the effectiveness of the Directive in the area of internal market, 
ensuring  free  movement  of  goods  and  fair  competition.  It  has  also  affected  the  performance  of  the 
Directive  in  eliminating  the  risks  to  road  safety  and  damage  of  infrastructure  posed  by  overloaded 
vehicles. 

The  lack  of  clarity  in  the  Directive's  provisions  and  the  lack  of  enforcement  are  interconnected.  The 
ambiguity  in  the  provisions  created  challenges  for  enforcement  authorities,  while  weak  enforcement 
further exacerbated non-compliance and undermined the harmonization objectives. 

The links between the conclusions of the ex-post evaluation and the impact assessment are summarised in 
Annex 9. 

5 

 
 
2.  PROBLEM DEFINITION 

The  key  problems,  corresponding  drivers  and  consequences  that  are  relevant  for  the  revision  of  the 
Directive are presented in Figure 1. 

Figure 1: Problem tree 

2.1.  What are the problems? 

2.1.1.  Problem 1:  Low uptake  of  zero-emission  heavy-duty vehicles  and energy  saving 

technologies and schemes 

The evaluation has shown that the incentives to improve the energy efficiency of road transport and to 
reduce  the  GHG  emissions  via  the  deployment  of  alternatively-fuelled  HDVs  (including  ZEVs)  and 
improved aerodynamics were insufficient and not reflecting the operational and zero-emission technology 
requirements, and that intermodal transport remains partially disadvantaged. 

The amendments introduced in 2015 (Directive (EU) 2015/71932) provided for certain derogations from 
the maximum authorised weights and dimensions of HDV to encourage deployment of new “greening” 
technologies and 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. The share of alternatively fuelled medium and heavy-duty vehicles in 
the EU yearly registrations has slowly increased from 0.5% in 2016 to 7% in 202033. Even though the 
registrations of ZEVs are increasing, their current share of the EU fleet is still very low. In 2020, 0.2% of 
all  lorries  above  3.5  tonnes  and  nearly  1%  of  buses  in  use  in  the  EU  were  electrically  rechargeable34 
(Figure 2). 

32 OJ L 115, 6.5.2015, p. 1–10. 
33 https://www.acea.auto/files/ACEA-report-vehicles-in-use-europe-2022.pdf  
34 Including battery electric and plug in hybrids.  

6 

 
 
 
                                                 
Figure 2: Share of alternatively fuelled vehicles in the EU fleet in 2020  

 Source: ACEA 

Overall, the uptake of zero-emission vehicles in the HDV (in particular truck) fleet is very limited. The 
EU  truck  fleet  (above  3.5 tonnes)  continues  to be strongly dominated  by  fossil fuel  engines. Road 
freight transport relies predominantly on diesel (96.3% of all trucks in the EU run on diesel), with only 
0.7% of all trucks being run on alternatively fuelled internal combustion engines (natural gas and LPG). 
The share of electrically chargeable trucks, including battery electric and plug in hybrid vehicles, is as low 
as 0.2%. Buses make more use of alternative fuels in internal combustion engines (3.7% of the EU fleet) 
than  trucks.  The  figures  also  show  higher  uptake  of  hybrid  electric  (1.4%)  and  electrically  chargeable 
(1%)  buses,  mostly  used  in  urban  transport.  The  sales  of  zero-emission  buses  over  7.5t  are  growing 
rapidly35. 

One  position  paper36  and  other  stakeholders’  feedback  provided  to  the  Commission37  identify  the 
availability  of  recharging  and  refuelling  infrastructure,  the  price,  total  cost  of  ownership  (TCO38)  and 
duration of charging, as the main barriers to the broad uptake of zero- and low-emission vehicles. At the 
same  time,  the  stakeholders  in  the  trucking  industry  call  for  rapid  decarbonisation  of  the  road  freight 
sector and for an ambitious quick and broad roll-out of the related infrastructure to enable the uptake of 
ZE  HDVs39.  They  call  on  the  EU  and  the  national  governments  to  put  in  place  enabling  policies  to 
accelerate  the  market  uptake  of  ZEV  and  removing  barriers  holding  back  the  transition,  including  the 
current  limits  on  weights  and  dimensions  of  HDVs.  These  issues  are  being  addressed  by  different 
legislative initiatives mentioned in section 1.3, and W&D  Directive  can also play an important role in 
providing  a  comprehensive  solution  by  removing  the  technical  and  administrative  barriers  to  the 
deployment of ZE HDVs. 

In  addition  to switching to  alternative  fuels,  research  projects  and testing  activities  show that  emission 

35 Over 10% of buses sold in 2020 were electrically chargeable (including battery electric and plug in hybrids).  
36 See https://www.iru.org/resources/iru-library/iru-position-accelerating-decarbonisation-road-transport-through-faster-
update-alternative-fuels from the International umbrella association of road transport operators IRU, 12.11.2020. 
37 For instance, the on-line public consultation carried out in the context of the impact assessment for the revision of the 
HDV  CO2  Emission  Standards  Regulation,  available  at:  https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/13168-Reducing-carbon-emissions-review-of-emission-standards-for-heavy-duty-vehicles_en  
38  The TCO of a vehicle is the cost of purchase  plus  the cost to operate  the vehicle over its useful life, such as  fuel, 
maintenance, taxes and charges. 
34 Joint declaration - The road freight transport is ready to fully decarbonise - European Clean Trucking Alliance 

7 

 
 
 
                                                 
reductions are possible via energy savings through improved vehicle aerodynamics for the complete 
vehicle, of about 5-10%40. However, the uptake of devices enabling such savings (notably aerodynamic 
cabs and rear flaps) has been very low until now due to past regulatory obstacles as well as a limited type 
of  operations  (mainly  long-distance  motorway  driving)  which  the  use  of  these  devices  has  been 
economically beneficial so far. The 2015 amendments to the W&D Directive supported the improvement 
of vehicles’ aerodynamics by allowing extra length for HDVs equipped with rear aerodynamic devices 
and for HDVs equipped with cabs improving the aerodynamics and safety of the vehicle, as well as the 
visibility, safety and comfort of drivers. However, 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 flaps41 apply only since December 201942.  In addition, the length derogation for the 
new cabs applies only from September 202043, which delayed their placing on the market.  

The first and the only truck equipped so far with an elongated cab was placed on the market on 9 June 
202144.  It  is  reported45,46  that  the  cab  was  elongated  by  160mm  at  the  front  and  330mm  at  the  rear. 
Coupled  with  re-designed  windows  and  packaging,  the  elongated  cab  is  claimed  to  have  substantially 
improved direct vision, beneficial for road safety. However, the re-shaping of the front is less radical than 
was envisaged by concepts studied in the development of the Directive47, limiting the potential energy 
savings only to high-speed long-distance trips.  

The  requirements  of  the  HDV  CO2  Standards  Regulation  in  combination  with  the  need  for  improved 
aerodynamics  to  reduce  energy  consumption  and  the  Direct  Vision  Regulation48  is  expected  to  drive 
widespread  introduction  of  elongated  cabins49.  However,  it  appears  likely  that,  in  response  to  market 
demands  and  the  prioritisation  of  manufacturers  to  roll-out  zero-emission  powertrains  over  improved 
aerodynamics, much of the length increase possible under the legislation will be put at the rear of the cab, 
where it can be used to benefit interior space for driver comfort and/or additional space for zero-emission 
equipment, such as hydrogen tanks.  

As regards the implementation of  rear flaps, although neither technology suppliers, nor  manufacturers 
have provided figures that would allow to quantify the actual use of rear devices in freight transport, they 

40 https://aeroflex-project.eu/wp-content/uploads/2018/04/Uniresearch_AEROFLEX_flyer_A4_1816_web.pdf. 
41 Commission Implementing Regulation (EU) 2019/1916, amended by Implementing Regulation 2020/349. 
42 Commission Regulation (EU) 2019/1892. 
43 Article 9a(3) of the Weights and Dimensions Directive. 
44 Next Generation DAF truck launched on the 9th June 2021. https://youtu.be/4wLUrs4tmQE   
45 https://www.daf.com/en/news-and-media/news-articles/global/2021/q2/daf-is-starting-the-future-with-an-entirely-
new-line-up-of-trucks-short 
46 https://startthefuture.daf.com/-/media/files/document-library/brochures/ngd/new-generation-daf-brochure-06-2021-
en_web.pdf 
47 According to the estimations of the Impact Assessment accompanying the legislative proposal for a revision of the 
W&D  Directive  (SWD(2013)  108  final),  based  on  FKA  Report  104190,  Aachen  2011,  on  high-speed  long-distance 
trips “if the lower part of the front of the driving cabin was streamlined and extended by 0.8 m, the aerodynamic drag 
coefficient (CD) would drop by 6.4% resulting in a reduction of fuel consumption by 3.2  to 5.3%. Shorter extensions 
(0.4 m) of cabins would yield markedly poorer results (4.5% reduction in CD). With a longer extension (1.2 m) the gain 
would increase to 8.9%.” 
48 The ‘Direct Vision Regulation’ are standards being negotiated in the context of UNECE Working Party on General 
Safety Provisions (WP.29) with the  goal of reducing blind spots for truck drivers. The Regulation is currently in the 
latest stages for final approval https://unece.org/transport/documents/2021/10/informal-documents/iwg-vru-proxi-draft-
un-regulation-direct-vision  
49  According  to  the  information  gathered  during  the  consultation  activities  Daimler  and  Scania  are  considering  to 
introduce elongated cabs for ZE trucks.   

8 

 
 
                                                 
all  agree  that  there  is  no  increase  in  the  demand  for  such  devices.  According  to  the  Automobile 
Manufacturers Association (ACEA) “implementation of the measures envisaged by the W&D Directive at 
the national level caused delays in the real world uptake, as did uncertainties related to other legislation 
(General  Safety  Regulation,  Direct  Vision  Regulation)  which  occurred  in  parallel  with  the  W&D 
developments”. 

In addition to these improvements to the HDVs, increased use of intermodal transport is considered 
an important element in the decarbonisation of freight transport in the EU, due to its energy and 
emission saving potential. It combines the better environmental performance and energy efficiency of 
non-road transport with the accessibility and flexibility of road transport on the 'last mile'. The volume of 
intermodal  freight  transport  in  tonne-kilometres  has  more  than  doubled  in  the  last  30  years,  since  the 
adoption of the Combined Transport Directive, and has been the fastest growing market segment in three 
important  non-road  freight  modes  (i.e.  rail,  inland  waterways,  short  sea  shipping),  even  if  this  relative 
growth advantage has in recent years slowed (Figure 3).  

Figure 3: Freight transport activity of unimodal (excluding the intermodal respective legs) and total intermodal 
transport (including road and non-road legs), 2005-2020 (in billon tkm)  

1500

1200

900

600

300

0

Road (excl intermodal
road-legs)
Rail (excl. intermodal)

IWW (excl. intermodal)

SSS (excl. intermodal)

Intermodal (all modes, all
legs)

2005

2015
Source: Statistical pocketbook 2022, REFIT evaluation of Combined Transport Directive (2016) and Ricardo et al. 
support study (2023)50   

2010

2020

The  use  of  45-foot  containers  and  swap  bodies,  which  is  estimated  to  account  for  19%  of  the  ISO-
container category, has similarly been increasing during this period as it is considered the most efficient 
cargo unit for intermodal transport. Enabling51 the use of standard 45-foot containers and swap bodies has 
been highly welcomed by the market operators and the expectation is that the large containers (45-foot 
and high-cube) will increase gradually their market share of containerised transport in the future. Swap 
bodies  are  large  containers  designed  to  be  easily  transferred  between  road  and  rail  modes  of 
transport without special handling equipment by lifting them from below, as they are equipped with 
up-folding legs. Compared to traditional shipping containers, swap bodies have more inside space 
despite  the  same  external  dimensions,  and  thus  allow  for  greater  cargo  capacity.  Directive  (EU) 
2015/719  introduced  weight  derogations  for  5-  and  6-axle  HDV  combinations  involved  in  intermodal 
transport operations (from 40 tonnes to 42 tonnes or 44 tonnes depending on the axle configuration) to 
compensate for the extra weight of the empty containers and swap bodies.  

50 Ricardo et al. (2023), Impact assessment support study on amendment of Combined Transport Directive. 
51 Directive (EU) 2015/719. 

9 

 
 
 
 
                                                 
Figure 4: Swap body trailer with extended legs, during loading process. 

Source: Schmitz Cargobull 

However, the effects of this measure to promote intermodal transport have been partially cancelled out in 
eleven  Member  States52  (representing  24.6%  of  the  total  road  freight  transport  activity  in  the  EU  in 
202053) where the weight limits for the vehicle combinations used in domestic road-only operations were 
increased  to  at  least  44  tonnes.  As  a  result,  while  overall  energy  and  operational  efficiency  of  road 
transport operations increased in those Member States, shippers and operators involved in (containerised) 
intermodal  transport  have  been  put  in  a  disadvantaged  position  by  having  lower  loading  capacity  as 
compared  to  road-only  transport.  The  cost  efficiency  of  road-rail  intermodal  transport  is  particularly 
sensitive to pre- and post-haulage costs54, since this activity typically has a larger cost compared with its 
share  of  the  total  distance  in  the  transport  chain.  Improving  the  efficiency  of  pre-  and  post-haulage 
activities is, therefore, of utmost importance for the competitiveness of the intermodal transport system55. 

2.1.2.  Problem  2  –  Fragmentation  of  the  market  for  heavier  and  bigger  (freight) 

transport vehicles 

The W&D Directive establishes the maximum weight and dimensions for different types of heavy-duty 
vehicles (e.g. 16.50 m and 40 tonnes for articulated vehicles with 5 or 6 axles). Vehicles complying with 
these requirements can freely circulate throughout the EU territory. At the same time, the Directive allows 
for national derogations for heavier or bigger vehicles to circulate on the national territory only. 
Member  States  have  granted  national  derogations,  allowing  increased  weights  and  dimensions,  in  an 

52  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  tonnes,  the  Netherlands  of  up  to  50  tonnes  and  Italy 
allows a maximum weight of up to 56 tonnes for the transport of excavation and mining materials. 
53 Source: Statistical pocketbook 2022. 
54  Pre-  and  post-haulage  costs  refer  to  the  expenses  incurred  before  and  after  the  actual  transportation  of  goods.  In 
intermodal containerised transport, this includes the costs associated with transhipment as well as the movement of the 
empty container before and after its use for transport of goods.  
55 Bergqvist, R. and Behrends, S. (2011), Assessing the effects of longer vehicles: The case of pre- and post-haulage in 
intermodal transport chains, Transport Reviews, available at: 
https://www.researchgate.net/deref/http%3A%2F%2Fdx.doi.org%2F10.1080%2F01441647.2011.584980  

10 

 
 
 
                                                 
uncoordinated manner (see problem driver 4 for details). This has created a patchwork of rules, which 
hampers the free circulation of HDVs within the EU, distorts competition, renders enforcement ineffective 
and leads to loss of operational and energy efficiency. It affects particularly the market segments of high-
capacity  vehicles,  vehicle  transporters  and  indivisible  loads  and  limits  the  pursued  economic  and 
environmental savings in these segments. For instance, due to the lack of harmonisation at the EU level in 
this regard, high-capacity  vehicles (e.g. 44 tonne vehicles and vehicle combinations European modular 
systems – EMS56) allowed to circulate in national transport in neighbouring Member States  cannot, in 
principle,  cross  the  borders  of  those  Member  States  to  continue  the  operation.  The  call  for  evidence57 
revealed  that  80%  of  174  contributors,  representing  companies  and  business  associations  (mainly  road 
transport and logistic operators, truck manufacturers, construction businesses, agricultural producers and 
chemical industry), considered the lack of harmonisation in this respect a significant hurdle and demanded 
the allowance of 44 tonnes in international transport.  

European Modular Systems (EMS) are particular case. EMS are allowed in cross-border operations 
based on bilateral agreements, limited to one single border crossing between two neighbouring Member 
States  who  allow  EMS  on  their  territories.  This  is  based  on  the  broad  interpretation  of  the  W&D 
Directive58 which is meant to preserve the international competition in the transport market. However, it 
has  also  created  geographical  areas  within  which  cross-border  transport  is  allowed  but  that  are 
unconnected. For instance, international transport by EMS between Finland and Sweden cannot continue 
to  Denmark,  even  though  the  latter  also  allows  EMS  on  its  territory.  International  transport  between 
Germany and the Netherlands cannot continue to Belgium, although Belgium allows EMS. According to 
information  from  national  authorities  in  the  context  of  the  stakeholders’  consultation,  discussions  are 
ongoing  to  possibly  allow  cross-border  transport  of  EMS  between  Portugal  and  Spain  and  between 
Germany and Denmark in the near future.  

The national rules and trials allowing the circulation of EMS impose specific additional conditions mostly 
citing  reasons  of  road  safety  and  protection  of  the  infrastructure.  These  national  requirements  are 
diverging and hamper even more the use of EMS in cross-border operations. For example, in Germany 
EMS are limited to a maximum weight of 40 tonnes while in the Netherlands EMS can reach 60 tonnes of 
weight  but  must  be  equipped  with  sideguard  warnings  and  drivers  must  follow  specific  training.  The 
bilateral agreement between the Netherlands and Germany reflects these national requirements creating 
specific legal frameworks for these regional markets within the EU internal market. 

Abnormal transport or transport of indivisible loads59 is a relatively small, though important segment, 
as it is linked with the strategic areas of renewable energy, civil engineering and infrastructure, oil and gas, 
heavy  industry  and  power  generation  sectors.  This  segment  also  suffers  from  diverging  national  rules, 

56 According to article 4.4(b) of the W&D Directive, 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. These combinations are known as modular concept or European modular systems (EMS). 
57 A call for evidence was open for feedback from 1 January 2022 to 21 February 2022: Commercial vehicles – weights 
and dimensions (evaluation) (europa.eu) and gathered 224 contributions, out of which 174 were from companies and 
sectoral organisations.  
58 The explanation provided by former Vice-President Siim Kallas in 2012 – see Annex 12. 
59 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”. 

11 

 
 
                                                 
procedures and requirements for obtaining a permit to circulate across the EU. The patchwork of rules 
creates administrative burden, causes delays and makes cross-border operations inefficient and prone to 
fraud (it is estimated that 25% of such transport in the EU is not covered by special permits60) adversely 
affecting road safety and the infrastructure. In 2011, the European association of abnormal road transport 
and  mobile  cranes  (ESTA)  conducted  an  economic  impact  assessment  and  concluded  that,  if  all 
recommendations  of  the  European  Best  Practice  Guidelines  for  Abnormal  Road  Transports61  were 
followed, particularly in terms of simplification and harmonisation of the rules and procedures to obtain 
the special permits, the savings could amount to EUR 800 million every year62. 

2.1.3.  Problem 3 – Ineffective and inconsistent enforcement of transport rules for HDV  

The variety and complexity of the regulatory frameworks (EU, national and bilateral/multilateral) and the 
resulting lack of legal certainty have led to inefficient and inconsistent enforcement of the rules in cross 
border  transport.  For  instance,  the  cross-border  transport  between  France  and  Belgium  by  44  tonnes 
HDVs (both Member States allow a maximum weight of 44 tonnes in national transport) was for many 
years tolerated, even if not allowed by the W&D Directive63. The recent enforcement actions taken by 
France64,  which  according  to  the  complaints  by  operators,  target  only  incoming  transport  (to  France), 
while  outgoing  transport  with  44t  HDVs  can  continue  to  and  through  Benelux  countries  without 
restrictions,  could  lead  to  discriminatory  controls  and  create  a  competitive  advantage  for  international 
transport operators carrying goods from France to the Benelux countries compared to their counterparts 
serving the French territory.  

Similarly, it is the current practice that cross-border transport of vehicle carriers with extended length (i.e. 
longer than the W&D limits, but allowed under national derogations) is accepted all over the EU as long 
as the extensions used are permitted in the Member States crossed. 

The evaluation shows that exceeding the maximum allowed masses and axle loads of HDV is the most 
frequent infraction. A survey conducted by the Conference of European Directors of Roads CEDR among 
its  members  (i.e.  road  authorities)  reveals  that  the  percentage  of  overloaded  vehicles  in  Europe  varies 
between 2% and 18%65. The circulation of overloaded vehicles, resulting from low compliance and weak 
enforcement, not only leads to distortions of competition between hauliers, but can endanger road safety 

transports:  European  best  practice  guidelines,  Publications  Office.  Available 

60 Commission Staff Working Document, Report on the implementation of the amendments to Directive 96/53/EC 
introduced by Directive (EU) 719/2015. SWD(2023) 70 final. 
61 In 2008, an expert group comprising experts designated by the Member States 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. Source: European Commission (2008), 
Abnormal  Road 
at: 
https://op.europa.eu/en/publication-detail/-/publication/fa2d050b-24d2-469c-af61-43838653f075  
62  According  to  the  economic  impact  assessment  this  amount  can  be  disaggregated  as  follows:  1)  efficiency 
improvement: EUR 50 million; 2) corridors: EUR 30 million; 3) introduction of SERT: EUR 270 million; 4) private 
escorts replacing police effort: EUR 450 million.  
63 As explained under Problem 2, national legislation can allow for trucks beyond the 40 tonnes of the Directive in the 
national  territory,  but  those  are  not  allowed  to  cross  the  border,  even  when  similar  national  rules  exist  in  the 
neighbouring Member State. 
64 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. ELI:  https://www.legifrance.gouv.fr/eli/decret/2021/7/29/TRAT2109942D/jo/texte.   
JORF n°0176 du 31 juillet 2021. Texte n° 58. 
65 CEDR Report 2017/05 (2017). Conditions for efficient road transport in Europe. 

12 

 
 
                                                 
and create risks of damage to the infrastructure, in particular its parts that are not adapted to accommodate 
the traffic by heavier/bigger vehicles (e.g. old bridges, certain roads). 

According to the recent biennial report on the implementation of the W&D Directive66, around 17 million 
vehicles and vehicle combinations were checked at the roadside in 2019 and 2020 in the territories of the 
nineteen  Member  States  that  have  provided  data.  More  than  half  million  offences  (3.3%  of  the  HDV 
controlled) of  exceeding  the maximum weight or the maximum  axle  weight were detected.  There  are, 
however, very significant differences among Member States in the number of controls performed. In the 
reporting  period  2019-2020,  Ireland  performed  the  highest  number  of  controls  (around  12.6  million 
controls), followed by Poland (around 3 million controls) and Italy (almost 600,000 controls). Substantial 
differences  were  also  observed  in  the  efficiency  of  controls  measured  as  the  percentage  of  infractions 
detected  per  control  carried  out.  The  detection  rates  range  from  72.2%  in  Estonia  (2,166  infractions 
detected out of 2,929 controls carried out) to 0.2% in Poland (7,217 infractions detected out of 3,050,851 
controls carried out). 

The  legal  uncertainty  about  the  applicable  rules  in  cross-border  transport  and  the  diverging  levels  of 
enforcement were considered as the most important issues to be addressed by the revision of the W&D 
Directive in the two workshops with industry stakeholders and with national experts of the Member States 
held on the 15 and 16 December 2022, respectively.  

2.2.  What are the problem drivers? 

Problem driver 1: Current technical standards are not adapted to the needs of ZEV  

The existing provisions are inadequate and/or insufficient to encourage the investment in zero-emission 
vehicles. To reach the same range as a diesel vehicle (or other fossil fuel vehicles), zero-emission vehicles 
typically need a higher mass (battery electric trucks) or volume (fuel cell electric trucks). The amendments 
introduced  by  Directive  (EU)  2015/719  and  by  Regulation  (EU)  2019/1242  increased  the  permitted 
weight  for  zero-emission  vehicles  to  compensate  for  the  loss  of  loading  capacity  caused  by  the  extra 
weight  linked  to  the  zero  emission  powertrains.  Truck  manufacturers  and  technology  suppliers  argue, 
however, that these allowances are insufficient and that additional weight and axle-weight67 is needed, in 
particular for long-haul freight transport, because batteries need to be bigger and heavier.  

The extra weight allowance applies to certain buses, rigid trucks and tractors only, excluding 4-axle motor 
vehicles,  2-axle  rigid  buses  and  vehicles  forming  part  of  a  vehicle  combination  other  than  the  tractor. 
These allowances neither consider new technological developments such as electric trailers equipped with 
auxiliary motors and batteries which reduce the demand of energy from the motor vehicle and/or power 
other elements, such as cooling units of reefers. These innovative solutions cannot benefit nowadays from 
extra  weight  allowance  to  compensate  for  the  weight  of  the  system,  which  discourages  their  market 
uptake. 

Battery  electric  vehicles  (BEV)  and  fuel cell  electric vehicles  (FCEV powered  with  hydrogen) require 
space  to  store  the  batteries  and  the  hydrogen  tanks68  which  are  commonly  installed  behind  the  cab. 
Current rules do not allow for extra length to compensate for the space needed for  this type of energy 

66 COM(2023) 183 final.  
67 ACEA position paper on the “Review of the Weights & Dimensions”, December 2022. 
68 ACEA position paper on the “Revision of the Weights & Dimensions”, 1 Feb 2021. 

13 

 
 
                                                 
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 cannot offer the same payload capacity as 
an internal combustion engine (ICE) truck. In the second case, the driver’s comfort and safety pursued via 
the introduction of new elongated cabs might be affected.  

The  needs  for  extra  weight  and  length  have  been  consistently  reported  by  truck  manufacturers  and 
technology developers69. Hydrogen Europe, ACEA70 and one truck manufacturer estimated the necessary 
increases of the Gross Vehicle Weight (GVW) by 2 tonnes and of length (by 0.9 to 1.5 m) for a long-haul 
hydrogen-powered HDV that would enable those vehicles to cover the range of at least 600 km on one 
refill. 

The  need  to  adapt  the  weights  and  dimensions  standards  was  also  confirmed  during  the  public 
consultation.  During  a  workshop  with  115  industry  stakeholders,  organised  in  December  2022, 
participants considered the inadequacy of current technical standards for the needs of ZEV as one of the 
three most important issues to be addressed. This is in line with the results of the open public consultation 
in which 93 out of 127 respondents stated that adapting the technical standards to the needs of ZEV would 
be a very useful or useful measure.   

Problem  driver  2:  Insufficient  incentives  for  the  uptake  of  ZEV,  rear  aerodynamic  devices  and 
aerodynamic cabs 

Vehicle  manufacturers  are  committed  to  reducing  CO2  emissions  by  bringing  a  wide  range  of  zero-
emission  vehicles  to  the  market71.  However,  their  uptake  largely  depends,  according  to  European 
manufacturers, on transport operators being able to invest in them and operate them profitably72. The lack 
of technological maturity currently keeps the costs of the available solutions high and thus impedes the 
uptake  of  alternative  fuels,  including  zero-emission  vehicles73.  Nonetheless,  the  impact  assessment 
accompanying  the  revision  of  the  HDV  CO2  performance  standards74    found  that,  in  all  policy 
combinations considered, the TCO is positive along the vehicle lifespan. The positive TCO determines net 
economic savings, even  without  considering the  monetisation of the CO2  and  air pollutants  emissions, 
since the fuel savings outweigh the capital costs and other costs. Other recent studies indicate that long-
haul battery-electric trucks will reach TCO75 parity in the coming years, which will very much depend on 
the  amount  and  intensity  of  available  policy  incentives  and  the  technological  developments76.  High 
upfront vehicle costs pose a serious market barrier for the EU hauliers, the great majority of which are 
micro and small enterprises, as addressed by the Impact Assessment of the revised HDV CO2 Standards. 

69  ICCT  (International  Council  on  Clean  Transportation),  Fuel  cell  electric  tractor-trailers:  technology  overview  and 
fuel economy: https://theicct.org/wpcontent/. 
70 ACEA position paper on the “Review of the Weights & Dimensions”, December 2022. 
71 ACEA’s overview of 34 zero-emission trucks that are already available or soon to come to the market, 19 September 
2022.  
72 https://www.acea.auto/files/ACEA-position-paper-2022_HDV-CO2-Review.pdf  
73  Van  Grinsven:  Alternative  fuels  infrastructure  for  heavy-duty  vehicles,.  Brussels:  European  Parliament,  Policy 
Department for Structural and Cohesion Policies, 2021. 
74 SWD/2023/88 final. 
75 See footnote 38. 
76  ICCT,  2021  “Total  cost  of  ownership  for  tractor-trailers  in  Europe:  Battery  electric  versus  diesel”;  Traton  group: 
“Both BEV and FCEV are likely to ultimately beat Diesel on cost; H2Accelerate: Analysis of cost of ownership and the 
policy support required to enable industrialisation of fuel cell trucks. 18 July 2022. 

14 

 
 
                                                 
Regarding energy-saving technologies such as improved aerodynamics, the interest within the sector has 
been  low.  Despite  the  estimated  benefits77  highlighted  by  environmental  associations  and  flaps 
manufacturers, the operators consider that the use case for the rear flaps is limited. Firstly, because they 
are not suitable for certain types of vehicles (e.g. car transporters), cargo (e.g. indivisible loads), operations 
(e.g. intermodal operations) or weather conditions (e.g. snow and ice). Secondly, the rear flaps are mostly 
effective  in  vehicles  when  travelling  at  constant  high  speed  on  long  distances.  Hence  the  return  on 
investment is not warranted. As shown in Figure 5:  Power  required  for  a  40-tonne  vehicle  combination  to 
overcome  the  aerodynamic  drag  and  rolling  resistance,  as  a  function  of  the  vehicle  speed, aerodynamic drag 
only starts affecting fuel consumption significantly at higher speeds (60km/h and above),  which makes 
their use interesting for long-distance transport and on motorways.  

Figure 5: Power required for a 40-tonne vehicle combination to overcome the aerodynamic drag and rolling 
resistance, as a function of the vehicle speed 

Source: Martini, 2016 

Road transport operators also argue that the use of those devices requires additional skills and work of a 
driver  and  involves  the  risk  of  unintentional  damage.  The  lack  of  direct  economic  benefit  has  also 
eliminated the demand from trailer rental/leasing companies and poses a significant market barrier to the 
adoption of more energy-efficient vehicles78.  

According  to  the  Impact  Assessment  accompanying  the  current  HDV CO2  standards, the main  drivers 
hindering the uptake of more fuel-efficient technologies (other than ZEV) were found to be environmental 
externalities, imperfect and asymmetric information in the new vehicle market, access to finance and cost 
pass through.  

As regards aerodynamic cabs, truck manufacturers had insufficient time to bring them into the market. 
Firstly,  the  length  allowance  necessary  for  their  placing  unto  the  market  was  not  applicable  until  1 
September 202079. Secondly, cab designs usually have a fixed lifespan of the order of 10-20  years for 
economic reasons. Thirdly, there has been competing pressure from other regulations, such as the General 
Safety Regulation and the Direct Vision Regulation. Manufacturers have also indicated that their efforts 
were dedicated to the development of alternative powertrains as their preferred way to improve energy 

77 According to the impact assessment accompanying the  revision of the WDD in 2013, the use of rear aerodynamic 
devices could lead to a reduction in fuel consumption in the range of 5-8% [SWD(2013) 108 final]. More up-to-date 
assessment in SWD(2018) 185 final. 
78 SWD (2023) 70 final. 
79 Thanks to the adoption of Commission Decision (EU) 2019/984. 

15 

 
 
 
                                                 
efficiency in the transport sector. Nevertheless, they also indicated that they would continuously design 
more aerodynamic cabs, which will become the standard for all BEV trucks. 

Problem driver 3: Current technical standards do not sufficiently promote intermodal operations 

According to a recent comparative evaluation of transhipment technologies for intermodal transport80 the 
most common type of containers, in terms of length, used in containerised transport are 20’ (about 6.10m) 
and 40’ (about 12.20m) containers, with a standard external height of 8’ 6’’ (about 2.60m) or 9’ 6’’ (about 
2.90m, so-called high-cube container). The advantage of high-cube containers is their much better ratio in 
terms of volume per tonne.   

Skeletal trailers (container only – no deck), used for the transport of containers, typically have 1.4m height 
from  floor to  deck/container locks. With a height  of  about 2.90m high-cube containers  and  high  swap 
bodies,  HDV  transporting  them  reach  a  total  height  of  4.30m,  therefore  exceeding  the  maximum 
authorised height by 20 cm.  In the absence of additional height allowance of 20cm for HDVs in cross-
border operations, the use of high cube containers is limited to the domestic operations in the territories of 
Member  States  that  granted  national  derogations  increasing  the  maximum  height81.  Transport  of  high 
cube containers in cross-border operations requires a special permit for abnormal transport by HDV or 
necessitates the use of a special equipment (low wheels skeletal trailers) which adds costs to the transport 
operation.  

Figure 6: Dimensions of a skeletal trailer with a high cube container 

Source: Own representation 

In addition, the national derogations from the authorised weight limits allowed under W&D Directive for 
national transport put intermodal transport in a disadvantaged position as regards loading capacity. Under 
national weights derogations the HDVs gain a payload, while the extra 2 or 4t allowance for HDVs in 
intermodal transport only compensates the weight of an empty container to maintain the usual payload of 
40t HDV.   

80 doi: 10.2832/743839. 
81  Finland,  France,  Ireland,  Sweden  and  Slovenia  have  a  permissible  height  of  ≥4.2m  applicable  to  containerised  transport. 
Source:  https://www.itf-oecd.org/sites/default/files/docs/dimensions-2019.pdf.  Estonia  and  Italy  have  reported  to  grant  ISO-
containers at height of 4.3m. Source: CEDR Report 2017/05 (2017), https://www.cedr.eu/download/Publications/2017/2017-5-
Conditions-for-efficient-road-transport-report.pdf.  According  to  the  information  gathered  during  the  consultation  activities 
Sweden  and  Finland  allow  HDV  of  4.5m  height  provided  that  the  infrastructure  allows  it  (no  low  bridges).    Other  height 
derogations for vehicle carriers are also allowed in several Member States. 

16 

 
 
 
 
                                                 
Problem driver 4: The current legal framework hampers cross-border transport and the realisation of 
the full potential of heavier and/or bigger HDVs 

In line with the W&D Directive Member States may authorise the circulation on their national territory of 
HDV  exceeding  the  maximum  authorised  by  the  Directive  weights,  without  any  restrictions,  and 
maximum dimensions in prescribed cases, namely: specialised vehicles (e.g. used in the forestry industry), 
European Modular System (EMS) and trial schemes with vehicles incorporating new technologies or new 
concepts.  Several  Member  States  have  launched  trials  to  test  the  circulation  of  EMS,  where  the  most 
common combinations are 25.25 m and 60 tonnes.  

The W&D Directive does not explicitly allow  the use of heavier or longer vehicles  (i.e. exceeding the 
limits set in the Directive) in international transport. The HDVs used in international transport are bound 
by the limits set in the Directive even when they cross the territory of two neighbouring Member States 
that allow the same higher maximum authorised weights and/or dimensions on their territories. However, 
based on the broad interpretation of the W&D Directive, it was considered lawful to cross one border with 
such heavier and/or longer vehicles between neighbouring countries that allow the same  weight and/or 
dimensions excesses (further explained in problem driver 5). 

Currently, the use of modular systems (EMS) of at least 25.25m long is allowed in Finland and Sweden, 
and  is  being  tested  in  Denmark,  the  Netherlands,  Belgium,  Spain,  Portugal,  Czech  Republic  and 
Germany. Italy authorises longer semitrailers to allow for a maximum length of the vehicle combination 
of 18m. Cross-border transport of EMS is allowed between Finland and Sweden, Sweden and Denmark, 
Belgium and the Netherlands and between Germany and the Netherlands.  

Figure 7: Maximum national permissible lengths of HDVs and allowed cross-border transport  

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

All  Member  States  authorising  the  circulation  of  EMS  allow  them  with  a  maximum  gross  vehicle 
combination weight of at least 60 tonnes, with the exception of Germany where it is limited to 40 tonnes 
(44 tonnes in intermodal  transport).  Belgium, Czech Republic,  France,  Ireland,  Italy,  Luxembourg, the 
Netherlands, Portugal, Sweden, Denmark and Finland allow the circulation in national transport of five 
and/or six-axle vehicle combinations (standard articulated vehicles and road trains) with a weight of 44 

17 

 
 
 
tonnes and beyond, in some cases82. There is a particular situation of the Benelux countries. It originates 
in the Treaty Establishing the Benelux Economic Union83, which was recognised by article 350 of the 
Treaty  of  the  Functioning  of  the  EU84.  As  a  result,  Belgium,  Luxembourg  and  the  Netherlands  are 
allowed to conduct trials with heavier and longer HDV in cross-border operations between them in the 
context of the Benelux internal market. Currently, the Benelux countries allow for cross-border transport 
by heavier vehicles up to 44t. 

Figure 8: Maximum national permissible weights of HDVs and allowed cross-border transport  

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

Member States in which EMS are authorised, report that their use brings substantial savings in terms of 
energy consumption, greenhouse gas (GHG) emissions and operational costs. According to their ex-post 

82 Czech Republic allows a maximum weight of up to 48t, the Netherlands of up to 50t and Italy allows a maximum 
weight of up to 56t for the transport of excavation and mining materials. 
83 Consolidated version of the Treaty Establishing the Benelux Economic Union.  
84 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.”  

18 

 
 
 
                                                 
assessment the use of EMS does not attract freight transport from other modes of transport, and it slightly 
improves road safety without significant infrastructure investments85. 

The so called ‘loaded length’ of vehicle transporters is not regulated under the W&D Directive. Member 
States introduced national rules allowing the extra length via the use of front and/or rear overhangs when 
loaded. These national rules have been granted in all Member States but one86 and they allow for extra 
length for loaded vehicle transporter starting from 20.35m and beyond. In practice, cross-border transport 
of vehicles carriers exceeding the maximum length set in the WDD is considered lawful by most Member 
States as long as national standards in the territories crossed are met.  

Figure 9: Maximum “loaded” length (via front and/or rear overhangs) of vehicle transporters in meters in the 
EU based on national legislation  

Source: ECG  

The  transport of indivisible loads is  subject to  a  national permit  as  required  by  the  W&D  Directive. 
National rules vary significantly between Member States as regards 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 permits87 and the route selection and check88. To address these 

85  See  among  others  the  study  Cider  L,  Larsson  L,  HCT  DUO2-project  Gothenburg-Malmö  in  Sweden,  2019;  Road 
Accidents in Denmark Involving EMS; Evaluation of Trial  with European Modular System. December 2011. Danish 
Road  Directorate;  presentations  from  Finland,  Sweden  and  Denmark  at  “The  Nordic  perspective:  EMS  and  EMS2 
trucks––the positive outcomes and  lessons  learned”; position paper for the Finish Ministry of Transport of 8.4.2022; 
Socio-Economic  effects  of  loner  and/or  heavier  road  transport  vehicles-the  Swedish  case;  Monitoring  Modal  Shift. 
Longer and heavier vehicles. The follow-up measurement (2011). Ministry of Infrastructure and the Environment, The 
Netherlands; Monitoring traffic safety Longer and Heavier Vehicles. March 2020. Ministry of Transport, public works 
and water management, The Netherlands; Lahti. O. (2020): Fuel economy. Fuel economy 16.5 semitrailer 25.25 EMS. 
32 EMS2; University of Zaragoza. Análisis del comportamiento en pruebas de funcionamiento de vehículos modulares 
en  conjuntos  DUOTRAILER.  March  2020;  Accident  analysis  for  traffic  safety  aspects  of  High-Capacity  Transports. 
May 2014. Chalmers University of Technology, Department of Vehicle Safety.  
86 Malta that does not allow extra length for car transporters. 
87 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.  

19 

 
 
 
                                                 
administrative hurdles, the Commission Expert Group elaborated and adopted in 2008 the European Best 
Practice Guidelines for Abnormal Road Transports (BPG). Although the BPGs, as endorsed by Member 
States,  offered  a  list  of  rules  and  procedures  promoting  harmonisation,  safer  operations  and  improved 
transparency, the Guidelines have barely been followed by Member States. No progress has been made as 
regards the implementation of the uniform SERT document89 nor the abnormal transport corridors and 
only a few Member States have fully implemented the one-stop-shop principle.  

The  Directive  does  not  regulate  the  weight  of  5-  and  6-axle  rigid  trucks.  Therefore,  in  cross-border 
transport these vehicles must comply with the 32t weight limit set by the Directive for 4-axle rigid trucks 
(four-axle  motor  vehicles  with  two  steering  axles).  This  legislative  loophole  adds  to  operational  and 
energy inefficiencies when using such 5- or 6- axle rigid trucks in cross-border operations.  

Problem driver 5: Legal uncertainty about the applicable rules to cross-border transport and levels of 
enforcement 

The use of EMS in national transport in nine Member States triggered the question of the lawfulness of 
the  cross-border  transport  between  neighbouring  Member  States  that  allow  the  use  of  longer  and/or 
heavier vehicles  on their territories90.  The  Directive is  not sufficiently  clear  about  that.  Some  Member 
States considered that as there is nothing in the Directive clearly forbidding such cross-border operations, 
they  can  allow  the  cross-border  operations  by  longer  and/or  heavier  (EMS  and  44t  HDVs)  based  on 
bilateral  agreements.  These  diverging  interpretations  of  the  rules  in  force  have  led  to  diverging 
enforcements practices or even lack of controls of compliance. 

Another ambiguity stemming from the Directive relates to the rules for vehicle carriers in cross-border 
transport.  These  HDVs  use  overhangs  to  increase  the  maximum  length  when  they  are  loaded.  As  the 
Directive does not define a ‘loaded length’, some Member States and vehicle carriers consider that the 
Directive does not forbid cross-border operations by HDVs, the loaded length of which exceeds the length 
limits set in the W&D Directive. It is the general practice that cross-border transport of vehicle carriers is 
accepted as long as the extensions used (type and length) are permitted in the Member States  crossed. 
According to the complaint submitted by one of the key stakeholders in this segment, at least one Member 
State  started  fining  foreign  car  transporters  for  using  vehicles  with  a  loaded  length  exceeding  18.75m 
(maximum  authorised  by  the  WDD  in  international  traffic)  even  though  that  loaded  length  does  not 
exceed  the  national  extra  length  allowance  in  that  Member  State.  Such  inconsistencies  in  enforcement 
create legal uncertainty and raise the issue of discrimination against foreign operators.    

88  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.  
89 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 it is recognised in other 5 Member States. 
90 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, stated that the cross-border use of longer (not heavier) 
vehicles was lawful for journeys crossing one single border between two Member States that allow such longer vehicles 
on their territories if the derogation conditions were met, as it would not significantly affect international competition. 

20 

 
 
                                                                                                                                                                  
As regards the number and effectiveness of controls of overloaded HDV, the W&D  Directive requires 
that Member States carry  out in each calendar  year an appropriate number of checks on the weight of 
vehicles or vehicle combinations in circulation, proportionate to the total number of vehicles inspected 
each year in its territory. However, the Directive does not specify what can be considered “proportionate” 
and does not oblige Member States to notify the total number of HDVs inspected each year, which would 
enable to assess whether the share of controls on the maximum weights in the total number of controlled 
vehicles  is  proportionate.  The  biennial  implementation  reports  reveal  that  there  are  huge  discrepancies 
between Member States  as  regards the  number of controls  of  weight  of HDVs  carried out  every  year, 
ranging  from  5.2  million  and  3  million  (in  2020,  in  Ireland  and  Poland,  respectively)  to  370  and  700 
controls  (in  2020,  in  Latvia  and  the  Netherlands,  respectively).  The  effectiveness  of  those  controls  of 
compliance (detection rate calculated as a percentage of detected overloaded vehicles in total number of 
vehicles controlled) also differs vastly, ranging from 73% and 45% (in 2020, in Estonia and in Belgium, 
respectively)  to  0.2%  and  1%  (in  2020,  in  Poland  and  Sweden,  respectively).  These  differences  in 
performance  of  compliance  checks  undermine  the  harmonisation  and  internal  market  objectives  of  the 
Directive, leading to uneven competition, as companies in countries with lax enforcement may gain an 
unfair advantage over those in countries with stricter and more effective enforcement.  

Additional information on problem analysis 

The  relative  importance  of  the  three  identified  problems  (low  uptake  of  zero-emission  HDVs, 
fragmentation of the market for longer and heavier vehicles, and ineffective and inconsistent enforcement 
of transport rules for HDV) vary in the context of the underperformance of the Directive.  

Low  uptake  of  zero-emission  (ZE)  HDVs  and  of  energy-saving  solutions  have  multiple  underlying 
causes, among which the Directive’s deficiency has a limited contribution. The Directive focuses on the 
demand side of the ZE HDV market, but it fails to provide sufficient incentives for the sector to encourage 
the investment in zero-emission technologies, such as sufficient weights or dimensions to compensate the 
weight and/or size of the technology and ensure at least the same loading capacity as conventional fossil 
fuel HDVs. There are numerous other causes of the low uptake of zero-emission vehicles (ZEV), both on 
supply  and  demand  side,  which  cannot  be  attributed  to  or  solved  by  the  revision  of  the  Directive.  As 
regards  the  low  uptake  of  energy-saving  solutions,  such  as  aerodynamic  devices  and  cabs,  their 
deployment  was  dependent  on  the  adoption  of  the  type-approval  legal  framework,  which  effectively 
started applying only since 2020. Hence, this part of the problem does not stem directly and entirely from 
the Directive.  

The other two problems, fragmentation of the market for longer and heavier vehicles and ineffective and 
inconsistent  enforcement,  result  greatly  from  the  deficiencies  of  the  Directive.  Unclear  and  missing 
provisions  of  the  Directive  led  to  the  patchwork  of  national  rules  and  requirements,  diverging 
interpretations and control practices. The inconsistent enforcement (strict controls and sanctions in some 
Member States and lenient in others) results from the lack of mandatory level of controls and minimum 
common  control  requirements.  These  are  the  main  causes  of  the  Directive’s  underperformance  with 
regard to its objectives of ensuring free and efficient movement of goods and fair competition. These are 
also sources of potential risks to road safety and damage to infrastructure. 

As to the comprehensiveness of the problem analysis, it must be noted that the identified problem drivers 
focus only on those aspects that stem directly from the deficiencies of the Directive and which can be 
addressed  entirely  (e.g.  through  adapting  the  technical  standards,  clarifying  the  rules  for  cross-border 
operations, strengthening  enforcement  requirements)  or  partially  (e.g.  by  providing incentives  for  ZEV 
and energy-saving solutions) by the revision of the Directive. There are other issues, independent from the 

21 

 
 
Directive, that contribute to the Directive’s overall underperformance in achieving decarbonisation and 
harmonisation objectives. The low uptake of zero-emission vehicles for freight transport is also due to: 
higher  Total  Cost  of  Ownership  (TCO)  compared  to  conventional  vehicles,  low  availability  of 
recharging/refuelling  infrastructure,  long  duration  of  charging,  limited  range  of  vehicles,  lack  of  ZEV 
offer. Those issues are being addressed by other initiatives, such as the ‘Fit for 55’ initiatives, in particular, 
the Alternative Fuel Infrastructure Regulation (AFIR), the Eurovignette and the proposed revision of the 
CO2 standards Regulation for HDVs. The external factors contributing to challenges with harmonisation 
include:  economic  considerations  (e.g.  stakeholders  prioritize  cost-effectiveness,  profitability,  and 
competitiveness), safety concerns (stakeholders have differing perspectives on the safety implications of 
longer  and  heavier  vehicles), technological  challenges  (availability,  affordability,  and maturity  of zero-
emission HDV technologies and supporting infrastructure), national interests and specificities (e.g.  types 
of key industrial sectors, transport infrastructure capacities) 

The revision of the Directive is not the right tool to address those external aspects, therefore they 
are not included in this impact assessment analysis.  

2.3.  How likely are the problems to persist? 

Without EU action the issues related to the current technical standards that are not adapted to the needs of 
ZE HDVs and do not sufficiently promote intermodal operations are likely to persist.  
The road sector is composed mainly of SMEs91. Hauliers in the hire and reward market are often price 
takers rather than price makers for highly competitive work that yields low profit margin (1-3%)92. The 
IRU’s Market Analysis report of 2021 found that small companies with fewer than 10 employees had an 
average net profit margin of just 0.7% in 2020, while larger companies with more than 50 employees had 
an average net profit margin of 3.5%93.  

While the  Impact Assessment supporting the revision of CO2 HDV standards Regulation showed that, 
also for SMEs94, the fuel savings outweigh the increased capital costs of the vehicles, it is crucial, notably 
for SMEs, that profits are not negatively affected by the reduced payload for this to happen. The uptake of 
aerodynamic devices and energy-saving technologies is expected to be driven by the road toll discounts 
(possible  under  the  Eurovignette  Directive)  received  on  the  basis  of  mandatory  energy  efficiency 
certification of box shaped trailers95. and the uptake of ZE HDV96, as better aerodynamics increase the 

91  According  to  Eurostat  data  99%  of  all  companies  providing  road  transport  services  are  SMEs  (as  defined  by 
Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises -
OJ  L  124,  20.5.2003,  p.  36–41-,  i.e.  enterprises  employing  up  to  250  people  and  with  a  turnover  of  less  than  €50 
million). According to IRU  80% of companies operating commercial transport (including passenger cars professional 
services as taxis, rent a car, etc.) in the EU are SMEs and 30% of commercial road transport companies hold no more 
than 25 vehicles in their fleet. 
92Multiple sources: Commission report:  An Overview of the EU Road Transport Market in 2015. Task A  - Collection 
and  Analysis  of  Data  on  the  Structure  of  the  Road  Haulage  Sector  in  the  European  Union;  Commercial  Motor,  17 
February 2020;  
93 IRU Market Analysis report, 2021; 
94 The SMSs analysis took into account both: the increased capital costs (due to higher interest rate) and the fact that 
smaller companies value less future (energy) savings. It showed that the TCO is positive also for micro enterprises.  
95 Commission Implementing Regulation (EU) 2022/1362.  
96 According to the EU funded AEROFLEX project "innovations reduce the energy need for the complete vehicle 
combination: less energy need means more range with the same battery capacity and/or fuel cell in the pulling unit or 
the same range with a smaller battery and/or fuel cell". https://aeroflex-project.eu/wp-
content/uploads/2021/10/AEROFLEX_D6.6-Final-technical-assessment-results-CO-PUBSUM.pdf  

22 

 
 
                                                 
autonomy  range  of  ZEV.  Intermodal  transport  is  likely  to  remain  partially  disadvantaged  (in  terms  of 
payload)  compared  to  44t  HDVs  allowed  in  national  transport97  and  reduce  the  effectiveness  of  the 
revision of the Combined Transport Directive.   

The rising costs of fuel and increasingly stringent measures to reduce CO2 emissions from road transport 
(e.g. in the forms of fuel taxes and the ETS) as well as the scarcity of professional drivers will intensify the 
already  fierce  competition  between  hauliers  in  the  road  transport  sector.  In  search  for  savings,  the 
operators would likely  resort to  alternatives  with lower  costs of  capital than  ZEVs, such  as  the  use of 
biofuels, which are the preferred option for many  road transport operators98, as well as to  increase the 
loading capacity of trucks to the maximum extent possible.  

In the absence of EU action and changes to the legal framework, the fragmentation of the market will 
intensify. Diverging national rules and bilateral agreements will continue to be adopted among Member 
States, as already announced by some Member States, to address specific circumstances and to improve 
the operational and economic efficiency of road transport as well as cope with the shortage of professional 
drivers. 

As  regards  the  effectiveness  of  controls,  some  improvements  can  be  expected  thanks  to  gradual 
deployment of weigh-in-motion systems in all Member States and, to a lesser extent, of systems allowing 
the direct enforcement of the weight rules. However, the level of enforcement will vary from Member 
State  to  Member  State  and  the  compliance  with  the  rules  on  maximum  weights  and  dimensions  will 
continue to be subject to interpretation by the national authorities, and to the willingness of Member States 
to  enforce  the  rules  in  international  (intra-EU)  transport.  Without  providing  legal  clarity  on  the  rules 
applicable to cross-border operations by certain vehicles and the increase in effectiveness of enforcement, 
the  number  of  overloaded  vehicles  on  the  EU  roads  may  further  increase  causing  quicker  road  wear, 
endangering road safety and distorting competition. 

The analysis incorporates throughout all its dimensions relevant  foresight tools.  It does so to anticipate 
trends and issues that may affect the initiative and build a robust, future-proof evidence base for its likely 
impact.  The  megatrend  “climate  change  and  environmental  degradation”99  is  relevant  for  the  problem 
related  to  the  low  uptake  of  zero-emission  heavy-duty  vehicles  and  energy  saving  technologies  and 
schemes. According to the 2022 Strategic Foresight Report100, the aspect of “enabling a greener transport 
sector with digital technologies” is one of the areas where the twinning of the green and digital transitions 
is expected to have a major effect. It is particularly relevant to the challenges linked to the continuously 
growing population, increasing consumer awareness, evolving costs of sustainable transport options and 
new supply chain business models affecting the transport sector. This has been duly taken into account in 
the analysis presented in the following sections. 

97 Only France has adopted measures to (partially) compensate for the loss payload of containerised transport via the 
adoption  in  July  2022  of  a  Decree  (Décret  n°  2022-1045)  to  increase  the  maximum  weight  of  trucks  involved  in 
combined transport from 44t to 46t as part of an 18 months experiment. 
98 Among others Accelerating the decarbonisation of road transport through the faster update of alternative fuels, IRU 
position paper 12 November 2020, and UPS, Delivering sustainable logistics and smart recharging, 14 September 2022. 
99 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en  
100 COM(2022) 289 final. 

23 

 
 
                                                 
3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

Title VI (Transport, Articles 90-100) of the Treaty  on the Functioning of the European Union (TFEU) 
establishes the EU’s right to act in the area of transport. Article 91(1)(a) of the TFEU provides that the 
Union  has  competence  in  the  field  of  transport  to  lay  down  common  rules  applicable  to  international 
transport between the EU Member States and Article 91(1)(d) TFEU provides the same competence to 
adopt any other appropriate provisions in the transport policy area. 

3.2.  Subsidiarity: Necessity of EU action 

The  on-going  deepening  of  the  EU  Internal  Market  together  with  the  liberalisation  of  the  road  freight 
transport market have increased cross-border trade and the transnational dimension of the road transport 
services. To facilitate cross-border operations by HDVs while ensuring fair competition and road safety 
on  the  EU  internal  market,  the  EU  has  already  adopted  legislation  –  Directive  96/53/EC  –  setting  the 
limits as to the size and weights of the HDVs used in such operations. At the same time, in line with the 
subsidiarity principle, the Directive safeguards the right of each Member State to allow the circulation of 
bigger  and/or  heavier  vehicles  on  its  own  territory  according  to  their  geographical  and  economic 
specificities, such as industry needs, transport infrastructure, availability and capacity of other transport 
modes, etc.  

While  the  Directive  represents  a  step  forward  in  the  process  of  harmonisation  of  certain  technical 
standards of the HDVs circulating on the EU roads, the deficiencies of the Directive identified during the 
evaluation, result in 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 
Transport  Area  that  should  ease  the  movements  of  citizens  and  freight,  reduce  costs  and  enhance  the 
sustainability  of  European  transport.  EU  action  is  necessary  to  remove  these  unnecessary  barriers  to 
efficient, fair and sustainable transport operations on the EU internal market.  It is for the same reason 
necessary to provide legal certainty and to ensure the compliance with the rules applicable in cross-border 
transport, in particular as regards HDV exceeding the maximum weights and dimensions set in the W&D 
Directive as allowed in national traffic. 

In  addition,  the  Directive  has  proven  ineffective in  boosting the uptake of alternative  fuels  and  energy 
saving  technologies  and  only  partially  effective  in  promoting  intermodal  transport.  In  the  context  of 
emerging technological developments in the automotive industry and new EU targets on decarbonisation 
of transport sector as a whole, it is necessary to take further EU actions to incentivise and accelerate the 
deployment of zero-emission HDVs, improve compatibility with other modes of transport and contribute 
to the EU greening objectives. 

The  revision  of  the  Directive  does  not  affect  the  possibility  for  Member  States  to  develop  solutions 
according to local circumstances and for operations on national territories.  

The public consultation revealed that 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  and  to 
improve the environmental performance of the transport sector.  

24 

 
 
3.3.  Subsidiarity: Added value of EU action 

The evaluation of the Directive confirmed its added value by establishing EU standards for weights and 
dimensions  of HDVs  used  in  cross-border operations.  It  has  also  revealed  the Directive’s  deficiencies, 
including legal loopholes and ambiguities, standards not adapted to the technological progress, hampering 
the use of the latest decarbonisation technologies and improving efficiency of cross border transport.  

A lack of coordinated EU action would translate into the need for Member States to act individually and 
to  reach  bilateral  agreements,  leading  to  a  risk  of  further  market  fragmentation  due  to  the  diversity  of 
national  rules.  Market  fragmentation  would  potentially  translate  into  competitive  distortions  and 
discriminatory control practices. It would also weaken the incentive to deploy zero-emission vehicles and 
energy efficient technologies to the overall EU market. Furthermore, while public financial support plays 
a role to promote the market uptake of zero-emission vehicles, they differ among Member States, some of 
which  may  not  adopt  them  at  all,  and  they  would  not  provide  with  the  necessary  stability  and 
irreversibility  for  a  long-term  business  case  that  would  allow  strategical  planning  for  road  transport 
operators and HDV manufacturers. 

Overall, initiatives at the national, local and sectoral level will not be sufficient or adequate to address the 
identified EU-wide problems and their underlying drivers and to deliver on decarbonisation targets set at 
the EU level.  

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The  general  objectives  of  this  initiative  are  to  improve  the  energy  and  operational  efficiency  of  road 
transport operations in the broader context of increased EU environmental and climate ambition by 2030 
and EU climate neutrality by 2050 (i.e., achieve net zero GHG emissions by 2050) and to ensure the free 
movement of goods and fair competition on the internal road transport market. 

4.2.  Specific objectives 

The specific objectives of this initiative are threefold: 

1.  To remove barriers for the uptake of ZEV and energy-saving devices and incentivise intermodal 

transport.  

2.  To harmonise the rules on maximum weights and dimensions of HDV in cross-border operations. 
3.  To improve the enforcement of cross-border rules, including for road safety purposes. 

These  objectives  must  be  achieved  while  safeguarding  the  balance  between  the  requirements  of 
infrastructure maintenance, road safety and the reduction of the GHG and pollutant emissions from the 
transport system. The connection between problem drivers, specific objectives and general objectives is 
presented in Figure 10. 

25 

 
 
Figure 10: Correspondence between the problem drivers and the specific objectives 

The  first  specific  objective  is  related  to  the  EU  Green  Deal  goals.  It  reflects  the  need  to  remove  the 
existing technical and economic barriers to facilitate and speed up the uptake of the “greening measures” 
(ZEVs, energy-saving technologies and intermodal transport). It addresses problem drivers 1, 2 and 3 by 
providing  clear  incentives  and/or  requirements  for  road  transport  operators  to  improve  energy  and 
operational performance of transport operations including through enhanced modal cooperation.  

The  second  objective  is  related  to  the  policy  goal  of  achieving  the  EU  Single  Market  and  addresses 
problem  driver  4.  This  specific  objective  will  provide  an  adequate,  stable  and  enforceable  regulatory 
framework for more efficient and more sustainable transport operations by bigger and/or heavier HDVs. 
More  efficient  road transport operations  by  such vehicles  will also  contribute to  economic  growth  and 
bring environmental and social benefits including by reducing the number of vehicles and drivers needed 
to carry the same amount of cargo.  

The third specific objective relates to a general EU goal of effective enforcement and uniform application 
of  the  EU  law.  It  addresses  problem  driver  5  and  is  closely  linked  with  the  specific  objective  2  to 
harmonise and streamline the rules to be enforced. It will step up enforcement by providing  for better, 
more targeted, more efficient and consistent controls of compliance. This serves the general objective of 
ensuring fair conditions of competition and ensures road safety and the protection of the infrastructure.   

The specific objectives will also contribute towards the Sustainable Development Goal SDG 13 (“Take 
urgent action to combat climate change and its impacts”) and SDG 3 (“Ensure healthy lives and promote 
well-being for all at all ages”). 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

The  EU  Reference  scenario  2020  (REF2020)  is  the  starting  point  for  the  impact  assessment  of  this 
initiative. The REF2020 takes into account the impacts of the COVID-19 pandemic that had a significant 
impact on the transport sector. More detailed information about the preparation process, assumptions and 

26 

 
 
 
 
results are included in the Reference scenario publication101. Building on REF2020, the baseline has been 
designed to include the initiatives of the ‘Fit for 55’ package proposed by the Commission on 14 July 
2021102 and the initiatives of the RePowerEU package proposed by the Commission on 18 May 2022103.  
The baseline scenario factors in the proposals for a revision of the HDV CO2 standards Regulation104 and 
the new Euro 7  standards105 as well as other initiatives being part of the  Road Safety Package106. The 
baseline  scenario  assumes  no  further  EU  level  intervention  beyond  the  current  W&D  Directive.  More 
details on the baseline are provided in Annex 4107. 

The baseline also incorporates foresight megatrends108 and developments captured in the 2022 Strategic 
Foresight Report109. Among others, it captures the trend of increasing demand for transport as population 
and living standards grow as well as the links between the digital and green transition. In particular, the 
projected transport activity draws on the long-term population projections from Eurostat and GDP growth 
from the Ageing Report 2021110 by the Directorate General for Economic and Financial Affairs. 

In the baseline scenario, EU transport activity is projected to grow post-2020, following the recovery from 
the COVID pandemic. Road transport would maintain its dominant role within the EU by 2050. Buses 
activity (expressed in passenger-kilometres) is projected to grow by 13% between 2015 and 2030 (42% 
for 2015-2050). For freight, heavy goods vehicles activity (expressed in tonne-kilometres) is projected to 
go up by 30% by 2030 relative to 2015 (57% for 2015-2050). The activity of heavy goods vehicles above 
32 tonnes would grow at slightly slower pace, by 27% by 2030 relative to 2015 (47% for 2015-2050). 
Rail transport activity is projected to grow significantly faster than for road, driven in particular by the 
completion of the TEN-T core network by 2030 and of the comprehensive network by 2050, supported by 
the  CEF,  Cohesion  Fund  and  ERDF  funding,  but  also  by  measures  of  the  ‘Fit  for  55’  package  that 
increase to some extent the competitiveness of rail relative to road and air transport. Passenger rail activity 
is projected to go up by 24% by 2030 relative to 2015 (67% for 2015-2050). Freight rail traffic would 
increase by 42% by 2030 relative to 2015 (91% for 2015-2050)111. Congestion costs would increase by 
about 14% by 2030 and 32% by 2050, relative to 2015. Congestion on the inter-urban network would be 
the result of growing freight transport activity along specific corridors, in particular where these corridors 

101  https://energy.ec.europa.eu/data-and-analysis/energy-modelling/eu-reference-scenario-2020_en 
102 COM(2021) 550 final. 
103 COM(2022) 230 final. 
104 COM(2023) 88 final. 
105 COM(2022) 586 final.   
106  Proposal  for  a  Directive  amending  the  Driving  Licence  Directive,  proposal  for  a  Directive  amending  the  Cross-
Border  Enforcement  Directive  and  proposal  for  a  Directive  on  the  Union-wide  effect  of  certain  driving 
disqualifications. 
107  The  baseline  scenario  does  not  consider  the  forthcoming  revision  of  the  Combined  Transport  Directive,  the  rail 
capacity initiative and the CountEmissions EU initiative. It should be noted that including the proposed revision of the 
Combined  Transport  Directive  in  the  baseline  would  lead  to  higher  uptake  of  intermodal  transport.  Thus,  the  policy 
options  would  result  in  somewhat  lower  reduction  in  external  costs  of  transport  relative  to  the  baseline,  and  thus 
somewhat lower net benefits. This is however not expected to result in a change in the ranking of the policy options. 
108 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
109 COM(2022) 289 final. 
110 doi:10.2765/733565. 
111 The Sustainable and Smart Mobility Strategy uses 2015 as the base year for the milestones on the growth in rail and 
waterborne  transport  activity.  In  addition,  due  to  the  COVID-19  pandemics,  the  lockdowns  and  all  the  consequent 
effects on the transport sector do not qualify 2020 as representative base year. For these reasons, 2015 has also been 
selected as a base year for showing the growth in road transport activity. Using 1995 as a base year the growth in heavy 
goods vehicles activity (expressed in tonne-kilometres) is projected at 79% by 2030 relative to 1995 (116% for 1995-
2050) in the baseline scenario. For buses, the growth for 1995-2030 is projected at 17% (47% for 1995-2050). 

27 

 
 
                                                 
cross urban areas with heavy local traffic.  

The share of zero-emission vehicles in the total heavy goods vehicles stock is projected at 5% in 2030, 
going up to 30% in 2040 and 71% in 2050 in the baseline scenario. In terms of tonne-kilometres, zero-
emission heavy goods vehicles are projected to account for 136.8 billion tonne-kilometres in 2030 (around 
7% of total tonne-kilometres by heavy goods vehicles), 1,060.7 billion tonne-kilometres in 2040 (around 
48% of the total tonne-kilometres by heavy goods vehicles) and 2,147.3 billion tonne-kilometres in 2050 
(around 88% of the total tonne-kilometres by heavy goods vehicles). 

CO2  emissions from transport112  are projected to be  26%  lower  by  2030  compared to 2015,  and  94% 
lower by 2050. The baseline scenario shows that the emission reductions from the transport sector would 
contribute towards the ambition of at least 55% emission reductions by 2030 and climate neutrality by 
2050, while relying to a significant extent on technological solutions (i.e. the uptake of low-  and zero-
emission vehicles and of renewable and low carbon fuels) and carbon pricing. This would depart from the 
balanced approach underpinning the impact assessments accompanying the ‘Fit for 55’ package and the 
staff working document accompanying the REPowerEU initiatives113, showing a combined approach of 
carbon pricing instruments and regulatory-based measures to deliver on the increased climate ambition114. 
NOx emissions are projected to go down by 56% between 2015 and 2030 (87% by 2050), mainly driven 
by the electrification of the road transport and in particular of the light duty vehicles segment. The decline 
in particulate matter (PM2.5) would be slightly lower by 2030 at 53% relative to 2015 (91% by 2050)115.  

Heavy duty vehicles can generate increased wear and tear of infrastructure. In the baseline scenario, the 
road  maintenance  costs  attributed  to  HGVs  above  32  tonnes  are  projected  to  increase  from  EUR  13.9 
billion in 2015 to EUR 15.5 billion in 2030 and EUR 18.9 billion in 2050.  

The  baseline  scenario  reflects  the  projected  higher  energy  prices  driven  by  the  Russian  invasion  of 
Ukraine116. Beyond this aspect, it was however not possible to quantify the impact of the Russian invasion 
of Ukraine in the context of the baseline scenario, as there is large uncertainty with respect to its impacts, 
in  particular  for  the  medium  to  long  term.  While  its  impact  is  felt  in  terms  of  trade  (e.g.  grain,  bulk 
fertilizers and hydrocarbons) and in certain geographical areas, the impact on the baseline of this initiative 
is expected to be relatively limited.  

112 Including international aviation but excluding international maritime. 
113  SWD(2022) 230 final. 
114  The scenarios underpinning the impact assessments accompanying the ‘Fit for 55’ initiatives and the staff working 
document accompanying the REPowerEU initiatives incorporated a broader range of policies (including this initiative) 
that were represented in a stylised way ahead of the actual proposals, to show the delivery of at least 55% emissions 
reduction  target  by  2030  and to  account  for  the  interaction  with  the  forthcoming  initiatives.  Therefore,  this  initiative 
contributes towards at least 55% emissions reductions target by 2030 and achieving climate neutrality by 2050. 
115  The  baseline  projections  are  quantified  with  the  PRIMES-TREMOVE  model,  which  projects  the  evolution  of 
demand  for  passengers  and  freight  transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a 
formulation based on  microeconomic  foundation of decisions of  multiple actors. Operation, investment and emission 
costs, various policy measures, utility factors and congestion are among the drivers that influence the projections of the 
model.  The  projections  of  activity,  equipment  (fleet),  usage  of  equipment,  energy  consumption  and  emissions  (and 
other externalities) constitute the set of model outputs. More details are provided in Annex 4. 
116 SWD(2022) 230 final.  

28 

 
 
                                                 
5.2.  Description of the policy options 

Based  on  the  consultation  activities  and  desk  research  undertaken  in  the  context  of  the  Impact 
Assessment117, the Commission identified a set of individual measures having the potential to address the 
problem drivers identified in the problem definition in section 2.  

The  following  process  was  applied  for  establishing  the  policy  packages:  (i)  identifying  the  policy 
measures which can be discarded based on a first preliminary assessment; (ii) identifying a list of retained 
policy  measures  addressing  the  problems  and  respective  problem  drivers;  (iii)  combining  retained 
measures into policy packages constituting viable policy alternatives for achieving the objectives of the 
initiative.  

5.2.1.  Discarded policy measures 

Some policy measures considered in the preparatory phase of the impact assessment were discarded based 
on pre-screening and preliminary assessment of their potential contribution to solving the problems and 
addressing the problem drivers. These measures include: (i) the mandatory craneability118 of semitrailers; 
(ii)  mandatory  equipping  of  HDVs  with  aerodynamic  devices;  (iii)  mandatory  equipping  of  HDVs, 
exceeding  the  maximum  weights  set  in  the  Directive,  with  on-board  weighing  (OBW)  device.  The 
detailed explanations of the discarded policy measures are provided in Annex 8. 

In addition, a simplification of the HDV weights and dimensions regulatory framework based on fit-for-
purpose  approach  has  not  been  considered.  First,  the  issue  of  weights  and  dimensions  of  HDVs  is 
complex  and  interconnected  with  various  factors,  such  as  road  safety,  infrastructure  capacity, 
environmental impact, and market competitiveness. Simplifying the regulatory framework while ensuring 
these aspects are adequately addressed can be very challenging. Secondly, stakeholder interests differ. The 
weights  and  dimensions  of  HDVs  involve  multiple  stakeholders,  including  manufacturers,  transport 
operators,  infrastructure  managers,  and  public  authorities.  Each  stakeholder  has  specific  interests  and 
concerns,  which  can  make  it  difficult  to  reach  a  consensus  on  a  simplified  regulatory  framework  that 
satisfies all parties involved. Thirdly, there are various technical and operational considerations that have 
to be addressed. HDVs come in various configurations and are used for different purposes, such as long-
haul transport, urban delivery, or specialized operations. Designing a simplified regulatory framework that 
accommodates  these  diverse  needs  and  ensures  safe  and  efficient  operations  can  be  a  considerable 
challenge. 

5.2.2.  Retained policy measures 

The  retained  policy  measures  have  been  grouped  in  3  policy  options:  policy  option  A  (PO-A),  policy 
option  B  (PO-B)  and  policy  option  C  (PO-C).  Table  1  provides  an  overview  of  the  retained  policy 
measures and their links with specific objectives and policy options. A more detailed description of the 
policy measures is included in Annex 6. 

Table 1: Policy options and policy measures 

117 Details on all consultation activities are provided in Annex 2. 
118 Craneability refers to the feature of a vehicle that make it suitable for handling by cranes to move a loading unit (e.g. 
semitrailer) from road vehicle to pocket wagon or on another mode vehicle. Craneable vehicles usually have reinforced 
frames  and  chassis  and  accessory  features  such  as  hydraulic  systems  and  must  be  compatible  with  crane  type  and 
capacity. 

29 

 
 
                                                 
Specific objective 

No. 

Policy measure 

PO A 

PO B 

PO C 

SO1: Remove barriers for the uptake of 
ZEV and energy-saving technologies & 
incentivise intermodal transport 

SO2: Harmonise the rules on maximum 
W&D of HDV in cross-border operations 

SO3: Improve the enforcement of cross-
border rules, including for road safety 
purposes 

Common policy measures (PMc) to all policy options 

PMc1 

PMc2 

PMc3 

PMc4 

Allow for extra weight and extra length for ZE heavy 
goods vehicles and 2-axle rigid buses 
Allow for extra height to accommodate high-cube 
containers in intermodal transport 
Harmonise maximum permitted weight of 5- and 6-
axle HDV (40t)  
Allow cross-border transport of 44t-HDV and EMS 
between "allowing" MS 

PMc5 

Harmonise the loaded length of vehicle carriers  

PMc6 

PMc7 

Reinforced MS obligation to conduct minimum level 
of checks of HDV's weight 
Set common principles for the voluntary 
implementation of intelligent access policies 

X 

X 

X 

X 

X 

X 

X 

Policy measures (PM) assigned to one or two different policy options (PO) 

SO1: Remove barriers for the uptake of 
ZEV and energy-saving technologies & 
incentivise intermodal transport 

SO2: Harmonise the rules on maximum 
W&D of HDV in cross-border operations 

SO3: Improve the enforcement of cross-
border rules, including for road safety 
purposes 

PM1 

PM2 

PM3 

PM4 

PM5 

PM6 

PM7 

PM8 

Allow for extra weight for HDV which are ZEVs 
regardless the weight of the ZE technology used 
Align definition of intermodal transport with the 
Combined Transport Directive (to include all 
intermodal loading units) 
Allow international (intra-EU) transport of EMS1119 at 
least in core and comprehensive TEN-T network 
conditioned to be ZEV or part of an intermodal transport 
operation  
Set minimum administrative and safety requirements 
for the transport of indivisible loads 
Set international transport corridors for indivisible 
loads 
Require a minimum number of Weigh-in-motion 
systems to be deployed in the TEN-T network 
Require a minimum amount of "certified" Weigh-in-
motion (WIM) systems to be deployed in the TEN-T 
network for direct enforcement purposes 
Require EMS to comply with higher safety standards for 
HDV than those provided for in the General Safety 
Regulation and driver's minimum experience or training 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

5.2.3.  Description of policy options 

Policy option A  

Policy option A (PO-A) includes seven policy measures that are common to all three policy options. The 
inclusion  of  the  “common”  policy  measures  in  all  three  policy  options  reflects  the  extensive  feedback 
gathered from public and private stakeholders related to their needs, as well as to the current practices and 
experiences reported by Member States and by the private sector. Both public and private stakeholders 

119 EMS1 is a modular combination of standard vehicles (motor vehicle, tractor, trailer, semitrailer),  where (typically) 
the maximum length of the combination is 25.25 m and the weight 60t, depending however on the number of axles. 

30 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
                                                 
were  supportive  of  the  common  policy  measures  in  the  context  of  the  stakeholders’  consultation 
process120.  

PO-A guarantees  the minimum progress needed to address all problem drivers and specific objectives, 
ensuring legal clarity and a certain level of harmonisation of rules consolidating current positive practices. 
Namely, in relation to Specific Objective 1 (SO1: Remove barriers for the uptake of ZEV and energy-
saving technologies & incentivise intermodal transport), PO-A seeks to ensure that zero-emission HDVs 
and intermodal transport are on equal footing compared to diesel trucks and road-only transport in terms 
of payload capacity and height of high-cube containers, respectively. To do that PO-A allows extra weight 
and length to accommodate ZE technologies, including in trailers, semitrailers and dollies and in two-axle 
rigid  buses  (PMc1),  and  allows  extra  height to  accommodate  for  the transport of high-cube  containers 
used in intermodal operations (PMc2). 

PMc1  would  address  the  needs  identified  in  problem  drivers  1  and  2.  It  provides  for  increasing  the 
maximum gross vehicle combination weight (GVCW) up to a maximum of 4 tonnes121, the maximum 
axle weight, when necessary, and the maximum length up to 90 cm, in order to compensate for the weight 
and  the  size  of  ZE  powertrains  (i.e.  weight  of  electric  batteries  and  space  for  hydrogen  tanks)  thus 
preventing  the  loss  of  payload.  This  allowance  for  ZE  HDVs  would  apply  to  any  zero-emission 
technology installed in any vehicle, including 2-axle rigid buses, which under current rules are excluded 
from  extra  weight  allowance  for  ZE  powertrains,  and  any  combination  of  vehicles  (motor  vehicle, 
semi/trailers and dollies). As regards the heaviest vehicle combinations, i.e. those with 5 or more axles, 
this measure would enable a maximum GVCW of 44 tonnes for HDVs in road-only operations and of 46 
or 48 tonnes (depending on the axle combination) for HDVs in intermodal operations. The current legal 
framework allows already circulation of vehicles with a maximum GVCW of up to 46 tonnes in case of 
ZE HDV (extra 2 t) involved in intermodal transport operations (extra 4 t). PMc1 as well as the measure 
PMc2 on increasing the height of HDV to accommodate high-cube containers will address the problem 
driver 3 by ensuring that the technical requirements of HDVs are compatible with technical standards in 

120 In particular, the extra weight or dimensions to accommodate the ZE technology (and prevent the loss of payload) 
and  allowing  44t  HDVs  and  EMS  in  operations  between  Member  States  allowing  those  vehicles  on  their  territories 
have been broadly supported. Among more than 700 contributions in total, around 10% of contributions opposed or not 
fully supported the higher weights and dimensions of vehicles in cross-border transport. These positions were mainly 
from  rail  sector  concerned  about  increased  competitiveness  of  road  sector  and  from  few  Member  States  who  do  not 
allow heavier vehicles due to the concerns of a damage to infrastructure and risks to road safety. The contributions from 
multimodal stakeholders showed support to additional weights and dimensions  if it benefits intermodal transport. The 
workshops  with  Member  States  (53  participants)  and  with  industry  stakeholders  (171  participants),  organised 
separately, revealed that both types of stakeholders have the same priorities as regards removing barriers  to the uptake 
of ZE HDVs and to the use of energy and operational efficient vehicles and schemes (EMS). They have voted equally 
high on increasing the weights and dimensions for ZE HDVs and for allowing EMS and 44t HDVs between allowing 
Member  States  or  broader,  but  on  the  TEN-T  network.  They  have  also  equally  prioritized  the  need  to  improve 
enforcement by increasing the level of controls as well as ensuring that EMS comply with the latest safety standards. 
121  Currently  the  W&D  Directive  allows  an  additional  GVW  of  2  tonnes  for  certain  ZE  HDVs  which  would  be 
incremented in another 2 tonnes resulting in a potential increased GVW of 4 tonnes. 

31 

 
 
 
 
                                                 
other modes of transport thus facilitating intermodal operations122.  

To  address the Specific Objective 2  (SO2:  Harmonise the  rules  on  maximum  W&D  of  HDV  in  cross-
border  operations),  PO-A  builds  on  the  current  practices  regarding  the  excesses  in  weights  and 
dimensions that have been tolerated or considered lawful by the Member States, in particular, in cross-
border  transport  of  44-tonnes  HDV,  European  Modular  System  (EMS)  and  vehicle  carriers.  A  certain 
level of harmonisation is provided based on the national rules shared among neighbouring Member States. 
PO-A  offers  three  measures  to  address  Specific  Objective  2:  PMc3,  PMc4  and  PMc5.  PMc3  aims  to 
further harmonise the maximum permitted weight of 5- and 6-axle HDV in cross-border transport (set at 
40t) by including also 5- and 6-axle rigid trucks in scope of the Directive. PMc4 will allow cross-border 
transport of 44t HDV (articulated vehicles and road trains) and/or EMS between allowing Member States 
(i.e. Member States that allow such heavier and/or longer vehicles in national transport). Both measures – 
PMc3  and  PMc4  -  will  address  the  problem  driver  4  by  removing  unjustified  barriers  to  using 
heavier/longer  vehicles  in  cross-border  operations  between  Member  States  that  use  such  vehicles  in 
domestic operations. PMc5  will introduce a harmonised maximum loaded length of vehicle carriers  of 
20.75m which will also contribute to solving problem driver 4. This measure will also contribute to the 
harmonisation objective of the intervention by removing the national divergences as regards the type and 
length of overhangs allowed.  

Responding to Specific Objective 3 (SO3: Improve the enforcement of cross-border rules, including for 
road safety purposes), PO-A improves enforcement by setting a minimum number of controls per million 
vehicle-km to be performed yearly by Member States as regards compliance of HDVs with the rules on 
maximum weights (PMc6), corresponding to the median level in the EU. In addition, PO-A provides for a 
harmonised approach for the voluntary implementation of intelligent access policies123  based on general 
principles of accessibility, non-discrimination and interoperability of systems (PMc7). This measure aims 
to  further facilitate  efficient  enforcement  and to  prevent  a  risk  of damage to  infrastructure  and of  road 
safety by some types of heavier and/or longer HDV124. These measures will address problem driver 5 and 
will  contribute  to  stepping  up  enforcement  of  the  rules  in  force,  providing  with  a  comprehensive 

122 The W&D Directive sets the maximum authorised height in international (intra-EU) transport at 4m, which requires 
road transport operators involved in the transport of high-cube containers to resort to special equipment (low skeletal 
trailers and gooseneck trailers) or to request special permits for indivisible loads (only possible in cases where the road 
infrastructure  can  accommodate  4.3m  high  HDV).  Twelve  Member  States  allow  higher  limits  in  national  transport: 
Slovenia,  Hungary  and  Slovakia  allow  a  maximum  authorised  height  of  4.2  meters  and  Finland,  France,  Ireland, 
Sweden,  Estonia,  Italy,  Bulgaria,  Portugal  and  Spain  allow  4.3  meters  or  more.  PMc2  aims  at  removing  the  “legal” 
limitation to the circulation of HDVs transporting high-cube containers (or swap bodies of equivalent height), without 
prejudice to the application of road traffic national provisions limiting the maximum height of HDV on certain roads of 
civil engineering structures. 
123  Intelligent  Access  Policies  (IAP)  is  an  extension  of  already  existing  Urban  Vehicle  Access  Regulation.  IAP 
primarily ensures matching the performance and characteristics of a road freight vehicle with the state and capability of 
specific  section  of  an  infrastructure  network,  i.e.  it  ensures  that  the  correct  vehicles  runs  on  the  correct  road  at  the 
correct time. The IAP concept is tested in some projects like the NORDICWAY project. 
124  Intelligent  access  policies  (IAP)  are  in  their  initial  stages  of  conception  and  testing,  which  limits  PMc7  to  the 
establishment  of  common  general  principles  to  facilitate  their  harmonised  deployment  in  the  future.  The  actual 
implementation  of  IAP  would  have  the  potential  to  facilitate  the  introduction  of  a  performance-based  approach  to 
allowing the circulation of heavier and/or longer HDVs and to facilitate the enforcement of rules. However, it cannot 
provide  support  for  greening  or  enable  the  harmonisation  of  rules.  Therefore,  it  can  only  be  considered  as  a 
complementary  measure.  At  the  same  time,  Member  States  have  opted  for  the  deployment  of  weighing  systems 
installed  in  the  infrastructure  (the  so-called  weigh-in-motion  or  WIM  systems),  as  opposed  to  on-board-weighing 
equipment to be installed in the vehicle. The WIM systems allow to achieve the same results as the IAP rendering the 
mandatory deployment of IAP redundant. Hence, IAP are considered to be deployed on a voluntary basis. 

32 

 
 
                                                 
framework  for  the  safe  and  fair  circulation  of  HDVs  exceeding  the  maximum  authorised  weights  and 
dimensions, including those in support of zero-emission propulsion systems and intermodal transport. 

Overall, PO-A is expected to largely contribute to removing the existing regulatory barriers for the uptake 
of ZE technologies and to indirectly promote the uptake of aerodynamic devices which will render the use 
of  ZE powertrains more  efficient  (e.g.  longer  range travelled  and longer battery  life) by  reducing their 
energy consumption. As regards the harmonisation of the rules, PO-A will sanction existing practices that 
have proven successful in several Member States in terms of economic and environmental benefits. This 
policy option will only partially address the fragmentation of the market, given that not all Member States 
allow any excesses in weights and dimensions in national transport, leaving a variety of rules that would 
also pose a challenge in terms of enforcement in cross-border operations. The barriers to the development 
of  intermodal  transport  would  also  be  partially  eliminated.  This  policy  option  will  ensure  a  common 
minimum level of enforcement to check maximum permitted weights (total and per axle) and support the 
voluntary implementation of innovative enforcement tools in a harmonised way, as overload of vehicles is 
one of the most common infringements and has a direct impact on competition, road safety and damage to 
road infrastructure.  

Policy option B 

Policy  Option  B  (PO-B)  includes  all  seven  common  policy  measures  and  additional  ones  providing 
further  incentives  for  the  deployment  of  ZE  HDVs,  encouraging  intermodal  transport,  more 
harmonisation  in  terms  of  administrative  requirements  for  specific  cross-border  operations  requiring 
permits and more requirements related to enforcement.   

In PO-B, in relation to specific objective 1, support to greening goes further than in PO-A by offering a 
competitive  advantage  to  road  operators  using  ZEV  or  being  involved  in  intermodal  transport  (i.e.  by 
considering  lorries,  trailers  and  semitrailers  as  intermodal  transport  units).  In  addition  to  the  common 
policy measures  discussed above, PO-B will address SO1 by  two measures. PM1 will allow a fixed 4 
extra tonnes for HDV which are ZEV, irrespective of the ZE powertrain technology used, thus addressing 
problem  driver  2.  While  maintaining  the  same  maximum  GVW  as  in  PO-A,  this  policy  measure  will 
incentivise investment in the newest technologies that will become lighter/smaller allowing for gains in 
payload. Those Member States which already allow the circulation of HDV of up to 44 tonnes will be 
allowed to continue to do so during a transition period also in cross-border traffic, as enabled by PO-A125.  

PM2  will  address  problem  driver  3  by  aligning  the  definition  of  intermodal  transport  in  the  W&D 
Directive with the Combined Transport Directive in order to consider semitrailers as intermodal transport 
units  (now  limited  to  containers  and  swap  bodies)126.  As  a  consequence,  HDVs  for  which  trailers  or 
semitrailers are used for intermodal operations would benefit from 4 additional tonnes of payload as there 

125  PM1  will  limit  the  possibilities  granted  under  PMc4  as  regards  the  circulation  of  44-t  HDVs  in  cross-border 
transport after the transition period, which will only be possible if they are zero-emission or, as it is the case under the 
current legal framework, involved in intermodal transport. PO-B will also maintain the possibility to cumulate the extra 
weight of the zero-emission technologies (4 tonnes under PM1) to the additional allowance granted to HDVs involved 
in intermodal transport.  
126 Under the W&D Directive, HDVs involved in intermodal transport 5/6-axle articulated vehicles and road trains are 
granted  an  additional  GVW  of  2  tonnes  or  4  tonnes,  reaching  up  to  42  tonnes  or  44  tonnes,  depending  on  the  axle 
configuration.  PM2  will  allow  the  same  extra  weight  also  for  intermodal  (non-containerised)  transport  where  lorry, 
trailer,  semi-trailer  are  the  intermodal  loading  units.  When  the  heaviest  vehicle  combinations  involved  in  intermodal 
transport are zero-emission they also benefit from the extra weight allowance envisaged in PM1. PO-B will thus result 
in a maximum weight of the heaviest vehicle combinations used in intermodal transport of 48 tonnes if they are ZEV. 

33 

 
 
                                                 
is no weight of empty containers or swap bodies to be compensated.  This extra weight allowance  will 
cover also compensation for the weight of craneable semitrailers, which is estimated between 200 kg and 
1  tonne127.  To  verify  whether  the  transport  loading  unit  was/will  be  used  in  intermodal  operation, 
controllers can currently check a consignment note (CMR128) in combination with evidence of reloading, 
from  other  modes  operators129.  These  controls  will  be  facilitated  by  the  implementation  of  eFTI 
(Electronic Freight Transport Information) Regulation130 as operators will be able to record all the freight 
transport data in a digital format in a certified eFTI platform prior to an operation, and authorities would 
have access to this data for control purposes.  

In relation to specific objective 2, PO-B goes further than PO-A by providing for limited harmonisation of 
the market sector of indivisible loads, where a first step was made with the adoption of the Best Practice 
Guidance for Abnormal Transport. PO-B will address SO2 and contribute to solving problem driver 4 by 
adding  a  measure  (PM4)  on  harmonisation  of  the  requirements  and  procedures  for  issuing  permits 
(currently subject to different national rules) for performing transport of indivisible load requiring longer 
HDVs. The measure envisages the implementation of the one-stop-shop concept, at national level, for the 
submission  of  applications  for  national  permits  at  a  single  national  location  and  the  use  of  digital 
documents.  Public  administrations  where  the  one-stop-shop  is  not  yet  implemented  will  have  to  adapt 
their  national  procedures  to  handle  permission  requests.  The  use  of  a  digital  document,  namely  the 
introduction of a common abnormal road transport registration document at EU level, could be done in 
two stages. The first stage would be the mutual acceptance between Member States of existing abnormal 
road transport registration documents. The second stage would be to agree on the SERT document and its 
utilisation by the EU permit granting authorities.   

Finally, to address  SO3 and contribute to solving problem diver 5, PO-B imposes a minimum amount of 
Weigh-in-Motion (WIM) systems to be deployed by Member States on the TEN-T network (every 300 
km)  for targeting  controls131  (PM6).  This measure  will  also  entail  an  assessment of the most  adequate 
locations within the TEN-T network  to install such systems. This measure aims to further enhance the 
efficiency and effectiveness of controls and contribute to improving compliance.     

Policy  Option  B  is  expected  to  further  increase  the  greening  impact  of  the  intervention,  by  providing 
additional incentives (e.g. potential extra payload to the deployment of ZEV). The aim is to incentivise the 
uptake  of  ZEV  as  well  as  of  aerodynamic  devices  and  cabs  which  will  allow  lighter  technologies  by 
reducing  the  energy  consumption  and  increasing  the  vehicle  autonomy  (range  between  the 
charging/refuelling  points).  This  policy  option  will  further  facilitate  intermodal  transport  operations  in 
which semitrailers are used as intermodal loading units, remove current fragmentation of the market for 
the transport of indivisible loads and strengthen enforcement via more targeted controls.  

127 Position paper from the  Austrian Federal Economic Chamber (WKO) “Creating  favourable framework conditions 
for businesses on the way to decarbonisation of the transport sector”, from September 2022. 
128 Although CMR is the document containing information about the carriage by road, it contains a section where the details 
about successive carriers should be added as well as carrier’s reservations and observations on taking over the goods.  
129  It  is  a  common  practice  that  a  train  company  issues  a  confirmation  that  semitrailer  has  been  loaded/unloaded  in 
order to determine the moment when responsibility passes form one operator to another. 
130 Regulation (EU) 2020/1956. 
131  MS  are  currently  obliged  to  deploy  WIM  systems  in  the  infrastructure  to,  at  least,  detect  HDV  that  could  be 
overloaded. MS are free to decide where and how many WIM systems can be installed in any part of to install. 

34 

 
 
 
                                                 
Policy Option C 

PO-C includes all seven common policy measures, two measures (PM2 and PM4) from PO-B and four 
additional  measures.  Altogether,  this  policy  option  is  the  most  ambitious  in  terms  of  decarbonisation, 
harmonisation and enforcement efforts.   

PO-C will strengthen SO1 by one additional measure - PM3 which  will allow international operations 
(intra-EU)  by  EMS1  (of  up  to  25.25m  long  and  60  tonnes  of  GVCW),  at  least  on  the  core  and 
comprehensive  TEN-T  network,  under  the  condition  that  they  are  ZEV  or  involved  in  intermodal 
transport operation. PM3 will thus  address problem drivers 2 and 3. The verification of the intermodal 
nature of the operation, will be facilitated by  certified eFTI platforms containing all data related to the 
cargo and its movements, including transport modes used through the entire transport operation chain. An 
assessment of the TEN-T network by Member States will also be necessary, in particular to ensure the 
manoeuvrability  and  visibility  of  EMS  at  critical  infrastructure  points,  such  as  roundabouts,  and  the 
suitability of the network to bear the increased weight of the vehicle combinations. This assessment could 
take  advantage  of  the  gap  analysis  conducted  under  EU  Action  Plan  on  military  mobility,  as  military 
transport share many  of  the  critical  aspects  with  EMS. Those Member States  which  already  allow the 
circulation of  non-ZE  EMS would be allowed to continue to do so during a transition period in cross-
border traffic, as enabled by Policy Option A.  

PO-C will further contribute to SO2 by setting “abnormal transport corridors” for indivisible loads (PM5) 
thus  addressing  problem  driver  4.  With  this  measure  abnormal  transport  (carriage  of  indivisible  loads) 
would  be  allowed  within  those  corridors,  including  crossing  borders,  without  the  need  for  national 
permits.  

Finally, to address SO3, PO-C proposes two measures that contribute to solving problem driver 5. PM7 
will require a minimum amount of certified Weigh-in-motion (WIM) systems to be deployed in the TEN-
T network (every 300 km) allowing for automated enforcement (from detecting the overweight vehicles 
to automatically issuing a penalty or alerting authorities for further action). The certified WIM systems 
will significantly increase their effectivity (controls could be performed 24h/7d) by reducing the need for 
additional resources (certified secondary scales and enforcement officers at the site) and replacing random 
ineffective  roadside  controls.  The  measure  will  increase  the  cost  of  the  systems  and  require  their 
certification and regular calibration. This policy measure is directly related to PM3, allowing EMS in the 
TEN-T network, and to PM5 requiring setting international abnormal transport corridors primarily on the 
TEN-T  network.  PM8  will  require  EMS  to  comply  with  higher  safety  standards  for  HDV  than  those 
provided for in the General Safety Regulation, such as a minimum power engine or side-warning devices. 
It will also require that drivers of EMS have a minimum number of years of experience driving HDV for 
which an EC driving licence is required or completing a specific training course for EMS drivers. This 
policy measure is directly related to PM3.  

While the cross-border transport of EMS is envisaged in all policy options via PMc4, it is limited to traffic 
between those Member States that already allow them. These “allowing” Member States have tested EMS 
and assessed their impacts in terms of road safety, infrastructure protection and modal cooperation and 
they have reported, among others, that the use of EMS leads naturally to the renewal of the fleet (operators 
tend to acquire new vehicles to be used in EMS combinations), which brings safety improvements due to 
more modern vehicles, and that operators also employ their best and most experienced drivers to drive 
EMS.   

Building  on  PO-A  and  PO-B,  Policy  Option  C  aims  to  bring  higher  operational  efficiency  of  road 
transport and higher environmental benefits, in particular, by allowing for a wider use of EMS at EU level 
and by linking them with ZE technologies and/or intermodal operations. PO-C will thus provide a higher 
level of harmonisation and environmental performance. Road safety and better enforcement of the rules in 

35 

 
 
force  are  also  addressed  for  these  vehicles,  with  more  stringent  conditions  related  to  the  vehicle 
specifications and to driver’s experience.  

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section summarises the main expected economic, social and environmental impacts of each policy 
option132. The proposed measures included in the policy options are assumed to be implemented from 
2025 onwards, so the assessment has been performed for the period 2025-2050 and covers EU27. Costs 
and benefits are expressed as present value over the 2025-2050 period, using a 3% discount rate. Further 
details on the methodological approach are provided in Annex 4. 

6.1.  Economic impact 

The assessment of the economic impacts includes the costs and benefits which the various policy options 
entail for public administrations, the European Commission and road transport operators. In addition, this 
section  covers  the  impacts  on  the  functioning  of  the  internal  market  and  competition,  SMEs  and 
competitiveness, and digital by default.  

6.1.1.  Impact on public administrations 

All  policy  options  are  expected  to  lead  to  adjustment  costs,  administrative  costs  and  adjustment  costs 
savings for national authorities. In addition, PO-B and PO-C are also expected to result in administrative 
costs savings. Each category of costs/costs savings is discussed below (see also Table 2 to Table 4), while 
a  detailed  analysis  including  the  estimates  and  the  assumptions  used  for  deriving  the  costs  and  costs 
savings for each policy measure included in each policy option is provided in Annex 4. 

Adjustment  costs  for  Member  States  administrations.  The  recurrent  adjustment  costs  for  MS 
administrations in 2030, 2040 and 2050 relative to the baseline are provided in Table 2, while the one-off 
costs  are  shown  in Table  3Error!  Reference source  not found..  In  terms of recurrent  costs, PO-A is 
estimated  to  result  in  the  lowest  additional  costs  among  the  options  (EUR  46.6  million  in  2030  going 
down  to  zero  up  to  2050)  relative  to  the  baseline.  These  costs  relate  to  the  maintenance  of  road 
infrastructure, due to the extra weight allowance for ZEV in PMc1 (included in PO-A). They are projected 
to decrease over time due to the improvement in technology, leading to the reduction of the weight of the 
batteries, and the lower number of trips required for transporting the same amount of cargo. It should also 
be noted that in PMc1, the purpose of the extra length and weight for ZE technologies is only to prevent 
the loss of payload capacity and/or range in comparison with diesel vehicles. The recurrent adjustment 
costs are higher in PO-C (EUR 50.3 million in 2030 and EUR 3.7 million in 2050), which in addition to 
the  maintenance  costs  for  road  infrastructure  due  to  PMc1  also  includes  the  recurrent  costs  for  the 
calibration of the Weigh-in-Motion (WIM) systems (PM7). PO-B shows the highest recurrent adjustment 
costs  among  the  options  (EUR  71.6  million  in  2030  and  EUR  547.5  million  in  2050),  relative  to  the 
baseline,  driven  by  the  combined  effect  of  PMc1  and  PM1.  It  should  be  noted  that  in  PM1  the  extra 
weight for HDV which are ZEV is granted regardless of the weight of the ZE technology used and thus 
the  impact  on  maintenance  costs  of  road  infrastructure,  as  explained  in  Annex  4,  is  estimated  to  be 
significantly higher.  

132 The analysis in this section is based on TML et al. (2023), Impact assessment support study for the revision of the 
directive on weights and dimensions of heavy-duty vehicles, and on the analysis of stakeholders' feedback. 

36 

 
 
                                                 
In addition, PO-A is estimated to result in one-off adjustment costs (see Table 3) of EUR 10.5 million for 
updating the inventory of bridges and tunnels (PMc2). In PO-B, in addition to the costs related to updating 
the inventory of bridges and tunnels, one-off adjustment costs are expected for the implementation of the 
one-stop-shop principle at national level (PM4) and the deployment of Weigh-in-Motion (WIM) systems 
every 300 km in the TEN-T network (PM6). Thus, total one-off adjustment costs in PO-B are estimated at 
EUR 102.7 million. PO-C shows the highest one-off adjustment costs relative to the baseline (EUR 7.7 
billion),  mainly  due  to  the  adaptation  costs  for  infrastructure  and  reinforcement  costs  for  bridges  in 
PM3133.  

Expressed as present value over 2025-2050, total adjustment costs for Member States administrations are 
estimated at EUR 446.6 million in PO-A, EUR 4.3 billion in PO-B and EUR 8.3 billion in PO-C relative 
to the baseline (see Table 4). Over 95% of total adjustment costs for Member States administrations in all 
policy options relate to maintenance and reinforcement of road infrastructure.  

Administrative  costs  for  Member  States  administrations.  PO-B  and  PO-C  are  estimated  to  lead  to 
recurrent administrative costs (EUR 0.9 million per year from 2025 onwards) driven by the maintenance 
and management of the one-stop-shop systems at national level for the submission of applications and the 
Special European Registration of Trucks and Trailers (PM4 in both PO-B and PO-C)134. In PO-A, the 
recurrent administrative costs (EUR 39.1 million in 2030 and EUR 48.7 million in 2050) are driven by the 

133  As  explained  in  Annex  4  (section  3),  the  need  for  adapting  specific  elements  of  the  infrastructure  will  be  the 
outcome of inspections. A number of Member States (SE, DK, DE) have already undertaken such inspections. Based 
on this information, the adaptation costs per km of the road infrastructure to the dimensions of EMS (e.g. upgrading of 
roundabouts, adaptation of acceleration and deceleration lanes to enter and exit a motorway and provision of adequate 
parking  spaces)  was  estimated  at  EUR  10,000  per  km.  The  analysis  for  Germany  was  used  as  starting  point.  By 
extrapolating  to  all  the  affected  Member  States,  the  one-off  adjustment  costs  are  estimated  at  EUR  727  million.  In 
addition, the one-off adjustment costs for the reinforcement of bridges are estimated at EUR 6.9 billion, drawing on a 
study  by  TML  et  al.  (Effects  of  adapting  the  rules  on  weights  and  dimensions  of  heavy  commercial  vehicles  as 
established within Directive 96/53/EC). Thus, the total one-off adjustment costs for public authorities are estimated at 
EUR 7.6 billion for PM3. 
134 As explained in Annex 4 (section 3), the introduction of the one-stop-shop concept will require national procedures 
to be  adapted to handle permission requests across all authorities involved  within each  Member State. Each Member 
States shall appoint a single authority to handle the permission request. The single authority will also be in charge of 
internally involving other national or regional competent authorities. The application process will be digital by default, 
and  therefore  PM4  shall  be  based  on  an  IT  tool.  The  development  of  the  IT  tool  and  the  implementation  phase  will 
entail  one-off  costs.  According  to  the  Better  Regulation  toolbox,  these  one-off  costs  for  the  IT  tool  are  classified  as 
adjustment  costs  and  explained  in  detail  in  Annex  4,  including  detailed  costs  per  Member  State.  Recurrent  annual 
maintenance  costs  for  the  IT  tools  and  management  of  the  systems  are  also  to  be  expected  and  are  classified  under 
administrative costs in line with the Better Regulation toolbox. Based on a study by COWI and TRT (COWI and TRT 
(2021),  Study  on  Implementation  of  the  Weights  and  Dimension  Directive),  the  recurrent  annual  costs  related  to  the 
maintenance and management of the systems are estimated at 5% of development costs. These refer to additional costs 
with  respect  to  the  baseline.  The  countries  with  (partial)  systems  in  place  were  already  incurring  some  maintenance 
costs. This is why the additional maintenance costs are assumed to be proportional to the additional development costs. 
The additional costs are thus estimated at EUR 0.9 million per year from 2025 onwards. 

37 

 
 
                                                 
obligation to conduct a minimum level of checks on HDV’s weight (PMc6)135. In addition, in PO-C one-
off  administrative  costs  for  inspections  will  be  needed  to  assess  the  suitability  of  the  infrastructure  to 
accommodate EMS136. Total administrative costs, expressed as present value over 2025-2050 relative to 
the baseline (see Table 4), are estimated to be the highest in PO-A (EUR 762.7 million), followed by PO-
C (EUR 25.4 million) and PO-B (EUR 16.4 million).  

Administrative costs savings for Member States administrations. PO-B and PO-C are also expected to 
result in administrative costs savings for Member States administrations. The implementation of the one-
stop-shop systems at national level is estimated to lead to costs savings for processing the permit requests 
by public authorities (PM4) in both PO-B and PO-C (EUR 81.5 million in 2030 and EUR 64.1 million in 
2050,  relative  to  the  baseline).  In  addition,  in  PO-B  the  non-certified  WIM  systems  are  expected  to 
considerably  increase  the  effectiveness  of  controls  for  pre-identifying  the  HDVs  that  are  likely  to  be 
overloaded, although some manual/roadside checks would remain necessary. The reduction in the number 
of manual/roadside checks is estimated to lead to costs savings of EUR 1.1 billion in 2030 and EUR 1.5 
billion in 2050 relative to the baseline, considering the combined effect of PM6 and PMc6 in PO-B. In 
PO-C, the certified WIM systems (PM7) eliminate the need for roadside controls with certified scales in 
the TEN-T network, where 67% of the circulation of HDVs occurs. PM7 will allow Member States to 
reach the minimum level of controls envisaged by PMc6 while increasing the ratio of infractions detected 
and will  reduce the  administrative  costs  for  public  authorities linked  to  roadside inspections  (EUR  1.1 
billion in 2030  and  EUR  1.5 billion in  2050,  relative to the  baseline).  In  addition, setting  international 
transport corridors for indivisible loads (PM5) in PO-C would result in additional costs savings for public 
authorities due to a reduction in the time for processing the permits (EUR 5.8 million in 2030 and EUR 
8.4 million in 2050). Total administrative costs savings, expressed as present value over 2025-2050 (see 
Table 4), are estimated at EUR 22.8 billion in PO-B and EUR 23.6 billion in PO-C relative to the baseline.   

Adjustment costs savings for Member States administrations. The adjustments costs savings for Member 
States authorities (see Table 2) are related in all policy options to a reduction in the maintenance costs for 
road infrastructure.  This is an effect of a decrease in the number of trips and road transport activity in 
vehicle-kilometres relative to the baseline, driven by an increase in payload (PMc3, PMc4), the shift from 
road-only  to  intermodal  transport  (PM2,  PM3)  or  the  reduction  in  the  frequency  and  severity  of 

135  As  explained  in  Annex  4  (section  3),  PMc6  will  require  public  authorities  to  perform  additional  tests  in  the  9 
Member  States  below  the  threshold  of  6.4  weight  tests  per  million  vehicle-kilometres  (Belgium,  Bulgaria,  Germany, 
Estonia, Spain, Finland, Latvia, Netherlands, Poland and Sweden). More details on the Member States above and below 
the threshold are provided in Annex 4. The evolution of the total number of weight tests over time in the baseline and 
under PMc6 takes into account the projected transport activity. For instance, in 2025 these Member States will have to 
undertake 239.2 thousand additional weight tests to reach the threshold, going up to 275.3 thousand in 2030 and 343.3 
thousand  in  2050.  No  additional  tests  are  required  in  the  8  Member  States  above  the  threshold  (Austria,  Denmark, 
Greece,  Ireland,  Italy,  Luxembourg,  Slovenia  and  Slovakia).  In  addition,  for  Cyprus,  Czechia,  France,  Croatia, 
Hungary,  Lithuania,  Malta,  Portugal  and  Romania  for  which  there  is  no  information  provided  on  their  enforcement 
activity in compliance with article 10g of the W&D Directive, it is assumed that they meet the EU threshold. Based on 
the  stakeholders’  consultation  and  the  REMOVE  project  (i.e.  data  was  obtained  for  Croatia,  Italy,  Finland,  Estonia, 
Poland, Latvia, Malta and Luxembourg. Source: Wermskerken (2005), Project REMOVE work package 4 final report 
on cost benefit analysis), each weight test is considered, on average, to require one hour for two officers (one hour for 
each). The cost per check is estimated at EUR 142. Taking into account the additional number of tests required and the 
cost per test, the administrative costs for public authorities under PMc6 are estimated at EUR 39.1 million in 2030 and 
EUR 48.7 million in 2050 relative to the baseline. 
136  As  explained  in  Annex  4  (section  3),  inspections  will  be  needed  to  assess  the  suitability  of  the  infrastructure,  to 
accommodate EMS. In case specific elements of the infrastructure are considered not suitable for EMS circulation, this 
will lead to the need of reinforcement (discussed under adjustment costs). The inspection costs are estimated at EUR 
0.5 million per Member State, for the Member States that currently do not allow EMS. The one-off administrative costs 
for public authorities due to PM3 are thus estimated at EUR 9 million relative to the baseline. 

38 

 
 
                                                 
overloading  practices  (PMc6,  PM6,  PM7).  The  total  adjustment  costs  savings  are  estimated  to  be  the 
highest in PO-C (EUR 377.3 million in 2030 and EUR 487.9 million in 2050), followed by PO-B (EUR 
154.4 million in 2030 and EUR 188.9 million in 2050) and PO-A (EUR 31 million in 2030 and EUR 38 
million in 2050). Expressed as present value over 2025-2050 (see Table 4), the adjustment costs savings 
for Member States administrations are estimated at EUR 7.5 billion in PO-C, EUR 3 billion in PO-B and 
EUR 0.6 billion in PO-A.  

Net costs savings/net costs for Member States administrations. As shown in Table 2, PO-B and PO-C 
are estimated to result in net costs savings relative to the baseline in 2030, 2040 and 2050 while PO-A 
would result in net costs for Member States administrations. Expressed as present value over 2025-2050, 
PO-C is projected to lead to net costs savings of EUR 22.8 billion and PO-B to net costs savings of EUR 
21.5 billion, while PO-A would result in net costs of EUR 0.6 billion relative to the baseline (see Table 4).  

Table 2: Recurrent costs and costs savings for public administrations in the POs relative to the baseline scenario 
(EU27), in 2030, 2040 and 2050, in million EUR (2022 prices)  

PO-A 
2040 

26.1 
26.1 

2030 

46.6 
46.6 

Difference to the Baseline 
PO-B 
2040 
336.8 

2050 
547.5 

2030 

71.6 

2050 

0.0 
0.0    

PO-C 
2040 

29.8 
26.1 

2030 

50.3 
46.6 

2050 

3.7 
0.0 

67.8 

333.1 

543.8    

39.1 
39.1 

43.7 
43.7 

48.7 
48.7    

3.7 

0.9 

3.7 

0.9 

3.7    

0.9 

3.7 
0.9 

3.7 
0.9 

3.7 
0.9 

0.0 

0.0 

0.9 
0.9 
0.0  1,186.5  1,286.9  1,538.5  1,226.5  1,332.1  1,592.4 

0.9 

0.9 

0.9 

0.9 

81.5 

55.0 

64.1 

81.5 
5.8 

55.0 
7.0 

64.1 
8.4 

1,105.0  1,231.9  1,474.3    

31.0 
0.9 
5.6 
24.4 

34.6 
1.8 
5.8 
27.0 

38.0 
2.0 
6.2 
29.9    

154.4 
0.9 
5.6 

171.1 
1.8 
5.8 

188.9 
2.0 
6.2 

1,139.2  1,270.0  1,519.9 
487.9 
430.3 
2.0 
1.8 
6.2 
5.8 

377.3 
0.9 
5.6 

16.0 

17.6 

19.5 

16.0 
16.0 

17.6 
30.3 

19.5 
46.0 

131.9 

145.9 

161.3    

Adjustment costs  

PMc1  
PM1&PMc1 
PM3 
PM4 
PM6 
PM7 

Administrative costs 

PMc6 
PM4 

Administrative costs 
savings 
PM4 
PM5 
PM6&PMc6 
PM7&PMc6 

Adjustment costs savings 

PMc3 
PMc4 
PMc6  
PM2 
PM3 
PM6&PMc6 
PM7&PMc6 

414.3 
-10.7  1,268.5  1,120.4  1,179.0  1,552.7  1,731.7  2,075.7 
Net costs savings/net costs  
Source:  TML  et  al.  (2023),  impact  assessment  support  study;  Note:  negative  values  for  ‘Net  costs  savings/net  costs’ 
represent net costs.  

374.7 

338.9 

-54.7 

-35.2 

Table 3: One-off costs for public administrations in the POs relative to the baseline scenario (EU27), in million 
EUR (2022 prices)  

Adjustment costs  

PMc2 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

10.5 
10.5 

102.7 
10.5 

7,728.1 
10.5 

39 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
PM3 
PM4 
PM6 
PM7 

Administrative costs 

PM3 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

17.8 
74.4    

0.0 

0.0 

7,590.9 
17.8 

108.9 
9.0 
9.0 

Source: TML et al. (2023), impact assessment support study 

Table  4:  Costs  and  costs  savings  for  public  authorities  by  policy  option  and  measure  relative  to  the  baseline, 
expressed as present value over 2025-2050 (in million EUR, 2022 prices) 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

Adjustment costs  

PMc1  
PMc2 
PM1&PMc1 
PM3 
PM4 
PM6 
PM7 

Administrative costs 

PMc6 
PM3 
PM4 

Administrative costs savings 

PM4 
PM5 
PM6&PMc6 
PM7&PMc6 

Adjustment costs savings 

PMc3 
PMc4 
PMc6  
PM2 
PM3 
PM6&PMc6 
PM7&PMc6 

466.6 
456.1    
10.5 

762.7 
762.7    

0.0 

609.6 
25.0 
106.2 
478.4    

4,346.6 

10.5 
4,175.4    

17.8 
142.9    

16.4 

16.4 
22,796.3 
1,203.5 

21,592.8    

3,028.0 
25.0 
106.2 

312.9 

2,583.8    

8,252.5 
456.1 
10.5 

7,590.9 
17.8 

177.1 
25.4 

9.0 
16.4 
23,586.0 
1,203.5 
121.9 

22,260.6 
7,540.6 
25.0 
106.2 

312.9 
459.3 

6,637.1 
22,848.8 
Net costs savings/net costs 
Source: TML et al. (2023), impact assessment support study; Note: The baseline scenario is also expressed as present 
value over 2025-2050, for consistency reasons. Negative values for ‘Net costs savings/net costs’ represent net costs.  

21,461.3 

-619.8 

6.1.2.  Impact on the European Commission 

Adjustment costs for the European Commission. All policy options are expected to lead to adjustment 
costs for the European Commission. For PMc7 (included in all policy options), the development of IAP 
standards will proceed in two steps. First, a study will be carried out followed by the use of the findings 
and the assessment of the study to draft the standards assisted by an expert group. The cost of the initial 
study  is  estimated  at  EUR  400,000.  The  average  cost  for  a  two-day  workshop  hosted  by  European 
Commission (EC), where participants are reimbursed by the EC is estimated at around EUR 30,000. Two 
of  such  in-person  workshops  may  be  required  as  well  as  two  online  meetings.  Compensation  for  the 

40 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
experts contributing to the meetings is estimated at EUR 5,000 for each meeting. Therefore, the one-off 
adjustment costs for PMc7 are estimated at EUR 0.47 million. For PM4 (included in both PO-B and PO-
C), technical and operational standards for information exchange will need to be established. This will 
also  be  done  in  two  steps.  A  study  will  be  carried  out  to  compile  the  required  elements  and  propose 
several options for the establishment of the standards. In a second stage, the findings and assessment of 
the study will be used to draft the standards with the help of an expert group. The one-off adjustment costs 
for PM4 are estimated at EUR 0.46 million. For PM8 (included in PO-C) the reinforced safety features in 
vehicles beyond the General Safety Regulation and Type Approval legal framework are also expected to 
be  developed  with  the  help  of  an  expert  group,  drawing  on  a  study  commissioned  by  the  European 
Commission. The one-off adjustment costs for PM8 are estimated at EUR 0.47 million137. Thus, total one-
off adjustment costs for the European Commission are estimated at EUR 0.47 million in PO-A, EUR 0.93 
million in PO-B and EUR 1.4 million in PO-C relative to the baseline. 

6.1.3.  Impact on road transport operators 

All  policy  options  are  expected  to  result  in  adjustment  costs  but  also  in  adjustment  costs  savings  and 
administrative costs savings for road transport operators (see Table 5 and Table 6). Detailed explanations 
on the estimates and assumptions used for deriving the costs and costs savings for each policy measure 
included in each policy option are provided in Annex 4. In addition, this section also provides the impacts 
on the transport activity performed by zero-emission vehicles.  

Adjustment  costs  for  road  transport  operators.  In  PO-A,  the  reinforced  Member  States  obligation  to 
conduct a minimum number of checks of HDV's weight (PMc6) is expected to lead to additional costs for 
road transport operators for cooperating with public authorities for performing the manual/roadside checks 
and also to additional operation costs for the operators that were operating overloaded trucks (i.e. non-
compliant  operators)  in  the  baseline  and  now  comply  with  the  weight  limits.  The  additional  operation 
costs for non-compliant operators are due to the need of performing more vehicle-kilometres to transport 
the  same  quantity  of  goods.  For  PO-A,  the  recurrent  adjustment  costs  for  transport  operators  are  thus 
estimated at EUR 32.7 million in 2030 and EUR 41.7 million in 2050 relative to the baseline (see Table 
5).  In PO-B, the joint effect of the reinforced Member States obligation to conduct a minimum number of 
checks  of  HDV's  weight  (PMc6)  and  the  requirements  on  the  installation  of  WIM  systems  (PM6) 
enhances the efficiency and effectiveness of controls. PO-B achieves higher level of compliance than PO-
A with lower number of manual/roadside checks than in the baseline, due to the use of WIM systems as a 
filter  to  pre-identify  HDV  that  are  likely  to  be  overloaded.  The  adjustment  costs  for  non-compliant 
operators are estimated to be higher in PO-B than in PO-A (EUR 107.3 million in 2030 and EUR 140.1 
million in 2050, relative to the baseline) due to the higher number of vehicle-kilometres to transport the 
same quantity of goods. In PO-C, the joint effect of the requirement on a minimum amount of certified 
Weigh-in-motion  (WIM)  systems  and  PMc6  will  significantly  increase  the  effectiveness  of  controls, 
relative to PO-A  and PO-B,  and  the operation  costs  for  non-compliant operators  (EUR 265  million  in 
2030 and EUR 346.9 million in 2050, relative to the baseline), with controls potentially being carried out 
24  hours  per  day  while  eliminating  the  need  for  ad-hoc  manual/roadside  checks.  By  minimising  the 
proportion of overloaded vehicles, compliant operators will benefit from a levelled playing field. PO-C 
additionally includes adjustment costs related to the requirement for EMS to comply with higher safety 

137 Compared to PM4, PMc7 and PM8 also foresee a compensation for the experts contributing to the online meetings 
estimated at EUR 5,000 for each meeting. 

41 

 
 
 
                                                 
standards for HDV under PM8, for training EMS drivers under PM8138. Thus, PO-C results in adjustment 
costs  estimated  at  EUR  295  million  in  2030  and  EUR  381.8  million  in  2050  relative  to  the  baseline. 
Expressed  as  present  value  over  2025-2050,  the  adjustment  costs  for  road  transport  operators  are 
estimated at EUR 6.8 billion in PO-C, EUR 2.1 billion in PO-B and EUR 0.6 billion in PO-A (see Table 
6).  

Adjustment  costs  savings  for  road  transport  operators.  In  PO-A,  the  extra  length  and  weight  to 
accommodate ZE technologies (PMc1), the harmonisation of the maximum permitted weight of 5- and 6-
axle HDV in  cross-border transport  (PMc3),  allowing  cross-border transport  of  44t and  EMS  between 
"allowing" MS (PMc4) and the harmonisation of the loaded length of vehicle carriers (PMc5) leads to 
operation costs savings for road transport operators due to the increase in the average payload and the 
reduction in the number of trips (see Table 5). The total adjustment costs savings for PO-A are estimated 
at  EUR  603.4  million  in  2030  and  EUR  793.2  million  in  2050,  relative  to  the  baseline.  In  PO-B,  the 
combined effect of PMc1 and PM1 (allowing 4 extra tonnes for HDV for ZEVs, irrespective of the ZE 
powertrain technology) leads to higher operation costs savings for road transport operators than in PO-A, 
due to the increase in the average payload and the  larger  reduction in the number of trips.  In addition, 
aligning the definition of intermodal transport with the Combined Transport Directive (PM2) results in 
adjustment costs savings due to the shift from road-only to intermodal operations, while PM6 and PMc6 
lead to lower costs relative to the baseline due to the reduced time required for cooperating with the public 
authorities for manual/roadside weight checks. Thus, PO-B is estimated to lead to total adjustment costs 
savings for road transport operators of EUR 2.1 billion in 2030 and EUR 2.9 billion in 2050, relative to 
the  baseline.  In  PO-C,  the  common  measures  for  all  options  (PMc1,  PMc3,  PMc4,  PMc5)  and  the 
common  measure  with  PO-B  (PM2)  lead  to  similar  adjustment  costs  savings.  However,  PO-C 
additionally results in operation costs savings due to the extra payload allowed through the use of EMS1 
in the core and comprehensive TEN-T network, conditioned to be ZEV or part of an intermodal transport 
operation (PM3) and lower costs relative to the baseline due to the reduced time required for cooperating 
with the public authorities for manual/roadside weight checks (PM7 and PMc6). The costs savings for 
PM7 and PMc6, relative to the baseline, are larger than those for PM6 and PMc6 (included in PO-B), due 
to  the  elimination  of  the  need  for  ad-hoc  manual/roadside  checks  thanks  to  the  use  of  certified  WIM 
systems.  PO-C  is  thus  expected  to  result  in  total  adjustment  costs  savings  for  transport  operators, 
estimated at EUR 2.3 billion in 2030 and EUR 3.7 billion in 2050 relative to the baseline. Expressed as 
present value over 2025-2050 relative to the baseline (see Table 6), total adjustment costs savings for road 
transport operators are estimated to be the highest in PO-C (EUR 49.1 billion), followed by PO-B (EUR 
42.8 billion) and PO-A (EUR 12.1 billion).  

Administrative  costs  savings  for  road  transport  operators.  All  policy  options  result  in  administrative 
costs savings for road transport operators (see Table 5). In PO-A, allowing for extra height (+0.3m) to 
accommodate  high-cube  containers  in  intermodal  transport  (PMc2)  eliminates  the  administrative  costs 
linked  to  the  authorisation  of  higher  trucks  (i.e.  the  costs  of  permits).  PO-A  is  estimated  to  lead  to 
administrative costs savings of EUR 168.5 million in 2030 and EUR 196.9 million in 2050 relative to the 
baseline.  The  average  number  of  permits  over  2025-2035  is  estimated  at  2.37  million  per  year. 
Considering the cost per permit of EUR 70, based on the stakeholders’ consultation activities, the average 
annual cost savings are estimated at EUR 165.9 million. These administrative costs savings are not subject 
to the application of the ‘one in, one out’ approach. 

138  These  costs  are  estimated  at  EUR  996.5  million  in  2025,  going  down  to  EUR  30.1  million  in  2030  and  EUR  35 
million in 2050 relative to the baseline.  

42 

 
 
                                                 
PO-B  results  in  higher  total  administrative  costs  savings  (EUR  250.3  million  in  2030  and  EUR  261.1 
million in 2050, relative to the baseline) than PO-A due to the reduction in the time needed to prepare and 
submit the requests for the issuance of special permits for the transport of indivisible loads139,140, driven by 
the application of the one-stop-shop principles at national level and the digitalisation of documents (PM4). 
For PM4, for the purpose of the application of the ‘one in, one out’ approach, the annual average cost 
saving per permit over 2025-2035 has been estimated at EUR 64.1. Considering the average number of 
permits over 2025-2035, estimated at 1.12 million, the average annual cost savings are estimated at EUR 
71.8 million. 

Total  administrative  costs  savings  for  road  transport  operators  in  PO-C  are  estimated  at  EUR  256.2 
million in 2030 and EUR 269.4 million in 2050, relative to the baseline. PO-C additionally envisages (in 
addition  to  PMc2  and  PM4)  setting  abnormal  transport  corridors  for  indivisible  loads  up  to  certain 
excesses  in  W&D  and  for  EMS  (PM5).  Road  transport  operators  are  expected  to  benefit  from  the 
simplification of procedures under PM5. Permits will continue to be required for all trips as any trip will 
always begin or end outside the TEN-T network. However, PM5 is expected to result in a reduction of the 
time needed for preparing and submitting the request for the permits. The annual average cost saving per 
permit over 2025-2035 has been estimated at EUR 5.3. Considering the average number of permits over 
2025-2035, estimated at 1.12 million, the average annual cost savings due to PM5 are estimated at EUR 
5.9 million for the purpose of the application of the ‘one in, one out’. 

Expressed as present value over 2025-2050 relative to the baseline (see Table 6), total administrative costs 
savings for road transport operators are estimated to be the highest in PO-C (EUR 4.5 billion), followed 
by PO-B (EUR 4.4 billion) and PO-A (EUR 3.2 billion).   

Table 5: Recurrent costs and costs savings for transport operators in the POs relative to the baseline scenario 
(EU27), in 2030, 2040 and 2050, in million EUR (2022 prices)  

PO-A 
2040 

37.1 
37.1 

2030 

32.7 
32.7 

603.4 
23.7 
28.8 
106.6 
444.2 

693.5 
9.1 
58.9 
139.0 
486.5 

Adjustment costs 

PMc6 
PM6&PMc6 
PM7&PMc6 
PM8 

Adjustment costs savings 

PMc1 
PMc3 
PMc4 
PMc5 
PM1&PMc1 
PM2 

Difference to the Baseline 
PO-B 
2040 
122.4 

2030 
107.3 

2050 
140.1 

2050 

41.7 
41.7    

107.3 

122.4 

140.1    

PO-C 
2040 
335.0 

2030 
295.0 

2050 
381.8 

265.0 
30.1 

346.9 
35.0 
793.2  2,086.2  2,511.3  2,941.3  2,305.2  2,883.6  3,661.0 
-1.9 
65.5 
175.2 
554.4 

-1.9    
65.5 
175.2 
554.4 

9.1 
58.9 
139.0 
486.5 

23.7 
28.8 
106.6 
444.2 

303.4 
31.6 

58.9 
139.0 
486.5 
294.7 

65.5 
175.2 
554.4 
485.6    

28.8 
106.6 
444.2 
78.8 

1,160.2  1,233.9  1,303.6  1,160.2  1,233.9  1,303.6 

139  Article  2  of  Council  Directive  96/53/EC  defines  an  indivisible  load  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 the 
W&D Directive in all respects.” 
140 The transport of an indivisible load requiring longer HDVs and specific safety measures is subject to the issuance of 
special permit for each trip or for the number of trips performed in a given period of time. Special permits may include 
conditions  such  as  vehicle  escorts,  allowed  time  frames,  authorised  speeds,  etc.  Different  countries  and  regions  have 
different rules and procedures in place for obtaining such permits. 

43 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
                                                 
PO-A 
2040 

2030 

2050 

PM3 
PM6&PMc6 
PM7&PMc6 

Difference to the Baseline 
PO-B 
2040 

2050 

2030 

267.6 

298.3 

357.0    

PO-C 
2040 
648.6  1,196.2 

2050 

2030 
265.8 

275.9 

307.5 

368.0 

Administrative costs 
savings 
PMc2 
PM4 
PM5 

168.8 
168.8 

180.5 
180.5 

269.4 
196.9 
64.1 
8.4 
948.5  2,229.2  2,624.4  3,062.2  2,266.3  2,791.1  3,548.6 
Net costs savings 
Source:  TML  et  al.  (2023),  impact  assessment  support  study;  Note:  negative  values  for  ‘adjustment  costs  savings’ 
represent net costs. 

242.6 
180.5 
55.0 
7.0 

256.2 
168.8 
81.5 
5.8 

235.6 
180.5 
55.0 

261.1 
196.9 
64.1 

250.3 
168.8 
81.5 

196.9 
196.9 

837.0 

739.5 

Table  6: Costs  and  costs  savings  for  road  transport  operators  by  policy  option  and  measure  relative  to  the 
baseline, expressed as present value over 2025-2050 (in million EUR, 2022 prices) 

Adjustment costs savings 

12,138.5 

42,831.1 

Adjustment costs 

PMc6 
PM6&PMc6 
PM7&PMc6 
PM8 

PMc1 
PMc3 
PMc4 
PMc5 
PM1&PMc1 
PM2 
PM3 
PM6&PMc6 
PM7&PMc6 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

643.0 
643.0    

2,132.6 

6,816.9 

2,132.6    

344.5    
808.5 
2,317.2 
8,668.2 

808.5 
2,317.2 
8,668.2 
3,907.8    

21,900.6 

5,228.7    

5,273.4 
1,543.4 
49,093.5 
344.5 
808.5 
2,317.2 
8,668.2 

21,900.6 
9,664.0 

PMc2 
PM4 
PM5 

Administrative costs savings 

5,390.4 
4,543.6 
3,218.2 
1,203.5 
121.9 
46,820.3 
Net costs savings 
Source: TML et al. (2023), impact assessment support study; Note: the baseline scenario is also expressed as present 
value over 2025-2050, for consistency reasons.   

4,421.7 
3,218.2 
1,203.5 

3,218.2 
3,218.2 

45,120.2 

14,713.7 

Net costs savings for road transport operators. As shown in Table 5, all policy options are expected to 
result in net costs savings for road transport operators  relative to the baseline in 2030, 2040 and 2050. 
Expressed as present  value over 2025-2050 (see Table 6), PO-C is projected to lead to  the highest  net 
costs savings (EUR 46.8 billion) followed by PO-B (EUR 45.1 billion) and PO-A (EUR 14.7 billion).  

Transport activity performed by zero-emission vehicles. The measures incentivising the uptake of zero-
emission HDVs (PMc1 and PMc4 in PO-A, PMc1, PMc4 and PM1 in PO-B and PMc1, PMc4 and PM3 
in PO-C) are estimated to lead to a reduction in the operation costs per tonne for these vehicles relative to 
the  baseline,  due  to  the  higher  average  payload  relative  to  the  baseline.  The  combined  effect  of  the 
reduction  in  the  operation  costs  per  tonne  and  higher  average  payload  is  the  increase  in  the  transport 

44 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
activity  in  tonnes  and  tonne-kilometres  for  the  zero-emission  vehicles,  coupled  with  a  decrease  in  the 
number of trips and vehicle-kilometres driven relative to the baseline.   

As explained in Annex 4 (section 1), based on literature review141,142, the price elasticity of demand for 
road transport (-0.3) is used to calculate the changes in the number of tonnes transported by road, relative 
to the baseline, due to the changes in the transport costs per unit of transport. In addition, a price elasticity 
of  -0.1  is  used  to  reflect  rebound  effects  due  to  the  use  of  more  energy-efficient  vehicles,  with  lower 
operating costs. The changes in transport activity in tonnes-kilometres due to the policy measures relative 
to the baseline are calculated based on the changes in transport activity in tonnes and the average mileage 
per origin-destination from the baseline scenario. In the following step, the changes in the number of trips 
are derived using the average payload corresponding to the policy measures143 and the activity in tonne-
kilometres. The activity in vehicle-kilometres is further derived by multiplying the number of trips with 
the average mileage per origin-destination from the baseline scenario.   

The increase in the transport activity of zero-emission vehicles by policy option relative to the baseline (in 
billion tonne-kilometres and percentage change to the baseline) for 2030, 2040 and 2050 is provided in 
Table 7.  

Table  7:  Increase  in  transport  activity  of  zero-emission  vehicles  by  policy  option  relative  to  the  baseline  (in 
billion tonne-kilometres and percentage change to the baseline) 

Baseline (billion tonne-kilometres) 
Difference to the baseline (billion tonne-kilometres) 

PO-A 
PO-B 
PO-C 

% change relative to the baseline  

PO-A 
PO-B 
PO-C 

Source: TML et al. (2023), impact assessment support study   

2030 

2040 

2050 

136.8 

1,060.7 

2,147.3 

1.5 
5.4 
7.3 

1.1% 
3.9% 
5.3% 

2.8 
8.3 
19.3 

0.3% 
0.8% 
1.8% 

3.5 
8.6 
36.2 

0.2% 
0.4% 
1.7% 

In addition, sensitivity analysis has been performed to show the impacts of different price elasticities of 
demand for road transport on the transport activity by ZEV. Two cases have been considered: (i) case A, 
using a price elasticity of demand of -0.2, and (ii) case B, using a price elasticity of demand of -0.4. These 
are  to  be  compared  with  the  central  case,  using  a  price  elasticity  of  demand  of  -0.3  (see  Table  7). 
Considering the range of elasticities, the transport activity performed by ZEV is estimated to increase in 
PO-A by 0.8 to 1.4% in 2030 and 0.1 to 0.2% in 2050 relative to the baseline (see Table 8). The increase 
would  be  higher  in  PO-B,  estimated  at  2.7  to  5.2%  in  2030  and  0.3  to  0.5%  in  2050  relative  to  the 
baseline, and the highest in PO-C (4.9 to 5.7% in 2030 and around 1.7% in 2050 relative to the baseline). 
The ranking of the policy options in terms of transport activity performed by ZEV remains unchanged 
considering the different price elasticities of demand for road transport.    

141 De Jong et al (2010). Price sensitivity of European road freight transport - towards a better understanding of existing 
results. A report for Transport & Environment. The Hague: Significance. 
142 Rijkswaterstaat (2020). DP07 - Eindanalyse BasGoed 5.0. Rijswijk: Rijkswaterstaat 
143 For example, the changes in average payload capacity for PMc1 and PM1 are described in detail in Annex 4. 

45 

 
 
 
  
  
  
  
  
  
                                                 
Table 8: Increase in transport activity of zero-emission vehicles by policy option relative to the baseline in case A 
and case B (in billion tonne-kilometres and percentage change to the baseline) 
2030 

2050 

2040 

Difference to the baseline (billion tkm) 

PO-A 

Case A (elasticity -0.2) 

Case B (elasticity -0.4) 

PO-B 

Case A (elasticity -0.2) 

Case B (elasticity -0.4) 

PO-C 

Case A (elasticity -0.2) 

Case B (elasticity -0.4) 

% change to the baseline  

PO-A 

Case A (elasticity -0.2) 

Case B (elasticity -0.4) 

PO-B 

Case A (elasticity -0.2) 

Case B (elasticity -0.4) 

PO-C 

Case A (elasticity -0.2) 

Case B (elasticity -0.4) 

1.1 

2.0 

3.7 

7.1 

6.7 

7.8 

0.8% 

1.4% 

2.7% 

5.2% 

4.9% 

5.7% 

2.2 

3.4 

5.9 

10.7 

18.7 

19.9 

0.2% 

0.3% 

0.6% 

1.0% 

1.8% 

1.9% 

3.0 

4.0 

6.4 

10.8 

35.7 

36.7 

0.1% 

0.2% 

0.3% 

0.5% 

1.7% 

1.7% 

Source: TML et al. (2023), impact assessment support study   

6.1.4.  Impact on the internal market and competition of the road transport sector 

All  policy  options  are  expected  to  have  a  positive  impact  on  the  functioning  of  the  internal  market. 
Removing  the  barriers  to  the  free  movement  of  goods  via  the  harmonisation  of  the  rules  allows  road 
transport  operators  to  provide  transport  services  more  efficiently  for  the  benefit  of  the  customers 
throughout the EU. The harmonisation measures in PO-A (PMc3, PMc4 and PMc5) will remove the main 
barrier  to  cross-border  operations  by  heavier/longer  HDVs  between  “allowing”  Member  States,  while 
Member  States  will  retain  the  flexibility  to  adapt  the  rules  for  domestic  operations  to  national 
circumstances,  such  as  infrastructure  standards  and  operational  conditions.  PO-B  and  PO-C  will,  in 
addition, streamline and digitalise the authorisation procedures for the issuing of national permits for the 
transport  of  indivisible  loads  (PM4  in  PO-B  and  PO-C)  and  further  simplify  procedures  by  setting 
abnormal transport corridors for indivisible loads (PM5 in PO-C) improving transport services, as well as 
reducing unauthorised runs.  

A higher level of compliance with the rules on the maximum authorised weight and axle weight of HDV 
will contribute to eliminating unfair business practices. All policy options set a minimum level of controls, 
as envisaged by PMc6, as well as a harmonised approach to the voluntary implementation of intelligent 
access  policies  (PMc7).  The  efficiency  and  effectiveness  of  such  controls  on  compliance  with  the 
maximum authorised weights is further strengthened in PO-B by the deployment of WIM systems in the 
TEN-T  network  for  targeting  controls  (PM6).  PO-C  will  in  addition  require  the  certification  of  WIM 

46 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
systems to allow for direct (automatic) enforcement in the TEN-T network (PM7), eliminating the need to 
deploy inspectors to carry out roadside checks, analyse the findings and issue fines.  

6.1.5.  Impact on the competitiveness of the road, rail, inland waterways and intermodal 

transport sectors  

The main positive impact on the competitiveness of the road transport sector is linked to the  common 
policy measures addressing the Specific Objective 2 (SO2: Harmonise the rules on maximum W&D of 
HDV  in  cross-border  operations),  namely  PMc3,  PMc4  and  PMc5.  They  aim  at  removing  existing 
barriers to cross-border road freight transport and improving the efficiency of road transport operations. At 
the  same  time,  the  improved  competitiveness  of  road  freight  transport  needs  to  be  achieved  without 
attracting  freight  transport  from  other  modes  with  generally  even  lower  externalities,  namely  rail  and 
waterborne transport, which would affect the competitiveness of those sectors. For this reason, all policy 
options include policy measures supporting intermodal transport144.  

The possible impact of the policy options on modal shift has also been assessed. More specifically, the 
changes in transport activity due to the changes in the road transport prices and due to the changes in the 
relative prices between transport modes are assessed based on price elasticities from the literature. Two 
sources145,146 have been identified that look at elasticities for the EU freight transport sector and have been 
used for the assessment, as explained in section 1 of Annex 4. 

Given that PMc4 (included in all policy options) generally extends the use of EMS and 44t HDV in cross-
border transport without any distance limitation, while other modes are considered more suitable for long 
distance transport, the reverse modal shift from rail and inland navigation towards road has been estimated 
based on the potential reduction in the costs of the road transport services and the cross-price elasticities of 

144 It should be noted that there is no robust evidence based on Member States experience with the EMS supporting the 
statement that harmonisation measures that improve efficiency of transport operations without additional requirements 
(not conditioned to be ZEV or involved in intermodal transport) would lead to a reverse  modal shift from rail and/or 
water base modes of transport to road. The feedback provided by Member States that have allowed the circulation of 
EMS  in  national  and  cross-border  transport  (Finland  and  Sweden,  and  EMS  is  being  tested  in  Denmark,  the 
Netherlands, Belgium, Spain, Portugal, Czech Republic and Germany authorise EMS in national transport, while cross-
border  transport  is  allowed  between  Finland  and  Sweden,  Sweden  and  Denmark,  Belgium  and  the  Netherlands  and 
between  Germany  and  the  Netherlands)  and  to  a  lesser  extent  of  those  allowing  44  tonnes  HDVs  in  national  traffic 
(Belgium,  Czech  Republic,  France,  Ireland,  Italy,  Luxembourg,  the  Netherlands,  Portugal,  Sweden,  Denmark  and 
Finland),  as  well  as  the  feedback  from  the  transport  and  logistics  operators  that  have  made  use  of  EMS,  44  tonnes 
HDVs and vehicle carriers with additional length (road operators, shippers and producers, as well as EU representatives 
of the finished vehicle logistics), shows positive impacts in terms of road safety and negligible modal shift effects. This 
evidence also shows that shifts in activity occur rather between different categories of  HDVs,  as  more efficient ones 
(such as EMS) substitute standard 40 tonne trucks. However, one concern stressed during the consultation activities as 
regards the coherence of the Weights and Dimensions Directive with other EU policies is that the  Directive would put 
other,  more  sustainable  modes  of  transport  in  a  competitive  disadvantage,  ultimately  contributing  to  a reverse  modal 
shift.  For  this  reason,  all  policy  options  include  policy  measures  that  support  the  shift  from  road-only  to  intermodal 
transport  (PMc2  in  PO-A,  PM2  in  PO-B  and  PM2  and  PM3  in  PO-C)  thus  mitigating  possible  negative  impacts  on 
modal shift. 
145 De Jong et al (2010). Price sensitivity of European road freight transport - towards a better understanding of existing 
results. A report for Transport & Environment. The Hague: Significance. 
146  Rijkswaterstaat (2020). DP07 - Eindanalyse BasGoed 5.0. Rijswijk: Rijkswaterstaat 

47 

 
 
                                                 
demand (see Annex 4)147. This is estimated at 4.9 billion tonne-kilometres in 2030 and 5.5 billion tonne-
kilometres in 2050 relative to the baseline, or 0.7% of the total rail and inland navigation activity in the 
baseline in 2030 and 0.6% in 2050. 

At  the  same  time,  PO-A  is  expected  to  increase  the  efficiency  of  intermodal  transport  of  high-cube 
containers (PMc2) and enable the use of ZE HDVs in intermodal containerised operations as the extra 
weight  and  length  for  ZEVs  provided  under  PMc1  can  be  combined  with  the  extra  weight  granted  to 
HDV involved in intermodal transport. The shift from road-only to intermodal transport is estimated at 
around  12  billion  tonne-kilometres  in  2030  and  14  billion  tonne-kilometres  in  2050,  relative  to  the 
baseline, as explained in Annex 4. The risks of reverse modal shift will be further mitigated in PO-B, as 
PM2  will  further  support  intermodal  transport  by  considering  trailers  and  semitrailers  as  intermodal 
loading units. This measure  will  render  a  non-containerised intermodal transport more  attractive  to the 
operators  using  standard  vehicles,  who  will  be  able  to  benefit  from  the  4t  extra  weight  for  intermodal 
operations (see Annex 4 for more details). In addition, PO-B will require that as of 2035, 44-t HDV that 
are used in cross-border non-intermodal operations between allowing Member States (under PMc4) are 
ZEV (PM1). The shift from road-only to intermodal transport in PO-B is estimated at around 21 billion 
tonne-kilometres  in  2030  and  26  billion  tonne-kilometres  in  2050,  relative  to  the  baseline.  PO-C  will 
enable further reductions in transport costs, alongside with further incentives for the uptake of ZEV and 
intermodal transport, thanks to PM3 which allows for the circulation of EMS in international (intra-EU) 
transport  on  TEN-T  network  provided  that  they  are  either  ZEV  or  part  of  an  intermodal  transport 
operation (see Annex 4). The shift from road-only to intermodal transport in PO-C is estimated at around 
23 billion tonne-kilometres in 2030 and 28 billion tonne-kilometres in 2050, relative to the baseline.  

In addition, the sector of indivisible loads transport will benefit from the streamlining of the procedures to 
obtain national permits, including the digitalisation of documents (PM4) in PO-B and PO-C, while PO-C 
will further improve the efficiency of this market segment by setting abnormal transport corridors which 
will further simplify the authorisation of abnormal transport in certain cases.  

All policy options may improve the international competitiveness of the EU commercial road transport 
sector  by  making  it  greener  and  more  efficient,  including  by  encouraging  involvement  in  intermodal 
operations. They may also positively affect the road transport sector’s capacity to innovate, by providing 
incentives to the deployment of zero-emission HDVs and intermodal operations that may drive innovation 
in logistics and supply chain management. 

6.1.6.  Impact on small and medium enterprises (SMEs) 

In  the  road  transport  sector  99% of  companies  are SMEs  (enterprises employing up  to  250  people and 
with  a  turnover  of  less  than  EUR  50  million148,149).  Intermodal  transport  involves  by  definition  many 
different economic  agents. While  many  operators  in  rail  transport  and shipping  are medium  and  some 
even large companies, operators in inland waterways and many intermodal organisers are often SMEs. 

147 As explained in Annex 4 (section 1), the following elements have been taken into account for estimating the changes 
in  the  number  of  tonnes  transported  and  the  potential  reverse  modal  shift:  the  price  elasticity  of  demand  for  road 
transport,  the  cross-price  elasticity  of  demand  for  rail  transport,  the  cross-price  elasticity  of  demand  for  inland 
navigation, the cross-price elasticity of demand for different road vehicle categories. In addition, a price elasticity of  -
0.1 is used to take into account rebound effects due to the use of more energy-efficient vehicles, with lower operation 
costs. 
148 Commission SWD(2017) 194 final.   
149 https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_1B_SE_R2__custom_3493320/default/table  

48 

 
 
                                                 
Therefore, the initiative is considered relevant for the SMEs and the SME test has been performed (see 
Annex 11). 

As  explained  in  section  6.1.3,  all  policy  options  are  expected  to  result  in  net  costs  savings  for  road 
transport  operators,  estimated  at  EUR  46.8  billion  in  PO-C,  followed  by  PO-B  with  net  costs  savings 
estimated at EUR 45.1 billion and PO-A with net costs savings of EUR 14.7 billion, expressed as present 
value over 2025-2050 relative to the baseline (in 2022 prices). Considering the very large share of SMEs 
in the road transport sector, most of these net costs savings are expected to be attributed to them although 
the available data did not allow a split of these costs savings between the two groups of operators (i.e. 
SME and others). In addition, the increase in intermodal transport in all policy options will have a positive 
economic impact on the SMEs involved, which the highest benefits expected in PO-C and PO-B.    

6.1.7.  Digital by default 

PO-B  and  PO-C  are  expected  to  have  a  positive  impact  on  the  application  of  the  ‘digital  by  default’ 
principle,  by  stimulating  the  transition  to  the  digitalisation  of  documents  (e.g.  permits  for  abnormal 
transport) and transport data related to cargo, vehicle, route, etc. (e.g. on eFTI platforms) due to PM4. 

6.2.  Social impact 

The social impacts are assessed in terms of impacts on road safety, health and fundamental rights. 

6.2.1.  Road safety 

All policy options are estimated to reduce the number of fatalities from road accidents in which HDVs are 
involved. The main driver is the reduction in the number of trips and vehicle-kilometres driven relative to 
the  baseline  due  to  the  increased  payload  of  HDVs  (the  same  amount  of  goods  transported  with  less 
vehicles)  and  the  shift  from  road-only  to  intermodal  transport.  Thus,  the  risk  exposure  is  reduced, 
offsetting the potential higher risk represented by heavier and/or bigger HDVs. Cumulatively, over the 
period 2025-2050, PO-A is estimated to result in 237 lives saved and to lead to a reduction in the external 
costs of accidents by EUR 0.5 billion relative to the baseline (expressed as present value over 2025-2050). 
PO-B is expected to result in 411 lives saved and external costs savings of roughly EUR 0.9 billion, while 
PO-C accounts for 642 lives saved and external costs savings of approximately EUR 1.4 billion over the 
same period150. 

Two factors were considered in assessing the impacts of the policy measures on road safety: i) the change 
in  risk  per  vehicle-kilometre  relative  to  the  baseline,  and  ii)  the  change  in  the  number  of  vehicle-
kilometres driven relative to the baseline. The change in the risk factor associated to each policy measure 
draws  on  literature  review  and  additional  analysis  performed  in  the  context  of  the  impact  assessment 
support study. The changes in the vehicle-kilometres driven are derived for each policy measure, drawing 
on the changes in costs and price elasticities. 

For the risk factor, as explained in section 4 of Annex 4, the assessment was based, on the one hand, on 
literature  focusing  on  engineering  predictions,  which  studies  the  engineering  effects  of  overloading 

150  To  monetise  the  external  costs  of  fatalities,  the  unit  costs  at  Member  State  level  from  the  Handbook  on  external 
costs of transport have been used. At EU level, the unit cost per fatality is estimated at EUR 3.9 million in 2022 prices. 
Source: Essen, H. et al. (2020), Handbook on the external costs of transport: version 2019  – 1.1, Publications Office, 
available at: https://data.europa.eu/doi/10.2832/51388 

49 

 
 
                                                 
vehicles both within and beyond their design limit as well as the specific additional risks of EMS of 60 
tonnes  versus  standard  44  tonne  HGVs151.  On  the  other  hand,  post-hoc  statistical  methods  were  also 
considered. These included a comparison of the fatality rates of different vehicles within existing length 
limits  (16.5/18.75)  by  gross  vehicle  weight  (GVW)  and  number  of  axles152,  which  was  updated  and 
extended to smaller vehicles in the context of the impact assessment support study, and a comparison of 
EMS with HGVs of up to 40 tonnes and 18.75m in Sweden153, which found that the actual fatality rate in 
the EMS group was 21% lower than that for the 40 tonne vehicles. 

Policy measures PMc1, PM1 and PMc3 envisage a modest increase in the mass of HDVs. Based on the 
sources  mentioned  above,  for  PMc1  and  PM1,  the  increase  in  mass  from  42  tonnes  to  44  tonnes  was 
considered to increase the risk by 0.5%. In PMc3, permitting 5 and 6-axle rigid vehicles was estimated to 
lead to a 1% risk increase. It should be noted that this factor represents an increase in risk per vehicle. 
Given that the measures lead to an overall decrease in the number of vehicle-kilometres driven, the overall 
effect is a decrease in the number of fatalities. 

PMc4,  PM3  and  PM8  envisage  larger  capacity  increases  connected  to  EMS.  Engineering  assessments 
show a large increase in risk per km, associated with the larger weight gain and the addition of length 
related risks (e.g. poor manoeuvrability)154. However, statistical observations suggest a reduction in the 
risk per kilometre associated with EMS compared with standard vehicles155. This apparent contradiction 
is explained by the fact that EMS are implemented with additional safety features compared to standard 
HGVs and that they are used differently than standard HGVs such that their exposure to risk is different 
(e.g. more of their time is spent on safer parts of the road network). Operators also tend to use their best 
drivers on EMS. The anecdotal evidence suggests that drivers of EMS drive them more carefully than 
they  would  drive  a  standard  HGV  because  of  the  perception  of  increased  difficulty  and  risk  that  the 
additional length and articulation point brings. Moreover, EMS tend to be newer compared to other HGVs 
and are thus equipped with more modern safety features than the average HGV. Taking into account all 
these factors, a 5% reduction in risk has been estimated for PMc4 and PM3, which is further reduced to 
6%  with  the  introduction  of  PM8.  Here  again,  besides  the  inherent  risk  per  vehicle,  the  effect  of  the 
measures on the number of vehicle-kilometres has been taken into account to calculate the overall impact 
on road safety. 

For  PMc5  (i.e.  vehicle  carriers),  it  was  considered  that  front  and  rear  overhangs,  that  cause  additional 
swept path that fall outside of turning circle limits, would be the main risk rather than load. Based on an 
analysis of collision data identifying typical manoeuvring related collisions, undertaken in the context of 
the support study, it was estimated that PMc5 would increase the fatality risk of each vehicle by 0.02%. 
As in previous cases, the effect of the measure on the number of vehicle-kilometres has been taken into 
account to calculate the overall impact on road safety. 

151  Breemersch,  T.  et  al.  (2021).    Overweight  vehicles’  impacts  on  road  infrastructure  and  safety.  Transport  and 
Mobility Leuven. 
152 Knight, I., et al. (2008). Longer and/or longer and heavier goods vehicles (LHVs)  - a study of the likely effects if 
permitted in the UK. Crowthorne: TRL Published Project Report PPR 285.   
153  Balint,  A.  et  al.  (2014).  Accident  analysis  for  traffic  safety  aspects  of  High  Capacity  Transports.  Chalmers 
University of Technology, Department of Vehicle Safety. 
154  Breemersch,  T.  et  al.  (2021).    Overweight  vehicles’  impacts  on  road  infrastructure  and  safety.  Transport  and 
Mobility Leuven. 
155  Balint,  A.  et  al.  (2014).  Accident  analysis  for  traffic  safety  aspects  of  High  Capacity  Transports.  Chalmers 
University of Technology, Department of Vehicle Safety. 

50 

 
 
                                                 
PMc6,  PM6,  and  PM7  reduce  the  number  of  overloaded  vehicles.  When  the  overloaded  vehicles  are 
within their design limit, the effect on safety risk per kilometre is expected to be the same as for legally 
loaded  vehicles.  However,  when  overloads  go  above  the  design  limit  the  safety  risks  substantially 
increase. No studies were identified that could provide a quantification of the scale of this increase. Based 
on expert opinion in the context of the support study, 2% higher risk per kilometre was assumed for all 
overloaded vehicles compared to the legally loaded vehicles.  

6.2.2.  Impacts on health 

All policy options are expected to reduce air pollutant and noise emissions as a consequence of the uptake 
of ZEV, which will progressively increase their share in the HDV fleet as shown in section 6.1.3, but also 
due  to  the  reduction  in  the  number  of  trips  and  thus  vehicle-kilometres  driven.  The  reduction  in  the 
external  costs of  air  pollution  (in  terms  of  impacts  on  human  health)  and  noise  will  benefit  society  by 
improving the quality of the air and reducing the acoustic contamination. It will also improve the working 
conditions of HDVs drivers thanks to the reduced levels of noise and vibrations inside the vehicles. PO-A 
is estimated to result in external costs savings for air pollutant emissions (NOx and Particulate Matter) 
estimated at EUR 1.6 billion, expressed as present value over 2025-2050 relative to the baseline, while 
PO-B results in external costs savings of EUR 2.1 billion, and PO-C of EUR 6.2 billion. With regard to 
acoustic contamination, the external costs of noise emissions are projected to decline by EUR 0.6 billion 
in  PO-A,  EUR  0.7  billion  in  PO-B  and  EUR  1  billion  in  PO-C  relative  to  the  baseline156.  All  policy 
options  contribute  towards  Sustainable  Development  Goal  3  (“Ensure  healthy  lives  and  promote  well-
being for all at all ages”). 

6.2.3.  Impacts on fundamental rights  

The policy options were assessed to determine if they have an impact on the fundamental rights and/or 
equal  treatment  of  EU  citizens.  The  starting  point  of  the  assessment  of  the  fundamental  rights  is  the 
Charter of Fundamental Rights of the European Union157. All POs were assessed having regard to the 
relevant EU instrument and it was concluded that they maintain full respect for human and fundamental 
rights and none will have any negative impact thereon. 

6.3.  Environmental impact 

The environmental impacts are assessed in terms of impacts on CO2 emissions, air pollution emissions 
and  noise.  Air  pollution  emissions  and  noise  related  external  costs  were  analysed  in  section  6.2.2. 

156 To calculate the external costs of air pollution  emissions and noise, the unit costs from the Handbook on external 
costs of transport have been used (expressed in 2022 prices). Source: Essen, H. et al. (2020), Handbook on the external 
costs of transport: version 2019 – 1.1, Publications Office, available at: https://data.europa.eu/doi/10.2832/51388 
157 OJ C 326 of 26.10.2012 p.2 

51 

 
 
                                                 
Nevertheless, Table 9 additionally provides the reduction in thousand tonnes of NOx and PM emissions in 
the policy options relative to the baseline for 2030 and 2050158.  

Similarly, the reduction in the CO2 emissions is estimated as a result of the increase in the share of zero-
emission vehicles in the HDVs fleet (due to PMc1 in PO-A, PMc1 and PM1 in PO-B, PMc1 and PM3 in 
PO-C), the increase in the intermodal transport (due to PMc2 in all policy options, PM2 in PO-B and PO-
C and PM3 in PO-C) and the improved efficiency of transport operations (PMc3, PMc4 and PMc5 in all 
policy  options).  As  explained  in  section  6.1.5,  the  measures  supporting  the  increase  in  the  intermodal 
transport are estimated to mitigate the risk of modal backshift resulting from the harmonisation measures. 
The reduction in CO2 emissions relative to the baseline in 2030 and  2050 is provided in  Table  9. For 
2030, in PO-A the reduction is estimated at 0.4% of the CO2 emissions from freight transport relative to 
the baseline, in PO-B at 1% and in PO-C at 1.1%. Cumulatively, over 2025-2050, PO-A is estimated to 
reduce CO2 emissions by 10.7 million tonnes relative to the baseline (0.5% of the CO2 emissions from 
freight transport). PO-B would reduce CO2 emissions by 27.8 million tonnes (1.2% of the CO2 emissions 
from  freight  transport)  and  PO-C  by  29.8  million  tonnes  (1.3%  of  the  CO2  emissions  from  freight 
transport), over the same period. The external costs savings of CO2 emissions, expressed as present value 
over 2025-2050 relative to the baseline, are estimated to reduce by EUR  1.3 billion in PO-A, EUR 3.5 
billion in PO-B and EUR 3.7 billion in PO-C. 

Table  9:  Reduction  in  CO2  emissions  and  air  pollution  emissions  in  the  POs  relative  to  the  baseline  scenario 
(EU27), in 2030 and 2050  

Reduction in CO2 emissions (thousand tonnes) 
Reduction in NOx emissions (thousand tonnes) 
Reduction in PM emissions (thousand tonnes) 
Source: TML et al. (2023), impact assessment support study 

609.6 
2.6 
0.9 

25.1 
0.5 
0.4 

2030 

2050 

2030 
1,592.7 
5.1 
1.0 

2050 

54.6 
0.7 
0.4 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

2030 
1,714.3 
7.3 
2.8 

2050 

63.8 
3.3 
3.0 

All policy options are consistent with the environmental objectives of the European Green Deal and the 
European  Climate  Law159.  All  policy  options  contribute  towards  Sustainable  Development  Goal  13 
(‘Take urgent action to combat climate change and its impacts’). No significant harm is expected on the 
environment in any of the policy options. 

158 As explained in Annex 4 (section 1) of the impact assessment report, the CO2 emissions intensity by vehicle type 
and  transport  mode  from  the  baseline  scenario  (including  its  evolution  over  time)  is  used  together  with  the  transport 
activity to calculate the CO2 emissions. For NOx and PM2.5, the EEA/EMEP emission inventory guidebook for road 
transport  was  used (Tier 2 emission  factors for heavy duty  vehicles, EURO VI D/E) for the base year, adjusted over 
time  to  match  the  NOx  and  PM2.5  emissions  from  the  baseline  scenario  developed  with  the  PRIMES-TREMOVE 
model.  To  calculate  the  external  costs  of  CO2  emissions,  the  unit  costs  from  the  Handbook  on  external  costs  of 
transport have been used (expressed in 2022 prices). Source: Essen, H. et al. (2020), Handbook on the external costs of 
transport: version 2019 – 1.1, Publications Office, available at: https://data.europa.eu/doi/10.2832/51388. 
159 Regulation (EU) 2021/1119. 

52 

 
 
  
                                                 
7.  HOW DO THE OPTIONS COMPARE? 

7.1.  Effectiveness 

The assessment of effectiveness looks at the extent to which the general and specific objectives (SO) of 
the intervention, as previously described, are met. Table 10 provides the links between policy objectives 
and assessment criteria. A detailed assessment is provided in Annex 10. 

Table 10: Links between objectives and assessment criteria 
General objectives 

Specific objective 

Assessment criteria  

(i) 

improve 

The  general  objectives 
are: 
the 
energy  and  operational 
efficiency  of 
transport 
operations  in  the  broader 
context  of  increased  EU 
climate ambition by 2030 
and EU climate neutrality 
by  2050;  (ii)  ensure  the 
free  movement  of  goods 
and  fair  competition  on 
the internal road transport 
market. 

SO1  -  Remove  barriers  for  the 
uptake  of  ZEV  and  energy-saving 
devices  and  incentivise  intermodal 
transport 

SO2  -  Harmonise  the  rules  on 
maximum  weights  and  dimensions  
of HDV in cross-border operations 

Increase  of  transport  activity  performed  by  ZE 
HDVs 
Expected increase in intermodal transport  
Expected reduction in CO2 emissions 
Expected  reduction  in  the  number  of  barriers  to 
cross-border 
transport,  including  the  need  for 
special permits 
Simplification  of  authorization  procedures  for 
issuing permits for abnormal transport  

SO3  -  Improve  the  enforcement  of 
cross-border  rules, 
including  for 
road safety purposes 

Infringement detection ratio 
Level of controls on maximum weights of HDVs  
Duration of controls  

Each of the policy options addresses the problems identified, their drivers and the general and specific 
objectives. All three policy options provide support to a wider range of operations than the current W&D 
Directive, though the effectiveness varies between the different options. 

Regarding SO1, PO-A effectively contributes to the uptake of ZEV, as operators do not lose any payload 
when using such vehicles due to the PO’s measures increasing weight and length for ZE technologies. 
However,  PO-B  is  more  effective,  as  weight  allowances  are  granted  irrespective  of  the  weight  of  the 
technology used, which could result in higher payloads for operators and thus creating more incentives for 
them to invest in ZE technologies. While PO-A facilitates somewhat intermodal containerised transport, 
PO-B significantly improves the attractiveness of intermodal transport by extending the allowance of extra 
4t (currently to compensate the weight of empty container or swap body used in intermodal operations) 
also for non-containerised intermodal operations. In practice, it means that operators using conventional 
HDVs may, in fact, benefit from additional payload when using their trucks, trailers and semitrailers in 
intermodal operations. Consequently, the  alignment of the W&D  Directive  with the CTD  under PO-B 
would bring along synergy effects in promoting growth of intermodal transport. PO-C is more effective in 
addressing SO1 than PO-A and PO-B, by further incentivising the use of ZEV and shift to intermodal 
transport as it removes regulatory barriers for the use of EMS in cross-border operations, and at the same 
time introduces several conditions for the use of EMS (which must be ZEV or/and intermodal and used in 
dedicated  parts  of  the  TEN-T  road  network).  These  conditions  imposed  by  PO-C  entail  upfront 
investment or a change of a business model by operators, limiting the use cases.  

For SO-2, PO-A harmonises the rules for cross-border operations by certain types of HDVs (5- and 6-
axle), heavier HDVs (44t) and introduces the harmonised loaded length for car carriers. PO-A allows the 
cross-border transport of EMS between Member States that already allow these vehicles combinations. It 
does not fully harmonise the rules as EMS are subject to the national limits in terms of length, weight and 
axel  weight,  which  provides  Member  States  with  the  possibility  to  adapt  their  use  to  the  national 

53 

 
 
 
circumstances. PO-A will also reduce the need for special permits linked to the transport of high-cube 
containers. These measures effectively contribute to smooth cross-border operations and eliminate legal 
barriers  to  certain  intermodal  transport  operations,  ensuring  fair  competition  between  operators  on  the 
internal road transport market. Through the harmonisation of the rules, PO-A creates legal certainty and a 
clear  regulatory  framework  for  operators  and  enforcers.  PO-B  further  extends  this  effectiveness  in 
harmonisation  by  providing  common  requirements,  harmonised  documents  and  procedures  for  the 
authorisation of abnormal transport, including the transport of indivisible loads. Although the segment is 
small,  it  is  mostly  involved  in  international  operations,  as  the  type  of  goods  (e.g.  wind  turbines,  large 
industrial equipment, specialised components) are often transported across borders for assembly or to a 
remote construction or mining site. Therefore, harmonisation of administrative and safety requirements 
render  the  operations  more  efficient  reducing  unnecessary  burden  for  operators.  PO-B  is  thus  more 
effective than PO-A in providing clear rules facilitating fair, safe and efficient cross-border operations.   
PO-C brings additional effect compared to PO-B by setting corridors in the EU for abnormal transport 
operations which enhances clarity as regards the part of network that can be used. PO-C also harmonises 
the use of EMS of 25.25m long and 60t all over the EU, but it creates new barriers impeding the currently 
existing cross-border transport of EMS beyond those limits.  

For  SO3,  PO-A  is  effective  in  enhancing  enforcement  obligations  on  Member  States  by  introducing 
minimum  thresholds  for  controls  on  overloaded  vehicles.  The  overall  significance  of  such  controls  is 
strong, as their increased frequency and effectiveness discourage non-compliant behaviours, thus reducing 
the  number  of  overloaded  vehicles  circulating  on  EU  roads,  contributing  to  less  risks  to  road  safety. 
However, PO-A maintains random controls which are not an efficient way of detecting infringements and, 
as a consequence of the increase in the overall number of checks PO-A will also increase the time and 
resources  dedicated  to  performing  those  roadside  checks.  PO-A  provides  for  additional  possibilities  of 
enhancing  effectiveness  of  controls  and  improving  compliance  via  the  implementation  of  intelligent 
access  policies.  However,  its  voluntary  nature  may  result  in  a  limited  outreach.  PO-B  introduces  the 
obligation  to  deploy  a  minimum  number  of  WIM  systems  per  Member  State,  to  help  enforcers  detect 
overloaded vehicles while they are in motion. Thus, PO-B is more effective than PO-A as it allows for 
targeting checks at non-compliant (overloaded) vehicles rendering the controls more efficient (increasing 
the  infringement  detection  rate)  further  dissuading  from  non-compliant  behaviour.    The  use  of  WIM 
systems  will  in  addition  increase  the  ratio  of  controls  performed  by  Member  States  with  the  same  (or 
lower) level of resources dedicated to performing roadside checks. PO-C introduces even more advanced 
enforcement tools by requiring the use of certified WIMs, which do not only detect overloaded vehicles, 
but  also  automatically  analyse  the  type  and  severity  of  infringement  and  issue  a  fine.  However,  the 
efficiency of enforcement is not as significantly increased between PO-B and PO-C as it is between PO-B 
and PO-A. Moreover, PO-C measure imposing extra safety requirements on vehicles and drivers of EMS 
(PM8)  does  not  bring  significant  safety  gains,  as  EMS  are  usually  carried  out  with  better  and  newer 
vehicles by experienced and specifically trained drivers.  

7.2.  Efficiency 

Efficiency concerns the ‘extent to which objectives can be achieved for a given cost (cost effectiveness)’. 
In all policy options, the benefits outweigh the increase in costs, relative to the baseline. The estimates of 
costs and benefits are summarised in Table 11. 

Table  11: Summary  of  costs  and  benefits  of  policy  options  –  net  present  value  for  2025-2050  compared  to  the 
baseline (in million EUR), in 2022 prices 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

Transport operators 

54 

 
 
  
  
  
  
PO-A 

Difference to the Baseline 
PO-B 

PO-C 

466.6 
762.7 
0.0 
609.6 

643.0 
12,138.5 
3,218.2 

6,816.9 
49,093.5 
4,543.6 

2,132.6 
42,831.1 
4,421.7 

4,346.6 
16.4 
22,796.3 
3,028.0 

Adjustment costs 
Adjustment costs savings 
Administrative costs savings 
Public authorities 
Adjustment costs  
Administrative costs 
Administrative costs savings 
Adjustment costs savings 
European Commission 
Adjustment costs  
External costs savings 
3,695.0 
Reduction in external costs of CO2 emissions 
6,232.9 
Reduction in external costs of air pollution emissions 
957.0 
Reduction in external costs of noise emissions 
1,363.9 
Reduction in external costs of accidents 
15,096.1 
Total costs 
97,012.6 
Total benefits 
81,916.5 
Net benefits 
Benefits to costs ratio 
6.4 
Source: TML et al. (2023), impact assessment support study; Note: The baseline scenario is also expressed as present 
value over 2025-2050, for consistency reasons. 

3,451.0 
2,113.1 
702.5 
877.4 
6,496.5 
80,221.1 
73,724.5 
12.3 

1,319.5 
1,642.7 
599.9 
535.8 
1,872.9 
20,064.2 
18,191.4 
10.7 

8,252.5 
25.4 
23,586.0 
7,540.6 

0.93 

0.47 

1.40 

The major cost elements of the policy options are related to adjustment costs for public authorities and for 
road transport operators. Over 95% of total adjustment costs for public authorities in all policy options 
relate  to  maintenance  and  reinforcement  of  road  infrastructure.  PO-C  shows  the  highest  total  costs, 
estimated at EUR 15.1 billion, followed by PO-B (EUR 6.5 billion) and PO-A (EUR 1.9 billion). PO-C is 
also estimated to result in the highest total benefits, estimated at EUR 97 billion expressed as present value 
over  2025-2050  relative  to  the  baseline,  followed  by  PO-B  (EUR  80.2  billion)  and  PO-A  (EUR  20.1 
billion).  

Overall,  all  policy  options  result  in  net  benefits  relative  to  the  baseline.  PO-C  shows  the  highest  net 
benefits,  estimated  at EUR 81.9 billion  expressed  as present  value over 2025-2050, followed  by  PO-B 
(EUR 73.7 billion) and PO-A (EUR 18.2 billion). PO-B shows the highest benefit to cost ratio among the 
options (12.3), followed by PO-A (10.7) and PO-C (6.4). 

7.3.  Coherence 

Internal coherence assesses how well the various provisions of the revised Directive fit together and work 
in a coordinated manner to achieve its objectives. The measures under each policy option are compatible 
with each other, however, the effectiveness of some of them may be limited by the co-existing provisions 
of the Directive. This is the case of PO-A, whose measures aimed at advancing the intermodal transport 
(PMc2) and the uptake of zero-emission HDVs (PMc1), coexist with the existing (and to be maintained) 
national derogations allowing for higher weights and dimensions for conventional HDVs used in national 
road-only operations. The extra weight/length under national derogations allow for extra payload while 
the  extra  weight/length/height  under  PO-A  only  compensate  the  weight  and  size  of  zero-emission 
powertrain or a container. This incompatibility restricts the effectiveness of the incentives to ‘green’ the 
fleet and the freight operations provided under PO-A.  

55 

 
 
  
  
  
  
  
  
  
  
  
  
PO-B  significantly  reduces  this  incompatibility  by  allowing  the  extra  weight/length  for  ZE  HDVs, 
irrespective the weight of the technology (PM1) and by classifying trailers and semitrailers as intermodal 
transport units able to benefit from extra 4t allowance for intermodal transport (PM2). At the same time, 
by bringing extra 4t of payload to HDVs used in non-containerised operations, PM2 slightly weakens the 
incentive  for  containerised  transport  provided  by  the  Directive,  where  extra  4  t  is  used  greatly  to 
compensate the weight of empty container or swap body and not to increase payload.   

PO-C contains the same slight inconsistency between incentives for containerised and non-containerised 
transport.  The  potential  inconsistency  between  PMc4  allowing  for  cross-border  operations  by 
conventional  EMS  and  44t  HDVs  between  allowing  Member  States  allowing  and  PM1  and  PM3  is 
eliminated by introducing the target date of end 2035 as of which, in order to participate in cross-border 
operations,  44t  HDVs  must  be  ZEV,  and  EMS  must  be  either  ZEV  or  part  of  intermodal  operations. 
External coherence assesses compatibility and consistency of the revised Directive with other EU laws 
and relevant EU policies as well as international obligations. All policy options are consistent with the 
EU, national and international standards related to road safety, access to the road transport market, free 
movement of goods and protection of environment. They allow for synergy effect with the initiative on 
CO2 standards for HDVs and are co-dependent with the Alternative Fuel Infrastructure Regulation, TEN-
T Regulation and Connecting Europe Facility as regards development of high-quality road infrastructure 
and charging/fuelling stations on the road network necessary for the efficient deployment and use of zero-
emission  and  longer/heavier  vehicles.  In  addition,  PO-B  brings  stronger  consistency  with  Combined 
Transport Directive by aligning the concepts of intermodal and combined transport (PM 2). PO-B and 
PO-C strengthen the links with TEN-T Regulation by introducing mandatory installation of WIMs on the 
TEN-T road network (PM 6 and PM 7) and are in line with the EU digitalisation objectives by introducing 
digitalise documents and automated WIMs (PM4 and PM7).  

7.4.  Subsidiarity and proportionality 

In terms of subsidiarity, all policy options fulfil this principle, as they all bring about the harmonisation of 
the legal framework applicable on the EU internal road transport market. This harmonisation allows for 
fair and seamless cross-border freight transport operations and for aligning the pace of decarbonisation of 
national  HDV  fleets  operating  on  the  EU  market,  which  would  not  be  achieved  through  individual 
national initiatives or through bilateral or multilateral agreements between Member States. The initiative 
allows to reduce the negative externalities that are not domestic in nature such as emissions (GHG and air 
pollutants) and congestion reducing their impacts across national borders. All policy options preserve the 
prerogative of Member States to grant national derogations that reflect national and regional needs and 
operational  conditions.  PO-A  provides  for  lowest  level  of  intervention  but  is  not  so  effective  in 
incentivising the decarbonisation of transport operations and increasing consistency and effectiveness of 
enforcement  across  the  borders.  PO-C  provides  for  most  intensive  intervention  by  introducing  the 
obligation  on  Member  States  to  allow  the  circulation  on  the  TEN-T  network  of  European  Modular 
Systems  (longer/heavier  combination  of  vehicles)  provided  that  they  are  zero-emission  or  involved  in 
intermodal operations (PM 3). This measure may  be seen by the Member States who currently do not 
allow weight or length excesses from the limits set in the Directive, as too interventionist. PO-B strikes the 
balance between establishing minimum standards at the EU level for decarbonisation and enforcement of 
freight operations and leaving Member States flexibility in setting more ambitious solutions, in particular 
as regards enforcement tools. 

As to the proportionality, PO-A and PO-B contribute to improving energy and operational efficiency of 
cross-border transport operations and strengthening enforcement effectively, without imposing significant 
costs for operators and entailing only some upfront investment costs for Member States (PMc6 and PM6). 

56 

 
 
PO-C may raise concerns of disproportionality, due to the high level of policy intervention regarding high-
capacity transport (indivisible loads, EMS) and enforcement requirements, resulting in significant changes 
to  the  existing  approaches  in  Member  States  as  well  as  considerable  upfront  investments  necessary  to 
implement measures PM5, PM7 and PM8. 

7.5.  Conclusion – ranking of the policy options 

Table 12 provides a summary of the comparison of the options against the baseline scenario in terms of 
effectiveness, efficiency, coherence, subsidiarity and proportionality. The following ranking symbols have 
been used: from '+' (more effective/efficient/coherent/ proportionate than the baseline) to '++++' (much 
more  effective/efficient/coherent/  proportionate  than  the  baseline);  from  '-'  (less  effective/efficient/ 
coherent/proportionate  than  the  baseline)  to  '----'  (much  less  effective/efficient/coherent/  proportionate 
than the baseline). 

Table 12: Comparison of options in terms of effectiveness, efficiency, coherence, subsidiarity and proportionality 
relative to the baseline 

Criteria 
Effectiveness 
Efficiency 
Coherence 
Subsidiarity and proportionality 

8.  PREFERRED OPTION 

POA 
++ 
++ 
-/+ 
++ 

POB 
+++ 
+++ 
++ 
++ 

POC 
++++ 
+ 
++ 
-/+ 

8.1.  Identification of the preferred policy option and stakeholders’ views 

All policy options address the identified problems and their drivers and contribute to achieving specific 
and main objectives, although with a different level of effectiveness and efficiency.  

Policy option A sanctions what is a general practice in Member States, harmonising the conditions for 
cross-border  traffic  with  longer  and/or  heavier  vehicles.  By  adapting  the  technical  standards  of  HDV 
ensuring  that  ZE  HDVs  do  not  lose  the  payload  compared  with  conventional  combustion  engine,  it 
incentivises  the  uptake  of  zero-emission  technologies.  It  also  further  improves  the  efficiency  of 
containerised  transport  and  promotes  intermodal  transport.  It  somewhat  strengthens  enforcement  by 
mandating  a  minimum  level  of  controls.  These  measures  do  not  entail  additional  investments  by 
operators,  and  imply  additional  insignificant  enforcement  costs,  mainly  in  Member  States  where  the 
current level of controls is low. However, it requires certain investments in the infrastructure by Member 
States.  The  measures  contained  in  this  option  greatly  reflect  the  demands  of  the  stakeholders  gathered 
during consultations activities.  

Policy option B goes further in enabling intermodal operations and in encouraging greening of the HDV 
fleet by providing additional economic incentives through additional loading capacity to HDVs with zero-
emission powertrains or HDVs involved in intermodal (non-containerised) operations. It harmonises the 
authorisation  requirements  and  administrative  procedures  for  cross-border  transport  by  certain 
longer/heavier  vehicles  and  introduces  mandatory  weight  control  equipment  to  be  installed  in  road 
infrastructure for more effective and efficient enforcement. This option requires certain investments and 
administrative  reforms  by  Member  States,  while  for  operators  it  brings  benefits  such  as  reduced 
administrative burdens and possibility of additional payload in emission-free and intermodal operations.  

Policy option C promises the highest level of harmonisation, decarbonisation and enforcement. However, 
compared to the other options, this comes with a much higher level of intervention and upfront costs to be 

57 

 
 
borne  by  operators  and  national  authorities.  In  addition,  due  to  the  high  level  of  interventionism,  this 
policy option may be more difficult to adopt and implement. 

From the comparison of the policy options presented in section 7 of this report, it appears that PO-C is the 
most  effective  in  addressing  specific  objective  1  (Remove  barriers  for  the  uptake  of  ZEV  and  energy-
saving devices and incentivise intermodal transport) in terms of increase in transport activity performed 
by  ZE  HDVs,  increase  in  intermodal  transport  and  reduction  in  CO2  emissions.  It  is  also  the  most 
effective in addressing specific objective 2 (Harmonise the rules on maximum weights and dimensions of 
HDV in cross-border operations) and specific objective 3 (Improve the enforcement of cross-border rules, 
including for  road  safety  purposes).  It  shows the highest net  benefits,  but  at  the same time  entails the 
highest level of costs. The total costs of PO-C are 132% higher than those resulting from PO-B, while the 
total benefits are only 21% higher for PO-C compared to PO-B. The higher costs of PO-C are linked to 
the mandatory measures (PM3, PM7 and PM8) that require higher adjustment costs for public authorities 
and  transport  operators.  These  costs  relate  in  particular  to  maintenance  and  reinforcement  of  road 
infrastructure due to the obligation on Member States to allow the circulation on the TEN-T network of 
European Modular Systems (longer/heavier combination of vehicles) provided that they are zero-emission 
or involved in intermodal operations (PM3), investments in "certified" Weigh-in-motion (WIM) systems 
(PM7) and training for the EMS drivers (PM8).  

PO-B appears to be less effective than PO-C in achieving the specific objectives. However, this will be 
achieved in a more progressive and efficient way, entailing a higher benefit to cost ratio than PO-C, and 
allowing a smooth transition for authorities and operators. Measures under PO-B are easier and quicker to 
implement.  PO-B  strikes  the  balance  between  establishing  minimum  standards  at  the  EU  level  for 
decarbonisation  and  enforcement of  freight operations  and  leaving  Member States flexibility  in setting 
more ambitious solutions, in particular as regards enforcement tools. Thus, PO-B is assessed to be more 
proportionate than PO-C.  

Hence,  based  on  the  trade-off  between  effectiveness  and  efficiency  of  different  policy  options,  it  is 
concluded that PO-B is the preferred policy option. It provides for the rights balance between achieving 
the desired objectives effectively while ensuring that the measures proposed under this policy option do 
not go further than what is necessary to resolve the problem efficiently. 

Stakeholders  widely  supported  the  measures  common  to  all  policy  options.  During  the  open  public 
consultations,  majority  of  respondents  considered  it  important  to  increase  the  maximum  weights  and 
dimensions to the limits most used in Members States (67 out of 125 respondents) and to authorise cross-
border transport by heavier/longer vehicles between the neighbouring Member States who allow the same 
standards  (74  out  of  131  respondents).  The  dedicated  workshops  confirmed  these  findings  and  further 
specified the supported measures. The authorities and industry representatives considered that: an extra 
length/weight to accommodate for ZE technologies (in all vehicles and units), a cross-border transport by 
44t  HDVs  and  EMS  in  allowing  Member  States,  harmonisation  of  a  vehicle  carrier  loaded  length  at 
20.75m and establishing minimum level of checks of HDVs’ weight, are the most important measures for 
decarbonisation, harmonisation and enforcement.  

At  the  same  time,  a  few  Member  States  (four  national  authorities)  and  rail/intermodal  transport 
stakeholders  (two  associations)  showed  some  resistance  to  allowing  cross-border  operations  by 
heavier/longer HDVs, even if only among allowing Member States. This was due to concerns of impacts 
on road infrastructure and of possible modal backshift from rail to road. However, no robust arguments or 
evidence of potential modal backshift or damage to infrastructure resulting from the cross-border nature of 
operations have been demonstrated.  

58 

 
 
In  addition  to  these  common  measures,  the  other  PO-B  measures,  such  as  allowing  maximum  extra 
weight  of  4t  regardless  the  weight  of  ZE  technology  and  considering  trailers  and  semitrailers  as 
intermodal transport units (thus eligible to benefit from extra 4t weight for intermodal operations) were 
much  welcomed  by  the  transport  sector  and  by  manufacturers  (87  of  128  and  74  of  123  respondents, 
respectively). The great majority of stakeholders demanded and supported the harmonisation of certain 
technical  requirements  for  loaded  length  of  car  transporters  and  simplification  of  administrative 
procedures  concerning  the  permits  for  abnormal  transport  operations  (80  of  124  respondents).  These 
measures  have  been  considered  crucial  for  ensuring  fair  competition  and  increasing  environmental 
efficiency of freight transport. 

8.2.  REFIT (simplification and improved efficiency) 

This  initiative  is  part  of  the  Commission  Work  Programme  2022  under  Annex  II  (REFIT  initiatives), 
under the heading ‘A New Push for European Democracy’. It has an important REFIT dimension in terms 
of simplification and alignment of the technical requirements and administrative procedures that Member 
States  apply  to  a  circulation  of  longer  and/or  heavier  vehicles  on  their  territories  and  in  cross  border 
operations. The initiative will reduce administrative burdens for operators related to diverging and costly 
requirements for permits for a transport of abnormal/indivisible load. An important cost burden resulting 
from the current WDD are the implications for operators who are hindered from performing cross-border 
operations  by  longer/heavier  vehicles  that  are  allowed  in  two  (or  more)  neighbouring  Member  States. 
Lack of clarity in WDD provisions leads to diverging national interpretations as to cross-border operations 
by  such  vehicles  and  consequently  to  a  patchwork  of  practices,  where  in  some  cases  operators  are 
obligated to partially un-load the vehicle before crossing the border and in others, they may freely cross 
the border based on bilateral arrangements between the two Member States. The initiative will remove the 
legal uncertainty regarding border crossing operations by longer/heavier vehicles (e.g., car transporters, 
EMS, 44t HDVs) and the related administrative burdens. In addition, by establishing common standards 
for the enforcement of cross-border rules, more legal certainty for operators, manufacturers and authorities 
will  be  created.  Overall,  by  the  introduction  of  harmonised  rules  and  conditions  for  cross-border 
operations by vehicles exceeding certain weights and dimensions, the initiative will simplify and improve 
the efficiency of the legislation reducing regulatory burdens for operators and contributing to the smooth 
fair and safe functioning of the internal road transport market. 

8.3.  Application of the ‘one in, one out’ approach  

PO-B  is  expected  to  lead  to  administrative  costs  savings  for  road  transport  operators  from  the 
reduction in the time needed to prepare and submit the requests for the issuance of special permits 
for the transport of indivisible loads (EUR 1.2 billion, expressed as present value over 2025-2050 
relative to the baseline) enabled by  the application of the one-stop-shop principles at national level 
and the digitalisation of documents. For the purpose of the ‘one in, one out’ approach, the annual 
administrative costs savings are estimated at  EUR 71.8 million per year from the reduction in the 
time needed to prepare and submit the requests for the issuance of special permits for the transport 
of indivisible loads, enabled by  the application of the one-stop-shop principles at national level and 
the digitalisation of documents160.  

160 As explained in section 6.1.3, the annual average cost saving per permit over 2025-2035 has been estimated at EUR 64.1. 
Considering  the  average  number  of  permits  over  2025-2035,  estimated  at  1.12  million,  the  average  annual  cost  savings  are 
estimated at EUR 71.8 million. 

59 

 
 
                                                 
In addition, as explained in section 6.1.3, PO-B is also expected to result in adjustment costs and 
adjustment  costs  savings  for  road  transport  operators.  Overall,  PO-B  would  result  in  net  costs 
savings  for  road  transport  operators,  estimated  at  EUR  45.1  billion,  expressed  as  present  value  over 
2025-2050 relative to the baseline. 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission will monitor and evaluate the actual impacts of the legislation through different actions 
and a set of indicators allowing to measure progress in achieving specific and operational objectives. The 
monitoring  actions  include  regular  (biennial)  reporting  by  Member  States  about  number  and  type 
(random,  targeted,  and  automated)  of  controls  of  compliance  performed  and  number  and  category  of 
infringements detected. Based on these national submissions the Commission will prepare biennial reports 
to  the  European  Parliament  and  the  Council  on  the  implementation  by  the  Member  States  of  the 
provisions on weights and dimensions of HDVs and drawing conclusions on the compliance by Member 
States with their enforcement obligations and on the observance by operators of the rules on weights of 
HDVs.  

The  regular  reporting  will  also help to  observe the  trends in  compliance  levels  and in  effectiveness  of 
enforcement activities and tools. The Commission will be assisted by the  Road  Transport  Committee 
and  the  Expert  Group  on  Weights  and  Dimensions  in  identifying  and  discussing  cases  of  divergent 
interpretations of the EU rules on weight and dimensions, different national requirements and enforcement 
practices with the aim to establish common approach and issue guidance, where needed. The Committee 
will also facilitate collection of statistics on different road transport segments, such as abnormal transport 
or vehicle transporters. To monitor the uptake of zero-emission HDVs the Commission will collect the 
data  from  manufacturers,  suppliers  and  type  approval  national  authorities  and  will  continue  the 
cooperation with the European Environment Agency (EEA). The Commission may also encourage and 
support the exchange of best practices among Member States, by sharing information on effective 
enforcement  techniques,  training  programs  for  inspectors  and  promoting  cooperation  between 
enforcement  agencies.  The EEA combines the data  on all newly registered HDVs in Member States, 
which  the  Commission  collects  from  the  national  authorities,  with  the  monitoring  data  from 
manufacturers. The Commission publishes these monitoring data every year. To measure the progress and 
the actual effects of the initiative, a list of operational objectives and indicators for assessing the progress 
towards  them  have  been  identified  and  are  detailed  in  Annex  13.  Regular  evaluation  of  the 
implementation of the W&D Directive will be important in order to assess its effectiveness and efficiency 
and in order to measure progress against the specific objectives. In future, reporting and monitoring may 
be  further  automated  and  digitalised.  The  regular  contacts  with  the  members  of  the  Commission’s 
Committee on Road Transport and of a dedicated Expert Group will also facilitate the monitoring of the 
implementation of the Directive and taking mitigation measures in a timely manner.  

The success of the W&D Directive can be measured against operational objectives as follows:  

1) The success in removing barriers to the internal market can be determined by the degree to which the 
revised Directive achieves harmonization of weights and dimensions regulations across Member States. 
This  can  be  measured  by  the  number  of  eliminated  national  requirements  and  by  monitoring  the 
administrative  and  operational  costs  reductions  related  to  streamlined  authorisation  procedures  and 
facilitated cross-border operations. The relevant information will be collected from the key stakeholders, 
including  hauliers  associations,  abnormal  load  transport  organisations  and  statistics  from  national 
competent authorities.  

60 

 
 
2) The success in boosting the uptake of zero-emission HDVs and energy-saving devices can be assessed 
based on the increased number of zero-emission HDVs registered, sales volumes, and their share in the 
overall HDV fleet, increased number of HDVs sold with energy-saving devices installed. The relevant 
information will be gathered from statistics from Member States, automotive manufacturers and hauliers’ 
associations.   

3) The success in promoting intermodal operations can be measured by monitoring the increase in volume 
of intermodal  operations (containerised  and  non-containerised), increase  in number  of  hauliers that  are 
involved  in  intermodal  operations,  increase  in  volume  of  transport  of  high-cube  containers.  The 
information will be gathered from the sectoral organisations, official statistics on volumes of operations by 
transport mode and changes in modal shares of freight transport. The relevant data can also be collected 
from eFTI platforms, containing information on cargo transportation.  

4) The success in enforcement can be assessed by evaluating the effectiveness of enforcement measures. 
Data  on  the  number  of  inspections,  detected  infringements,  detection  ratio,  penalties  imposed,  and 
compliance rates as well as number and types of WIM systems installed would be collected from national 
authorities, in particular enforcement agencies. Stakeholders can also provide insights into the consistency 
and effectiveness of enforcement practices. 

5)  The  success  of  the  revised  Directive  can  also  be  measured  by  improvements  in  road  safety  and 
environmental outcomes. Data on accident rates involving HDVs, emissions reductions, and the overall 
environmental  impact  of  HDV  operations  would  be  gathered  from  the  enforcement  agencies,  statistics 
from road safety monitoring and the European Environment Agency. 

The key stakeholders involved in providing data for monitoring and evaluation purposes include national 
authorities  responsible  for  inspections  and  enforcement,  vehicle  manufacturers,  industry  associations, 
transport operators, European Environmental Agency and relevant EU and national databases.  The EU 
can  use  these  data  to  assess  the  Directive's  effectiveness,  identify  areas  for  improvement,  and  make 
informed policy decisions related to weights and dimensions regulations. 

The EU social, market and technical rules applicable to road transport are closely interlinked and they are 
accompanied by well-established monitoring and enforcement system at the EU and national levels. The 
enforcement of Weights and Dimensions Directive is part of this system. When non-compliance with the 
prescribed weights and dimensions requirements is detected during the roadside inspections, enforcement 
actions are taken by the competent authorities in accordance with the national penalty system. While the 
type and level of sanctions is the competence of Member States, they must ensure that penalties are non-
discriminatory, effective, dissuasive and proportionate to the seriousness of infringement committed. The 
level  of  seriousness  of  infringements  is  determined  by  the  EU  secondary  legislation  (Implementing 
Regulation  (EU)  2016/403).  In  addition,  the  infringements  of  the  Directive  must  be  recorded  in  the 
national register of road transport undertakings, exchanged via the European Register of Road Transport 
Undertakings (ERRU) and reflected in the risk rating score of the undertaking (as required by Regulation 
1071/2009).  The  undertakings  with  the  higher  risk  score  shall  be  subject  to  targeted  more  frequent 
controls. The non-compliance with the Directive may affect the good repute of road transport operator and 
the right to operate on the internal market (Regulation 1071/2009). In future, cross-border implementation 
of sanctions will be facilitated through the proposed revision of the Cross-Border Enforcement Directive.

61 

 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The  lead  DG  is  the  Directorate-General  for  Mobility  and  Transport  DG  MOVE,  Unit  C1:  Road 
Transport. 

DECIDE reference number: PLAN/2021/11805. 

Item 8.b) in Annex I to Commission Work Programme 2023, headline ‘A European Green Deal’, 
part of the Greening freight package161. 

2.  ORGANISATION AND TIMING 

The Call for evidence162 was published on 8 March 2022. 

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

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

3.  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.  RSB  issued  a  postivie  opinion  with  reservations  on  26  May  2023.  The  comments  received 
from the Board have been addressed in the revised version of the Impact Assessment as detailed in 
the table below. 

Table 13: Modifications of the impact assessment report in response to RSB comments 

Detailed RSB comments What to improve 

(1)  The  report  should  better  explain  the  approach  and 
assumptions  that  underpin  the  modelling  and  its 
link  to  the  cost-benefit  analysis.  In  particular,  it 
should  provide  a  better  explanation  of  the  analysis 
of  the  expected  increase  in  transport  activity  by 
zero-emission  vehicles  by  policy  option.  It  should 
the  (one-off  and  recurrent) 
detail  better  how 
adjustment  and  administrative  costs  and  cost 
savings  have  been  calculated.  It  should  also  revise 
the ‘One In, One Out’ section and correctly identify 
the costs and cost savings in scope of offsetting. 

Modifications to the impact assessment 

The explanations on the approach used and the increase in 
activity  of  ZEV  by policy option, relative  to the  baseline, 
have  been  added  in  section  6.1.3.  In  addition,  sensitivity 
analysis  has  been  performed  to  account  for  the  impact  of 
higher/lower  price  elasticity  of  demand  for  road  transport 
on  the  transport  activity  performed  by  ZEV.  The  results 
are presented in section 6.1.3.  

Further  explanations  on 
the 
adjustment  and  administrative  costs  have  been  added  in 
section  6.1.1,  including  references  to  Annex  4  (section  3) 
where  the  costs  and  costs  savings  for  each  measure  are 

the  quantification  of 

161  COM (2022) 548 final of 18 October 2022. 
162  Commercial vehicles – weights and dimensions (evaluation) (europa.eu). 

62 

 
 
 
                                                 
discussed in detail (including the assumptions used and the 
results).  In  addition,  tables  with  the  impacts  by  policy 
option and policy measure expressed as present value over 
2025-2050  relative  to  the  baseline  have  been  added  in 
sections  6.1.1  and  6.1.3  (in  addition  to  the  impacts  for 
2030,  2040  and  2050 
the  baseline). 
Explanations  on  the  infrastructure  maintenance  costs  and 
infrastructure  reinforcement  and  upgrading  costs  have 
been added in section 1 of Annex 4. 

relative 

to 

level  and 

Sections  8.3  and  6.1.3  and  Annex  3  to  the  impact 
assessment report have been revise in order to clarify that 
under the scope of the ‘one in, one out’ approach PO-B is 
expected  to  lead  to  administrative  costs  savings  for  road 
transport  operators  from  the  reduction  in  the  time  needed 
to  prepare  and  submit  the  requests  for  the  issuance  of 
special permits for the transport of indivisible loads (EUR 
1.2  billion,  expressed  as  present  value  over  2025-2050 
relative to the  baseline), enabled by  the application of the 
one-stop-shop  principles  at  national 
the 
digitalisation of documents. For the purpose of the ‘one in, 
one out’ approach, the annual administrative costs savings 
are  estimated  at  EUR  71.8  million  per  year  due  to  the 
reduction  in  the  time  needed  to  prepare  and  submit  the 
requests  for  the  issuance  of  special  permits  for  the 
transport of indivisible loads.   
Further  explanations  as  regards  the  methodology  and 
evidence  used in the analysis of road safety impacts  have 
been  added  to  section  6.2.1  of  the  impact  assessment 
report.  
The  additional  information  on  problem  analysis  has  been 
added  to  section  2.2  of  the  impact  assessment  report.  It 
explains  the  relative  importance  of  the  key  problems  and 
identifies  other  external  problem  drivers  (beyond  the 
Directive)  that  contribute  to  the  underperformance  of  the 
Directive.  
Additional  explanations  have  been  added  to  section  5.2.3 
about  the  differences  between  the  policy  options,  the 
interrelation between their respective policy measures and, 
in  particular  between  PM3  and  PM7  and  PM8  (on 
enforcement  and  safety  requirements  for  vehicles  and 
drivers) within PO-C. 

In  addition,  PO-A  has  been  revised  to  include  measure 
PMc7,  which  was  previously  included  only  in  PO-B  and 
PO-C. The adjustment costs for the European Commission 
in section 6.1.2 and the  summary of costs and benefits  of 
policy  options  presented  in  section  7.2  have  been  revised 
accordingly.  The  addition  of  PMc7  to  PO-A  has  not 
changed  the  ranking  of  the  policy  options  in  terms  of  
benefits to costs ratio (Table 11). 
The scoring of policy options has been  modified in  Table 
12 to better reflect the analysis performed in section 7. The 
choice  of  the  preferred  policy  option  was  based  on  the 
analysis  of  trade-offs  between  the  effectiveness  and 
efficiency  of  different  policy  options.  The  description  of 
key  trade-offs  has  been  added  to  section  8  of  the  impact 
assessment report.   

(2)  The  report  should  better  explain  the  methodology 
and  evidence  used  to  conclude  that  the  overall 
impact on road safety will be positive. 

(3)  The  report  should  clarify  in  its  problem  definition 
the relative importance of the problem drivers. The 
report  should  assess  to  what  extent  these  problem 
drivers  are  sufficiently  exhaustive  to  design  the 
revision as effective as possible. 

(4)  The report should better explain why there are three 
policy options designed around six common policy 
measures  and  to  what  extent  these  options  can  be 
considered complete. The report should also explain 
how  the  other  policy  measures,  in  particular  on 
enforcement  and  training,  are  assigned  to  specific 
options 

(5)  The  report  should  set  out  the  scoring  methodology 
used  when  comparing  the  options,  particularly 
when  comparing  the  options  on  effectiveness  and 
efficiency,  and  align  the  scoring  better  with  the 
analysis.  It  should  highlight  the  key  trade-offs 
the 
between  effectiveness  and  efficiency 
selection of the preferred option. 

for 

63 

 
 
 
  
4.  EVIDENCE, SOURCES AND QUALITY 

The  impact  assessment  is  based  on  several  sources,  using  both  quantitative  and  qualitative  data, 
collected from Member States and industry. This includes: 

  The  Commission  Report  on  the  implementation  of  the  amendments  to  Directive  96/53/EC 

introduced by Directive (EU) 719/2015163. 

  The ex-post evaluation of the Weights and Dimensions Directive (see Annex 15).  

  External  support  study  to  the  ex-post  evaluation  of  the  Weights  and  Dimensions  Directive 
carried  out  by  an  independent  consortium  led  by  Transport  &  Mobility  Leuven  and  Ramboll 
Management  Consulting,  further  consisting  of  Panteia,  LNEC,  Apollo  Vehicle  Safety,  and 
individual subcontracted experts. 

  External  technical  support  to  carry  out  the  desk  research,  consultation  activities  and  the 
measurement of impacts of the policy options and policy mesaures of the impact assessment by 
an  independent  consortium  led  by  Transport  &  Mobility  Leuven  and  Ramboll  Management 
Consulting,  further  consisting  of  Panteia,  LNEC,  Apollo  Vehicle  Safety,  and  individual 
subcontracted experts. 

  Stakeholder consultation activities (see Annex 2) 

  Commission’s  experience  in  monitoring  and  implementing  the  Weights  and  Dimensions 

Directive  

  The  Member  States’  reports  on  the  carry  out  of  controls  of  overloaded  heavy-duty  vehicles  in 

accordance with Article 10g of the Weights and Dimensions Directive.   

163  Commission  Staff  Working  Document:  Report  on  the  Implementation  of  the  amendments  to  Directive  96/53/EC 
introduced by Directive (EU) 719/2015, SWD(2023) 70 final. 

64 

 
 
 
 
 
 
 
                                                 
ANNEX 2: STAKEHOLDER 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 Evidence164 (CfE) (21 January 2022 to 21 February 2022), 
  An open public consultation165 (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.  

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: 

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

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

164 
dimensions-evaluation-/feedback_en?p_id=27827305 
165 
dimensions-evaluation-/public-consultation_en 

65 

 
 
 
                                                 
High-level stakeholder 
group 

Description 

Stakeholder 
engagement 
activity 

Road infrastructure 
authorities 

Road transport 
undertakings (freight 
and passenger transport 
operators)  

Business associations  

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 regards to infrastructure 
protection  and  development,  intermodal  transport  and 
road safety. 

CfE 

OPC 

Survey  

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

that 

CfE 

OPC 

Survey 

Workshop 

Business  organisations  represent  the  interests  of  their 
members  who  are  usually  companies  engaged  in 
transportation of goods by road, rail or a combination of 
both.  Road  transport  associations  represent  companies 
that operate HDVs for transporting goods or passengers 
by road. Rail transport associations 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.   

CfE 

OPC 

Survey 

Workshop 

Shippers  

Forwarders; 

for 

are 

arranging 

responsible 

the 
Shippers 
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. 

responsible 

for  managing 

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

rates  with 

road 

66 

CfE 

OPC 

Survey 

CfE 

OPC 

Survey 

 
 
 
 
High-level stakeholder 
group 

Description 

Stakeholder 
engagement 
activity 

EU  Member  States 
national authorities  

goods and managing all necessary documentation. 

National  authorities  are  responsible  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, adopting the safety measures and 
ensuring  compliance  with  all  the  relevant  EU  and 
national  legislation  applicable  to  the  commercial  road 
transport sector.   

CfE 

OPC 

Survey 

Workshop 

HDV manufacturers 
and OEMs (Original 
Equipment 
Manufacturers)  

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. 

CfE 

OPC 

Survey 

Other 
stakeholders 
society, 
academia) 

relevant 
(civil 
NGOs, 

Other relevant stakeholder groups include consumer 
organisations, 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 

Citizens 

representing  a 

Although 
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% 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 

88 

39.3% 

67 

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

84 
28 
7 
5 
3 
9 
224 

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, 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  

24 
21 

18.3% 
16.0% 

68 

 
 
Infrastructure managers 
Manufacturers 
Other road stakeholders 
TOTAL 
*Does not add up to 100% due to rounding 

14 
9 
63 
131 

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 followed the 
various elements of the evaluation matrix, namely effectiveness (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: 

69 

 
 
 
  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 

70 

 
 
 
 
below).  One  concern  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 

71 

 
 
 
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. 

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.  

72 

 
 
 
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 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 

73 

 
 
 
 
 
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, 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 

74 

 
 
 
 
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. 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 

75 

 
 
 
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. 

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. 

76 

 
 
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 

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 

77 

 
 
 
 
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. 

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 

78 

 
 
 
 
 
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  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. 

79 

 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The  revision  of  the  Directive  on  the  maximum  weights  and  dimensions  of  heavy-duty  vehicles 
(HDVs) aims at  increasing the  sustainability of  road transport, deepening the internal  market  and 
ensuring road safety. 
The  preferred  policy  option  will  provide  incentives  for  speeding  up  the  uptake  of  zero-emission 
powetrain technologies and for enhanced involvement in intermodal operations. It will bring legal 
certainty  for  carrying  out  cross-border  operations  by  heavier  and/or  longer  vehicles,  harmonising 
the conditions for such operations. Finally, it will strenghten and harmonise enforcement across the 
EU, improving compliance with the rules in force. 

The  impacts  of  the  preferred  policy  option  are  expected  to  be  significant,  affecting  various 
stakeholders  in  different  ways.  The  main  groups  of  affected  stakeholders  are:  road  transport 
operators,  HDV  drivers,  manufacturers,  national  administrations,  transport  services  clients  and 
society at large. 

The road transport operators will benefit from the possibility of extra payload when they involve 
in intermodal operations and/or when they use zero-emission (ZE) HDVs. The possibility of extra 
payload and improved energy efficiency of ZE HDVs will ensure a faster return on investment in 
the  ZE powetrains  for operators. Clarification  and harmonisation  of the rules applicable to  cross-
border  transport  by  longer  and/or  heavier  vehicles,  such  as:  44t  HDVs  and  European  Modular 
Systems (EMS) between allowing Member States, and car transporters and indvisible load carriers 
throughout the EU, will improve energy and operational efficiency of operations. This will bring, 
among others, operation costs savings for operators and will allow them to optimise the use of their 
fleets  and  of  drivers’  working  time.  The  streamlining  and  digitalisation  of  procedures  for  the 
issuing  of  permits  for  abnormal  transport  will  benefit  operators  active  in  this  segment.  The  road 
transport operators will also benefit from more targeted controls which will eliminate idle time of 
drivers and vehicles durings unnecessary roadside controls of compliant vehicles. 

Drivers  driving  ZE  HDVs  will  enjoy  improved  working  conditions  thanks  to  the  reduction  of 
vibrations,  noise  and  air  pollution  in  the  cabins  of  their  vehicles.  Drivers  who  will  have  more 
opportunities to involve in intermodal operations, performing only first and/or last mile deliveries, 
will benefit from spending less time away from home. Drivers driving vehicles compliant with the 
authorised  maximum  weights  will  also  benefit  from  the  elimination  of  costs  linked  with  the 
unnecessary stops for roadside inspections of vehicles. 

Manufacturers  who,  anyway  will  have  to  comply  with  the  targets  imposed  by  the  HDV  CO2 
Standards  Reguation,  will  benefit  from  the  higher  demand  for  the  ZE  HDVs  from  operators  who 
will  want  to  realize  the benefits  of  energy  and  operational  efficiencies  linked  with  the  use  of  ZE 
HDVs as well as other energy saving solutions.   

National  administrations  will  initially  bear  some  upfront  adjustment  costs  related  to  the 
installation of a minimum number of weigh-in-motion (WIM) systems and introduction of the one-
stop-shop mechanism and procedures for authorisations of transport of abnormal/individible loads, 
including the electronic register for HDVs and their trailers used for such operations. They will also 
bear  some  adjustment  costs  linked  to  a  more  intensive  wear  and  tear  of  the  road  infrastructure 
caused by the circulation of heavier HDVs equipped with zero-emission powertrains, as well as to 

80 

 
 
 
 
 
more inspections of sensitive civil engineering structures (old bridges). Public authorities will incur 
regular  maintenance  and  calibration  costs  of  WIMs  and  will  benefit  from  more  efficient  targeted 
controls with the use of WIMs and a reduction in the processing time for permits due to the one-
stop-shops, which will bring administrative costs savings. In addition they will benefit of adjustment 
costs savings linked to lower maintenance costs for infrastructure due to the decrease in the number of 
trips (driven by the increased payload), the shift from road-only to intermodal transport and the reduction 
in the frequency and severity of overloading practices.  

Transport  service  clients  will  benefit  from  more  efficient  and  sustainable  transport  operations 
which may also result in more competitive prices compared with operations performed by standard 
HDVs.  

The society at large will benefit from a reduction in road transport externalities, in particular CO2 
emissions, air polutant and noise emissions due to the growing use of ZE HDVs in road operations, 
the increase in the intermodal transport and broader use of energy saving modular schemes. Road 
safety  will  improve  due  to  the  reduced  HDV  traffic  and  better  compliance  with  the  rules  on 
maximum authorised weights through gradual eliminations of overloaded HDVs on the roads. 

2.  SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred option (PO-B) 

Description 

Adjustment costs savings 
for road transport operators, 
expressed as present value 
over 2025-2050 relative to 
the baseline 

Amount 

Direct benefits 

EUR 42.8 billion 

Comments 

in 

to 

to 

road 

the  reduced 

the  reduction 

Benefits 
transport  operators, 
estimated at EUR 42.8 billion expressed as 
present value over 2025-2050 relative to the 
the 
baseline,  due 
operation  costs  and 
time 
required  for  cooperating  with  the  public 
for  manual/roadside  weight 
authorities 
checks.  The  reduction  in  operation  costs  is 
driven  by  an  increase 
in  the  average 
payload and the reduction in the number of 
trips (due to the extra length and weight to 
accommodate 
the 
harmonisation  of  the  maximum  permitted 
weight  of  5-  and  6-axle  HDV  in  cross-
transport,  allowing  cross-border 
border 
transport  of  44t  and  EMS  between 
"allowing"  MS    and  the  harmonisation  of 
the  loaded  length  of  vehicle  carriers),  and 
by  the  shift  from  road-only  to  intermodal 
operations  (due  to  the  alignment  of  the 
definition  of  intermodal  transport  with  the 
Combined Transport Directive). 

technologies, 

ZE 

Administrative costs 
savings for road transport 
operators, expressed as 
present value over 2025-
2050 relative to the baseline 

EUR 4.4 billion 

Benefits  to  road  transport  operators,  from 
the  elimination  of  permits  for  the  use  of 
higher  trucks  to  accommodate  high-cube 
containers in intermodal transport (EUR 3.2 
billion,  expressed  as  present  value  over 
2025-2050  relative  to  the  baseline),  and  
from  the  reduction  in  the  time  needed  to 

81 

 
 
 
 
  
I. Overview of Benefits (total for all provisions) – Preferred option (PO-B) 

Description 

Amount 

Comments 

indivisible 

prepare  and  submit  the  requests  for  the 
issuance of special permits for the transport 
of 
loads  (EUR  1.2  billion, 
expressed as present  value over 2025-2050 
relative  to  the  baseline)  enabled  by    the 
application  of  the  one-stop-shop  principles 
at  national  level  and  the  digitalisation  of 
documents. 

Adjustment costs savings 
for national public 
authorities, expressed as 
present value over 2025-
2050 relative to the baseline 

EUR 3 billion 

Administrative costs 
savings for national public 
authorities, expressed as 
present value over 2025-
2050 relative to the baseline 

EUR 22.8 billion 

Reduction in external costs 
of CO2 emissions, expressed 
as present value over 2025- 
2050, relative to the 
baseline 

Indirect benefits 

EUR 3.5 billion 

Reduction  in  external  costs 
of  air  pollutant  emissions, 
expressed  as  present  value 
over  2025-2050,  relative  to 
the baseline 

EUR 2.1 billion 

to  a 

reduction 

Benefits 
to  national  public  authorities, 
estimated  at  EUR  3  billion  expressed  as 
present value over 2025-2050 relative to the 
baseline,  due 
the 
maintenance  costs  for  road  infrastructure. 
This  is  an  effect  of  a  decrease  in  the 
number  of  trips  relative  to  the  baseline 
(driven by an increase in payload), the shift 
from road-only to intermodal transport and 
the reduction in the  frequency and severity 
of overloading practices. 

in 

Benefits 
to  national  public  authorities, 
estimated at EUR 22.8 billion expressed as 
present value over 2025-2050 relative to the 
baseline,  due  the  implementation  of  the 
one-stop-shop systems at national level and 
thus  the  costs  savings  for  processing  the 
permit  requests,  and  the  reduction  in  the 
number of manual/roadside checks enabled 
by the WIM systems. 

Indirect  benefit  to  society  at  large,  due  to 
the tonnes of CO2 emissions saved, enabled 
by the higher use of ZE HDVs, the shift to 
intermodal transport and the decrease in the 
number  of  trips  (driven  by  the  increased 
payload).  The  reduction  in  the  external 
costs of CO2 emissions is estimated at EUR 
3.5 billion, expressed as present value over 
the  2025-2050  horizon  relative 
the 
baseline. 

to 

to 

intermodal 

transport  and 

Indirect  benefit  to  society  at  large,  due  to 
the tonnes of air pollutant emissions saved, 
enabled by the higher use of ZE HDVs, the 
the 
shift 
decrease  in  the  number  of  trips  (driven  by 
the increased payload). The reduction in the 
external  costs  of  air  pollutant  emissions  is 
estimated  at  EUR  2.1  billion,  expressed  as 
present  value  over  the  2025-2050  horizon 
relative to the baseline. 

Reduction in external costs 
of noise emissions, 
expressed as present value 

EUR 0.7 billion 

Indirect  benefit  to  society  at  large,  due  to 
the  reduction  in  noise  emissions,  enabled 
by the higher use of ZE HDVs, the shift to 

82 

 
 
I. Overview of Benefits (total for all provisions) – Preferred option (PO-B) 

Description 

Amount 

Comments 

over 2025-2050, relative to 
the baseline 

accidents 
expressed 

Reduction  in  external  costs 
(i.e. 
of 
road 
as 
fatalities), 
present  value  over  2025 
2050, 
the 
baseline 

relative 

to 

EUR 0.9 billion 

intermodal transport and the decrease in the 
number  of  trips  (driven  by  the  increased 
payload).  The  reduction  in  the  external 
costs  of  noise  emissions  is  estimated  at 
EUR 0.7 billion, expressed as present value 
over  the  2025-2050  horizon  relative  to  the 
baseline. 

Indirect  benefit  to  society  at  large,  due  to 
the  lives  saved,  enabled  by  the  shift  to 
intermodal transport and the decrease in the 
number  of  trips  (driven  by  the  increased 
payload).  The  reduction  in  the  external 
costs  of  accidents  is  estimated  at  EUR  0.9 
billion, expressed as present value over  the 
2025-2050 horizon relative to the baseline. 

Administrative cost savings related to the ‘one in, one out’ approach* 

Administrative costs 
savings for road transport 
operators, per year relative 
to the baseline 

EUR 71.8 million per year 

Direct  benefit  to  road  transport  operators 
estimated  at  EUR  71.8  million  per  year 
from  the  reduction  in  the  time  needed  to 
prepare  and  submit  the  requests  for  the 
issuance of special permits for the transport 
of 
the 
application  of  the  one-stop-shop  principles 
at  national  level  and  the  digitalisation  of 
documents. Expressed as present value over 
2025-2050  relative  to  the  baseline,  the 
benefits are estimated at EUR 1.2 billion.  

loads,  enabled  by 

indivisible 

II. Overview of costs – Preferred option (PO-B) 

Direct adjustment costs, 
expressed as present value 
over 2025-2050, relative to 
the baseline 

Direct administrative costs, 
expressed as present value 
over 2025-2050, relative to 
the baseline 

Direct enforcement costs 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent  One-off 

Recurrent 

One-off 

Recurrent 

- 

- 

- 

- 

- 

- 

- 

- 

- 

For road transport 
operators: EUR 
2.1 billion 

For national 
public 
authorities: EUR 
102.7 million 

For national 
public 
authorities: 
EUR 4.2 billion 

For the European 
Commission: 
EUR 0.9 million 

For national 
public 
authorities: 
EUR 16.4 
million 

- 

- 

- 

- 

- 

Costs related to the ‘one in, one out’ approach 

83 

 
 
 
 
 
 
II. Overview of costs – Preferred option (PO-B) 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent  One-off 

Recurrent 

One-off 

Recurrent 

Total   

Direct adjustment 
costs, expressed 
as present value 
over 2025-2050, 
relative to the 
baseline  

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

For road transport 
operators:  EUR 
2.1 billion 

- 

- 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option (PO-B) 

Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG 13 (“Take urgent action to 
combat climate change and its 
impacts”) 

1,592.7  thousand  tonnes  of  CO2  emissions 
saved  in  2030  and  54.6  thousand  tonnes  of 
CO2 emissions saved in 2050. 

The reduction in CO2 emissions is driven by 
the  higher  use  of  ZE  HDVs,  the  shift  to 
intermodal transport and the  decrease in the 
number  of  trips  (driven  by  the  increased 
payload).  

SDG 3 (“Ensure healthy lives 
and promote well-being for all 
at all ages”) 

5.1  thousand  tonnes  of  NOx  emissions  saved 
in  2030  and  0.7  thousand  tonnes  of  NOx 
emissions saved in 2050; 1 thousand tonnes of 
Particulate  Matter  emissions  saved  in  2030 
and  0.4  thousand  tonnes  of  NOx  emissions 
saved in 2050. 

The  reduction  in  air  pollution  and  noise 
emissions is driven by the higher use of ZE 
HDVs,  the  shift to intermodal transport and 
the  decrease  in  the  number  of  trips  (driven 
by the increased payload).  

Reduction  in  the  external  costs  of  noise 
emissions,  estimated  at  EUR  0.7  billion 
expressed  as  present  value  over  2025-2050 
relative to the baseline. 

411 lives saved, cumulatively over 2025-2050, 
relative to the baseline.  

The  lives  saved  are  enabled  by  the  shift  to 
intermodal transport and the  decrease in the 
number  of  trips  (driven  by  the  increased 
payload).  

84 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1.  Description of the analytical methods used  

the  baseline  scenario  for 

The  main  model  used  for  developing 
the 
PRIMES-TREMOVE transport model by E3Modelling, a specific module of the PRIMES models. 
The model has a successful record of use in the Commission's energy, transport and climate policy 
assessments. In particular, it has been used for the impact assessments underpinning the “Fit for 55” 
package166,  the  impact  assessments  accompanying  the  2030  Climate  Target  Plan167  and  the  Staff 
Working  Document  accompanying 
the 
Commission’s proposal for a Long Term Strategy169 as well as for the 2020 and 2030 EU’s climate 
and  energy  policy  framework  and  the  impact  assessments  accompanying  the  Road  Safety 
Package170.  

the  Sustainable  and  Smart  Mobility  Strategy168, 

initiative 

this 

is 

For the assessment of the impacts of the policy options an excel-based tool has been developed by 
TML  et  al.171  in  the  context  of  the  impact  assessment  support  study172.  The  tool  draws  on  the 
Standard Cost Model for the assessment of the costs and includes an assessment of the impacts on 
transport activity, costs for transport operators and public authorities, environment and road safety. 
The excel-based tool builds on data from Eurostat, the analysis of stakeholders' feedback and desk 
research undertaken in the context of the impact assessment support study. The proposed measures 
which involve the amendment of the Directive are assumed to be implemented from 2025 onwards, 
so that the assessment has been undertaken for the 2025-2050 period and refers to EU27. Costs and 
benefits are expressed as present value over the 2025-2050 period, using a 3% discount rate. 

PRIMES-TREMOVE model  

The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  demand  for  passengers  and 
freight  transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a  formulation 
based  on  microeconomic  foundation  of  decisions  of  multiple  actors.  Operation,  investment  and 
emission costs, various policy measures, utility factors and congestion are among the drivers that 
influence  the  projections  of  the  model.  The  projections  of  activity,  equipment  (fleet),  usage  of 
equipment, energy consumption and emissions (and other externalities) constitute the set of model 
outputs.  

The  PRIMES-TREMOVE  transport  model  can  therefore  provide  the  quantitative  analysis  for  the 
transport  sector  in  the  EU,  candidate  and  neighbouring  countries  covering  activity,  equipment, 
energy  and  emissions.  The  model  accounts  for  each  country  separately  which  means  that  the 

166 Delivering the European Green Deal | European Commission (europa.eu) 
167 SWD(2020)176 final. 
168 "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0331"  
169 Source: 2050 long-term strategy (europa.eu)   
170 https://transport.ec.europa.eu/news/european-commission-proposes-updated-requirements-driving-licences-and-
better-cross-border-2023-03-01_en  
171 Consortium led by TML, including Ramboll, Panteia, Apollo, LNEC. 
172 The analysis in this section is based on TML et al. (2023), Impact assessment support study for the revision of the 
directive on weights and dimensions of heavy-duty vehicles, and on the analysis of stakeholders' feedback. 

85 

 
 
                                                 
detailed  long-term  outlooks  are  available  both  for  each  country  and  in  aggregate  forms  (e.g.  EU 
level). 

In  the  transport  field,  PRIMES-TREMOVE  is  suitable  for  modelling  soft  measures  (e.g.  eco-
driving, labelling); economic measures (e.g. subsidies and taxes on fuels, vehicles, emissions; ETS 
for transport when linked with  PRIMES;  pricing of congestion and other externalities such as air 
pollution, accidents and noise; measures supporting R&D); regulatory measures (e.g. CO2 emission 
performance  standards  for  new  light  duty  vehicles  and  heavy  duty  vehicles;  EURO  standards  on 
road  transport  vehicles;  technology  standards  for  non-road  transport  technologies,  deployment  of 
Intelligent Transport Systems) and infrastructure policies for alternative fuels (e.g. deployment of 
refuelling/recharging  infrastructure  for  electricity,  hydrogen,  LNG,  CNG).  Used  as  a  module  that 
contributes to the PRIMES energy system model, PRIMES-TREMOVE can show how policies and 
trends  in  the  field  of  transport  contribute  to  economy-wide  trends  in  energy  use  and  emissions. 
Using  data  disaggregated  per  Member  State,  the  model  can  show  differentiated  trends  across 
Member States.  

The  PRIMES-TREMOVE  has  been  developed  and  is  maintained  by  E3Modelling,  based  on,  but 
extending  features  of,  the  open  source  TREMOVE  model  developed  by  the  TREMOVE173 
modelling  community.  Part  of  the  model  (e.g.  the  utility  nested  tree)  was  built  following  the 
TREMOVE model.174 Other parts, like the component on fuel consumption and emissions, follow 
the COPERT model. 

Data inputs 

The  main  data  sources  for  inputs  to  the  PRIMES-TREMOVE  model,  such  as  for  activity  and 
energy consumption, come from EUROSTAT databases and from the Statistical Pocketbook "EU 
transport  in  figures175.  Excise  taxes  are  derived  from  DG  TAXUD  excise  duty  tables.  Other  data 
comes from different sources such as research projects (e.g. TRACCS project) and reports. 

In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010 
and 2015 historical data. Available data on 2020 market shares of different powertrain types have 
also been taken into account. 

Excel-based tool for W&D impact assessment 

The excel-based tool is in essence a cost and emission calculation tool, based on Eurostat data, the 
baseline  projections  developed  with  the  PRIMES-TREMOVE  model,  price  elasticities  and  other 
data,  allowing  a  split  into  different  dimensions.  This  tool was developed to calculate the economic, 

173 Source: "https://www.tmleuven.be/en/navigation/TREMOVE" 
174  Several  model  enhancements  were  made  compared  to  the  standard  TREMOVE  model,  as  for  example:  for  the 
number of  vintages (allowing representation of the choice  of second-hand cars);  for the  technology categories  which 
include vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types, 
such  as  biofuels  (when  they  differ  from  standard  fossil  fuel  technologies),  LPG,  LNG,  hydrogen  and  e-fuels.  In 
addition,  representation  of  infrastructure  for  refuelling  and  recharging  are  among  the  model  refinements,  influencing 
fuel choices. A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; the 
model  considers  that  the  trip  distances  follow  a  distribution  function  with  different  distances  and  frequencies.  The 
inclusion of heterogeneity was found to be of significant influence in the choice of vehicle-fuels especially for vehicles-
fuels with range limitations. 
175 Source: https://ec.europa.eu/transport/facts-fundings/statistics_en  

86 

 
 
                                                 
social  and  environmental  impacts  of  the  policy  measures  and  policy  options  compared  to  the  baseline 
scenario.  

It includes data on transport activity by origin-destination, price elasticities, the vehicle stock and vehicle 
characteristics,  the  payload  by  vehicle  category,  energy  consumption  and  emissions,  fatalities,  vehicle-
related costs and infrastructure maintenance costs. It also includes the calculations of the costs and cost 
savings due to the measures for transport operators and public authorities. The main input sources used are 
provided below. 

Transport activity 

Eurostat176  provides  the  transport  activity  in  terms  of  tonnes,  tonne-kilometres  and  vehicle-
kilometres  for  national  and  international  transport  by  Member  State  (MS).  For  international 
transport,  this  also  includes  the  data  by  origin  and  destination.  This  is  needed  because  several 
policy  measures  relate  to  international  transport  between  Member  States.  The  evolution  of  the 
transport  activity  over  time  draws  on  the  baseline  projections  developed  with  the  PRIMES-
TREMOVE  model.  The  changes  in  transport  activity  (including  the  split  between  internal 
combustion engine, battery electric and fuel cell electric vehicles) due to the policy measures relative to 
the  baseline  are  used  to  calculate  the  impacts  on  energy  consumption  and  emissions,  road  safety, 
transport operators’ costs, maintenance costs for infrastructure, etc. 

Vehicle characteristics and costs  

The  vehicle  characteristics177  used  in  the  excel-based  tool  draw  on  the  New  Mobility  Patterns 
study178, the Maut statistics179 and the baseline scenario developed with the PRIMES-TREMOVE 
model.  This  information  allowed  to  split  the  transport  activity,  including  for  international  and 
domestic  transport,  by  vehicle  type  (internal  combustion  engine,  battery  electric  and  fuel  cell 
electric), weight class and number of axles.  

The  transport-related  costs  and  their  evolution  over  time  draw  on  the  New  Mobility  Patterns 
study180  and  the  baseline  scenario  developed  with  the  PRIMES-TREMOVE  model.  The  vehicle 
cost components considered are the purchase costs, registration costs, ownership costs, maintenance 
costs, insurance costs, labour costs, tolls and fuel costs by vehicle type. Variations in purchase costs 
of  zero-emission  heavy-duty  vehicles  as  compared  to  the  baseline  consequence  of  the  increased 
availability of such zero-emission vehicles (effect of earlier achievement of mass production) that 

176 International tonnes and tonne-kilometres: 
"https://ec.europa.eu/eurostat/databrowser/view/road_go_ia_rc/default/table?lang=en" 
National tonnes and tonne-kilometres: 
"https://ec.europa.eu/eurostat/databrowser/view/road_go_na_tgtt/default/table?lang=en" 
177 Vehicle characteristics refer to the actual average payload and maximum payload, the type of powertrain (internal 
combustion engine, battery electric and fuel cell electric), weight class and number of axles. 
178 European Commission, Directorate-General for Mobility and Transport, Papadimitriou, G., Mellios, G., Borgato, S., 
et al., Study on new mobility patterns in European cities: final report. Task C, Development of a consistent dataset for 
quantitative analysis, Publications Office of the European Union, 2022,   
179 This source has been used to identify the vehicle characteristics of international transport. Germany is considered a 
good proxy for EU27 due to the exports/imports and transit traffic. 
180 European Commission, Directorate-General for Mobility and Transport, Papadimitriou, G., Mellios, G., Borgato, S., 
et al., Study on new mobility patterns in European cities: final report. Task C, Development of a consistent dataset for 
quantitative analysis, Publications Office of the European Union, 2022,   

87 

 
 
                                                 
may  occur  as  a  consequence  of  the  policy  measures  assessed  in  this  Impact  Assessment  are  not 
considered.     

Energy intensity, emissions intensity and external costs (including for noise) 

The energy intensity and  CO2  emissions intensity  (for road, rail and inland  navigation), and their 
evolution over time, draw on the baseline scenario developed with the PRIMES-TREMOVE model. 

For  NOx  and  PM2.5,  the  EEA/EMEP  emission  inventory  guidebook  for  road  transport  was  used 
(Tier 2 emission factors for heavy duty vehicles, EURO VI D/E), adjusted to match the NOx and 
PM2.5 emissions from the baseline scenario developed with the PRIMES-TREMOVE model. For 
zero-emission vehicles, all exhaust emissions are set to zero. 

To calculate the external costs of CO2 emissions, air pollution emissions and noise, the unit costs 
from the Handbook on external costs of transport181 have been used (expressed in 2022 prices). For 
noise,  the  unit  value  corresponding  to  battery  electric  vehicles  was  assumed  to  be  half  of  that  of 
diesel vehicles. 

Road safety  

The CARE database182 was used for the total number of fatalities in the base year. It was also used to 
identify  the  share  of  fatalities  from  accidents  involving  HGVs.  The  evolution  of  the  number  of 
fatalities over time draws on the baseline scenario developed with the PRIMES-TREMOVE model. 

The  CARE  database  does  not  allow  to  split  the  fatalities  from  accidents  in  which  EMS  are 
involved. The difference in risk per vehicle-kilometre for EMS was estimated based on a literature 
review, covering predictive engineering methods183 (suggesting an increase by 10%) and post-hoc 
statistical  methods  (suggesting  a  21%  decrease  in  risk).  The  mid-point  of  this  range  (a  6% 
reduction, or a ‘risk multiplier’ of 0.94) was selected for the analysis. 

To monetise the external costs of fatalities, the unit costs at Member State level from the Handbook on 
external costs of transport184 have been used. At EU level, the unit cost per fatality is estimated at 
EUR 3.9 million in 2022 prices.  

Price elasticities 

To calculate the changes in the number of tonnes transported due to the policy measures, the following 
price elasticities were used.  

181  Essen,  H.  et  al.  (2020),  Handbook  on  the  external  costs  of  transport:  version  2019  –  1.1,  Publications  Office, 
available at: https://data.europa.eu/doi/10.2832/51388. Note: To transform the unit costs from the Handbook, which are 
expressed in 2016 prices, in 2022 prices the HICP (PRC_HICP_AIND) from Eurostat has been used.  
182 CARE database (europa.eu) 
183 Knight, I., et al. (2008). Longer and/or longer and heavier goods vehicles (LHVs)  - a study of the likely effects if 
permitted in the UK. Crowthorne: TRL Published Project Report PPR 285. 
184  Essen,  H.  et  al.  (2020),  Handbook  on  the  external  costs  of  transport:  version  2019  –  1.1,  Publications  Office, 
available at:   

88 

 
 
                                                 
 Table 14: Price elasticities used to estimate the changes in the number of tonnes transported 
Elasticity 
Price elasticity of demand for road transport185 
Cross price elasticity of demand for rail transport186 
Cross price elasticity of demand for inland navigation187 
Cross price elasticity of demand for different road vehicle categories188 
Rebound effects 
Source : TML et al. (2023), impact assessment support study  

Value 
-0.3 
0.5 
0.2 
-0.1 
-0.1 

Price elasticity of demand for road transport: This elasticity was used to calculate the changes in tonnes 
transported by road, relative to the baseline, due to changes in the transport costs per unit of transport. This 
elasticity is also used to assess the impact on the transport activity by internal combustion engine and zero-
emission vehicles.   

Cross price elasticity of demand for rail transport: This elasticity is used to assess the impact of a possible 
shift from rail to road transport, relative to the baseline, when road transport becomes more cost efficient. 
The elasticity is used only for those origin-destination pairs that have a rail connection.  

Cross price elasticity of demand for inland navigation: This elasticity is used to assess the impact of a 
possible  shift  from  inland  navigation  to  road  transport,  relative  to  the  baseline,  when  road  transport 
becomes more cost efficient. The elasticity is used for transport in and between EU countries where inland 
navigation plays a significant role.  

Cross  price  elasticity  of  demand  for  different  road  vehicle  categories:  This  elasticity  is  used  to 
assess the impact of a shift between road vehicle categories, more specifically from trucks below 32 
tonnes and 4 axles to trucks above 32 tonnes and 4 axles.  

Rebound effects: This price elasticity takes into account rebound effects due to the use of more energy-
efficient vehicles, with lower operation costs.   

Building on the changes in tonnes relative to the baseline, the changes in the transport activity in tonne-
kilometres and vehicle-kilometres is subsequently calculated, taking into account the annual mileage and 
the average payload. 

Infrastructure maintenance costs 

The  infrastructure  maintenance  costs  in  the  baseline  scenario  draw  on  data  from  the  OECD 
database189.  The  infrastructure  maintenance  costs  from  OECD  cover  spending  on  preservation  of  the 

185 De Jong et al (2010). Price sensitivity of European road freight transport - towards a better understanding of existing 
results. A report for Transport & Environment. The Hague: Significance. 
186 Rijkswaterstaat (2020). DP07 - Eindanalyse BasGoed 5.0. Rijswijk: Rijkswaterstaat 
187 Rijkswaterstaat (2020). DP07 - Eindanalyse BasGoed 5.0. Rijswijk: Rijkswaterstaat 
188 Rijkswaterstaat (2020). DP07 - Eindanalyse BasGoed 5.0. Rijswijk: Rijkswaterstaat 
189 OECD (2023), Infrastructure maintenance (indicator). doi: 10.1787/c73dc965-en  (Accessed on 06 April 2023) 

89 

 
 
                                                 
existing transport network.  It only  covers  maintenance  expenditures  by  public  authorities. Heavy  duty 
vehicles are the main responsible for road maintenance costs190.  

The  impact  on  the  infrastructure  of  the  different  policy  measures  is  presented  as  part  of  the 
adjustment  costs  for  public  authorities  in  section  3  of  Annex  4,  with  a  distinction  between 
maintenance costs and reinforcement costs. 

The main damage mechanisms directly  from  heavy traffic are the damage target  fatigue  cracking 
and secondary rutting (COST 334, 2001). How aggressive a vehicle is in terms of pavement wear 
was  determined  based  on  the  ’standard  axles’  approach  that  converts  axle  weights  and 
configurations  to  the  equivalent  number  of  standard  10  tonne  axles.  Once  the  aggressiveness  of 
each group of axles has been calculated, the overall aggressiveness of a truck can be obtained by 
adding  the  number  of  standard  axles  represented  by  each  individual  group  of  axles  fitted  to  the 
vehicle under consideration (OECD ITF, 2011). This was calculated for a range of baseline vehicle 
configurations and for some modified vehicles (e.g. plus 2 tonnes GVW and plus 1 tonne max axle 
weight), needed for the assessment of the policy measures and options. 

The  impact  on  pavement  wear  depends  not  only  on  the  weight  per  axle  but  also  on  the  type  of 
pavement. Thus, three road factors were assumed for each vehicle type, corresponding to the three 
main types of pavement: flexible, semi-rigid and rigid.  

According to the load per axle, the damage induced to pavement will increase according to a power 
function, depending on the type of pavement. The individual aggressiveness of an axle of X tonnes 
is  assessed  as  an  equivalent  number  of  10  tonne  standard  axles  (Neq)  by  using  the  formula191: 
Neq=(X/10)^a.  The  exponent  a  is  4,  6  and  12  for  flexible,  semi-rigid  and  rigid  pavement 
respectively.  The  lifetime  of  a  pavement  structure,  for  a  given  traffic  history,  is  inversely 
proportional  to  the  number  of  equivalent  standard  axles192,193.  The  road  wear  factors  by  type  of 
pavement in the baseline scenario are provided in Table 15. 

Table 15: Road wear factors by type of pavement in the baseline scenario 

Type of pavement 

Flexible 

Semi-rigid 

Rigid 
Source : TML & Ramboll et al. (2023), impact assessment support study  

Value 

0.75 

0.32 

0.03 

The road wear factors are used in the calculation of the infrastructure maintenance costs, by taking 
into account the share by type of pavement in each country. As the results are directly related to the 

190 Low, J.M. et al. (2023), The hidden cost of road maintenance due to the increased weight of battery and hydrogen 
trucks  and  buses  -  a  perspective,  Clean  Technologies  and  Environmental  Policy  volume  25,  pages  757–770.  The 
analysis  indicates  that  vehicles  under  7.5  tonnes  have  a  negligible  impact  on  road  wear.  It  is  assumed  that  90.5%  of 
road wear is attributed to HGVs (of which 58.7% to HGVs above 32 tonnes), 7.5% to heavy buses, and 2% to cars and 
other vehicles. 
191 AASHTO (1993), Guide for design of pavement structures. 
192 COST334 (2001), Effects of wide single tyres and dual tyres. 
193 PIARC (2022), Overweight vehicles: impact on road infrastructure and safety. 

90 

 
 
                                                 
type  of  pavement,  for  the  EU  countries  where  this  information  was  not  available194,  the  average 
shares by pavement type at EU level were used as proxy.   

To calculate the infrastructure maintenance costs in the baseline and for each policy measure and 
option,  the  values  of  road  wear  are  multiplied  by  the  transport  activity  expressed  in  vehicle-
kilometres and by the unit maintenance costs per vehicle-kilometre.  

The elements determining the variation in axle weight, are the extra axle weight directly granted by 
some policy measures (PMc1 and PM1), as well as the changes in the average payload that are a 
consequence  of  the  improvement  in  technology  leading  to  the  reduction  of  the  weight  of  the 
batteries  over  time  and  the  lower  number  of  trips  required  for  transporting  the  same  amount  of 
cargo with less vehicles. The impact of those variations in axle weight  are measured by applying 
the relevant road wear factors (presented in Table 15 above) taking into account the share by type 
of  pavement  in  each  country  (flexible,  semi-rigid  and  rigid)  as  provided  by  public  sources  of 
information were available. 

Infrastructure reinforcement and upgrading costs 

The potential need for reinforcement of pavements or bridges and infrastructure upgrading due to 
the  authorisation  of  heavier  and  longer  HDVs  is  also  considered.  In  particular,  for  PM3 
(authorisation  of  EMS  in  the  TEN-T  network  conditioned  to  be  ZEV  or  involved  in  intermodal 
transport) based on the experience and infrastructure assessments carried out prior to allowing EMS 
like  in  Sweden,  Germany  and  Denmark.  These  costs  consist  of  inspection  costs  to  determine  the 
needs  for  upgrading  or  for  limitation  of  access  (e.g.  in  PMc2)  and  costs  for  the  upgrading  of  the 
infrastructure. The type of investments necessary for PM3, are related to the extra length of these 
vehicles  and  the  need  to  ensure  their  manoeuvrability,  visibility  of  these  vehicles,  as  well  as  the 
provision of adequate parking space. One-off adjustment costs for the reinforcement of bridges are 
also considered.  

The  infrastructure  costs  linked  to  the  current  maximum  weights  and  dimensions  authorised  in 
national and international transport are considered as part of the baseline. As a consequence, some 
policy  measures  such  as  PMc4  (authorisation  of  44  tonnes  HDVs  and  EMS  among  the  Member 
States that already allow the m in national transport) will not generate adjustment costs linked to the 
infrastructure. Similarly, the increase in maximum weight below the limits currently allowed by the 
Weights  and  Dimensions  Directive  (i.e.  42  tonnes  for  ZEVs,  44  tonnes  for  intermodal  and  46 
tonnes for ZEV involved in intermodal transport) are considered as part of the baseline. 

2.  Baseline scenario 

In  order  to  reflect  the  fundamental  socio-economic,  technological  and  policy  developments,  the 
Commission  prepares  periodically  an  EU  Reference  Scenario  on  energy,  transport  and  GHG 
emissions.  The  socio-economic  and  technological  developments  used  for  developing  the  baseline 
scenario  for  this  impact  assessment  build  on  the  latest  “EU  Reference  scenario  2020” 

194 Data was available for Austria, Germany, Denmark, Spain, Finland, France and Portugal. 

91 

 
 
                                                 
(REF2020)195.  The  same  assumptions  have  been  used  in  the  policy  scenarios  underpinning  the 
impact assessments accompanying the “Fit for 55” package196.  

Main assumptions of the Baseline scenario 

The main assumptions related to economic development, international energy prices and technologies are 
described below. 

Economic assumptions  

The modelling work is based on socio-economic assumptions describing the expected evolution of the 
European society. Long-term projections on population dynamics and economic activity form part of the 
input  to  the  model  and  are  used  to  estimate  transport  activity,  particularly  relevant  for  this  impact 
assessment.  
Population projections from Eurostat197  are used to  estimate the  evolution  of the  European  population, 
which is expected to change little in total number in the coming decades. The GDP growth projections are 
from the Ageing Report 2021198 by the Directorate General for Economic and Financial Affairs, which 
are based on the same population growth assumptions. 

Table 16: Projected population and GDP growth per Member State 

Population 

GDP growth 

EU27 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

2020 
447.7 

8.90 

11.51 

6.95 

4.06 

0.89 

10.69 

5.81 

1.33 

5.53 

67.20 

83.14 

10.70 

9.77 

4.97 

60.29 

1.91 

2.79 

0.63 

2025 
449.3 

9.03 

11.66 

6.69 

3.94 

0.93 

10.79 

5.88 

1.32 

5.54 

68.04 

83.48 

10.51 

9.70 

5.27 

60.09 

1.82 

2.71 

0.66 

2030 
449.1 

9.15 

11.76 

6.45 

3.83 

0.96 

10.76 

5.96 

1.31 

5.52 

68.75 

83.45 

10.30 

9.62 

5.50 

59.94 

1.71 

2.58 

0.69 

2020-‘25 
0.9% 

2026-‘30 
1.1% 

0.9% 

0.8% 

0.7% 

0.2% 

0.7% 

1.6% 

2.0% 

2.2% 

0.6% 

0.7% 

0.8% 

0.7% 

1.8% 

2.0% 

0.3% 

1.4% 

1.7% 

1.7% 

1.2% 

0.8% 

1.3% 

0.6% 

1.7% 

2.0% 

1.7% 

2.6% 

1.2% 

1.0% 

0.7% 

0.6% 

2.6% 

1.7% 

0.3% 

1.9% 

1.5% 

2.0% 

195 EU Reference Scenario 2020 (europa.eu) 
196 Policy scenarios for delivering the European Green Deal (europa.eu) 
197 EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu)   
198 The 2021 Ageing Report : Underlying assumptions and projection methodologies The 2021 Ageing Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)   

92 

 
 
 
  
                                                 
Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Population 

GDP growth 

2020 
0.51 

17.40 

37.94 

10.29 

19.28 

5.46 

2.10 

47.32 

10.32 

2025 
0.56 

17.75 

37.57 

10.22 

18.51 

5.47 

2.11 

48.31 

10.75 

2030 
0.59 

17.97 

37.02 

10.09 

17.81 

5.44 

2.11 

48.75 

11.10 

2020-‘25 
2.7% 

2026-‘30 
4.1% 

0.7% 

2.1% 

0.8% 

2.7% 

1.1% 

2.1% 

0.9% 

1.4% 

0.7% 

2.4% 

0.8% 

3.0% 

1.7% 

2.4% 

1.6% 

2.2% 

Beyond the update of the population and growth assumptions, an update of the projections on the sectoral 
composition  of  GDP  was  also  carried  out  using  the  GEM-E3  computable  general  equilibrium  model. 
These projections take into account the potential medium- to long-term impacts of the COVID-19 crisis 
on  the  structure  of  the  economy,  even  though  there  are  inherent  uncertainties  related  to  its  eventual 
impacts.  Overall,  conservative  assumptions  were  made  regarding  the  medium-term  impacts  of  the 
pandemic  on  the  re-localisation  of  global  value  chains,  teleworking  and  teleconferencing  and  global 
tourism. 

International energy prices assumptions  

Alongside  socio-economic  projections,  transport  modelling  requires  projections  of  international 
fuel prices. The table below shows the oil prices assumptions of the baseline and policy options of 
this impact assessment, that draw on the modelling underpinning the REPowerEU package199.  

Table 17: Oil prices assumptions  
Oil 

2015 

in $'15 per boe 

in €'15 per boe 
Technology assumptions 

2020 

2030 

2040 

2050 

52.3 

47.2 

39.8 

35.8 

92.1 

83.0 

97.4 

87.8 

117.9 

106.3 

Modelling scenarios is highly dependent on the assumptions on the development of technologies, both in 
terms of performance and costs. For the purpose of the impact assessments related to the “Climate Target 
Plan”  and  the  “Fit  for  55”  policy  package,  these  assumptions  have  been  updated  based  on  a  rigorous 
literature  review  carried  out  by  external  consultants  in  collaboration  with  the  JRC.  Continuing  the 
approach  adopted  in  the  long-term  strategy  in  2018,  the  Commission  consulted  on  the  technology 
assumption  with  stakeholders  in  2019.  In  particular,  the  technology  database  of  the  PRIMES  and 
PRIMES-TREMOVE  models  (together  with  GAINS,  GLOBIOM,  and  CAPRI)  benefited  from  a 
dedicated consultation workshop held on 11th November 2019. EU Member States representatives also 
had the opportunity to comment on the costs elements during a workshop held on 25th November 2019. 
The updated technology assumptions are published together with the EU Reference Scenario 2020200. The 
same assumptions have been used in the context of this impact assessment. 

199 SWD(2022)230 final. 
200 EU Reference Scenario 2020 (europa.eu) 

93 

 
 
 
  
                                                 
Policies in the Baseline scenario  

Building on REF2020, the baseline has been designed to include the initiatives of the ‘Fit for 55’ 
package  proposed  by  the  Commission  on  14 July  2021201  and  the  initiatives  of  the  RePowerEU 
package proposed by the Commission on 18 May 2022202. It also reflects the Commission proposal 
of 2023 for a revision of the Regulation on CO2 emission standards for heavy-duty vehicles203. The 
baseline  scenario  assumes  no  further  EU  level  intervention  beyond  the  current  Weights  and 
Dimensions Directive. 

The  baseline  also  incorporates  foresight  megatrends204  and  developments  captured  in  the  2022 
Strategic  Foresight  Report205.  Among  others,  it  captures  the  trend  of  increasing  demand  for 
transport as population and living standards grow as well as the links between the digital and green 
transition.  In  particular,  the  projected  transport  activity  draws  on  the  long-term  population 
projections  from  Eurostat  and  GDP  growth  from  the  Ageing  Report  2021206  by  the  Directorate 
General for Economic and Financial Affairs. 

The  baseline  scenario  does  not  consider  the  forthcoming  revision  of  the  Combined  Transport 
Directive, the rail capacity initiative and the CountEmissions EU initiative. It should be noted that 
including the proposed revision of the Combined Transport Directive in the baseline would lead to 
higher  uptake  of  intermodal  transport.  Thus,  the  policy  options  would  result  in  somewhat  lower 
reduction  in  external  costs  of  transport  relative  to  the  baseline,  and  thus  somewhat  lower  net 
benefits. This is however not expected to result in a change in the ranking of the policy options. 

Baseline scenario results 

In  the  baseline  scenario,  EU  transport  activity  is  projected  to  grow  post-2020,  following  the 
recovery from the COVID pandemic.  Road transport would maintain its dominant role within the 
EU  by  2050.  Buses  activity  (expressed  in  passenger-kilometres)  is  projected  to  grow  by  13% 
between 2015 and 2030 (42% for 2015-2050). For freight, heavy goods vehicles activity (expressed 
in tonne-kilometres) is projected to go up by 30% by 2030 relative to 2015 (57% for 2015-2050). 
The activity of heavy goods vehicles above 32 tonnes would grow at slightly slower pace, by 27% 
by  2030  relative  to  2015  (47%  for  2015-2050).  Rail  transport  activity  is  projected  to  grow 
significantly faster than for road, driven in particular by the completion of the TEN-T core network 
by  2030  and  of  the  comprehensive  network  by  2050,  supported  by  the  CEF,  Cohesion  Fund  and 
ERDF funding, but  also  by measures of the ‘Fit for 55’ package that increase to  some extent the 
competitiveness of rail relative to road and air transport. Passenger rail activity is projected to go up 

201 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en 
202 "https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131" 
203 “https://climate.ec.europa.eu/eu-action/transport-emissions/road-transport-reducing-co2-emissions-
vehicles/reducing-co2-emissions-heavy-duty-vehicles_en#raising-our-ambition” 
204 "https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en" \l "explore" 
205 COM(2022) 289 final of 29 June 2022. 
206  The  2021  Ageing  Report :  Underlying  assumptions  and  projection  methodologies  The  2021  Ageing  Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)   

94 

 
 
                                                 
by 24% by 2030 relative to 2015 (67% for 2015-2050). Freight rail traffic would increase by 42% 
by 2030 relative to 2015 (91% for 2015-2050) 207.  

The share of zero-emission vehicles in the total heavy goods vehicles stock is projected at 5% in 2030, 
going up to 30% in 2040 and 71% in 2050 in the baseline scenario. In terms of tonne-kilometres, zero-
emission heavy goods vehicles are projected to account for 136.8 billion tonne-kilometres in 2030 (around 
7% of total tonne-kilometres by heavy goods vehicles), 1,060.7 billion tonne-kilometres in 2040 (around 
48% of the total tonne-kilometres by heavy goods vehicles) and 2,147.3 billion tonne-kilometres in 2050 
(around 88% of the total tonne-kilometres by heavy goods vehicles). 

Congestion costs would increase by about 14% by 2030 and 32% by 2050, relative to 2015. Congestion 
on  the  inter-urban  network  would  be  the  result  of  growing  freight  transport  activity  along  specific 
corridors, in particular where these corridors cross urban areas with heavy local traffic.  

CO2  emissions  from  transport208  are  projected  to  be  26%  lower  by  2030  compared  to  2015,  and 
94% lower by 2050. The baseline scenario shows that the emission reductions from  the transport 
sector  would  contribute  towards  the  ambition  of  at  least  55%  emission  reductions  by  2030  and 
climate neutrality by 2050, while relying to a significant extent on technological solutions (i.e. the 
uptake  of  low-  and  zero-emission  vehicles  and  of  renewable  and  low  carbon  fuels)  and  carbon 
pricing.  This  would  depart  from  the  balanced  approach  underpinning  the  impact  assessments 
accompanying  the  ‘Fit  for  55’  package  and  the  staff  working  document  accompanying  the 
REPowerEU  initiatives209,  showing  a  combined  approach  of  carbon  pricing  instruments  and 
regulatory-based measures to deliver on the increased climate ambition210.  

NOx emissions are projected to go down by 56% between 2015 and 2030 (87% by 2050), mainly 
driven  by  the  electrification  of  the  road  transport  and  in  particular  of  the  light  duty  vehicles 
segment. The decline in particulate matter (PM2.5) would be slightly lower by 2030 at 53% relative 
to 2015 (91% by 2050) 211.  

207 The Sustainable and Smart Mobility Strategy uses 2015 as the base year for the milestones on the growth in rail and 
waterborne  transport  activity.  In  addition,  due  to  the  COVID-19  pandemics,  the  lockdowns  and  all  the  consequent 
effects on the transport sector do not qualify 2020 as representative base year. For these reasons, 2015 has also been 
selected as a base year for showing the growth in road transport activity. Using 1995 as a base year the growth in heavy 
goods vehicles activity (expressed in tonne-kilometres) is projected at 79% by 2030 relative to 1995 (116% for 1995-
2050) in the baseline scenario. For buses, the growth for 1995-2030 is projected at 17% (47% for 1995-2050). 
208  Including international aviation but excluding international maritime. 
209  SWD(2022) 230 final of 18 May 2022. 
210  The scenarios underpinning the impact assessments accompanying the ‘Fit for 55’ initiatives and the staff working 
document accompanying the REPowerEU initiatives incorporated a broader range of policies (including this initiative) 
that were represented in a stylised way ahead of the actual proposals, to show the delivery of at least 55% emissions 
reduction  target  by  2030  and to  account  for  the  interaction  with  the  forthcoming  initiatives.  Therefore,  this  initiative 
contributes towards the at least 55% emissions reductions target by 2030 and achieving climate neutrality by 2050. 
211  As  explained  in  section  1  of  Annex  4,  the  baseline  projections  are  quantified  with  the  help  of  the  PRIMES-
TREMOVE  model.  The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  demand  for  passengers  and 
freight  transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a  formulation  based  on 
microeconomic  foundation  of  decisions  of  multiple  actors.  Operation,  investment  and  emission  costs,  various  policy 
measures,  utility  factors  and  congestion  are  among  the  drivers  that  influence  the  projections  of  the  model.  The 
projections  of  activity,  equipment  (fleet),  usage  of  equipment,  energy  consumption  and  emissions  (and  other 
externalities) constitute the set of model outputs.  

95 

 
 
                                                 
Heavy  duty  vehicles  are  the  main  responsible  for  road  maintenance  costs.  The  road  maintenance 
costs attributed to HGVs above 32 tonnes are projected to increase by 11% by 2030 relative to 2015 
(36% increase during 2015-2050). Table 18 provides the projected evolution of maintenance costs 
for road infrastructure attributed to HGVs above 32 tonnes in the baseline, by Member State.  

Table 18: Maintenance costs for road infrastructure attributed to HGVs above 32 tonnes (EUR million) 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
ES 
FI 
FR 
EL 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU27 
Source : TML et al. (2023), impact assessment support study  

2015 
            406  
            268  
            284  
              58  
            402  
         2,126  
            638  
              71  
              28  
            299  
         1,526  
            104  
            144  
            166  
              48  
         5,325  
              93  
              20  
            102  
                8  
            334  
            244  
            104  
            276  
            695  
              59  
            118  
       13,947  

2025 
            489  
            109  
            216  
              82  
            546  
         3,958  
            700  
            112  
              27  
            416  
         1,355  
            115  
            147  
            239  
              45  
         3,918  
              86  
              24  
            160  
                9  
            370  
            311  
            115  
            305  
            635  
              86  
            143  
       14,717  

2030 
            514  
            114  
            227  
              86  
            574  
         4,162  
            736  
            118  
              28  
            438  
         1,425  
            121  
            155  
            251  
              48  
         4,120  
              91  
              25  
            168  
                9  
            389  
            327  
            121  
            321  
            667  
              90  
            150  
       15,476  

2040 
            568  
            126  
            251  
              95  
            635  
         4,602  
            814  
            130  
              31  
            484  
         1,576  
            134  
            171  
            278  
              53  
         4,555  
            101  
              28  
            186  
              10  
            430  
            362  
            134  
            355  
            738  
            100  
            166  
       17,112  

2050 
            628  
            140  
            277  
            105  
            702  
         5,089  
            900  
            144  
              34  
            535  
         1,742  
            148  
            190  
            307  
              58  
         5,037  
            111  
              31  
            206  
              11  
            475  
            400  
            148  
            393  
            816  
            110  
            184  
       18,921  

The baseline scenario reflects the projected higher energy prices driven by the Russian invasion of 
Ukraine212. Beyond this aspect, it was however not possible to quantify the impact of the Russian 
invasion of Ukraine in the context of the baseline scenario, as there is large uncertainty with respect 
to its impacts, in particular for the medium to long term. While its impact is felt in terms of trade 
(e.g. grain, bulk fertilizers and hydrocarbons) and in certain geographical areas, the impact on the 
baseline of this initiative is expected to be relatively limited. 

3.  Impacts of policy measure in terms of costs and cost savings 

This section explains the inputs used and provides the assessment of costs of the policy measures included 
in  the  policy  options.  The  estimates  take  into  account  the  synergies  between  the  policy  measures 

212  SWD(2022) 230 final of 18 May 2022.  

96 

 
 
 
                                                 
included  in  the  policy  options.  The  estimation  of  the  costs  draws  on  the  impact  assessment  support 
study213, including  input  collected  through  desk  research  and  stakeholder interviews  during the impact 
assessment process. 

PMc1: Allow for extra weight and extra length to ZE heavy  goods vehicles (HGVs) and 2-axle 
rigid buses 

PMc1  provides  for  increasing  the  maximum  gross  vehicle  combination  weight  (GVCW)  up  to  a 
maximum of 2 tonnes214, the maximum axle weight up to a maximum of 1 tonne on the drive axle 
or a bogie containing a drive axle215 and the maximum length of the vehicle combination up to 90 
cm.  The  weight  allowance  for  ZE  HGVs  also  applies  to  2-axle  rigid  buses  and  to  any  vehicle 
combination  equipped  with  zero  emission  technologies  (i.e.  motor  vehicle,  semi/trailers  and 
dollies).  This  accounts  for  technological  developments,  such  as  electric  trailers  equipped  with 
auxiliary motors and batteries which reduce the demand of energy from  the motor vehicle and/or 
other power elements, such as cooling units of reefers. However, this measure offers no support for 
using an e-trailer to hybridize a non-zero-emission vehicle. 

The purpose of this measure is  to  compensate for the weight  and the size of ZE powertrains  (i.e. 
weight  of  electric  batteries  and  space  for  hydrogen  tanks)  thus  preventing  the  loss  of  payload 
capacity  and/or  range  in  comparison  with  diesel  vehicles.  In  other  words,  the  extra  weight  and 
dimensions  should  be  allocated  to  the  powertrains  and  not  to  expand  the  payload.  As  a 
consequence, the effect of this measure is expected to fade out over time with technology evolution 
as the weight of batteries is expected to decrease and, therefore, the ZE powertrains become of a 
similar  weight  to  the  equivalent  diesel  powertrains.  Similarly,  the  need  for  extra  length  will  be 
satisfied by the progressive uptake of elongated cabs concepts, for which de facto no length limit 
applies.  

Adjustment cost savings for transport operators 

Battery Electric Vehicles (BEV). The energy per kilogram and per cubic meter of batteries is much 
lower  than  that  of  diesel  engines.  Based  on  current  energy  density  of  batteries  (i.e.  180-250 
Wh/kg)216, 44 tonne BEV have an equivalent range with that of 40 tonne diesel vehicles217.  

According  to  the  data  from  the  study  on  New  Mobility  Patterns  in  European  Cities218,  a  current 
diesel 40 tonne articulated vehicle has a maximum payload of 25.3 tonnes and an average payload 
of  10.1  tonnes  (i.e.  taking  into  account  empty  trips).  Taking  into  account  the  current  density  of 
batteries,  BEV  have  a  maximum  payload  of  23.3  tonnes  and  an  average  payload  of  9.3  tonnes. 

213  TML  &  Ramboll  et  al.  (2023),  Impact  assessment  support  study  for  the  revision  of  the  directive  on  weights  and 
dimensions of heavy-duty vehicles.  
214  Currently  the  W&D  Directive  allows  an  additional  GVW  of  2  tonnes  for  certain  ZE  HDVs  which  under  PMc1 
would be increased by another 2 tonnes resulting in a potential increase of GVW by 4 tonnes. 2-axle rigid buses do not 
enjoy any derogation, thus their maximum GVW would only increase by 2 tonnes. 
215 Currently the W&D Directive allows a maximum authorised axle weight on the driving axle of 11.5 tonnes. 
216 Ballard (2022), Fuel Cell Trucks / Weights & Dimensions Directive and ICCT (2021). 
217  The  survey  undertaken  in  the  context  of  the  impact  assessment  support  study  shows  that  the  OEMs  request  an 
additional 4 tonnes of Gross Vehicle Weight (GVW) for ZEVs compared to diesel vehicles (an increase from 40 tonnes 
for diesel to 44 tonnes for ZEV), an extra tonne on the drive axle (from 11.5 to 12.5 tonnes), and an extra 1.5 meters in 
length to provide long-haul heavy trucks with equivalent range capabilities. 
218 Sustainable transport Studies (europa.eu) 

97 

 
 
                                                 
PMc1 will increase the payload of a BEV up to the same level as for a diesel vehicle, estimated at 
8.6% in terms of maximum payload or average payload (Table 19).  

Table 19: Effect of PMc1 on the payload of BEV HGVs in 2025 
BEV HGVs 

Diesel HGVs 

Maximum payload (tonnes) 
Average payload (tonnes) 
Source : TML et al. (2023), impact assessment support study  

25.3 
10.1 

23.3 
9.3 

BEV 
under PMc1 

Payload increase 
New 
vehicle 

Fleet 

25.3 
10.1 

8.6% 
8.6% 

3.4% 
3.4% 

As  explained  above,  a  40-tonne  tractor-semitrailer  combination  has  a  maximum  payload  of  25.3 
tonnes, with a total volume of 90m³ and a floor space of 34m². Cargo with a higher mass density 
than 279 kg/m³ is weight constrained. Based on the evidence collected in the context of the impact 
assessment support study, around 40% of the loaded trips are estimated to be  weight constrained. 
Therefore,  the  improvements  for  the  fleet  are  estimated  at  3.4%  for  the  maximum  and  average 
payload.  

However,  as  technology  progresses,  propulsion  and  energy  storage  systems  will  become  lighter. 
Energy  density  of  batteries  is  expected  to  increase  to  500  Wh/kg  by  2030  and  to  800  Wh/kg  by 
2050219.  Thus,  by  2035  new  vehicles  entering  the  market  would  be  equivalent  to  those  permitted 
now (2 tonnes extra for ZEV).  

From 2035 onwards, the incentive provided by this policy measure in terms of compensating for the 
need  of  heavier  batteries  is  compensated  by  technological  evolution  and  no  additional  benefit  is 
foreseen for new vehicles. However, those vehicles  that had already entered  the market  at  higher 
weights would continue to circulate until 2045220.  

Fuel cell electric vehicles (FCEVs). The energy stored per kilogram for hydrogen is higher than for 
diesel but hydrogen needs to be stored in a highly compressed and very cold state to maximise the 
energy per unit volume. The need for cooling and compression equipment adds to the weight and 
space requirements of FCEVs. Ballard (2022)221 shows that with the current state of the technology, 
FCEV  can  already  achieve  the  same  performance  as  diesel  vehicles  within  the  current  2  tonne 
allowance. However, they require more space for the hydrogen storage tanks. The 90 cm additional 
length included under PMc1 would compensate for that. 

Based on the current semitrailer length of 13.6m, the load capacity increase provided by PMc1 for 
FCEV  is  estimated  at  7.1%  per  vehicle  (see  Table  20).  This  policy  measure  will  only  benefit 
volume constrained cargo. Based on the evidence collected in the context of the impact assessment 
support study, around 60% of the loaded trips are estimated to be volume constrained.   

Table 20: Effect of PMc1 on the payload of FCEVs in 2025 

Diesel HGVs 

FCEV HGVs 

FCEV 

Payload increase 

219  Hill,  N.,  Clarke,  D.,  Blair,  L.  and  Menadue,  H.,  Circular  Economy  Perspectives  for  the  Management  of  Batteries 
used in Electric Vehicles, Publications Office  of the European Union, Luxembourg, 2019, ISBN 978-92-76-10938-9, 
doi:10.2760/608912, JRC117790. 
220 The lifetime of BEVs is assumed to be 10 years, higher than that of diesel vehicles (which is around 7 years) due to 
the lower maintenance requirements and higher capital cost. 
221 Ballard (2022), Fuel Cell Trucks / Weights & Dimensions Directive. 

98 

 
 
  
 
  
                                                 
Length 
13.6m 
Source : TML et al. (2023), impact assessment support study  

12.7m 

under PMc1 

New vehicle 

Fleet 

13.6m 

7.1% 

4.3% 

The  elongated  cab  design  already  allows  for  additional  length,  as  long  as  safety,  comfort, 
aerodynamics,  and  turning  criteria  are  met  in  line  with  Regulation  (EU)  2021/535.  However,  a 
limited number of such vehicles are on the market and day-cab trucks are less likely to be equipped 
with elongated cabs (which are mainly used as sleeping cabs) in the short term. It is estimated that 
by  2025  10%  of  new  tractors  will  have  such  design,  going  up  to  100%  by  2035.  Assuming  a  10 
year lifetime for a FCEV, no vehicles making use of the length derogation will be part of the fleet 
by 2045.  

The  increase  in  payload  with  respect  to  the  baseline  for  BEV  and  FCEV  HGVs  leads  to  lower 
operation costs for these vehicles and a higher uptake.  

Operation  costs.  For  BEV  HGVs,  the  increase  in  payload  of  2  tonnes  is  estimated  to  lead  to  an 
increase in the energy consumption per vehicle kilometre estimated at 0.3% relative to the baseline 
in 2025.  For FCEV HGVs, the increase in lengths of 90 cm is estimated to lead to an increase in 
energy consumption per vehicle kilometre of 0.4% relative to the baseline in 2025222. On the other 
hand, the increases in payload will reduce the transport costs of ZEV per tonne-kilometre. Overall, 
the decrease in costs per tonne-kilometre is estimated at 0.3% for BEV HGVs and 0.3% for FCEV 
HGVs  in  2025  with  this  advantage  first  increasing  to  0.9%  and  1.1%,  respectively,  by  2035  and 
then  fading  out  over  time  due  to  technology  development.  The  increases  in  transport  activity  of 
ZEV are estimated taking into account the price elasticity of demand for road transport (see section 
1 of Annex 4). No impact on the modal shares of road and inland navigation are expected due to 
this measure.  

Capital costs. PMc1 is not expected to have an impact on capital costs. First, the tractor would be 
the  same.  For  BEV,  the  same  semitrailer  can  carry  two  extra  tonnes  without  adaptations.  For 
FCEV,  the  wheelbase  of  the  tractor  would  need  to  be  extended,  adding  a  weight  of  300  kg222. 
However, the cost of conversion is expected to be equivalent to the costs of elongated cabs design. 

Effect on buses and coaches 

The weight allowance for ZE HGVs would apply also to 2-axle rigid buses which under the current 
legal framework do not enjoy any extra weight allowance to compensate for the ZEV technology. 

Examining the specifications of different vehicles in the market and comparing  them to regulated 
limits showed that only 2-axle touring coaches (no standees) and double decked 2 axle city buses 
are currently weight constrained. Other buses would not lose significant payload if moving to ZEV 
technologies. Data on transport activity (expressed in vehicle-kilometres) for 2 axle coaches is not 
available.  Input  received  during  the  stakeholders’  consultation223  showed  that  in  terms  of  vehicle 
stock, 2 axle rigid coaches represent around one third of the total stock.  

222  A  basic  semitrailer  weighs  around  6-7  tonnes.  The  increase  due  to  PMc1  is  estimated  at  462  kg.  However,  the 
weight of wheelbase and tyres will be the same.  Therefore, it is estimated that a longer semitrailer is 300 Kg heavier 
than a standard semitrailer. 
223 ACEA (European Automobile Manufacturers' Association) and CONFEBUS (the Spanish bus operator association).  

99 

 
 
 
                                                 
The impacts of PMc1 on transport activity, the stock of ZEV and the adjustment costs savings for 
transport  operators  for  2030,  2040  and  2050  relative  to  the  baseline  are  provided  in  Table  21. 
Expressed  as  present  value  over  2025-2050,  the  total  recurrent  adjustments  costs  savings  for 
transport operators relative to the baseline are estimated at EUR 344.5 million (in 2022 prices), of 
which EUR 24 million corresponding to buses and coaches. The reduction in the total number of 
vehicle-kilometres relative to the baseline and the increase in the uptake of zero-emission vehicles 
is projected to have a positive impact on environment.   

Table 21: Impacts of PMc1 on transport operators relative to the baseline 

2030 

2040 

2050 

Reduction in total transport activity (vkm million) 
Reduction in the number of trips (million) 
Increase in ZEV transport activity (vkm million) 
Increase in ZEV transport activity (tkm million) 
Increase in the stock of ZEV (thousand) 
Adjustment costs savings for HGVs (EUR million) 
Adjustment costs savings for buses and coaches (EUR million) 
Adjustment costs savings for all HDVs (EUR million) 
Source: TML et al. (2023), impact assessment support study; Note: negative values represent adjustment costs.   

4.4 
21.3 
50.0 
1,318.9 
1.3 
22.1 
1.7 
23.7 

0.0 
0.0 
73.6 
1,785.0 
2.4 
8.5 
0.6 
9.1 

    0.0 
0.0 
63.6 
1,542.1 
2.5 
-1.8 
-0.1 
-1.9 

Adjustment costs (recurrent) for public authorities  

Maintenance costs related to infrastructure. Maintenance costs of pavement depend on the type of 
pavement and the axle weight. PMc1 includes an allowance of one additional tonne per axle and, 
therefore, this is  expected to lead to an increase  in  the maintenance costs. The extra maintenance 
costs  steam  from  the  extra  weight  allowance  for  BEV.  For  FCEV  no  impact  is  expected  on 
pavement  maintenance.  Two  other  elements  that  lead  to  lower  damage  to  the  infrastructure  were 
also taken into account in the calculations: the improvement in technology leading to the reduction 
of the weight of the batteries over time and the lower number of trips required for transporting the 
same amount of cargo.  

Overall, PMc1 leads to an increase in the maintenance costs of infrastructure, as shown in Table 22 
for 2025, 2030 and 2040 relative to the baseline.  Expressed as present value over 2025-2050, the 
adjustment costs for public authorities are estimated in EUR 456.1 million relative to the baseline 
(in 2022 prices). 

Table 22: Impacts of PMc1 on public authorities relative to the baseline 

Adjustment costs for public authorities (EUR million) 

5.6 

46.6 

26.1 

0.0 

2025 

2030 

2040 

2050 

Source : TML et al. (2023), impact assessment support study  

Reinforcement costs for pavement and bridges 

The  potential  need  for  reinforcement  of  pavements  or  bridges  was  also  considered.  Many  factors 
lead  to  pavement  deterioration.  For  instance,  the  icing  and  de-icing  process  are  among  the  most 
aggressive actions, which may lead to severe damages; floods and soil  movements also affect the 
pavement  infrastructures.  While  axle  and  vehicle  loads  are  an  element  influencing  the  pavement, 
these  are  already  covered  under  the  maintenance  costs  discussed  above.  No  additional 
reinforcement of the pavement is required under this policy measure. 

100 

 
 
  
 
Similarly, many elements may affect bridges (e.g.  age, wind loads, earthquakes, current and river 
flow  and  floods),  which  are  of  many  different  types  (e.g.  suspended,  cable  stayed,  orthotropic 
decks,  composite  girder  and  plate,  arches,  bowstrings,  integral  slabs,  reinforced  or  pre-stressed 
concrete  girder,  box  girder,  cantilever)  and  materials  (e.g.  steel,  reinforced  concrete,  pre-stressed 
concrete, wood) and with lengths varying from 2-5 m up to 1,500 m or more. A bridge is composed 
of several sub-structures, sensitive either to wheel or axle loads, to group of axles, to single vehicles 
or  to  a  series  of  vehicles  on  one  or  more  lanes.  The  maintenance  of  bridges  is  mainly  driven  by 
ageing, corrosion, creep and shrinkage of concrete, and combination of actions (wind, traffic loads, 
scouring, temperature, etc.). 

New EU bridges designed since 1995-2000 are compliant with the Eurocode 1991-2. Several MS 
(Germany,  France, Sweden) have set  up or are planning upgrade programs to  bring their existing 
bridge stock in line with those requirements. The design loads are relatively high, with extra safety 
factors. For bridges designed to comply with these standards, the increase in weight under PMc1 is 
not expected to require additional costs. 

The adjustment costs related to the assessment of the infrastructure for which the load may need to 
be restricted are considered jointly with PMc2.  

PMc2: Allow for extra height to accommodate high-cube containers in intermodal transport 

PMc2 provides for increasing the maximum height of HDV to 4.3 meters in order to accommodate 
high-cube  containers  using  standards  skeletal  trailers.  The  W&D  Directive  sets  the  maximum 
authorised  height  in  international  (intra-EU)  transport  at  4  meters,  which  requires  road  transport 
operators  involved  in  the  transport  of  high-cube  containers  to  resort  to  special  equipment  (low 
skeletal  trailers  and  gooseneck  trailers)  or  to  request  special  permits  for  indivisible  loads  (only 
possible in cases where the road infrastructure can accommodate 4.3 meters high HDV).  

PMc2  aims  at  removing  the  “legal”  limitation  to  the  circulation  of  HDVs  transporting  high-cube 
containers (or swap bodies of equivalent height), without prejudice to the application of road traffic 
national  provisions  limiting  the  maximum  height  of  HDV  on  certain  roads  of  civil  engineering 
structures. 

Twelve Member States allow higher limits  in  national  transport:  Slovenia, Hungary  and Slovakia 
allow a maximum authorised height of 4.2 meters and Finland, France, Ireland, Sweden, Estonia, 
Italy, Bulgaria, Portugal and Spain allow 4.3 meters or more. 

Table 23: Maximum vehicle height per Member State, in meters 
Member States 

Height limit 

AT 

BE 

BG 

CZ 

DK 

DE 

EE 

IE 

EL 

4.0 

4.0 

4.3* 

4.0 

4.0 

4.0 

4.3 

≥4.3 

4.0 

101 

 
 
Member States 

Height limit 

ES 

FR 

HR 

IT 

CY 

LV 

LT 

LU 

HU 

MT 

NL 

PL 

PT 

RO 

SI 

SK 

FI 

4.5* 

≥4.3 

4.0 

4.3 

4.0 

4.0 

4.0 

4.0 

4.2 

4.0 

4.0 

4.0 

4.6* 

4.0 

4.2 

4.2 

≥4.3 

SE 
Source: TML et al. (2023), impact assessment support study; * Member States allowing a maximum height of 4.3m or 
above, but not for containers. 

≥4.3 

In the Member States that already allow 4.3 meters high vehicles, high-cube containers can be used except 
for Bulgaria, Spain and Portugal. Therefore, the impacts of the measure are limited to 21 Member States. 

In  2021,  around 6% of road freight activity (expressed  in tonne-kilometres) was  represented  by  the 
transport  of  containers224.  In  terms  of  tonnes,  of  12.5  billion  tonnes  transported  by  road  in  the  EU27, 
around 1 billion (8%) were transported in containers. Transport in the aforementioned 21 MS account for 
81% of this containerised transport, of which around 30% makes use of high-cube containers225 (around 
249 million tonnes). PMc2 is estimated to affect a transport volume of 316 million tonnes in 2030, 338 
million tonnes in 2040 and 369 million tonnes in 2050 in the 21 Member States concerned. 

Administrative cost savings (recurrent) for transport operators 

Currently, two solutions are implemented by operators to transport high-cube containers: 

-  Obtaining  a  special  permit  for  abnormal  transport  to  carry  high-cube  containers  exceeding  30cm  in 
height. The cost associated with obtaining a special permit for transport high-cube containers is estimated 
in EUR 60-75 for a return trip, based on feedback received during the stakeholder consultation process, or 
EUR 500-EUR 2,300 for a full year.  

- Using special  equipment  of  low  wheel skeletal  trailers  (with  a loading  height  of  1.1m instead of the 
standard  1.4m).  This  is  likely  the  preferred  option  as  it  does  not  come  to  extra  costs  as  compared  to 

224 Source: Eurostat (ROAD_GO_TA_TCRG). 
225 Based on Woodburn, A. (2008), The challenge of high cube ISO containers for British rail freight operations; PWC 
and Kombiconsult (2022), Comparative evaluation of transhipment technologies for intermodal transport and their cost. 

102 

 
 
                                                 
standard semitrailers, but their use is mostly restricted to operators specialised in containerised transport. 
Based  on  the  input  from  a  terminal  operator,  it  is  estimated  that  80%  of  high  cube  containers  are 
transported using gooseneck trailers.   

PMc2 would address the hauliers making use of the first solution. It will eliminate the administrative cost 
of obtaining the  permits, increasing the attractiveness of this type  of transport.  In the baseline scenario 
permits are estimated to be needed for 20% of the trips, based on feedback from a terminal operator. The 
estimated reduction in the number of permits and the administrative costs savings for transport operators 
in 2030, 2040 and 2050 relative to the baseline are provided in Table 24. For estimating the costs savings 
the cost per permit was assumed to be EUR 70 per round trip. Expressed as present value over 2025-2050, 
the  adjustment  cost  savings  for  hauliers  operating  in  the  21  Member  States  affected  by  PMc2  are 
estimated at EUR 3.2 billion relative to the baseline (in 2022 prices). 

Table 24: Impacts of PMc2 on transport operators relative to the baseline 

Reduction in the number of permits (million) 

Administrative costs savings (million EUR) 

Shift from unimodal road to intermodal transport (billion tkm) 
Source: TML et al. (2023), impact assessment support study 

2030 

2040 

2050 

2.4 

168.8 

11.7 

2.6 

180.5 

12.8 

2.8 

196.9 

14.4 

The average number of permits over 2025-2035 is estimated at 2.37 million per year. Considering 
the  cost  per  permit  of  EUR  70,  based  on  the  stakeholders’  consultation  activities,  the  average 
annual cost savings are estimated at EUR 165.9 million. These administrative costs savings are not 
subject to the application of the ‘one in, one out’ approach. 

The elimination of the need of obtaining a permit for operators that make use of this option in the baseline 
is estimated to result in costs savings of 2-7% per tonne relative to the baseline depending on the Member 
State and time period.  

Taking into account the price elasticity of transported volume and the estimated decrease in the operation 
costs due to PMc2, the shift from road-only to intermodal transport is estimated at 12 billion tonne-
kilometres in 2030 relative to the baseline and 14 billion tonne-kilometres in 2050. The shift from 
road-only to intermodal transport is projected to have a positive impact on environment.  

Impact on OEMs 

The  need  for  low  floor  container  chassis  will  be  significantly  reduced  but  still  required  under 
certain circumstances (i.e. to cross under bridges or tunnels not adapted to the 4.3 m height). The 
latter will permit OEMs to manage their stocks and adapt to the new circumstances. 

Adjustment costs for public authorities 

This measure will not require adapting the infrastructure as infrastructure managers can restrict the 
access  to  the  sections  of  the  network  where  the  infrastructure  would  not  allow  it.  However, 
infrastructure managers would need to make sure that the inventory of bridges and tunnels is up to 
date  and  make  this  inventory  available  to  road  users  so  that  they  can  plan  their  journeys 
accordingly.  The  one-off  adjustment  costs  for  updating  the  inventory  are  estimated  at  EUR  10.5 
million for the 21 affected Member States or EUR 0.5 million on average per Member State. 

103 

 
 
 
PMc3: Harmonise the maximum permitted weight of 5- and 6-axle HDV (40t) 

PMc3 sets the weight standard of 5- and 6-axle rigid vehicles in national and international transport 
to a maximum permitted weight of 40t. Rigid HDVs of 5 or 6 axles are currently not regulated in 
the W&D Directive. As a consequence, they are admitted in international transport with the same 
GVW of a 4-axle rigid trucks, i.e. 32t. The current Directive already establishes a maximum GVW 
of 40t for articulated vehicles of 5 and 6 axles. This measure extends the same maximum GVW to 
rigid vehicles. 

Adjustment cost savings for transport operators 

According to the data compiled in the context of the New Mobility Patterns Study226, the average 
payload  for  the  category  of  rigid  HDVs  above  32t  is  only  36.5%  of  the  maximum  payload  (see 
Table 25). PMc3 is expected to trigger a shift in activity from current 32t 4-axle rigid trucks to 5- 
and 6-axle rigid trucks. The average payload for rigid trucks over 32t is estimated to increase from 
the current 7.2t to 9.5t (a 32% increase).  

Avg payload (t) 

Max payload (t) 

Table 25: Maximum vs average payload for rigid trucks 
Vehicle type 
Rigid 3.5 - 7.5 t 
Rigid 7.5 - 12 t 
Rigid 12 - 14 t 
Rigid 14 - 20 t 
Rigid 20 - 26 t 
Rigid 26 - 28 t 
Rigid 28 - 32 t 
Rigid >32 t (currently) 
Average 
Rigid > 32 t (under PMc3) 
9.5 
Source: New Mobility Patterns Survey and TML et al. (2023), impact assessment support study 

2.0 
5.0 
7.0 
9.7 
13.7 
16.4 
18.4 
19.7 

1.1 
2.3 
3.4 
4.7 
6.6 
7.9 
8.9 
7.2 

19.7 

Ratio 

56.3% 
47.1% 
48.3% 
48.3% 
48.3% 
48.2% 
48.3% 
36.5% 
48.1% 
 48.1% 

The increase in the payload increases the capital and operation costs but, at the same time, reduces 
the number of trips needed through the shift in activity from the current 32t 4-axle rigid trucks to 5- 
and  6-axle  rigid  trucks227.  Transport  operators  can  thus  improve  efficiency  and  reduce  the  costs. 
Overall, total recurrent adjustments costs savings for transport operators relative to the baseline are 
provided  in  Table  26.  Expressed  as  present  value  over  2025-2050,  total  adjustment  costs  savings 
are  estimated at EUR 808.5 million relative to the baseline. 

Table 26: Impacts of PMc3 on transport operators relative to the baseline 

Decrease in total transport activity in vkm (million) 
Reduction in the number of trips (million) 
Adjustment costs savings (EUR million, 2022 prices) 
Source: TML et al. (2023), impact assessment support study 

Adjustment costs savings for public authorities  

2030 

2040 

2050 

20.6 
220.4 
28.8 

41.9 
447.7 
58.9 

47.0 
500.8 
65.5 

226 New Mobility Patterns Study. 
227  To  estimate  the  shift  the  own  elasticity  of  road  transport  demand  (in  tonnes)  of  -0.10  was  used.  Source: 
Rijkswaterstaat (2020). 

104 

 
 
  
  
 
                                                 
The heavier a truck the quicker the infrastructure is damaged and need maintenance. On the other 
hand, the  fewer vehicles  (i.e. trips)  the lower the damage. Under PMc3,  the latter  effect  is  larger 
than the former and the measure is thus expected to generate costs savings for the maintenance of 
road  infrastructure.  Overall,  the  adjustments  costs  savings  for  public  authorities  relative  to  the 
baseline in 2030, 2040 and 2050 are provided in Table 27. Expressed as present value over 2025-
2050, they are estimated at EUR 25 million relative to the baseline. 

Table 27: Impacts of PMc3 on public authorities relative to the baseline 

Adjustment costs savings for public authorities (EUR million, 2022 prices) 
Source: TML et al. (2023), impact assessment support study 

2030 

2040 

2050 

0.9 

1.8 

2.0 

PMc4: Allow cross-border transport of 44t-HDV and EMS between "allowing" MS 

PMc4 allows the cross-border transport, on one hand, of 5- or 6-axle HDV with a maximum GVW 
of 44t and, on the other, of EMS between allowing Member States (i.e. Member States that allow 
such  heavier  and/or  longer  vehicles  in  national  transport).  This  measure  takes  account  of  the 
national permissible weights (total and per axle) and length that are common to the respective MS 
(“minimum common denominator”) and to the part of the network where these vehicles are allowed 
in  national  traffic,  but  it  does  not  condition  the  cross-border  transport  to  the  compliance  with 
additional requirements that could be imposed nationally to the vehicle or to the driver.  

Making use of the current possibility of granting national derogations, a significant number of MS 
allow national transport at weights and dimensions in excess of the standard EU limits (see Table 
28). 

Table 28: Weigh allowance beyond the standard EU limits for “allowing” Members States 

44 tonnes (standard HDVs) 

  Belgium 
  Czechia 
  Denmark 
  Estonia 
  Finland 
  France 
 
 
  Luxembourg 
  Netherlands (50t) 
  Portugal 
  Sweden 

Ireland (46 tonne)* 
Italy (56 tonne) 

EMS 

  Belgium (60t) 
  Czechia (48t) 
  Denmark (60t) 
  Germany (40t) 
  Finland (76t) 
  Netherlands (60t) 
  Portugal (60t) 
  Spain (60t, 70t in trial) 
  Sweden (64t, 74t in a trial) 

Notes: * For Ireland, 46t are allowed if the trucks are equipped with EBS and ESC. 
Source: TML et al. (2023), impact assessment support study 

Under  PMc4,  the  trucks  with  allowances  beyond  the  EU  limits,  which  were  limited  to  national 
traffic, would now be allowed to circulate internationally across “allowing” Member States. There 
would be no limit to the border crossings as long as the common denominator is respected. PMc4 
would  affect  international  transport  only  among  “allowing”  Member  States.  National  transport 
would not be affected. 

105 

 
 
  
 
 
 
Based  on  the  current  national  limits  and  applying  the  common  denominator,  Table  29  shows  the 
extra average payload for international transport for pairs of “allowing” Member States. 

Table 29: Extra payload under PMc4 for pairs of Member States 

Origin 
BE 
BE 
BE 
BE 
BE 
BE 
BE 

CZ 
CZ 
CZ 
CZ 
CZ 
CZ 

DE 
DE 
DE 
DE 
DE 

DK 
DK 
DK 
DK 
DK 
DK 

ES 

FI 
FI 
FI 
FI 
FI 

FR 
FR 
FR 
FR 
FR 

IT 

LU 
LU 
LU 

NL 
NL 
NL 
NL 
NL 
NL 
NL 

PT 

Destination 
CZ 
DE 
DK 
FI 
FR 
LU 
SE 

BE 
DE 
DK 
FI 
NL 
SE 

BE 
DK 
FI 
NL 
SE 

BE 
CZ 
DE 
FI 
NL 
SE 

PT 

BE 
CZ 
DE 
DK 
NL 

BE 
IT 
LT 
LU 
NL 

FR 

BE 
FR 
NL 

CZ 
DE 
DK 
FI 
FR 
LU 
SE 

ES 

106 

Extra payload 

20.0% 
20.0% 
20.0% 
20.0% 
2.0% 
3.0% 
20.0% 

20.0% 
20.0% 
20.0% 
20.0% 
20.0% 
20.0% 

20.0% 
20.0% 
20.0% 
20.0% 
20.0% 

20.0% 
20.0% 
20.0% 
20.0% 
20.0% 
50.0% 

50.0% 

20.0% 
20.0% 
20.0% 
50.0% 
20.0% 

2.0% 
2.0% 
0.0% 
2.0% 
2.0% 

2.0% 

3.0% 
2.0% 
3.0% 

20.0% 
20.0% 
20.0% 
20.0% 
2.0% 
3.0% 
20.0% 

50.0% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Origin 
SE 
SE 
SE 
SE 
SE 

Destination 
BE 
CZ 
DE 
DK 
NL 

20.0% 
20.0% 
20.0% 
50.0% 
20.0% 
Notes: For 44t the extra payload is 2% to 3%. For EMS the extra payload is based on weight constrained goods and 
limited to 20%. Between Member States that already have a bilateral agreement, there is not extra payload. When there 
is a choice, EMS prevails over 44 t. 
Source: TML et al. (2023), impact assessment support study 

Extra payload 

Adjustment cost savings for transport operators 

The  increase  in  the  average  payload  is  expected  to  lead  to  a  decrease  in  the  costs  per  tonne-
kilometre for international transport as well as to a reduction in vehicle-kilometres, number of trips 
and  an  increase  in  the  tonnes-kilometres.  As  a  consequence,  PMc4  leads  to  adjustments  costs 
savings for transport operators (see Table 30) relative to the baseline estimated at EUR 2.3 billion, 
expressed as present value over 2025-2050. 

Table 30: Impacts of PMc4 on transport operators relative to the baseline 

Increase in total volume - number of tonnes (thousand)        
Decrease in total transport activity in vkm (million) 
Increase in total transport activity in tkm (million) 
Reduction in the number of trips (million) 
Adjustment costs savings (EUR million, 2022 prices) 
 Source: TML et al. (2023), impact assessment support study 

2030 

2040 

2050 

  11,923 
125.6 
4,930.5 
305.5 
106.6 

  12,314 
126.3 
5,047.3 
309.8 
139.0 

  13,211 
134.1 
5,458.6 
326.2 
175.2 

The  increase  in  efficiency  of  road  transport  also  induces  a  modal  shift  from  rail  and  inland 
waterways towards road transport, estimated at 4.9 billion tonne-kilometres in 2030 and 5.5 billion 
tonne-kilometres  in  2050  relative  to  the  baseline.  This  is  particularly  due  to  the  shift  from  the 
vehicle category >32 with 6 axles. 

Adjustment costs savings for public authorities  

The heavier a truck the quicker the infrastructure is damaged and need maintenance. On the other 
hand, the  fewer vehicles (i.e. trips) the lower the damage. Under PMc4, the latter  effect  is  larger 
than the former and the measure is thus expected to generate costs savings for the maintenance of 
road  infrastructure.  Overall,  the  adjustments  costs  savings  for  public  authorities  relative  to  the 
baseline in 2030, 2040 and 2050 are provided in Table 31. Expressed as present value over 2025-
2050, they are estimated at EUR 106.2 million relative to the baseline. 

Table 31: Impacts of PMc4 on public authorities relative to the baseline 

Adjustment costs savings for public authorities (EUR million, 2022 prices) 
Source: TML et al. (2023), impact assessment support study 

PMc5: Harmonise the loaded length of vehicle carriers 

2030 

2040 

2050 

5.6 

5.8 

6.2 

PMc5 introduces a standard for the maximum overhang of loads used in road trains specialised in 
the  transport  of  vehicles  (vehicle  transporters  or  vehicle  carriers)  in  national  and  international 
traffic.  The  maximum  authorised  length  of  these  vehicles  is  the  general  18.75m.  However  this 
length  can be  exceeded  when they are loaded (through national  derogations), via  the use of front 

107 

 
 
 
  
and/or rear cantilevers or overhangs, up to a maximum of 20.75m. This measure aims at removing 
the national divergences as regards the type and length of overhangs allowed in national transport 
described in the table below. 

In practice, with the exception of France, Luxemburg, Portugal, Spain (and Malta), all MS already 
allow a loaded length of vehicle of at least 20.75m (see Table 32). Therefore, a harmonisation of 
the  length  at  20.75m  does  not  seem  to  entail  any  particular  problem  in  terms  of  safety  or 
infrastructure. This will allow those four Member States an increase by one full vehicle, i.e. from 8 
to 9 and by two full vehicles in Malta (where no overhangs are currently allowed). 

A  further  issue  is  that  the  distribution  of  the  extra  length  granted  in  the  form  of  overhangs  is 
different  across  Member  States.  Given  that  the  W&D  Directive  does  not  regulate  vehicles 
overhangs,  in  practice,  operators  comply  with  the  lowest  common  denominator  of  what  each 
Member State allows nationally. This affects particularly the international traffic between France, 
Belgium, Luxembourg, Germany and Italy. 

Table 32: National length limits for vehicle carriers 

Country 

EU 
(WDD) 
AT 
BE 

BG 

HR 

CY 

CZ 
DK 
EE 
FI 
FR 
DE 
GR 

HU 

IE 
IT 
LV 
LT 
LU 
MT 

NL 

PL 
PT 
RO 
SK 
SI 
ES 
SE 
CH 

Total  loaded 
length 

Front 
overhang 

Rear 
overhang 

Comment 

18.75 

Undefined 
20.75 

- 

- 

Undefined 
0.5 

Undefined  Overhang must be shorter than 1/4 of trailer length 

1.5 

Undefined 

Undefined 

Undefined 

Vehicles over 18.75m but under 22m can circulate after payment 
of a tax 

21 

* 

1 

* 

20.75 
20.75 
20.75 
Undefined 
20.35 
20.75 
20.75 

Undefined 
Undefined 
Undefined 
1 
0 
0.5 
0.5 

* 

* 

21.75 
21 
Undefined 
20.75 
20 
18.75 

20.75 

20.75 
20.55 
21.75 
20.75 
22 
20.55 
24 
20.35 

Undefined 
Undefined 
Undefined 
Undefined 
1 
0 

0.5 

0.5 
0 
Undefined 
0 
0 
0 
Undefined 
0.5 

*  *: 1/6 of last vehicle of the load 

*:The overall loaded length in Cyprus can be: (A) the total length 
of the vehicle combination (max 18.75m) plus up to 10% of the 
rigid vehicle’s length as front overhang (provided that there is no 
overhang to the rear of the vehicle); (B) 18.75m plus part of the 
10% overhang as front overhang of the rigid vehicle (the rest of 
the 10% overhang is then at the rear of the rigid vehicle and not 
the trailer) 
In practice, 0.5m front and 1.5m rear overhang is allowed 

*:  Vehicles  up  to  22m  need  a  (paid)  permit.  No  overhangs  are 
allowed, so longer vehicles need to use an extension. 

* 

Undefined 
2 
Undefined 
2 
1.6 
1.5 
1.5 

* 

3 

Undefined  Front overhang can only be used with rear overhang 
Undefined 
Undefined 
Undefined 
0 

2 

The load should not extend by more than 5.00 m to the rear when 
measured from the centre of the rear axle of the trailer 

2 
1.8 
Undefined 

0  Only a rear extension can be used in practice 

1.5 
1.8 
Undefined 
1.1 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Source: ECG (ECG, 2021), https://www.ecgassociation.eu/activities/eu-affairs/ 

Adjustment cost savings for transport operators 

As  explained  above,  this  measure  will  allow  Spain,  Portugal,  France,  Luxembourg  and  Malta  to 
increase the number of vehicles transported in each truck, and therefore reduce transport activity in 
terms  of  vehicle-kilometres  (vkm).  The  transport  of  transport  equipment  (NST2007  group  12)228 
represented 2% of total tonnes transported by road in the EU, 3.9% of tonnes-kilometres and 5.1% 
of  vehicle-kilometres229  in  2021.  There  is  no  data  available  on  the  share  of  domestic  versus 
international  transport  at  the  level  of  the  type  of  good.  At  the  overall  level  (for  all  goods  types), 
loaded  domestic  transport  represents  around  52%  of  all  transport  activity,  while  international 
loaded  transport  around  28%  (in  vkm);  the  rest  is  empty  transport230.  The  share  of  total  vkm 
potentially affected by this measure would thus be around 1.4%. 

A higher load factor would allow a 11.1% decrease in activity in vkm for the same cargo moved for 
those countries. The total reduction in vkm for the MS affected by PMc5 is shown in Table 33. The 
cost saving per vkm is estimated at EUR 1.45. The recurrent adjustment costs savings relative to the 
baseline are provided in Table 33. Expressed as present value over 2025-2050, they are estimated at 
EUR 8.7 billion relative to the baseline.    

Table 33: Impacts of PMc5 on transport operators relative to the baseline 

Reduction in transport activity in vkm (million) 

Adjustment costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study 

Adjustment costs for public authorities  

2030 

289.0 

444.2 

2040 

316.3 

486.5 

2050 

360.9 

554.4 

Carrying  9  cars  instead  of  7  or  8  will  increase  the  transported  mass  and  could  potentially  affect 
infrastructure/pavement. The average mass of a car is 1.481 tonnes (ICCT, 2022). At 7 vehicles, the 
cargo of a vehicle transported would weigh 10.4 tonnes, which would increase to 13.3 tonnes when 
9 cars are loaded. While this increase should have some impacts on pavements, the GVW of such a 
vehicle would still be well below the maximum allowed GVW and the designed weight limits for 
pavement. With the additional length likely to be achieved by extending front and rear overhang for 
those countries currently with lower length limits, there could be some additional cost from damage 
to  roadside furniture  etc. when manoeuvring, or the need to  restrict tertiary  routes  where damage 
could occur, but this impact is likely very small.  

Administrative costs for public authorities  

There  are  likely  some  inspection  costs  for  public  authorities  associated  with  slightly  increased 
length in the affected MS. These costs cannot be estimated, but they are expected to be limited. 

228 Not all of this could be transported by vehicles that could make use of this measure, e.g. it also includes transport of 
vehicle parts. 
229 Eurostat: table ROAD_GO_TA_DCTG. 
230 Eurostat: table ROAD_GO_TA_TOTT.  

109 

 
 
  
                                                 
PMc6: Reinforce MS obligation to conduct a minimum level of checks on HDV’s weight 

PMc6 will mandate Member States to carry out every  year a minimum number of controls of the 
compliance of HDV with the rules on maximum total weight and maximum axle weight per million 
vehicle-kilometre (vkm) in each Member State. This measure does not preclude how the controls 
are performed, i.e. via physical inspection on the roadside or automatic systems allowing for direct 
enforcement without stopping the HDV controlled. The measure aims at ensuring a minimum level 
of enforcement in the EU which is expected to improve the competition and road safety.   

Data indicates that the number of HDVs controlled regarding their weight231 is very heterogeneous 
across Member States, ranging from less than 0.65 weight controls per million vkm in Finland, the 
Netherlands or Poland, to around 20 or more in Greece, Ireland, and Slovenia (see Table 34). This 
policy  measure  aims  to  reinforce  the  Member  States  obligation  to  conduct  a  minimum  level  of 
checks of HDV weight. Based on the median value for the list of Member States presented in Table 
34, the minimum number of weight tests required would be 6.4 per million vkm. 

Table 34: Weight checks performed in 2020, checks per million vkm 

Member State 
AT 
BE 
BG 
DE 
DK 
EE 
EL 
ES 
FI 
IE 
IT 
LU 
LV 
NL 
PL 
SE 
SI 
SK 
MEDIAN 

Weight checks/million vkm 

9.29 
1.10 
2.80 
5.48 
10.93 
6.41 
24.54 
6.37 
0.50 
4539.22 
19.01 
14.95 
0.80 
0.14 
0.62 
3.37 
22.42 
12.93 
6.41 

Notes: The data on transport activity (in vkm) follow the registration criteria.  
Source: TML et al. (2023), impact assessment support study, based on data from “31st report from the Commission on 
the implementation of the social legislation relating to road transport”232 

Nevertheless, heavy goods vehicle operators also face burden every time they are subject to police 
control.  These  controls  can  include  roadside  checks,  vehicle  inspections  and  documentation 
reviews. Operators may incur costs related to the time spent to comply with these checks, as well as 
potential  fines  and  penalties  for  non-compliance.  In  addition,  if  a  vehicle  is  found  to  be  non-

231 These checks can be made in certified static scales with specialised teams (inspectors/police/…) or by certified WIM 
systems. 
232 Report from the Commission to the European Parliament and the Council on the implementation in 2019-2020 of 
Regulation  (EC)  No  561/2006  on  the  harmonisation  of  certain  social  legislation  relating  to  road  transport  and  of 
Directive 2002/15/EC on the organisation of the working time of persons performing mobile road transport activities 
(31st report from the Commission on the implementation of the social legislation relating to road transport). 

110 

 
 
                                                 
compliant,  it  may  need  to  be  taken  out  of  service  for  unloading  or  repairs,  resulting  in  loss  of 
revenue.  

Administrative costs for public authorities 

PMc6 will require public authorities to perform additional tests in the 9 Member States below the 
threshold of 6.4 weight tests per million vkm233. The evolution of the total number of weight tests 
over time takes into account  the  projected transport activity.  For instance, in  2025 these Member 
States  will  have  to  undertake  239.2  thousand  additional  weight  tests  to  reach  the  threshold.  No 
additional tests are required in the 8 Member States above the threshold234.  

Based  on  the  stakeholders’  consultation  and  the  REMOVE  project235,  each  weight  test  is 
considered, on average, to require one hour for two officers (one hour for each). The cost per check 
is estimated at EUR 142.  

Taking into account the additional number of tests required and the cost per test, the administrative 
costs  for  public  authorities  under  PMc6  are  estimated  at  EUR  34  million  in  2030  and  EUR  48.7 
million  in  2050  relative  to  the  baseline.  Expressed  as  present  value  over  2025-2050  the 
administrative costs are estimated at EUR 0.8 billion relative to the baseline. 

Table 35: Impacts of PMc6 on public authorities relative to the baseline 

2025 

2030 

2040 

2050 

Cumulative/ 
present value 
(2025-2050) 

Weight tests in the baseline (thousand) 

6,683.5 

8,022.4 

8,943.7 

10,703.7 

227,351 

Required additional weight tests relative to the 
baseline (thousand) 

239.2 

275.3 

307.8 

343.3 

Additional administrative costs (EUR million) 

34.0 

39.1 

43.7 

48.7 

7,752 

762.7 

Source: TML et al. (2023), impact assessment support study 

Adjustment costs savings for public authorities  

Adjustment  cost  savings  for  public  administrations  are  related  to  public  expenditures  on 
infrastructure maintenance. PMc6 is expected to reduce the frequency and severity of overloading 
practices,  mitigating  the  premature  damage  of  the  road  infrastructure  due  to  overloaded  HDVs. 
Wermskerken (2005)236 cited research showing that in the Netherlands EUR 18.1 to 42.3 million of 
road damage was caused by overloaded vehicles. Based on data from the OECD on the total road 
maintenance  costs  for  the  Netherlands,  this  represents  2.9  to  6.7%  (mid-point  4.8%)  of  all  road 

233 These are Belgium, Bulgaria, Germany, Estonia, Spain, Finland, Latvia, Netherlands, Poland and Sweden. 
234 These Member States are Austria, Denmark, Greece, Ireland, Italy, Luxembourg, Slovenia and Slovakia. In addition, 
for  Cyprus,  Czechia,  France,  Croatia,  Hungary,  Lithuania,  Malta,  Portugal  and  Romania  for  which  there  is  no 
information provided on their enforcement activity in compliance with article 10g of the W&D Directive it is assumed 
that they meet the EU threshold. 
235  Data  were  obtained  for  Croatia,  Italy,  Finland,  Estonia,  Poland,  Latvia,  Malta  and  Luxembourg.  Wermskerken 
(2005), Project REMOVE work package 4 final report on cost benefit analysis. 
236  Wermskerken  (2005),  Project  REMOVE  work  package  4  final  report  on  cost  benefit  analysis.  Deliverable  of  the 
REMOVE project funded by the EC. 

111 

 
 
 
 
                                                 
maintenance  costs  attributed  to  overloaded  vehicles.  It  was  assumed  that  this  share  would  apply 
across the EU. 

An essential element to assess such costs savings is how effective increased checks are at reducing 
the frequency and/or magnitude of overloading. Some quantitative analysis has been undertaken so 
far237.  Winter  &  Campbell  (2009)238  identified  that  the  use  of  WIM  data  to  target  checks  more 
effectively in Montana, US produced a 20% reduction. Studies of a pause in checks found that the 
incidence  of  overloaded  vehicles  (by  GVW)  increased  from  2.27%  before  to  3.67%  during  the 
pause  and  decline  to  3.19%  after.  Based  on  driver  hours  enforcements,  Elvik  &  Erke  (2006)239 
found that increasing the frequency of checks by 200% would result in benefits of around 85% of 
the maximum achievable. Regan et al. (2006)240 found that replacing low frequency manual checks 
with high frequency automated checks reduced overloading by 89% (Florida) to 97% (Maryland) at 
the enforcement sites (not necessarily across the whole network).  

Based  on  the  above  estimates,  it  was  assumed  that  due  to  routes  not  encountering  WIM  and  the 
potential for operators to deliberately avoid WIM an overall effectiveness of direct enforcement via 
certified  WIM  would  be  40%  effective,  pre-selection  WIM  would  be  20%  effective  and  manual 
checks  would  be  half  as  effective  as  pre-selection  WIM  (10%).  These  assumptions  are  used  in 
PM7, PM6 and PMc6, respectively. On the other hand, PMc6 is also expected to lead to an increase 
in the vehicle-km performed by compliant HDVs, partially offsetting the benefits of the reduction 
in overloaded HDVs.  

As  a  result,  PMc6  will  lead  to  EUR    478.4  million  infrastructure  costs  savings  over  the  period 
2025-2050,  expressed  as  present  value  relative  to  the  baseline  (in  2022  prices).  The  adjustment 
costs savings for public authorities related to infrastructure maintenance due to PMc6 are presented 
in Table 36.  

Table 36: Impacts of PMc6 on public authorities relative to the baseline 

2025 

2030 

2040 

2050 

Present 
value 
(2025-
2050) 

Adjustment costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study. 

23.2 

24.4 

27.0 

29.9 

478.4 

237  See  for  example:  Henny,  &  van  Loo  (2019),  Remove  Requirement  for  enforcement  of  overloaded  vehicles  in 
Europe, The Heavy Vehicle Transport Technology Forum;   Honefanger, S. et al. (2007), Commercial  Motor Vehicle 
Size  and  Weight  enforcement  in  Europe,  US  DOT  FHWA;  Marchadour  &  Jacob  (undated),  Development  and 
Implementation  of  a  WIM  network  for  enforcement  in  France,  International  Society  for  Weigh  in  Motion  IS-WIM; 
Todts,  W.  (2014),  Briefing:  Weight  sensors  for  lorries  -  effective,  affordable  reliable,  Brussels:  Transport  & 
Environment;    Oehry,  H.  &  van  Driel  (2013),  Study  on  heavy  vehicle  on-board  weighing,  Rapp  Trans  published  by 
Transport & Environment;  van Velzen (undated), The design of weight enforcement strategies for overloaded vehicles 
on complex road networks, The Netherlands: The Technical University of Delft.  
238 Winter, K., & Campbell, B. (2009). Technology helps us do things better: Virtual weigh stations, other new methods 
for enforcing the law prolong highway life and increase vehicle citations. Virginia Department of Transportation. 
239 Elvik, R., & Erke, A. (2006). Road Safety Measures: A catalogue of estimated effects. TOI report 851/2006. 
240 Regan, A., Park, M., Nandiraju, S., & Yang, C.-H. (2006). Strategies for successful implementation of virtual weigh 
and compliance systems in California. Institute of transportation studies University of California, Berkeley. 

112 

 
 
  
 
                                                 
Adjustment costs for transport operators 

The  truck  driver  will  have  to  stop  for  about  one  hour  to  perform  the  test.  The  economic  cost 
associated to delaying the vehicle by that one hour is estimated at EUR 34.8241. 

According to  the data on the number of checks  undertaken by Member States and the number of 
infractions,  86.8%  of  the  trucks  stopped  were  not  overloaded.  It  should  be  noted  that  other 
estimates have shown a lower proportion. For example, Wermskerken (2005)236 reported that based 
on  a  questionnaire  filled  in  by  Member  States  manual  stops  were  sufficiently  targeted  such  that 
only  50%  of  those  stopped  were  not  overloaded.  However,  the  number  of  Member  States  that 
replied and the precise details were not clear. 

Taking  into  account  the  estimated  increase  in  the  number  of  weight  tests  required  by  PMc6,  the 
adjustment  costs  for  transport  operators  (compliant  and  non-compliant)  for  cooperating  with  the 
public authorities are provided in Table 37. 

PMc6  is  expected  to  reduce  overloading  practices.  If  operators  that  were  previously  operating 
overloaded trucks will now comply with the weight limits, then more vehicle-km will be required to 
transport  the  same  quantity  of  goods.  This  will  affect  transport  operators  which  were  operating 
under  infraction.  By  minimising  the  proportion  of  overloaded  vehicles,  compliant  operators  will 
benefit from a levelled playing field. This applies to both domestic and international transport. The 
adjustment costs due to reduced overloading practices are provide in Table 37.  

Total adjustment costs for transport operators, expressed as present value over 2025-2050 relative 
to the baseline, are estimated at EUR 643 million.  

Table 37: Impacts of PMc6 on transport operators relative to the baseline  

2025 

2030 

2040 

2050 

Cumulative/ 
present value 
(2025-2050) 

Adjustment costs for cooperating with public authorities 
for performing the weight tests (EUR million) 
Increase in transport activity due to reduced overloading 
practices (vkm million) 
Adjustment  costs  due  to  reduced  overloading  practices 
(EUR million) 
Total adjustment costs (EUR million) 
Source: TML et al. (2023), impact assessment support study 

8.2 

9.5 

10.6 

11.8 

184.7 

14.8 

17.2 

19.7 

22.2 

20.0 
28.2 

23.2 
32.7 

26.5 
37.1 

29.9 
41.7 

492.6 

458.3 
643.0 

PMc7:  Set  common  principles  for  the  voluntary  implementation  of  intelligent  access  policies 
(IAP) 

IAP primarily ensures matching the performance and characteristics of a road freight vehicle with 
the  state  and  capability  of  specific  section  of  an  infrastructure  network,  i.e.  it  ensures  that  the 
correct vehicles runs on the correct road at the correct time. Access rules can refer to weight limits, 

241 Motor transport cost tables 2020, counting only fixed costs per operating hour that excluded distance related costs 
such as fuel, "https://motortransport.co.uk/annual-cost-tables-history” 

113 

 
 
  
                                                 
dimensions limits, speed limit compliance, as well as day and/or time restrictions for categories of 
vehicles. 

IAP is a nascent technology and could become a barrier to international traffic if Member States or 
even  regions  independently  were  to  introduce  their  own  systems  without  setting  standards  for 
information exchange.  

PMc7 aims at facilitating a harmonised implementation of Intelligent Access Policies (IAP) in the 
EU based on common principles to be respected by Member States when they voluntary implement 
them,  such  as  public  accessibility  to  the  information,  non-discrimination.  PMc7  would  mean  a 
common approach to ensure the interoperability of IAP’s necessary hardware and software. 

IAP aim to further facilitate efficient enforcement and to address the concerns of a risk of damage 
to  infrastructure  and  of  road  safety  by  some  types  of  HDVs.  Assessing  the  overall  impacts  of  a 
generalised introduction of IAP requires a thorough analysis and goes well beyond PMc7, which is 
limited  to  introducing  common  standards  to  facilitate  IAP.  Therefore,  the  assessment  hereafter 
focuses only on the restricted aspect of standardisation. 

Adjustment costs for the European Commission 

The development of IAP standards will proceed in two steps. A study will be carried out to compile 
the  required  elements  and  propose  several  options  for  the  establishment  of  the  standards.  In  a 
second  stage,  an  expert  group  will  use  the  findings  and  assessment  of  the  study  to  draft  the 
standards. 

The cost of the initial study is estimated at EUR 400,000. The average cost for a two-day workshop 
hosted by European Commission (EC), where participants are reimbursed by the EC is around EUR 
30,000.  Two  of  such  in-person  workshops  may  be  required  as  well  as  two  online  meetings. 
Compensation  for  the  experts  contributing  to  the  online  meetings  is  estimated  in  EUR  5,000  for 
each meeting. Therefore, the one-off adjustment costs for the European Commission are estimated 
at EUR 0.47 million. 

PM1:  Allow  for  extra  weight  for  HDV  which  are  ZEV  regardless  of  the  weight  of  the  ZE 
technology used  

PM1  allows  4  extra  tonnes  for  HDVs  in  national  and  international  traffic  which  are  ZEV  (i.e.  2 
extra  tonnes  as  under  the  current  Directive  plus  2  additional  tonnes)  to  5/6-axle  HGV  only.  In 
addition to PMc1, the extra weight is granted regardless of the weight of the ZE technology used. 
This also means that the effect of the measure will not fade out with technology progress, but the 
effect  will  continue  over  time.  For  instance,  when  technology  will  allow  for  a  reduction  in  the 
weight of batteries, operators could use this to increase the payload capacity of ZEV and improve 
the business case of these vehicles. 

PM1 will enable a maximum GVCW of 44 tonnes for zero-emission HGVs in road-only operations 
and  of  46  tonnes  or  48  tonnes  (depending  on  the  axle  combination)  for  HDVs  involved  in 
intermodal operations242.  

242  Currently  the  WD  Directive  allows  a  maximum  GVCW  of  up  to  46  tonnes  for  ZE  HDV  involved  in  intermodal 
transport operations. 

114 

 
 
                                                 
Those  Member  States  which  already  allow  the  circulation  of  HDV  of  up  to  44  tonnes  will  be 
allowed to  continue to  do so during a transition  period also  in  cross-border traffic, as enabled by 
PMc4. The transition period will finish in 2035 to allow sufficient adaptation time for operators to 
be able to renew their fleet.  

Adjustment costs savings for transport operators 

As indicated in the discussion on PMc1, given that diesel engines are heavier (and considering also 
a standard tank capacity of 1,000 litre), BEV with 5-6 tonne batteries are estimated to be 4 tonnes 
heavier than diesel vehicles. As indicated for PMc1, the increase of battery energy density due to 
technology progress is  expected to lead to “weight parity” between diesel and BEV by 2030 (i.e. 
batteries  of  3  tonnes  and  GVW  of  42  tonnes  as  under  the  current  directive).  While  longer  term 
projections  on  energy  density  are  scarce  and  divergent,  the  following  assumptions  were  made:  a 
1000 kWh battery  will weigh 2.2 tonnes in  2040 (energy  density:  450  Wh/kg) and 1.7 tonnes  by 
2050  (energy  density:  600  Wh/kg).  This  would  bring  a  payload  bonus  of  2  tonnes  by  2030,  3.8 
tonnes  by  2040  and  4.3  tonnes  by  2050.  With  the  maximum  GVW  maintained  at  44t,  these 
reductions in battery weigh over time will provide a bonus in loading capacity as shown in Table 
38. 

Table 38: Assumptions on technology evolution and its impact on payload capacity under PM1, tonnes 

BEV battery weight in the baseline 
BEV weight difference to ICE vehicles 
BEV payload bonus under PM1 with respect to BEV in the baseline  
BEV payload bonus with respect to ICE vehicles under PM1 
FCEV tank/fuel cell system weight in the baseline 
FCEV weight difference to ICE vehicles 
FCEV payload bonus under PM1 with respect to FCEV in the baseline  
FCEV payload bonus with respect to ICE vehicles under PM1 
Source: TML et al. (2023), impact assessment support study 

2025 
6 
4 
2 
0 
0.8 
1.3 
2.7 
2.7 

2030 
4 
2 
2 
2 
0.6 
1.0 
2.7 
3.0 

2035 
3 
1 
2 
3 
0.4 
0.9 
2.7 
3.1 

2040 
2.2 
0.2 
2 
3.8 
0.3 
0.8 
2.7 
3.2 

2050 
1.7 
-0.3 
2 
4.3 
0.2 
0.7 
2.7 
3.3 

The  payload  bonus  for  FCEV  would  be  larger  in  the  initial  years  than  for  BEV.  According  to 
Ballard (2022)243, FCEV with a 150 kWh battery (weighing 820 kg at 180 Wh/kg) and 80kg of H2 
storage are around 1.3 tonnes heavier than an equivalent diesel vehicle. With a 4 tonne general ZEV 
exemption, they would have a payload bonus of 2.7 tonnes  in 2025, which would increase to 3.3 
tonnes in 2050 (see Table 38). It is assumed that there is no evolution in the weight of the hydrogen 
tanks over time. As discussed for PMc1, only the weight constrained BEV and volume constrained 
FCEV  will  benefit  from  this  measure.  In  addition,  the  lifetime  of  trucks  is  taken  into  account  to 
obtain the actual effect of PM1 in terms of payload capacity over the fleet of vehicles as a whole.   

PM1 would result in an increase in the transport activity (expressed in tonne-kilometres) performed 
by ZEV vehicles. The increase in the average payload is expected to lead to a decrease in the costs 
per tonne-kilometre for international transport as well as to a reduction in total transport activity in 
vehicle-kilometres  and  the  number  of  trips.  As  a  consequence,  PM1  leads  to  adjustments  costs 
savings  for  transport  operators  (Table  39)  relative  to  the  baseline  estimated  at  EUR  3.9  billion, 
expressed as present value over 2025-2050. 

243 Ballard (2022), Fuel Cell Trucks / Weights & Dimensions Directive. 

115 

 
 
  
                                                 
Table 39: Impacts of PM1 on transport operators relative to the baseline 

Decrease in total transport activity in vkm (million) 
Reduction in the number of trips (million) 
Increase in ZEV transport activity (tkm million) 
Adjustment costs savings (EUR million, 2022 prices) 
Source: TML et al. (2023), impact assessment support study 

Adjustment costs for public authorities  

2030 

18.7 
91.3 
4,475.2 
78.8 

2040 

2050 

172.3 
845.2 
7,276.7 
294.7 

336.1 
1,639.1 
6,607.5 
485.6 

The heavier a truck the quicker the infrastructure is damaged and need maintenance. On the other 
hand, the fewer vehicles (i.e. trips) the lower the damage. Under PM1, the  former  effect is larger 
than the latter and the measure is thus expected to result in additional costs for the maintenance of 
road  infrastructure.  Overall,  the  adjustment  costs  for  public  authorities  relative  to  the  baseline  in 
2030, 2040 and 2050 are provided in  Table 40. Expressed as present  value over 2025-2050, they 
are estimated at EUR 4.2 billion relative to the baseline. 

Table 40: Impacts of PM1 on public authorities relative to the baseline 

Adjustment costs for public authorities (EUR million, 2022 prices) 
Source: TML et al. (2023), impact assessment support study 

2030 

67.8 

2040 
333.1 

2050 

543.8 

PM2:  Align  the  definition  of  intermodal  transport  with  the  Combined  Transport  Directive  (to 
include all intermodal loading units) 

The  current  directive  granted  an  additional  GVW  of  2  or  4  tonnes  for  containerised  transport 
involved in intermodal transport (depending on the axle configuration). PM2 extends this additional 
allowance to non-containerised intermodal transport244. When vehicles are alternatively-fuelled or 
zero-emission they  also  benefit from  the  extra weight  allowance  envisaged in  the W&D (1 tonne 
and  2  tonnes,  respectively).  PM2  will  thus  result  in  a  maximum  GVW  of  these  vehicle 
combinations  of  between  42  and  46  tonnes  depending  on  the  axle  configuration  and  the  type  of 
fuel. 

Adjustment costs savings for transport operators 

About half of the Member States already allow 44t for semitrailers in national traffic, therefore this 
measures will only affect the 13 Member States that do not yet allow 44t HDVs: Austria, Bulgaria, 
Greece,  Croatia,  Germany,  Latvia,  Lithuania,  Hungary,  Poland,  Romania,  Slovenia,  Slovakia, 
Estonia245.  

This measure is expected to affect palletised and pre-slung goods, which are the ones most suitable 
to be transported in trailer/semitrailers. PM2 is expected to work through two channels: on the one 
hand, transport of more than 300 km which could shift to intermodal and, on the other, transport of 
less  than  150  km  which  corresponds  to  the  road  leg  or  last  mile  transport  of  current  intermodal 
transport operations (as well as new “last mile” traffic induced from the shift to intermodal).  

244 This refers to transport where lorry, trailer, semi-trailer are the intermodal loading units. 
245  Cyprus  and  Malta  are  also  in  the  group  of  Member  States  currently  not  allowing  44t  for  intermodal  transport. 
However, given their insularity and size, this measure is not relevant for them. 

116 

 
 
  
  
                                                 
According  to  Eurostat,  about  1,700  million  tonnes  of  palletised  and  pre-slung  goods  were 
transported  by  road  in  the  concerned  Member  States  in  2021,  of  which  850  million  tonnes  were 
transported on distances smaller than 150 km and 530 million tonnes on distances larger than 300 
km (Table 41).  

Table 41: Total transport vs. palletised and pre-slung goods transported on road in 2021 (million) 

Member 
State 

Total Transport 

Tonnes 

vkm 

tkm 

Austria 
Bulgaria 
Croatia 
Estonia 
Germany  
Greece 
Hungary 
Latvia 
Lithuania 
Poland 
Romania 
Slovakia 
Slovenia 
Total (13) 
p.m. EU27 
Source: Eurostat (road_go_ta_tcrg) 

403.5 
162.5 
86.5 
28.9 
3,108.0 
271.0 
242.2 
86.4 
113.1 
1,580.5 
307.4 
154.8 
98.9 
6,643.6 
12,547.3 

2,112 
2,131 
897 
320 
23,068 
1,519 
2,576 
1,356 
3,769 
26,560 
4,168 
3,108 
1,739 
73,323 
134,254 

26,296 
35,176 
13,632 
5,212 
296,136 
21,061 
36,887 
14,973 
57,729 
379,838 
61,845 
30,129 
24,948 
1,003,862 
1,758,184 

Tonnes 
67.0 
45.8 
24.0 
6.1 
756.2 
46.4 
77.5 
23.2 
65.6 
440.3 
88.8 
47.4 
33.2 
1,721.7 
3,482.3 

Total 
vkm 

884 
1,509 
539 
174 
10,130 
616 
1,504 
481 
3,003 
13,077 
3,062 
1,701 
1,206 
37,886 
72,602 

tkm 

9,583 
24,513 
7,702 
2,433 
118,120 
9,175 
19,561 
6,309 
46,648 
178,698 
44,406 
18,184 
16,385 
501,717 
880,019 

Palletised and pre-slung 
Up to 150 Km 
vkm 

More than 300 Km 
vkm 

tkm 

Tonnes 
45.6 
14.2 
10.4 
2.4 
467.8 
27.1 
40.0 
14.9 
9.3 
163.0 
27.8 
20.7 
10.2 
853.4 
1,815.3 

266 
93 
78 
17 
2,657 
151 
218 
59 
73 
1,108 
156 
208 
68 
5,152 
11,573 

tkm 
2,030 
807 
522 
134 
24,253 
1,291 
2,084 
910 
695 
9,315 
1,768 
1,128 
648 
45,585 
95,309 

Tonnes 
9.4 
22.5 
8.6 
2.0 
129.8 
9.4 
21.2 
5.4 
47.2 
197.6 
46.8 
18.1 
18.3 
536.3 
998.5 

376 
1,254 
378 
127 
4,537 
338 
1,012 
368 
2,762 
10,491 
2,670 
1,263 
1,054 
26,630 
47,926 

5,098 
21,783 
6,079 
1,973 
62,025 
6,027 
14,198 
4,801 
43,961 
152,450 
39,564 
15,375 
14,765 
388,099 
653,660 

Table 42: Shares of palletised and pre-slung goods transported on road in total transport, in 2021 

Member 
State 

Total Transport 

vkm 

tkm 

Tonnes 
404 
162 
86 
29 
3,108 
271 
242 
86 
113 
1,581 
307 
155 
99 
6,644 
12,547 

Austria 
Bulgaria 
Croatia 
Estonia 
Germany  
Greece 
Hungary 
Latvia 
Lithuania 
Poland 
Romania 
Slovakia 
Slovenia 
Total (13) 
p.m. EU27 
Source: Eurostat (road_go_ta_tcrg) 

2,112 
2,131 
897 
320 
23,068 
1,519 
2,576 
1,356 
3,769 
26,560 
4,168 
3,108 
1,739 
73,323 
134,254 

26,296 
35,176 
13,632 
5,212 
296,136 
21,061 
36,887 
14,973 
57,729 
379,838 
61,845 
30,129 
24,948 
1,003,862 
1,758,184 

Tonnes 
16.6% 
28.2% 
27.8% 
21.2% 
24.3% 
17.1% 
32.0% 
26.9% 
58.0% 
27.9% 
28.9% 
30.6% 
33.6% 
25.9% 
27.8% 

Total 
vkm 
41.9% 
70.8% 
60.1% 
54.4% 
43.9% 
40.6% 
58.4% 
35.5% 
79.7% 
49.2% 
73.5% 
54.7% 
69.4% 
51.7% 
54.1% 

Palletised and pre-slung 
Up to 150 Km 

tkm 
36.4% 
69.7% 
56.5% 
46.7% 
39.9% 
43.6% 
53.0% 
42.1% 
80.8% 
47.0% 
71.8% 
60.4% 
65.7% 
50.0% 
50.1% 

Tonnes 
11.3% 
8.7% 
12.1% 
8.4% 
15.1% 
10.0% 
16.5% 
17.3% 
8.2% 
10.3% 
9.0% 
13.4% 
10.3% 
12.8% 
14.5% 

vkm 
12.6% 
4.4% 
8.7% 
5.3% 
11.5% 
9.9% 
8.5% 
4.4% 
1.9% 
4.2% 
3.7% 
6.7% 
3.9% 
7.0% 
8.6% 

tkm 
7.7% 
2.3% 
3.8% 
2.6% 
8.2% 
6.1% 
5.6% 
6.1% 
1.2% 
2.5% 
2.9% 
3.7% 
2.6% 
4.5% 
5.4% 

More than 300 Km 
vkm 
17.8% 
58.8% 
42.1% 
39.7% 
19.7% 
22.3% 
39.3% 
27.1% 
73.3% 
39.5% 
64.1% 
40.6% 
60.6% 
36.3% 
35.7% 

Tonnes 
2.3% 
13.8% 
10.0% 
6.9% 
4.2% 
3.5% 
8.7% 
6.2% 
41.7% 
12.5% 
15.2% 
11.7% 
18.5% 
8.1% 
8.0% 

tkm 
19.4% 
61.9% 
44.6% 
37.9% 
20.9% 
28.6% 
38.5% 
32.1% 
76.2% 
40.1% 
64.0% 
51.0% 
59.2% 
38.7% 
37.2% 

Cargo transported on distances longer than 300 km. The extra allowance of 4 tonnes represents an 
increase  by  16%  in  the  load  capacity  with  respect  to  the  current  levels246;  after  considering  the 
increase in energy consumption, this translates into 11.6% decrease in operational costs per tonne. 
This  measure  would  impact  only  weight  restricted  cargo,  according  to  McKinnon,  CNT  and 
Panteia. Therefore, PM2 is expected to entail a shift of 2.2% of palletised and pre-slug transport on 
distances longer than 300 km from road-only to intermodal transport.  

Cargo transported on distances below 150 km. The (semi)trailers currently involved in intermodal 
transport will also benefit from the operational costs savings. 

Taking  into  account  all  these  elements,  PM2  leads  to  adjustments  costs  savings  for  transport 
operators  (Table  43)  relative  to  the  baseline  estimated  at  EUR  21.9  billion,  expressed  as  present 
value over 2025-2050. 

246 Maximum load capacity for 40t trailers and semitrailers is estimated in 25t on average.  

117 

 
 
                                                 
Table 43: Impacts of PM2 on transport operators relative to the baseline 

Shift from unimodal road to intermodal transport (billion tonne-kilometres) 

Total decrease in road transport activity (million vehicle-kilometres) 

Adjustment costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study 

Adjustment costs savings for public authorities  

2030 

2040 

2050 

9.4 

10.5 

11.8 

535.9 

595.3 

667.5 

1,160.2 

1,233.9 

1,303.6 

As PM2 will lead to a reduction in the total road transport activity in vkm, the maintenance costs 
for infrastructure are expected to decrease relative to the baseline. Overall, adjustment costs savings 
for  public  authorities  relative  to  the  baseline  are  estimated  at  EUR  312.9  million,  expressed  as 
present value over 2025-2050 (see also Table 44). 

Table 44: Impacts of PM2 on public authorities relative to the baseline 

Adjustment costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study 

2030 
16.0 

2040 
17.6 

2050 
19.5 

PM3: Allow international (intra-EU) transport of EMS1 at least in the core and comprehensive 
TEN-T network conditioned to be ZEV or part of an intermodal transport operation 

PM3 allows the circulation of EMS of up to 25.25m long and 60 tonnes of GVW in international 
traffic  in  all  Members  States  within  the  TEN-T  network.  This  is  conditional  on  the  EMS  being 
either zero-emission vehicles or vehicles involved in an intermodal transport operation.  

Adjustment cost savings for transport operators 

The  main  benefits  to  transport  operators  from  PM3  will  come  from  the  extra  payload  allowed 
through  the  use  of  60t  instead  of  the  standard  vehicles  and  the  subsequent  decrease  in  operating 
costs.  The  reduction  in  costs  of  using  EMS  is  well  established  among  transport  operators247  and 
corroborated  by  the  literature248.  PM3  will  impact  national  and  international  transport  activity  of 
hauliers operating in Member States that currently do not allow EMS. However, hauliers operating 
in Member States that currently allow EMS (“allowing Member States”249) will also be affected as 
regards international traffic as described below. 

The W&D Directive sets the maximum GVW for the heaviest category of vehicles (5- and 6-axle 
HGVs)  at  40t  (42t  for  ZE  HDV  and  44t  for  HDVs  involved  in  intermodal  transport).  However, 
Estonia,  France,  Ireland  and  Italy  allow  higher  weight  limits  as  shown  in  Table  45.  On  the  other 
hand,  all  Member  States  currently  allowing  the  circulation  of  EMS  allow  them  with  a  minimum 
GVW of 60t, with the only exception of Germany (40t) and the Czech Republic (48t) and, in many 

247 ACEA (2019) High Capacity Transport – Smarter Policies for Smart Transport. 
248  Among  others,  ITF  (2019),  “High  Capacity  Transport:  Towards  Efficient,  Safe  and  Sustainable  Road  Freight”, 
International Transport Forum Policy Papers, No. 69, OECD Publishing, Paris. The potential savings of EMS are based 
on  the  ratio  of  standard  trucks  that  could  be  replaced  by  longer  EMS.  According  to  the  HCT  DUO2-project  study, 
standard trucks can be replaced by HCVs at a ratio of 3:2 (for 25.25m EMS1), meaning that 2 EMS can move the same 
amount of goods as 3 standard trucks. 
249  Member  States  allowing  the  circulation  of  EMS  are  Finland,  Sweden,  Denmark,  Germany,  the  Netherlands, 
Belgium, Czechia, Spain and Portugal. 

118 

 
 
 
 
                                                 
cases  in  international  traffic  subject  to  bilateral  agreements250.  For  the  allowing  Member  States, 
with  the  exception  of  Germany  and  Czechia,  PM3  will  not  change  this  allowance.  Among  the 
allowing  Member  States  Finland  and  Sweden  currently  allow  vehicles  heavier  than  60t  in  cross-
border  transport  and  therefore,  under  PM3,  the  maximum  allowed  GVW  will  decrease  in 
international  traffic  between  these  two  Member  States  following  a  transition  period  up  to  2035.  
The national operations in the allowing Member States will not change. The change in payload per 
vehicle stemming from PM3 is summarised in Table 45251. Hauliers operating in allowing Member 
States  will  be  able  to  extend  their  operations  to  international  traffic  without  a  limitation  in  the 
number of borders crossed and to any other Member State.  

Table 45: Additional payload by vehicle when using EMS to replace standard trucks 

Member 
State 

Maximum GVW (t) 

Currently 

EMS (under PM3) 

Increase in 
payload 
per vehicle 

40 
60 
40 
48 
40 
60 
44 
40 
60 
76 
44 
40 
40 
46 
56 
40 
44 
40 
60 
40 
60 
40 
64  
40 
40 

50% 
AT 
0% 
BE 
50% 
BG 
25% 
CZ 
50% 
DE 
0% 
DK 
36% 
EE 
50% 
EL 
0% 
ES 
-21%* 
FI 
36% 
FR 
50% 
HR 
50% 
HU 
30% 
IE 
7% 
IT 
50% 
LT 
36% 
LU 
50% 
LV 
0% 
NL 
50% 
PL 
0% 
PT 
50% 
RO 
-6%* 
SE 
50% 
SI 
SK 
50% 
Notes: * A transition period till 2035 is foreseen for transport between FI and SE. The decrease in payload follows this 
transition period (post-2035). Within FI and SE the original maximum GVW will prevail.  In Sweden, 74t are allowed 
in a trial. In Germany, the maximum allowed GVW goes up to 44t in intermodal transport and 46 tonnes in intermodal 
transport with ZEV. International road traffic for Cyprus and Malta is not considered possible and therefore excluded 
from the calculations.  
Source: TML et al. (2023), impact assessment support study 

60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 
60 

Operators from Member States already allowing the circulation of EMS will also benefit from PM3 
beyond the savings stemming from PMc4. First, operators will be able to drive through all Member 

250 Cross-border traffic of EMS under bilateral agreements is currently allowed between Finland and Sweden, Sweden 
and Denmark, Germany and the Netherlands, and the Netherland and Belgium. 
251  The  use  of  25.25m  EMS  would  significantly  increase  the  volume  compared  to  standard  trucks;  therefore,  the 
additional payload could be even larger for volume constraint goods. However, for the purpose of calculating operating 
costs savings, a conservative increase in payload as presented in the table has been used. 

119 

 
 
                                                 
States  without  the  restriction  of  being  an  “allowing”  Member  State  (as  under  PMc4)  or  having  a 
bilateral agreement, as it is currently the case. This offers potential for the optimisations of routes 
and increases the geographical scope of operations. Secondly, they will be able to use 60t vehicles 
across the whole EU and will not be subject to the “minimum common denominator” anymore. 

On  the  other  hand,  PM3  also  entails  some  restrictions  with  respect  to  the  current  situation. 
International operations will be limited to EMS that are either ZEV or are involved in an intermodal 
transport operation. This is expected to result in a reduction in transport costs per tonne kilometre 
due to the increased payload. EMS that are not ZEV or involved in intermodal transport will not be 
allowed to operate cross-border. However, those Member States which already allow the circulation 
of EMS will be allowed to continue to do so during a transition period also in cross-border traffic, 
as enabled by PMc4. The transition period will finish in 2035 to allow sufficient adaptation time for 
operators to be able to renew their fleet. 

The reduction of operating costs will generate a modal shift from rail and inland navigation to road 
transport. This is estimated using the price elasticity of demand presented in section 1 of Annex 4. 

Taking  into  account  all  these  elements,  Table  46  and  Table  47  summarise  the  effect  of  PM3  in 
terms of transport activity by type of truck.  

Table 46: Decrease in transport activity due to PM3 relative to the baseline, in thousand vkm  

Number of axles 
4 
5 
6 
Total 

2025 

2030 

2040 

2050 

0.0 
6.2 
181.5 
187.7 

0.0 
41.1 
231.5 
272.6 

0.0 
86.0 
464.4 
550.5 

0.0 
144.7 
749.1 
893.7 

Source: TML et al. (2023), impact assessment support study 

Table 47: Increase in transport activity due to PM3 relative to the baseline, in thousand tonnes 

Number of axles 
4 
5 
6 
Total 

2025 

2030 

0.0 
-2,642.4 
24,214.7 
21,572.3 

0.0 
-6,242.5 
41,435.0 
35,192.5 

2040 

0.0 
-11,369.3 
96,170.0 
84,800.7 

2050 

0.0 
-17,236.0 
164,828.9 
147,592.9 

Source: TML et al. (2023), impact assessment support study; Note: negative values represent a decrease.  

Overall, PM3 is estimated to generate adjustments costs savings for transport operators (Table 48) 
relative to the baseline estimated at EUR 9.7 billion, expressed as present value over 2025-2050.  

Table 48: Impacts of PM3 on transport operators relative to the baseline 

2030 

2040 

2050 

in 

  35,193 

total  volume  -  number  of  tonnes 

Increase 
(thousand) 
Decrease in total transport activity in vkm (million) 
Reduction in the number of trips (million) 
Shift  from  unimodal  road  to  intermodal  transport 
(billion tonne-kilometres)   
Adjustment  costs  savings  (EUR  million,  2022 
prices) 
Source: TML et al. (2023), impact assessment support study; Note: In terms of impact on the shift from unimodal road 
to  intermodal  transport  the  estimates  provided  here  take  into  account  the  synergies  between  PM3  and  PM2  (both 
included in PO-C).  

272.6 
1,316.9 
11.0 

550.5 
2,524.1 
12.2 

893.7 
3,927.6 
13.7 

  147,593 

  84,801 

1,196.2 

648.6 

265.8 

120 

 
 
  
Administrative costs for public authorities 

Inspections will be needed to assess the suitability of the infrastructure to accommodate EMS. In 
case specific elements of the infrastructure are considered not suitable for EMS circulation, this will 
lead to the need of reinforcement (see below).  The costs related to the inventory of infrastructure 
are included under PMc2. The inspection costs are estimated at EUR 0.5 million per Member State, 
for the Member States that currently do not allow EMS. The one-off administrative costs for public 
authorities due to PM3 are estimated at EUR 9 million relative to the baseline.  

Adjustment costs savings for public authorities  

In principle, PM3 would generate adjustment costs for public authorities related to the maintenance 
of  infrastructure  except  in  those  Member  States  that  are  currently  allowing  60t  EMS  or  heavier. 
These are, in general, linked to the increase in the maximum total weight of vehicle combinations 
(and their length). However, in PM3 this increase in weight is outweighed by the decrease in the 
transport  activity  in  vkm.  Thus,  PM3  leads  to  costs  savings  related  to  the  maintenance  of 
infrastructure.  

Under current rules and considering PMc1, 46t HDV are already allowed to circulate across the EU 
territory in national and international transport. Therefore, the impact in terms of maintenance costs 
is already included in the estimates for PMc1.  Under PM3, only the additional maintenance costs 
are calculated. The adjustment costs savings related to road maintenance relative to the baseline, are 
estimated at EUR 459.3 million, expressed as present value over 2025-2050 (in 2022 prices).  

Table 49: Impacts of PM3 on adjustment costs savings for public administrations relative to the baseline 

Reduction in transport activity in vkm (million) 

Adjustment costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study 

Adjustment costs for public authorities  

2025 

2030 

2040 

2050 

187.7 

272.6 

550.5 

893.7 

13.0 

16.0 

30.3 

46.0 

Based  on  the  experience  of  the  MS  currently  allowing  EMS,  the  main  elements  impacting  the 
infrastructure relate to the extra length of EMS, namely manoeuvrability and visibility, particularly 
in  parking  areas  and  roundabouts.  The  increase  in  total  weight  may  pose  issues  as  regards  old 
bridges as explained in PMc1. However, this usually affects secondary roads while PM3 is limited 
to the TEN-T network where bridges are designed and maintained to higher standards. The critical 
weight  parameter  affecting  the  infrastructure  is  the  axle-weight,  which  will  remain  the  same  or 
decrease due to the addition of axles of EMS. 

The need for adapting specific elements of the infrastructure will be the outcome of the inspections, 
discussed above. A number of Member States252 have already undertaken such inspections. Based 
on this information, the adaptation costs per km of the road infrastructure to the dimensions of EMS 
(e.g. upgrading of roundabouts, adaptation of acceleration and deceleration lanes to enter and exit a 
motorway  and  provision  of  adequate  parking  spaces)  was  estimated  at  EUR  10,000  per  km.  By 
extrapolating  to  all  the  affected  Member  States253,  the  one-off  adjustment  costs  are  estimated  at 

252 Sweden, Denmark, Germany. 
253  The  analysis  for  Germany  was  used  as  starting  point.  Lippold  &  Schemmel  (2017),  Parking  at  rest  areas  with 
vehicles and oversize vehicle combinations. 

121 

 
 
  
                                                 
EUR  727  million.  In  addition,  the  one-off  adjustment  costs  for  the  reinforcement  of  bridges  are 
estimated at EUR 6.9 billion254. Thus, the total one-off adjustment costs for public authorities are 
estimated at EUR 7.6 billion for PM3. 

PM4: Set minimum administrative and safety requirements for the transport of indivisible loads 

The  transport  of  an  indivisible  load255  requiring  longer  HDVs  and  specific  safety  measures  is 
subject  to  the  issuance  of  special  permit  for  each  trip,  which  include  elements  such  as  vehicle 
escorts, allowed time frames, authorised speeds, etc. Different countries and regions have different 
rules and procedures in place for obtaining such permits.  

PM4 aims at harmonising the requirements and procedures for issuing such national permits. PM4 
envisages  the  implementation  of  some  of  the  recommendations  of  the  European  Best  Practice 
Guidelines (BPG) for abnormal road transport256. Namely, the one-stop-shop principle at national 
level  for  the  submission  of  applications,  the  implementation  of  a  harmonised  abnormal  road 
transport application form (where only the language of the application form vary between Member 
States),  the  mutual  acceptance  between  Member  States  and  the  setting  of  a  Special  European 
Registration  of  Trucks  and  Trailers  (SERT)257.  The  full  digitalisation  of  the  system  will  allow  to 
interconnect  national  databases.  For  this,  technical  and  operational  standards  for  information 
exchange will need to be established. 

Administrative cost saving for transport operators 

Currently,  11  Member  States  already  apply  (fully  or  partially)  the  one-stop  shop  principle  for 
granting  permits for the transport of indivisible loads.  In the  rest  of Member States, the principle 
has not been applied so far (7 Member States) or the actual situation has not been communicated (9 
Member States). For the Member States where the actual situation has not been communicated, for 
the  purpose  of  the  calculations,  it  has  been  assumed  that  they  partially  apply  the  one-stop  shop 
principle. In addition, SERT is currently only adopted in the Netherlands but accepted in five other 
Member States. See Table 50 for details. 

For  transport  operators,  PM4  will  lead  to  time  savings.  The  time  needed  to  prepare  the  request, 
physically  submit  it  (possibly  at  multiple  locations)  and  to  fetch  the  permit  will  be  reduced.  The 
introduction  of  the  one-stop-shop  principles  entails  the  appointment  of  a  single  authority  per 
Member  State  to  handle  the  permit  requests.  The  procedures  would  be  then  transparent  to  the 
applicants, which only have to deal with one authority, providing them with clarity and facilitating 
the administrative process. Based on the literature review and the consultation activities258, the time 
currently  needed  is  estimated  at  4  hours  for  Member  States  with  no  one-stop  shop  in  place,  3.5 

254  Effects  of  adapting  the  rules  on  weights  and  dimensions  of  heavy  commercial  vehicles  as  established  within 
Directive 96/53/EC. 
255  Article  2  of  Council  Directive  96/53/EC  defines  an  indivisible  load  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 the 
W&D Directive in all respects.” 
256 European Best Practice Guidelines for abnormal road transport. 
257  The  SERT  provides  national  authorities,  in  a  single  document  or  database,  the  detailed  technical  information 
necessary to assess the compatibility of a vehicle with the specific requirements of the abnormal road transport that is 
not available on the registration certificate. 
258  COWI  (2021),  ESTA  economic  impact  assessment  2013,  interview  with  ESTA  (European  association  abnormal 
road transport and mobile cranes). 

122 

 
 
                                                 
hours for Member States with partial one-stop shops in place and 3 hours for Member States with 
physical one-stop shops in place. In the baseline scenario, due to digitalisation this is projected to 
go down to 3 hours from 2035 onwards for Member States with no one-stop shop in place, to 2.5 
hours for Member States with partial one-stop shops in place and to 2 hours for Member States with 
one-stop shops in place. For Member States with no one-stop shop in place, the introduction of a 
digital one-stop shop is expected to reduce the time needed by transport operators for preparing and 
submitting the request by 2 hours until 2035 and by 1 hour from 2035 onwards. For Member States 
with  a  partial  one-stop  shop  in  place,  the  introduction  of  a  digital  one-stop  shop  is  expected  to 
reduce the time by 1.5 hours until 2035 and by 0.5 hours from 2035 onwards. For Member States 
with  a  physical  one-stop  shop  in  place,  the  introduction  of  a  digital  one-stop  shop  is  expected  to 
reduce the time by 1 hour by 2035. The introduction of SERT will further reduce the time needed 
for preparing and submitting the request to 1 hour. Depending on the initial system in place in each 
Member  State,  the  time  savings  per  permit  for  transport  operators  due  to  PM4  relative  to  the 
baseline are provided in Table 50.  

Table 50: Time savings per permit for transport operators due to PM4 relative to the baseline  

Member State 

SERT 

One-stop-
shop 
in place 

Time saved per permit (hours) 

until 2035 

from 2035 onwards 

Adopted 

Accepted 
Yes 
Yes 

Yes 

2.0 
Austria 
1.0 
Belgium 
1.5 
Bulgaria 
1.0 
Czechia 
1.0 
Denmark 
1.0 
Germany  
1.5 
Estonia 
2.0 
Ireland 
1.5 
Greece 
1.0 
Spain 
2.0 
France 
1.5 
Croatia 
2.0 
Italy 
1.5 
Cyprus 
1.5 
Latvia 
1.5 
Lithuania 
1.0 
Luxembourg 
1.5 
Hungary 
1.5 
Malta 
0.0 
Netherlands 
1.0 
Poland 
1.0 
Portugal 
2.0 
Romania 
1.0 
Slovenia 
1.5 
Slovakia 
2.0 
Finland 
Sweden 
2.0 
Source: COWI & TRT (2021). Study on the Implementation of the Weights and Dimension Directive, Final report, and 
TML et al. (2023), impact assessment support study. 

No 
Yes 
n.a. 
Yes 
Yes 
Yes 
n.a. 
No 
n.a. 
Yes 
No 
n.a. 
No 
n.a. 
n.a. 
n.a. 
Yes 
Partially 
n.a. 
Yes 
Yes 
Yes 
No 
Yes 
n.a. 
No 
No 

3.0 
2.0 
2.5 
2.0 
2.0 
2.0 
2.5 
3.0 
2.5 
2.0 
3.0 
2.5 
3.0 
2.5 
2.5 
2.5 
2.0 
2.5 
2.5 
1.0 
2.0 
2.0 
3.0 
2.0 
2.5 
3.0 
3.0 

Yes 

Yes 

Yes 

Yes 

Following  the  consultation  activities,  seven  Member  States  have  communicated  the  number  of 
permits  they  issued  in  2021.  Those  amounted  in  total  to  460  thousand  permits  or  24  permits  for 

123 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
every  100  trucks  in  their  stock  (see  Table  51).  This  ratio  was  used  to  estimate  the  number  of 
permits issued in the rest of Member States.  

Table 51: Permits issued for the transport of indivisible loads in 2021 
Member State 
Germany 
Spain 
Hungary 
Latvia 
Poland 
Finland 
Sweden 
Total 
Source: TML et al. (2023), impact assessment support study 

Permits 

369,918 
24,940 
2,700 
2,488 
15,305 
10,000 
34,651 
460,002 

The number of permits  has been  assumed to  grow over time in  line with  the vehicle stock in  the 
baseline. To estimate the costs savings for transport operators due to PM4, the tariffs per hour from 
the Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs 
(i.e. ISCO 3 – Technicians and associate professionals) have been used (EUR 34 per hour in 2022 
prices). Based on the estimated number of permits and the time saved  for requesting the permits, 
the  administrative  costs  savings  for  transport  operators  are  provided  in  Table  52.  Expressed  as 
present value over 2025-2050, they are estimated at EUR 1.2 billion relative to the baseline. 

Table 52: Impacts of PM4 on administrative cost savings for transport operators relative to the baseline 

Total number of permits 

2025 

2030 

2040 

2050 

1,025,053 

1,111,787 

1,327,348 

1,549,879 

Administrative costs savings (EUR million) 

75.8 

81.5 

55.0 

64.1 

Source: TML et al. (2023), impact assessment support study 

For the purpose of the application of the ‘one in, one out’ approach, the annual average cost saving per 
permit over 2025-2035 has been estimated at EUR 64.1. Considering the average number of permits over 
2025-2035, estimated at 1.12 million, the average annual cost savings are estimated at EUR 71.8 million. 

The waiting time to obtain a permit will also be reduced. According BPG, in 2005 the waiting time 
went from two working days up to two months. While a waiting time of 5 up to 15 working days is 
considered  to  be  acceptable,  depending  on  how  many  road  authorities  need  to  intervene,  even 
assuming  some  reduction  in  the  waiting  time  since  2005  PM4  should  further  reduce  the  waiting 
time per permit application. This was however not possible to monetise. 

Adjustment costs for public authorities 

The  introduction  of  the  one-stop-shop  concept  will  require  national  procedures  to  be  adapted  to 
handle permission requests across all authorities involved within each Member State. Each Member 
States  shall  appoint  a  single  authority  to  handle  the  permission  request.  The  single  authority  will 
also  be  in  charge  of  internally  involving  other  national  or  regional  competent  authorities.  The 
application process  should be digital  by default,  and therefore PM4 shall be based on  an  IT tool. 
The development of the IT tool and the implementation phase (e.g. staff training) will entail one-off 
costs. Recurrent annual maintenance costs are also to be expected. They are discussed below under 
administrative costs.  

124 

 
 
  
The one-off costs would  be independent of the number of permits  granted per  year in  a Member 
State, but will depend on the current system in place in each Member State. The one-off costs have 
been estimated using the assumptions based on COWI & TRT (2021) as follows: 
-  Full  development  of  a  one-stop  shop  system,  including  the  introduction  of  SERT:  EUR 

1,000,000. 

-  Additional costs for a partially developed one-stop shop system: EUR 700,000. 
-  Introduction of SERT: EUR 400,000 for a one-stop shop system already in place. 
-  Adaptation of the system for the exchange of information with other MSs: EUR 200,000 for a 

one-stop shop system and SERT already in place. 

Table 53: National implementation of the one-stop-shop principle 

Accepted 
Yes 
Yes 

Member State 

SERT 

Adopted 

One-stop-shop 
in place 

One-off 
costs 
EUR million 

Yes 

1.0 
Austria 
0.4 
Belgium 
0.7 
Bulgaria 
0.4 
Czechia 
0.4 
Denmark 
0.4 
Germany  
0.7 
Estonia 
1.0 
Ireland 
0.7 
Greece 
0.4 
Spain 
1.0 
France 
0.7 
Croatia 
1.0 
Italy 
0.7 
Cyprus 
0.7 
Latvia 
0.7 
Lithuania 
0.4 
Luxembourg 
0.7 
Hungary 
0.7 
Malta 
0.2 
Netherlands 
0.4 
Poland 
0.4 
Portugal 
1.0 
Romania 
0.4 
Slovenia 
0.7 
Slovakia 
1.0 
Finland 
1.0 
Sweden 
Total EU27 
17.8 
Source: COWI & TRT (2021). Study on the Implementation of the Weights and Dimension Directive (Final report) and 
TML et al. (2023), impact assessment support study 

No 
Yes 
n.a. 
Yes 
Yes 
Yes 
n.a. 
No 
n.a. 
Yes 
No 
n.a. 
No 
n.a. 
n.a. 
n.a. 
Yes 
Partially 
n.a. 
Yes 
Yes 
Yes 
No 
Yes 
n.a. 
No 
No 

Yes 

Yes 

Yes 

Yes 

Taking into account all these elements, the one-off costs related to the implementation of the new 
systems are estimated at EUR 17.8 million (in 2022 prices). 

125 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Administrative costs for public authorities 

The recurrent annual costs related to the maintenance and management of the systems are estimated 
at  5%  of  development  costs259.  They  are  estimated  at  EUR  0.89  million  per  year  from  2025 
onwards. Expressed as present value over 2025-2050, the administrative costs for public authorities 
are estimated at EUR 16.4 million.  

Administrative costs savings for public authorities 

Based  on  the  literature  review  and  the  consultation  activities260,  the  time  currently  needed  for 
processing a permit request by public authorities261 is estimated at 4 hours for Member States with 
no one-stop shop in place, 3.5 hours for Member States with partial one-stop shops in place and 3 
hours  for  Member  States  with  physical  one-stop  shops  in  place.  In  the  baseline  scenario,  due  to 
digitalisation this is projected to go down to 3 hours from 2035 onwards for Member States with no 
one-stop shop in place, to 2.5 hours for Member States with partial one-stop shops in place and to 2 
hours for Member States with one-stop shops in place. For Member States with no one-stop shop in 
place,  the  introduction  of  a  digital  one-stop  shop  is  expected  to  reduce  the  time  needed  for 
processing the request by 2 hours until 2035 and by 1 hour from 2035 onwards. For Member States 
with  a  partial  one-stop  shop  in  place,  the  introduction  of  a  digital  one-stop  shop  is  expected  to 
reduce the time by 1.5 hours until 2035 and by 0.5 hours from 2035 onwards. For Member States 
with  a  physical  one-stop  shop  in  place,  the  introduction  of  a  digital  one-stop  shop  is  expected  to 
reduce the time by  1 hour by 2035. The introduction of SERT  will further reduce the  processing 
time to 1 hour. 

Based  on  the  estimated  number  of  permits  and  the  time  savings  for  processing  the  permits,  it  is 
estimated that  public administrations will save a total  of EUR  1.2 billion relative to  the baseline, 
expressed as present value over the period 2025-2050 (in 2022 prices).  

Table 54: Impacts of PM4 on administrative cost savings for public authorities relative to the baseline 

Total number of permits 

2025 

2030 

2040 

2050 

1,025,053 

1,111,787 

1,327,348 

1,549,879 

Administrative costs savings (EUR million) 

75.8 

81.5 

55.0 

64.1 

Source: TML et al. (2023), impact assessment support study 

Adjustment costs savings for public administrations related to infrastructure 

PM4 is not expected to have an impact on the traffic volumes or the chosen routes, so no significant 
impacts  on  infrastructure  costs  are  expected.  This  being  said,  PM4  is  likely  to  improve  the 
availability of information about constraints  on certain routes and, therefore, to reduce the risk of 

259  These  refer  to  additional  costs  with  respect  to  the  baseline.  The  countries  with  (partial)  systems  in  place  were 
already  incurring  some  maintenance  costs.  This  is  why  the  additional  maintenance  costs  are  proportional  to  the 
additional development costs. 
260  COWI  (2021),  ESTA  economic  impact  assessment  2013,  interview  with  ESTA  (European  association  abnormal 
road transport and mobile cranes). 
261 Processing the permit entails verifying on a case-by-case basis that bridge structures, road tunnels and any other road 
infrastructure on the route can accommodate the transit of the vehicles used. This also includes the cooperation between 
various departments, preparing the approval document, signing and delivering the permit. 

126 

 
 
  
                                                 
damage  to  infrastructure  caused  by  incorrect  route  choices.  Thus,  some  marginal  savings  on 
infrastructure maintenance are to be expected from PM4 although these could not be estimated. 

Adjustment costs for the European Commission 

Technical and operational standards for information exchange will need to be established for PM4. 
This  will be done in  two steps. A study will be carried out  to  compile the required elements  and 
propose several options for the establishment of the standards. In a second stage, an expert group 
will use the findings and assessment of the study to draft the standards. 

The cost of the initial study is estimated at EUR 400,000. The average cost for a two-day workshop 
hosted by European Commission (EC), where participants are reimbursed by the EC is estimated at 
around  EUR  30,000.  Two  of  such  in-person  workshops  may  be  required  as  well  as  two  on-line 
meetings. Therefore, the total one-off adjustment costs for the European Commission are estimated 
at EUR 0.46 million. 

PM5: Set international transport corridors for indivisible loads 

PM5 envisages the creation of corridors across the EU allowing passage rights to the transport by 
road  of  abnormal  loads262,  provided  that  the  corridors  meet  certain  pre-defined  criteria  (e.g. 
minimum  dimensions  and  height).  This  would  implement  the  recommendations  of  the  European 
Best Practice Guidelines (BPG) for abnormal road transport.  

PM5  is  in  line  with  the  current  practice  of  granting  long-term  permits,  for  which  Member  States 
have identified and pre-classified routes for abnormal road transports. The information on the parts 
of  the  road  network  classified  as  adequate  for  the  carriage  of  abnormal  loads  under  certain 
thresholds should be kept up to date and be readily accessible to the stakeholders. 

Administrative cost savings for transport operators 

It is assumed that a permit will continue to be required for all trips as any trip will always begin or 
end outside the TEN-T network. The number of permits in the baseline is assumed to grow in line 
with  the  vehicle  stock.  The  routes  that  are  used  will  not  change  as  restrictions  on  weights  or 
dimensions of vehicles will not change. However, the effect of PM5 will be a reduction of the time 
needed for preparing and submitting the request for the permits. The reduction in the time required 
by  operators  to  prepare  the  permit  request  is  estimated  at  10  minutes  per  permit.  The  projected 
number  of  permits  and  the  administrative  costs  savings  relative  to  the  baseline  are  provided  in 
Table  55.  Expressed  as  present  value  over  2025-2050,  administrative  costs  savings  for  transport 
operators are estimated at EUR 121.9 million (in 2022 prices).  

Table 55: Impacts of PM5 on administrative costs for transport operators relative to the baseline 
2040 

2025 

2030 

Total number of permits (million) 

Administrative costs savings (EUR million) 

Source: TML et al. (2023), impact assessment support study 

1.03 

5.4 

1.11 

5.8 

1.33 

7.0 

2050 

1.55 

8.4 

262 “Loads surpassing the allowed limits” are called abnormal loads by experts. “They include anything from a mobile 
house  and  mobile  crane  to  exceptionally  large  and  heavy  indivisible  loads  such  as  electric  transformers,  chemical 
reactor vessels, airplane fuselage or wings” (BPG). 

127 

 
 
 
  
                                                 
For the purpose of the application of the ‘one in, one out’ approach, the annual average cost saving per 
permit over 2025-2035 has been estimated at EUR 5.3. Considering the average number of permits over 
2025-2035, estimated at 1.12 million, the average annual cost savings are estimated at EUR 5.9 million. 

Administrative cost savings for public administrations 

PM5  is  expected  to  also  reduce  the  time  public  authorities  need  to  process  the  permits.  This  is 
estimated at 10 minutes per permit. The projected number of permits and the administrative costs 
savings for public authorities relative to the baseline are provided in Table 56. Expressed as present 
value over 2025-2050, they are estimated at EUR 121.9 million (in 2022 prices).  

Table 56: Impacts of PM5 on administrative costs for public authorities relative to the baseline 
2040 

2025 

2030 

Total number of permits (million) 

Administrative costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study 

1.03 

5.4 

1.11 

5.8 

1.33 

7.0 

2050 

1.55 

8.4 

PM6: Require a minimum amount of Weigh-in-motion systems to be deployed in the TEN-T 
network  

PM6 mandates the deployment  of Weigh-in-Motion (WIM) systems  every  300  km in the TEN-T 
network263.  Under  this  policy  measure  the  WIM  systems  do  not  need  to  be  certified  for  direct 
enforcement.  They  will  be  used  to  better  target  manual  controls.  This  policy  measure  will  not 
remove  the  need  for  physical  roadside  controls  in  certified  scales  that  will  be  necessary  to 
determine the infractions and to set fines.   

PM6 aims to further enhance the efficiency and effectiveness of controls, contributing to increase 
the level of compliance, by using WIM systems as a filter to pre-identify HDV that are likely to be 
overloaded.  Only  those  pre-identified  vehicles  will  be  stopped  and  submitted  to  a  roadside 
inspection  with  certified  scales,  optimising  the  public  resources  and  reducing  the  unnecessary 
hassle to compliant road operators. The experience from Member States shows an average of 97% 
accuracy of non-certified WIM systems264.  It is expected that the use of this automatic systems will 
decrease substantially the overall number of HDVs checked relative to the baseline. 

This  measure  will  require  some  Member  States  to  install  more  WIM  systems  than  initially 
envisaged  by  them,  as  well  as  an  assessment  of  the  most  adequate  locations  within  the  TEN-T 
network.  Currently,  258  WIM  systems  have  been  installed  in  10  Member  States  as  reflected  in 
Table 57. The remaining Member States are estimated to have installed in their territories the EU 
average proportion of WIM systems per km of TEN-T with a minimum of 1 system per MS. Thus a 
total 296 WIM systems are estimated to have been installed in the TEN-T network in the EU.  

263  MS  are  currently  obliged  to  deploy  WIM  systems  in  the  infrastructure  to,  at  least,  detect  HDV  that  could  be 
overloaded. MS are free to decide where and how many WIM systems to deploy. They can be installed in any part of 
the network. 
264 Antofie et al. (2019), Approach of the Walloon legal Metrology (Belgium)  for  weigh in  motion (WIM) free flow 
direct enforcement. Proceedings of the 8th international conference on weigh in motion. 

128 

 
 
  
 
 
 
                                                 
Table 57: WIM systems deployed in the EU   

Country 

Installed 
WIM 
systems 

Estimated WIM 
systems installed 
(EU average) 

TEN-T 
network (km) 

Number of WIM 
systems required by 
PM6 

Additional WIM 
systems required 
by PM6 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

EU 

30 

14 

8  

29 

107 

15 

16 

3 

6 

30 

1 

1 

1 

1 

7 

1 

3 

7 

1 

6 

1 

1 

1 

1 

1 

3 

1 

1,814.3 

1,844.7 

2,580.2 

445.2 

1,975.9 

11,348.4 

1,624.8 

1,354.7 

4,655.8 

12,030.0 

5,192.0 

14,611.9 

1,572.8 

2,544.9 

2,219.7 

10,706.8 

2,178.5 

90.5 

1,680.2 

117.39 

1,951.2 

7,751.1 

2,822.4 

4,837.9 

6,447.5 

643.2 

1,566.9 

7 

7 

9 

2 

7 

38 

6 

5 

16 

41 

18 

49 

6 

9 

8 

36 

8 

1 

6 

1 

7 

26 

10 

17 

22 

3 

6 

6 

6 

8 

1 

0 

31 

0 

4 

14 

34 

10 

20 

5 

0 

0 

30 

7 

0 

5 

0 

0 

23 

9 

14 

16 

0 

5 

296 

106,609.0 

371 

247 

Source: TML et al. (2023), impact assessment support study. 

Adjustment costs for public administrations  

It is estimated that 247 WIM systems will need to be additionally installed in the TEN-T network. 
PM6 only affects those MS that have not reached the minimum threshold of 1 WIM system every 
300 km as shown in Table 57. The one-off costs per WIM265 are estimated at EUR 0.3 million and 

265 The one-off costs per WIM take into account the civil engineering services for the installation of the systems and the 
capital expenditure for the acquisition of WIM systems. 

129 

 
 
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
                                                 
the recurrent costs (calibration costs) at EUR 15,000 per WIM per year.  Total one-off adjustment 
costs are estimated at EUR 74.4 million, while the recurrent adjustment costs at EUR 3.7 million. 
Expressed as present value over 2025-2050, PM6 is estimated to lead to adjustment costs for public 
authorities estimated at EUR 142.9 million, of which EUR 74.4 million one-off costs.  

Table 58: Adjustment costs per Member State due to PM6 relative to the baseline   
Country 

Maintenance costs (in million EUR) 

One-off costs 
(in million 
EUR) 

2025 

2030 

2035 

2040 

2045 

2050 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

1.8 

1.8 

2.4 

0.3 

0.0 

9.3 

0.0 

1.2 

4.2 

10.2 

3.0 

6.0 

1.5 

0.0 

0.0 

9.0 

2.1 

0.0 

1.5 

0.0 

0.0 

6.9 

2.7 

4.2 

4.8 

0.0 

1.5 

0.1 

0.1 

0.1 

0.0 

0.0 

0.5 

0.0 

0.1 

0.2 

0.5 

0.2 

0.3 

0.1 

0.0 

0.0 

0.5 

0.1 

0.0 

0.1 

0.0 

0.0 

0.3 

0.1 

0.2 

0.2 

0.0 

0.1 

EU 
3.7 
Source: TML et al. (2023), impact assessment support study. 

74.4 

0.1 

0.1 

0.1 

0.0 

0.0 

0.5 

0.0 

0.1 

0.2 

0.5 

0.2 

0.3 

0.1 

0.0 

0.0 

0.5 

0.1 

0.0 

0.1 

0.0 

0.0 

0.3 

0.1 

0.2 

0.2 

0.0 

0.1 

3.7 

0.1 

0.1 

0.1 

0.0 

0.0 

0.5 

0.0 

0.1 

0.2 

0.5 

0.2 

0.3 

0.1 

0.0 

0.0 

0.5 

0.1 

0.0 

0.1 

0.0 

0.0 

0.3 

0.1 

0.2 

0.2 

0.0 

0.1 

3.7 

0.1 

0.1 

0.1 

0.0 

0.0 

0.5 

0.0 

0.1 

0.2 

0.5 

0.2 

0.3 

0.1 

0.0 

0.0 

0.5 

0.1 

0.0 

0.1 

0.0 

0.0 

0.3 

0.1 

0.2 

0.2 

0.0 

0.1 

3.7 

0.1 

0.1 

0.1 

0.0 

0.0 

0.5 

0.0 

0.1 

0.2 

0.5 

0.2 

0.3 

0.1 

0.0 

0.0 

0.5 

0.1 

0.0 

0.1 

0.0 

0.0 

0.3 

0.1 

0.2 

0.2 

0.0 

0.1 

3.7 

0.1 

0.1 

0.1 

0.0 

0.0 

0.5 

0.0 

0.1 

0.2 

0.5 

0.2 

0.3 

0.1 

0.0 

0.0 

0.5 

0.1 

0.0 

0.1 

0.0 

0.0 

0.3 

0.1 

0.2 

0.2 

0.0 

0.1 

3.7 

According to the information provided by public authorities during the consultation activities, only 
one  Member  State  declared  their  intention  of  installing  certified  WIM  systems  for  direct 
enforcement.  While  it  is  possible  that  some  Member  States  decide  to  opt  for  the  installation  of 
certified WIM systems on a voluntary basis, due to their higher benefit to cost ratio, the assessment 
of impacts of PM6 does not take into account the extra cost incurred by those Member States. 

130 

 
 
 
Adjustment cost savings for public administrations  

Adjustment  cost  savings  for  public  administrations  are  related  to  the  public  expenditure  on 
infrastructure  maintenance.  PM6  is  expected  to  reduce  the  frequency  and  severity  of  overloading 
practices,  mitigating  the  premature  damage  of  the  road  infrastructure  due  to  overloaded  HDVs, 
which  are  estimated  to  account  for  4.8%  of  all  road  maintenance  costs266.  The  reduction  in 
maintenance costs linked to overloaded HDVs will primarily benefit the TEN-T road infrastructure, 
that represents around 67%267 of the total vkm in the EU268, and where WIM systems under PM6 
will  be  deployed.  Outside  the  TEN-T  network  a  positive  effect  is  expected  as  the  number  of 
overloaded  HDVs  that  partially  use  the  TEN-T  will  decrease  and  a  negative  effect  as  part  of 
overloaded  HDVs  will  actively  avoid  the  TEN-T  network.  Given  that  the  second  effect  will  be 
influenced by the choice of location of the WIM systems within the TEN-T network, as well as by 
the additional enforcement measures adopted at national level, overall it is estimated that the impact 
of PM6 on the part of the network outside the TEN-T network will be neutral.  

As indicated in PMc6, the available literature, although limited, estimates that WIM systems for the 
pre-selection  of  overloaded  HDVs  have  double  the  effectiveness  (20%)  of  traditional  manual 
controls (10%) in reducing the number of overloaded vehicles. Overall, the increased compliance is 
assumed to reduce the maintenance costs linked to overloaded vehicles in the TEN-T by the same 
proportion. PM6 is also expected to lead to an increase in the vehicle-km performed by compliant 
HDVs, partially offsetting the benefits of the reduction in overloaded HDVs.  

The joint effects of PMc6 and PM6 (in PO-B) on the infrastructure maintenance costs relative to the 
baseline are provided in Table 59. Expressed as present value over 2025-2050, the adjustment costs 
savings are estimated at EUR 2.6 billion (in 2022 prices).  

Table 59: Impacts of PM6 (jointly with PMc6) on adjustment costs for public authorities relative to the baseline  

2025 

2030 

2040 

2050 

Reduction  in  the  overloaded  vehicles 
(million vkm) 

           407  

                 454  

                 479  

                 512  

Adjustment cost savings (EUR million) 
Source: TML et al. (2023), impact assessment support study  

           125.5  

           131.9  

           145.9  

           161.3  

Administrative costs savings for public authorities 

Non-certified WIM systems are used to pre-identify HDVs that are likely to be overloaded, but in 
order to determine the infraction a measurement with a certified scale is still foreseen. Thus, while 
PM6 considerably increases the effectiveness of controls, some manual/roadside checks still remain 
necessary.  PM6  will  allow  Member  States  to  increase  the  ratio  of  infractions  detected  relative  to 

266 See PMc6 for an explanation of the source. 
267  Analysis  accompanying  the  impact  assessment  for  the  revision  of  Regulation  (EU)  N°  1315/2013  on  Union 
guidelines for the development of the trans-European transport network; the total amount of road freight tkm (table 18) 
for 2020, and the amount of activity on the TEN-T comprehensive network (table 21) to calculate the share. 
268 Report from the Commission to the European Parliament and the  Council on the implementation in 2019-2020 of 
Regulation  (EC)  No  561/2006  on  the  harmonisation  of  certain  social  legislation  relating  to  road  transport  and  of 
Directive 2002/15/EC on the organisation of the working time of persons performing mobile road transport activities 
(31st report from the Commission on the implementation of the social legislation relating to road transport). 

131 

 
 
 
  
                                                 
PMc6  while  substantially  decreasing  the  number  of  road-side  checks,  by  97%  relative  to  the 
baseline. 

The administrative costs savings for public authorities due to PM6 (in PO-B) are estimated at EUR 
1.1  billion  in  2030  and EUR  1.5  billion  in  2050.  Expressed  as  present  value  over  2025-2050  the 
administrative costs savings are estimated at EUR 21.6 billion. 

Table 60: Impacts of PM6 (in PO-B) on administrative costs for public authorities relative to the baseline 

2025 

2030 

2040 

2050 

Weight tests in the baseline (thousand) 

6,683.5 

8,022.4 

8,943.7 

10,703.7 

Reduction in the number of weight tests relative 
to the baseline (thousand) 

6,483.0 

7,781.7 

8,675.4 

10,382.6 

Cumulative/ 
present value 
(2025-2050) 

227,351 

220,530 

Administrative costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study 

920.6 

Adjustment costs savings for road transport operators  

1,105.0 

1,231.9 

1,474.3 

21,592.8 

Road transport operators will benefit from adjustment cost savings relative to the baseline, linked to 
the  reduced  time  required  for  cooperating  with  the  public  authorities  for  the  weight  control.  As 
indicated in PMc6 the average time per weight control is one hour and the economic cost associated 
to delaying the vehicle by that one hour is estimate at EUR 34.8. The accuracy of WIM systems in 
identifying overloaded control is 97%, as opposed to 13.3% of currently performed controls269. The 
adjustment  costs  savings  due  to  PM6  and  PMc6,  jointly,  are  provided  in  Table  61.  Expressed  as 
present value over 2025-2050, they are estimated at EUR 5.2 billion.  

Table 61: Impacts of PM6 on road transport operators (adjustment costs savings) relative to the baseline 

Adjustment costs savings (EUR million) 
Source : TML et al. (2023), impact assessment support study 

Adjustment costs for transport operators 

2025 

2030 

2040 

2050 

222.9 

267.6 

298.3 

357.0 

PM6  jointly  with  PMc6  (in  PO-B)  is  expected  to  reduce  overloading  practices.  If  operators  that 
were  previously  operating  overloaded  trucks  will  now  comply  with  the  weight  limits,  then  more 
vehicle-km  will  be  required  to  transport  the  same  quantity  of  goods.  This  will  affect  transport 
operators  which  were  operating  under  infraction.  By  minimising  the  proportion  of  overloaded 
vehicles,  compliant  operators  will  benefit  from  a  levelled  playing  field.  This  applies  to  both 
domestic and international transport.  

269  REPORT  FROM  THE  COMMISSION  TO  THE  EUROPEAN  PARLIAMENT  AND  THE  COUNCIL  on  the 
implementation  in  2019-2020  of  Regulation  (EC)  No  561/2006  on  the  harmonisation  of  certain  social  legislation 
relating to road transport and of Directive 2002/15/EC on the organisation of the working  time of persons performing 
mobile  road  transport  activities  (31st  report  from  the  Commission  on  the  implementation  of  the  social  legislation 
relating to road transport). 

132 

 
 
 
 
  
                                                 
Table 62: Impacts of PM6 and PM6c (in PO-B) on transport operators relative to the baseline  

Increase in transport activity (vkm million) 
Adjustment costs (EUR million) 
Source : TML et al. (2023), impact assessment support study 

2025 

2030 

2040 

2050 

Cumulative/ 
present value 
(2025-2050) 

68.2 
79.7 
91.8  107.3 

90.9  104.0 
122.4  140.1 

2,293.5 
2,132.6 

PM7: Require a minimum amount of "certified" Weigh-in-Motion systems to be deployed in the 
TEN-T network for direct enforcement purposes 

PM7 mandates the deployment of the same amount of WIM systems as in PM6, i.e. every 300 km 
in  the  TEN-T  network.  However,  PM7  envisage  the  use  of  theses  WIM  systems  for  direct 
enforcement  purposes.  Under  PM7  the  WIM  systems  will  require  certification  and  regular 
calibration  in  order  to  serve  as  proof  of  the  commission  of  an  infraction.  The  certified  WIM 
systems will significantly increase the effectiveness of controls as compared to PM6, with controls 
potentially be carried out 24h/7d, by reducing the need for additional resources (certified secondary 
scales and enforcement officers at the site) as they eliminate ad-hoc roadside controls.  
On 1st March 2023 the Commission adopted a legislative proposal270 to amend the Directive (EU) 
2015/413271  (the  Cross-Border  Enforcement  Directive  or  CBE  Directive).  This  proposal  aims  at 
further  enhancing  road  safety  by  extending  the  scope  of  the  CBE  Directive  to  other  road-safety-
related traffic offences. The “use of an overloaded vehicle”272 is one of them. As a consequence, the 
tools provided by the CBE Directive can be applied to identify the offender detected through WIM 
systems and facilitate its prosecution. 

Adjustment costs for public administrations  

This  measure  will  require  some  Member  States  to  install  more  WIM  systems  than  initially 
envisaged by them, as required under PM6, and the upgrading of currently deployed WIM systems 
that should be certified (as reflected in Table 63). Thus, under PM7 a total 101 WIM systems that 
have been installed in the TEN-T network in the EU will be upgraded/certified and 247 additional 
certified WIM systems will be installed.  

Table 63: WIM systems deployed in the EU   
Country  WIM systems installed  

Installed   Estimated 

Installed 
certified 
WIM 
systems 

TEN-T 
network 
(km) 

Certified 
WIM  systems 
required 
by 
PM7 

Non-certified 
WIM  systems 
to 
be 
upgraded 

Additional 
new  certified 
WIM systems  

AT 

BE 

1 

1 

1,814.3 

1,844.7 

1 

7 

7 

1 

0 

6 

6 

270 COM(2023) 126 final. 
271 Directive (EU) 2015/413 of the European Parliament and of the Council of 11 March 2015 facilitating cross-border 
exchange of information on road safety related traffic offences (OJ L 68, 13.3.2015, p. 9–25). 
272 The ‘use of an overloaded vehicle’ is defined in the legislative proposal amending the CBE Directive as “using a 
vehicle that does not comply with the requirements set for its maximum authorized weights, as laid down in the national 
laws, regulations or administrative provisions transposing Council Directive 96/53/EC, or in the law of the Member 
State of the offence for vehicles or operations for which there are no such requirements set in that Directive”. 

133 

 
 
  
 
 
  
 
  
                                                 
BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

30 

14 

8  

29 

107 

15 

16 

3 

6 

30 

1 

1 

7 

1 

3 

7 

1 

6 

1 

1 

1 

1 

1 

3 

1 

2,580.2 

445.2 

1,975.9 

11,348.4 

1,624.8 

1,354.7 

4,655.8 

12,030.0 

5,192.0 

14,611.9 

1,572.8 

2,544.9 

2,219.7 

10,706.8 

2,178.5 

90.5 

1,680.2 

117.39 

1,951.2 

7,751.1 

2,822.4 

4,837.9 

6,447.5 

643.2 

1,566.9 

5 

107 

15 

6 

1 

EU 
Source: TML et al. (2023), impact assessment support study. 

296 

128 

106,609.0 

9 

2 

7 

38 

6 

5 

16 

41 

18 

49 

6 

9 

8 

36 

8 

1 

6 

1 

7 

26 

10 

17 

22 

3 

6 

1 

1 

2 

7 

6 

1 

3 

7 

8 

29 

1 

0 

0 

6 

1 

1 

1 

1 

7 

3 

1 

3 

6 

3 

1 

8 

1 

0 

31 

0 

4 

13 

34 

10 

20 

5 

0 

0 

30 

7 

0 

5 

0 

0 

23 

9 

14 

16 

0 

5 

371 

101 

247 

The one-off costs per new WIM273 installed are estimated at around EUR 0.4 million and upgrading 
of  the  existing  ones  at  EUR  0.1  million  per  WIM.  The  recurrent  costs  (maintenance  costs)  are 
estimated at EUR 15,000 per WIM per year. Total one-off adjustment costs are estimated at EUR 
108.9 million, while the recurrent adjustment costs at EUR 3.7 million. Expressed as present value 
over  2025-2050,  PM6  is  estimated  to  lead  to  adjustment  costs  for  public  authorities  estimated  at 
EUR 177.1 million, of which EUR 108.9 million one-off costs. 

Adjustment cost savings for public administrations  

Adjustment  cost  savings  for  public  administrations  are  related  to  the  public  expenditure  on 
infrastructure maintenance. Like in PM6, PM7 is expected to reduce the frequency and severity of 
overloading practices, mitigating the premature damage of the road infrastructure due to overloaded 
HDVs,  which  are  estimated  to  account  for  4.8%  of  all  road  maintenance  costs.  The  reduction  in 
maintenance costs linked to overloaded HDVs will primarily benefit the TEN-T road infrastructure, 

273 The one-off costs per WIM take into account the civil engineering services for the installation of the systems and the 
capital expenditure for the acquisition of WIM systems. 

134 

 
 
  
 
  
 
  
  
 
  
 
  
 
  
 
  
 
 
 
  
 
  
 
  
  
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
 
  
                                                 
that holds 67% of the total vkm in the EU, and where WIM systems under PM7 will be deployed. 
Outside the TEN-T network it is expected a positive effect as the number of overloaded HDVs that 
partially  use  the  TEN-T  will  decrease  and  a  negative  effect  as  part  of  overloaded  HDVs  will 
actively avoid the TEN-T network. Given that the second effect will be influenced by the choice of 
location of the WIM systems within the TEN-T network, as well as by the additional enforcement 
measures adopted at national level, overall it is estimated that the impact of PM7 on the part of the 
network outside the TEN-T network will be neutral.  

As  indicated  in  PMc6,  the  available  literature,  although  limited,  allows  to  make  estimates  that 
certified WIM systems for direct enforcement have double the effectiveness (40%) of pre-selection 
WIM  systems  (20%)  and  four  times  the  effectiveness  of  traditional  manual  controls  (10%)  in 
reducing  the  number  of  overloaded  vehicles.  Overall  the  increased  compliance  will  reduce  the 
maintenance costs linked to overloaded vehicles in the TEN-T in the same proportion. PM7 is also 
expected  to  increase  the  amount  of  vehicle-km  performed  by  compliant  HDVs  during  the  period 
2025-2050  as  compared  to  the  baseline,  partially  offsetting  the  benefits  of  the  reduction  in 
overloaded HDVs. As a result, PM7 will lead to EUR 6.6 billion infrastructure costs savings over 
the period 2025-2050 expressed as present value (in 2022 prices). 

Table 64: Impacts of PM7 on adjustment costs for public authorities relative to the baseline  

2025 

2030 

2040 

2050 

Adjustment cost savings (EUR million) 
Source: TML et al. (2023), impact assessment support study  

           322.3  

           338.9  

           374.7  

           414.3  

Administrative costs savings for public authorities 

Certified WIM systems eliminate the need for road side controls with certified scales in the TEN-T 
network, where 67% of the circulation of HDVs occurs. PM7 will allow Member States to reach the 
minimum level of controls envisaged by PMc6 while increasing the ratio of infractions detected and 
will reduce the administrative costs for public authorities linked to roadside inspections.  

Table 65: Impacts of PM7 on administrative costs for public authorities relative to the baseline 

2025 

2030 

2040 

2050 

Reduction in the number of weight tests relative 
to the baseline (thousand) 

6,683.5 

8,022.4 

8,943.7 

10,703.7 

949.1 
Administrative cost savings (EUR million) 
Source : TML et al. (2023), impact assessment support study  

1,139.2 

1,270.0 

1,519.9 

Adjustment cost savings for road transport operators  

Cumulative/ 
present value 
(2025-2050) 

227,351 

22,260.6 

Road transport operators will benefit from adjustment cost savings relative to the baseline, linked to 
the  reduced  time  required  for  cooperating  with  the  public  authorities  for  the  weight  control.  As 
indicated in PMc6 and in PM6 the average time per weight control is one hour and the economic 
cost associated to delaying the vehicle by that one hour is estimate at EUR 34.8. The accuracy of 
WIM  systems  in  identifying  overloaded  HDVs  is  100%,  as  opposed  to  13.25%  for  the  currently 

135 

 
 
 
  
 
performed controls274. The adjustment costs savings linked to the elimination of unnecessary road 
side  checks  relative  to  the  baseline  are  estimated  at  EUR  5.4  million  expressed  as  present  value 
over the period 2025-2050 (in  2022 prices). The economic impacts  of PM6  for  road operator for 
2025, 2030, 2040 and 2050 are provided in Table 66. 

Table 66: Impacts of PM7 on road transport operators (adjustment costs savings) relative to the baseline 

2025 

2030 

2040 

2050 

Cumulative/ 
present value 
(2025-2050) 

Adjustment costs savings (EUR million) 
Source: TML et al. (2023), impact assessment support study 

229.8 

275.9 

307.5 

368.0 

5,390.4 

Adjustment costs for transport operators 

PM7  is  expected  to  reduce  overloading  practices.  If  operators  that  were  previously  operating 
overloaded trucks will now comply with the weight limits, then more vehicle-km will be required to 
transport  the  same  quantity  of  goods.  This  will  affect  transport  operators  which  were  operating 
under  infraction.  By  minimising  the  proportion  of  overloaded  vehicles,  compliant  operators  will 
benefit from a levelled playing field. This applies to both domestic and international transport.  

Table 67: Impacts of PM7 on transport operators relative to the baseline  

Transport activity (vkm million) 
Adjustment costs (EUR million) 
Source : TML et al. (2023), impact assessment support study 

2025 

2030 

2040 

2050 

Cumulative/ 
present value 
(2025-2050) 

168.8  196.7 
227.4  265.0 

225.3  257.5 
303.4  346.9 

5,671.6 
5,273.4 

PM8: Requirements for EMS and drivers: mandatory and harmonised 

All  Member  States  currently  allowing  the  circulation  of  EMS  also  apply  safety  requirements  to 
them beyond the minimum regulated standards of type approval for vehicles or driver licensing and 
the Certificate of Professional Competence for drivers.  

Currently,  those  standards  vary  among  Member  States  and  risk  becoming  a  barrier  to  the 
international  traffic  of  EMS.  Therefore,  PM8  aims  to  make  such  requirements  mandatory  and 
harmonised. 

Adjustment costs for transport operators 

As  indicated  in  PMc4,  9  Member  States  already  allow  the  circulation  of  EMS  in  their  national 
territory275. The additional standards for EMS refer to both drivers and equipment.  

274  REPORT  FROM  THE  COMMISSION  TO  THE  EUROPEAN  PARLIAMENT  AND  THE  COUNCIL  on  the 
implementation  in  2019-2020  of  Regulation  (EC)  No  561/2006  on  the  harmonisation  of  certain  social  legislation 
relating to road transport and of Directive 2002/15/EC on the organisation of the working time of persons performing 
mobile  road  transport  activities  (31st  report  from  the  Commission  on  the  implementation  of  the  social  legislation 
relating to road transport). 
275 Belgium, Czechia, Denmark, Germany, Finland, Netherlands, Portugal, Spain and Sweden. 

136 

 
 
 
  
 
                                                 
PM8  will  requires  drivers  to  have  five  years  of  experience  in  driving  HGV276  and  to  have 
successfully  completed  a  specific  training.  Currently,  such  trainings  are  already  a  requirement  in 
Belgium, Germany and Netherlands. In the other six Member States with EMS there is not such a 
requirement.  

The following data has been used for the estimation of the number of drivers that would be required 
to complete such a training in those six Member States: 

-  The active HGV driving licences and the projected number of licences until 2050, including the 
projected  number  of  new  HGV  driving  licences,  drawing  on  the  Impact  Assessment  for  the 
revision of the Driving Licence Directive. 

-  The stock of EMS and its projected evolution in the baseline scenario. 

A  total  of  1.08  million  drivers  are  estimated  to  require  completing  a  specific  training  in  the  six 
Member States, of which 604 thousand corresponding to existing drivers in 2025 and 481 thousand 
to new drivers that will join the profession throughout 2026-2050. 

The cost for a three-day specific training is estimated in EUR 1,650. This is based on the current 
training taking place in Belgium, Germany and the Netherlands. 

The number of trainings and the adjustment costs for transport operators relative to the baseline are 
provided  in  Table  68.  Expressed  as  present  value  over  2025-2050,  adjustment  cost  for  transport 
operators are estimated at EUR 1.5 billion. 

Table 68: Impacts of PM8 on transport operators relative to the baseline  

2025 

2030 

2040 

2050 

Number of trainings 
Adjustment costs (EUR million) 
Source : TML & Ramboll et al. (2023), impact assessment support study 

     603,920  
         996.5  

    18,220  
        30.1  

    19,167  
        31.6  

    21,193  
        35.0  

In the Member States that currently do not allow the circulation of EMS, the requirement of such a 
training will be part of the conditions for the introduction of EMS and, therefore, is considered to 
be already included under the calculations for PM3. 

Adjustment costs for the European Commission 

On top of the special requirements for drivers, the Member States require reinforced safety features 
in the vehicles beyond the General Safety Regulation and Type Approval legal framework. These 
additional requirements include aspect such as lower minimum turning circle diameter to improve 
manoeuvrability, electronically controlled brake system (EBS) for faster brake response time over 
the longer distance between cab and rearmost axle, minimum power to weight ratio 5kw/tonne to 
reduce differential speeds between EMS and other traffic by ensuring certain minimum acceleration 
performance  and  minimum  mass  on  the  driven  axle(s)  to  ensure  a  minimum  standard  of  traction 
when moving away from rest or climbing a gradient in slippery conditions. 

While  different  Member  States  require  a  different  combination  of  the  above  mentioned  features, 
safety level is considered to be equivalent across the allowing Member States. To avoid the risk that 

276 This will be accredited with the date of issuance of the licence. 

137 

 
 
  
                                                 
different  vehicle  requirements  could  lead  to  restrictions  to  the  international  traffic  of  EMS,  PM8 
will  harmonise  the  vehicle  requirements  for  new  vehicles  while  maintaining  the  same  level  of 
safety  as  it  is  currently  the  case.  Therefore,  no  impact  on  the  costs  for  transport  operators  is 
expected.  

However, for establishing the exact requirements, an expert group will develop the standards based 
on a study which will compile the various existing requirements and propose several options for the 
establishment  of  the  standards.  The  cost  of  the  initial  study  is  estimated  in  EUR  400,000.  The 
average cost for a two-day workshop hosted by European Commission (EC), where participants are 
reimbursed by the EC is around EUR 30,000. Two of such in-person workshops may be required as 
well as two online meetings. Compensation for the experts contributing to the online meetings is 
estimated in EUR 5,000 for each meeting. Therefore, the one-off adjustment costs for the European 
Commission due to PM8 are estimated at EUR 0.47 million. 

4.  Methods for the assessment of the impacts on road safety 

The  impact  on  safety  of  the  different  policy  measures  has  been  measured  in  terms  of  expected 
reduction in fatalities. To monetise the external costs of fatalities, the unit costs at Member State level 
from the Handbook on external costs of transport277 have been used. At EU level, the unit cost per 
fatality is estimated at EUR 3.9 million in 2022 prices.  

The analysis was based, on the one hand, on literature focusing on engineering predictions, which 
studied the engineering effects of overloading vehicles both within and beyond their design limit278 
as well as the specific additional risks of EMS at 60 tonnes versus standard 44 tonne HGVs279. On 
the other hand, post-hoc statistical methods were also considered. These included a comparison of 
the  fatality  rates  of  different  vehicles  within  existing  length  limits  (16.5/18.75)  by  GVW  and 
number  of  axles280,  which  was  updated  and  extended  to  smaller  vehicles  in  the  context  of  the 
support study; and a comparison of EMS with HGVs of up to 40 tonnes and 18.75m in Sweden281, 
which found that the actual fatality rate in the EMS group was 21% lower than that for the 40 tonne 
vehicles. 

Policy  measures  PMc1,  PM1  and  PMc3  envisage  to  a  modest  increase  in  mass  for  HDVs.  For 
PMc1 and PM1, the increase in mass from 42 tonnes to 44 tonnes was considered to increase the 
risk by 0.5%. In PMc3, permitting 5 and 6-axle rigid vehicles was estimated to lead to a 1% risk 
increase. It should be noted that this factor represents an increase in risk per vehicle. Given that the 
measures  lead  to  an  overall  decrease  in  the  number  of  vehicle-kilometres,  the  overall  effect  is  a 
decrease in the number of fatalities. 

277  Essen,  H.  et  al.  (2020),  Handbook  on  the  external  costs  of  transport:  version  2019  –  1.1,  Publications  Office, 
available at:   
278  Breemersch,  T.  et  al.  (2021).    Overweight  vehicles’  impacts  on  road  infrastructure  and  safety.  Transport  and 
Mobility Leuven. 
279 Knight, I., et al. (2008). Longer and/or longer and heavier goods vehicles (LHVs)  - a study of the likely effects if 
permitted in the UK. Crowthorne: TRL Published Project Report PPR 285. 
280 Ib. 
281  Balint,  A.  et  al.  (2014).  Accident  analysis  for  traffic  safety  aspects  of  High  Capacity  Transports.  Chalmers 
University of Technology, Department of Vehicle Safety. 

138 

 
 
                                                 
PMc4, PM3 and PM8 envisage larger capacity increases connected to EMS. Abstract engineering 
analysis  predict  a  large  increase  in  risk  per  km,  associated  with  the  larger  weight  gain  and  the 
addition  of  length  related  risks  (e.g.  poor  manoeuvrability).  However,  statistical  observations 
suggest  a  large  reduction  in  risk  per  km  associated  with  EMS  compared  with  standard  vehicles. 
This  apparent  contradiction  is  explained  by  the  fact  that  EMS  are  implemented  with  additional 
safety features than standard HGVs and that they are used differently than standard HGVs such that 
their  exposure  to  risk  is  different  (e.g.  more  of  their  time  is  spent  on  safer  parts  of  the  road 
network), and that operators tend to use their best drivers on EMS. In addition, there is anecdotal 
evidence  to  suggest  that  drivers  of  EMS  drive  them  more  carefully  than  they  would  a  standard 
HGV  because  of  the  perception  of  increased  difficulty  and  risk  that  the  additional  length  and 
articulation point brings. Moreover, EMS tend to be at the newer end of the range of vehicles and 
thus  they  are  equipped  with  more  modern  safety  features  than  the  average  HGV.  Taking  into 
account all these factors, a 5% reduction in risk has been estimated for PMc4 and PM3, which is 
further  reduced  to  6%  with  the  introduction  of  PM8.  Here  again,  besides  the  inherent  risk  per 
vehicle, the effect of the measures on the number of vehicle-kilometres has been taken into account 
to calculate the overall impact on road safety. 

For  PMc5  (i.e.  vehicle  carriers),  it  was  considered  that  front  and  rear  overhangs,  that  cause 
additional swept  path  that fall outside of turning circle limits, would  be the main risk  rather than 
load.  Based  on  an  analysis  of  collision  data  identifying  typical  manoeuvring  related  collisions, 
undertaken  in  the  context  of  the  support  study,  it  was  estimated  that  PMc5  would  increase  the 
fatality  risk  of  each  vehicle  by  0.02%.  As  in  previous  cases,  the  effect  of  the  measures  on  the 
number of vehicle-kilometres has  been taken into account  to  calculate the overall impact  on road 
safety. 

PMc6, PM6, and PM7 reduce the number of overloaded vehicles. When the overloaded vehicles are 
within their design limit, the effect on safety risk per km is expected to be the same as for legally 
loaded vehicles. However, when overloads go above the design limit the safety risks substantially 
increase, likely exponentially. However, no scientific studies were identified that could quantify the 
scale of this increase. Based on expert opinion in the context of the support study, 2% higher risk 
per km was assumed for all overloaded vehicles compared to the legally loaded vehicles. 

The impact of the policy options on road safety is presented in Table 69. 

Table  69:  Decrease  in  the  number  of  fatalities  (cumulative  over  2025-2050)  in  the POs  relative  to  the  baseline 
scenario  (EU27)  and  the  reduction  in  the  external  costs  expressed  as  present  value  over  2025-2050,  in  million 
EUR (2022 prices)  

Decrease in the number of fatalities 
Reduction in the external costs of fatalities (million EUR) 
Source: TML et al. (2023), impact assessment support study 

PO-A 

Difference to the Baseline 
PO-B 

PO-C 

237 
535.8 

411 
877.4 

642 
1,363.9 

139 

 
 
 
ANNEX 5: COMPETITIVENESS CHECK 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS  

Dimensions of 
Competitiveness 

Cost 
and 
competitiveness 

price 

International 
competitiveness  

Capacity to innovate 

SME competitiveness 

Impact of the 
initiative 

(++ / + / 0 / - / -- / 
n.a.) 

++ 

+ 

+ 

++ 

References to sub-sections of 
the main report or annexes 

Section 6.1.3, 6.1.4. and 6.1.5. of 
the SWD and Annex 4 

Section 6.1.5 of SWD 

Section 6.1.5 and 6.1.7 of SWD 

Section  6.1.6  of  the  SWD  and 
Annex 11 

2.  SYNTHETIC ASSESSMENT  

2.1. Cost and price competitiveness 

The  preferred  policy  option  will  bring  significant  improvements  in  the  operational 
efficiency  of  road  transport  operations,  including  the  efficiency  of  road-legs  of 
intermodal  operations.  These  efficiencies  result  mainly  from  the  measures  enabling  to 
carry the same (or more) amount of cargo with less trips by road vehicles in cross-border 
operations  (PMc2,  PMc3,  PMc4,  PMc5,  PM2),  including  intermodal  operations,  and 
from  measures  facilitating the transition  to  zero-emission transport (PMc1, PM1) while 
maintaining (or even gaining) a payload. Additionally, administrative cost savings come 
from measure streamlining the administrative procedures related to the use of high-cube 
containers in intermodal transport (PMc2) and for indivisible loads (PM4). As indicated 
in  section  6.1.3,  administrative  costs  savings  are  estimated  at  EUR  4.4  billion  in  PO-B, 
expressed  as  present  value  over  2025-2050,  relative  to  the  baseline.  The  initiative  will 
improve, in particular, the competitiveness of road transport operators involved in cross-
border  operations,  while  ensuring  stronger  modal  cooperation  with  other  modes  of 
transport,  especially  in  long-distance  operations,  where  other  modes  (rail,  inland 
waterways, short-sea shipping) are more price-competitive than road-only transport.  As 
explained in section 6.1.3, net costs savings for road transport operators are estimated at EUR 
45.1 billion in PO-B,  expressed as present value over 2025-2050 relative to the baseline (in 
2022 prices). 

2.2. International competitiveness 

The initiative may improve the international competitiveness of the EU commercial road 
transport  sector  by  making  it  greener  and  more  efficient,  including  by  encouraging 

140 

 
 
involvement in intermodal operations, thus reducing somewhat the demand for drivers282 
whose  shortage  is  an  acute  and  global  challenge.  In  addition,  it  can  be  expected  that 
compliance  with  the  revised  Directive  will  improve  the  safety  and  reliability  of  the 
HDVs,  which  can  enhance  the  reputation  of  EU  road  transport  companies  on  the 
international market. 

2.3. Capacity to innovate 

The  initiative  can  positively  affect  the  road  transport  sector’s  capacity  to  innovate,  in 
several  ways.  By  providing  incentives  to  the  deployment  of  zero-emission  HDVs,  it 
encourages the manufacturers to develop new solutions and technologies to make the ZE 
powertrains  lighter  and/or  smaller,  thanks  to  which  road  operators  would  gain  extra 
payload,  and  manufacturers  higher  demand  for  such  vehicles.  As  the  initiative  is  zero-
emission technology neutral, it may also trigger search for new technological solutions to 
address the issue of scarcity and price of raw material (e.g. lithium, cobalt, used broadly 
in  electric  battery  powertrains).  The  revised  Directive  can  also  drive  innovation  in 
logistics and supply chain management, as companies seek to optimize their operations, 
including  by  improving  load  factors  and  searching  for  more  cost-competitive  and 
accessible  intermodal  combinations.  The  initiative  will  also  stimulate  the  transition  to 
digitalisation  of  documents  (e.g.  permits  for  abnormal  transport)  and  transport  data 
related to cargo, vehicle, route, etc. (e.g. on eFTI platforms). 

2.4. SME competitiveness  

Given that SMEs constitute the great majority of the road transport sector, the assessment 
of  the  overall  cost  and  price  competitiveness  aspects  is  relevant  for  small  and  medium 
road transport companies. Hence, the initiative has a positive impact on competitiveness 
of SMEs, in particular those engaged in cross-border as well as intermodal operations, by 
improving their operational and energy efficiency and facilitating the transition to zero-
emission operations. 

282  All  policy  options  lead  to  a  reduction  in  the  vehicle-kilometres  driven  relative  to  the  baseline,  which 
translates into the reduction of drivers needed for performing transport operations. 

141 

 
 
                                                 
ANNEX 6: DETAILED DESCRIPTION OF POLICY MEASURES  

PMc1: Allow for extra weight and extra length to ZE heavy goods vehicles (HGVs) and 
2-axle rigid buses 

PMc1 provides for increasing the maximum gross vehicle combination weight (GVCW) 
up to a maximum of 2 tonnes283, the maximum axle weight up to a maximum of 1 tonne 
on  the  drive  axle  or  a  bogie  containing  a  drive  axle284  and  the  maximum  length  of  the 
vehicle combination up to 90 cm.  

The  purpose  of  this  measure  is  to  compensate  for  the  weight  and  the  size  of  ZE 
powertrains  (i.e.  weight  of  electric  batteries  and  space  for  hydrogen  tanks)  thus 
preventing  the  loss  of  payload  in  comparison  with  diesel  vehicles.  In  other  words,  the 
extra weight and dimensions should be allocated to the powertrains and not to expand the 
payload. As a consequence, the effect of this measure is expected fade out over time with 
technology evolution as the weight of batteries is expected to decrease and, therefore, the 
ZE powertrains become of a similar weight and dimension with that of equivalent diesel 
powertrains.  

For  the  heaviest  vehicle  combinations,  i.e.  those  with  5  or  more  axles,  this  measure 
would enable a maximum GVCW of 44 tonnes for HDVs in road-only operations and of 
46 or 48 tonnes (depending on the axle combination) for HDVs  involved in intermodal 
operations285. The weight allowance for ZE HDVs would apply also to 2-axle rigid buses 
and  to  any  vehicle  of  the  combination  equipped  with  zero  emission  technologies  (i.e. 
motor  vehicle,  semi/trailers  and  dollies)  to  take  account  of  technological  developments 
such  as  electric  trailers  equipped  with  auxiliary  motors  and  batteries  which  reduce  the 
demand of energy from the motor vehicle and/or other power elements, such as cooling 
units  of  reefers.  However,  this  measure  offers  no  support  for  using  an  e-trailer  to 
hybridize a non-zero-emission vehicle.  

As regards the maximum length, HDVs will have to comply with the so-called “turning 
circle rule”286 to ensure their manoeuvrability and no extended length will be granted to 
trailers  or  semitrailers,  given  that  standard  loading  units  are  essential  to  ensure 
interoperability in and between transport modes. 

PMc2:  Allow  for  extra  height  to  accommodate  high-cube  containers  in  intermodal 
transport 

PMc2  provides  for  increasing  the  maximum  height  of  HDV  to  4.3m  in  order  to 
accommodate high-cube containers using standards skeletal trailers. The W&D Directive 

283 Currently the W&D Directive allows an additional GVW of 2 tonnes for certain ZE HDVs which under 
PMc1 would be increased by another 2 tonnes resulting in a potential increase of GVW by 4 tonnes. 2-axle 
rigid buses do not enjoy any derogation, thus their maximum GVW would only increase by 2 tonnes. 
284  Currently  the  W&D  Directive  allows  a  maximum  authorised  axle  weight  on  the  driving  axle  of  11.5 
tonnes. 
285 Currently the W&D Directive allows a maximum GVCW of up to 46 tonnes for ZE HDV involved in 
intermodal transport operations. 
286 The turning circle rule is envisaged in point 1.5 of Annex I of the W&D Directive, according to which 
“Any  motor vehicle or vehicle combination which is in motion must be able to run within a swept circle 
having an outer radius of 12.50m and an inner radius of 5.30m”. 

 
 
                                                 
sets  the  maximum  authorised  height  in  international  (intra-EU)  transport  at  4m,  which 
requires  road  transport  operators  involved  in  the  transport  of  high-cube  containers  to 
resort  to  special  equipment  (low  skeletal  trailers  and  gooseneck  trailers)  or  to  request 
special permits for indivisible loads (only possible in cases where the road infrastructure 
can accommodate 4.3m high HDV).  

This  measure  aims  at  removing  the  “legal”  limitation  to  the  circulation  of  HDVs 
transporting  high-cube  containers  (or  swap  bodies  of  equivalent  height),  without 
prejudice  to  the  application  of  road  traffic  national  provisions  limiting  the  maximum 
height of HDV on certain roads of civil engineering structures.     

PMc3: Harmonise the maximum permitted weight of 5- and 6-axle HDV (40t) 

PMc3  sets  the  weight  standard  of  5-  and  6-axle  rigid  vehicles  in  national  and 
international  transport  to  a  maximum  permitted  weight  of  40t.  Rigid  HDVs  of  5  or  6 
axles  are  currently  not  regulated  in  the  W&D  Directive.  As  a  consequence,  they  are 
admitted in international transport with the same GVW of a 4-axle rigid trucks, i.e. 32t. 
The  current  Directive  already  establishes  a  maximum  GVW  of  40t  for  articulated 
vehicles  of  5  and  6  axles.  This  measure  extends  the  same  maximum  GVW  to  rigid 
vehicles. 

PMc4: Allow cross-border transport of 44t-HDV and EMS between "allowing" MS 

PMc4  allows  the  cross-border  transport,  on  one  hand,  of  5-  or  6-axle  HDV  with  a 
maximum GVW of 44t and, on the other, of EMS between allowing Member States (i.e. 
Member States that allow such heavier and/or longer vehicles in national transport). This 
measure takes account of the national permissible weights (total and per axle) and length 
that  are  common  to  the  respective  MS  (“minimum  common  denominator”)  and  to  the 
part of the network where these vehicles are  allowed in  national  traffic,  but  it does not 
condition the cross-border transport to the compliance with additional requirements that 
could be imposed nationally to the vehicle or to the driver.  

As a result, the cross-border transport of 44-t HDV can be limited to 6-axle vehicles or 
vehicle  combinations  (the  number  of  axles  refers  to  the  type  of  vehicle  to  which  the 
national derogation applies). The cross-border transport of EMS can be limited to EMS 
with a length of 25.25m and a GVW of 40t, depending on the national legal framework. 
Likewise, the cross-border transport of 34m and 70t EMS (or higher) could be authorised 
between Member States that permit those modular systems in their territories. The cross-
border  traffic  of  44t-HDV  and  EMS  is  limited  to  the  part  of  the  network  where  these 
vehicles are allowed in national traffic. The number of border crossings is not limited.  
On the other hand, the additional requirements for 44t-HDV or EMS, such as a specific 
drivers  training  or  safety  features  to  the  vehicles  (e.g.  minimum  power  engine)  that 
Member  States  may  impose  to  their  national  hauliers  cannot  impede  the  acceptance  of 
44t-HDV or EMS registered in a different MS. 

143 

 
 
This measure does not pose any enforcement challenges, as it can be implemented under 
the same scheme currently used for 44t-HDV and EMS287. 

PMc5: Harmonise the loaded length of vehicle carriers 

PMc5  introduces  a  standard  for  the  maximum  overhang  of  loads  used  in  road  trains 
specialised  in  the  transport  of  vehicles  (vehicle  transporters  or  vehicle  carriers)  in 
national and international traffic. The maximum authorised length of these vehicles is the 
general  18.75m.  However  this  length  can  be  exceeded  when  they  are  loaded  (through 
national  derogations),  via  the  use  of  front  and/or  rear  cantilevers  or  overhangs,  up  to  a 
maximum of 20.75m. This measure aims at removing the national divergences as regards 
the type and length of overhangs allowed in national transport. 

PMc6:  Reinforce  MS  obligation  to  conduct  a  minimum  level  of  checks  on  HDV’s 
weight 

PMc6  will  mandate  Member  States  to  carry  out  every  year  a  minimum  number  of 
controls  of  the  compliance  of  HDV  with  the  rules  on  maximum  total  weight  and 
maximum axle weight per million vehicle-kilometre (vkm) in  each Member State. This 
measure does not preclude how the controls are performed, i.e. via physical inspection on 
the roadside or automatic systems allowing for direct enforcement without stopping the 
HDV controlled. The measure aims at ensuring a minimum level of enforcement in the 
EU which is expected to improve the competition and road safety.   

PMc7:  Set  common  principles  for  the  voluntary  implementation  of  intelligent  access 
policies 

IAP  primarily  ensures  matching  the  performance  and  characteristics  of  a  road  freight 
vehicle with the state and capability of specific section of an infrastructure network, i.e. it 
ensures that the correct vehicles runs on the correct road at the correct time. Access rules 
can  refer  to  weight  limits,  dimensions  limits,  speed  limit  compliance,  as  well  as  day 
and/or time restrictions for categories of vehicles. 

IAP is a nascent technology and could become a barrier to international traffic if Member 
States or even regions independently were to introduce their own systems without setting 
standards for information exchange.  

PMc7  aims  at  facilitating  a  harmonised  implementation  of  Intelligent  Access  Policies 
(IAP)  in  the  EU  based  on  common  principles  to  be  respected  by  Member  States  when 
they  voluntary  implement  them,  such  as  public  accessibility  to  the  information,  non-
discrimination. PMc7 would mean a common approach to ensure the interoperability of 
IAP’s necessary hardware and software.  

IAP aim to further facilitate efficient enforcement and to address the concerns of a risk of 
damage to infrastructure and of road safety by some types of HDVs. 

287 Some MS allow the circulation of  EMS under a permit scheme of abnormal transport that allows the 
public authorities to assess that the type of modular system is acceptable, as well as to communicate to the 
operators the part of the network that it is available to them during a period of time (minimum 1 year). 

144 

 
 
 
                                                 
PM1: Allow for extra weight for HDV which are ZEV regardless the weight of the ZE 
technology used  

PM1 allows 4 extra tonnes for HDVs in national and international traffic which are ZEV 
(i.e.  2  extra  tonnes  as  under  the  current  Directive  plus  2  additional  tonnes)  to  5/6-axle 
HGV only.  In additon to PMc1, the extra weight is be granted regardless the weight of 
the ZE technology used. PM1 will incentivise the investment in the newest technologies 
implementation  of  improved 
that  will  become 
aerodynamics that will reduce the need for energy storage, allowing for gains in payload 
as  compared  to  diesel  trucks.  This  competitive  advantage  is  expected  to  further 
incentivise the uptake of ZEV.  

lighter/smaller,  as  well  as 

the 

PM1 will enable a maximum GVCW of 44 tonnes for zero-emission HGVs in road-only 
operations and of 46 tonnes or 48 tonnes (depending on the axle combination) for HDVs 
involved in intermodal operations288.  

Those Member States which already allow the circulation of HDV of up to 44 tonnes will 
be allowed to continue to do so during a transition period also in cross-border traffic, as 
enabled by PMc4. The transition period should be aligned with the target dates set in the 
CO2 Standards Regulation to reinforce the effects of both initiatives, thus 2035.  

PM2:  Align  the  definition  of  intermodal  transport  with  the  Combined  Transport 
Directive (to include all intermodal loading units) 

PM2  aligns  the  definition  of  intermodal  transport  in  the  W&D  Directive  with  the 
Combined  Transport  Directive.  The  current  definition  introduced  in  Article  2.a  of  the 
W&D  Directive  by  Directive  (EU)  2015/719  considers  that  intermodal  transport 
operation shall mean “the combined transport operations defined in Article 1 of Council 
Directive  92/106/ECC289  engaged  in  the  transport  of  one  or  more  containers  or  swap 
bodies, up to a total maximum length of 45 feet;”. This reduces the scope of the combined 
transport operations that are supported by the W&D Directive to containerised transport 
and leaving out transport of goods where the lorry, trailer, semi-trailer, with or without 
tractor  unit  are  the  intermodal  loading  units  that  can  be  transhipped  between  modes  of 
transport.  

The  aim  of  PM2  is  to  provide  the  same  support  to  all  intermodal/combined  transport 
operations  regardless  the  type  of  loading  unit  employed.  Under  the  current  W&D 
Directive, HDVs involved in intermodal transport 5/6-axle articulated vehicles and road 
trains are granted an additional GVW of 2 tonnes or 4 tonnes, reaching up to 42 tonnes or 
44  tonnes,  depending  on  the  axle  configuration.  PM2  will  allow  the  same  extra  weight 
also for intermodal (non-containerised) transport where lorry, trailer, semi-trailer are the 

288  Currently  the  WD  Directive  allows  a  maximum  GVCW  of  up  to  46  tonnes  for  ZE  HDV  involved  in 
intermodal transport operations. 
289 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)   

145 

 
 
 
                                                 
intermodal  loading  units.  As  a  consequence,  this  type  of  intermodal  transport  would 
benefit  from  almost  4  additional  tonnes  of  payload  as  there  is  no  weight  of  empty 
containers  or  swap  bodies  to  be  compensated,  providing  a  competitive  advantage  as 
compared  to  only-road  transport  and  compensating  for  the  extra  weight  (which  is 
estimated between 200Kg and 1 tonne) of craneable trailer/semitrailers.  

When  5/6-axle  articulated  vehicles  and  road  trains  involved  in  intermodal  transport  are 
alternatively-fuelled or zero-emission they also benefit from the extra weight allowance 
envisaged  in  the  W&D  (1  tonne  and  2  tonnes,  respectively).  PM2  will  thus  result  in  a 
maximum GVW of these vehicle combinations of 42 to 46 tonnes depending on the axle 
configuration and the type of fuel.  

PM3:  Allow  international  (intra-EU)  transport  of  EMS1  at  least  in  core  and 
comprehensive  TEN-T  network  conditioned  to  be  ZEV  or  part  of  an  intermodal 
transport operation  

PM3  allows  the  circulation  of  EMS  of  up  to  25.25m  long  and  60  tonnes  of  GVW  in 
international traffic in all Members States within the TEN-T network, under the condition 
that  they  are,  either  zero-emission  vehicles,  or  involved  in  an  intermodal  transport 
operation.  As  regards  the  geographical  scope,  the  TEN-T  network  would  ensure 
connectivity throughout the EU, but Member States can voluntary extend it to additional 
parts of their networks, as it is the case in those Member States that currently allow the 
circulation of EMS.  

PM3 will affect Member States and their hauliers in a different way.  

Hauliers operating in allowing Member States will be able to extend their operations to 
international  traffic  without  a  limitation  in  the  number  of  borders  crossed  and  to  any 
other  Member  State.  However,  their  international  operations,  which  at  the  moment  are 
possible  between  two  neighbouring  allowing  Member  States  (based  on  bilateral 
agreements) will be limited to EMS that are either ZEV or are involved in an intermodal 
transport operation. Other EMS will not be allowed to operate cross-border; however, as 
a transition, in the “allowing MS”, these later EMS will be able to continue operating in 
international  traffic  until  2035.  The  national  operations  in  the  allowing  Member  States 
will not change.  

For those MS that already authorise the circulation of EMS in their territories (“allowing 
MS”290)  there  will  be  no  impacts  on  the  infrastructure.  The  two  only  exception  are 
Germany and the Czechia, for which PM3 entails an increase in the maximum authorised 
weight limit for EMS, from 40t (44t in intermodal transport and 46 tonnes in intermodal 
transport with ZEV) to 60t in Germany and from 48t to 60t, in the Czechia.  

On the other hand, this PM will affect the infrastructure needs of the Member States that 
do not currently allow EMS in  their territories (“non-allowing MS”). They will need to 
inspect  the  road  TEN-T  network  to  assess  whether  it  is  adequate  for  the  circulation  of 
EMS,  i.e.  for  a  GVW  of  60  tonnes  instead  of  46  tonnes291  and  a  maximum  length  of 

290  Currently,  the  allowing  Member  States  are  Finland,  Sweden,  Denmark,  Germany,  the  Netherlands, 
Belgium, Czech Republic, Spain and Portugal. 
291  Under  the  current  W&D  Directive  5/6-axle  articulated  vehicles  and  road  trains  can  reach  up  to  46 
tonnes if they are ZEV involved in intermodal transport operations.  

146 

 
 
                                                 
25.25m instead of 18.75m, and upgrade the infrastructure where necessary. This will also 
be  the  case  of  Germany  and  the  Czech  Republic  as  regards  the  weight  standards  for 
EMS.  

This  measure  will  provide  benefits  to  hauliers  operating  in  the  currently  non-allowing 
MS in  the form  of  an increase in  the payload, both  in  volume and  in  weight. This will 
compensate  for  the  capital  investment  necessary  to  electrify  their  fleets,  as  well  as 
provide a competitive advantage to intermodal transport beyond that provided by PMc2 
and PM2. 

PM4:  Set  minimum  administrative  and  safety  requirements  for  the  transport  of 
indivisible loads 

PM4 aims at  harmonising  the  requirements and  procedures  for  issuing national permits 
for performing transport of indivisible load292 requiring longer HDVs and specific safety 
measures.  PM4  envisages  the  implementation  of  some  of  the  recommendations  of  the 
European Best Practice Guidelines (BPG) for abnormal road transport. Namely, the one-
the 
stop-shop  principle  at  national 
implementation of a harmonised abnormal road transport application form and the setting 
of a Special European Registration of Trucks and Trailers. 

the  submission  of  applications, 

level  for 

The  introduction  of  the  one-stop-shop  principles  entails  the  appointment  a  single 
authority  per  Member  State  to  handle  the  permission  request,  without  prejudice  of  the 
internal  involvement  of  other  competent  authorities  at  national  or  regional  levels.  The 
internal procedures would be then transparent to  the applicants, which only had to deal 
with  one  authority,  providing  them  with  clarity  and  facilitating  the  administrative 
process.    

A  harmonised  abnormal  road  transport  application  form  was  agreed  between  national 
experts and published in the BGP where only the language of the application form vary 
between Member States.  

A  Special  European  Registration  of  Trucks  and  Trailers  (SERT)  provides  national 
authorities  in  a  single  document  or  database  with  the  detailed  technical  information 
necessary  to  assess  the  compatibility  of  a  vehicle  with  the  specific  requirements  of  the 
abnormal road transport that is not available on the registration certificate (and for which 
most countries have developed their own information documents).  

PM5: Set international transport corridors for indivisible loads 

PM5 envisages the implementation of one of the recommendations of the European Best 
Practice  Guidelines  (BPG)  for  abnormal  road  transport:  the  creation  of  abnormal  road 
corridors  across  the  EU  allowing  passage  rights  to  the  transport  by  road  of  abnormal 

292 Article 2 of Council Directive 96/53/EC defines indivisible load 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 the W&D Directive in all respects.” 

147 

 
 
                                                 
loads293  provided  that  the  corridors  meet  certain  pre-defined  criteria  (minimum 
dimensions and height as defined in the BPG).  

PM5 is in line with the current practice of granting long-term permits, for which Member 
States  have  identified  and  pre-classified  routes  for  abnormal  road  transports.  The 
information  on  the  parts  of  the  road  network  classified  as  adequate  for  the  carriage  of 
abnormal  loads  under  certain  thresholds  should  be  kept  up  to  date  and  be  readily 
accessible to the stakeholders. 

PM6: Require a minimum amount  of  Weigh-in-motion systems to  be deployed in the 
TEN-T network  

PM6 mandates the deployment every 300 km in the TEN-T network. The WIM systems 
would be used at least for targeted controls294, which means that they do not need to be 
certified for direct enforcement. This measure aims to further enhance the efficiency and 
effectiveness of controls and contribute to increasing the level of compliance, but will not 
remove  the  need  for  physical  roadside  controls  in  certified  scales  to  determine  the 
commission of infractions and to set fines.     

This  measure  will  require  Member  States  to  install  more  WIM  systems  than  initially 
envisaged by them,  as  well as an assessment of the most adequate locations within the 
TEN-T network.  

PM7:  Require  a  minimum  amount  of  "certified"  Weigh-in-Motion  systems  to  be 
deployed in the TEN-T network for direct enforcement purposes  

PM7  mandates  the  deployment  every  300Km  in  the  TEN-T  network  of  certified  WIM 
systems for direct enforcement purposes. The certified WIM systems will exponentially 
increase  the  effectivity  of  controls,  with  controls  potentially  be  carried  out  24h/7d,  by 
reducing  the  need  for  additional  resources  (certified  secondary  scales  and  enforcement 
officers  at  the  site)  as  they  eliminate  ad-hoc  roadside  controls.  Under  PM7  the  WIM 
systems will require certification and regular calibration in order to serve as proof of the 
commission of an infraction.  
On  1st  March  2023  the  Commission  adopted  a  legislative  proposal295  to  amend  the 
Directive (EU) 2015/413296 (the Cross-Border Enforcement Directive or CBE Directive). 
This proposal aims at further enhancing road safety by extending the scope of the CBE 
Directive  to  other  road-safety-related  traffic  offences.  The  “use  of  an  overloaded 

293  “Loads  surpassing  the  allowed  limits”  are  called  abnormal  loads  by  experts.  “They  include  anything 
from a mobile house and mobile crane to exceptionally large and heavy indivisible loads such as electric 
transformers, chemical reactor vessels, airplane fuselage or wings” (BPG). 
294 MS are currently obliged to deploy WIM systems in the infrastructure to, at least, detect HDV that could 
be overloaded. MS are free to decide where and how many WIM systems to deploy. They can be installed 
in any part of the network. 
295 COM(2023) 126 final. 
296 Directive (EU) 2015/413 of the European Parliament and of the Council of 11 March 2015 facilitating 
cross-border exchange of information on road safety related traffic offences (OJ L 68, 13.3.2015, p. 9–25). 

148 

 
 
 
 
                                                 
vehicle”297  is  one of them. As a consequence, the tools provided by the CBE Directive 
can be applied to identify the offender  detected through WIM systems  and facilitate its 
prosecution. 

PM8:  Require  EMS  to  comply  with  higher  safety  standards  for  HDV  than  those 
provided  for  in  the  General  Safety  Regulation  and  driver's  minimum  experience  or 
training  

All  Member  States  allowing  the  circulation  of  EMS  also  apply  additional  safety 
requirements  that  go  beyond  the  minimum  regulated  standards  of  type  approval  for 
vehicles or driver licensing and CPC for drivers. Those standards vary  among Member 
States. Currently, those standards vary among Member States and risk becoming a barrier 
to  the  international  traffic  of  EMS.  Therefore,  PM8  aims  to  make  such  requirements 
mandatory and harmonised. 

PM8  proposes  an  initial  nominal  package  based  on  the  requirements  that  have  been 
present  for  some  time  as  a  consequence  of  the  General  Safety  Regulation  or  are 
commonly available in the market but not yet ubiquitous. They reflect the most common 
type  of  measures,  either  imposed  by  Member  States  or  that  have  become  the  natural 
business  practice.  As  long  as  the  road  safety  objective  is  preserved  the  concrete  list  of 
requirements and safety systems can be the subject of technical negotiation.  

PM8 proposes the following list of cumulative safety measures: 

  Driver requirements: 

o  To be in possession of a EC driving licence for a minimum of 5 years. 
o  To have completed a specific training, following the Dutch example. 
  Vehicle  requirements  covered  the  General  Safety  Regulation  and  the  type 

approval legal framework, but which have not yet fully penetrated the fleet: 

o  ABS: to better ensure stability under braking. 
o  Electronic Stability controls: to reduce the chance of rollover.  
o  Blind spot mirrors and/or blind spot camera monitor systems. 
o  Front  underrun  protection:  to  ensure  standards  of  protection  in  impacts 

with cars at the front. 

  Vehicle  requirements  not  covered  by  the  General  Safety  Regulation  and  Type 

Approval legal framework: 

o  Minimum  turning  circle  based  on  the  W&D  Directive  requirements  but 
with  an  inner  circle  of  2m  diameter  instead  of  5.3m  to  improve 
manoeuvrability. 

297 The ‘use of an overloaded vehicle’ is defined in the legislative proposal amending the CBE Directive as 
“using  a  vehicle  that  does  not  comply  with  the  requirements  set  for  its  maximum  authorized  weights,  as 
laid  down  in  the  national  laws,  regulations  or  administrative  provisions  transposing  Council  Directive 
96/53/EC, or in the law of the Member State of the offence for vehicles or operations for which there are 
no such requirements set in that Directive”. 

149 

 
 
                                                 
o  Mandatory  electronically  controlled  brake  system  (EBS)  for  faster  brake 
response time over the longer distance between cab and rearmost axle. 
o  Minimum  power  to  weight  ratio  5kw/tonne  to  reduce  differential  speeds 
between EMS and other traffic by ensuring certain minimum acceleration 
performance. 

o  Minimum  mass  on  the  driven  axle(s)  to  ensure  a  minimum  standard  of 
traction  when  moving  away  from  rest  or  climbing  a  gradient  in  slippery 
conditions. 

150 

 
 
 
 
ANNEX 7: RULES ON WEIGHTS AND DIMENSIONS OF HDVS 

The Weights  and Dimensions Directive  (Council  Directive 96/53/EC298)  establishes the 
maximum  authorised  dimensions  of  heavy-duty  vehicles  (HDVs)  in  national  and 
international  traffic  and  the  maximum  authorised  weights  in  international  traffic.  The 
primary  objective  was  to  ensure  fair  competition  and  eliminate  the  obstacles  to  cross-
border  traffic,  while  safeguarding  the  right  balance  with  the  need  to  protect  road 
infrastructure and guarantee road safety. 

Scope 

The W&D Directive applies to: 

1)  the  dimensions  of  motor  vehicles  in  categories  M2  and  M3  and  their  trailers  in 
category O and motor vehicles in categories N2 and N3 and their trailers in categories 
O3 and O4, as defined in the type approval legal framework.  

Those  categories  of  vehicles  are  currently  defined  in  Article  4  of  Regulation  (EU) 
2018/858299 and correspond, in general terms, to: 

-  buses and coaches: motor vehicles designed and constructed primarily for the 
carriage  of  passengers  and  their  luggage,  with  more  than  eight  seating 
positions in addition to the driver's seating position (categories M2 and M3),  
-  heavy goods vehicles: motor vehicles designed and constructed primarily for 
the carriage of goods with a maximum mass exceeding 3,5 tonnes (categories 
N2 and N3)  
and their trailers or semitrailers (category O, O3 and O4).  

- 

Light  duty  vehicles  and  vans  below  3.5  tonnes  and  passenger  cars  below  eight 
seating positions for the passengers are outside the scope of the W&D Directive.  
Buses comprising more than one articulated section are expressly excluded from the 
scope of the Directive (Article 1.3 of the W&D Directive).  

2)  the weights  and certain  other characteristics of the HDVs defined in  point  1 above. 
All the values of weights, which are indicated in Annex I of the W&D Directive, are 
valid as circulation standards and thus refer to loading conditions, not  to production 
standards.  

General rules 

The key limits regarding maximum dimensions as set in Annex I of the W&D Directive 
are the following: 

298 Consolidated text:  Council  Directive 96/53/EC of 25 July 1996 laying down  for certain road vehicles 
circulating within the Community the maximum authorized dimensions in national and international traffic 
and the maximum authorized weights in international traffic. 
299 Consolidated text: Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 
2018  on  the  approval  and  market  surveillance  of  motor  vehicles  and  their  trailers,  and  of  systems, 
components  and  separate  technical  units  intended  for  such  vehicles,  amending  Regulations  (EC)  No 
715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC. 

151 

 
 
  
                                                 
-  maximum  length:  16.5m  for  articulated  vehicles  (motor  vehicle/semi-trailer 
combinations) and 18.75m for road trains (motor vehicle/trailer combinations);  

-  maximum height: 4 m; and 
-  maximum width: 2.55 – 2.60m. 

The key limits regarding maximum weights as set in Annex I of the W&D Directive are 
the following: 

-  maximum weight or gross vehicle weight (GVW):  

  18 tonnes for two-axle trucks; 
  19,5 tonnes for two-axle buses;  
  26 tonnes for three-axle motor vehicles; 
  28 tonnes for three-axle articulated buses;  
  32 tonnes for four-axle vehicles; 
  36 tonnes for four-axle vehicle combinations; 
  40 tonnes for five or six-axle vehicle combinations, which could be increased 
to  42/44  tonnes  (depending  on  the  number  of  the  axles  of  the  vehicle 
combination) for certain vehicles engaged in intermodal transport operations; 

-  Axle weight: 

  Maximum axle weight of a driving axle: 11.5 tonnes. 
  Maximum axle weight of a single axle: 10 tonnes. 
  Sum  of  the  axle  weights  per  tandem  axle  and  per  tri-axle  of  trailers  and 
semitrailers  may  not  exceed  certain  limits  ranging  from  11  tonnes  to  24 
tonnes depending on the distance between axles. 

  Minimum  weight  borne  by  the  driving  axle  or  driving  axles  of  a  vehicle  or 
vehicle combination must not be less than 25 % of the total laden weight of 
the vehicle or vehicle combination, when used in international traffic. 
One key additional requirement set in Annex I of the W&D Directive refers to the so 
called  “Turning  circle  rule”  which  aims  at  ensuring  the  manoeuvrability  of  all  HDV. 
According to this rule any motor vehicle or vehicle combination which is in motion must 
be able to turn within a swept circle having an outer radius of 12.50m and an inner radius 
of 5.30 m. 

Vehicles complying with limits set in the W&D Directive are allowed to circulate on the 
territory of the EU without any restrictions.  

National and international derogations 

The  W&D  Directive  allows  for  national  derogations,  so  that  Member  States  may 
authorise  the  circulation  in  their  territories  of  HDV  exceeding  the  maximum  weights 
(with  no  limitations)  and  /or  maximum  dimensions  set  in  the  Directive.  The  national 
derogations for dimensions of vehicles are limited to specific use cases, namely:     
(i) 
(ii) 
(iii) 

specialised vehicles, such as the ones used in the forestry industry; and  
European Modular System (EMS) 
trial schemes; 

152 

 
 
 
The W&D Directive does not explicitly allow heavier or longer vehicles in international 
transport. HDV used in international transport are bound by the limits set in the Directive 
even  when  they  cross  the  territory  of  two  neighbouring  Member  States  that  allow  the 
same  higher  maximum  authorised  weights  and/or  dimensions  on  their  territories.  Here, 
the directive foresees certain exceptions. 

Derogations to maximum dimensions in national transport  

Articles  4(4)  and  (5)  of  the  Directive  allows  for  extra  dimensions  of  HDVs  in  the 
following cases: 

1)  local activities: Member States may allow in their territory longer (and/or wider) 
specialised vehicles or vehicle combinations in  circumstances  in  which they  are 
not  normally  carried  out  by  vehicles  from  other  MS,  e.g.  operations  linked  to 
logging and forestry industry. 

These specialised longer vehicles have been in use, in particular in Sweden and 
Finland. 

2)  modular  concept:  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.  These  combinations  are  known  as  modular  concept  or  European 
modular systems (EMS). 

These  derogations  have  its  origin  in  the  need  to  preserve  the  regime  of  the 
Scandinavian countries, which traditionally operated longer vehicles (up to 22 or 
24 meters) in domestic transport. To avoid the distortion of competition Member 
States  could  operate  larger  vehicles  and  trailers  with  deviating  dimensions  on 
their  territory  as  long  as  operators  from  a  different  Member  States  could 
compose competitive vehicle combinations with standard European equipment. It 
has resulted in the authorisation in the Scandinavian countries of EMS of up to 
25.25m, the shortest possible combination with equivalent loaded length as their 
22-24m long vehicles. 

3)  trial  periods:  Member  States  may  conduct  local  transport  operations  for  trial 
periods incorporating new technologies or new concepts, with vehicles or vehicle 
combinations exceeding maximum weights and/or dimensions.  

Member  States  have  made  use  of  this  possibility  to  allow  EMS  too.  The  most 
common  combinations  of  EMS  under  trial  schemes  are  25.25  m  and  60  tonnes, 
although other variants exist.  

Currently, the use of modular systems (EMS) of 25.25m long is allowed in Finland and 
Sweden,  and  is  being  trialled  in  Denmark,  the  Netherlands,  Belgium,  Spain,  Portugal, 
Czech  Republic  and  some  German  Länder.  Additionally,  Italy  allows  for  longer 
semitrailers so as to allow for a maximum length of the vehicle combination of 18m. 

Derogations to maximum weights in national transport  

Member  States  are  free  to  allow  on  their  territories  the  circulation  of  heavier  vehicles 
without any limitations.  

153 

 
 
As  a  result,  there  is  a  range  of  national  weight  limitations  in  the  EU  for  vehicle 
combinations of five or more axles varying from 40t to 44t, 48t, 50t, 60t and up to 104t 
for nine and ten-axel vehicle combinations in different Member States.  

All  Member  States  allowing  EMS  (Finland  and  Sweden,  and  trials  in  Denmark,  the 
Netherlands,  Belgium,  Spain,  Portugal  and  Czech  Republic)  with  the  exception  of 
Germany,  allow  for  an  extra  weight  (of  up  to  60  tonnes  in  most  cases).  Additionally, 
Belgium, Czech Republic, France, Ireland, Italy, Luxembourg, the Netherlands, Portugal, 
Sweden, Denmark and Finland allow the circulation in national transport of five and/or 
six-axle vehicle combinations with a maximum weight of 44 tonnes300. 

Derogations to maximum weights in international transport  

Apart  from  derogations  from  the  maximum  authorised  weight  for  intermodal  transport 
operations,  alternatively  fuelled  vehicles,  and  the  transport  of  indivisible  loads,  the 
directive does not foresee any derogations from weight limits applicable to international 
transport.  This  means  that  the  Directive  does  not  allow  to  cross  borders  by  heavier 
vehicles (other than those eligible for derogation) between neighbouring countries even if 
both  of  them  authorise  44  tonnes  HDVs  (or  use  heavier  EMS)  in  their  respective 
territories.  

There is, however, a particular situation applicable to the Benelux countries. It originates 
in  the  Treaty  Establishing  the  Benelux  Economic  Union301,  which  was  recognised  by 
article  350  of  the  Treaty  of  the  Functioning  of  the  EU302.  As  a  result,  Belgium, 
Luxembourg  and  the  Netherlands,  are  allowed  to  take  advantage  of  the  possibility 
foreseen in article 4(5) of the WDD303, without the borders of the three countries being 
an impediment to conducting trials, in order to realise the Benelux internal market. The 
Benelux countries have made use of this possibility for cross-border transport by heavier 
vehicles up to 44t. 

In addition to this diversity of regimes, the directive foresees the international transport 
of indivisible loads304 which, owing to their dimensions or masses, cannot be transported 
in  a vehicle or vehicle combination complying  with  the limits  set in  the Directive. The 
circulation  of  this  particular  type  of  transport  is  subject  to  a  national  special  permit, 
which should be issued without discrimination (article 4(3) of the Directive). Other than 

the  Benelux  Economic  Union  available 

300 Czech Republic allows a maximum weight of up to 48t, the Netherlands of up to 50t and allows a maximum weight 
of up to 56t for the transport of excavation and mining materials. 
301  Consolidated  version  of 
the  Treaty  Establishing 
https://wetten.overheid.nl/BWBV0005047/2012-01-01  
302 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.” 
303 Article 4.5 of the Weights and Dimensions Directive: “Member States may allow vehicles or vehicles combinations 
incorporating new technologies or new concepts which cannot comply with one or more requirements of this Directive 
to carry out local transport operations for a trial period”. 
304 Indivisible load is defined by Article 2 of Council Directive 96/53/EC 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”.  

in 

154 

 
 
                                                 
that, Member States are free to authorise the transport of indivisible loads and to set the 
procedure and conditions for the issuing of the permits.  

155 

 
 
 
 
ANNEX 8: DISCARDED POLICY MEASURES  

Mandating that semitrailers are craneable 

This  measure  was  proposed  during  the  consultation  activities  (call  for  evidence,  open 
public  consultation,  targeted  consultation/interviews  and/or  position  papers305)  by 
stakeholders involved in rail transport as a measure that would promote intermodal road-
rail  transport.  It  appears,  however,  that  it  will  have  a  negative  impact  on  intermodal 
transport (road-rail and road-maritime) for reasons explained below. 

Firstly, craneability is not necessary for most intermodal transport using semitrailers. On 
the  one  hand,  the  biggest  share  of  intermodal  transport  in  semitrailers  takes  place  on 
ferries  (64%  of  all  intermodal  transport  operations306),  where  semitrailers  and  trucks 
enter  the  ferries  by  their  own  means.  On  the  other  hand,  craneability  is  not  strictly 
necessary  for  all  rail-road  intermodal  transport,  given  that  there  are  horizontal 
transhipment technologies available for non-craneable semitrailers and for the so-called 
“rolling  highways”  307.  These  horizontal  transhipment  technologies  are  used  in 
approximately one-third of all semi-trailer intermodal road-rail operations in the EU. 

Secondly,  mandating  the  craneability  of  semitrailers  would  be  against  the  principle  of 
transhipment 
facto 
technological  neutrality 
technologies in detriment of the horizontal ones. 

imposing  de 

to  vertical 

the  resort 

Finally, it  would  increase the  cost  and reduce the efficiency  of intermodal  transport, in 
particular  for  containerised  transport  (both  in  maritime  and  railway  transport)  as  a 
consequence of the costs of the technology308 and its maintenance. In addition, the weight 
of  the  technology  would  reduce  the  semitrailers  loading  capacity  by  approximately  1 
tonne.  

Overall,  this  measure  would  not  effectively  and  efficiently  promote  the  intermodal 
operations. 

305  See  position  paper  from  the  European  railway  operators  and  railway  infrastructure  companies 
association (CER) “Combined Transport AND road vehicle Weights & Dimensions, two sides of the same 
coin 
10  GUIDING  PRINCIPLES  for  the  Revision  of  the  Multimodal  Regulatory  Framework”  from  19 
September 2022. 
306  European  Commission,  Directorate-General  for  Mobility  and  Transport, Comparative  evaluation  of 
transhipment technologies for intermodal transport and their cost: final report, Publications Office of the 
European Union, 2022, https://data.europa.eu/doi/10.2832/743839. 
307 The Rolling highway is a transport system for accompanied combined transport by rail or a special train 
in which complete trucks or semitrailers are transported by rail. 
308 The European Commission, Directorate-General for Mobility and Transport, Comparative evaluation of 
transhipment technologies for intermodal transport and their cost: final report, Publications Office of the 
European  Union,  2022, https://data.europa.eu/doi/10.2832/743839  estimates  the  costs  of  craneable 
semitrailers in an additional 1.000€ per unit cost and a slightly higher maintenance costs per year (+30€) as 
compared to non-craneable semitrailers. 

156 

 
 
 
                                                 
Mandating the equipment of HDV with aerodynamic devices 

To address the low uptake of aerodynamic devices, the Commission considered making 
the  use  of  aerodynamic  and  other  energy-saving  technologies  mandatory.  The 
stakeholders  consultations  revealed  a  significant  reluctance  between  respondents  as 
regards the usefulness of this measure309. 

The  evaluation  of  the  W&D  Directive  confirmed  that  the  low  uptake  of  aerodynamic 
devices is mainly due to the fact that not enough time had passed since the adoption of 
the necessary type-approval legislation and secondary legislation in December 2019 and 
therefore more time should be allowed for the current rules to become effective. During 
the consultation process, several stakeholders expressed the views that the business case 
for the use of such devices is not so strong and common across the road haulage sector in 
order to create a high level of demand. Indeed, the benefits of the use of such devices (i.e. 
reducing  the  drag  and  improving  fuel  efficiency  leading  to  lower  operating  costs  and 
GHG  emissions)  can  mainly  be  observed  in  long-haul  trucking  operations  with  high 
speeds over longer stretches of highways. The benefits are very limited in other types of 
operations, such as short-haul delivery trucks going at lower speeds and making frequent 
stops.  

Some industry stakeholders (e.g. vehicle transporters) pointed out that due to the shape of 
their  loads,  there  is  little  to  be  gained  by  using  aerodynamic  devices.  They  argued  that 
more energy efficiency can be achieved by transporting a larger volume of goods at once, 
e.g.  by  increasing  loaded  length.  An  obligation  to  equip  vehicles  with  aerodynamic 
devices could prove counterproductive if it is offset by a reduction in energy efficiency 
due to a lower loading capacity.  

Furthermore,  the  stakeholders  raised  concerns  about  the  technical  feasibility  and 
usefulness of such a measure in intermodal operations. Indeed, the aerodynamic devices 
that increase the height or width of the truck could affect compatibility with rail transport 
and other modes.  

Nevertheless,  as  the  use  of  aerodynamic  devices,  such  as  rear  flaps,  underbody  panels, 
side  cover  extensions  or  gap  reducers,  promise  benefits  of  greater  energy  efficiency,  it 
can  be  expected  that  operators  will  be  interested  in  installing  them  in  the  new  zero-
emission  trucks  (e.g.  to  optimize  the  use  of  the  battery  and  reduce  the  frequency  of 
breaks for charging). The increased interest will incentivise truck manufacturers to offer 
additional aerodynamic equipment at competitive prices. 

In addition, the HDV CO2 standards promote indirectly the adoption of such devices by 
setting  fleet-wide  CO2  reduction  targets  (confirmed  15%  by  2023  with  respect  to  2019 
baseline and propose 45% by 2030) that can directly be translated into energy efficiency 
gains.  

309 According to the open public consultation out of 134 participants, 25% considered the measured useful, 
while 74% considered the measure detrimental or at least not particularly useful. 

157 

 
 
                                                 
Given  the  above,  and  the  fact  that  none  of  the  stakeholders  argued  in  favour  of  an 
obligation to equip HDV with aerodynamic devices, there is no strong justification for an 
additional regulatory intervention in this area.  

Mandating the equipment of HDV exceeding the maximum weights with on-board 
weighing (OBW) devices. 

To step up enforcement, all Member States opted for the installation of Weigh-in-motion 
(WIM)  systems  in  the  road  infrastructure  instead  of  imposing  the  use  of  On-Board 
Weighing  (OBW)  equipment  for  vehicles,  ensuring  that  all  HDVs  can  be  checked  as 
regards their compliance with the maximum authorised weight throughout the whole EU 
territory.  However,  as  shown  in  the  evaluation  report  there  is  a  general  lack  of 
information  on  the  number  of  WIM  systems  installed,  in-service,  operated,  or  on  the 
number of measurements gathered. 

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  OBW310  for  reasons  of  societal  costs,  transport  efficiency, 
fair  competition  and  technology  uncertainties.  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. 

The Commission considered a measure of mandatory equipping the HDV, exceeding the 
maximum weights set in the Directive, with OBW devices in order to address the market 
segments  posing  a  higher  risk  to  the  protection  of  the  infrastructure  and  to  road  safety 
(namely,  EMS  and  indivisible  loads).  Mandating  OBW  would  limit  the  scope  of  the 
measure  to  those  relatively  small  market  segments  and  would  duplicate  the  detection 
systems,  adding  disproportionate  costs  to  public  authorities311,  to  manufacturers  and  to 
road  transport  operators312.  The  same  result  could  be  achieved  more  efficiently  via  the 
installation of a minimum number of WIM systems and performing a minimum level of 
controls. 

310 As a  way of example, the cost-benefit analysis carried out by the Swedish Transport Agency in 2020 
(“Scales  in  the  infrastructure  or  in  the  vehicles?”)  concluded  that  mandating  OBW  systems  have  greater 
costs than the expected benefits (societal economic cost of SEK 7.8 billion). 
311 Costs for public authorities include, among others the set-up of the system to receive and process the 
information, including the equipment of the network with road-side units and/or smart devices for control 
officers. 
312 According to the same  analysis carried out by the Swedish  Transport Agency in 2020 (“Scales in the 
infrastructure  or  in  the  vehicles?”),  the  average  installation  cost  is  estimated  for  around  10.500  €  per 
vehicle. 

158 

 
 
 
 
                                                 
ANNEX 9: CONCLUSIONS OF THE EVALUATION 

The links between the conclusions of the ex-post evaluation  and the impact assessment 
are summarised in the table below. 

Table 70: Links between conclusions of the ex-post evaluation and the impact assessment 

Main ex-post evaluation conclusions 

Impact Assessment 

Policy  measures  are  designed  to  clarify  the 
provisions and  further  harmonise technical and 
administrative  requirements  for  the  use  of 
longer  and/or  heavier  vehicles  in  cross-border 
operations.  

The  impact  assessment  assesses  measures  to 
boost the  uptake of zero-emission technologies 
and  to  further  promote  intermodal  transport  by 
allowing extra weights/length for zero-emission 
HDVs  and  extra  height 
intermodal 
operations.  It  also  supports  the  increase  in 
energy  performance  of 
operational 
conventional  vehicle  combinations  in  cross-
border traffic. 

and 

for 

The  impact  assessment  takes  into  account  the 
vehicle  safety  and  road  safety  requirements  as 
well as the capacity of the road infrastructure to 
handle 
and 
dimensions of HDVs. 

increased  weights 

possibly 

Policy  measures  are  defined 
remove 
and 
unnecessary 
administrative  burdens  with  regard  to  cross-
border traffic of longer/heavier vehicles.  

regulatory 

barriers 

to 

The  measures  also  support  targeting  roadside 
controls to render enforcement more efficient. 

Conclusions on effectiveness 

The  Directive  was  only  partially  successful  in  achieving  its 
objectives.  The  Directive  removed  technical  barriers  to  carrying 
out  cabotage  operations  and  facilitated  cross-border  transport 
operations  by  standard  HDVs.  However,  due  to  various  national 
derogations and ambiguities of certain provisions of the Directive, 
a  patchwork  of  diverging  national 
technical  and 
administrative requirements for the use of longer/heavier vehicles 
as  well  as  bilateral  arrangements  emerged,  leading  to  the 
fragmentation of certain segments of the internal market. 

rules, 

The  Directive  had  limited  impact  on  sustainability.  It  has 
facilitated  the  containerised  intermodal  transport  by  allowing 
extra  weight  to  compensate  the  weight  of  empty  container. 
However  by  allowing  for  higher  weight  limits  in  national  road-
only  operations,  the  intermodal  operations  have  been  put  in  a 
disadvantaged  position.  The  provisions  to  incentivise  the  uptake 
of  alternatively  fuelled  powertrains  and  aerodynamic  devices 
were  insufficient  and  not  reflecting  the  operational  and  zero-
emission technology requirements. 

The  Directive  has  been  effective  in  improving  road  safety  and 
preventing wear and tear of infrastructure as it sets maximum safe 
limits  for  weights  and  sizes  of  HDVs  which  however  can  be 
adapted  in  national  territories  to  the  MS  infrastructure  standards 
and operational conditions. 

Conclusions on efficiency 

The Directive reduced administrative burden by providing that all 
vehicles  must  comply,  in  principle,  with  the  same  standards  in 
cross-border  traffic.  On  the  other  hand,  by  enabling  higher 
national  standards  on  weight/dimension  of  HDVs  and  national 
requirements  for  the  circulation  of  longer  vehicles  on  their 
territories,  the  Directive  rendered  certain  operations  more  costly 
and  procedures  more  time-consuming.  The  Directive  has  not 
enabled efficient enforcement.  

Conclusions on coherence 

159 

 
 
  
 
The Directive is coherent with the relevant EU road transport and 
transport  decarbonisation  policies  and  initiatives.  Inconsistencies 
have  been  found  between  the  Directive  and  the  Combined 
Transport  Directive  with 
the  definition  of 
intermodal/combined  transport.  The  internal  incoherence  of  the 
certain  provisions  of  the  Directive  also  hampered  more  effective 
promotion on intermodal operations.   

regard 

to 

Conclusions on EU added value 

The  Directive’s  EU  added  value  lies  in  facilitating  cross-border 
trade  in  the  EU  Single  Market  by  harmonizing  the  (standard) 
HDV technical requirements across Member States.  

Conclusions on relevance 

in 

the 

The  Directive  remains  relevant,  as  it  continues  to  address  key 
challenges 
transport  sector,  such  as  road  safety, 
environmental  protection,  and  fair  competition.  However,  its 
provisions need to be updated to effectively and efficiently realize 
the Directive’s objectives. 

The  impact  assessment  supports  the  alignment 
of  the  Directive’s  provisions  with  those  in  the 
Combined Transport Directive. Policy measures 
are  defined  to  create  synergies  with  other 
relevant  initiatives  such  as  TEN-T  Regulation, 
rail  capacity  initiative,  and  CO2  standards  for 
HDVs.    

for 

Policy  measures  will  support  harmonisation  of 
requirements 
in  cross-border 
the  use 
operations  of  non-standard  HDVs  (such  as  car 
transporters,  abnormal 
to 
strengthen the internal market.  

transport,  etc.) 

Policy measures are defined to update and adapt 
certain  provisions  of  the  Directive  to  the 
technological  developments  such  as  zero-
emission 
technologies,  multimodality  and 
digitalisation. 

160 

 
 
ANNEX 10: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS 

This annex provides more detailed explanations on the assessment of effectiveness of the policy options, complementing the analysis in section 7.1. 

Key impacts expected 

 

 

O 

 

 

 

Strongly negative 

Negative 

No or negligible impact 

Positive 

Moderately positive 

Strongly positive 

Unclear 

Specific policy objective 1: Remove barriers for the uptake of ZEV and energy-saving devices and incentivise intermodal transport 

PO-A 

PO-B 

PO-C 

increase 

Expected 
transport 
performed by ZE HDVs 

of 
activity 

Positive 
performed by ZE HDVs.  

impact  on 

increasing 

the  activity 

Moderately  positive  impact  on  increasing  the 
activity performed by ZE HDVs. 

Strong  positive  impact  on  increasing  the  activity 
performed by ZE HDVs. 

Compensating  the  losses  in  weight  and  length 
capacity of HDVs linked to the weight and space 
taken by zero-emission technologies (PMc1) will 
ensure a level playing field for ZEV as compared 
to diesel HDVs, including the extra weight born 
trailers  and  semitrailers  equipped  with 
by 
powertrains.  The 
auxiliary 
incentive  for  BEV  is  however  limited  as  it  is 
expected that from 2035 onwards the decrease in 
the  weight  of  batteries  will  make  this  policy 
measure redundant. The incentive will remain for 
emerging 
FCEV 

zero-emission 

potential 

other 

and 

The  maximum  compensation  necessary  for  the 
extra  weight  of  the  zero-emission  technologies 
envisaged under PO-A will be maintain over the 
period  2025-2050  in  PO-B  regardless  of  the 
weight  of  the  technology  (PM1).  This  will 
provide  additional  payload  to  FCEV  instantly 
and  to  BEV  progressively  as  batteries  become 
lighter. PO-B will thus provide greater incentives 
to  operators  to  invest  in  ZEV  and  to  HDVs 
manufacturers  to  develop  lighter  technologies 
and improve the aerodynamics that will increase 
the  range  of  ZEV  and  reduce  the  consumption 

PO-C will integrate the benefits of PO-A and, by  
allowing  the  use  of  zero-emission  EMS  in 
national and international transport (PM3), it will 
bring  additional  incentives  for  ZEV  stemming 
from  the  increased  payload  and  the  reduction  in 
transport  costs.  As  a  result,  cumulatively  over 
2025-2050,  PO-C  is  estimated  to  increase  the 
activity  of  road  freight  transport  performed  by 
ZEV by 430.6 billion tonne-kilometres relative to 
the baseline.  

 
 
 
 
 
 
technologies.  As  a  result,  cumulatively  over 
2025-2050,  PO-A  is  estimated  to  increase  the 
activity  of  road  freight  transport  performed  by 
ZEV by 62.3 billion tonne-kilometres relative to 
the baseline. 

from  the  main  powertrain  in  refrigerated  units. 
PO-B  will also ensure  that as of 2035 44t HDV 
will  be  able  to  circulate  in  international  traffic, 
only  if  they  are  ZEV,  allowing  operators  that 
currently use 44t HDV in international transport 
to  progressively  renew  their  fleets.  As  a  result, 
cumulatively over 2025-2050, PO-B is estimated 
to  increase  the  activity  of  road  freight  transport 
performed  by  ZEV  by  176.4  billion  tonne-
kilometres relative to the baseline.   

Expected 
intermodal 
operations 

increase 

in 
transport 

Positive 
transport operations  

impact  on 

increasing 

intermodal 

Strong  positive  impact  on  increasing  intermodal 
transport operations  

Strong  positive  impact  on  increasing  intermodal 
transport operations  

The  transport  of  high-cube  containers  with  non-
dedicated  equipment  will  be  facilitated  through 
the  elimination  of  national  permits  (PMc2), 
reducing  the  administrative  burden  and  costs 
linked  to  obtaining  such  permits.  However,  the 
effectiveness  of  this  measure  is  limited  by  the 
fact  that  part  of  the  road  infrastructure  is  not 
accessible to vehicles with height of 4.3m.   PO-
A  will  not  incentivise  the  uptake  of  non-
containerised intermodal transport.  In PO-A, the 
shift  from  road-only  to  intermodal  transport  is 
estimated  at  around  12  billion  tonne-kilometres 
in 2030 and 14 billion tonne-kilometres in 2050, 
relative to the baseline.  

In  addition  to  the  support  provided  by  PO-A, 
PO-B significantly improves the attractiveness of 
intermodal transport by extending the allowance 
of  extra  4  tonnes  (currently  used  to  compensate 
the  weight  of  empty  container  or  swap  body  in 
intermodal operations) also  to non-containerised 
intermodal  operations  (PM2).  In  practice,  it 
means  that  operators  using  conventional  HDVs 
may benefit from additional payload when using 
in 
their 
trailers  and 
the 
intermodal 
alignment  of  the  W&D  Directive  with  the  CTD 
under PO-B would bring along synergy effects in 
promoting  growth  of  intermodal  transport.  The 
shift  from  road-only  to  intermodal  transport  in 
PO-B  is  estimated  at  around  21  billion  tonne-
tonne-
kilometres 

operations.  Consequently, 

in  2030  and  26  billion 

semitrailers 

trucks, 

PO-C will integrate the benefits of PO-A and PO-
B.  In  addition,  allowing  in  international  traffic 
EMS involved in intermodal transport (PM3) will 
provide further incentives to intermodal transport 
stemming  from  the  increased  payload  and  the 
reduction in transport costs, above those provided 
by PO-B operations.  The shift from road-only to 
intermodal  transport  in  PO-C  is  estimated  at 
around  23  billion  tonne-kilometres  in  2030  and 
28  billion  tonne-kilometres  in  2050,  relative  to 
the baseline. 

162 

 
 
 
 
Expected  reduction  in  CO2 
emissions 

Positive impact on reducing CO2 emissions from 
freight transport 

Strong  positive  impact  on  reducing  barriers  to 
cross-border transport 

Strong  positive  impact  on  reducing  barriers  to 
cross-border transport 

kilometres in 2050, relative to the baseline.  

In  PO-A  the  reduction  in  the  CO2  emissions  is 
driven  by  the  increase  in  the  share  of  zero-
emission  vehicles  in  the  HDVs  fleet  (due  to 
PMc1),  the  increase  in  the  intermodal  transport 
(due  to  PMc2)  and  the  improved  efficiency  of 
transport  operations  (PMc3,  PMc4  and  PMc5).  
Cumulatively 
is 
estimated  to  reduce  CO2  emissions  by  10.7 
million  tonnes  relative  to  the  baseline  (0.5%  of 
the CO2 emissions from freight transport). 

2025-2050,  PO-A 

over 

In  PO-B  the  reduction  in  the  CO2  emissions  is 
driven  by  the  increase  in  the  share  of  zero-
emission  vehicles  in  the  HDVs  fleet  (due  to 
PMc1  and  PM1),  the  increase  in  the  intermodal 
transport  (due  to  PMc2  and  PM2)  and  the 
improved  efficiency  of 
transport  operations 
(PMc3,  PMc4  and  PMc5  in  all  policy  options).  
is 
Cumulatively 
estimated  to  reduce  CO2  emissions  by  27.8 
million  tonnes  relative  to  the  baseline  (1.2%  of 
the CO2 emissions from freight transport). 

2025-2050,  PO-B 

over 

In  PO-C  the  reduction  in  the  CO2  emissions  is 
driven  by  the  increase  in  the  share  of  zero-
emission  vehicles  in  the  HDVs  fleet  (due  to 
PMc1  and  PM3),  the  increase  in  the  intermodal 
transport  (due  to  PMc2,  PM2  and  PM3)  and  the 
improved  efficiency  of 
transport  operations 
(PMc3,  PMc4  and  PMc5  in  all  policy  options).  
Cumulatively over 2025-2050, PO-C is estimated 
to reduce CO2 emissions by  29.8 million tonnes 
relative  to  the  baseline  (1.3%  of  the  CO2 
emissions from freight transport). 

Specific policy objective 2: Harmonise the rules on maximum weights and dimensions  of HDV in cross-border operations 

Expected  reduction  of  the 
to 
number  of  barriers 
transport, 
cross-border 
including 
for 
special permits  

the  need 

Moderately  positive  impact  on  reducing  barriers 
to cross-border transport 

Strong  positive  impact  on  reducing  barriers  to 
cross-border transport 

Strong  positive  impact  on  reducing  barriers  to 
cross-border transport 

PO-A  fully  eliminates  the  regulatory  barriers  at 
EU  level  for  cross-border  transport  of  5-  and  6-
axle  rigid  trucks,  harmonising  their  maximum 
weights with that of vehicles combinations of the 
same  number  of  axles  (PMc3).  PO-A  also   
eliminates  the  regulatory  barriers  to  the  cross-
transporters, 
border 
regulating  the  extended  length  of  these  vehicles 
via  the  use  of  overhangs  (PMc5),  currently 

transport  of 

vehicle 

PO-B further reduces regulatory barriers relative 
to  PO-A,  by  harmonising  the  weight  standards 
for  ZEV  HDVs  in  national  and  international 
transport  (PM1).  It  also  aligns  the  definition  of 
intermodal 
the  Combined 
Transport Directive, bringing into scope all types 
of  intermodal  transport  (currently  limited  to 
containerised transport) (PM2). 

transport  with 

transport  with 

In  addition  to  the  common  measures  included  in 
all options and the alignment of the definition of 
the  Combined 
intermodal 
Transport  Directive  (included  in  PO-B),  PO-C 
also  harmonises  the  use  of  EMS  in  international 
traffic within the EU by allowing their circulation 
on  the  TEN-T  network  under  certain  conditions: 
(i)  maximum  25.25m  long  and  weigh  maximum 
60t of  maximum  weight; (ii)  ZEV or engaged in 

163 

 
 
Simplification 
authorisation 
for 
abnormal transport 

issuing  permits 

of 
procedures 
for 

subject to national rules.  

intermodal operation.  

PO-A  removes 
to  cross-border 
the  barriers 
transport  operations  by  heavier  HDVs  (44t)  and 
by  longer  and/or  heavier  vehicle  combinations 
(EMS),  however  the  harmonisation  effects  are 
limited to the operations between Member States 
that  allow  such  vehicles  in  national  transport  in 
their  territories  (PMc4).  Moreover,  EMS  remain 
subject  to  the  national  limits  in  terms  of  length, 
weight  and  axel  weight,  in  order  to  adapt  to  the 
national  circumstances  and 
the 
investments  in  infrastructure.  PO-A  will  also 
eliminate the administrative barrier related to the 
need for special permits linked to the transport of 
high-cube containers (PMc2). 

limit 

to 

The  positive  effects  of  this  harmonisation  are 
however  partially  offset  by  the  fact  that  these 
conditions  for  circulation  pose  new  barriers  in 
Member  States  which  currently  use  EMS  in 
cross-border operations without restrictions. 

Setting  abnormal  road  transport  corridors  (PM5) 
will  further  simplify  the  procedures  for  special 
permits  for  the  transport  of  indivisible  loads 
falling  within  certain  thresholds  as  regards  the 
maximum  weights  and  dimensions.  However, 
those  thresholds  remain  subject  to  national  rules 
and,  therefore,  the  continuity  of  the  corridors  in 
international transport is not guaranteed. 

No  impact  on  the  simplification  of  procedures 
for issuing permits for abnormal transport. 

Strong  positive  impact  on  the  simplification  of 
procedures  for  issuing  permits  for  abnormal 
transport. 

Strong  positive  impact  on  the  simplification  of 
procedures  for  issuing  permits  for  abnormal 
transport. 

(PM4). 

PO-B  will  reduce  administrative  barriers  linked 
to the  issuance of national permits  for abnormal 
transport 
It  will  harmonise  and 
streamline  the  procedures  for  obtaining  such 
one-stop-shop 
permits 
approach, 
road 
transport application  form  as  well as the  mutual 
acceptance  between  Member  States  and  the 
setting  of  a  Special  European  Registration  of 
full 
Trucks 

the  harmonised  abnormal 

and  Trailers, 

introducing 

enabling 

the 

by 

a 

PO-C will reduce administrative barriers linked to 
the  issuance  of  national  permits  for  abnormal 
transport (PM4). It will harmonise and streamline 
the  procedures  for  obtaining  such  permits  by 
introducing  a  one-stop-shop  approach, 
the 
harmonised  abnormal  road  transport  application 
form  as  well  as  the  mutual  acceptance  between 
Member  States  and  the  setting  of  a  Special 
European  Registration  of  Trucks  and  Trailers, 
enabling the full digitalisation of the system.  

164 

 
 
 
 
Specific policy objective 3:  Improve the enforcement of cross-border rules, including for road safety purposes 

digitalisation of the system.  

detection 
Infringement 
ratio (number of infractions 
detected  per  number  of 
HDVs controlled) 

No impact on better detecting infringements. 

Strong  positive 
infringements. 

impact  on  better  detecting 

Strong  positive 
infringements. 

impact  on  better  detecting 

PO-A  maintains  random  roadside  checks  which 
are  not 
efficient  way  of  detecting 
an 
infringements.  

The  wide  deployment  of  WIM  systems  on  the 
TEN-T  network,  where  most  commercial 
transport  operations 
are  performed,  will 
significantly  improve  the  ratio  of  detection  of  
overloaded vehicles (from 13.25% to 97%).  

The wide deployment of WIM systems for direct 
enforcement  on  the  TEN-T  network  will  slightly 
improve 
ratio  of  overloaded 
vehicles  as  compared  to  PO-B  (from  97%  to  a 
100%). 

the  detection 

Level 
controls 
of 
maximum  weights 
HDVs 

on 
of 

Positive impact on ensuring a minimum level of 
controls on maximum weights of HDVs. 

Strong  positive  impact  on  ensuring  a  minimum 
level of controls on maximum weights of HDVs. 

Strong  positive  impact  on  ensuring  a  minimum 
level of controls on maximum weights of HDVs. 

By imposing a ratio of controls on the maximum 
weight  and  axle  weight  of  HDV  per  vehicle-km 
in  all 
(6  controls  per  million  vehicle-km) 
Member  States  the  average  level  of  controls 
performed  in  the  EU  is  ensured  as  a  minimum. 
Nevertheless,  substantial  differences  remain  due 
to  the  limitations  in  human  resources  and  the 
equipment dedicated at national level. 

The  wide  deployment  of  WIM  systems  (PM6) 
will substantially increase the number of controls 
performed on HDVs´ weight with equal or lower 
level  of  resources  dedicated  to  weights  roadside 
checks than in the baseline. Resources could then 
be  dedicated  more  intensively  to  secondary 
roads.  The  establishment  of  common  minimum 
principles  to  the  voluntary  implementation  of 
intelligent 
could 
contribute  to  the  broader  deployment  of  these 
schemes,  which bring additional possibilities for 
the  control  of  compliance  of  all  HDVs  in  given 
territory.  However,  its  voluntary  nature  may 
lower 
limited  outreach 
result 

policies 

(PM8) 

access 

in  a 

thus 

165 

The  wide  deployment  of  certified  WIM  systems 
(PM7)  for  direct  enforcement  will  substantially 
increase  the  number  of  controls  performed  on 
HDVs´  weight    with    lower  level  of  resources 
dedicated  to  weights  roadside  checks  than  in  the 
baseline. Resources could then be dedicated more 
  The 
secondary 
intensively 
establishment of common minimum principles to 
the voluntary implementation of intelligent access 
policies  (PM8)  could  contribute  to  the  broader 
these  schemes,  which  bring 
deployment  of 
additional  possibilities 
the  control  of 
compliance  of  all  HDVs  in  given  territory. 
However,  its  voluntary  nature  may  result  in  a 

roads. 

for 

to 

 
 
 
 
Duration  of  controls    on 
maximum  weights 
of 
HDVs 

No  impact  on  reducing  the  duration  of  controls 
as PO-A maintains random roadside checks. 

Strong  positive  impact  on  reducing  the  duration 
of controls. 

Strong  positive 
infringements. 

impact  on  better  detecting 

effectiveness. 

limited outreach thus lower effectiveness. 

The  wide  deployment  of  certified  WIM  systems 
for  direct  enforcement  (PM7)  will  eliminate  the 
need for roadside checks on maximum weights of 
HDVs  on  the  TEN-T  network  However,  a 
minimum  level  of  police  surveillance  will  be 
serious 
necessary 
to 
infringements 
the 
can 
infrastructure  and  pose  a  risk  to  road  safety.  
Roadside checks performed on other parts of the 
network will not be affected by PO-C.  

interrupt 
that 

compromise 

the  most 

Directly  linked  to  the  higher  effectiveness  of 
WIM  systems  in  detecting  overloaded  HDVs 
(PM6),  the  number  of  roadside  checks  on 
maximum  weights  of  HDVs  carried  out  on  the 
TEN-T  network  will  decrease  substantially 
relative  to  the  baseline,  although  some  physical 
checks  at  the  roadside  will  still  be  necessary. 
Roadside checks performed on other parts of the 
network will not be affected by PO-B.  

166 

 
 
 
 
 
ANNEX 11: SME TEST 

Step  (1)  of SME  test  (identification of affected businesses).  In  the  road  transport  sector 
99%  of  companies  are  SMEs  (enterprises  employing up  to  250  people and  with  a 
turnover of less than EUR 50 million313,314). Intermodal transport involves by definition 
many different economic agents. While many operators in rail transport and shipping are 
medium  and  some  even  large  companies,  operators  in  inland  waterways  and  many 
intermodal organisers are often SMEs. Therefore, the initiative is considered relevant for 
the SMEs and the SME test has been performed (see Annex 11).  

Step  (2)  of  SME  test  (consultation  of  SME  stakeholders).  SMEs  constitute  a  significant 
share of the stakeholders involved in the consultation activities: 80 out of 128 companies that 
responded  to  the  open  public  consultation  were  SMEs  and,  among  them,  32  were 
microbusiness  (below  10  employees).  13  were  associations  of  transport  operators  and 
forwarders representing the interest of SMEs submitted their responses to the online survey-
questionnaire in the targeted stakeholder consultation, where a total of 24 transport operators 
and forwarders participated. The specific needs and challenges for SMEs were duly taken into 
account throughout the impact assessment. Key issues are mentioned below. 

Step  (3)  of  SME  test  (assessment  of  the  impacts  on  SMEs).  SMEs  stressed  the  need  to 
increase the efficiency of transport operations by removing barriers to cross-border transport 
between Member States where the same weight and dimension standards apply (prohibition of 
44t HDV in cross-border transport was the main identified barrier), as well as the reduction of 
administrative burden and simplification of procedures for the issuing of national permits. 

As explained in section 6.1.3, all policy options are expected to result in administrative and 
adjustment costs savings for road transport operators as well as to an increase in the adjustment 
costs. Overall, net costs savings for road transport operators are estimated at EUR 46.8 billion 
in PO-C, followed by PO-B with net costs savings estimated at EUR 45.1 billion and PO-A 
with net costs savings of EUR 14.7 billion, expressed as present value over 2025-2050 relative 
to the baseline (in 2022 prices).  

Considering the very large share of SMEs in the road transport sector, most of these net costs 
savings are expected to be attributed to them although the available data did not allow a split of 
these costs savings between the two groups of operators (i.e. SME and others). In addition, the 
increase in intermodal transport in all policy options will have a positive economic impact on 
the SMEs involved, which the highest benefits expected in PO-C and PO-B. 

Step (4) of SME test (minimizing negative impacts on SMEs). As indicated in section 6.1.3, 
all policy options are expected to result in a reduction of administrative costs for road transport 
operators,  in  particular  as  a  consequence  of  the  policy  measures  aimed  at  simplifying  the 
procedures  for  the  issuing  of  national  permits  for  abnormal  transport  (PMc2  in  all  policy 

313European Commission, Impact Assessment accompanying the document Proposal for a Regulation 
amending the Regulation (EC) No 1071/2009 and Regulation (EC) No 1072/2009, SWD(2017) 194 final. 
https://eur-lex.europa.eu/resource.html?uri=cellar:9d5c61bf-4629-11e7-aea8-
01aa75ed71a1.0001.02/DOC_1&format=PDF   
314 Eurostat: Services by employment size class. 
“https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_1B_SE_R2__custom_3493320/default/table” 

 
 
 
                                                 
options, PM4 in PO-B and PO-C and PM5 in PO-C), which affects the transport of indivisible 
loads,  the  transport  of  high-cube  containers  and  the  authorisation  of  EMS  in  cross-border 
transport.  Administrative  costs  savings  are  estimated  to  be  the  highest  in  PO-C  (EUR  4.5 
billion),  followed  by  PO-B  (EUR  4.4  billion)  and  PO-A  (EUR  3.2  billion),  expressed  as 
present value over 2025-2050, relative to the baseline.  

All  policy  options  will  eliminate  the  inefficiencies  of  road  transport  resulting  from  the 
divergence  between  national  and  international  (intra-EU)  rules  via  the  adoption  of 
harmonisation measures (PMc4, PMc5). In addition, it is expected that a reduction of transport 
costs will facilitate the uptake of ZEV and/or the resort to intermodal transport (PMc1, PM1, 
PM2 and PM3) for SMEs.  

Alternative options. None. 

 
 
 
ANNEX 12: LETTER FROM FORMER VICE-PRESIDENT SIIM 
KALLAS, 13 JUNE 2012 

 
 
 
 
 
 
 
 
 
 
ANNEX 13: MONITORING  

To measure the progress and the actual effects of the initiative, a list of operational objectives 
and indicators for assessing the progress towards them have been identified and are detailed in 
Table 71. 

Table 71: Operational objectives and indicators for the monitoring of impacts 

Operational objectives 
Increase  the  uptake  of  zero-emission  HDVs  and 
aerodynamic devices 

Increase the intermodal freight transport 

Improve  operational  efficiency  of  cross-border 
road transport operations 
Increase effectiveness of controls for compliance 

Indicators 

Number of newly registered ZE HDVs per year 
Share of ZE HDVs in total fleet 
Share of HDV with aerodynamic devices 
Share of HDVs involved in intermodal operations 
The  use  of  45’  containers  transported  as  part  of 
intermodal transport 
The use of EMS in cross border traffic 

Number of vehicles controlled per year 
Number  and  gravity  of  infringements  (level  of 
excess of weight) detected 
Number  and  type  of  Weigh-in-Motion  systems 
installed  
Changes in infringement detection ratio 

The data for assessing these operational objectives will draw on the from regular monitoring 
activities  described  in  section  9  as  well  as  ad  hoc  data  collection  actions,  including  by 
exploiting  the  existing  databases  and  data  exchange  systems,  such  as  CARE  database  or 
European Register of Road Transport Undertaking (ERRU). 

 
 
 
 
 
 
ANNEX 14: VISUALS FOR CONCEPT UNDERSTANDING 

Figure 11: Articulated vehicle consisting of truck and semitrailer, semitrailer highlighted 

Source: Longer Semi-trailer Trial (publishing.service.gov.uk) 

Figure 12: Classic trailer (for comparison) attached to rigid truck, trailer highlighted. 

Source: Longer Semi-trailer Trial (publishing.service.gov.uk) 

 
 
 
 
 
 
 
 
Figure 13: Swap body 

Source: Schmitz Cargobull 

Figure 14: Swap body trailer (empty)  

Source: Schmitz Cargobull 

 
 
 
 
 
 
Figure 15: Swap body trailer (loading process)  

Source: Schmitz Cargobull 

Figure 16: Truck powertrain  

Source:  Williamson,  D.  et  al.  (2018):  The  hunt  for  proper  relation  weights  in  product  architecture 
clustering, Nord Design Conference, 2018 

 
 
 
 
 
Figure 17: Rear aerodynamic flaps on a semitrailer 

Source: ZF 

Figure 18: TEN-T network 

 
 
 
 
 
 
ANNEX 15: EVALUATION REPORT (SEPARATE DOCUMENT) 

Separate document: Evaluation SWD and specific annexes.