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 92/106/EEC as regards a support framework for intermodal transport of goods and Regulation (EU) 2020/1056 of the European Parliament and the Council as regards calculation of external costs savings and generation of aggregated data
Date: 2023-11-07
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: carriage of goods, combined transport, common transport policy, data processing, freight rate, inland waterway transport, maritime transport, rail transport, road transport, savings

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 7.11.2023  SWD(2023) 351 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 92/106/EEC as regards a support framework for intermodal transport of goods and Regulation (EU) 2020/1056 of the European Parliament and the Council as regards calculation of external costs savings and generation of aggregated data {COM(2023) 702 final} - {SEC(2023) 373 final} - {SWD(2023) 352 final}  
 
 
Table of Contents 

1. 

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

1.1.  Political context ................................................................................................. 1 
1.2.  Legal context ..................................................................................................... 2 
1.3.  Synergies with other EU policy instruments ..................................................... 3 
1.4.  Evaluation of the Directive ................................................................................ 5 
1.5.  Sustainable development goals (SDG) .............................................................. 6 

2. 

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

2.1.  What is the problem? ......................................................................................... 6 
2.2.  What are the problem drivers? ........................................................................ 12 
2.3.  How likely is the problem to persist? .............................................................. 16 

3.  WHY SHOULD THE EU ACT? ........................................................................................................ 17 

3.1.  Legal basis ....................................................................................................... 17 
3.2.  Subsidiarity: Necessity of EU action ............................................................... 17 
3.3.  Subsidiarity: Added value of EU action .......................................................... 17 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 17 

4.1.  General objectives ........................................................................................... 17 
4.2.  Specific objectives ........................................................................................... 18 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 19 

5.1.  What is the baseline from which options are assessed? .................................. 19 
5.2.  Description of the policy options .................................................................... 22 
5.2.1. Retained policy measures ................................................................................ 22 
5.2.2. The construction and description of the options .............................................. 26 
5.3.  Measures and options discarded at an early stage ........................................... 28 
5.3.1. Discarded policy measures .............................................................................. 28 
5.3.2. Policy options discarded at an early stage ....................................................... 29 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 29 

6.1.  Economic impact ............................................................................................. 29 
6.1.1. Impact on competitiveness of intermodal transport, modal shift and GDP .... 29 
6.1.2. Impact on national public administrations ...................................................... 34 
6.1.3. Impact on the European Commission .............................................................. 37 
6.1.4. Impact on businesses ....................................................................................... 37 
6.1.5. Impact on SMEs .............................................................................................. 40 
6.1.6. Digital by default ............................................................................................. 41 
6.1.7. Impact on the functioning of the internal market and on competition ............ 41 
6.1.8. Regional distribution of impacts ..................................................................... 42 
6.1.9. Impact on energy consumption ....................................................................... 43 
6.2.  Social impact ................................................................................................... 43 
6.2.1. Impact on road safety and on congestion ........................................................ 43 
6.2.2. Impact on employment .................................................................................... 44 
6.2.3. Impacts on fundamental rights ........................................................................ 45 

I 

 
6.3.  Environmental impacts .................................................................................... 45 

7.  HOW DO THE OPTIONS COMPARE? ............................................................................................ 46 

7.1.  Effectiveness .................................................................................................... 46 
7.2.  Efficiency ........................................................................................................ 48 
7.3.  Coherence ........................................................................................................ 49 
7.4.  Subsidiarity and proportionality ...................................................................... 49 

8. 

PREFERRED OPTION ...................................................................................................................... 51 

Identification of the preferred policy option ................................................... 51 
8.1. 
8.2.  REFIT (simplification and improved efficiency) ............................................ 52 
8.3.  Application of the ‘one in, one out’ approach ................................................. 53 
8.4.  Sensitivity analysis for the preferred policy option ......................................... 53 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 54 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 56 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................ 62 

ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................................... 75 

ANNEX 4: ANALYTICAL METHODS ..................................................................................................... 79 

ANNEX 5: COMPETITIVENESS CHECK .............................................................................................. 120 

ANNEX 6: RETAINED MEASURES ....................................................................................................... 123 

ANNEX 7: DISCARDED MEASURES .................................................................................................... 131 

ANNEX 8: HISTORICAL CONTEXT FOR CTD .................................................................................... 133 

ANNEX 9: TOOLBOX OF SUPPORT TOOLS ........................................................................................ 135 

ANNEX 10: TRANSPARENCY REQUIREMENTS ON TERMINALS.................................................. 136 

ANNEX 11: TERMINAL CATEGORIES – RAIL .................................................................................... 137 

ANNEX 12: EFFECTIVENESS OF THE POLICY OPTIONS ................................................................. 138 

ANNEX 13: SME TEST ............................................................................................................................ 144 

ANNEX 14: FINANCIAL SUPPORT MEASURES AND MODAL SHIFT ............................................ 146 

II 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

CTD 

CEEU 

SDG 

GHG 

EU 

TFEU 

RR 

IWW 

SSS 

CT 

SSMS 

OPC 

HDV 

eFTI 

bn 

tkm 

ktoe 

Mtoe 

SO 

PM 

PO 

TEU 

Combined Transport Directive 

Common EU framework for GHG emissions accounting in transport and 
logistics, CountEmissions EU 

Sustainable Development Goal 

Greenhouse gases 

European Union 

Treaty on the Functioning of the EU 

Rail-road intermodal transport 

Inland-waterways-road intermodal transport 

Short sea shipping-road intermodal transport 

Combined transport 

Smart and Sustainable Mobility Strategy 

Open public consultation 

Heavy goods vehicle 

Electronic Freight Transport Information 

Billion 

Tonne kilometre 

Kilo tonnes of oil equivalent 

Million tonnes of oil equivalent 

Specific objective 

Policy measure 

Policy option 

Twenty-foot equivalent unit 

III 

 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1. 

Political context 

This Impact Assessment accompanies a legislative proposal for a revision of Council Directive 92/106/EEC on the 
establishment of common rules for certain types of combined transport (CT) of goods between Member States. 
The Combined Transport Directive (CTD or the Directive)1 is the only EU legal instrument that directly supports 
intermodal transport and thus incentivises the shift from road freight to lower emission transport modes (inland 
waterways, maritime transport and rail).  

Today’s political choice is established in the European Climate Law2, according to which the European 
Union (EU or Union) needs to reduce its economy-wide greenhouse gas (GHG) emissions by at least 55% 
by 2030 as compared to 1990 levels, and achieve climate neutrality by 2050. The European Green Deal 
Communication3 pointed to the need to reduce transport GHG emissions by 90% by 2050 to achieve climate 
neutrality. Furthermore, to reduce its dependence of fossil fuels, the Union also needs to improve its energy 
efficiency, as highlighted in the REPowerEU package4, which lists the revision of the CTD as an important 
tool in this regard5. The Zero Pollution Action Plan6 promotes the switch to cleaner transport to reduce air 
and noise pollution. 

The transformation towards low-emission and low-energy consumption freight transport requires a holistic 
approach. The Commission Communication on the Sustainable and Smart Mobility Strategy (SSMS)7 
emphasises that all policy levers must be pulled to (1) make all transport modes more sustainable, (2) make 
sustainable alternatives widely available in a multimodal transport system and (3) put in place the right 
incentives to drive the transition. It calls for decisive action to shift more activity towards more sustainable 
transport modes, notably by moving a substantial amount of freight onto rail, inland waterways, and short 
sea shipping8.  

Intermodal transport is key in enabling the higher uptake of rail and waterborne freight transport, which alone 
very rarely provide door-to-door transport solutions. Intermodal transport, providing the last mile door-to-door 
connections, combines the better environmental performance9 and energy efficiency of non-road transport with 
the accessibility and flexibility of road transport. It also enables a more efficient allocation of volumes among 
transport modes, both in terms of resource allocation and tackles effectively those road transport externalities 
which are hard to fully internalise, in particular congestion and accidents. Therefore, it is instrumental to achieve 
the ambition of the SSMS and that of the European Green Deal, which also called for a substantial part of the 75% 
of inland freight carried today by road to be shifted to rail and inland waterways. The SSMS accordingly announced 
that to support the greening of cargo operations in Europe, the existing framework for intermodal transport needs 
a substantial revamp and must be turned into an effective tool.  

Even though the performance in volumes of intermodal freight transport has increased substantially over the last 
30 years, road still dominates freight transport in the EU, because intermodal transport is often not competitive 
with road-only transport. There are several reasons. First, success of intermodal transport depends on the 

1 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. 
2 Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework 
for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate 
Law’), OJ L 243, 9.7.2021, p. 1-17. 
3 COM(2019) 640 final. 
4 RePowerEU Plan, COM(2022)230 final. 
5 EU 'Save Energy', COM(2022) 240 final. 
6 COM(2021) 400 final. 
7 COM(2020) 789 final.  
8 The SSMS set milestones for rail freight traffic to double and inland waterways/short sea shipping freight traffic to increase by 
50% by 2050. 
9 The 2016 evaluation of the CTD estimated that the shift from road-only to intermodal transport has brought along an annual 
saving of up to EUR 2.1 billion in external costs in 2011. 

1 

 
 
performance (availability, reliability, punctuality, speed) and cost of each part of the chain, i.e. the services offered 
by rail and waterborne transport, transhipment terminals as well as the road transport for the ‘last mile’. There are 
performance gaps in all those elements that need to be addressed by respective sectoral legislation and industry 
efforts. Second, as long as the level of internalisation of the external costs between the modes differs, non-road 
and intermodal transport on medium-long distances is not price-competitive with road-only operations. The SSMS 
notes that to deliver fair and efficient pricing across all transport modes, a comprehensive set of measures 
is needed. Only then would polluters and users take full responsibility for the costs they generate, allowing users 
to make choices aligned with what is best for society. 

In this context, the purpose of the CTD is to ensure, by compensating current market imperfections, that faster 
and more significant uptake of intermodal transport will be achieved by complementing other policies described in 
section 1.3, and by so doing frontload as much as possible the reduction of negative externalities caused by freight 
transport. 

Definitions10: 
•  Multimodal transport is carriage of goods or passengers by at least two different modes of transport.  
• 

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

•  Combined transport is a subset of intermodal transport meeting the definition in the CTD11.  

Considering that the definition of CT is very narrow, this impact assessment addresses the problems and 
potential of “intermodal transport” in general. Only where the issue relates narrowly to operations covered 
by the current CTD is the term CT used. 

1.2.  Legal context 

Since 197512, the EU has had an instrument to support eligible intermodal operations with an objective to increase 
the competitiveness of CT vis-à-vis road-only freight transport and thereby achieve higher uptake of CT. The CTD 
does not regulate the access to market, nor does it establish any obligations on market participants or address any 
issues relevant to specific modes. Instead, its objective is to provide support for the freight operations with better 
environmental performance, to the operators who decide to apply. The CTD defines the eligibility (Article 1: 
definition) for support measures, i.e. which operations can benefit as well as conditions for proof of eligibility 
(Article 3). For those strictly defined eligible operations (see footnote 11), the CTD provides two types of benefits: 
regulatory measures and economic support, the aim of which is to ensure that CT can take place without 
restrictions and that the cost to the final user - the transport organiser - is reduced to make CT competitive with 
the road-only option.  

Regulatory measures safeguard the freedom to provide the cross-border services and preserve CT from possible 
national protectionist measures (bans on authorisation schemes, quotas and regulated tariffs (prices) for all or part 
of the CT operation in Articles 2 and 8 respectively). It also clarifies that CT organisers (shippers or logistics 
companies) can use non-resident road hauliers for road-legs of CT the same way as they can use non-resident 
road-hauliers for international road-only transport (Article 4) and provides an additional possibility for own-
account transport in CT allowing shippers and consignees to use each-others semi-trailers (Article 9).  

As regards economic support, the CTD establishes two types of fiscal incentives13 and the basic methodology for 
establishing the eligible costs (Article 6). The support is designed and borne by Member States. The support can be 

10 OECD Glossary of Statistical Terms, OECD Publishing, Paris, 2008, https://doi.org/10.1787/9789264055087-en.  
11 The operation has to take place between Member States, involve road leg(s) and non-road leg(s). The latter can be rail 
or waterborne (IWW, SSS) and has to be at least 100 km. The road legs are limited to the nearest suitable station when 
connecting to rail or 150 km for waterborne transport. It also includes a closed list of eligible loading units. 
12  Council  Directive  75/130/EEC  of  17  February  1975  on  the  establishment  of  common  rules  for  certain  types  of 
combined road/rail carriage of goods between Member States, OJ L 48, 22.2.1975. 
13 Tax reductions for road vehicles transport on rail and tax exemptions for road vehicles used exclusively in CT.  

2 

 
 
 
a lump-sum or proportional to the rail leg in that Member State, and take the form of reimbursement, reduction or 
exemption from listed road taxes. CTD does not clarify who the beneficiaries have to be, thus the fiscal incentives 
can be granted either to road hauliers or to CT organisers with the view to reduce the total cost of the door-to-
door operation.  

Finally, it establishes a reporting obligation for the Commission, assisted by the Member States, to report biennially 
on the CT market developments. 

In order to increase the effectiveness of the CTD, the Commission made a proposal in 1998 to amend the CTD, but 
due to no result in negotiations withdrew the proposal in 2001. In 2016, the Commission conducted a REFIT 
evaluation14 and subsequently made a new proposal in 2017. This proposal was withdrawn in 2020 as negotiations 
between the co-legislators had resulted in an outcome that would have reduced the ambition of the CTD at the 
time when political objectives required the opposite. Further details on the REFIT analysis, earlier amendment 
proposals and reasons for their withdrawal are given in Annex 8. 

The  lessons  learnt  from  the  1998  and  2017  proposals  and  negotiation  outcomes  were  taken  into 
consideration when designing the policy measures and options in this impact assessment. More specifically 
this initiative has considered: 
-  The need for a fundamentally different approach to the eligibility criteria. The eligibility criteria in the 
current CTD are defined in terms of length of different road and non-road legs and distances from 
suitable  terminals,  which  do  not  always  reflect  actual  geographical  conditions  and  lead  to  many 
inconclusive discussions with the Member States. Furthermore, these criteria do not reflect the actual 
environmental performance of the fleet and energy carriers.  

-  The terminal investment requirements, while necessary, do not fit into the scope of the Directive and 
were therefore opposed by many Member States. Therefore, these are now addressed separately in the 
Commission proposal for the revision of the TEN-T Regulation.  

-  The need to coordinate with the State aid rules, which was another request of Member States during 

the 2017 negotiations. 

-  The  use  of  digital  solutions  for  eligibility  checks  and  enforcement,  which  allow  to  consider  more 
effective approach to eligibility based on the actual environmental benefits of each operation. The use 
of e.g. eFTI platforms would ensure that for transport organisers and public authorities the application 
of such criteria would not be overly complex, but instead will lead to savings of administrative costs 
compared to the current paper-based regime. In addition, in the future the reuse of the aggregated data 
on e-FTI platforms can facilitate market monitoring and improve the effectiveness of economic support 
measures. 

-  Different situations in Member States will require a different approach to support measures.  

1.3. 

Synergies with other EU policy instruments   

Uptake of intermodal transport allows, to the extent it leads to the higher use of non-road modes, reducing 
the external costs induced by freight transport at the system level. There is already a range of policies in 
place which (a) target the environmental performance of individual modes and (b) internalise external costs 
by applying polluter pays and user pays principles. Making individual modes more sustainable in terms of 
their energy efficiency and use of sustainable fuels, and thus reducing the transport externalities, has been 
addressed  with  a  range  of  policy  tools  (CO2  standards  for  vehicles,  the  Renewable  Energy  Directive, 
FuelEU Maritime and ReFuelEU Aviation Regulations, the Alternative Fuels Infrastructure Regulation, 
etc). For example, the CO2 standards for vehicles target the uptake of low and zero-emission vehicles in the 
road transport sector, the FuelEU Regulation ensures the uptake of sustainable fuels in the maritime sector 
and the ReFuelEU Regulation in the aviation sector. The Renewable Energy Directive complements these 
initiatives  by  focusing  on  the  supply  of  renewable  energy,  while  the  Alternative  Fuels  Infrastructure 
Regulation enables the uptake of zero-emission vehicles and sustainable fuels by ensuring the rollout of 

14 SWD(2016) 140 final. 

3 

 
 
infrastructure. They all eventually aim to reducing the emissions from transport. Progress is on its way, 
requiring  however  time  and  significant  investments  to  materialise  as  well  as  additional  research  and 
development efforts. 

Similarly, a range of measures already target internalisation of external costs, with the aim to allow the 
society to make the right choices. For transport emissions the most effective tool is considered to be carbon 
pricing, including the extension of ETS to maritime transport and seting up a self-standing ETS for road 
transport and buildings. Ongoing reviews of energy and vehicle taxes, which are gradually adjusted and 
phased in, are sensitive to carbon content, and represent another tool for internalising the external costs of 
emissions from transport. The new common EU framework for GHG emissions accounting in transport 
and logistics (CEEU) will allow for improved transparency and accountability on transport-related external 
costs. Infrastructure charges represent another pricing measure. Smart, distance-based road charging, with 
varied rates for the type of vehicle, as provided for by the revised Eurovignette Directive, is an effective tool 
to  incentivise  sustainable  and  economically  efficient  choices,  manage  traffic  and  reduce  congestion. 
Eventually the different work strands come together in a mutually compatible, complementary and coherent 
policy. This however is expected to take time to materialise. In this context, the SSMS set a milestone for 
all external costs of transport within the EU to be covered by the transport users at the latest by 205015. 

As  explained,  the  interaction  of  these  policies,  some  of  which  are  applied  at  the  EU  level  and  others 
nationally, is complex. Unlike the above-mentioned initiatives for internalisation of external transport costs, 
whose starting point is mode-specific internalisation and which are part of the baseline scenario, the CTD 
focuses on the level playing field between modes and aims to act directly on the competitiveness gap, based 
on  regular  market  analyses.  Therefore,  its  review  is  the  most  appropriate  tool  to  address  its  uneven 
competitive position. 

Apart from price competitiveness discussed above, the attractiveness of intermodal transport depends on the 
performance of individual modes and available infrastructure capacity. Therefore, this initiative is developed in 
close coordination with other transport legislation and legislative proposals, including those within the Greening 
Transport Package, of which this initiative is part of. 

It has strong connections with other parts of this package, notably the initiative for increasing the share of rail in 
international transport and the amendment of the Weights and Dimensions Directive16 on road transport, which 
are important for removing mode specific barriers to intermodal transport. Moreover, the new common EU 
framework for GHG emissions accounting in transport and logistics (CEEU) and the implementation of the 
Electronic Freight Transport Information Regulation17 (eFTI) provide a technical framework to enable the 
implementation of the revised CTD. The revision is also consistent with the recently adopted Naiades 
Communication18, which calls for the greater integration of inland waterways into a modern, trans-European 
intermodal transport system. In addition, a precondition for the use of intermodal and multimodal transport is the 
availability of appropriate infrastructure at sufficient capacity. The recent study on transhipment technologies19 
(PWC, KombiConsult (2022) study) found that there are shortcomings on the TEN-T network for intermodal 
transport, and transhipment capacity is insufficient for rail and inland waterways. The terminal capacity has been 

15 The SSMS sets a milestone for all external costs of transport within the EU to be covered by the transport users at the 
latest by 2050. 
16 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, OJ L 235, 17.9.1996, p. 59–75. It allows heavier and longer road vehicles to be used in intermodal 
transport, including CT road legs. 
17  Regulation  (EU)  2020/1056  of  the  European  Parliament  and  of  the  Council  of  15  July  2020  on  electronic  freight 
transport information, OJ L 249, 31.7.2020, p. 33–48. 
18 COM(2021) 324 final.  
19  Comparative  analysis    of  transhipment  technologies  for  intermodal  transport  and  their  costs,  PWC,  KombiConsult 
2022,  https://transport.ec.europa.eu/news/study-analyses-transhipment-options-more-competitive-intermodal-transport-
and-terminal-capacity-ten-2022-05-05_en  

4 

 
 
addressed in the context of Commission proposal for the revision of the TEN-T Regulation20 that includes for the 
first time an obligation on Member States to ensure sufficient multimodal freight terminal capacity based on a 
dedicated analysis and action plan. These measures can be expected to deliver better infrastructure capacity for 
intermodal transport after 2030.   

Importantly, the revision of the CTD is closely coordinated with the revision of the Guidelines for State aid to 
railway undertakings21 and the newly adopted Land and Intermodal Transport Enabling Regulation22. This allows 
the application of certain support, if defined in a dedicated block exemption regulation, without prior notification, 
thus addressing the Member States’ call for simplification in State aid procedures during the 201723 CTD revision 
attempt. In essence, the CTD will establish policy goals, while State aid rules will set the framework for public 
support to achieve these policy goals, including definition of eligible costs, beneficiaries and aid intensity. 

Finally, it should be noted that a link between CTD and road cabotage is brought up by some stakeholders. As 
explained above, Article 4 of the CTD provides an equal treatment of international CT to international road 
transport as regards the use of non-resident hauliers. In the revision of Regulation (EU) 1072/2009 in 202024, the 
co-legislators provided a derogation from Article 4 of the CTD in case of its abuse, while reconfirming that Article 4 
has been useful and remains in force25. Given that this measure was not part of the Commission’s proposal, the 
Commission voiced its concerns and conducted a study26 on the application of such restrictions on CT operations. 
The study found that even a low drop in the transported volumes entailed by the obligation can have negative 
impact on rail freight connections and can lead to inefficiencies and additional emissions.  

1.4.  Evaluation of the Directive  

An evaluation27 of the CTD was carried out in 2014-2016 and concluded that the CTD continues to be a 
relevant instrument for supporting freight transport combining different modes. It was estimated that the 
shift from road-only to intermodal transport has brought along an annual saving of up to EUR 2.1 billion in 
external costs in 2011. The shift from road to rail saved 7.3 Mt of CO2, while the shift to inland waterways 
saved 0.96 Mt of CO2. For comparison, the CO2 emissions produced by heavy goods vehicles (HGVs) in 
2011 were 203 Mt. While not all of these savings can be attributed to the CTD, it was established that 
without EU action, cross-border CT services would likely have been faced with barriers due to different 
legal systems, making CT services less attractive and possibly unfeasible. The evaluation shows that the 
intermodal  transport  operations  in  the  EU  measured  in  the  twenty-  foot  equivalent  unit  (TEU)  have 
quadrupled  during  the  last two decades  with  a  clear "jump" just  after  the  implementation of  the  CTD, 
allowing the intermodal transport sector to grow on average at almost double the speed of road transport. 

However, a number of provisions of the CTD, e.g. the requirement to use paper documents, are outdated 
since  they  reflect  the  market  situation  in  1992.  Other  provisions  of  the  CTD  suffer  from  diverging 
transposition  and  implementation  at  Member  State  level  which  causes  daily  practical  problems  to  the 
industry and hence such provisions are not entirely effective. Furthermore, the economic support measures 

20 COM(2021) 812 final.  
21 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13154-Rail-transport-revision-of-State-aid-
guidelines_en  
22 Council Regulation (EU) 2022/2586 of 19 December 2022 on the application of Articles 93, 107 and 108 of the 
Treaty on the Functioning of the European Union to certain categories of State aid in the rail, inland waterway and 
multimodal transport sector, OJ L338, 30.12.2022, p.35-39. 
23 SWD(2017) 362 final. 
24 Regulation (EU) 1055/2020 of the European Parliament and of the Council of 15 July 2020 amending Regulations 
(EC) No 1071/2009, (EC) No 1072/2009 and (EU) No 1024/2012 with a view to adapting them to developments in the 
road transport sector, OJ L 249, 31.7.2020, p. 17–32. 
25 Actions for annulment in respect of this provision have been lodged with the Court of Justice by some Member States 
(C-542/20,  Lithuania  v.  Parliament  and  the  Council,  C-545/20,  Bulgaria  v.  Parliament  and  the  Council,  C-547/20, 
Romania v. Parliament and the Council and C-554/20, Poland v. Parliament and the Council). 
26  “Data gathering and analysis of the impacts of cabotage restrictions on combined transport road legs”, TRT Trasporti 
e Territorio, November 2020;  https://ec.europa.eu/transport/modes/road/studies/road_en 
27 SWD (2016) 140 final 

5 

 
 
are  very  limited  and  therefore  do  not  have  a  significant  impact  on  the  competitiveness  of  intermodal 
operations (further analysis in section 2.2.3). The efficiency problem reported by the industry is related to 
the  inability  to  use  electronic  documents  throughout  the  EU.  Otherwise,  both  the  industry  and  public 
administrations indicated in the public consultation that the policy measures are proportionate for achieving 
the policy objectives.  

1.5. 

Sustainable development goals (SDG) 

The CTD contributes to SDG 13 (Take urgent action to combat climate change and its impacts), SDG 9 (Build 
resilient infrastructure, promote inclusive and sustainable industrialisation and foster innovation) and SDG 11 
(Make cities and human settlements inclusive, safe, resilient and sustainable). For further details, see Annex 3. 

2.  PROBLEM DEFINITION 

The underlying problems, problem drivers and implications that are relevant for the revision of the CTD are 
presented in Figure 1. 

Figure 1: Problem tree 
Drivers 

PD1: Eligibility for support under the 
CTD is too narrow and complicated 

PD2: Lack of market 
monitoring/empirical basis for support 

PD3: Incentives provided by the CTD to 
enhance relative competitiveness of 
intermodal transport are insufficient to 
reduce the gap with road-only transport 

PD4: Inefficiencies in scheduling, 
planning and running intermodal 
transport 

2.1.  What is the problem? 

Problems 

Implications 

Current uptake of 
intermodal transport is 
insufficient for 
effectively 
contributing to the 
reduction of external 
costs and energy 
consumption of 
transport 

Environmental impacts of the 
transport sector (GHG 
emissions, air pollution, 
noise) are not sufficiently 
mitigated 

Other externalities (road 
congestion, road safety) 
are not sufficiently reduced 

Energy consumption is not 
reduced 

2.1.1.  Problem – Current uptake of intermodal transport is insufficient for effectively contributing 

to the reduction of external costs and energy consumption of transport 

Road  transport’s  share  in  today’s  freight  transport  mix  is  presistently  high  (74.4%  of  intra-EU  inland 
transport and 53.3% of all intra-EU transport in 2020), being the main driver of high negative externalities 
(including CO2 emissions, but also air and noise pollution, accidents etc.) and energy consumption. The 
total external costs generated by freight transport in the EU are of the order of EUR 203 billion annually28. 
38% of these costs are generated by HGVs, (see Table 1). Accidents and congestion are the biggest cost 
components for any given HGV transport operation.  

Table 1: Annual external costs of HGV freight transport by externality  

Externality 

HGV external cost (EUR billion) 

Congestion 
Accidents 
Air pollution 
Climate change (GHG) 
Noise 
Other 

14.6 
23.0 
13.9 
9.6 
9.1 
7.3 

Share of given externality in total 
HGV external costs 
18.8% 
29.7% 
17.9% 
12.4% 
11.7% 
9.4% 

Source: The Handbook on the external costs of transport CE Delft et al. (2019); Note: Other includes “well-to-tank” and 

28 Handbook on the external costs of transport, CE Delft (2019), https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1 

6 

 
 
 
habitat damage externalities.  

Source: European Commission (2019); Note: Other includes “well-to-tank” and habitat damage externalities.  

The average external cost for rail transport and IWW per tonne-km (tkm) are almost three times lower, at 
EUR 0.013 per tkm and EUR 0.019 per tkm, respectively, compared to the average external cost for HGVs at EUR 
0.042 per tkm. This difference is expected to reduce over time, mostly due to the decarbonisation of road 
transport which leads also to lower air pollution. However, the total external costs of road-only transport are 
expected to remain higher in particular due to congestion, but also due to road accidents which despite of 
continuous improvement of safety measures29 would be hard to fully internalise with mode specific measures.  

Similarly, the energy consumption of mass transport such as rail and waterborne transport is considerably 
lower  per  tkm  than  that  of  road-only  transport.  A  recent  case  study  of  ten  popular  intermodal  routes 
established  that  average  energy  savings  of  door-to-door  intermodal  transport  compared  to  road-only 
transport is between 54 and 71%30. Average energy consumption per tkm is 0.146 kWh for road transport, 
but 0.02 kWh for rail, 0.034 kWh for SSS and 0.046 kWh for IWW31. It is important to note that for 
intermodal  transport,  the  external  cost  and  energy  consumption  is  higher  than  in  unimodal  non-road 
transport due to the included road leg(s). The absolute difference is the bigger the higher is the share of the 
non-road leg, as illustrated in Figure 2.  

Figure 2: Average external costs and energy consumption for different distances of door-to-door intermodal container 
transport (20 tonnes) compared to road only operation on same distance  

Rail-road

IWW-road

SSS-road

Road only

2750
2500
2250
2000
1750
1500
1250
1000
750
500
250
0

External costs, €

Energy
consumption, kWh

External costs, €

Energy
consumption, kWh

External costs, €

Energy
consumption, kWh

Source: Own calculations based on PWC, KombiConsult (2022) and Ricardo et al. support study (2023)  

300km

600km

1000 km

The volume of intermodal freight transport in tkm and TEU, including CT, has more than doubled in the 
last 30 years, since the adoption of the current CTD and has been the fastest growing market segment in 
three important non-road freight modes (i.e. rail, IWW, SSS), even if this relative growth advantage has in 
recent years slowed. However, it makes up still only 17% of total rail, IWW, SSS and road transport activity. 
This is because of two main reasons. First, it started from a relatively low base so even doubling its volume 
still results in a low share. Second, road transport activity has continued to grow at a sustained rate, in 
particular during the recent years, not allowing intermodal transport to increase its share in total rail, IWW, 
SSS and road transport activity. It has however increased its share in total non-road transport as the other 
market segments (conventional rail, inland waterways and short sea shipping) have grown at considerably 
slower pace than intermodal transport (Figure 3). 

29 On 1 March 2023 the European Commission proposed updated requirements for driving licences and better cross-
border enforcement of road traffic rules. 
30 Comparative study on CO2 emissions in door-to-door combined transport, UIRR, d-fine (2021), 
https://www.uirr.com/en/media-centre/leaflet-and-studies/mediacentre/2102-comparative-study-on-co2-emissions-in-
door-to-door-ct-d-fine.html 
31 Ricardo et al. support study (2023). 

7 

 
 
 
Figure 3: Freight transport activity of unimodal (excluding the intermodal respective legs) and total intermodal transport 
(incl. 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)

Source: Statistical pocketbook 2022, REFIT evaluation of CTD (2016) and Ricardo et al. support study (2023) 

2005

2010

2015

2020

The overall freight transport volume (expressed in tkm) in the EU has increased by 36% between 1995 and 
2020; however due to Covid-19, freight transport experienced a large drop in 2020 (-3.6% year on year). 
The biggest contributor to this growth has been road transport, which grew 54.8% between 1995 and 2020. 
Between 2005 and 2020 total freight transport increased by 5.7%, while road transport volume increased 
by 9.9% (157 billion tkm). As a result, road transport continues to have the largest and increasing share in 
EU freight transport. In 2020, total road transport (including intermodal road-legs) accounted for 53.3% of 
the total freight transport (in tkm), going up from 51.3% in 200532.  

In contrast, over the same period the transport volume for rail and IWW decreased respectively by 4.4% 
and 5% (when including intermodal operations). Only the volume of SSS increased by 9.5%33. The situation 
in non-road transport without intermodal is however even graver as both rail transport and inland waterways 
transport  decreased  considerably  between  2005  and  2020.  The  growth  of  intermodal  non-road  legs 
experienced however a sizable growth (Figure 3 and Table 2).  

Table 2: Change of rail, inland waterways, short sea shipping and road transport volume between 2005 and 2020 

Road 

Total mode 
9.9% 

Mode without intermodal 
9.6% 

Intermodal   
12.5% 

-4.4% 

Rail 
Inland 
waterways 
Short sea 
shipping 
Source: Statistical pocketbook 2022, REFIT evaluation of CTD (2016) and Ricardo et al. support study (2023)  

108.3% 

-13.9% 

74.1% 

88.8% 

10.1% 

-9.2% 

-5.0% 

9.5% 

As far as non-road modes remain more environmentally sustainable, their much faster growth is essential 
to achieve the ambition of a more sustainable transport system as set by the Commission in the SSMS. The 
strategy specifies that rail freight traffic should increase by 50% by 2030 and double by 2050; and transport 
by inland waterways and short sea shipping should increase by 25% by 2030 and by 50% by 2050 (relative 
to 2015 levels). As can be seen in Table 2, intermodal transport is a key driver for growing freight volumes 
of non-road transport modes. Given that these modes alone rarely deliver door-to-door, intermodal solutions 
with road connections to and from terminals are necessary. Combining road with non-road legs in freight 
transport allows for high degrees of flexibility while improving the competitiveness of non-road legs and 
thereby contributing to meeting the milestones in the SSMS.   

32 Statistical Pocketbook (2022), EU Transport in figures, https://transport.ec.europa.eu/media-
corner/publications_en  
33 Ibid. 

8 

 
 
 
 
The problems for the intermodal sector remain more or less the same as in 1992 when the current CTD was 
adopted, even if some developments have taken place since then. Before the 1998 amendment proposal for 
CTD, the Commission adopted a dedicated Communication on intermodal transport34 that highlighted four 
key needs: (i) a European strategy on infrastructure, (ii) a single transport market, including on competition 
rules, (iii) identification and elimination of obstacles to intermodality and (iv) adressing associated friction 
costs or specific barriers for intermodal transport uptake such as higher costs, longer journeys with delays, 
unreliable time planning, lack of quality services, limitations on types of goods transported, higher risk to 
damage cargo and more complex administrative procedures.  

However,  the  1998  amendment  was  withdrawn  as  explained  above.  While  the  consecutive  TEN-T 
Regulation  revisions  have  improved  the  non-road  infrastructure,  they  have  not  adressed  specifically 
intermodal  infrastructure  bottlenecks.  Only  the  latest  revision  of  the  TEN-T  Regulation35  proposes 
dedicated obligation for addressing transhipment capacity and quality of multimodal terminals. Similarly, 
the existing State aid rules do not include dedicated guidelines for intermodal transport. While the ongoing 
review of State aid rules in this area is expected to include provisions for intermodal transport, the State aid 
provided today by different Member States is outside the scope of the CTD and remains very diverse (see 
section 2.2.3). Finally, there has been no or very limited change as regards the mentioned friction costs.  

This was also well highlighted in the results of the open public consultation (OPC), where the respondents 
were  asked  to  rate  the  different  factors  that  impact  the  competitiveness  of  intermodal  transport.  99 
respondents replied to this question during the public consultation. The most pertinent reasons (more than 
60%  of  respondents  assign  strong  or  very  strong  impact)  why  intermodal  transport  is  not  competitive 
include:  road-only  transport  being  cheaper  door-to-door,  the  habit  of  using  road-only  transport,  high 
transhipment cost and insufficient terminal infrastructure and insufficient non-road connections from nearby 
terminal (terminal service offer)36. The results are given in Figure 4.  

The lack of terminals and better functioning of rail and inland waterways sectors, which should contribute 
to better service offer and connections with non-road modes, is addressed by other initiatives as explained 
in  section  1.3.  As  regards  the  habit  of  using  road-only  transport  and  complexities  of  starting  to  use 
intermodal transport, both problems are difficult to pinpoint as well as to address. The complexities are 
mostly inherent to intermodal transport as it always involves many parties, multiple contracts and different 
laws and rules, in particular for international operations. Logistics companies and freight forwarders are 
specialised in solving these issues for shippers, if the main concern – the higher costs – can be addressed.   

34 COM(97) 243 final. 
35 COM(2021) 812 final.  
36 Cheaper road: 42 out of 68 industry respondents, 10/14 public authorities, 4/10 EU citizens, 1/3 NGO, 1/1 trade 
union and 4/4 others. Transhipment costs: 43/68 industry respondents, 10/14 public authorities, 4/10 citizens, and 
1/4 other. Lack of suitable terminal capacity: 50/68 industry respondents, 5/14 public authorities, 6/10 citizens, 1/3 
NGO, 1/1 trade union and 3/4 others. Lack of suitable connection: 42/68 industry respondents, 5/14 public 
authorities, 6/10 citizens, 1/4 NGO, 1/1 trade union and 4/4 others.  

9 

 
 
 
Figure  4:  Responses  to  “To  what  extent  do  the  following  factors  affect  the  lack  of  competitiveness  of 
multimodal/intermodal37 transport compared with road-only transport (on a scale of 0-5, where 0 is no impact and 5 is 
very strong impact)?” 

As regards the high costs, the impact assessment for the 2017 CTD review proposal already established that 
road-only  transport  is  considerably  cheaper  on  medium  long  distances,  while  on  longer  distances, 
intermodal transport is in most cases cost-competitive. The PWC, KombiConsult (2022) study38 confirmed 
that, when considering all transport cost components of an intermodal operation, at 600 km all intermodal 
options are more expensive than similar road-only transport, while at 1000 km most intermodal options 
become competitive. The main reason for this is high transhipment and transport operation organisation and 
management  costs that derive  from  complexity  of  multiparty  operation. The shorter the  distance of  an 
operation, the bigger the relative share of these costs in the total cost structure. Road-leg costs also make up 
a considerable part of intermodal transport cost in shorter and medium long operations, in particular as road 
legs in intermodal transport are often priced not per tkm, but per time to factor in long waiting times for 
loading/unloading and in terminals (Figure 5).  

These additional costs are inherent to intermodal transport and are the main reason why intermodal transport 
is not competitive on shorter distances. For example, the price gap with road-only transport on 500 km 
distance  is  around  19%.  At  600 km,  the  price  difference  is  around  9%  and  at  1000 km,  the  average 
intermodal rail operation is 20% cheaper than a road-only operation. 

37 During the stakeholder consultation, inclusion of multimodal operations within the scope of the CTD was considered, 
however this option was discarded, as explained in Annex 7. 
38 PWC, KombiConsult (2022), op.cit.  

10 

 
 
 
Figure 5: Cost components and their share in an average 500 km and 1000km rail-road intermodal operation compared 
to road-only operation on same distance39 

Road-only 500 km

Road

Rail-road intermodal 500km

Road

Rail

Chain management

Transhipment

Loading unit cost

Road-only 1000km

Road

Rail-road intermodal 1000km

Road

Rail

Chain management

Transhipment

Loading unit cost

Source: own calculations based on the PWC, KombiConsult (2022) study models  

0 €

200 €

400 €

600 €

800 €

1.000 €

The average distance at which intermodal operations become cost competitive with  road-only transport 
without any support have been assessed to be 733 km for rail intermodal, 249 km for IWW intermodal and 
817 km for SSS intermodal operations40. Broadly, below those average distances, operations are normally 
not competitive and thus organisers of operations shorter than these “break-even distances” are unlikely to 
consider intermodal operations as an alternative to road-only transport.  

Due to these inherent costs intermodal transport on short dinstances always remains more expensive than 
road-only. At the same time its cost-competitivenes in medium-to-long distances is affected by the fact that 
today’s transport prices do not reflect to the full extent the external costs of different modes. In case external 
costs would be fully reflected, “break-even distances” would be around 600 km (Figure 6) and the market 
prices alone would direct shippers  towards more sustainable choices. However, the SSMS foresees the 
internalisation  of  external  costs  of transport  (except  those  from infrastructure)  at the  latest  by  2050  by 
pursuing a comprehensive set of measures41. 

Meanwhile, there is large untapped potential on the EU transport market to increase the uptake of intermodal 
transport on medium-long distances. A large part of road-only operations in EU are below the break-even 
distances established above42. Around 23% of road-only freight transport is between 500 and 999 km and 
additional  18%  between  300-500  km43,  which  are  distances  considered  interesting  for  intermodal 
transport44. A sizable part of those operations could be carried out by intermodal transport if the market 
conditions, in particular infrastructure availability and price, were right. The main question is how to make 
operations at shorter distances interesting for transport organisers. Operations above these distances are 
already cost-competitive with road-only transport, so it can be assumed that those that are still using road 
do so for reasons other than price competitiveness. 

39 Differences exist, even within the same modal combination depending on the transhipment technologies and loading 
units used as well as between different parts of the EU. For example, in rail-road transport, the container transport is the 
most cost competitive segment and the so-called Rolling Road, i.e. accompanied intermodal transport, where full vehicle 
is  transported on  a  train,  is  least  cost  competitive  vis-à-vis  road-only  transport  at  all  distances.  PWC,  KombiConsult 
(2022). 
40 Ricardo et al. support study (2023), op.cit. 
41 Internalisation of external costs is a process of developing and implementing over time a range of dedicated measures 
in  various  sectoral  policies.  Some  measures  are  already  adopted  (Eurovignette  Directive,  the  revised  EU  Emission 
Trading Scheme), some are negotiated (the Energy Taxation Directive) and others are still under consideration. Some are 
harmonised at the EU level (the EU Emission Trading Scheme), but most leave room for flexibility at national level (road 
charges and rail track access charges, vehicle and energy taxation). Most of these measures have transitional and/or phase 
in periods. 
42 Ricardo et al. support study (2023), op.cit. 
43 According to Eurostat, today 60% of road transport is above 300km and 42% above 500km. 
44 Shorter distances are unlikely to be ever competitive for rail and SSS. For IWW, considerably shorter distances could be 
interesting, but potential only exists where there are inland waterways.  

11 

 
 
 
Figure 6: Total cost (transport cost and external cost) comparison of selected intermodal transport options at 600 km 
with road-only transport at same distance  

1.600 € 
1.400 € 
1.200 € 
1.000 € 
800 € 
600 € 
400 € 
200 € 
- € 

Container
craned

Semitrailer
craned

Semitrailer
horizontal
transhipment

Accompanied
full vehicle

Container

Container

Semitrailers
RoRo

Transport costs
Transport costs road-only incl tolls

RAIL

IWW
External costs
Total road-only incl tolls and external costs

SSS

Source: PWC, KombiConsult (2022) 

2.2.  What are the problem drivers? 

This section explains the four problem drivers behind the insufficient uptake of intermodal freight transport. 
Problem driver 1 (Eligibility for support under the CTD is too narrow and complicated) and problem driver 
3 (The incentives provided by the CTD to enhance the relative competitiveness of intermodal transport are 
insufficient to reduce the gap with road-only transport), are most critical. At the same time, tackling issues 
identified in problem driver 2 (Lack of market monitoring/empirical basis for the support) and problem 
driver 4 (Inefficiencies in scheduling, planning and running intermodal transport) would provide synergies 
with measures addressing the key drivers. 

2.2.1.  Problem Driver 1: Eligibility for support under the CTD is too narrow and complicated 

According to the REFIT evaluation45 and the 2017 impact assessment46, the definition of eligible operations 
in Article 1 of the CTD was found first, to cover only a small part of operations and second, to be imprecise 
and causing practical problems for enforcement. 26 out of  49 respondents47 to the stakeholders  survey 
agreed  or  strongly  agreed  that  the  current  eligibility  criteria  are  too  narrow.  Only  operations  between 
Member States are covered. In addtion, the definition also sets a minimum size limit for eligible loading 
units,  excluding  operations  with  smaller  loading  units.  Finally,  different  eligibility  conditions  apply  to 
different modal combinations, which creates both unequal treatment as well as difficulties in case different 
non-road legs are used in one operation. Overall, more than half of the intermodal operations in the EU, 
including all domestic intermodal operations, are excluded48. 

Importantly, the way the eligible operations are defined is not fully aligned with the objectives of the CTD. 
The eligibility is based on distance limits for different 'legs' to ensure that only operations with short road 
legs and a major part of operation on the non-road leg would be eligible. In reality, the definition allows 
operations where road leg(s) in the same operation together are longer than the non-road leg(s) to qualify, 
as well as operations where the substitution between road and non-road is not possible  and thus no modal 
shift can be promoted. At the same time, a number of short-distance IWW operations are excluded despite 
having a high potential of reducing road congestion, in particular around large ports. Consequently, 24 out 

45 SWD(2016) 140 final. 
46 SWD(2017) 362 final. 
47 20/31 industry respondents, 5/8 national authorities and 1/10 others. 
48 Updating EU combined transport data, ISL, KombiConsult 2017, https://op.europa.eu/en/publication-detail/-
/publication/c5b643b4-9e78-11e7-b92d-01aa75ed71a1/language-en  

12 

 
 
 
of 49 stakeholders survey respondents49 believed that the current eligibility criteria are not entirely relevant 
to promote the uptake of intermodal transport and the reduction of CO2 emissions and other externalities.  

Moreover,  the language  used  in the  definition has  resulted  in different  transposition  and  application in 
Member States bringing along delays due to road checks, fines, court proceedings and infringements over 
the years. 25 out of  49 survey respondents and 15 out of 29 interviewees50 considered that the current 
eligibility definition allows different interpretations. For example, the most-contested term in the current 
definition is the 'nearest suitable terminal' – that defines the eligibility for road legs for rail-road CT (RR) 
options51. This term has caused considerable problems to industry, as operators are fined for violating road 
cabotage or weights and dimensions rules, where national provision violate the CTD.   

In addition, two issues relate to proof of eligibility. First, the provisions for proof of eligibility are ineffective 
and outdated. The information that is required to be presented does not allow establishing that an operation 
is eligible in all cases, in particular for initial road legs. Secondly, the CTD leaves it to the operators to 
decide which documents they provide for the proof and that no additional documents can be requested 
(explicitly  clarified  in  the  amendment  in  200852),  however  some  Member  States  nevertheless  request 
specific document formats. This can cause problems, in particular for international operations, because 
operators would  have to  prepare  different types of transport documents for  different parts of the  same 
operation.  

2.2.2.  Problem Driver 2: Lack of market monitoring/empirical basis for the support 

As concluded by the REFIT evaluation, the CTD lacks an effective market monitoring framework that 
would allow to tailor support measures according to the actual situation. 18 out of 49 survey respondents53 
agreed or strongly agreed that an empirical basis to determine the adequate level of support is missing.  

The CTD establishes a biennial reporting obligation on the Commission with assistance from the Member 
States. However,  there  are major  challenges  to  collating reliable  and  comparable market data.  While  a 
number of primary sources on intermodal transport data are available, they all cover only certain segments 
of  the  market  and  often  use  different  definitions  or  units  of  measurement  thereby  rendering  data 
incomparable. The majority of the Member States do not gather, let alone regularly report, intermodal door-
to-door transport data54. Eurostat reports some data per mode, but does not report door-to-door intermodal 
volumes nor any data on transhipment55.  

49 18/31 industry respondents, 5/8 national administrations 1/10 others. 
50 20/31 industry, 5/8 national administrations in the survey; 10/21 industry, 2/5 administrations and 3/3 NGOs in 
interviews 
51 The Commission posed the question in the interpretation to CJEU in C-305/06, but the Court reached its decision on 
the case before this question, so no answer was given.  
52  Council  Regulation  (EC)  No  569/2008  of  12  June  2008  amending  Regulation  No  11  concerning  the  abolition  of 
discrimination  in  transport  rates  and  conditions,  in  implementation  of  Article  79(3)  of  the  Treaty  establishing  the 
European Economic Community, OJ L 161, 20.06.2008. 
53 14 out of 31 industry respondents and 4/8 authorities. 
54 Member States primarily gather transport statistics in compliance with EU legislation that cover different modes of 
transport  (i.e.  Regulation  (EU)  70/2012  (road  transport),  Regulation  (EC)  91/2003  (rail  transport,  Regulation  (EC) 
1365/2006  (inland  waterway  transport)  and  Regulation  (EU)  42/2009  (maritime  transport).  However,  none  of  these 
regulations  includes  an  obligation  to  specifically  gather  data  on  intermodal  operations  in  the  respective  modes.  13 
Member States collect and analyse statistical data on intermodal transport operations, but mostly per mode and not modal 
combinations. 
55 Eurostat includes the following information on intermodal transport: (1) unitisation (transport in containers and other 
intermodal loading units) per mode, in tkm of gross-weight for road, rail and inland waterways and tonnes for SSS (2) 
long-distance 
potential). 
containers 
https://ec.europa.eu/eurostat/cache/metadata/en/tran_im_esms.htm Eurostat also provided data on intermodal operations 
on pilot project basis, providing grants for Member States to gather such data. The pilot was ended because of the lack 
of interest from Member States.  

(called 

freight 

modal 

shift 

road 

in 

13 

 
 
Due to the lack of comparable data on the market situation of combined transport, the Commission paused 
systematic reporting in 2002. To fulfil its obligation, the Commission contracted and published in 2014 an 
extensive market analysis, which was updated in 2017. The lack of data was acknowledged as an issue in 
the REFIT  evaluation  and in the  subsequent impact  assessment56.  For  both  of  those reports,  dedicated 
primary data gathering was carried out with the help of consultants.  

Moreover, the CTD does not entail an automatic review mechanism to update the national support schemes 
in line with market developments and needs. Even if the fiscal incentive shemes under Article 6 are very 
limited, most Member States have not notified these to the Commission. Those schemes have therefore not 
been assessed by the Commission regarding their compliance with State aid rules and do not necessarily 
have a time limit. Other national support schemes beyond the scope of the CTD must have been notified to 
the Commission and thus must have a time-limit.  

In the absence of adequate market analysis, notification of State support to the Commission and automatic 
review for all the support schemes, it is not possible to assess if the support schemes are effective, efficient 
and compatible with the internal market. In such a situation, the incentives provided to intermodal transport 
are uneven, where some Member States can end up providing too little or too much support.  

2.2.3.  Problem  Driver  3:  The  incentives  provided  by  the  CTD  to  enhance  the  relative 
competitiveness  of  intermodal  transport  are  insufficient  to  reduce  the  gap  with  road-only 
transport  

The modus operandi of the CTD is to make intermodal freight transport more competitive by providing 
economic support and regulatory measures to compensate for market imperfections. However, according 
to  the  REFIT  evaluation,  the  support  measures  established  by  the  CTD  to  enhance  the  relative 
competitiveness of combined transport are very limited. Indeed, 70 out of the 100 responses to the OPC 
agree that this is an issue57. The recent European Court of Auditors special report on intermodal transport 
also concluded that support on intermodal transport was not sufficiently effective as there was still no level 
playing field for intermodal freight transport in the EU due to regulatory and infrastructure barriers58. 

The limited effectiveness of the support measures provided in the CTD derives from four issues. First, the 
economic support is provided only to road vehicles in RR. Second, it applies to a very limited share of 
operations covering only road vehicles transported on rail (rolling road operations) and road vehicles used 
exclusively for combined transport operations. These types of operations cover around 5-6% of intermodal 
operations in the EU. Transport of containers is not covered. Third, the level of economic support, even for 
this limited range of operations, is not sufficient to induce a change in the choice for the transport mode. 
The CTD does not specify the level of support and the 2014 market analysis59 found that the reimbursements 
of vehicle taxes translate to support of EUR 1 to EUR 50 per operation, constituting less than 1% of total 
costs. Furthermore, the support is provided to road hauliers (i.e. transport operators) and in most cases the 
benefit is not passed through to transport organisers who make the decisions on the choice of transport 
mode. According to the stakeholders survey, 19 out of 49 respondents60 agreed or strongly agreed with the 
low, ineffective and inefficient support measures being an issue. 

Fourth, national support is very heterogeneous. Given the limited scope of the CTD, several Member States 
have  dedicated  support  for  intermodal  transport  beyond  the  provisions  of  the  CTD,  notified  to  the 

56 SWD(2017) 362 final. 
57 This included 11 public authorities (CZ, 2 public authorities from BE, AT, 3 public authorities from FR, NO, IT, DE, 
SE), 49 industry stakeholders, four citizens and six responses under the category ‘others’. 
58 Intermodal Freight Transport, EU still far from getting freight off the road, European Court of Auditors 2023, 
https://www.eca.europa.eu/Lists/ECADocuments/SR-2023-08/SR-2023-08_EN.pdf 
59  Analysis  of 
/publication/675724ad-969f-11e7-b92d-01aa75ed71a1  
60 Including four public authorities (MT, PL, HR, LV), 13 industry stakeholders and two responses under the category 
‘others’. 

transport,  KombiConsult  2014,  https://op.europa.eu/en/publication-detail/-

the  EU  combined 

14 

 
 
Commission  under  respective  State  aid  rules.  While  in  all  State  aid  to  intermodal  transport  operations 
approved  by  the  Commission  the  methodology  to  quantify  the  aid  amount  is  the  same61,  the  support 
schemes still vary in terms of scope, level, eligibility and beneficiaries. For instance, some cover specific 
types of operations on one mode (e.g. start-up operations in IWW in Netherlands) or specific routes on one 
mode (e.g. support for SSS in Spain), others provide wide support to shippers per loading unit transported 
on RR (e.g. Croatia), support RR in the form of lump sums per operation or support transhipment costs (e.g. 
Luxembourg). While these differences between the type and level of support across Member States may be 
justified by national market situations, they increase the administrative burden for operators and create 
frictions in the internal market. 18 out of 49 respondents62 to the survey considered different measures in 
different Member States as a problem.  

2.2.4.  Problem Driver 4: Inefficiencies in scheduling, planning and running intermodal transport 

By definition, intermodal transport involves multiple parties and entails complex arrangements, which in 
turn increase the costs of organising and carrying out an operation. The complexity of arrangements is 
further aggravated by different habits and systems used in the different transport modes, as well as lack of 
transparency  and  cooperation  between  the  parties  involved.  While  logistics  companies  and  freight 
forwarders are specialised in solving these issues for shippers, such inherent complexities of intermodal 
transport operations, as far as they are not alleviated, still contribute to aggravating the problem. 

Three  main  issues  regarding  inefficiencies  have  been  identified  that  are  not  dealt  with  horizontally  or 
homogeneously under different sectoral legislation:  

1. Data interchange: The SSMS identifies the need to improve multimodal data interchange and smart 
traffic  management  to  simplify  the  complex  regulatory,  administrative  and  business  arrangements. 
Operators  use  different  intermodal  and  unimodal  planning  and  execution  tools,  with  a  wide  variety  of 
interfaces and frequently, each with its own dataset requirements and  semantics. 13 out of 49 respondents63 
to the stakeholders’ survey agreed that there is lack of interoperability, and the fragmentation of the different 
data sharing systems is an important limiting issue. Existing data sharing applications include information 
on orders, business documents, planning data and support of protocols and safety regulations. The lack of 
communication between different systems has a significant impact not only during the planning phase, but 
also  during  the  operation  phase.  For  example,  issues  related  to  the  insufficient  tracking  and  tracing  of 
shipments prevent operators from monitoring the operation and responding adequately to delays64. 12 out 
of the 49  respondents65 to the stakeholders’ survey, including all shippers/organisers consulted, identified 
this as a factor that hinders the uptake of intermodal transport. 

2.  Transparency:  Lack  of  transparency  about  terminal  operations,  their  facilities  and  services,  is  an 
important  problem  not  dealt  with  sufficiently  in  mode  specific  legislation.  Lack  of  information  about 
terminals was identified as a problem in the PWC, KombiConsult study66 as well as by the recent European 
Court of Auditors report67. There is not enough information available to transport organisers, in particular 
to new entrants, to accurately compare the services and facilities of terminals. For rail, rules are set in 
Regulation 2017/2177 on access to service facilities, but its application has only partially solved the issue. 
No transparency requirements for information to be made publicly available exist for inland waterways and 

61 It is calculated as a percentage of the avoided external costs. When the aid intensity stays below 50% of the avoided 
external  costs  and  30%  of  the  total  cost  of  the  subsidised  transport  mode,  the  Commission  considers  that  there  is  a 
presumption of necessity and proportionality of the aid. For aid above these thresholds, Member States must demonstrate 
the need and proportionality of the measures in question.  
62 13 out of 31 industry stakeholders and 5/8 authorities. 
63 Including three public authorities (DK, LV, PL), seven industry stakeholders, and three responses under ‘others’ category. 
64  Gathering  additional    data  on  EU  combined  transport,  TRT  2017,  https://op.europa.eu/en/publication-detail/-
/publication/e58e6253-fc01-11e7-b8f5-01aa75ed71a1  
65 Including two public authorities (DK, PL), eight industry stakeholders and two responses under ‘others’ category. 
66 PWC, KombiConsult (2022), op.cit. 
67 European Court of Auditors (2023), op. cit. 

15 

 
 
short  sea  shipping  terminals.  This  results  in  inability  to  make  initial  assessments  if  desired  intermodal 
operations would even be possible, without entering a dialogue with all terminals.  

3. Operational inefficiencies in terminals. Intermodal transport requires transhipment between the modes 
in a transhipment terminal. Low operational efficiency of terminals can considerably increase the handling 
time and delays due to issues such as yard congestion, the need for shunting due to short handling tracks, 
delays in transhipment due to insufficient transhipment technology or staff, lack of suitable transhipment 
equipment, among others. The investments by terminals into improving their operational efficiency are 
unequal and sometimes insufficient, in particular in areas with less competition between the terminals. The 
poor quality of service in terminals in the vicinity was considered by 37 of 100 respondents68 in the OPC as 
a factor negatively affecting the competitiveness of intermodal transport. While the proposed revision of the 
TEN-T Regulation imposes some requirements on TEN-T RR terminals (such as to be able to tranship all 
types  of  loading  units  for  vertical  transhipment  terminals  and  handle  740  m  long  trains  without 
manipulation),  no  other  motivation  exists  for  terminal  upgrades  in  areas  where  there  is  no  or  limited 
competition.  

2.3.  How likely is the problem to persist? 

According to the 2022 Strategic Foresight Report69, coupled with population growth and higher living standards, 
the demand for transport will continue to grow. In the baseline scenario, EU road freight transport is projected to 
grow by 49% by 2050, notwithstanding efforts to shift more traffic to other modes such as rail or waterborne. 
However, as the Strategic Foresight Report identifies synergies between digital and green transitions, digitalisation 
and artificial intelligence is also expected to boost the emergence of more efficient multimodal mobility solutions. 
This would also benefit intermodal freight transport and developments in this direction have already started, e.g. 
with the implementation of the eFTI Regulation. 

However, without further EU level action, the uptake of intermodal transport options for freight operations is likely 
to remain limited in the short to medium term. With no further changes to the CTD, only a limited share of the 
market would continue to have access to existing support which is needed to compensate for the lack of level 
playing field between the modes. Inconsistent interpretation and implementation of the CTD by Member States is 
expected to continue creating legal uncertainties. Even for eligible operations, the level of support is expected to 
remain insufficient to incentivise the shift from road-only transport to intermodal transport options. With no 
changes to the eligibility (i.e. the definition), the support would continue to be less effective and limited to less 
than half of all the intermodal operations in the EU. 

While some identified inefficiencies in intermodal transport will be addressed, either by way of other EU legislation 
or market developments, the cost of intermodal transport would not go down to the level that would make most 
medium-long operations competitive. Other external factors affecting the transport market can have further 
negative impact on competitiveness. For example, the current energy crisis has, due to high electricity costs, 
increased the price gap between road-only and intermodal transport70. Thus, the need for the CTD, as an 
instrument to support the competitiveness of intermodal transport, remains, while the appropriateness of the 
level and type of support needs to be continuously assessed vis-à-vis market developments. 

While there have been discussions with Eurostat to improve the reporting of intermodal transport data, no 
revision of relevant Eurostat regulations is currently planned. The information on market conditions can only be 
gathered by dedicated studies. Some inefficiencies might be reduced due to unilateral steps by private parties, in 
particular on transparency. Similarly, private third-party development of planning tools or sector-wide voluntary 
agreements on data interoperability are possible, albeit unlikely, in particular between different modes. 

68 Five public authorities (2 public authorities from BE, AT, FR, IT), 25 industry stakeholders, four EU citizens and three responses under ‘others’ category. 
69 COM(2022) 289 final. 
70 UIRR/UIP joint statement, https://www.uirr.com/en/media-centre/press-releases-and-position-
papers/2022/mediacentre/2370-joint-erfa-uip-uirr-statement-on-energy-price-increases.html   

16 

 
 
Nevertheless, without EU level action, it will not be possible to ensure a common level of interoperability and 
transparency across the EU.  

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

Title VI (Articles 90-100) of the Treaty on the Functioning of the EU71 (TFEU) establishes the EU’s prerogative to 
make provisions for the Common Transport Policy. Article 91(1)(c) TFEU provides that the EU has competence in 
the field of transport to lay down measures to improve transport safety, while Article 91(1)(d) TFEU provides the 
same competence as regards “any other appropriate provisions”. 

3.2. 

Subsidiarity: Necessity of EU action 

Under the principle of subsidiarity, in areas which do not fall within its exclusive competence, the EU shall act only 
if, and in so far as, the objectives of the proposed action cannot be sufficiently achieved by the Member States. 
Negative transport externalities, in particular those relating to climate change, are trans-boundary 
problems, which cannot be solved by national or local action alone. The pressing need to reduce GHG 
emissions produced by freight transport applies equally to cross-border and domestic operations. This is 
also the case of congestion and accidents on major transport corridors.  Thus, the problem identified needs to 
be addressed at EU level because it has a cross-border dimension. Otherwise, non-harmonised and fragmented 
approaches at national level, which will fall short of effectively addressing the cross-border issues of intermodal 
transport (81% of which is international) bear the risk of leading to competitive distortions in the Single Market. 

3.3. 

Subsidiarity: Added value of EU action 

The aim of the CTD is to promote the uptake of intermodal transport, of which 81% is between Member States, 
across the EU through support framework based on common eligibility criteria. From the policy and the internal 
market perspective, it is important to aim that the benefits provided for in the CTD are applicable in a comparable 
way throughout the EU. In conditions, where economic support under the today’s CTD is very limited, many 
Member States have reverted to supporting intermodal operations directly under the State aid rules. Those 
support measures may not be equally accessible to all operators, given that different eligibility criteria are used. 
Therefore, some operators may gain a competitive advantage with impacts beyond their national border. EU 
action with the aim to harmonise rules on eligibility and support framework that are coordinated with State aid 
rules, will help create comparable treatment of operators across EU, simplify administrative procedures for 
industry, the Member States and the Commission and improve the functioning of the internal market. This cannot 
be achieved with regulation at Member State level only.  

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The CTD sets the increase of the uptake of intermodal transport as a means to achieve the objective of reducing 
negative transport externalities72. In the same vein, the general objective of this revision is to facilitate an increase 
in the share of rail, SSS and IWW transport in total intra-EU freight transport to reduce the negative externalities 
and the energy consumption in the transport sector as well as to mitigate the fragmentation of internal market. In 
particular, in the context of a holistic approach together with a variety of modal initiatives on rail, inland 
waterways, short sea shipping and road transport as well as horizontal instruments on infrastructure, digital 

71 Consolidated version of the Treaty on the Functioning of the European Union, OJ C 326, 26.10.2012, p. 47–390. 
72 The preamble of CTD states: “Whereas the increasing problems relating to road congestion, the environment and 
road safety call, in the public interest, for the further development of combined transport as an alternative to road 
transport.” 

17 

 
 
solutions and GHG accounting, its objective is to bring forward in time the higher uptake of intermodal transport 
while the effects of other instruments have not yet taken full effect.  

The initiative should also contribute to the digital transformation as well as SDG. More specifically, it should 
contribute towards SDG 13 (Take urgent action to combat climate change and its impacts), SDG 9 (Build resilient 
infrastructure, promote inclusive and sustainable industrialisation and foster innovation) and SDG 11 (Make cities 
and human settlements inclusive, safe, resilient and sustainable).  

4.2. 

Specific objectives 

The specific objectives (SOs) and their correspondence with the problem drivers are presented in Figure 7. 

Figure 7: Specific objective and their relation to problem drivers 

Problem drivers 

Specific objectives 

General objective 

PD1: Eligibility for support under the 
CTD is too narrow and complicated 

SO1: Provide support to a wider range 
of operations under effective and 
common eligibility conditions 

PD2: Lack of market 
monitoring/empirical basis for support 

SO2: Ensure better support by 
improving reporting on the intermodal 
transport  

PD3: Incentives provided by the CTD 
to enhance relative competitiveness of 
intermodal transport are insufficient to 
reduce the gap with road-only transport 

SO3: Increase the competitiveness of 
intermodal transport to contribute to 
reducing negative externalities  

PD4: Inefficiencies in scheduling, 
planning and running intermodal 
transport 

SO4: Improve transparency and 
cooperation and simplify entry to the 
market 

GO: Facilitate an 
increase in the share of 
rail, SSS and IWW 
transport in total intra-
EU freight transport, to 
reduce negative 
externalities and energy 
consumption of 
transport as well as 
mitigate the 
fragmentation of the 
internal market 

Specific Objective 1 (SO1) - Provide support to a wider range of intermodal operations under effective and common 
eligibility conditions. The first specific objective is based on the need to improve the existing eligibility conditions 
and ensure that a larger part of intermodal operations could be included in the scope, while applying effective 
eligibility criteria. It would be important to ensure the coverage of all operations that could significantly contribute 
to reducing negative externalities but are not cost competitive vis-à-vis road-only transport. 28 of 49 respondents 
to the survey and 18 out of 29 interviewees73 supported that CTD eligibility assessment should be extended to a 
wider range of operations. All respondents to the survey agreed that eligibility conditions should be justified from 
the perspective of the general objective and made easy to control. Multiple stakeholders pointed out in the 
stakeholder meeting as well as in comments to the survey that the eligibility should be the same for different 
modal combinations. 

Specific Objective 2 (SO2) - Ensure better support by improving reporting on the intermodal transport. The second 
specific objective reflects the need to base the economic support on empirical evidence and to ensure that this 
support is regularly adjusted to consider the real needs of the market as well as the decreasing price gap as 
external costs become increasingly internalised. 20 out of 49 survey74 respondents supported the objective to 
improve monitoring and reporting on the status of intermodal transport.  

Specific Objective 3 (SO3) - Increase the competitiveness of intermodal transport to contribute to reducing negative 
externalities. The third specific objective refers to the need to make intermodal transport a more attractive 
alternative to road-only transport. 22 out of 49 respondents75 to the survey agreed or strongly agreed that the 
objective of the revised CTD should be to increase the competitiveness of intermodal transport. In practical terms, 

73 23/31 industry and 5/8 authority respondents in survey, 15/21 industry and 3/5 authorities in interviews. 
74 16/31 industry and 4/8 authority respondents. 
75 18/31 industry and 4/8 authority respondents. 

18 

 
 
 
the provided support should reduce the price gap between road-only and intermodal transport and thereby result 
in bringing down the distance at which an intermodal transport becomes cost competitive also for the medium-
long operations, leading to a higher uptake of intermodal transport and lower external costs of freight transport. 

Specific Objective 4 (SO4) - Improve transparency and cooperation and simplify entry to the market. The fourth 
objective reflects the need to make it easier for transport organisers to take up intermodal transport. In this 
regard, the CTD should improve the cooperation and exchange of information between the different parties in the 
transport chain and improve the efficiency of transhipment terminals as well as ensure that the information about 
services and facilities in terminals would be easily available. 17 out of 49 survey respondents and 18 out of 29 
interviewees76 agreed or strongly agreed that improving transparency and cooperation to facilitate and simplify 
entry to the market is an important objective. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

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

The starting point for the impact assessment of this initiative is the EU Reference scenario 2020 (REF2020)77, which 
takes into account the impacts of the COVID-19 pandemic on the transport sector. 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 202178 and the initiatives of the REPowerEU package proposed by the Commission on 18 May 202279. 
More specifically, it should be noted that the baseline scenario takes into account the CO2 standards for vehicles, 
the FuelEU maritime Regulation and the ReFuelEU aviation Regulation, as well as the Alternative Fuels 
Infrastructure Regulation and the proposed review of the Renewable Energy Directive. It also reflects the extension 
of the ETS to the maritime sector and seting up a self-standing ETS for road transport and buildings, as well as the 
proposed revision of the Energy Taxation Directive. Beyond this, it reflects the Eurovignette Directive and national 
measures like vehicle taxation. Thus, the baseline scenario takes into account the complex synergies between 
these policy instruments. The baseline scenario assumes no further EU level intervention on intermodal transport 
beyond the current CTD. For further details see Annex 4. 

In terms of transport network, the baseline scenario accounts for the proposed revision of the TEN-T Regulation80. 
It assumes that the high-quality TEN-T rail network would be gradually completed in three steps: 2030 for the core 
network, 2040 for the extended core network and 2050 for the comprehensive network. It also assumes full 
electrification of the core TEN-T rail network by 2030 and of the comprehensive network by 2050. In addition, the 
proposal includes for the first time an obligation on Member States to ensure sufficient multimodal freight 
terminal capacity based on dedicated analysis and action plans, which is part of the baseline scenario. The baseline 
also incorporates foresight megatrends81 and developments captured in the 2022 Strategic Foresight Report82, 
such as 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 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, its activity going up by 29.1% by 
2030 relative to 2015 (48.9% for 2015-2050)83. Rail transport activity is projected to grow significantly 
faster than road, driven in particular by the gradual completion of the TEN-T network, where Member States 
and private investment will continue to be supported by the EU funding instruments such as Connecting 

76 13/41 and 4/8 authority respondents in survey, 14/21 industry and 2/5 authority respondents, 2/3 NGOs. 
77  Detailed information about the preparation process, assumptions and results are provided in the EU Reference Scenario 
2020, https://energy.ec.europa.eu/data-and-analysis/energy-modelling/eu-reference-scenario-2020_en 
78 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en 
79 https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131 
80 COM(2021) 812 final. 
81 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
82   COM(2022) 289 final. 
83 More explanations on the relation with the baseline scenarios underpinning the ‘Fit for 55’ package and REPowerEU 
package are provided in Annex 4.  

19 

 
 
Europe Facility, Cohesion Fund and the European Regional Development Fund. Measures of the ‘Fit for 
55’ package also increase to some extent the competitiveness of rail and of waterborne transport relative to 
road transport. Freight rail traffic would increase by 42.2% by 2030 relative to 2015 (96% for 2015-2050), 
hence falling short of the milestone of the SSMS of increasing the traffic by 50% by 2030 and doubling it 
by 205084. Inland waterways and short sea shipping activity is projected to go up by 21.1% by 2030 relative 
to 2015 (49.5% for 2015-2050), also falling short of the milestone of the SSMS, in particular for 2030 (i.e. 
increase inland waterways and short sea shipping traffic by 25% by 2030 and by 50% by 2050)85.  

In 2015, the total intermodal transport volume in the EU was 534 billion tkm (Table 3)86. 68.5% of this was carried 
by SSS. RR constituted 28.5%, while transport by IWW, which is relevant only within a limited number of river 
basins, accounted for 3%. 54% of all intermodal transport was containerised (from which 58% on SSS), 18.7% was 
carried in semitrailers (from which 77% on ferries), 4% in swap-bodies almost entirely on rail and 24% was 
accompanied transport in full vehicle combinations (90% of this on ferries). By 2020, the total volume of intra-EU 
intermodal transport had grown by 9% compared to 2015, to 584 billion tkm. Out of this 69.2% was maritime 
intermodal transport, 28.3% RR and 2.6% IWW.  

Table 3: Intermodal and combined transport, 2015 

Mode 

Intra-EU freight 
bn tkm 

Door-to-door intermodal 
bn tkm 

% of total 
intra-EU 
freight 

Intermodal legs 

bn tkm 

% of total 
modal freight 

bn tkm 

Door-to-door  CT 
% of 
intermodal 

Road 
Rail 
152 
IWW 
16 
SSS 
366 
Total 
534 
Source: Statistical pocketbook 2022; Ricardo et al. support study (2023)  

1,562 
396 
147 
864 
2,969 

149 
123 
14 
248 
534 

5% 
1% 
12% 
18% 

10% 
31% 
9% 
29% 
18% 

92 
11 
123 
226 

60% 
69% 
34% 
42% 

The operations covered by the definition in the CTD are considerably lower constituting 42.3% in 2015 and 
42.1% in 2020 from total intra-EU intermodal transport and amounting to 226 billion tkm and 246 billion 
tkm, respectively. For rail intermodal, in 2015, 60% of operations were covered by the CTD, for IWW 69% 
and for SSS 34%87. 

84 As rail infrastructure capacity will need to accommodate an increasing amount of demand, in the baseline scenario by 
2030 nearly 9,000 kilometres of rail (about 6.5% of the network) would be affected by capacity restrictions, of which 
6,500 kilometres would be congested (4.7% of the network) and 2,500 kilometres highly utilised (1.8% of the network). 
By 2050, the rail network affected by capacity restrictions is projected to further increase to 20,200 kilometres (about 
14.6% of the network), of which 11,500 kilometres would be  congested (8.3% of the network) and 8,700 kilometres 
highly utilised (6.3% of the network). 
85 The scenarios underpinning the impact assessments accompanying the 2030 Climate Target Plan and the ‘Fit for 55’ 
initiatives and the staff working documents accompanying the SSMS and the REPowerEU package, took into account a 
broader range of policies (including this initiative as well as the initiatives on rail capacity, the revision of the Weights 
and Dimensions Directive and the CEEU) 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.  These initiatives (in particular the rail capacity initiative) are  contributing towards the achievement of the 
milestones set in the context of the SSMS. To define a meaningful baseline scenario for the initiatives being part of the 
Greening  freight  package,  these  initiatives  were  not  considered  in  the  baseline  scenario.  This  is  the  reason  why  the 
milestones of the SSMS are not assumed to be met in the baseline. 
86 ISL, KombiConsult (2017), op. cit. As no comparable data is systematically collected on the road legs of intermodal 
transport, intermodal specific data is based on the ISL, KombiConsult study (2017) where 2015 was the latest reported 
year. The UK volumes have been subtracted for comparison with future projections on EU27. Intermodal transport in EU 
includes domestic and intermodal door-to-door transport operations, including road legs and non-road legs. Intermodal 
traffic between EU and third countries such as deep-sea maritime transport is not included. 
87 This is due to the fact that many maritime operations, in particular island transport, are domestic and thus excluded 
from the scope, or that the road legs are longer than allowed by the current CTD, e.g. according to ISL, KombiConsult 
(2017), the median length of road legs in maritime intermodal is 98 km, while the average is 257 km, meaning that while 
majority of road legs are within current length limits, some are considerably longer.  

20 

 
 
 
 
 
 
The projected growth in the different intermodal segments is defined based on the expected evolution of the 
increase in the overall EU freight transport activity, and the increasing role of the unitised transport within 
the  EU freight  market.  It  also takes into  account  the measures aimed  at  reducing  and internalising the 
external costs of transport, mentioned above, and the complex synergies between them. At the same time, 
the  baseline  evolution  for  this  impact  assessment  has  been  defined  using  a  conservative  approach, 
considering in particular the constraints on terminal capacity88. As a result, in the baseline scenario, the total 
intra-EU intermodal transport is projected to grow 33% by 2030 and 91% by 2050 (relative to 2015). By 
2030, the RR will grow by 55% and by 2050 almost triple (171% relative to 2015), while IWW would grow 
by 4% by 2030 and 37.4% by 2050. SSS intermodal is expected to grow by 25% by 2030 and 60% by 2050. 
The operations covered by today’s CTD are expected to grow at comparable rates (Figure 8).  

Figure 8: Projected growth of intra-EU intermodal and combined transport in the baseline scenario 

 600

 500

 400

 300

 200

 100

 -

Rail intermodal

IWW intermodal

SSS intermodal

Rail CTD

IWW CTD

SSS CTD

2015

2020

2030

2040

2050

Source: Ricardo et al. support study (2023) 

Comparing the total non-road legs volume of intermodal transport with the respective total modal activity, 
the intermodal transport accounted for 27.4% of all EU27 non-road freight transport activity in 2015. For 
the various modes, in 2015 the share of transport activity carried on intermodal transport was 31% for rail 
and 29% for SSS, while for IWW this share is lower, around 9%. In the baseline scenario, the share of 
intermodal in total non-road freight is estimated to reach 28.9% in 2030 and 32.9% in 2050. The highest 
increase in the share is expected in the rail intermodal sector.  

CO2 emissions from transport are projected to be 24% lower by 2030 compared to 2015, and 87% 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 initiatives89, showing a combined approach of carbon pricing 
instruments and regulatory-based measures to deliver on the increased climate ambition90. NOx emissions 
are  projected  to  go  down  by  56%  between  2015  and  2030  (85%  by  2050),  mainly  driven  by  the 

88 Terminal capacity will likely remain an issue in the immediate future especially in the rail sector until sufficient terminal 
capacity,  as  proposed  by  the  TEN-T  Regulation  revision,  is  ensured.  The  recent  PWC,  KombiConsult  (2022)  study 
estimates for instance that terminal capacity in the EU will increase by only 18% until 2030, considering current plans 
for both terminal upgrades and new terminal constructions. 
89 SWD(2022) 230 final. 
90 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.  The scenario reflecting the 
‘Fit for 55’ initiatives, the REPowerEU initiatives and the forthcoming initiatives shows the need to reduce emissions 
from transport by 26% by 2030 relative to 2015 and by 94% by 2050. Therefore, this initiative contributes towards the at 
least 55% emissions reductions target by 2030 and achieving climate neutrality by 2050. 

21 

 
 
 
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 52% relative to 2015 (90% by 2050). 

Despite the infrastructure charges included in baseline, road freight congestion costs would continue to 
increase, and are estimated to amount to EUR 752 billion, expressed as present value over 2025-205091. 
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. External 
costs of road freight accidents are also projected to remain high, at EUR 98 billion expressed as present 
value over 2025-2050.  

The  baseline  scenario  reflects  the  projected  higher  energy  prices  driven  by  the  Russian  invasion  of 
Ukraine92. Beyond this aspect, it was however not possible to quantify the impact of the Russian invasion 
of Ukraine, 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 limited. The problem that 
the uptake of the intermodal freight transport is insufficient for effectively contributing to the reduction of 
external costs and energy consumption of transport is likely to persist.  

5.2.  Description of the policy options 

5.2.1.  Retained policy measures 

As a first step, a comprehensive list of possible policy measures was established after consultations with 
stakeholders, an expert meeting, independent research and the Commission’s own analysis. This list was screened 
based on the likely effectiveness, efficiency and proportionality of the proposed measures in relation to the given 
objectives, as well as their legal, political and technical feasibility. The retained policy measures have been grouped 
in three policy options, with one of them having three sub-options. Table 4 presents the list of policy measures 
included in the policy options, organised based on problem driver and specific objective they address. Measures 
PM3 (proof of eligibility via eFTI platforms) and PM16 and PM17 (improving transparency of terminal services) are 
common to all policy options. 

Table 4: List of retained measures and options 

No 

Categories measures by 
thematic area 

PO-
A 

PO-
B1 

PO-
B2a 

PO-
B2b 

PO-C 

Proble
m 
drivers 
and 
specific 
objectiv
es   

PM1 

PM2 
all-
intra
-EU 

Provide support to a wider range of operations under effective eligibility 
conditions 
Include in the scope all intermodal 
operations in the EU that save 
25% GHG when using intermodal 
operation instead of road-only; 
calculation of GHG savings is 
based on common EU 
methodology (CEEU) 
Include in the scope all intermodal 
operations in the EU that save 
40% external costs when using 
intermodal operation instead of 
road-only; calculation of external 
costs is based on common EU 
methodology based on the unit 

PD1 
SO1 

PD1 
SO1 

✓ 

✓ 

✓ 

✓ 

91 Road congestion costs cover both the road legs of intermodal transport operations and road-only transport operations.  
92 SWD(2022) 230 final.  

22 

 
 
 
 
 
 
 
 
 
No 

Categories measures by 
thematic area 

PO-
A 

PO-
B1 

PO-
B2a 

PO-
B2b 

PO-C 

Proble
m 
drivers 
and 
specific 
objectiv
es   

✓ 

PM2 
cross
- 
bord
er 

values from the Handbook93, 
established by means of an 
implementing act 
Include in the scope only cross-
border intermodal operations in 
the EU that save 40% external 
costs when using intermodal 
operation instead of road-only; 
calculation of external costs is 
based on common EU 
methodology  based on the unit 
values from the Handbook, 
established by means of an 
implementing act 
Establish common data set for 
proof of eligibility with 
implementation via eFTI platforms  
Ensure better support by improving reporting on the multimodal/ 
intermodal transport  
PM4  Replace reporting by the 

PD1 
SO1 

PD1 
SO1 

✓ 

✓ 

PM3 

Commission with Member States’ 
voluntary analysis and strategic 
planning for sustainable freight 
transport  

PD2 
SO2 

✓ 

PM5  Replace reporting by the 

Commission with Member States’ 
mandatory analysis and strategic 
planning for all freight transport 
system (cross-modal). An 
obligation to regularly review the 
measures.  

PM6  Reporting by the Commission with 
revised monitoring data and 
reporting period, including a 
review clause for reassessing the 
support regime established in the 
CTD.  
Obligation for Member States to 
notify ex ante their support 
schemes, which the Commission 
has to make available in a 
common website  

PD2 
SO2 

PD2 
SO2 

✓ 

Increase competitiveness of  multimodal/ intermodal transport 

PM7  Mandatory harmonised support, 

does not constitute State aid: 
harmonised obligation on Member 
States to provide support with an 
aim to reduce door-to-door costs 
of intermodal operations at a level 
that induces modal shift; remove 

PD3 
SO3 

93 The Handbook on the external costs of transport CE Delft et al. (2019). op.cit.  

23 

✓ 

✓ 

✓ 

 
     
 
 
 
 
 
 
 
 
 
 
 
 
No 

Categories measures by 
thematic area 

PO-
A 

PO-
B1 

PO-
B2a 

PO-
B2b 

PO-C 

Proble
m 
drivers 
and 
specific 
objectiv
es   

all existing regulatory measures 
(Articles 2, 4, 7, 8, 9) 

PM8  Voluntary non-harmonised 

support, the State aid rules apply 
where relevant: call on Member 
States to use operational support 
tools from the Toolbox with an 
aim to reduce door-to-door costs 
of intermodal operations at a level 
that induces modal shift 

PM9  Mandatory non-harmonised 

PD3 
SO3 

✓ 

support, the State aid rules apply 
where relevant: obligation on 
Member States to have at least 
one operational support tool from 
the Toolbox with an aim to reduce 
door-to-door costs of intermodal 
operation at a level that induces 
modal shift 
Voluntary support, the State aid 
rules apply where relevant: call on 
Member States to provide start-up 
support 
Mandatory non-harmonised 
support, the State aid rules apply 
where relevant: obligation on 
Member States to have at least 
one technological upgrade support 
measure from the Toolbox 
Limit the direct financial support 
only to short and medium-long 
operations that are normally not 
cost-competitive with road-only 
transport (mode specific 
thresholds) 
Exempt road-legs of eligible 
operations from weekend and 
holiday driving bans  

PD3 
SO3 

✓ 

PD3 
SO3 

✓ 

✓ 

PD3 
SO3 

PD3 
SO3 

PD3 
SO3 

✓ 

✓ 

✓ 

✓ 

✓ 

Improve transparency and cooperation and simplify entry to the market 

Define a data set for information 
to be shared between parties of 
transport chain by means of an 
implementing or delegated act 
Establish an obligation to use 
common data exchange protocols 
for operations covered by this 
Directive by means of an 
implementing or delegated act 
Require terminal operators to 
publish information on services 
and facilities available in each 
terminal. List of mandatory 

PD4 
SO4 

PD4 
SO4 

PD4 
SO4 

24 

✓ 

✓ 

✓ 

✓ 

✓ 

PM1
0 

PM1
1 

PM1
2 

PM1
3 

PM1
4 

PM1
5 

PM1
6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
No 

Categories measures by 
thematic area 

PM1
7 

information to be established in an 
implementing act. 
Provide a possibility to establish a 
framework of terminal categories 
based on minimum requirements 
on services/facilities available at 
terminals, by means of an 
implementing act. 

Proble
m 
drivers 
and 
specific 
objectiv
es   

PD4 
SO4 

PO-
A 

PO-
B1 

PO-
B2a 

PO-
B2b 

PO-C 

✓ 

✓ 

✓ 

The main questions that were addressed when choosing the retained policy measures and building the policy 
options are discussed below. 

Under  specific  objective  1  “Provide  support  to  a  wider  range  of  operations  under  effective  eligibility 
conditions” the main question of the analysis was which operations should be eligible for the support. From 
the perspective of the general objective, all intermodal operations in the EU, including domestic intermodal 
operations, should be covered (as in the 1998 and 2017 proposals). On the other hand, to cater for potential 
questions around subsidiarity, PM2-cross-border considered only cross-border operations.  

Regarding  eligibility  criteria,  following  the  experience  of  the  current  CTD,  previous  two  amendment 
attempts and the results of the stakeholder consultation, it was concluded that a new and more objective 
approach is needed for defining eligibility, where it is directly linked to the savings of the external costs. 
This means that only intermodal operations that achieve significant savings in external costs will be eligible 
under the revised CTD. Two different measures were analysed: eligibility based on GHG alone (PM1)94 or 
on  a  wider  set  of  externalities  including  in  additon  to  GHG  also  air  pollution,  noise,  congestion  and 
accidents95  (PM2-all-intra-EU  and  PM2-cross-border).  For  both,  further  analysis  was  carried  out  to 
establish the percentage threshold of external cost savings.  

Various thresholds (from 20% to 75%) were tested and assessed, the two guiding principles being to ensure 
that (a) all modal combination could be eligible and (b) a major part of operations would be carried by a 
non-road  mode  (see  Annex  4,  section  3.1.1).  Common  to  all  POs  is  a  measure  to  review  the  list  of 
information  that  needs  to  be  provided  for  proof  of  eligibility  and  establish  an  obligation  to  use  eFTI 
platforms for making this information available. eFTI platforms would automatically calculate eligibility 
based on transport data already in the system (PM3).  

Under the specific objective 2 “Ensure better support by improving reporting on the multimodal/ intermodal 
transport”, two measures were considered in addition to the possibility to keep the existing Commission 
reporting obligation with small changes in monitoring data and frequecy of reporting (PM6)96. These two 
measures involve market analysis and reporting by Member States, either voluntary (PM4) or mandatory 
(PM5). Such market analysis is needed to adjust the support measures, but also to evaluate the support 

94 An option with GHG only was considered, given that it was promoted by some stakeholders, even though it gathered 
less support than basing eligibility on a wider set of externalities (4 compared to 18 survey respondents out of 22, i.e. 
18%; and 4 compared to 14 interviewees out of 21, i.e. 33%). In addition, it was assessed, whether including in eligibility 
criteria only GHG, which is easier to monitor and could to some extent act as a proxy to capture the other externalities, 
could be sufficient to achieve the objectives.  
95 GHG, air pollution, congestion, noise, fatalities and injuries were used for modelling. 
96  The  “Impact  assessment  support  study  for  the  review  of  the  Community  guidelines  on  State  aid  for  railway 
undertakings” noted that to learn about the effectiveness and efficiency of various scheme designs, evidence is required, 
but  ex-post  evaluations  for  State  aid  schemes  under  the  Railway  Guidelines  are  very  rare.  The  introduction  of  the 
requirement to evaluate schemes could facilitate the generation of such evidence, and allow for better informed choices 
of scheme design in the future. 

25 

 
 
regime established in the CTD, given that over time different regulatory and market-based measures, which 
reduce and internalise the external costs, are phased in.  

Under the specific objective 3 “Increase competitiveness of multimodal/ intermodal transport”, a choice 
had to be made between different economic support and regulatory measures. As a result of an analysis of 
most common support schemes in the EU and in the world as well as those proposed in the literature, three 
types  of  support  measures  were  selected  –  operational  support  that  can  be  mandatory  and  harmonised 
(PM7), voluntary (PM8) or mandatory but not harmonised (PM9), start-up support and support for new 
services and for technological upgrade (e.g. for loading units, machinery and digital equipment). With a 
view to coordinate between national measures as well as with with State aid rules, lists of different support 
tools  that  could  be  used  under  these  measures  by  Member  States  –  a  Toolbox  –  was  established.  The 
Toolbox includes tools for operational (PM7, PM8, PM9) and for technological upgrade (PM11) support. 
Each group includes a list of different tools (for examples see Annex 9). A limitation of the admissibility 
for economic support under PM7-PM9 to only short and medium-long freight transport operations was 
retained to avoid supporting operations that are price-competitive without support (PM12). In addition, one 
new regulatory support measure in addition to existing ones in the current CTD is proposed similar to the 
1998  amendment  proposal,  to  establish  an  exemption  from  driving  bans  for  road-legs  of  intermodal 
transport to ensure timely arrival to terminals (PM13).  

Under the specific objective 4 “Improve transparency and cooperation to facilitate flexibility and simplify 
entry to the market”, measures for data interoperability (PM14, PM15) and terminal transparency (PM16, 
PM17) were retained.  

A detailed description of retained policy measures is given in Annex 6. 

5.2.2.  The construction and description of the options 

Policy measures are assigned to policy options (POs) based on their level of intervention. PO-A is the option with 
the softest intervention at EU level, while PO-C shows the strongest intervention. Following this general principle, 
the measures were selected so that in each policy option all identified problem drivers and specific objectives are 
addressed. The results of stakeholders’ consultations and field research were used for the final design of the 
measures and their combination into options, including variants to PO-B, allowing to assess different eligibility 
criteria. 

The different options are characterised by: 
-  The choice of scope and eligibility criteria (PD1, SO1): 

o  All  options,  except  PO-B2b,  cover  all  intra-EU  operations  (including  domestic).  PO-B2b 

includes only cross-border intra-EU operations.  

o  PO-B1 is based on GHG emissions reduction, while all other options consider a wider set of 
negative  externalities  from  the  transport  sector  (PM2).  PM3  is  included  in  all  POs,  as  it 
establishes a common enforcement regime. 

-  The way to organise market monitoring (PD2, SO2): (PM4-PM6) varies from Member States voluntary 
analysis and strategic planning in PO-A to a mandatory cross-modal analysis in most interventionist PO-
C. PO-B keeps the reporting obligation with the Commission. 

-  Different intervention intensities of economic and regulatory support measures (PD3, SO3): these vary 
from voluntary in PO-A to mandatory but not harmonised in PO-B to mandatory and harmonised in PO-
C. PO-A and PO-B will establish an upper distance limit to ensure that only operations that normally are 
not competitive with road-only can benefit. PO-C does not have such a limit, to allow to assess the impact 
of an alternative design. Support measures for PO-A and PO-B are defined in the Toolbox allowing 
Member States to choose, while in PO-C one common harmonised support scheme applies across the 
EU. In all options, the support should be sufficient to induce modal shift. 

-  The  choice  of  measures  to  ease  the  market  entry  and  cooperation  (PD4,  SO4):  all  options  include 
terminal  transparency  requirements  and  propose  to  categorise  terminals.  PO-C  defines,  in  addition, 

26 

 
common data sets and exchange protocols, with highest level of intervention in business-to-business data 
exchange process between different transport chain parties. 

Policy option A (PO-A) is the option with softest intervention at EU level. It applies to all intra-EU operations, 
except those that do not have a viable road alternative. The eligibility is based on a wider set of externalities, 
requiring savings of at least 40% of external costs, with a methodology established in the Handbook on the 
external costs of transport97 (PM2-all-intra-EU). The guidance for calculations will be established in an 
implementing act98. The data to be provided for the proof of eligibility will be reviewed and tied to eFTI platforms 
(PM3).  

The current Commission’s biennial reporting obligation will be replaced by a call to Member States to carry out 
regular analysis and strategic planning for sustainable modes of transport to choose appropriate support (PM4). 
While PO-A does not oblige Member States to provide any support, it does provide a Toolbox with predefined 
support tools to choose from (PM8). Where relevant, such support tools need to be compliant with State aid rules, 
including the time limits on support schemes. Member States are not required to change their existing State aid 
schemes (which are outside the scope of the current CTD). Member States are also called on to not support 
operations that are longer than the established cost-competitiveness distances to avoid inefficiencies and/or 
windfall profits (PM12). Sectoral State aid guidelines and block exemptions, where available, will apply. 

For terminal transparency and cooperation, one implementing act would introduce common transparency 
rules for terminals ensuring that all terminals make publicly available data on terminal facilities and services 
(PM16)  and  another  could,  after  additional  dedicated  analysis,  establish  a  terminal  categorisation 
framework (PM17). These measures are complementary to the proposed revision of the TEN-T Regulation, 
which addresses the terminal capacity and quality on the TEN-T network and is reflected in the baseline.  

Policy option B (PO-B) is the option that combines obligations at EU level with flexibility to take into account 
Member States specific situations. It obliges Member States to support intermodal transport but gives them a 
freedom to choose among the operational and technological upgrade support tools listed in the Toolbox, to 
address the challenges in national transport systems. For the scope, the following variants are analysed: 

•  PO-B1  and  PO-B2a  apply  to  all  intra-EU  operations  except  those  that  do  not  have  a  viable  road-

alternative (PM1 and PM2-all-intra-EU, respectively).  

•  PO-B2b applies only to cross-border intra-EU operations, having a similar scope to the current CTD 

(PM2-cross-border). 

Another set of variants are analysed for the eligibility condition:  

• 

• 

In option PO-B1, the eligibility is based on GHG savings with a threshold of 25% (expressed in tonnes 
of  CO2  equivalent,  PM1)  calculated  using  the  methodology  that  is  currently  being  elaborated  in  a 
parallel EU initiative, namely CEEU. 

In options PO-B2a and PO-B2b, the eligibility is based on a wider set of externalities, similarly to PO-
A (PM2-all intra-EU and PM2-cross-border, respectively).  

In all PO-B sub-options, the data to be provided for proof of eligibility will be reviewed and tied to eFTI platforms 
(PM3). 

For market analysis and reporting, all PO-B sub-options would rely on the current obligation where the 
Commission has to prepare the reports with assistance from Member States and by using dedicated market 
analysis studies (PM6). However, the interval between reports would be extended from 2 to 5 years, to 

97 CE Delft (2019).  
98 To ensure sufficiently precise comparison of operations, it would be necessary to continue updating the Handbook on 
regular basis, taking into account the latest scientific evidence. In addition, consistency and complementarity with the 
upcoming CEEU has to be ensured.  

27 

 
 
allow support measures to have an effect. The list of monitoring data to be covered by the report will be 
updated. A review clause for the assessment of the need to continue the support and its suitability will be 
included as well as an obligation on Member States to notify to the Commission their upcoming support 
schemes. The Commision has to publish this information.  

For support tools, all PO-B sub-options require Member States to reduce operational costs (PM9) as well 
as to provide support for technological upgrades (PM11) (at least one tool for each). However, Member 
States can choose their own tools from the Toolbox to adapt the support to national circumstances within 
the given limits. Furthermore, Member States are called upon to establish start-up support measure for new 
intermodal routes, in particular in case of new terminals (PM10). Member States are also called on not to 
support operations that are longer than the established cost-competitiveness distances to avoid inefficiencies 
and/or windfall profits (PM12). Sectoral State aid guidelines and block exemptions, where available, will 
apply. All PO-B sub-options would include a regulatory benefit exempting road-legs of eligible operations 
from fixed driving bans (night-time, weekend and holiday driving bans) (PM13).  

For terminal transparency and cooperation, the measures are the same as in PO-A. 

Policy option C (PO-C) establishes the strongest EU level intervention. It applies to all intra-EU operations 
except  those  that  do  not  have  a  road-alternative.  The  eligibility  is  the  same  as  for  PO-A  and  PO-B2 
suboptions, based  on  a  wider  set of  externalities  at  a 40% threshold  (PM2-all-intra-EU).  Like in other 
options, the data to be provided for proof of eligibility will be reviewed and tied to eFTI platforms (PM3).  

The Commission’s biennial reporting obligation will be replaced by Member States’ obligation to carry out 
regular  analysis  and  strategic  planning  that  covers  the  full  transport  system  and  includes  cross-modal 
analysis (PM5). This enables to assess the efficiency of the measures in terms of the objectives of increasing 
the share of rail, SSS and IWW transport in total intra-EU freight transport. In this context, Member States 
will have an obligation to gather data on intermodal operations in the respective modal combinations.  

For support tools, it obliges Member States to provide harmonised support to reduce the cost of (the part of) 
eligible operations taking place in their territory at the level that induces uptake of intermodal transport 
(PM7). This support level is assessed to be 10% of total door-to-door cost of the operation for the shipper 
(for more details, see section 6.1.1 and Annex 4, section 3.3.1). PO-C would also include a regulatory benefit 
exempting road-legs of eligible operations from fixed driving bans, as in PO-B (PM13).  

For data interoperability, PO-C provides establishing a defined data set that needs to be interoperable and can be 
shared across the transport chain (PM14). In addition, an obligation is established on Member States and private 
parties to ensure the use of common data sets and data exchange protocols between transport modes and 
different parties in intermodal operations, based on the ongoing work of the Digital Transport and Logistics forum 
(PM15). The measures for terminal transparency (PM16 and PM17) are the same as in PO-A and PO-B.  

5.3.  Measures and options discarded at an early stage 

5.3.1.  Discarded policy measures 

Regarding the scope, the possibility to extend the coverage of the CTD to all multimodal (rather than only 
intermodal) operations was evaluated but discarded as being technically unfeasible. In addition, a measure to 
extend the support to all intermodal operations, including to the parts taking place outside of EU territory was 
discarded due to high financial costs and implementation difficulties.  

As regards support measures, a call for Member States to provide any support without target support level and 
guidance from the Toolbox (as in PM8) was discarded as ineffective.   

Finally, a measure to establish common data standards only for eligible intermodal operations was discarded as 
ineffective, as was the measure of a voluntary industry-driven terminal categories framework. Establishment of EU 

28 

 
freight transport horizontal and vertical cooperation platforms was discarded as technically questionable and more 
suitable for private initiatives. 

A more detailed description of discarded policy measures is given in Annex 7. 

5.3.2.  Policy options discarded at an early stage 

One sub-option of PO-A, using GHG savings rather than a wider set of externalities, was discarded given its limited 
contribution to the objectives. Following the analysis on the externalities’ savings thresholds, two additional sub-
options of PO-B were discarded. Sub-option PO-B1’, where the GHG savings level was 40%, was discarded because 
IWW would never be eligible and SSS would not be eligible as of 2040. PO-B2’, where a wider set of externalities 
savings level was 25%, was discarded as having too low threshold, whereby all operations on rail would have been 
eligible, even those where the rail leg would be less than 10% of total distance. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section summarises the main expected economic, social and environmental impacts of each policy option99. 
The proposed measures are assumed to be implemented from 2025 onwards, so the assessment has been 
undertaken for the 2025-2050 period and refers to EU-27. 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 which the various policy options entail for 
national  public  administrations,  for  the  European  Commission  and  for  the  businesses.  A  quantitative 
assessment  of  the  impacts  on  volumes  of  intermodal  transport  and  on  administrative,  adjustment  and 
economic support costs as well as cost savings for businesses and public authorities per policy measure and 
policy option has been performed and is presented in detail in Annex 4. In addition, this section covers the 
impacts  on  the  competitiveness  of  intermodal  transport  and  GDP,  SMEs,  digital  by  default100,  the 
functioning  of the internal market  and  competition,  energy  consumption  and  regional  distribution.  The 
economic impacts result from the changes of the market price of intermodal transport and the resulting 
modal shift, on the one hand, and increased budgetary contribution by Member States, on the other hand.  

6.1.1.  Impact on competitiveness of intermodal transport, modal shift and GDP 

The support to be provided by Member States to eligible intermodal operations is aimed at achieving a reduction 
in the transport prices for senders of goods - the shippers, allowing operations that today are not price-competitive 
with road-only transport to have a comparable or lower price than a road operation on same distances. This is 
expected to motivate the shippers to choose more intermodal transport for their transport needs. The TRUST 
model has been used to estimate the impact on modal shift due to a reduction in transport costs (for the non-road 
legs of the intermodal operations) and transhipment costs brought about the support measures, while considering 
the multimodal transport network embedded in the model. More explanations about the model are provided in 
Annex 4. 

Evidence of the effectiveness of economic support measures on the uptake of intermodal transport and modal 
shift can be found in various applications across the EU. Results of the Marco Polo I programme (2003-2006) that 
amounted to EUR 41.8 million of funding, showed that funded actions resulted in a modal shift of 21.9 billion tkm 
away from road. Marco Polo II programme (2007-2013) had a longer duration, with final funding of EUR 99.8 
million, and included two new types of actions (Motorways of the Sea and traffic avoidance). The funding intensity 
was also doubled, from 1 to 2 EUR for each 500 tkm shifted away from road (i.e. from 0.002 to 0.004 EUR per tkm 

99  The  analysis  in  this  section  is  based  on  Ricardo  et  al.  support  study  (2023),  and  on  the  analysis  of  stakeholders' 
feedback. 
100 https://ec.europa.eu/info/sites/default/files/file_import/digitally-transformed_user-focused_data-
driven_commission_en.pdf 

29 

 
 
shifted). Considering all modal shift actions, Marco Polo II programme is estimated to have resulted in 35 billion 
tonne-kilometres shifted away from road, of which 19.5 bn tkm to rail, 14.8 bn tkm to SSS and 0.7 bn tkm to IWW. 
In addition, as explained in Annex 4, the results of Marco Polo II programme showed that each new intermodal 
service can shift between 815,000 and 846,000 tkm off the road (to rail and SSS services), and about 260,000 tkm 
in the case of IWW services101. Additional explanations on the Marco Polo programme and evidence from other 
support measures (Ferrobonus and Ecobonus in Italy, aid for rail transport in certain intermodal transport services 
and aid for innovative combined transport in Austria) at national level are included in Annex 14.  

The impact on modal shift driven by the three policy options is a function of eligibility (how many operations are 
eligible to be supported) and different approaches to support it.  

To identify the necessary level of support for making intermodal operations price-competitive, the analysis 
focussed on the average break-even distances, i.e. the shortest distance at which intermodal operations will 
become price-competitive with road-only operations, as discussed in section 2.1.1. Getting more operators to 
choose intermodal transport means in practice that the break-even distances in the future have to be shorter than 
today. This will depend on the share of costs supported by Member States. A limited cost-benefit analysis was 
carried out to establish what levels of support would provide which decrease in the break-even distances and 
which impact on volumes of modal shift, while also keeping in mind that increased support means a higher 
budgetary burden for Member States. Model simulations were used to estimate the stand-alone impact of 
reducing the costs on the break-even distance and on modal shift (i.e. without considering any eligibility condition), 
as shown in Figure 9. The analysis was carried out by reducing the door-to-door costs by 5%, 10%, 15% and 20%, 
and the impact on the distances at which the intermodal operation would become cost-competitive with road-
only transport was estimated. Based on stakeholder consultation, literature review and modelling, the reasonable 
support level (aid intensity) to compensate for the price gap between road-only and intermodal transport that 
would induce modal shift was assessed to be between 10% and 15%. A lower level than 10% will not result in 
sufficient price reduction to motivate operators to shift their operations to intermodal. A higher level will bring the 
break-even distances to levels where operations are not competitive for reasons other than price (transit time and 
inconvenience). Considering that higher support levels also bring along higher budgetary costs for Member States, 
10% has been chosen for the purpose of this impact assessment. For further details on the related assessment of 
support level, see Annex 4, section 3.3.1.  

Figure 9: Impacts of different levels of door-to-door cost reduction (% increase in intermodal transport activity compared 
to the baseline) 

12

10

8

6

4

2

0

5%

10%

15%

20%

Source: Ricardo et al. support study (2023) 

Rail

IWW

SSS

This level of support will not make all intermodal operations price-competitive, but rather will reduce the break-
even distance and thus make more medium-long distance intermodal operations interesting for shippers. The 

101 INEA (2020), Marco Polo II Programme, Final report. 

30 

 
 
 
short distance operations will not become price-competitive but are also less likely to shift to intermodal for other 
reasons, mostly due to longer transport time when terminal operations are involved. At the same time, long 
distance operations are already price-competitive and do not require additional economic support. Thus, the 
impact will be concentrated on medium-long intermodal operations between the distance threshold where they 
are already competitive and a new lower threshold where they will not become competitive due to reasons 
beyond cost-competitiveness. The assessment also takes into account the expected developments over time in the 
efficiency and prices of road-only transport and the resulting risk of reverse modal shift – the risk that some 
intermodal operations could move back to road-only transport if road transport becomes more competitive and 
the break-even distances of road and intermodal transport increase instead of decreasing.  

Figure 10 represents the break-even distances at which operations can become price-competitive with the 
proposed support of 10%, ceteris paribus. The impact is different on different modal combinations. The biggest 
impact will be felt on RR, where door-to-door operations up to 200 km shorter than today will become price 
competitive, with lower average competitive distance after support being 533 km (from which 417 km on rail). The 
smallest impact will be on IWW operations, where 45 km shorter operations, at around 204 km (from which 184 
on barge) will become price-competitive. SSS operations will figure in the middle with reduction of break-even 
distance by 120 km to 697 km (from which 541 km on sea). 

Figure 10: Average cost-competitive door-to-door distances in intermodal transport without and with the support 
proposed in this revision, per modal combination (cost in EUR and km) 

Source: Ricardo et al. support study (2023) 

The assessment also considers other factors that impact the decisions of shippers beyond price – availability of 
infrastructure, suitable connections, delivery time etc., meaning that not all operations within those distance 
bands will shift to intermodal.  

The final impact on new price-competitive break-even distances depends on the level of final effective support 
passed through to final users. The 2014 study on CT102 concluded, supported by the experience of DG Competition, 
that the pass-through of the support depends on who are the beneficiaries as well as specific conditions of a 
scheme. It is thus important that beneficiaries, conditions and level of support are established in a way that induce 
changes in the behaviour of those taking the decision on modal choice. This is also part of the assessment carried 
out by DG Competition of the State aid measures notified by Member States.  

102 KombiConsult (2014), op. cit.  

31 

 
 
The additional volumes of intermodal operations in 2030 and 2050, relative to the baseline, are presented in Table 
5. Cumulatively over 2025-2050, PO-A is expected to achieve a total additional volume of intermodal operations of 
24.6 bn tkm relative to the baseline. The modest increase is a result of the fact that in PO-A providing support will 
be voluntary, meaning little change compared to the baseline is expected. In PO-B and PO-C, the volumes are 
expected to grow at a considerably higher rate, with the growth increasing considerably between 2030 and 2040. 
Cumulatively over 2025-2050, the total additional volume for PO-B1 would be 1,388 bn tkm, for PO-B2a 1,391 bn 
tkm, for PO-B2b 1,072 bn tkm, and for PO-C 829 bn tkm103. The difference between PO-B1 and PO-B2a stems from 
different eligibility, in particular the fact that in PO-B1 the eligibility is based only on GHG savings, which makes 
most IWW and some SSS operations not eligible already before 2040. The difference between PO-B2a and PO-B2b 
stems from the different scope, with PO-B2a coving all intra-EU operations (including domestic) while PO-B2b only 
cross-border intra-EU operations. The total additional volume in PO-C is smaller than in PO-B mostly because of 
removal of existing regulatory measures, including the equivalent treatment of international combined transport 
with international road transport as regards the use of non-resident hauliers (Article 4) that is considered today the 
most important regulatory benefit by stakeholders. All policy options contribute towards SDG 9 (Build resilient 
infrastructure, promote inclusive and sustainable industrialisation and foster innovation). 

Table 5: Modal shift (traffic volume of new non-road legs) and total intermodal transport (incl. road legs) that would 
be induced by different POs and growth compared to the baseline in 2030 and 2050 (bn tkm) 

2030 
IWW 

Rail 

SSS 

Rail 

PO-A 

0.2 

17.0 
PO-B1 
PO-B2a  16.6 
PO-B2b  13.5 
8.4 
PO-C 

0.0 

0.3 

0.6 

0.6 

0.1 

11.3 

11.5 

10.7 

1.0 

36.7 

36.8 

24.3 

25.9 
Source: Ricardo et al. support study (2023) 

0.2 

5.3 

2050 
IWW 

0.0 

0.04 

0.8 

0.8 

0.3 

2030 

2050 

SSS 

0.2 

14.2 

14.7 

11.9 

9.8 

Total  
intermodal 
0.38 

37.9 

37.7 

32.8 

18.3 

% growth  

0.1% 

5.4% 

5.3% 

4.6% 

2.6% 

Total  
intermodal 
1.6 

66.1 

67.5 

48.1 

46.7 

% growth 

0.2% 

6.5% 

6.6% 

4.7% 

4.6% 

It is important to point out that in the sub-option PO-B1 with the GHG-only eligibility criterion, most IWW 
operations will not be eligible for support during the second half of the analysed period104, while almost all RR 
operations, including those where the rail leg is very short and road legs are longer than rail leg would be eligible. 
The increase in rail compensates for the loss in IWW and the total impact for PO-B1 is similar to PO-B2a both in 
each year as well as over the period of 2025-2050, relative to the baseline. The impact of PO-B2b is projected to be 
lower than that of PO-B2a due to the fact that it covers only cross-border intra-EU operations. 

103 The objective of the initiative is to induce a substitution effect. The income effect, as shown by the modelling results, 
is limited in all policy options (i.e. the increase in the total transport activity is lower than 0.2% relative to the baseline 
for all time periods). This is because the demand for freight transport depends on the demand and supply of goods and 
the  price  elasticity  of  demand  for  freight  transport  is  low.  Furthermore,  support  will  not  bring  the  price  lower  than 
currently charged for road transport services. 
104 The fact that most IWW operations will not be eligible under PO-B1 during the second half of the period is due to the 
fact that the greenhouse gas emissions performance of road transport is projected to significantly improve over time and 
catch up with that of IWW. This is not due to lower ability to reduce greenhouse gas emissions from IWW relative to 
road transport. It rather reflects the EU level and Member States level policies implemented and proposed so far, and 
included in the baseline. As different regulatory and market-based measures are phased in (reducing and internalising the 
external costs) the relevance and eligibility criteria in the CTD will need to be reassessed and adjusted. 

32 

 
  
 
Figure 11: Additional intermodal volume per policy option and mode over 2025-2050, relative to the baseline, in bn 
tkm 

IWW intermodal

SSS intermodal

Rail intermodal

0,0

100,0

200,0

300,0

400,0

500,0

600,0

700,0

800,0

900,0

1000,0

PO B2-b

PO C

PO B2

PO B1

PO A

Source: Ricardo et al. support study (2023) 

The increase in the intermodal rail traffic, as envisaged in the best performing policy options (PO-B1 and PO-B2a), 
is expected to require up to a maximum 3% increase in rail capacity relative to the baseline in 2050 that can be 
absorbed thanks to better management of the rail capacity105. In this context, it should be noted that the rail 
capacity initiative, part of the forthcoming Greening freight package, is expected to bring about an improvement in 
the management of capacity and traffic that results in visible progress of rail performance106. This comes in 
addition to the improvements in infrastructure envisaged in the baseline scenario, due to the proposed revision of 
the TEN-T Regulation. This includes for the first time an obligation on Member States to ensure sufficient 
multimodal freight terminal capacity based on dedicated analysis and action plans. Post-2030, terminal capacity is 
thus expected to increase in line with the demand. The proposal also envisages that the high-quality TEN-T rail 
network would be gradually completed in three steps: 2030 for the core network, 2040 for the extended core 
network and 2050 for the comprehensive network, as explained in section 5.1.1. 

The increase in the competitiveness of intermodal transport operations is expected to have knock-on effects 
throughout the entire economy, leveraging the initial impact on the transport sector. This is also expected to lead 
to positive impacts on GDP. The impact on GDP is however estimated to be small as the proposal does not bring 
along new transport activity, but rather induces redistribution of operations between the modes. All policy options 
are expected to have a small positive impact on GDP (Table 6). The changes are expected mostly due to positive 
effects on logistics organisers, terminal activity and engagement of more companies in one transport operation. 
PO-A is estimated to have a very limited impact on GDP relative to the baseline (less than 0.1% increase in 2030 
and 2050) because of the limited support given and the low impact on intermodal volumes. The impact of PO-B1 
will be larger relative to the baseline (less than 0.1% increase in 2030 and 0.1% increase in 2050), but relatively low 
compared to PO-B2a, PO-B2b and PO-C (0.1% increase in 2030 and around 0.3% increase in 2050).  

Table 6: Increase in GDP compared to the baseline, EU-27, EUR bn (in 2021 prices)  
PO-B2a 

PO-B1 

PO-A 

PO-B2b 

PO-C 

GDP 

2030 

2050 

0 

2 

5 

25 

15 

68 

15 

57 

16 

67 

Source: Ricardo et al. support study (2023) 

105 As explained in Annex 4, the TRUST model was used as part of the modelling framework for this impact assessment. 
The TRUST model is a European transport network model simulating road, rail, inland waterways and maritime transport 
activity. TRUST covers the whole EU and its neighbouring countries and it allows for the assignment of passenger and 
freight origin-destination (OD) matrices at NUTS3 level (about 1,600 zones) on the multimodal transport network. As 
explained in Annex 4, the model also reflects the intermodal transport chains. 
106 The preferred policy option estimates a 4% increase in rail capacity by 2050, relative to the baseline. 

33 

 
 
  
 
6.1.2.  Impact on national public administrations 

Adjustment costs for public authorities. Adjustment costs derive from different obligations on data gathering, 
analysis and strategic planning under PM4-PM6, where the strongest impact is expected in PO-C mandating new 
harmonised analysis and strategic planning for freight transport system in Member States (PM5). The recurrent 
adjustment costs in PO-C are estimated at EUR 1.6 million every 5 years from 2025 onwards, while the one-off 
costs at EUR 1.1 million for setting up the data gathering system. In PO-A, where the data gathering, analysis and 
strategic planning for sustainable freight transport remains voluntary (PM4), the recurrent costs are estimated at 
EUR 0.3 million every 5 years from 2025 onwards, while the one-off costs for setting up additional data gathering 
systems are EUR 0.2 million. In PO-B, there are no additional costs relative to the baseline for national public 
authorities. The costs for the European Commission (due to PM6) are discussed in section 6.1.3. Expressed as 
present value over 2025-2050, the total adjustment costs for national public authorities are estimated at EUR 1.4 
million in PO-A (of which EUR 0.2 million one-off costs) and at EUR 7.8 million in PO-C (of which EUR 1.1 million 
one-off costs)107. 

Economic costs (costs of support) for public authorities. By far the biggest impact on national administrations 
compared to the baseline is the cost of economic support deriving from extended eligibility and support measures 
under PM7-PM12 (see Table 7). The differences in these costs depend mostly on eligibility criteria which define 
how many operations would benefit from support (volume supported), including the scope (all intra-EU operations 
versus only cross-border intra-EU operations), as well as on the choice of type of support in each policy option. 

Table 7: Impacts on recurrent costs and costs savings for public authorities compared to the baseline, EU-27 (million 
EUR, in 2021 prices)  
Applicable policy measures 

Difference to the baseline 

PO-A 

PO-B1 

PO-B2a 

PO-B2b 

PO-C 

2030 
2030 
Adjustment costs for data gathering, analysis and strategic planning 

2030 

2050 

2050 

2050 

2030 

2050 

2030 

2050 

1.6 

1.6 

1,665.3 

2,394.1 

0.3 

0.3 

0.0 

0.0 

PM4 
PM5 

Economic costs – cost of support 

PM7* 
PM8 
PM9* 
PM10 
PM11 

Administrative costs savings 

246.7  352.2  262.0  437.9  200.3  269.0 
0.0 
112.0 
13.1 
5.1 

0.0  112.0 
5.1 

0.0  112.0 
5.1 

13.1 

13.1 

PM3 
Total costs 
Total costs savings 
Net costs 
Source: Ricardo et al. support study (2023), * The costs of support for PM7 and PM9 reflect the synergies with PM10-
PM13 on the intermodal volume eligible for support. 

0.0 
0.0 
0.0 
0.2 
2,395.7 
0.3  363.8  365.4  379.1  451.1  317.4  282.1 
0.0 
0.0 
0.2 
0.0 
0.3  363.5  365.4  378.8  451.1  317.2  282.1  1,666.6  2,395.7 

0.2 
1,666.9 
0.2 

0.2 
0.3 
0.2 
0.1 

0.0 

0.0 

0.2 

0.2 

0.0 

0.2 

0.2 

0.0 

In PO-A the support is voluntary (PM8) and thus Member States are expected to continue with their current 
support schemes, resulting in no additional operational support relative to the baseline, even if eligibility is 
theoretically increased (due to PM1). In PO-B1, the additional cost of operational support due to PM9 is estimated 
at EUR 246.7 million in 2030 and EUR 352.2 million in 2050 relative to the baseline. In PO-B2a, where eligibility is 
defined through saving 40% of wider set of externalities (PM2-all-intra-EU) for all intra-EU operations and the type 
of support provided is the same as in PO-B1 (PM9), the cost of operational support is projected to be EUR 262 
million in 2030 and EUR 437.9 million in 2050. In PO-B2b, the cost of operational support is projected at EUR 200.3 
million in 2030 and EUR 269 million in 2050, lower than in PO-B2a, due to the fact that PO-B2b only covers cross-
border intra-EU operations (PM2-cross-border). The cost of harmonised mandatory operational support in PO-C 

107 More detailed explanations of costs by policy measure are provided in Annex 4. 

34 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
due to PM7 (in combination with eligibility defined under PM2-all-intra-EU) is estimated to be considerably higher 
as no upper distance limit is applied on operations eligible for operational support (PM12). This is estimated at EUR 
1.7 bn in 2030 and EUR 2.4 bn in 2050 relative to the baseline (see Table 7).  

The economic cost of PM10 (start-up support) and PM11 (technological upgrade support) apply only in PO-B1, PO-
B2a and PO-B2b. They are estimated at EUR 112 million for PM10 and EUR 5.1 million for PM11 in 2030 relative to 
the baseline. In 2050, no start-up support applies anymore, while the technological upgrade support amounts to 
EUR 13.1 million (see Table 7).  

It needs to be clarified that the cost of operational support due to PM7/PM9 is affected by support provided under 
PM10 (start-up support) and PM11 (technological upgrade support) in PO-B, and by regulatory support under 
PM13 (exemptions from driving bans) in both PO-B and PO-C, each of which results in additional intermodal traffic 
relative to the baseline and thereby increases the volume of operations eligible for operational support108.  

At the same time, in PO-A and PO-B, PM12 limits the obligation to provide operational support only to those 
operations that are not financially self-sustained, thereby reducing the budgetary burden. The estimates for the 
cost of support provided above and in Table 7 already reflect all synergies between the support measures included 
in each option. More detailed explanations are provided in Annex 4.  

The total additional economic support by national public authorities relative to the baseline is estimated to be the 
highest in PO-C (EUR 1.7 billion in 2030 and EUR 2.4 billion in 2050), followed by PO-B2a (EUR 379.1 million in 2030 
and EUR 451.1 million in 2050), PO-B1 (EUR 363.8 million in 2030 and EUR 365.4 million in 2050), and PO-B2b (EUR 
317.4 million in 2030 and EUR 282.1 million in 2050). In PO-A, where support remains voluntary, no additional 
costs are expected. Expressed as present value over 2025-2050, the additional economic support is estimated at 
EUR 34.8 bn in PO-C, EUR 7.5 bn in PO-B2a, EUR 7.2 bn in PO-B1 and EUR 5.3 bn in PO-B2b relative to the baseline. 
The difference between PO-B1 and PO-B2 sub-options derives from different eligibility criteria.  

The estimated economic costs (cost of support) for public authorities in 2030 and 2050, by policy option 
and Member State compared to the baseline, are provided in Table 8 and Table 9 below. The tables provide 
both the cost of support in million EUR and as percent of GDP, relative to the baseline. The estimated 
economic costs (cost of support) for public authorities in 2030 and 2050, by policy measure and Member 
State compared to the baseline are provided in Annex 4. It should be noted however that due to the nature 
of the CTD, where the support provided also depends on the applications for support by transport operators, 
the  outcome  by  Member  State  may  turn  out  to  be  different  than  estimated  in  this  impact  assessment. 
However, the estimates below provide an indication of the order of magnitude of the cost of support.   

It should be noted that for 2030, the cost of support is estimated to be up to 0.03% of GDP for Member 
States in PO-B1 and PO-B2a and up to 0.05% of GDP for Member States in PO-C (see Table 8). For 2050, 
the cost of support is estimated at up to 0.02% of GDP for Member States in PO-B1 and PO-B2a and up to 
0.08% of GDP for PO-C (see Table 9). The higher cost of support, expressed as percent of GDP relative to 
the baseline, estimated for the Eastern European Member States can be explained by: the absence of support 
schemes under the current CTD in most of these countries; the higher effectiveness in terms of modal shift 
of support schemes in these countries, which depends on the relative costs of road and rail transport109; and, 
the comparatively lower GDP levels.   

108 It is however important to point out that while the economic support measures PM7-PM9 are complementary to PM10 
and PM11, they do not result in “double” support for an operation as the beneficiaries of these support measures are 
different (See Annex 4 on stakeholders). Support under PM10 and PM11 aims at enabling the operations and increasing 
their efficiency. When the support under PM10 and PM11 reduces the total cost of operation, the support given under 
PM7-PM9 will also reduce as the support is relative to the cost of operation. 
109 This is because of the lower road transport costs in these countries.  

35 

 
 
Table 8: Estimated economic costs (cost of support) for public authorities in 2030, by policy option and Member State, 
compared to the baseline (million EUR, in 2021 prices, and percent of GDP)  
Economic support (EUR million) 

Economic support as percent of GDP 

PO-A 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 

PO-B1 
7.4 
13.7 
4.4 
8.2 
0.0 
42.8 
16.2 
0.7 
29.7 
5.8 
9.2 
41.1 
15.8 
6.6 
0.0 
34.2 
2.8 
3.5 
0.1 
0.0 
52.2 
22.4 
6.1 
7.1 
10.2 
15.6 
7.9 
363.8 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 
FR 
HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU-27 

PO-B2a 
7.8 
14.5 
4.7 
8.4 
0.0 
45.4 
16.5 
0.8 
30.8 
6.2 
9.7 
42.7 
16.0 
7.0 
0.0 
35.5 
2.9 
3.7 
0.1 
0.0 
54.6 
23.0 
6.5 
7.6 
10.8 
15.8 
8.0 
379.1 

PO-B2-b 
4.8 
13.8 
3.8 
7.2 
0.0 
32.9 
15.7 
0.4 
28.6 
5.3 
8.2 
35.9 
14.9 
2.9 
0.0 
33.3 
1.5 
0.7 
0.1 
0.0 
53.5 
19.2 
6.4 
2.1 
4.0 
14.8 
7.3 
317.4 

PO-C 
36.9 
100.4 
31.4 
11.0 
0.0 
247.7 
30.7 
4.4 
130.7 
47.2 
66.1 
177.3 
25.7 
33.1 
0.2 
149.1 
16.1 
17.7 
0.4 
0.0 
293.3 
64.9 
46.8 
39.2 
62.7 
22.6 
9.6 
1665.3 

PO-A 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

PO-B1 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.00% 
0.00% 
0.00% 
0.01% 
0.01% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.01% 
0.00% 

PO-B2a 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.00% 
0.00% 
0.00% 
0.01% 
0.01% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.01% 
0.00% 

PO-B2-b 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.02% 
0.01% 
0.00% 

PO-C 
0.01% 
0.02% 
0.05% 
0.00% 
0.00% 
0.01% 
0.01% 
0.01% 
0.01% 
0.02% 
0.02% 
0.01% 
0.05% 
0.02% 
0.00% 
0.01% 
0.04% 
0.03% 
0.00% 
0.00% 
0.03% 
0.01% 
0.02% 
0.01% 
0.01% 
0.04% 
0.01% 
0.01% 

Source: Ricardo et al. support study (2023) 

Economic support as percent of GDP 

Table 9: Estimated economic costs (cost of support) for public authorities in 2050, by policy option and Member State, 
compared to the baseline (million EUR, in 2021 prices, and percent of GDP)  
Economic support (EUR million) 
PO-B1 
14.0 
18.3 
4.9 
5.4 
0.0 
65.8 
7.0 
1.3 
26.8 
7.5 
11.1 
41.4 
4.1 
10.6 
0.1 
30.5 

PO-B2-b 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

PO-B2-b 
7.4 
17.2 
4.4 
3.4 
0.0 
51.5 
7.0 
0.7 
21.8 
7.4 
9.2 
33.7 
3.1 
5.0 
0.0 
25.4 

PO-B2a 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 

PO-B2a 
17.1 
22.8 
6.3 
6.6 
0.0 
82.5 
8.5 
1.6 
32.6 
9.1 
13.6 
50.6 
5.0 
12.9 
0.1 
37.4 

PO-B1 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 

PO-A 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

PO-C 
0.01% 
0.02% 
0.05% 
0.01% 
0.00% 
0.01% 
0.01% 
0.01% 
0.01% 
0.02% 
0.02% 
0.01% 
0.04% 
0.02% 
0.00% 
0.01% 

PO-C 
69.5 
136.4 
38.4 
27.0 
0.0 
387.1 
51.5 
7.1 
200.0 
63.1 
80.2 
259.1 
26.5 
53.1 
0.3 
208.0 

PO-A 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 
FR 
HR 
HU 
IE 
IT 

36 

 
  
  
PO-A 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 

LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU-27 

Economic support (EUR million) 
PO-B1 
6.9 
5.1 
0.2 
0.0 
42.8 
18.5 
8.0 
10.4 
16.6 
4.9 
3.1 
365.4 

PO-B2-b 
2.2 
1.3 
0.2 
0.0 
46.1 
11.3 
8.3 
3.6 
6.5 
3.3 
2.2 
282.1 

PO-B2a 
8.4 
6.1 
0.2 
0.0 
53.9 
22.7 
9.7 
13.3 
20.1 
6.0 
3.8 
451.1 

Economic support as percent of GDP 

PO-C 
38.0 
25.6 
1.0 
0.0 
345.3 
115.9 
62.5 
57.8 
97.7 
27.4 
15.6 
2394.1 

PO-A 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

PO-B1 
0.02% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 

PO-B2a 
0.02% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 

PO-B2-b 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

PO-C 
0.08% 
0.04% 
0.00% 
0.00% 
0.03% 
0.01% 
0.02% 
0.01% 
0.01% 
0.03% 
0.01% 
0.01% 

Source: Ricardo et al. support study (2023) 

Administrative costs for public authorities. Administrative cost savings are estimated for public authorities 
deriving from the mandatory use of eFTI platforms with clear and relevant data requirements (PM3), thanks to 
which eligibility checks at road-side will become 10% quicker. Considering that intermodal pre- and post-haulage 
(i.e. road legs of intermodal transport) represents nearly 10% of road transport operations in EU-27, the 
administrative cost savings for authorities are estimated at EUR 0.2 million per year from 2025 onwards. The 
savings are the same for all policy options. It should be noted that costs savings are assumed to occur only until 
2035 as post-2035 eFTI and the digitalisation of transport information is expected to be widely in use in the 
baseline. Expressed as present value over 2025-2050, the administrative costs savings are estimated at EUR 2.3 
million relative to the baseline in all policy options. 

Net costs/costs savings for public administrations. Expressed as present value over 2025-2050, PO-A is expected 
to lead to total costs savings for public administrations estimated at EUR 0.9 million110, while PO-B and PO-C result 
in net costs. The highest net costs are projected in PO-C (EUR 34.8 bn), followed by PO-B2a (EUR 7.5 bn), PO-B1 
(EUR 7.2 bn) and PO-B2b (EUR 5.3 bn). The largest share of the costs originates from economic support to 
intermodal transport. 

6.1.3.  Impact on the European Commission  

Two measures are expected to lead to adjustment costs for the European Commission, namely PM6 (included in 
PO-B) and PM17 (included in all policy options). For PM6, the costs are estimated at EUR 0.3 million every five 
years to prepare the market monitoring report under PO-B (EUR 1.7 million expressed as present value over the 
period 2025-2050 relative to the baseline). In relation to the preparation of the implementing acts under PM17 in 
PO-A, PO-B and PO-C, as additional research is needed to establish the relevant criteria for terminal categories, 
one-off costs of EUR 0.3 million are foreseen for a study. More details on the costs are provided in Annex 4. Total 
adjustment costs for the European Commission, expressed as present value over 2025-2050 relative to the 
baseline, are estimated at EUR 2 million in PO-B and EUR 0.3 million in PO-A and PO-C (of which EUR 0.3 million 
one-off costs in PO-A, PO-B and PO-C). No other costs are projected for the European Commission. 

6.1.4.  Impact on businesses  

The shippers and transport organisations that choose to benefit of this proposal will face adjustment costs and 
administrative costs but they will also benefit of administrative costs savings compared to the baseline. Detailed 
explanations on costs and costs savings for businesses, by policy measure, are provided in Annex 4. In addition, the 
shippers will have a wider choice of transport options and benefit of easier entry to the market, in particular thanks 

110 In PO-A the recurrent adjustment costs due to PM4 are occurring every 5 years, while the administrative costs savings 
driven by PM3 every year for 2025-2035. Expressed as present value over 2025-2050 the total adjustment costs are lower 
than the total administrative costs savings, thus resulting in net costs savings. The calculation also takes into account the 
one-off adjustment costs due to PM4. 

37 

 
  
 
to the new terminal transparency obligation. The freight forwarders and logistics operators and connection 
organisers engaged in organising intermodal transport operations as well as transport operators in rail and 
waterborne transport and terminal operators are expected to experience an increase in business opportunities, as 
intermodal volumes increase. 

Adjustment costs (one-off) for businesses. The total adjustment costs relative to the baseline are estimated to be 
highest in PO-C (EUR 28.3 million) mostly due to the one-off costs for revising the internal information and data 
sharing protocols by businesses under PM15 and establishing a common harmonised data set for communication 
under PM14, followed by PO-A and PO-B (EUR 0.3 million). No data related requirements are envisaged in PO-A 
and PO-B as these are left to other future EU instruments to ensure wider application.  

One-off adjustment costs will occur for the eFTI platform providers (EUR 0.05 million, in all policy options) and for 
the terminal operators (EUR 0.21 million, in all policy options), who will be required to provide information on their 
services and facilities on their homepages (PM16) and assess and show their category (PM17). The recurrent costs 
for PO-A, PO-B and PO-C linked to transparency requirements and the need for regularly updating data (due to 
PM16) are reported under administrative costs below.  

Table 10: Impacts on one-off adjustment costs for businesses compared to the baseline, EU-27 (million EUR, in 2021 
prices)  
Applicable policy measures 

PO-A 

Difference to the baseline 
PO-B2a 

PO-B2b 

PO-B1 

PM3  
PM14 
PM15 
PM16 
PM17 
Total one-off adjustment costs 
Source: Ricardo et al. support study (2023) 

0.05 

0.05 

0.05 

0.05 

0.18 
0.03 
0.26 

0.18 
0.03 
0.26 

0.18 
0.03 
0.26 

0.18 
0.03 
0.26 

PO-C 

0.05 
5.60 
22.41 
0.18 
0.03 
28.28 

Administrative  costs  for  businesses.  Three  measures  are  expected  to  lead  to  administrative  costs  for 
businesses, namely PM16 (in all policy options) due to the transparency requirements and the need for 
regularly updating data, and PM10, PM11 and PM16 (in PO-B) for the application process and the need to 
compy  with  the  potential  ex-post  reporting  by  those  operators  who  choose  to  benefit  from  economic 
support. The administrative costs for the application process and ex-post reporting (PM10 and PM11) are 
estimated at EUR 0.38 million in PO-B1 and PO-B2a in 2030 and at EUR 0.22 million in PO-B2b. For 
2050, the are estimated at EUR 0.39 million in PO-B1, EUR 0.42 million in PO-B2a and EUR 0.19 million 
in PO-B2b (where the scope includes only cross-border intra-EU operations), relative to the baseline (see 
Table 11). They are however not counted towards the ‘one in, one out’ approach. 

As explained above, the transparency requirements and the need for regularly updating data under PM16 
also lead to administrative costs for businesses in PO-A, PO-B and PO-C. It is not possible to assess with 
precision how often terminals upgrade their services and facilities, but the efforts are expected to be limited, 
amounting to not more than 1 hour of work every 5 years for gathering the information and updating the 
homepage. To estimate the costs, the number of intermodal terminals in the EU (980) and the tariffs per 
hour for ISCO 3 (Technicians and associate professionals) have been used (31.1 EUR/hour). The recurrent 
administrative  costs  are  thus  estimated  at  EUR  0.03  million  (every  5  years).  For  the  purpose  of  the 
application of the ‘one in, one out’ approach, the annual average cost per terminal, spreading the 5-years 
costs annually, is estimated at 6.2 EUR. Considering the 980 intermodal terminals in the EU, the average 
annual costs are estimated at EUR 6,100. 

Total administrative costs for businesses are estimated to be highest in PO-B2a relative to the baseline (EUR 
0.41 million in 2030 and EUR 0.46 million in 2050), followed by PO-B1 (EUR 0.41 million in 2030 and 
EUR 0.42 million in 2050), PO-B2b (EUR 0.25 million in 2030 and EUR 0.22 million in 2050), and PO-
A and PO-C (EUR 0.03 million in 2030 and 2050). Expressed as present value over 2025-2050, they are 

38 

 
  
  
  
  
  
  
  
  
estimated at EUR 6.6 million in PO-B2a, EUR 6.4 million in PO-B1, EUR 3.2 million in PO-B2b and EUR 
0.1 million in PO-A and PO-C. 

Administrative  costs  savings  for  businesses.  Businesses  will  also  incur  recurrent  administrative  cost 
savings due to PM3 (proof of eligibility), PM6 (reporting by the Commission) and PM7-PM9 (support 
measures). In PM3 (included in all policy options) the proof of eligibility is implemented via the eFTI 
platforms, and operators engaged in intermodal transport will benefit from not having to manage paper-
based transport documents, in particular for road-side checks. In addition, the operators will benefit from 
updated data requirements that allow to check the eligibility faster at road-side checks. The costs savings 
due to the use of electronic data and appropriate data requirements are estimated to be on average 5 EUR 
per shipment111. In order to derive the total administrative costs savings for businesses, the unit cost savings 
are multiplied by the number of intermodal operations carried out under the different policy options. It must 
be noted that costs savings are assumed to occur until 2035 as post-2035 eFTI platforms are expected to be 
widely in use among EU operators; so there will be little case for PM3 to induce costs savings compared to 
the baseline. The costs savings by policy option in 2030, relative to the baseline, are provided in Table 11. 
Expressed as present value over 2025-2050, the administrative costs savings due to PM3 are estimated at 
EUR 3.35 bn in PO-A, EUR 4.08 bn in PO-B1, EUR 4.12 bn in PO-B2a, EUR 3.16 bn in PO-B2b and 
EUR 5.31 bn in PO-C. For the purpose of the application of the ‘one in, one out’ approach, the average 
number of eligible operations per year during the 2025-2035 period is estimated at 0.071 bn in PO-A, 0.086 
bn in PO-B1, 0.087 bn in PO-B2a, 0.067 bn in PO-B2b and 0.112 bn in PO-C. Applying the unit costs 
savings of 5 EUR per shipment, the administrative costs savings per year for the ‘one in, one out’ are 
estimated at EUR 0.35 bn in PO-A, EUR 0.43 bn in PO-B1 and PO-B2a, EUR 0.33 bn in PO-B2b and EUR 
0.56 bn in PO-C.   

PM7-PM9 are expected to lead to administrative costs saving for businesses. Operators who decide to apply 
for economic support will be subject to administrative costs related to the preparation of the application. 
These costs are only relevant to new applicants relative to baseline. However, the application process for 
the support under PM7-PM9 will be considerably simplified relative to the baseline thanks to clear eligibility 
rules (PM1/PM2) and the use of eFTI platforms (PM3) that will simplify the retrieval and submission of 
information to authorities for those operators that choose to apply for economic support – it will be possible 
to  download  the  information  about  eligibile  operations  directly  from  the  eFTI  platform.  Furthermore, 
ensuring the same eligibility conditions across EU will allow the organisers of international operations to 
considerably save time and cost from application preparation as an eligible operation will be eligible across 
EU the same way112. The administrative costs savings for businesses due to PM7-PM9 in 2030 and 2050, 
relative  to  the  baseline,  are  shown  in  Table  11.  Expressed  as  present  value  over  2025-2050,  they  are 
estimated at EUR 220.1 million in PO-A (due to PM8), EUR 196.4 million in PO-B1 (due to PM9), EUR 
192.6 million in PO-B2a (due to PM9), EUR 260.6 million in PO-B2b (due to PM9) and to EUR 172.2 
million in PO-C (due to PM7).  

Businesses are also expected to enjoy administrative costs savings under PM6 (included in PO-B1, PO-B2a 
and PO-B2b) thanks to the Commission centrally publishing the information on upcoming support schemes 
and thus saving operators time to monitor Member States plans in the application process. These savings 
come in addition to the costs savings for the preparation of the applications under PM7-PM9, and depend 
on    the  number  of  applications  for  support  in  PO-B1,  PO-B2a  and  PO-B2b.  Table  11  provides  the 
administrative costs savings in 2030 and 2050 for PO-B1, PO-B2a and PO-B2b relative to the baseline. 
Expressed as present value over 2025-2050, they are estimated at EUR 23.1 million in PO-B1, EUR 23.9 
million in PO-B2a and EUR 10.3 million in PO-B2b relative to baseline. Measure PM6, PM7-PM9 are not 
counted towards the ‘one in, one out’ approach. 

111 SWD (2017) 194 final. 
112 In the baseline scenario the application preparation is assumed to take 16 hours. All applicants are assumed to save 
4.2 hours per request. The Eurostat Labour Force Survey data for Non-Wage Labour Costs (i.e. ISCO 3 – Technicians 
and associate professionals) has been used (31.1 EUR/hour) to quantify the costs.   

39 

 
 
Total administrative costs savings for businesses are estimated to be highest in PO-C relative to the baseline 
(EUR 567.9 million in 2030 and EUR 7 million in 2050), followed by PO-B2a (EUR 444.3 million in 2030 
and EUR 10.2 million in 2050), PO-B1 (EUR 443.8 million in 2030 and EUR 10.7 million in 2050), PO-
A (EUR 367.7 million in 2030 and EUR 10.9 million in 2050) and PO-B2b (EUR 347.9 million in 2030 
and EUR 13.9 million in 2050). Expressed as present value over 2025-2050, they are estimated at EUR 
3.57  bn  in  PO-A,  EUR  4.30  bn  in  PO-B1,  EUR  4.34  bn  in  PO-B2a,  EUR 3.43 bn  in  PO-B2b  and 
EUR 5.48 bn in PO-C. 

Table 11: Impacts on recurrent costs and costs savings for businesses compared to the baseline, EU-27 (million EUR, in 
2021 prices)  

Applicable policy measures  

Administrative costs  

PM10  
PM11 
PM16 

Administrative costs savings 

PM3  
PM6  
PM7  
PM8  
PM9  
Total costs 
Total costs savings 
Net costs savings 
Source: Ricardo et al. support study (2023) 

Difference to the baseline 
PO-B2a 
2030  2050  2030  2050  2030  2050  2030  2050  2030  2050 

PO-B2b 

PO-B1 

PO-A 

PO-C 

0.10  0.00 
0.28  0.39 
0.03  0.03 

0.10  0.00 
0.27  0.42 
0.03  0.03 

0.10  0.00 
0.11  0.19 
0.03  0.03 

0.03  0.03 

0.03  0.03 

355.3 

0.0  431.3 
1.1 

0.0  431.7 
1.1 
1.6 

0.0  332.7 
0.5 
1.7 

0.0  557.3 
0.8 

0.0 

10.5 

7.0 

12.4  10.9 

0.03  0.03 

11.4 
9.2 
0.41  0.42 

11.5 
8.5 
0.41  0.46 

14.7  13.2 
0.25  0.22 

367.7  10.9  443.8  10.7  444.3  10.2  347.9  13.9  567.9 
9.7  347.6  13.7  567.8 
367.6  10.8  443.3  10.3  443.9 

0.03  0.03 
7.0 
7.0 

Net costs savings for businesses. All policy options are expected to result in net costs savings for businesses (see 
Table 11). Expressed as present value over 2025-2050, the net costs savings are estimated to be the highest in PO-
C (EUR 5.46 bn) relative to the baseline, followed by PO-B2a (EUR 4.33 bn), PO-B1 (EUR 4.30 bn), PO-A (EUR 3.57 
bn) and PO-B2b (EUR 3.43 bn). 

6.1.5.  Impact on SMEs 

Intermodal transport by definition involves many different economic agents. While many operators in rail 
transport and maritime shipping are medium and some even large companies, operators in road transport, inland 
waterways and many intermodal organisers are often SMEs. In the road transport sector, in particular, 99% are 
SMEs (enterprises employing up to 250 people and with a turnover of less than EUR 50 million113,114). Among 
logistics operators, freight forwarders and terminal operators, the EU has some of the world’s largest operators, 
but also many SMEs. Finally, there are many SMEs among all companies that need their freight to be transported. 
Therefore, the initiative is considered relevant for the SMEs and the SME test has been performed (see Annex 13). 

An increase in intermodal transport will have a positive economic impact on all these SMEs. As regards road 
hauliers, for those engaged today in long-distance road transport that would be replaced by intermodal transport, 
a change in type of business is expected. An intermodal transport operation usually involves two different road 
transport operators carrying out the road legs at each end of the operation. While the total number of kilometres 
driven will reduce - as is the objective of the CTD - the price per kilometre of short distance road legs is higher than 
of long-distance operations and thus profitability per kilometre is higher. As road hauliers are price setters and not 
price takers in intermodal operations, a switch from long-haul operations to intermodal road legs is not expected 
to impact their turnover. In intermodal road legs, the road carriage price is mostly quoted per time or per 

113SWD(2017) 194 final, https://eur-lex.europa.eu/resource.html?uri=cellar:9d5c61bf-4629-11e7-aea8-
01aa75ed71a1.0001.02/DOC_1&format=PDF   
114 https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_1B_SE_R2__custom_3493320/default/table  

40 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
operation, because a considerable amount of waiting time is involved both at loading and unloading and in 
terminals for the drivers. In addition, there are less empty truck operations, which otherwise occur due to inability 
to fill empty trucks on the long-distance return. 

As explained in section 6.1.4, all policy options are expected to result in net costs savings for businesses, estimated 
at EUR 5.46 bn in PO-C, followed by PO-B2a with net costs savings estimated at EUR 4.33 bn, PO-B1 with net costs 
savings of EUR 4.30 bn, PO-A with net costs savings estimated at EUR 3.57 bn, and PO-B2b with net costs savings 
estimated at EUR 3.43 bn, expressed as present value relative to the baseline. Considering the large share of SMEs 
estimated to operate in the intermodal transport sector, a significant share of these net costs savings is 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).    

6.1.6.  Digital by default  

All policy options will have a positive impact on the application of the ‘digital by default’ principle, introduced by 
the common measure on proof of eligibility (PM3) that applies to all policy options. The carriers who wish to 
benefit from the special regime will be obliged to use a certified eFTI platform for recording their transport data 
prior to an operation taking place. The eFTI platforms will include a dedicated option for intermodal transport that 
will pull the data from existing modal transport data sets with the transport organiser only needing to link the 
different legs. The platform will include a calculator, which on the basis of the information in transport contracts 
and some additional elements (such as type of the vehicle and fuel used) can calculate the savings in the external 
costs and will enable both the transport organiser as well as authorities carrying out road-side checks to 
immediately see if an operation is eligible or not. This will considerably simplify the collection and presentation of 
the data for the operators, eliminating the need for road hauliers to provide a large number of paper documents 
covering all intermodal operation legs. It will also simplify and make more robust the control process for the 
authorities, as eFTI platforms can include a simple but comprehensive confirmation interface for proof of eligibility, 
including the transport information about each leg and transhipment transaction. Data stored on a certified eFTI 
platform will be accessible to the authorities in all Member States the operation passes by, and can potentially be 
used for verification without stopping a vehicle115. Importantly, as explained in sections 6.1.2 and 6.1.4, the use of 
eFTI platforms will bring along significant administrative cost savings for public authorities, but in particular for 
businesses. Furthermore, the eFTI platforms can be used by shippers to collate the data on all eligible operations 
for the purposes of application for economic support. The eFTI platforms can provide an option to download a 
summary report of all eligible operations in a given timeframe with pre-defined additional information fields 
required by Member State giving the aid. They can also be used to gather aggregated data on operations chosen to 
benefit from the CTD on main transport lanes, volumes, distances, types of loading units used, for statistical and 
analytical purposes. 

6.1.7.  Impact on the functioning of the internal market and on competition 

Internal market. All policy options are expected to have a positive impact on the functioning of the internal 
market. The CTD does not regulate market access to intermodal transport as such. Access to different modal parts 
of intermodal transport is regulated in sectoral legislation. However, the regulatory provisions of the CTD ensure 
full liberalisation of eligible intermodal transport operations from quotas (Article 2), an extension of definition of 
own-account transport (Article 9) as well as the right to use non-resident hauliers for international operations in 
the same way as it is allowed for international road transport (Article 4).  

Furthermore, this initiative contributes to the creation of a more consistent framework to support intermodal. The 
proposed harmonised approach to eligibility for support (PM1 in PO-B1 and PM2 in other options) and 
enforcement via eFTI platforms in all options (PM3) will reduce the burden that the current Member State specific 
State aid schemes impose on transport organisers and shippers. Similarly, the proposed approach to the selection 
of economic support measures, where relevant in line with State aid rules (PM7-PM12), the common approach to 

115 Digital enforcement initiatives are currently under consideration. In the absence of EU legal framework, for now it 
depends on national legislation whether remote checks are permitted or not.  

41 

 
 
weekend/holiday driving bans (PM13) and data and transparency requirements on terminals (PM16-PM17) will 
improve the market functioning, lower the entry barriers to the use of intermodal transport and reduce the 
administrative burden. PO-C with mandatory harmonised support (PM7) and strongest intervention, including in 
addition to terminals’ transparency also full data cooperation (PM14, PM15) has the strongest impact on the 
functioning of the internal market. PO-A with voluntary non-harmonised support (PM8) performs only slightly 
better than the baseline, due to better defined eligibility (PM2). The PO-B sub-options differ in terms of their 
scope. PO-B1 and PO-B2a, which cover all intra-EU intermodal operations (PM2-all-intra-EU) perform better from 
the internal market perspective, given that a common regime for both domestic and international operations 
would reduce complexity and administrative burdens to the companies which handle both domestic and 
international operations (81% of intermodal operations are international). In PO-B2b only cross border operations 
are included (PM2-cross-border), which can lead to higher fragmentation, where Member States decide to apply 
different or no support regime for the domestic operations.  

Competition. Article 93 of TFEU states that State aid shall be compatible with the Treaty if it meets the needs of 
coordination of transport. The concept has been clarified by the Commission in the State aid Railway guidelines116. 
The disparities between the different modes of transport as regards negative externalities ought to be corrected 
by public support for those modes of transport which give rise to the lowest external costs117.The measures 
proposed in this revision can thus be seen as contributing to the needs of coordination of transport in line with 
Article 93 TFEU as interpreted by the Commission, if the eligibility is based on saving of the externalities as in PO-A, 
PO-B2a, PO-B2b and PO-C. In case of PO-B1 and eligibility based on GHG savings, the compatibility with State aid 
rules would have to be separately assessed by the Commission.  

Having an EU-level harmonised definition of eligible operations and a common objective as regards the cost 
reduction to final users resulting from the Member State’s support, reduces the risk of distortion to competition 
and improves the functioning of the internal market, as shippers and/or intermodal operators from all Member 
States would benefit from support based on same principles. PO-B sub-options do not prescribe harmonised rules 
for the design of the aid measures, which are left to the discretion of Member States, nor do they prescribe 
harmonised rules for eligible costs, beneficiaries or aid intensities, which are conditions assessed under the State 
aid rules to ensure the compatibility of the aid with the internal market. To that purpose, the close coordination of 
the current revision of the CTD and the ongoing revision of the State aid Railway guidelines is necessary and key to 
ensure the consistency of the Commission’s transport and competition policies118. Thus, competition and market 
integration aspects as well as the risk of overcompensation are safeguarded by adherence to the State aid rules.  

In case of PO-C, the support would be fully harmonised with no discretion left to Member States. Such support 
would not create market distortions and not constitute State aid as it would not be imputable to the Member 
State.  

6.1.8.  Regional distribution of impacts 

High road transport volumes affect central and peripheral regions differently and thus the relative benefit of modal 
shift is more important in central regions where transit traffic volumes are high. These regions have already 
relatively high intermodal transport volumes as compared to peripheral volumes as well as national support 

116 Community guidelines on State aid for railway undertakings, Communication from the Commission 2008/C 184/07, 
GU C 184 del 22.7.2008, p. 13–31. 
117 A review of the Commission’s case practice in the field of aid for the coordination of transport is available in the 
Commission’s Fitness check of the 2012 State aid modernisation package, railways guidelines and short-term export 
credit insurance (SWD(2020) 257 final), annex 6 Section V (p. 33) and annex 8, Section VII, p. 132 ff. 
118 The new Council Regulation, proposed in the context of the revision of the State aid Railway Guidelines, will enable 
the  Commission  to  declare  certain  categories  of  State  aid  to  greener  modes  of  transport compatible  with  the  internal 
market. These include certain types of aid in favour of rail, inland waterway and multimodal transport. In particular, aid 
supporting  the  coordination  of  transport,  i.e.  aid  provided  not  to  a  transport  operator,  but  to  a  shipper  or  transport 
organiser, has a very limited potential of distorting competition. Following the adoption of the proposed Regulation by 
the Council, the Commission intends to adopt a Block Exemption Regulation relieving Member States from the obligation 
of prior notification to the Commission of aid measures falling within these categories. 

42 

 
 
programs in place to motivate uptake of intermodal transport. However due to high transport volumes in general, 
the potential for modal shift remains high also in these regions. On the other hand, many peripheral regions today 
have very low levels of intermodal transport, both because low terminal density as well as no support to 
intermodal transport. Establishing any support schemes can have a considerable effect, in particular after the 
terminal capacity increase once the revised TEN-T Regulation takes effect. The highest positive effect is expected in 
PO-B2a, where the increase in the intermodal volumes relative to the baseline is the highest (see Table 5), followed 
by PO-B1, PO-B2b, PO-C, and PO-A. PO-B2b, which excludes domestic operations from the scope has lower 
impacts, given that some Member States may decide not to support these operations. It should be noted that 
under any option, Member States can go beyond the legal minimum established in the CTD and use different 
support measures to tackle their regional circumstances, subject to the adherence to the State aid rules, where 
relevant. 

6.1.9.  Impact on energy consumption 

All policy options are expected to lead to a decrease in energy consumption in the transport sector relative to the 
baseline due to the higher uptake of intermodal transport, which is more energy efficient than road-only transport 
as explained in section 2.1.2. PO-A is expected to bring along only a small increase in intermodal traffic and thus 
limited energy savings relative to the baseline. Cumulatively over 2025-2050 they are estimated at 86 kilo tonnes 
of oil equivalent (ktoe). The cumulative energy savings over 2025-2050 are estimated to be the highest in PO-B1 
(10.9 million tonnes of oil equivalent (Mtoe)), followed by PO-B2a (10.5 Mtoe), PO-B2b (7.3 Mtoe) and PO-C (3.7 
Mtoe). All policy options contribute towards SDG 11 (Make cities and human settlements inclusive, safe, resilient 
and sustainable). 

Table 12: Energy savings compared to the baseline in 2030, 2050, and cumulatively over 2025-2050, EU-27, (in ktoe) 

Energy consumption  2030 

2050 

2025-2050 

Source: Ricardo et al. support study (2023) 

6.2. 

Social impact 

PO-A 

PO-B1 

PO-B2a 

PO-B2b 

PO-C 

3 

3 

86 

416 

177 

401 

174 

10,883 

10,472 

242 

82 

7,311 

154 

19 

3,719 

This section assesses the impacts of the policy options on road safety and congestion, on employment and 
fundamental rights.  

6.2.1.  Impact on road safety and on congestion 

Road safety remains one of the priorities of the EU with clear goals for the reduction of road deaths and 
serious injuries by 2030 and 2050, to which the Road Safety Package recently proposed by the Commission 
would also contribute. On top of that, all policy options are projected to have postive impacts on road safety, 
leading to lives saved and injuries avoided due to the traffic shifted away from road-only transport. In PO-
A, the shifted traffic is very small and thus the decrease in the external costs of accidents (fatalities and 
injuries) is limited, i.e. EUR 102 million relative to the baseline, expressed as present value over 2025-2050 
(see Table 13). The impact is the highest in PO-B2a (EUR 1.7 bn external costs savings), followed by PO-
B1 (EUR 1.5 bn), PO-B2a (EUR 1.2 bn) and PO-C (EUR 0.5 bn). Similarly, the effect on congestion119 
depends on the type of intermodal transport used, the location of terminals and the volumes shifted away 
from  road-only transport  under  a  given option.  Intermodal  transport  non-road legs take place  normally 
between urban nodes, while road legs deliver the goods to and from the shipper and recipient. The situation 
is  somewhat  different when the  goods  are transported to  a port  (IWW  or SSS), that  allows to  entirely 
eliminate the road leg on one end of the intermodal transport and thus helping to reduce congestion more. 
The highest reduction in external costs of congestion is estimated for PO-B2a (EUR 7.6 bn), expressed as 

119 Congestion costs refer to road transport, covering both road-only transport and the road legs of intermodal transport 
operations. 

43 

 
 
 
present value over 2025-2050 relative to the baseline, followed by PO-B1 (EUR 7.2 bn), PO-B2b (EUR 5.5 
bn), PO-C (EUR 2.8 bn) and PO-A (EUR 0.4 bn)120.  

Table 13: Reduction in external costs of accidents (fatalities and injuries) and congestion in 2030, 2050 and present 
value over 2025-2050 relative to the baseline, EU-27 (million EUR, in 2021 prices)  

Accidents 

Congestion 

2030 

2050 

2025-2050 

2030 

2050 

2025-2050 

PO-A 

PO-B1 

PO-B2a 

PO-B2b 

PO-C 

5 

3 

102 

19 

14 

427 

73 

44 

1,547 

316 

215 

7,208 

76 

45 

1,663 

338 

226 

7,623 

57 

33 

1,214 

242 

163 

5,481 

25 

18 

530 

130 

88 

2,820 

Source: Ricardo et al. support study (2023) 

6.2.2.  Impact on employment 

All policy options are expected to lead to a small increase in the economy-wide level of employment relative 
to  the  baseline  by  2050121.  This  is  because  the  shift  to  intermodal  transport  solutions  involves  several 
transport modes, transhipment and terminal services that will generate more employment.  In 2030, the 
largest increase in the number of jobs created is expected in PO-B2a (24 thousand), followed by PO-C (19 
thousand), PO-B2b (15 thousand), PO-B1 (12 thousand). PO-A shows no significant impact relative to the 
baseline in 2030. In 2050, similarly to 2030, the largest increase in the number of jobs created is expected 
in PO-B2a (83 thousand), followed by PO-C (81 thousand), PO-B2b (69 thousand), PO-B1 (28 thousand) 
and PO-A (1 thousand). The main driver of the larger impact in PO-B2a, PO-B2b and PO-C is measure 
PM2 on establishing the eligibility of operations that achieve savings of 40% of externalities compared to 
road-only options, combined with the different combinations of measures introducing economic support to 
eligible intermodal solutions (i.e. PM7-PM10). The impact of PO-B2b is somewhat lower than that of PO-
B2a and PO-C due to the lower scope, covering only cross-border intra-EU operations.  

Table 14: Increase in economy-wide employment compared to the baseline, EU-27 (in thousand persons) 

PO-A 

PO-B1 

PO-B2a 

PO-B2b 

PO-C 

Employment 

2030 

2050 

0 

1 

12 

28 

24 

83 

15 

69 

19 

81 

Source: Ricardo et al. support study (2023) 

It  is  also  important  to  consider  the  impact  of  the  policy  options  on  each  transport  sector  individually. 
Although the results suggest that the potential job losses in the road transport are offset by increases in 
employment in the non-road transport sectors, the extent of the losses/gains in each sector is hard to estimate. 
The skills required for jobs in the different transport modes vary and therefore it is unlikely that there will 
be a direct job transfer between sectors. However, with re-training, mid-term adjustment should be possible. 
Given that one intermodal transport operation requires combination of short-haul road with long-haul non-
road operations, as well as transhipment and terminal services, it is clear that such a shift away from long-
distance  road  operations  will  create  more  “local”  higher  quality  jobs.  Therefore,  some  road  transport 
companies are expected to change the markets they serve, at least in the short-term.  On the other hand, the 
commercial road transport sector faces an increasing demand and a significant shortage of drivers (400,000 
for freight)122. The shift to intermodal solutions may alleviate to some extent the pressure on the shortage 
of drivers.  

120 It should be noted that the modelling results of the policy options account for the external costs associated to all freight 
transport operations and are not limited to intermodal transport. 
121 This is in line with the results from the 2017 impact assessment, which also pointed to the link between modal shift 
and the creation of jobs in the intermodal sector. 
122 IRU driver shortage report 2022. 

44 

 
 
 
 
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 for the assessment of the fundamental rights is the Charter of 
Fundamental Rights of the European Union123. All four 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 impacts  

Reduction of  external  costs  of transport through modal  shift.  The  reduction  of negative  environmental 
impacts is part of the general objective of the CTD and the saved external costs constitute part of the benefits 
of this revision. All POs are expected to have a positive impact on environment (see Table 15). The scale 
of environmental impacts depends on the volume of road-only transport replaced with intermodal non-road 
legs. The bigger this modal shift, the bigger the positive environmental impact. The policy options result in 
a replacement of 0.2 to 26 bn tkm road freight transport with non-road transport in 2030 and of 0.5 to 39.7 
bn tkm in 2050. The environmental impact depends however not only on the total volume replaced, but also 
on the mode that replaces the road part. This is the case of PO-B1 where most operations are shifted to rail, 
relative to PO-B2a where more operations are shifted to waterborne transport. On the other hand, as the 
overall shift towards intermodal transport operations is slightly higher in PO-B2a relative to PO-B1, the 
external costs savings are higher in PO-B2a relative to PO-B1.  

The  highest  reduction  in  environmental  external  costs  is  projected  in  PO-B2a  (EUR  4.60  bn  for  CO2 
emissions, EUR 0.47 bn for air pollution emissions and EUR 0.91 bn for noise), expressed as present value 
over 2025-2050 relative to the baseline, followed by PO-B1 (EUR 4.40 bn for CO2 emissions, EUR 0.45 
bn for air pollution emissions and EUR 0.85 bn for noise), PO-B2b (EUR 2.93 bn for CO2 emissions, EUR 
0.34 bn for air pollution emissions and EUR 0.69 bn for noise) and PO-C (EUR 2.67 bn for CO2 emissions, 
EUR 0.16 bn for air pollution emissions and EUR 0.46 bn for noise). PO-A shows significantly lower 
reductions in external costs. With regard to air pollution, PO-B and PO-C would lead to a marginal increase 
in external costs relative to the baseline in 2050. This however is not linked to the energy/fuel use but can 
be explained by increased particulate matter emissions from rail transport due to higher wear and tear124 as 
a consequence of increased rail activity, which outweighs the decrease in particulate matter emissions from 
road  transport125.  Expressed  as  present  value  over  2025-2050,  all  policy  options  result  however  in  a 
reduction of external costs of air pollution emissions. The assessment also takes into account the projected 
shifts between non-road modes; these however are not significant. 

Table 15: Changes in environmental external costs in 2030, 2050 and present value over 2025-2050 compared to the 
baseline, EU-27 (million EUR, in 2021 prices) 

PO-A 

PO-B1 

PO-B2a 

PO-B2b 

PO-C 

Climate change (GHG) 

Air pollution 

Noise 

2030 

2050 

2025-2050 

2030 

2050 

2025-2050 

2030 

2050 

-6 

-14 

-147 

-8 

-3 

-53 

-0.2 

-0.4 

-162 

-40 

-171 

-51 

-4,395 

-4,603 

-53 

18 

-448 

-37 

-24 

-60 

21 

-470 

-39 

-27 

-118 

-16 

-2,930 

-41 

23 

-337 

-36 

-22 

-98 

-11 

-2,665 

-31 

17 

-164 

-17 

-17 

123 OJ C 326 of 26.10.2012 p.2. 
124 Emissions from wear and tear for rail are currently not part of EMEP/EEA Guidebook, which does not consider non-
exhaust emissions of rail transport as a separate category. However, they are included here for sake of completeness. 
125 It should be noted that in the baseline scenario the particulate matter emissions are projected to reduce by 90% in 2050 
relative to 2015, driven by the uptake of zero-emission vehicles. For this reason, in 2050 the increase in particulate matter 
emissions from rail transport due to higher wear and tear outweighs the reduction in particulate matter from road transport, 
leading to higher particulate matter emissions relative to the baseline.    

45 

 
 
 
PO-A 

PO-B1 

PO-B2a 

PO-B2b 

PO-C 

2025-2050 

-7 

-846 

-905 

-694 

-455 

Source: Ricardo et al. support study (2023) 

All policy options are consistent with the environmental objectives of the European Green Deal and the European 
Climate Law126. All policy options contribute towards SDG 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. 

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 are met. Table 16 provides the assessment criteria for this. A detailed assessment of effectiveness is 
presented in Annex 12. 

Table 16:  Link between objectives and assessment criteria 

Objectives 

General objective 

Facilitate an increase in the share of rail, SSS and 
IWW in total intra-EU freight transport, to reduce 
negative externalities and energy consumption of 
transport as well as mitigate the fragmentation of 
the internal market 

Specific objectives 

Assessment criteria 

•  Impact on the volume of intermodal transport in the EU 
•  Reduction in external costs of transport (including CO2 
emissions, air pollutant emissions, noise, fatalities and 
injuries, and road congestion) 

SO1: Provide support to a wider range of 
operations under effective and common eligibility 
conditions 

SO2: Ensure better support by improving 
reporting on intermodal transport market  

•  Impact on the share of intermodal operations eligible for 

support 

•  Suitability and clarity of proof of eligibility conditions 

•  Impact on the availability of information and analysis of 

intermodal market  

SO3: Increase competitiveness of intermodal 
transport to contribute to reducing negative 
externalities 

•  Distance at which intermodal transport is price-

competitive with road-only transport 
•  Support is appropriate and effective 

SO4: Improve transparency and cooperation and 
simplify entry to the market 

•  Ease of data exchange between parties in intermodal 

transport chain  

•  Ease of access to terminal information 

Each of the options addresses the problems, their drivers and the general and specific objectives. Concerning SO1, 
all five options provide support to wider range of operations than the today’s CTD and achieve an almost identical 
increase in the share of operations eligible as well as suitable, common and clear eligibility conditions. However, 
PO-B1, where eligibility is based on GHG only ignores the benefits of non-road modes in terms of other 
externalities beyond the GHG emissions, resulting in some SSS operations and all IWW operations as of 2035 not 
being eligible. This is compensated by higher eligibility for rail but these additional rail operations that are eligible in 
PO-B1 (compared to PO-A, PO-B2a, PO-B2b and PO-C) can have very short rail legs (27% of total operation). 
Support to such operations is not desirable. Therefore, although producing similar net benefits as PO-B2a (see next 
section), PO-B1 is considered less effective, since in medium to long term, it results in over-reliance on rail-road 
intermodal operations, even with long road legs.  PO-A, PO-B2a, PO-B2b and PO-C ensure that all modal 
combinations are eligible throughout the period and that the non-road leg is always longer than the combined 
road legs in an operation.  

126 Regulation (EU) 2021/1119. 

46 

 
 
 
 
 
Concerning SO2, PO-A is somewhat more effective than the baseline as some additional Member States may start 
carrying out regular analysis and strategic planning for intermodal transport. PO-C aims to ensure that Member 
States were aware of the market development and the impacts of their support schemes, but in absence of EU 
level statistics, data availability difficulties persist, and EU level consolidation of the results would be challenging. 
PO-B retains centralised analysis (by the Commission) and foresees that the Commission will conduct a dedicated 
study every 5 years to prepare a regular report, making also use of information retrieved from eFTI platforms. PO-B 
sub-options also improve access to information on upcoming support schemes, making it much more effective 
relative to the baseline.  

SO3, PO-A is only somewhat more effective than the baseline in making intermodal operations more competitive, 
as support remains voluntary. PO-C does not reflect well the heterogeneous market situation and problems on the 
ground, where a harmonised solution may not deliver the best possible outcome in all Member States. PO-B’s sub-
options deliver comparable outcomes on price competitiveness to shippers; the effect is elevated thanks to 
additional start-up support that ensures better availability of connections/non-road services. Among the three, PO-
B2a is most effective, given its broader scope (if compared to PO-B2b) and the externalities-based eligibility (if 
compared to PO-B1). If measured by the amount of externalities saved, most effective in terms of SO3 is PO-B2a, 
followed by PO-B1, PO-B2b, PO-C and PO-A. 

Concerning SO4, no measures are foreseen for data rules in PO-A and PO-B on the assumption that horizontal 
legislation for all freight transport operations would be more effective than regulating data only for eligible 
intermodal operations. The impact on PO-C on data rules is positive, but low. As regards access to terminal 
information, all options ensure availability of terminal information and possibility for further transparency 
measures through implementing acts.  

With regard to the general objective of increasing the share of rail, SSS and IWW, PO-A is slightly more effective 
than the baseline, and only delivers very limited additional volumes, while PO-B2a and PO-B1 are much more 
effective than PO-B2b and PO-C (see Figure 12). Higher replacement volume of road-only transport with 
intermodal transport results in higher positive impacts from reducing the negative externalities of transport. The 
difference between PO-B1 and PO-B2a in terms of additional intermodal volumes is limited (1,388 bn tkm in PO-B1 
and 1,391 bn tkm in PO-B2a, cumulative for 2025-2050 relative to the baseline), but they differ in terms of which 
modal combinations deliver the uptake.  

Figure 12: Effect of new support measures on additional uptake of intermodal transport, bn tkm, 2025-2050 

Source: Ricardo et al. support study (2023)  

47 

 
 
7.2.  Efficiency 

Efficiency concerns "the extent to which objectives can be achieved for a given level of resource/at least cost". The 
costs and benefits are summarised in Table 17. 

Table 17:  Summary of costs and benefits per policy option (including one-off and recurrent costs) - present value for 
2025-2050 compared to the baseline (in million EUR) 

Baseline 

PO-A 

Difference to the Baseline 
PO-B2a 

PO-B1 

PO-B2b 

PO-C 

2.0 

0.3 

2.0 

0.3 

2.0 

1.4 
0.0 
2.3 

7.8 
34,825.2 
2.3 

0.0 
5,294.3 
2.3 

0.0 
7,476.3 
2.3 

0.0 
7,223.3 
2.3 

2.1 
24,941.6 
0.0 

National authorities 
Adjustment costs  
Economic cost of support 
Administrative costs savings 
European Commission 
Adjustment costs  
Businesses 
Adjustment costs 
Administrative costs  
Administrative costs savings 
Benefits (reduction in external costs relative to the baseline) 
External costs of GHG emissions 
External costs of air pollution emissions 
External costs of noise 
External costs of accidents 
External costs of congestion 
Total costs 
Total benefits 
Net benefits/costs 
Benefits to cost ratio 
Source: Ricardo et al. support study (2023); Note: for ‘net benefits/costs’ a positive sign stands for net benefits and a 
negative sign for net costs.  

4,394.6 
448.1 
846.0 
1,546.7 
7,207.5 
7,232.0 
18,748.3 
11,516.3 
2.59 

4,603.0 
470.3 
904.7 
1,663.4 
7,622.8 
7,485.2 
19,602.5 
12,117.3 
2.62 

2,929.7 
337.3 
694.4 
1,214.0 
5,481.1 
5,299.8 
14,087.9 
8,788.1 
2.66 

146.7 
53.3 
6.6 
101.8 
427.4 
2.1 
4,311.6 
4,309.5 
2065 

2,665.5 
163.8 
455.3 
530.1 
2,820.5 
34,861.7 
12,117.1 
-22,744.6 
0.35 

608,508 
218,819 
39,568 
98,081 
752,002 

0.3 
6.4 
4,303.1 

0.3 
0.1 
3,573.7 

0.3 
6.6 
4,336.0 

0.3 
3.2 
3,429.1 

0.0 
312.0 
0.0 

28.3 
0.1 
5,479.5 

0.3 

By far the biggest cost element of the policy options is the support by Member States authorities, which 
depends on eligibility conditions and foreseen support measures in a given option. Limited adjustment costs 
are expected for the eFTI providers and terminal operators for implementing the data and transparency rules 
and for Member States for regular analysis and strategic planning for intermodal transport.  

PO-A  shows  the  lowest  additional  costs  (EUR  2.1  million),  but  also  delivers  the  lowest  benefits 
(EUR 4.3 bn), expressed as present value over 2025-2050 relative to the baseline. The benefits are mainly 
due to the administrative costs savings from using the eFTI platforms on existing operations as well as due 
to the external cost savings thanks to the extension of the scope. However, the impact on modal shift is very 
small, as is the resulting small reduction of externalities. PO-C, on the other hand, shows the highest costs 
(EUR 34.9 bn), due to very high operational support (no upper distance limit for economic support) that is 
not offset by total benefits (EUR 12.1 bn). PO-B1 and PO-B2a have comparable cost and benefit levels. 
PO-B1 is estimated to result in total costs of EUR 7.2 bn and total benefits of EUR 18.8 bn, while PO-B2a 
is projected to result in total costs of EUR 7.5 bn and total benefits of EUR 19.6 bn. PO-B2b shows both 
lower total costs (EUR 5.3 bn) and lower total benefits (EUR 14.1 bn) than PO-B1 and PO-B2a, because it 
covers only cross-border intra-EU operations. While this limits the economic cost of support for Member 
States, it also limits the benefits in terms of external costs saved.  

The highest net benefits relative to the baseline are estimated for PO-B2a (EUR 12.1 bn), followed by PO-
B1 (EUR 11.5 bn), PO-B2b (EUR 8.8 bn) and PO-A (EUR 4.3 bn). PO-C results in net costs estimated at 
EUR 22.7 bn. PO-A shows the highest benefits to cost ratio (2065), followed by PO-B2b (2.66), PO-B2a 
(2.62), PO-B1 (2.59) and PO-C, with higher costs than benefits (0.35). 

48 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
7.3.  Coherence  

Internal coherence assesses how various elements of the revised CTD function together to achieve the objectives. 
Although all five POs address the identified problems, the level and intensity vary. PO-A is designed to leave the 
maximum flexibility to Member States as the problems are heterogeneous depending on their starting point 
(baseline) of already existing support frameworks. As a result, PO-A has the lowest intensity of EU-level 
intervention as regards strategic planning and support and no data requirements. The minimal EU-level 
intervention means that intermodal policy will remain almost entirely in the hands of Member States and thus the 
coherence with the general policy objective to facilitate at EU level the uptake of intermodal transport is low. PO-C 
brings along the overall highest EU-level intervention and full harmonisation both as regards strategic planning as 
well as support and detailed and specific data requirements. The high-level intervention ensures a homogenous 
approach to EU market and facilitates the functioning of the internal market. However, it fails to count for the 
differences in regions, markets and segments. PO-B follows a medium level flexible intervention whereby it sets 
minimum goal based common requirements applicable across the EU with central overview of developments, 
taking into account the heterogeneous market situations. Thus, PO-B shows higher internal coherence than PO-C. 
The only difference between the PO-B sub options PO-B1, PO-B2a and PO-B2b is eligibility. PO-B2b is slightly more 
coherent given that its eligibility (based on all external costs and covering all intra-EU operations) combined with 
the support measures supports best the general objective.  

External coherence concentrates on the compliance of the initiative with national policies, other EU instruments 
and relevant EU policies, as well as international obligations. The CTD in general and consequently all identified 
policy options have strong links to several other existing and planned EU instruments as discussed in section 1.3 
(Synergies with other EU policy instruments). The support provided under the CTD is meant to be complementary 
to other national and EU regulatory instruments, both horizontal and per transport mode and to work hand in 
hand with State aid rules. While other instruments provide a legal framework for different transport modes to 
operate in (modal regulation such as the envisaged initiative on measures to better manage and coordinate 
international rail traffic, Weights and Dimensions Directive), set requirements for physical and digital infrastructure 
(TEN-T Regulation, eFTI Regulation) or promote reduction of externalities (Eurovignette Directive, the upcoming 
CEEU Regulation), the role of CTD is to compensate for the remaining inefficiencies and market failures that hold 
back the operators from choosing more sustainable freight transport solutions. PO-A and PO-B1, where eligibility is 
based on GHG alone, are not however coherent with current State aid practice and rail legislation where a wider 
scope of externalities savings is required. Therefore, support measures under these options would either require 
changes in current practices or dedicated State aid assessment. When the external costs are fully internalised, 
CTD’s support may not be necessary or even desirable anymore. In this respect, all policy options are coherent 
with other EU laws. 

7.4. 

Subsidiarity and proportionality 

Negative externalities are trans-boundary problems produced by international transport, which cannot be solved 
by national or local action alone. Even domestic road operations create the negative externalities that are global in 
nature such as GHG emissions and congestion127. The objective of the revision cannot be sufficiently achieved at 
Member State level also because intermodal operations are mostly cross-border (81%). Comparing the policy 
options, PO-A leaves the highest level of flexibility on intervention to Member States. However, the impacts of this 
option are very close to the baseline, thus it is not effective in meeting the objectives of this initiative.  PO-C, at 
another extreme, leaves least choice to national and local levels with full EU-level harmonisation, without allowing 
for any subsidiarity in terms of tailoring the approach and budget planning. PO-B ensures a balance between EU 
level policy goals and subsidiarity, by allowing flexibility to address Member State specific or regional problems, 
while ensuring a common level of ambition on achievable benefits.  

127 Congestion is often considered to be local in nature, directly affects all road users, including those engaged in international 
freight transport. It also tends to propagate and produce spill-over effects affecting more than one Member State in cross-border 
areas. 

49 

 
 
Two further elements of policy options require attention from the subsidiarity perspective. First, all policy options, 
except PO-B2b propose to include in the scope of the revised CTD all intra-EU intermodal operations, rather than 
only cross-border operations as in the current CTD. However, the division into domestic and international is not 
effective in achieving the policy objective of reducing transport externalities and also problematic from the internal 
market perspective. It is difficult to explain why the same operation would be supported if done in cross-border 
context and not supported if done in national context. Including all operations in the scope ensures equal 
regulatory and economic treatment of all intermodal transport operations, be it domestic or cross-border, leading 
also to higher environmental benefits. Expanding the framework also improves the effectiveness of the initiative in 
terms of the uptake of non-road freight transport and its contribution to reducing the external costs and energy 
needs, while limiting the scope only to international operations would cut the number of operations that overall 
could help in achieving the EU Green Deal and SSMS milestones. From the internal market perspective, it needs to 
be added that national support provided today is heterogeneous and 18 out 20 of respondents128 to the 
stakeholders’ survey considered different measures in different Member States as a problem. PO-B2b, which 
excludes domestic operations from the scope of the CTD, would at least partly keep the same situation, which 
increases the complexity for operators and creates frictions in the internal market. For national authorities it could 
be challenging to justify the existence of different support regimes for cross-border and for domestic operations or 
to refuse to domestic operations the support they grant to cross-border operations. For this reason, the gain of 
subsidiarity under BO-B2b, where domestic operations are excluded from the scope of the CTD, is limited.  

Bringing all operations into the scope of the CTD would not allow to completely eliminate this fragmentation (given 
that Member States can always go further than the minimum requirements in the CTD, subject to compliance with 
State aid rules) but can significantly reduce it. Having a common minimum support regime will also avoid the risk 
of under-compensation of domestic operations129. The inclusion of domestic intermodal operations in the scope of 
the Directive was also strongly supported by the stakeholders. The majority of survey respondents (22 out of 27) 
and interviewees (17 out of 22) supported the extension of the scope of the CTD to cover all intermodal transport 
that saves certain negative externalities.  

Second, PM 13 proposes to exempt road-legs of eligible operations from weekend and holiday driving bans, 
including for domestic transport. Driving bans on roads during weekends and holidays, which today exist at least in 
13 Member States, aim to reduce congestion, and improve safety on roads during those periods, where the roads 
are used more for private travel. However, if applied to intermodal transport road legs, both in case of cross-
border or domestic intermodal operations, they create considerable problems for logistics chain, given that road 
legs cannot be carried out directly before or after the non-road leg. This results in terminal yard congestion, large 
traffic jams just before and after the driving ban times around terminals and inability to efficiently fill the rail, IWW 
or SSS vehicle/vessel during such driving bans.  EU level intervention to national rules in this regard is justified, 
given that impacts of national bans reach across the borders, impacting the functioning of the internal market and 
affecting the capacity usage on the TEN-T network. Removing driving bans for road vehicles carrying intermodal 
units and being part of an intermodal solution (which constitute only 10% of road freight traffic) would allow to 
exploit unused capacity during the period of driving ban for running more services130. This would allow better use 
of rail and terminal infrastructure capacity. Recognising this fact, most Member States having bans, already apply 
exemptions for intermodal transport road-legs131. However, these exemptions are very heterogeneous, not 
following the definition established in the CTD and some are discriminatory. It should be noted that bans have a 
similar effect to logistics chain and the use of infrastructure, be they applied to the road legs of cross-border or 
domestic intermodal operations. Furthermore, as mentioned above, national authorities could find it difficult to 
justify bans to domestic operations, while cross-border operations can run. Therefore, excluding domestic 
operations from PM13 due to subsidiarity concerns, would add complexity and administrative burdens, while in 

128 13 out of 14 industry stakeholders and 5/6 authorities. 
129 Today, several Member States do not provide any support. 
130 For example, an intermodal rail service running five times per week can benefit from the driving ban exemption to 
add an additional run during the weekend. 
131 Five Member States do not have any exemptions for intermodal road legs from driving bans. 

50 

 
 
practice making little difference in the volume of traffic on the roads132.Therefore, sub-options of PO-B and option 
PO-C, which include PM 13, would ensure uniform and equal application of what is already practice in several 
Member States. The impact of PM13 over 2025-2050 is estimated at 0.4% increase in the intermodal 
transport activity relative to the baseline.  

As regards proportionality, this proposal calls on Member States to implement economic and administrative 
support measures,bwhere relevant, in compliance with State aid rules) to certain types of transport operations. 
However, it is assessed that this support is proportional to achieve the policy objective. While none of the policy 
options entirely eliminates the competitiveness gap between intermodal and road-only transport, PO-B1 and PO-
B2a ensure sufficient modal shift at reasonable cost (each 49 cents of support under PO-B2a generates 1 EUR 
worth of reduction in external costs). PO-B2a has a similar benefit-cost ratio than PO-B2b, however it should be 
noted that it is missing out on opportunities, leaving domestic operations with equivalent environmental benefits 
without a support and thus resulting in 38% lower outcome on the benefits side.  

Legally, while some stakeholders were voicing preference for a Regulation, the choice of the instrument (revision 
of the Directive) is adequate as it allows satisfactory achievement of the objectives while also ensuring adherence 
to the subsidiarity principle. 

Table 18 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 '+' (somewhat more effective/efficient/coherent/proportionate than the baseline) to '++++' (much 
more effective/efficient/coherent/proportionate than the baseline); from '-' (somewhat less effective/ 
efficient/coherent/proportionate than the baseline) to '----' (much less effective/efficient/coherent/ proportionate 
than the baseline). 

Table  18:    Comparison  of  options  in  terms  of  effectiveness,  efficiency,  coherence,  subsidiarity  and  proportionality 
relative to the baseline 
Criteria 

PO-B2b 

PO-B2a 

PO-B1 

PO-C 

PO-A 

Effectiveness 
Efficiency 
Coherence 
Subsidiarity 
Proportionality 

+ 
++++ 
++ 
0 
+ 

8.  PREFERRED OPTION 

+++ 
++ 
+++ 
+/- 
++ 

++++ 
++ 
++++ 
+/- 
++ 

+++ 
++ 
+++ 
+ 
+ 

+++ 
-- 
++++ 
-- 
+ 

8.1. 

Identification of the preferred policy option 

Each of the options addresses the problems identified, their drivers and the specific objectives, however some 
options are more effective in achieving the specific and general objectives. All PO-B sub-options and PO-C are 
considerably more effective than PO-A. PO-A is only somewhat more effective than the baseline in delivering the 
SO3 and SO4 and has weak effectiveness on SO1 and SO2 as well as on the general objective. PO-B1, PO-B2b and 
PO-C are less effective than PO-B2a, as the latter is more effective in delivering on SO1 by having better balance of 
different modal combinations (compared to PO-B1) and SO2 (compared to PO-B2b and PO-C).  

With respect to efficiency, PO-A and all PO-B sub-options result in net benefits relative to the baseline while PO-C 
results in net costs. While PO-A has by far the highest benefit-cost ratio, it brings along very little modal shift and its 
benefits are almost entirely limited to administrative cost savings for existing intermodal operations. PO-B1 and 
PO-B2a produce comparable total modal shift and have a similar benefit-cost ratio, but PO-B1 does not allow equal 
access to support for all modal combinations and would result in support to RR operations even if major part of 

132 No data is available to assess what is the volume of national operations in five Member States which today do not 
exempt the road legs of the intermodal transport from the weekend and holiday driving bans. But applying EU averages, 
the  share  of  road  legs  affected  could  be  around  2%  (assuming  that  10%  of  road  transport  is  related  to  road  legs  of 
intermodal operations and about 20% of those are national operations). 

51 

 
 
operation takes place on road. PO-B2b has a similar benefit-cost ratio to PO-B1 and PO-B2a but its impact on total 
modal shift and reduction in external costs is more limited because it only covers cross-border intra-EU operations. 
In comparison to PO-B1 and PO-B2a it has also less potential in reducing the frictions in the internal market, given 
that domestic operations are not covered. 

Concerning coherence, all policy options are coherent between their various elements and with relevant EU 
legislation. However, PO-A could be considered under-ambitious as regards the objectives set in the European 
Green Deal and SSMS, given that it does not deliver sufficient modal shift. PO-B sub-options and PO-C are broadly 
comparable in their coherence in this regard. PO-B1, where eligibility is based on GHG alone, is not coherent with 
current State aid practice which calculate eligible costs based on saved externalities. PO-B2b is slightly less 
coherent than PO-B2a given that it has narrower eligibility scope. In terms of subsidiarity, PO-A ensures high 
consistency with the subsidiarity principle by leaving the decision on support entirely to Member States, while PO-
C ranks low as it enforces harmonised support and budget expenditure. PO-B1 and PO-B2a ensure a balanced 
outcome by providing for a common framework to support equal treatment of all intermodal operations and 
reduces fragmentation of the internal market, while granting flexibility to Member States to design their support 
measures effectively according to the local situation. PO-B2b. leaving domestic operations out of scope, has a slight 
advantage with regards to the subsidiarity principle, which is however mitigated by a compromise between 
subsidiarity and effectiveness and by questions of practical consequences as explained section 7.4. Finally, as 
regards proportionality, PO-B will strike the best balance by achieving the objectives in a coherent and effective 
way, while leaving the necessary scope for national decision. This is particularly the case for PO-B2a which has the 
highest net benefits. The proportionality of PO-B2b is somewhat lower, given that its intervention level can be 
suboptimal, leaving some domestic operations, with equivalent environmental benefits, without support.  

Thus, the preferred policy option is PO-B2a. It delivers on the objective by ensuring the highest modal shift and 
external cost savings with a good benefit-cost ratio, while also ensuring coherence, proportionality and 
subsidiarity. The envisaged substantial public support is necessary to compensate competitiveness gap of the 
intermodal transport until the parallel instruments tackling externalities of transport, both at EU and national level, 
kick in. PO-B2a is also the most effective, efficient and coherent policy response to tackle specific externalities that 
are prominent in road transport, namely congestion, accidents and pollution and which are hard to abate with 
mode based measures. Given that the support measures are meant to be regularly assessed and adjusted in light 
of regulatory and market developments, PO-B2a represents a balanced approach to achieving a level playing field 
between transport modes, allowing to frontload to the extent possible the savings in transport externalities. The 
measures in the preferred option are broadly supported by stakeholders, in particular to have a more robust 
eligibility criteria, allowing to treat all modal combinations equally. For the savings’ threshold, stakeholders 
supported inclusion of a wider set of externalities, rather than only GHG; there was however no consensus on the 
level of the threshold. Stakeholders also supported the inclusion of domestic operations within the scope, 
maintaining existing regulatory measures (ban of quotas and allowing to use of non-resident hauliers for road legs 
for cross-border operations) and agreed that implementing some support measures should be mandatory for 
Member States. There was also strong support for better information availability on terminals. 

PO-B2a complies with the principle of “do no significant harm” and delivers overall positive environmental impact 
in compliance with the “digital by default” principle.  

8.2.  REFIT (simplification and improved efficiency) 

The amendment to the CTD was part of the REFIT initiatives in 2017. However, the current revision is 
considered a new initiative under the Commission Work Programme 2023 under the heading A European 
Green  Deal133,  as  it  takes  a  new  and  different  approach  to  eligibility  and  support.  The  new  eligibility 
conditions, combined with an eligibility “calculator” on an eFTI platform and with increased and targeted 
support is expected to considerably increase the efficiency of the CTD. The revision ensures considerable 
simplification of procedures also to existing operations thanks to the use of eFTI platforms (PM3) that allow 

133 COM(2022) 548 final. 

52 

 
 
to simplify the proof of eligibility for industry as well as control of eligibility for public authorities. The use 
of eFTI will also simplify the preparation of applications for support for the industry and allow to gather 
information about intermodal operations benefitting from this Directive.  

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

The preferred option (PO-B2a) is expected to deliver significant recurrent administrative cost savings for businesses 
operating in the intermodal sector. As explained in section 6.1.4, thanks to the proof of eligibility that is 
implemented via the eFTI platforms (PM3), operators engaged in intermodal transport will benefit from not having 
to manage paper-based transport documents, in particular for road-side checks. The recurrent costs savings for 
businesses due to the use of electronic data are estimated at EUR 0.43 bn per year134. At the same time, under the 
new transparency rules (PM16), terminals will incur administrative costs for updating the information required to 
be published on their website. The recurrent annual average cost per terminal during 2025-2035 is estimated at 
EUR 6.2. Considering the 980 intermodal terminals in the EU, the average annual costs are estimated at EUR 6,100. 
The administrative costs savings largely outweigh the costs and thus the net recurrent administrative cost savings 
for businesses under the ‘one in, one out’ approach are estimated at EUR 0.43 bn annually.  

In addition, as explained in section 6.1.4, the preferred policy option is expected to result in one-off adjustment 
costs for businesses estimated at EUR 0.3 million.  

8.4. 

Sensitivity analysis for the preferred policy option 

Sensitivity analysis has been performed for the preferred policy option (PO-B2a), assuming different eligibility 
thresholds for the external costs savings when using an intermodal operation instead of road-only. More 
specifically, two alternative eligibility thresholds have been assessed: 30% external costs savings (PO-B2a - Case 1) 
and 50% external costs savings (PO-B2a - Case 2). They are compared to PO-B2a (Central case), which includes an 
eligibility threshold of 40% external costs savings. All other measures included in PO-B2a (Case 1) and PO-B2a (Case 
2) are the same as in PO-B2a (Central case). 

As shown in section 3.1.1 of Annex 4 (Table 35), the breakeven distances increase with the eligibility threshold. This 
means that a lower number of intermodal operations get support, the higher the eligibility threshold. Thus, as 
illustrated in Table 19, PO-B2a (Case 1) results in higher increase in total intermodal transport volumes relative to 
PO-B2a (Central case) and PO-B2a (Case 2) in lower increase in total intermodal transport volumes relative to PO-
B2a (Central case). Cumulatively over 2025-2050, the total additional intermodal volumes for PO-B2a (Case 1) are 
estimated at 1,430 bn tkm, for PO-B2a (Central case) at 1,391 bn tkm and for PO-B2a (Case 2) at 1,244 bn tkm, 
relative to the baseline.       

Table 19: Modal shift (traffic volume of new non-road legs) and total intermodal transport (incl. road legs) that would 
be induced by PO-B2a (Case 1), PO-B2a (Central case) and PO-B2a (Case 2) and growth compared to the baseline in 
2030 and 2050 (bn tkm) 

2030 

2050 

2030 

2050 

Rail 

IWW 

SSS 

Rail 

IWW 

SSS 

Total  

intermodal 

% 
growth  

Total  

intermodal 

% 
growth 

17.1 

0.6 

11.6 

38.7 

0.8 

14.7 

38.2 

5.4% 

69.1 

6.8% 

16.6 

0.6 

11.5 

36.8 

0.8 

14.7 

37.7 

5.3% 

67.5 

6.6% 

PO-B2a – Case 1 (30% 
reduction in external costs) 

PO-B2a – Central case (40% 
reduction in external costs) 

PO-B2a – Case 2 (50% 
reduction in external costs) 
Source: Ricardo et al. support study (2023) 

14.7 

0.5 

11.5 

30.2 

0.7 

14.6 

35.0 

4.9% 

61.1 

6.0% 

134  To  calculate  the  costs  savings  for  the  application of the ‘one in, one out’ approach,  the  cost  saving  per  shipment  is 
estimated at 5 EUR while the number of shipments at 0.087 billion. 

53 

 
  
 
The higher shift to intermodal transport in  PO-B2a (Case 1) relative to PO-B2a (Central case) leads to 
higher total costs relative to the baseline due to larger economic cost of support, but also to higher benefits 
due to the external costs savings. The opposite is true for PO-B2a (Case 2), which results in lower total costs 
and benefits compared to the baseline relative to PO-B2a (Central case). The total costs, total benefits, and 
net benefits for PO-B2a (Case 1), PO-B2a (Central case) and PO-B2a (Case 2) are shown in Table 20. In 
terms of benefits to costs ratio, the three cases are similar to each other and also to PO-B1 and PO-B2b (as 
illustrated in section 7.2), showing that the ranking of the options in terms of efficiency would not change 
with lower or higher eligibility thresholds.       

Table 20:  Summary of costs and benefits for PO-B2a (Case 1), PO-B2a (Central case) and PO-B2a (Case 2) - present 
value for 2025-2050 compared to the baseline (in million EUR) 

Total costs 
Total benefits 
Net benefits 
Benefits to costs ratio 
Source: Ricardo et al. support study (2023) 

PO-B2a (Case 1) 

Difference to the Baseline 
PO-B2a (Central case) 

PO-B2a (Case 2) 

7,662.8 
19,786.5 
12,123.6 
2.58 

7,485.2 
19,602.5 
12,117.3 
2.62 

6,870.7 
18,038.1 
11,167.4 
2.63 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission will monitor the implementation and effectiveness of this initiative through several actions and a 
set of core indicators that will measure progress towards achieving the operational objectives. In particular, the 
Commission will carry out regular analyses of the intermodal transport market as per PM6 as well as gather 
information about Member States support schemes.  

Table 21 presents performance areas, corresponding operational objectives and possible indicators for an effective 
monitoring framework. 

Table 21: Performance areas, corresponding operational objectives and possible indicators for an effective monitoring 
framework 

Performance area 

Operational objectives 

Possible indicators 

Level of intermodal support 
and costs of access  

•  Extend the level of support to a 
wider range of intermodal 
transport operators 

•  Number of Member States adopting support 
measures (by type of measure -financial, 
operational, start-up, technological) 

•  Reduce administrative costs 
for accessing intermodal 
transport support  

•  Type and level of support provided in each 

Member State 

•  Number of (transport) operators that have 

applied/benefited from support measures (by 
type of measure)  

•  Total level of support (in EUR) provided by 

Member States (in terms of budget 
available/actual support) 

•  Administrative costs for access to intermodal 

support  

Impact on intermodal 
transport  

•  Increase volume/share of 

•  Share of intermodal transport in total freight 

intermodal freight transport 

transport, compared to the baseline 

•  Share of individual transport modes in freight 

transport, compared to the baseline 
•  Main barriers that hinder the uptake of 

intermodal transport 

54 

 
  
 
 
Performance area 

Operational objectives 

Possible indicators 

Relative cost 
competitiveness of 
intermodal transport  

•  Reduce relative costs of 

•  Average break-even distance per mode 

intermodal transport in relation 
to road-only freight transport 

combination (and change from the current 
situation) 

Availability of information 
on intermodal transport 
facilities  

•  Ensure access to relative 
information concerning 
intermodal transport 
services/facilities 

•  Availability, ease of access and completeness 

of information concerning intermodal 
transport services (qualitative) 

Access to information on 
intermodal transport 

•  Improve access to information 

•  Commission reporting on intermodal 

on intermodal transport 
activity/market 

transport activity  

•  Availability of information on intermodal 

transport activity (qualitative) 

A  dedicated  study  is  planned  under  PM6  to  support  monitoring  activities,  in  particular  as  regards  the 
mapping of intermodal market developments and main remaining barriers. eFTI platforms can be used to 
gather aggregated data on eligible operations and their specifics such as main transport lanes, volumes, 
distances, types of loading units used, support provided and externalities saved etc. In cooperation with 
Eurostat, all or part of this information can be made public more often than the reports foreseen in PM6. 
Furthermore, the notifications of upcoming support measures to the Commission for central publication 
allows the Commission also to gather up-to-date information about Member States support schemes. The 
mentioned dedicated study will also have to gather information about terminal information and quality.  

The initiative will be successful if, through the provision of the support measures, it brings about an increase 
in the number of intermodal freight transport operations and leads to a higher share of non-road modes in 
the total freight transport mix.  

Ultimately, a successful scenario is one in which all Member States adopt support measures within the scope of 
the CTD, that are, where relevant, facilitated by State aid rules tailored to support intermodal operations. These 
support measures are used by operators and lead to improved access to intermodal transport services/facilities, 
reduce relative costs and enhance the competitiveness of intermodal transport operations, and eventually 
increase the share of intermodal transport operations in the total freight. It will also provide enhanced information 
on available intermodal transport services to address information barriers in the decision process. Furthermore, it 
will ensure sufficient information on the intermodal transport market (at both EU and national level), to help 
Member States target support measures to make them more effective and efficient.  

55 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The lead DG is DG MOVE, Unit D1: Maritime transport and logistics 

DECIDE reference number: PLAN/2020/8707 

Item 8.c in Annex I to Commission Work Programme 2023  

2.  ORGANISATION AND TIMING 

The impact assessment follows the ex-post (REFIT) evaluation in 2016135, the proposal for revision of the 
CTD in 2017 that was subsequently withdrawn in 2020, and the European Green Deal and SSMS that 
envisaged the introduction of a more ambitious proposal. The impact assessment started in 2021, with the 
inception impact assessment published on 19 August 2021136.  

The impact assessment on a possible review of the CTD was coordinated by an Inter-Service Steering Group 
(ISSG). The Commission Services participating in the ISSG were: Secretariat-General, Legal Service, DG 
Climate Action, DG Competition, DG for Employment, Social Affairs and Inclusion, DG Industry, 
Entrepreneurship and SMEs, DG for Energy, DG for Research and Innovation, Eurostat, Joint Research 
Centre. The Inter-Service Steering Group met 6 times: on 30 June 2021, 29 September 2021, 10 March 
2022, 30. June 2022, 27 October 2022 and 29 March 2023. It was consulted throughout the different steps 
of the impact assessment process: notably on all stakeholder consultation materials and deliverables from 
the external contractor and on the draft Staff Working Document.  

3.  CONSULTATION OF THE RSB 

The draft report was submitted to the RSB on 12 April 2023 and was discussed by the Board on 10 May 
2023. RSB issued a negative opinion on 12 May 2023. Recommendations from the Board were addressed in 
a revised version of the Impact Assessment report, submitted to the board on 12 June, as detailed in the 
table below. 

Table 22-1: Modifications of the IA report in response to the first RSB opinion 

Detailed RSB comments 

Modifications to the IA report  

(1)  The report should clearly set out the overarching 
rationale for promoting combined transport. It 
should better explain why combined transport is 
important, which market failure it aims to correct 
and how it helps to deliver on key EU policies. 

While the overall purpose of this initiative seems 
to be to reduce various negative externalities from 
freight transport, this should be made more 
explicit upfront or clarified if this is not the case. 
The report should describe more clearly which 
policy instruments aim to tackle transport 
externalities and explain why these alone are not 
sufficient. It should explain better the role of 
combined transport in this and how its expected 

The revised IA explains from the outset in section 1.1 
Political context and 1.3 Synergies with other EU policy 
instruments that higher uptake of intermodal transport 
allows, to the extent it leads to the higher use of non-
road modes, reducing the external costs induced by 
freight transport at the system level.  

In section 1.3 it clarifies that the CTD complements 
other transport policies, which (a) reduce external costs 
by targeting the environmental performance of 
individual modes and (b) internalise external costs by 
gradually applying polluter pays and user pays 
principles. Progress is on its way but takes time to 
materialise. For now, shifting freight away from road 

135 SWD(2016) 140 final. 
136 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13010-Sustainable-transport-revision-of-
Combined-Transport-Directive_en 

56 

 
 
 
Detailed RSB comments 

Modifications to the IA report  

effects interact with those from the broader 
instruments addressing transport externalities 
(e.g. ETS transport, CO2 standards, energy 
taxation, road charging, etc.). 

It should identify the remaining gap that might be 
tackled best through combined transport (and 
fiscal incentives) while reflecting parallel measures 
aiming to increase terminal availability and 
performance. 

The report should consequently consider 
corresponding objectives and make the reduction 
of externalities and ensuring a level playing field 
across transport modes the guiding principle 
throughout the report. 

It should consider the magnitude and importance 
of reducing externalities and possible prioritising 
between them, as some external costs seem 
higher than others. The reduction of specific 
externalities could find its way into the 
intervention logic via the specific objectives. 

(2)  The report should better explain the subsidiarity 
dimension of the initiative. It should better justify 
why domestic intermodal operations need to be 
included in the scope of the Directive and why 
such decision is not presented as a policy choice. 

would provide significant environmental benefits. In this 
context, the main market failure the CTD addresses is 
that today intermodal transport on short and medium 
distances is still non-competitive with road-only 
transport. The IA report clarifies that part of this 
problem is related to inefficiencies of the performance 
of non-road modes is addressed by other policies. 
However, another part of the problem is uneven 
internalisation of external costs. The latter is tackled by 
the CTD, which aims to support certain intermodal 
operations by compensating for a cost-competitiveness 
gap which still exists.  

In the revised report, the general objective in section 
4.1 is adjusted as follows: 

Facilitate an increase in the share of rail, SSS and IWW 
transport in total intra-EU freight transport, to reduce 
negative externalities and energy consumption of 
transport as well as mitigate the fragmentation of 
internal market 

In section 4.2 the following is added to SO3:  

Increase the competitiveness of intermodal transport to 
contribute to reducing negative externalities. 

The externalities have made the starting point of the 
problem definition in section 2.1 and the problem has 
been adjusted as follows: 

Current uptake of intermodal transport is insufficient for 
effectively contributing to the reduction of external costs 
and energy consumption of transport. 

The section on impact assessment and cost benefit 
analysis are already built around the calculation of 
saved external costs.   

While reducing all externalities is important, the revised 
IA report clarifies that, while GHG and other emissions 
can be effectively tackled by sectoral legislation, the 
issues with road accidents and congestion, could be 
more effectively addressed by the higher uptake of non-
road modes.  

Additional arguments, including the scale of cross-
border operations, equal footing of all similar operation 
and internal market aspects, accompanied by 
stakeholder views, are included in section 7.4 in the 
subsidiarity and proportionality section of the 
comparison of options to better explain the subsidiarity 
dimension of the initiative.  

In addition, a new option PO-B2b, a sub-option of 
option PO-B, which includes in the scope only cross-
border operations, has been included, allowing to 
compare the impacts of policy option with and without 
domestic operations. 

57 

 
Detailed RSB comments 

Modifications to the IA report  

Regarding the measure to remove bans imposed 
by Member States on driving at night-time, 
holidays and weekends for the road legs of eligible 
combined transport, the report should 
demonstrate whether and how such measure 
would respect the subsidiarity and proportionality 
principles. It should also discuss why Member 
States should not be allowed to continue to 
impose such bans (including for purely domestic 
transport), if justified by public interest reasons. 

(3)  The construction of broad policy options appears 

arbitrary.  

The features of options should be presented 
clearer (e.g. in terms of voluntary or mandatory 
State aid and the possibility to add further 
subsidies than prescribed). 

The options should be more clearly linked to the 
specific objectives and the underlying problem 
drivers as clarified above. 

Given the broad scope of transport externalities to 
be tackled, the report should explain why it 
considers options that address only one 
externality. 

It should clarify whether alternative eligibility 
saving rates were considered, and if so, why these 
were not included as variants for the relevant 
support measures. More generally, the report 
should consider the implications of other 
combinations of policy measures. 

Regarding the exemptions to night-time, holidays and 
weekends driving bans (PM13), the analysis in section 
7.4 has been strengthened to highlight the cross-border 
spill-over effects of national driving bans and their 
negative impact on the use of rail infrastructure and 
terminal capacity. It also includes internal market 
aspects and a reference to stakeholder views. 

The  description  of  policy  measures  in  section  5  (Policy 
options) and Annex 6 (Retained measures) of the revised 
IA report has been rechecked and amended. 

Section  5.2.2  (The  description  of  options)  explains  the 
underlying principles of assigning the policy measures to 
different options, such as stakeholder views, intensity of 
intervention  and  ensuring  that  all  problem  drivers  and 
specific objectives are covered. 

In section 5.2.1 (Retained policy measures) it is explained 
that an option (PO-B1) defining eligibility based on GHG 
savings  only  has  been  retained  in  response  to  the 
stakeholders’ request. 

In section 5.2.1 (Retained policy measures) it is 
explained that for both types of the eligibility criteria, 
based on GHG alone (PM1) and based on a wider set of 
externalities (PM2), further analysis was carried out to 
establish the percentage threshold of external cost savings 
retained in the options. As explained in section 3.1.1 of 
Annex 4, various thresholds (from 20% to 75%) were tested. 
In addition, a sensitivity analysis is included in section 8.4, 
applying one higher and one lower eligibility threshold for 
the preferred policy option.  

Some further adjustments have been made in the POs: 

•  PO-A: PM1 (GHG based eligibility) has been 
replaced with PM2 (externalities-based 
eligibility), to allow for its fairer comparison 
with PO-B. PM14 (defined dataset) has been 
excluded while PM16 and PM17 (terminal 
transparency and label) have been included, to 
be better in line with the low intervention level 
of this option. 

•  PO-B: includes a new variant PO-B2b, which 
covers only cross-border (rather than all) 
intermodal operations, to better assess 
subsidiarity aspects. 

•  PO-C: includes PM14, which is more in line 
with the high intervention intensity of this 
option. 

58 

 
 
Detailed RSB comments 

Modifications to the IA report  

The report should further explain the modelling 
approach. It should better justify the assumption 
that the 10% reduction of door-to-door transport 
costs would lead to higher uptake of intermodal 
transport. 

It should provide evidence of the effectiveness of 
financial support measures on the uptake of 
intermodal transport and modal shift. 

It should better explain the analysis to establish 
what levels of financial support is required to have 
an impact on volumes and modal shift and what 
that increased support would mean in terms of 
budgetary implications for Member States. 

(4)  The report should present a more balanced 
comparison of options and better justify the 
choice of the preferred one. 

It should clearly demonstrate that the envisaged 
financial support/fiscal incentives are a more 
effective and efficient policy response than what 
could be achieved via the broader instruments 
tackling externalities of transport. 

It should discuss the risk of overcompensating 
intermodal transport because of the combination 
of various measure such as those contributing to 
the internalisation of external cost of road 
transport expected to be achieved by 2050. 

The  revised  IA  report  explains  better  the  underlying 
reasoning of the assumption that the 10% cost reduction 
would  allow  to  attract  more  shippers  and  transport 
organisers  to  use  intermodal  transport.  More  detailed 
explanations have been provided in section 6.1.1 (Impact 
on  competitiveness  of  intermodal  transport,  modal  shift 
and GDP), including a reference to section 3.3.1 of Annex 
4, which explains the approach in depth.  

Annex  14  of  the  revised  IA  includes  examples  of  the 
impact of existing Member State support schemes to the 
uptake  of  different  modal  combinations  of  intermodal 
transport, main findings of which are included in section 
6.1.1 (Impact on competitiveness of intermodal transport, 
modal shift and GDP). 

Section 6.1.2 (Impacts on national public administration) 
includes  the  estimated  cost  of  support  by  policy  option 
and Member State (also expressed as percent of GDP). In 
addition, the estimated costs of support by policy measure 
and Member State have been added to Annex 4.  

Section 7 on the comparison of options has been 
revised, including corrections to the scoring, and 
separation of subsidiarity and proportionality scores. 
The narrative justifying the choice of the preferred 
option, has been improved, considering also the 
additional analysis conducted in the revised IA report, to 
follow up the other Board recommendations. 

The revised IA report has explained in section 1.3 
Synergies with other EU policy instruments that 
economic support measures are necessary policy 
response as far as other broader instruments that 
reduce and internalise external costs will be phased in 
and start having impact. As the competitiveness gap 
narrows, the relevance and eligibility criteria in the CTD 
as well as the design of State aid measures will need to 
be reassessed and adjusted, as provided for in PM5 and 
PM6 (market analysis, notifications and review). 

Such evaluation and corresponding adjustments will 
mitigate the risk of overcompensation. In section 6.1.7 
Impact on the functioning of the internal market and on 
competition it is recalled that all support schemes need 
to comply, where relevant,  with the State aid rules, 
which are designed to prevent overcompensation.  

RSB issued a postive opinion with reservations on 29 June 2023. The second set of recommendations from 
the Board were included in the revised version of the Impact Assessment report as detailed in the table 
below. 

Table 23-2: Modifications of the IA report in response to the second RSB opinion 

Detailed RSB comments 

Modifications to the IA report  

(1)  The  report  should  set  out  more  clearly  and 
consistently what the main motivation behind this 
initiative  is.  It  should  further  clarify  whether  the 
dominant  objective  is  to  tackle  the  remaining 

The revised IA underscores in sections 1.3 Political 
context and 1.3 Synergies with other EU policy 
instruments that the objective of the initiative is higher 
uptake of intermodal transport with a view to reduce 

59 

 
 
Detailed RSB comments 

Modifications to the IA report  

negative transport externalities or to increase the 
competitiveness  of  intermodal  transport  more 
generally.  While  the  revised  report  takes  better 
account  of  the  policy  context  for  broad  parallel 
initiatives  such  as  ETS  transport,  CO2  and  air 
pollution  standards,  energy  taxation,  road  safety 
and charging, Eurovignette etc, it remains unclear 
as  to  how  these  measures  interact  and  work 
in  tackling  negative  road  transport 
together 
externalities  and  what  gap  remains.  Under  the 
dynamic baseline the report  should be clearer on 
how  the  expected  contribution  of  the  other 
initiatives  would  affect  the 
instruments  and 
current  disadvantages  of  intermodal  transport  in 
terms  of  uneven  internalisation  of  external  costs. 
In doing so, the report should clearly indicate which 
type of external cost (e.g. congestion, accidents, air 
pollution, GHG emissions) is the most problematic 
one  under  the  evolving  gap  to  be  tackled  and 
whether  any  prioritisation  of  externalities 
is 
needed.  It  should  explain  more  convincingly  why 
this gap is apparently only (or best) to be tackled 
via  a  revision  of  the  CTD  and  why  adaptations  of 
the  other  instruments  were  not  considered  as 
alternative measures. 

the external costs induced by freight transport at the 
system level.  

It clarifies that unlike the other initiatives for 
internalisation of external transport costs, whose 
starting point is mode-specific internalisation (such as 
ETS transport, CO2 and air pollution standards, energy 
taxation, road safety and charging which are included in 
the Baseline scenario), the CTD focuses on the level 
playing field between modes and aims to act directly on 
the competitiveness gap, based on regular market 
analyses. Therefore, its review is the most appropriate 
tool to address the uneven competitive positions of the 
different freight transport modes. 

The baseline section has been revised to better reflect 
the initiatives that are covered in its scope. It also 
highlights that the synergies between these initiatives 
are reflected in the baseline. An estimation of the 
external costs of congestion and accidents has been also 
added in the baseline section.  

issues  and  why 

(2)  While  the  revised  report  presents  a  new  option 
that does not bring domestic transport under the 
scope of the CTD and thus provides greater policy 
choice in terms of complying with the subsidiarity 
principle, 
it  still  needs  to  better  argue  and 
substantiate why Member States would be not be 
able  to  take  appropriate  measures  on  domestic 
incentives  based 
transport 
arguments  such  as  better  utilisation  of  transport 
infrastructure  should  override 
justified  public 
interest considerations they may have (e.g. certain 
fixed  driving  bans).  In  this  context  the  report 
certain 
clarify  whether  exempting 
should 
operations  from  fixed  driving  bans  would  also 
apply  to  purely  domestic  combined  transport.  It 
should justify why no options were considered that 
would allow Member States to continue to impose 
justified  public 
regarding 
transport. 

interest  measures 

(3)  The  report  should  present  a  more  balanced 
comparison  of  options. 
should  ensure 
consistency  between  the  impact  analysis  and  the 
scoring  of  the  comparison  summary  table.  For 

It 

The IA explains in section 7.4 that leaving domestic 
operations out of the scope for subsidiarity 
considerations could result in lower support to certain 
operations that contribute equally to environmental 
benefits. On the one hand, this would not be in line 
with the policy objectives. On the other hand, for 
Member States authorities it could be challenging to 
justify the existence of different support regimes for 
cross-border and for domestic operations, or to refuse 
to domestic operations the support they grant to cross-
border operations.  

PM13 applies to all operations within the scope of the 
directive, which means that under the preferred policy 
option PO-B2a the driving bans should be lifted for the 
road legs of all intermodal operations. Such bans have 
a similar effect to logistics chain and the use of 
infrastructure, be they applied to the road legs of 
cross-border or domestic intermodal operations. 
Furthermore, national authorities could again find it 
difficult to justify bans to national operations, while 
international operations can run. Therefore, excluding 
national operations from PM13 due to subsidiarity 
concerns, would add complexity and administrative 
burdens, while in practice the impact on road volume 
can be very limited (the share of road operations 
possibly impacted is around 2%). 

Additional clarifications have been added in sections 
7.1, 7.4 and 8.1. 

60 

 
 
Detailed RSB comments 

Modifications to the IA report  

In particular, the IA clarifies that while PO-B1 produces 
similar net benefits as PO-B2a, it is considered less 
effective, since in medium to long term, it results in 
over-reliance on rail-road intermodal operations, even 
with rather long road legs.  

PO-B2a performs better than PO-B2b in terms of 
proportionality, despite having a similar benefit-cost 
ratio than PO-B2b, because it is missing out on 
opportunities, leaving domestic operations with 
equivalent environmental benefits without a support 
and thus resulting in 38% lower outcome on the 
benefits side.  

PO-B2b, that leaves domestic operations out of scope, 
has only a slight advantage with regards to the 
subsidiarity principle, because it compromises between 
subsidiarity and effectiveness while having questions 
about practical applicability as explained under point (2) 
above. 

Respective clarifications have been added to section 8.1. 

instance, it is not clear why options PO-B1 and PO-
B2a  receive  a  different  score 
in  terms  of 
effectiveness despite having quite comparable net 
benefits. Similarly, it is difficult to understand why 
PO-B2a performs significantly better than PO-B2b 
in  terms  of  proportionality,  despite  the  latter 
having  a  better  Benefit-Cost-Ratio.  It  is  also  not 
clear  why  PO-B2b  performs  only  slightly  better 
than  options  PO-B1  and  PO-B2a  in  terms  of 
subsidiarity,  given  that 
it  excludes  domestic 
transport from the scope. 

(4)  In  view  of  above,  the  report  should  better  justify 
the  choice  of  the  preferred  option,  including  in 
terms of compliance with the proportionality and 
subsidiarity  principles. 
It  should  also  better 
the  envisaged  substantial 
demonstrate 
financial  public  support 
is  a  more  effective, 
efficient  and  coherent  policy  response  than  what 
could be achieved via parallel instruments tackling 
externalities of transport.  

that 

4.  EVIDENCE, SOURCES AND QUALITY 

The impact assessment is based on several sources, using both quantitative and qualitative data. This 
includes: 

•  REFIT evaluation of the CTD (2016) 

•  Stakeholder consultation activities (see Annex 2) 

•  External support study carried out by an independent consortium (lead by Ricardo)  

•  Commission experience in monitoring and implementing the CTD  

61 

 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

This annex provides a summary of the outcomes of the consultation activities for the review of the CTD, 
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 their views and the main 
issues they raised. The full analysis of the consultation results is presented in the stakeholder consultation 
report annexed to the support study. 

The objectives of the consultation activities were the following: 

–  to collect information and opinions of stakeholders on the key problems and associated drivers, 
the  definition  of  relevant  policy  objectives  linked  to  those  problems,  and  the  identification, 
definition and screening of policy measures that could be considered in this Impact Assessment 

–  to gather information and opinions on the likely impacts of policy measures and options. 

1. OVERVIEW OF CONSULTATION ACTIVITIES 

Consultation activities have taken place in 2021 and 2022, from the publication of the Inception Impact 
Assessment (IIA) in August 2021, to the targeted consultation that closed in August 2022. 

As part of the initial feedback mechanism, interested parties had the possibility to provide feedback on the 
Inception Impact Assessment from 19 August to 16 September 2021. A total of 62 individual responses 
were received.  

Subsequently, an open public consultation was accessible on the website “Have your Say” from 7 March to 
30 May 2022. In total, 101 responses were received from different stakeholders. Some stakeholders also 
provided position papers together with their responses to the OPC. The views of the respondents are 
presented hereafter objectively, without any inference as to what any majority or minority of citizens may 
think of each topic. 

Finally, the following targeted consultation activities were carried out: 

–  A targeted online survey aimed to validate the problem definition and the objectives of the policy 
options, obtain input to define further the policy measures/options, and provide data needed to 
support the assessment of impacts of measures and expected costs. The survey ran from 16 May 
to 24 June and received 59 responses.  

–  Targeted stakeholder interviews were conducted with 29 stakeholders between May and August 

2022 (including three exploratory interviews were conducted in February 2022).   

–  One  stakeholder  expert  meeting  with  industry was  held  on  25  October  2022.  There  were  60 

participants representing 55 organisations. 

2.  STAKEHOLDER GROUPS CONSULTED 

The table below provides a short overview of the main types of stakeholders identified and targeted as part 
of the different consultation activities. 

62 

 
 
 
Table 24:  Key stakeholder roles and mapping against activities 

High-level stakeholder 
group 

Description 

Shippers and their 
associations  

Freight (chain) organisers 
and their associations 
(e.g. logistics operators, 
freight forwarders)  

Independent connection 
organisers (organisers of 
non-road leg services) 

Shippers are firms that need to ship goods as part of their 
business. Shippers can be producers, buyers or 
intermediaries. These shipments may be addressed to 
other offices, factories, warehouses, clients, end 
consumers, or are part of export operations. Shippers may 
arrange own multimodal/intermodal operations and deploy 
their own fleet for the movement of cargo, fully or partially, 
or may acquire the services partly or fully through 
organisers of multimodal transport operations. 
They attempt to minimise the cost of the logistics chain 
(cost of arranging and cost of transport) and, thus, make 
decisions on the management of the supply chain such as 
those related to modes and carriers to employ, inventory 
management and facility location. 
Freight organisers are organisations responsible for the 
assembling and organisation of shipments of goods for 
firms or other organisations. They hold responsibility for 
the timely and qualitative delivery of this cargo up to its 
destination. Freight organisers are involved in different 
stages of the supply chain management. They contract 
the services of transport operators and engage in 
interaction and negotiations with multiple carriers that may 
cover different stages of the operation. 
The decisions made by the freight organisers have the 
potential of reducing the shippers’ costs due to the optimal 
choice of transport route and mode choices. These 
choices also have an impact on environmental and social 
aspects. 
Freight organisers can also provide CT organiser services 
as well as all or part of the transport carrier services.  
Connection organisers are organisations that organise a 
rail, IWW or SSS service by subcontracting the carriers 
and selling “slots” on vehicle or vessel to shippers or 
freight organisers. They take the commercial risk of filling 
train/ship/barge.  
Connection organisers can be legally independent but be 
affiliated to transport operators or freight organiser. 
Freight organisers, transport operators or consortiums of 
shippers can act as connection operators.  

Transport operators 
(carriers) and their 
associations 

(e.g. maritime shipping 
lines, inland waterways 
operators, railway 
undertakings, road 
hauliers) 

Terminal operators and 
infrastructure managers 
and their associations 

Transport operators are organisations operating the 
vehicles and vessels involved in the movement of cargo.  
Transport operators make decisions and investment that 
could improve or hinder the compatibility and 
interoperability with other modes, the feasibility and 
optimality of combining modes. They are also responsible 
for aspects of sustainability and efficiency in the operation, 
such as energy efficiency measures, fleet sizing, 
technology upgrade, vehicle routing and scheduling, 
network configuration, among others. 
In multimodal and intermodal chains, transport operators 
can subcontract other transport operators to carry out all 
or part of the transport operation.  
Terminal operators make decisions that could leverage 
the synergies with other nodes and modes in the 
hinterland network. They interact and coordinate actions 

63 

Stakeholder 
engagement 
activity 
Exploratory 
interviews 

Targeted 
surveys 

Targeted 
interviews 

Stakeholder 
expert meeting 

OPC 

Exploratory 
interviews 

Targeted 
surveys 

Targeted 
interviews 

Stakeholder 
expert meeting 

OPC 

Exploratory 
interviews 

Targeted 
surveys 

Targeted 
interviews 

Stakeholder 
expert meeting 

OPC 
Targeted 
surveys 

Targeted 
interviews 

Stakeholder 
expert meeting 

OPC 

Targeted 
surveys 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Stakeholder 
engagement 
activity 
Targeted 
interviews 

Stakeholder 
expert meeting 

OPC 

Targeted 
surveys 

Targeted 
interviews 

OPC 

Targeted 
surveys 

Targeted 
interviews 

OPC 

High-level stakeholder 
group 

Description 

Public authorities 
(national and regional) 

Other stakeholders (civil 
society) 

with both freight organisers and transport operators and 
have a high responsibility on the integration of different 
transport interfaces. 
They make decisions that could impact transport choices, 
such as fees and charges for the use of their facilities and 
are partially responsible (together with national and 
regional authorities) for the deployment of investment to 
improve infrastructure, acquire transhipment equipment or 
adapt facilities for the combination road/vessel or 
rail/vessel. 
National authorities are responsible for transposing, 
implementing and enforcing the CTD, adopting support 
measures and reporting on the progress.  
Local authorities (regional governments and urban 
authorities in charge of Sustainable Urban Logistics 
Plans) may also be involved in the adoption of specific 
measures and will be directly or indirectly affected by the 
implementation of the relevant provisions. 
Other interested 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. 
One German trade union (Eisenbahn- und 
Verkehrsgewerkschaft EVG, the railway and transport 
union) responded to the OPC, as did three organisations 
that classified themselves as NGOs (which were pro-rail 
organisations from Germany and Poland and an 
organisation representing Swedish transport companies). 
For the OPC analysis, these were grouped under ‘Other’, 
along with those organisations that had classified 
themselves as ‘Other’ (i.e. from other stakeholder group 
type that those explicitly listed). The ‘Other’ group 
comprised one Austrian labour organisation, two inland 
waterway lobby groups and a network. In general, the 
responses from stakeholders included in category ‘Other’ 
did not differ from the responses of the industry 
stakeholders but were complementary to these. 

3. CONSULTATION ACTIVITIES – THE METHODOLOGY AND TOOLS USED 

The stakeholder consultation methodology relied on a combination of a range of methodologies and 
tools, which are described in more detail in this section.   

The participation to all the consultation activities is presented in the table below. The industry stakeholders 
included stakeholders from different roles explained above. However, many are engaged in different 
roles/activities at the same time and thus they were given an opportunity to identify their main role, or 
several roles. Similarly, several involved industry associations represent operators from various roles. For 
this reason, the industry stakeholders have not been separated into different roles.  

64 

 
 
 
 
 
 
 
 
 
 
 
Table 25:  Participation in different consultation activities  

Stakeholder type 

Industry 

EU citizens 

NGOs 

Public authorities 

Other 

Total 

IIA 

38 

13 

1 

4 

6 

62 

Inception Impact Assessment  

OPC 

Interviews 

Survey 

Workshop 

68 

10 

3 

14 

5 

21 

0 

0 

5 

3 

100 

29 

31 

0 

0 

8 

10 

49 

55 

0 

0 

0 

0 

55 

The consultation on the IIA focused on the objectives and preliminary problem drivers and policy measures 
for this revision as set out and described in the IIA. The majority of the received replies were general in 
nature.  

Open Public Consultation  

The OPC focused on the problem definition and the objectives of the revision, containing 22 detailed 
questions on the subjects. The OPC questions were prepared based on the results of OPC carried out 
for the impact assessment in 2017.  

Online survey 

A targeted survey was developed to gather information to validate the problem definition and the 
objectives of the policy options, obtain input to define further the policy measures/options. Major 
part of the survey was focused on obtaining the data needed to support the assessment of impacts of 
measures  and  expected  costs.  The  survey  was  aimed  at  national  authorities  and  industry 
representatives (associations and individual participants) from all relevant groups (freight organisers, 
transport operators, terminal operators, shippers).  

Interviews 

Three  exploratory  interviews  were  undertaken  during  the  inception  phase  of  the  study.  The 
exploratory interviews considered views on the identified problem drivers and policy objectives, but 
they also considered the potential impacts of policy measures.  

The  targeted  interviews  were  conducted  based  on  a  tailored  interview  checklist  (based  on  the 
questionnaire developed for the survey) that allowed to explore in depth the relevant topics for each 
stakeholder  group.  Discussions  with  stakeholders  focused  on  a  range  of  topics,  including  the 
identification of barriers for the use of more sustainable options, and their views on the policy options, 
confirming the extent to which relevant measures address the drivers contributing to the problems. 
They also assisted in understanding the cost elements associated to each policy measure and their 
magnitude. 

In  parallel,  targeted  follow  up  interviews  with  stakeholders  who  had  completed  the  survey  were 
carried  out.  The  aim  of  these  interviews  was  to  clarify  any  questions  in  relation  to  their  survey 
response, and delve further into certain topics that have been raised or missed.   

Stakeholder expert meeting 

The industry stakeholder expert meeting took place after the policy options under consideration had 
been  agreed  with  the  Commission,  but  before  the  preferred  policy  option  had  been  chosen.  The 
65 

 
stakeholder  expert  meeting  introduced  the  key  data  and  assumptions  underlying  the  scenarios 
developed  with  respect  to  each  of  the  policy  options  under  consideration,  presented  the  impact 
assessment methodology applied to assess the economic, social and environmental impacts of the 
policy  options,  as  well  as  the  initial  results  and  focused  on  the  discussion  on  the  choice  of  the 
preferred policy option. 

4. FEEDBACK RECEIVED 

Problem definition and objectives 

The stakeholder consultation activities revealed a large degree of agreement among stakeholders that 
the problems and objectives identified in this impact assessment are relevant for the development of 
intermodal transport137.  

The IIA consultation and OPC focused on the problem at a higher level, after which the survey and 
interviews took a more detailed and systematic approach to specifying the problem and an associated 
objective for the revision of the CTD. A common theme in the feedback on the IIA was a lack of 
clarity surrounding some of the definitions of the current CTD, while others suggested that the CTD 
should focus more on IWW and SSS in addition to road and rail transport. One industry respondent 
commented that restrictions on road transport would not solve the problems of other modes, while 
another  industry  respondent  noted  that  smaller  companies  faced  more  challenges  when  using 
intermodal transport. Overall, there was broad support across all stakeholder groups for the problems 
that were identified, and the associated objectives for the revision of the CTD.   

In the OPC, respondents were asked detailed questions about the problem. Two thirds of respondents 
believed that intermodal/multimodal transport was competitive with road-only transport in the EU 
without  support  only  in  some  situations  (63  out  of  95,  66%).  This  point  of  view  was  shared  by 
participating industry stakeholders, except for terminal operators, who were more pessimistic with 
three out of five considering intermodal/multimodal transport never or almost never competitive with 
road-only transport without support. Freight organisers (e.g. logistics operators, freight forwarders 
mostly  active  in  the  road  transport)  were  generally  more  sceptical  about  the  lack  of  price-
competitiveness of intermodal transport compared to road-only transport and the insufficiency of the 
support provided through the current CTD than the other industry stakeholder groups, who in their 
vast majority agreed that the lack of price-competitiveness was an obstacle to the development of 
intermodal  transport.  80  out  of  100  respondents  (80%)  implied  that  there  were  differences  in  the 
competitiveness  of  intermodal/multimodal  transport  in  different  Member  States,  with  common 
reasons being differences in the infrastructure and services that were available, as well as differences 
in the support provided. Respondents identified six factors as affecting the lack of competitiveness 
of intermodal/multimodal transport compared with road-only transport: transhipment costs (87 out 
of 94; 93%) and lack of suitable terminals in the vicinity (85 out of 95; 89%) were the most prominent 
ones. For both of these, at least 75% of respondents from each stakeholder type and industry sub-
category agreed that these were relevant factors. 80% of the respondents considered an additional 
four factors as being relevant, i.e.: road transport being cheaper than intermodal/multimodal transport 
for door-to-door operations (78 out of 94; 83%); habit of using road-only transport (78 out of 94; 
83%); lack of suitable service offer in terminals in the vicinity (76 out of 95; 80%); and delay/longer 
transit time compared with road-only transport (73 out of 92; 79%). For each of these, at least half of 
the respondents  from  each stakeholder type and industry sub-category felt  that these factors were 
relevant, with the exception of transport organisers, a minority of which (3 out of 7) felt that road 
transport  being  cheaper  than  intermodal/multimodal  transport  for  door-to-door  operations  was  a 
relevant factor. 

137  The  respective  shares  of  responses  presented  in  this  section  refer  to  the  total  amount of  responses  to  the  specific 
consultation question and not to the total amount of responses to the consultation activity as such. 

66 

 
 
The  questions  for  the  survey  and  interviews  were  designed  to  be  complementary.  In  relation  to 
problems associated with Thematic Area 1, ‘Extend support to a wider range of operations and set 
eligibility conditions that are simple and justified’, 25 out of 31 survey respondents (81%), and 19 
out of 23 interviewees (83%), ‘agreed’ or ‘strongly agreed’ that the current eligibility criteria were 
too narrow. This pattern was similar between different stakeholder groups, i.e.  freight organisers, 
transport  operators,  public  authorities,  and  civil  society  representatives.  23  out  of  31  survey 
respondents (74%) and 15 out of 21 interviewees (71%). Felt that some of the eligibility criteria were 
not  entirely  relevant  to  promote  modal  shift  or  to  reduce  CO2  emissions  and  other  externalities 
Similarly, 25 out of 31 survey respondents (81%) and 16 out of 19 interviewees (84%) had the view 
that  the  current  definition  of  CT  uses  ambiguous  terms.  The  prevailing  view  among  industry 
stakeholders was that the CTD needs to be restrictive and not allow for different interpretations per 
Member State. When asked to explain their responses, a couple of public authorities and the European 
Association  for  Forwarding,  Transport  and  Customs  Services/European  Logistics  Platforms 
Association  (CLECAT/ELPA;  representing  more  than  20  national  logistics  industry  associations) 
noted that it was not clear whether the definition of CT includes one or two-leg operations, and that 
this had been interpreted differently in different Member States. Some public authorities and industry 
respondents  (in  particular  road  hauliers)  were  concerned  that  the  revision  of  the  CTD  would  not 
sufficiently factor in the changes and modernisation of the freight transport market. The term "nearest 
suitable  terminal"  was  commonly  identified  by  freight  organisers  as  one  that  was  particularly 
ambiguous. The Irish Road Hauliage Association (IRHA) suggested that there needed to be flexibility 
on the length of road legs in particular, as a result of the different geographies in the EU’s Member 
States.  

There was support for the objectives identified to address these problems. 28 out of 30 of survey 
respondents (93%) and 20 out of 21 interviewees (95%) ‘agreed’ that the  Directive should extend 
support to a wider range of operations. In the survey, all industry stakeholders but one supported the 
extension  of  support.  On  respondent  felt  that  it  should  be  restricted  to  only  combined  transport 
operations.  The  response  was  similar  in  relation  to  the  other  objective  that  eligibility  conditions 
should be easy to control and justified, as all survey respondents (31 out of 31; 100%) and 20 out of 
22 of interviewees (91%) ‘agreed’ or ‘strongly agreed’ with this. The response was similar across all 
stakeholder groups. When asked to explain their responses, one association (CLECAT/ELPA) called 
for the scope to be extended to all multimodal transport operations in the EU, as long as the longest 
leg of the journey was carried out using a sustainable mode of transport, and that the initial and final 
road legs were relatively short. They also underlined that multimodal operations should make use of 
shipping, as well as rail and inland waterways.    

There was support for the definition of the problem under Thematic Area 2 ‘Improve monitoring and 
reporting  of  the  status  of  intermodal  transport’,  i.e.  that  there  was  a  lack  of  market 
monitoring/empirical basis to determine the adequate level of support. Eighteen out of 20 survey 
respondents (one industry stakeholder and one public authority neither agreed nor disagreed) and 15 
out  of  22  interviewees  (68%)  ‘agreed’  or  ‘strongly  agreed’  with  this  definition  of  the  problem. 
Similarly, there was support for the proposed objective to address this problem: Improve monitoring 
and reporting of the status of multimodal/intermodal transport, as 20 out of 21 of survey respondents 
(95%) and 15 out of 22 interviewees (68%) either ‘agreed’ or ‘strongly agreed’ with this objective. 
Among freight organisers, transport operators, and civil society representatives, several respondents 
expressed  support  for  improved  monitoring  and  reporting  requirements,  while  others  stated  that 
reporting for the sake of reporting should be avoided.   

Stakeholders generally ‘agreed’ with each of the four elements of the problem definition associated 
with Thematic Area 3, ‘Increase competitiveness of intermodal transport’. All but two of the survey 
respondents and interviewees (19 out of 21 in both cases; 90%) ‘agreed’ or ‘strongly agreed’ that 
there was an issue with the narrow application of support measures, while all but one (19 out of 20 
survey respondents (95%) and 20 out of 21 interviewees (95%)) stakeholder in each case ‘agreed’ or 

67 

 
‘strongly agreed’ that there was a problem with the insufficient level of incentives provided. With 
respect to the third element of the problem definition, differences in the application of the support 
measures, again all but two respondents (17 out of 19 survey respondents (89%) and 16 out of 18 
interviewees (89%)) in each case either ‘agreed’ or ‘strongly agreed’ that this was an issue. Finally, 
while 17 out of 18 survey respondents (94%) ‘agreed’ or ‘strongly agreed’ that there was a problem 
as  information  on  national  State  aid  is  inadequate,  therefore  access  is  unequal,  16  out  of  21 
interviewees (76%) held such a view. In the survey, most stakeholders that did not explicitly agree 
with the problems identified in this thematic area also did not disagree. One out of five responding 
public authorities in the survey disagreed that the level of incentives was insufficient and one out of 
three  responding  public  authorities  disagreed  that  the  information  on  national  State  aid  was 
inadequate (industry representatives all agreed on these two points). One road hauliers association 
(the  World  Road  Transport  Organisation  –  IRU)  noted  that  the  lack  of  harmonisation  of  support 
measures was a challenge to some cross-border operations.  

Similarly, 22 out of 23 survey respondents (96%) and 16 out of 19 interviewees (84%) either ‘agreed’ 
or  ‘strongly  agreed’  with  the  objective  that  was  proposed  to  address  these  problems:  increase 
competitiveness of multimodal/intermodal transport. In the survey, the responses of public authorities 
were split,  as four (strongly) agreed, one disagreed and three did  not  answer.  While  some freight 
organisers  and  transport  operators  argued  that  multimodal/intermodal  transport  was  less  cost-
effective than road-only transport so needed to be supported, both IRU and the European Shippers 
Council (ESC) pointed out that not only price competitiveness should be considered, but also other 
aspects such as flexibility, capacity and reliability. The Maltese and the Finnish transport ministries 
noted that increased competitiveness of multimodal/intermodal transport was needed. 

Under Thematic Area 4, ‘Increase transparency and cooperation to facilitate flexibility and simplify 
entry to the market’. 15 out of 18 respondents to the survey (83%) , and 16 out of 21 interviewees 
(76%), either ‘agreed’ or ‘strongly agreed’ that inefficiencies in scheduling, planning and running 
multimodal  transport  were  an  issue.  Freight  forwarders  and  shippers  had  a  bigger  tendency  than 
transport operators and terminal operators to see inherent inefficiencies in scheduling, planning and 
running multimodal transport as an important obstacle to the development of intermodal transport.  
Similarly 13 out of 18 survey respondents (72%) and 15 out of 21 interviewees (71%) of stakeholders 
either ‘agreed’ or ‘strongly agreed’ that a lack of multimodal information exchange and insufficient 
track and tracing of shipments were part of the problem (12 out of 18 survey respondents (67%) and 
14 out of 21 interviewees 67%)). This was across all stakeholder groups. In the survey, only on the 
tracking and tracing of shipments, the opinions of industry representatives diverged. Otherwise there 
was broad agreement on the problems under this thematic area. In the interviews, those respondents 
who  did  not  explicitly  agree  generally  did  not  disagree  either.  Deutsche  Post/DHL  did  not  see 
inefficiencies in scheduling and planning, but considered running multimodal transport a challenge, 
as  they  were  missing  a  standard  intermodal  information  exchange  space.  17  out  of  19  survey 
respondents were also in favour of the proposed objective to address the proposed problem definition 
and 18 out of 21 interviewees (86%) either ‘agreed’ or ‘strongly agreed’ that a relevant objective was 
to  improve transparency and cooperation to  facilitate flexibility and simplify entry to  the market. 
Three stakeholders disagreed or strongly disagreed (one each from industry, public authorities and 
civil society). 

Potential solutions 

The IIA sought stakeholders’ initial feedback on three options for amending the CTD, in addition to 
Option 1, which was ‘no change’. Option 2 proposed to expand the list of support tools and provide 
support to operations that saved certain negative externalities, while Option 3 additionally proposed 
to  make  it  an  obligation  that  the  support  tools  chosen  by  Member  States  be  based  on  a  regular 
analysis of the transport system. Option 4 in turn built on Option 3 by requiring that a certain number 
of mandatory, harmonised support measures be applied. There was also a general consensus amongst 

68 

 
 
respondents that change was needed, with many highlighting that action at the level of either Option 
3 or Option 4 would be most effective. 

The survey and interview identified three potential measures in response to the objectives identified 
in  relation  to  Thematic Area  1  ‘Extend  support  to  a  wider  range  of  operations  and  set  eligibility 
conditions that are simple and justified’. 22 out of 27 of survey respondents (81%) and 17 out of 22 
interviewees (77%) believed that the first measure (M1: extending the scope of the CTD to cover all 
intermodal  transport  that  saves  certain  negative  externalities)  would  contribute  to  either  a 
‘significant’ or ‘a large extent’ to achieving the stated objective of extending support to a wider range 
of operations and set eligibility conditions that are simple and justified. The responses were similar 
across stakeholder groups. 

On the measures extending the scope of the CTD to cover all intermodal transport that saves certain 
negative externalities, nine out of 14 industry stakeholders that responded said that they expected 
additional direct costs as a result of the implementation of the proposed measure. There were only 
two responses from  public authorities  - one respondent  (PL) expected additional direct  costs as a 
result of the implementation of the proposed measure and one did not (MT). 

Basing eligibility on the savings in relation to a wide set of externalities was more popular than basing 
eligibility solely on GHG emissions saved amongst both survey respondents (18 – compared to four 
– out of 22; 82%) and interviewees (14 – compared to four – out of 21; 67%). In the interviews, two 
industry associations and two public consultation were sceptical about basing eligibility on a wider 
set of externalities, mainly with the argument that GHG as a sole criterion would be simpler. In terms 
of  which  negative  externalities  to  include,  five  were  chosen  by  15  or  more  (out  of  18)  survey 
respondents, i.e. GHG emissions, accidents, air pollution, congestion and noise. A similar question 
was  asked  in  the  OPC,  which  gave  similar  results  as  all  those  who  supported  a  wide  range  of 
externalities being considered wanted to see GHG emissions included (37 out of 37; 100%), while 
large proportions also wanted congestion (34 out of 37; 92%); noise  (30 out of 37; 81%), energy 
efficiency (22 out of 27; 81%); air pollution (29 out of 37; 78%) and accidents (29 out of 37; 78%) 
considered. In the survey, the inclusion of some other externalities was considered by some to be 
important as they were all part of the broader issue, even though this would make the calculation 
more complex. Calculating GHG emissions was considered easier, but it was also underlined that the 
calculation of GHG emissions of different operations should be accurate. 

However, there was no clear consensus from the respondents to the survey on the minimum level of 
savings, of either GHG emissions or a wider range of externalities, that would need to be achieved 
compared to road transport for a CT journey to be eligible for support. As to GHG emissions, four 
industry stakeholders voted for a savings level of 61%-70% and three industry stakeholders voted for 
the minimum level 1%-10%. The one public authority that responded voted for a savings level of 
41%-50%. When considering a wider set of negative externalities, the one public authority voted for 
31%-40%, while the picture for industry was mixed. Three industry stakeholders voted for 41%-50%, 
two opted for the maximum 71%-80% and one for the minimum 1%-10%.  

Stakeholders were asked a series of questions in relation to second measure of Thematic Area 1: M2 
– Limit the direct operational financial support to operations with door-to-door distance of less than 
a certain value, which revealed little support for this measure. 15 out of 21 survey respondents (71%), 
both  industry  stakeholders  and  public  authorities,  and  11  out  of  20  interviewees  (55%)  did  not 
consider  that  the  establishment  of  a  distance  threshold  was  an  necessary  criterion  for  assessing 
eligibility. No differences were found across stakeholder groups. 17 out of 23 survey respondents 
(74%) and 14 out of 20 interviewees (70%) did not believe that a threshold of no more than 1000 km 
was  appropriate,  although  three  out  of  four  public  authorities  and  three  out  of  17  industry 
representatives  that  expressed  a  view  in  the  survey  did  consider  it  appropriate.  Among  the 
interviewed stakeholders, the European Barge Union (EBU, IRU and LTG Cargo (freigth organiser) 
considered a distance threshold an appropriate criterion for assessing eligibility, but did not think it 
69 

 
should  be  limited  to  1000  km.  Several  freight  organisers  and  the  Maltese  transport  authority 
considered the 1000-km threshold arbitrary and requested more flexibility. Stakeholders who were 
against  a  specific  distance  threshold  in  the  survey  stated  that  is  should  either  be  GHGs  or  other 
negative externalities that influence levels of support or that benefits should be provided for anyone 
engaging in multimodal operations to facilitate uptake. 

15 out of 23 survey respondents and ten out of 21 interviewees believed that the third measure relating 
to Thematic Area 1, i.e. M3: Establish new and adequate dataset obligations for proof of eligibility, 
would  help  to  achieve  the  objective  of  extending  support  to  a  wider  range  of  operations  and  set 
eligibility conditions that are simple and justified to either a large or significant extent.While logistics 
sector  representatives  saw  potential  benefits  for  multimodal/intermodal  transport  from  the 
introduction of tools of the eFTI Regulation, road sector representatives noted their reservation as 
eFTI was still under development, its uptake was still low or that it would add complexity. 

Six out of the 13 industry respondents indicated that there would be additional direct one-off costs 
for their organisations or member organisations due to the implementation of dataset obligations for 
proof of eligibility (three terminal operators plus a transport operator and two others), whilst the other 
six  respondents  indicated  that  it  would  impact  their  annual  operating  expenditures  (across  all 
subgroups  but  more  transport  operators).  The  main  costs  expected  by  UIRR  and  one  anonymous 
transport operator corresponded to the implementation of the digitalisation of data sharing and the 
increase in the number of man hours required for training and the recruitment of new staff. These 
were seen by WienCont to be different between different companies, with differences depending on 
the maturity of their administrative processes. Two public authority respondents indicated that there 
would  be  additional  direct  costs  as  a  result  of  the  implementation  of  this  measure,  whereas  three 
public authorities said that they did not know what would be the impact on additional costs. 

There  were  a  few  advantages  identified  across  both  public  authorities  and  industry  with  the 
introduction of new and adequate dataset obligations for proof of eligibility. Both stakeholder groups 
cited the increases in efficiency and transparency that obligations would provide, and the stronger 
foundations created for data sharing. The main disadvantages echoed by both public authorities and 
industry  were  the  added  human  resources  required  and  the  challenging  complexity  of  uniformly 
implementing data reforms. 

Under Thematic Area 2 ‘Improve monitoring and reporting of the status of intermodal transport’, 
stakeholders were asked to express their views on two possible measures for addressing the proposed 
objective,  i.e.  measures  M4,  establish  an  analysis  and  strategic  planning  obligation  for  Member 
States for sustainable transport modes only; and M5, establish an analysis and strategic planning 
obligation for Member States for all transport system (cross-modal). Stakeholders considered that 
M5 would contribute more towards the objective of improving monitoring and reporting of the status 
of  multimodal/intermodal  transport,  than  M4.  Amongst  stakeholders,  19  out  of  22  survey 
respondents (and 15 out of 22 interviewees) (86% and 68% respectively) considered that M5 would 
contribute to achieving the objective to a large or significant extent, compared to only 10 out of 22 
(and six out of 22 interviewees) (45% and 27% respectively) for M4. In the survey, the responses of 
public authorities where the same for both measures (three in favour, one against), while the industry 
clearly preferred M5. In the interviews, some freight organisers (e.g. IRHA, CLECAT/ELPA, IRU) 
found  the  concept  of  “sustainable  transport  modes”  too  difficult  to  define,  a  reason  for  their 
preference for M5. They reported fears that the definition could be too limited and could fully remove 
road transport without proper comparison of greener technologies in the different transport modes. 
EBU noted that road transport will become more sustainable in the future.The most popular frequency 
of reporting under M5 was two years (19 out of 22 survey respondents and 12 out of 20 interviewees; 
86%  and  60%  respectively),  largely  supported  by  the  industry,  while  several  public  authorities 
thought that the frequency of reporting should be every five years. In the survey, 12 out of 13 industry 
respondents (92%) stated that they would accept a reporting obligation on their intermodal activities.  

70 

 
For the measures under Thematic Area 2, on improving reporting, no responses were received on the 
relevant cost impacts. 

The first question relating to possible solutions under Thematic Area 3, ‘Increase competitiveness of 
intermodal transport’ asked stakeholders to indicate their preferred approach for introducing support 
tools.  The  most  popular  option  amongst  survey  respondents  (six  out  of  17;  35%)  was  M10,  i.e. 
mandatory adoption of  at  least one operational  support tool (eligibility based on this Directive’s 
definition) and at least one technological upgrade support tool (eligibility to be defined by MS) from 
the list of support Toolbox. This was followed by M7 (mandatory harmonised adoption of specific 
support tool by all MS for non-road legs costs), which was supported by five survey respondents 
(29%).  In the survey, respondents  from  the industry generally were more in  favour of mandatory 
harmonised support, whereas public authorities were more split between mandatory and voluntary 
and between harmonised and flexible approach.  M7 was also  the most popular response amongst 
interviewees (supported by five industry associations and two civil society representative out of 17 
replies; 41%). Those stakeholders that supported a mandatory approach argued that this would ensure 
harmonisation  between  Member  States  and  would  better  support  cross-border  journeys,  whereas 
those who supported a voluntary approach argued that a such an approach was more appropriate as 
Member States were different. 

Stakeholders were also asked for their views on making the detail of four of the measures mandatory. 
Respondents agreed or strongly agreed that the following support tools should be mandatory for all 
Member States in relation to:  

•  M6: Reductions or reimbursements of charges paid by the shipper or operator who organised the 
intermodal transport operation equal to the share or lump sum of certain transhipment costs (e.g. 
30%)    (ten  out  of  15  for  the  survey  and  17  out  of  21  amongst  the  interviews;  67%  and  81% 
respectively). 

•  M7: Reductions or reimbursements of costs paid by the shipper or operator who organises the 
transport operation equal to the share or lump sum of certain transport costs per loading unit on 
non-road leg (e.g. 20%) (eight out of 15 for the survey and 18 out of 21 amongst the interviews; 
53% and 86% respectively). 

•  M9: at least 1 mandatory tool for support from the list of support Toolbox that reduce/reimburse 
operational transport costs (ten out of 16 for the survey and 13 out of 17 amongst the interviews; 
63% and 76% respectively). 

•  M10: at least 1 mandatory tool for support from the list of support Toolbox that reduce/reimburse 
operational  transport costs and at least  1 mandatory tool for support from the list  of support 
Toolbox that provide financial support for setting up new routes and technological upgrades (ten 
out of 16 for the survey and eleven out of 17 amongst the interviews; 63% and 65% respectively). 

For all the items in the list above, support in the survey came essentially from industry stakeholders. 
Among public authorities, support and opposition to each of the above-listed measures was almost 
exactly split half/half. In the course of the stakeholder workshop, concerns about the potential adverse 
impact of the application of the tools being made voluntary on the level playing field were raised by 
a number of stakeholders.   

Interviewees also indicated which of the specific provisions that are currently in the CTD should be 
retained. 15 out of 20 were for retaining Article 2 (ban on quotas; 75%), Article 4 (equivalent use of 
non-resident hauliers as in international road transport; 15 out of 20; 75%) and Article 8 (ban on price 
controls; 12 out of 20; 60%). This reflected the responses to a similar question in the OPC, where 49 
out of 72 of respondents indicated their support for retaining Article 2 (68%) and Article 4 (39 out of 
59; 66%). In addition, 55 out of 72 (76%) of respondents to the OPC supported retaining both Article 

71 

 
6.1  (tax  reductions  or  reimbursements  to  road  hauliers  of  Rolling  Highway  CT  operations;  and 
Article 6.2 (tax exemptions to road hauliers for vehicles used exclusively in all new eligible CT; 57 
out of 73 (78%)).  

In the survey, stakeholders were asked for their views on how four policy measures under Thematic 
Area  4,  ‘Increase  transparency  and  cooperation  to  facilitate  flexibility  and  simplify  entry  to  the 
market’  would  contribute  to  meeting  the  proposed  objective  of  improving  transparency  and 
cooperation  to  facilitate  flexibility  and  simplify  entry  to  the  market.  For  both  M11  (establish 
interoperability  obligation  for  defined  data  set)  and  M12  (establish  common  data  exchange 
protocol), all survey respondents that had a view (12 out of 12; 100%) and 15 out of 22 interviewees 
(68%)  believed  that  these  measures  would  contribute  to  achieving  the  proposed  objective  to  a 
‘significant extent’. For M13, establish transparency requirements for services/facilities available at 
terminals, 12 out of 13 survey respondents (92%) and 13 out of 22 interviewees (59%) also believed 
that the measure would contribute to achieving the proposed objective to a ‘significant extent’ (on 
industry respondend chose “limited extent” as an answer).  

On M11, M12 and M13, two industry stakeholders (one transport operator and one freight organiser) 
expected some additional direct one-off costs for their organisation or their members, but did not 
expand further. Five industry stakeholders (across all subgroups) expected some additional ongoing 
costs  from  ensuring  compliance  with  requirements  for  these  measures,  but  again  did  not  expand 
further. 

Stakeholders were asked to indicate from a list of criteria those that they considered important for 
transparency  and  as  being  an  appropriate  basis  for  defining  terminal  categories.  At  least  ten 
interviewees  out  of  21  indicated  that  each  criterion  was  important.  No  interviewee  opposed  any 
criterion. Within the survey, the criteria listed as the most important (75%) by industry stakeholders 
was ‘connections by road, rail, inland waterways and short-sea’ and by public authorities (45%) was 
‘conditions for road hauliers’.  

Support tools  

A number of support tools could be adopted to support industry stakeholders to increase the use of 
multimodal/intermodal transport. Linked to questions under thematic area 3 above, stakeholders were 
also asked further questions on the details of the proposed support measures. 

As part of the OPC, stakeholders were asked a range of questions on support tools, including who 
should be the beneficiaries of these. There was broad support to apply policies or support measures 
to different actors, with transport organisers (85 out of 96; 89%) and shippers (83 out of 95; 87%) 
being the most popular beneficiaries to encourage them to choose intermodal/multimodal options. 59 
out  of  93  respondents  (63%)  believed  that  the  eligibility  for  support  should  be  based  on  new 
principles  rather  than  on  those  in  the  current  CTD.  With  the  exception  of  participating  terminal 
operators and freight organisers, the majority of whom were against giving up the current principles, 
all industry sub-categories responding to the OPC were in their majority in favour of introducing new 
principles. The most common aim of the support tools included in the CTD should be to provide 
support to cover the inherent disadvantages of intermodal/multimodal transport in order to make 
intermodal/multimodal  operations  price-competitive  vis-à-vis  road-only  transport  (58  out  of  75; 
77%). This was supported by the majority of respondents from each stakeholder group and industry 
sub-category.  There  was  also  broad  support  for  different  types  of  measures,  such  as:  economic 
support for technological upgrades (89 out of 96; 93%); regulatory support (85 out of 96; 89%); 
economic support to operations (85 out of 96; 89%); and administrative support (simplification of 
procedures)  (79  out  of  95;  83%).  All  stakeholder  groups  considered  these  measures  equally  as 
‘important’ or ‘very important’. 

72 

 
In the context of Thematic Area 3, stakeholders, including those from different industrial sectors, 
were asked tailored questions in the survey about different support tools. When asked about the most 
important factors in choosing intermodal transport operations, the most important factor given by 
industry respondents to the survey was price (11 out of 12; 92%), followed by reliability (six out of 
12;  50%) and delivery time (four out  of 12;  33%). These factors were similarly  considered to  be 
important  by  interviewees,  across  stakeholder  groups:  freight  forwarders,  transport  operators  and 
public authorities agreed to a very large extent. Some interviewees highlighted that, while gaining 
importance, sustainability was not yet a primary concern for customers. Industry respondents were 
also asked to provide the minimum level of reduction of transport costs that would be needed to make 
door-to-door intermodal transport solutions competitive with road-only transport for different ‘road-
other mode’ combinations. Road-rail combinations were considered to require least cost reductions, 
as half of those who responded (five out of ten) considered that reductions of less than 10% would 
be needed to make rail-road combinations competitive with road-only transport. On the other hand, 
for  road-SSS  combinations  half  of  those  who  responded  (two  out  of  four)  considered  that  cost 
reductions of less than 20% would be needed to make these combinations competitive, whereas three 
out of the five responses (60%) relating to road-inland waterways combinations felt that a reduction 
of over 25% was needed for these to become competitive.  

Stakeholders were then asked questions about different aspects of potential support tools, with the 
survey having more tailored questions for different types of stakeholder. First, there was a series of 
questions on potential financial support in the form of reductions or reimbursements of operational 
costs. Ten out of 15 interviewees ‘agreed’ or ‘strongly agreed’ with the inclusion of either a reduction 
or reimbursement of the transhipment costs incurred (67%), of the charges incurred for the use of 
certain infrastructure and of the operational transport costs to a shipper or operator who organises 
the transport operations (both nine out of 15; 60%). In the interviews, several industry associations 
declared themselves in favour of financial and non-financial support measures to make intermodal 
transport more cost-effective. Public authorities which responded tended to be more cautious as to 
their  capacity  to  provide  financial  support.  The  possibility  of  reducing  rail  access  charges  was 
referred to as an option by several public authorities. The survey revealed little experience with the 
use of these support measures. If such support tools were applied, there was a preference for these to 
be applied as a share of costs (e.g. three out of four supported the reduction or reimbursement of the 
transhipment costs incurred working in this way), but the numbers that responded to this question 
were  very  low.  Industry  respondents  also  tended  to  support  the  Member  State  where  the  costs 
occurred funding the support, although again the numbers were very low (e.g. again only three out 
of four shippers supported the reduction or reimbursement of the transhipment costs incurred working 
in this way). 

On the operational support measures, no industry stakeholder provided information on the impacts 
associated with the implementation of these measures. Naturally, industry stakeholders welcomed all 
additional  public  support.  The  Latvian  Ministry  of  Transport  noted  that  the  main  problem  for 
cohesion countries will be the level of EU support in general, first for the intermodal infrastructure 
(terminals,  equipment,  etc.)  but  also  for  supporting  intermodal  operations.  Latvia  considers  the 
situation regarding intermodal transport uneven between different Member States. In those Member 
States with a low population density, the low number of freight movements might not be enough to 
make intermodal transport profitable. 

Second,  there  were  questions  about  financial  support  for  setting  up  new  routes.  Eight  out  of  15 
interviewees (53%) ‘agreed’ or ‘strongly agreed’ with the inclusion of ‘start-up support to the shipper 
or operator for organising a new intermodal transport scheduled route’. Again, the survey revealed 
little experience with such support tools in practice and industry – again from a low level of response 
– felt that the support should be applied as a share of costs (e.g. four out of six transport operators; 
67%) and for these to be funded by the Member State were the costs occurred (e.g. six out of six 
transport operators; 100%). When asked in the interviews about their reasons for being in favour of 

73 

 
start-up support for a new scheduled route, it was noted that starting up long routes was a significant 
financial risk for operators and would often only become financially viable after several months of 
operation. Some industry representatives expressed their concern that new routes might be stopped 
again after support runs out. 

The third set of questions on support tools asked for views on financial support for technological 
upgrades. Six of the proposed support tools received a majority support from interviewees, i.e.:  

1.  Start-up  support  for  agents  for  establishing  an  open  access  consolidation  or  distribution 

centre or platform for intermodal transport (12 out of 14; 86%). 

2.  Financial  support  to  transport  operators  or  transport  chain  organisers  in  intermodal 

transport for ICT upgrades (12 out of 14; 86%). 

3.  Financial  support  to  transhipment  terminal  owners  or  operators  for  acquiring  additional 
clean equipment  for  increasing their handling capacity and ability to  handle new types of 
loading units (11 out of 14; 79%). 

4.  Financial support to transhipment terminal operators for acquiring clean transhipment and 

shunting equipment (11 out of 14; 79%). 

5.  Financial  support  to  transport  operators  for  retrofitting  non-cranable  semi-trailers  into 

cranable semitrailer (10 out of 15; 67%). 

6.  Financial support to transport operators/carriers or transport chain organisers for acquiring 
or/and using ‘clean’ vehicles or  vessels exclusively in  intermodal transport  (10 out  of 15; 
67%). 

15 out of 15 transport operators (100%), underlined that the initial investment costs had impacted 
their introduction of such technologies. The survey again revealed little experience with these support 
tools and again industry –  from a low level of response – also called for the support to be applied as 
a share of costs (e.g. 4 out of 5 terminal operators (80%)). 

The fourth set of questions related to potential regulatory support. Stakeholders ‘agreed’ or ‘strongly 
agreed’ with the inclusion of both of the proposed support tools, i.e. exemption of eligible intermodal 
transport road legs for from national/local traffic bans (13 out of 15; 87%) and allow increased weights and 
dimensions for road vehicles in intermodal transport road legs beyond EU rules (12 out of 15). The survey 
revealed that industry did not agree that these support tools should only apply to zero emission vehicles, 
e.g. 4 out of 5 transport operators disagreed that weekend or peak hour driving bans should only be lifted 
for zero emission vehicles. 

Expected evolution without further action  

Of the survey respondents  and interviewees who responded to  a question about  how the share of 
intermodal transport in their country would evolve without further support over the next decade, all 
but one considered that the share would either stagnate or decline by 2030. When asked about how 
the average costs per transport operation by mode would evolve without further revision of the CTD, 
stakeholders of all groups in the interviews agreed that costs would generally rise in the context of 
overall high inflation. 14 out of 19 of interviewees suggested that the cost of road transport would 
increase by more than 15% by 2030, whereas for other modes, ten out of 19 felt that the costs would 
either increase by at least 5% for rail or they did not know (12 out of 19 for inland waterways) and 
ten out of 19 for short sea shipping). When asked about the effects on costs for different modes of 
the regulatory framework, six out of seven of survey respondents (86%) and 13 out of 18 interviewees 
(72%) thought that costs for road transport would increase. Some respondents thought this also for 
short sea shipping, with five out of seven survey respondents (71%) and seven out of 18 interviewees 
(38%) (with a further nine indicating they do not know) indicating this. 

74 

 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The revision of the CTD aims at increasing the uptake of intermodal transport by making intermodal 
transport more competitive vis-à-vis road-only transport. The costs and benefits of the preferred option 
are expected to fall on different stakeholder groups.  

The preferred policy option is expected to have positive impacts on those involved in intermodal transport 
but may also lead to some negative impacts on those engaged in road-only transport that are not willing to 
shift to providing the intermodal road legs. At the same time, the shippers, while not bearing additional 
costs, will benefit from a wider range of transport options.  

Description of industry stakeholders’ roles and their place in the intermodal chain  

The intermodal transport market consists of four groups of industry stakeholders, defined here by type of 
activity, and Member State authorities. In some cases, the stakeholders participate in several activities in 
the sector and the stakeholder groups may somewhat overlap.  

The goods are owned and shipped by shippers, who have an interest to send the good from place of 
departure to place of arrival. The shippers may organise the transport themselves or hire a logistics 
company or freight forwarder to do the organisation for them. Thus, the shippers and logistics companies 
are treated in this impact assessment as transport organisers. They decide which mode of transport to use 
for the operation and are crucial in achieving modal shift. Some organisers, in particular bigger logistics 
companies, may also be engaged in actual transport activity and act as carriers for parts of the transport 
operation, typically the road leg, but not limited to it. For instance, some large shipping companies are 
developing their own logistics services for roads that connect to maritime services. Similarly, some shippers 
carry out on their own account transport for parts of operation, typically the road-leg.  

Transport carriers are companies actually carrying the goods either on rail (railway undertakings), inland 
waterways (barge operators), short sea shipping (maritime operators) or road (road hauliers). The carriers 
do not decide which mode of transport to choose, but simply carry out the operation as per transport 
contract on the mode of transport they are active in. The exception is the situation where a road haulier 
can decide to take a ferry instead of driving all the way without a transport organiser intervention. 
Sometimes carriers subcontract other carriers either in the same mode or other modes to carry out the 
operation.  

Dedicated companies exist, in particular in rail transport, that organise connections without organising 
door-to-door services or without providing actual transport services. These are known as either multimodal 
transport operators (MTOs) or combined transport operators (CTOs). In this impact assessment, they are 
called connection organisers. These economic agents take the commercial risk of establishing rail services 
between terminals, contract a railway undertaking to carry out the transport and sell “slots” to transport 
organisers on these trains. In such a model, the railway undertaking is not taking any risks as it is always 
paid for running a full-length train. It is the connection organiser that has to find sufficient shippers or 
logistics companies to actually fill the train and cover the costs it pays to the railway undertaking. These 
operators are crucial enablers of intermodal transport as railway undertakings are often unwilling to sell 
rail-space wagon-by-wagon and most shippers do not have sufficient freight to fill full block trains at 
regular intervals. Sometimes, logistics companies can act as connection organisers and sometimes shippers 
create consortiums among themselves to arrange new train services.  

Terminal operators play a part in intermodal transport by transhipping freight between modes. Usually, 
terminal operators do not provide other services in the intermodal chain. Terminals may be owned or be 
affiliated to carriers or connection organisers.  

75 

 
Figure 13: Comparative example of contractual relationships and the flow of goods between different industry 
stakeholders in road-only transport and in intermodal transport 

Finally, the revision has to take into account that modal shift to intermodal transport has an impact on 
those road hauliers who currently carry out road-only long-distance transport. The road hauliers can adapt 
to intermodal market and start providing intermodal road legs.  

All industry stakeholders mentioned, except long-distance road hauliers, are expected to benefit from 
increased competitiveness of the intermodal transport. For the carriers, the logistics companies, the 
volume of their operations and thus turnover will increase. For the connection organisers, their risks are 
reduced and as is investment payback-time. However, this does not necessarily translate into higher profits 
as competition with road-only transport is sharp and any increase in intermodal transport prices to 
shippers will result in operations simply taking place on road-only transport. Similarly, the carriers and 
logistics companies are not expected to raise their prices as the competing road transport price remains a 
constraining factor. For shippers, there is no cost saving impact expected, as the support is expected to 
bring the intermodal transport cost to a comparable level with road-only transport. Thus, for shippers who 
today use road-only transport, the reduction of the intermodal price will not actually affect their costs.  

2.  SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Option (PO-B2a) 

Description 

Amount 

Comments 

Administrative cost 
savings for businesses, 
expressed as present value 
over 2025-2050 relative to 
the baseline  

Administrative cost 
savings for Member State 
authorities, expressed as 
present value over 2025-

Direct benefits 

EUR 4.3 billion  

EUR 2.3 million 

76 

Administrative cost savings derive from 
simplified procedures thanks to the use of 
eFTI digital transport data platforms for proof 
of eligibility and for reporting eligible 
operations in support to the application 
process, as well as from easier access to 
information about upcoming support schemes. 
The beneficiaries are transport organisers. 

Mandatory use of eFTI platforms for proof of 
eligibility reduces the road-side check time. 

 
 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO-B2a) 

Amount 

Comments 

Description 

2050 relative to the 
baseline 

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

Reduction in energy 
consumption (cumulative 
over 2025-2050 relative to 
the baseline) 

Indirect benefits 

EUR 15.3 billion 

10.5 million of tonnes of oil equivalent 

Positive impact on GDP 
relative to the baseline 

GDP increase of 0.1% in 2030 and 0.3% in 
2050 relative to the baseline 

Positive impacts on 
employment relative to the 
baseline (additional 
persons employed over 
2025-2050) 

24,000 additional persons employed in 2030 
and 83,000 in 2050 

Indirect benefit to society at large, as the shift 
from road-only transport to intermodal 
transport saves external costs of GHG 
emissions, air pollutant emissions, noise, 
accidents and congestion 

Indirect benefit to society at large, as the shift 
from road-only transport to intermodal 
transport reduces overall energy consumption. 

Indirect benefit to society at large. The 
increase in the competitiveness of intermodal 
transport operations is expected to have 
knock-on effects throughout the entire 
economy, leveraging the initial impact on the 
transport sector. This is also expected to lead 
to positive impacts on GDP, which is 
estimated to increase by around 0.1% in 2030 
and 0.3% in 2050 relative to the baseline. 

Indirect benefit to society at large. The shift to 
intermodal transport solutions involves several 
transport modes, transhipment and terminal 
services that will generate more employment. 

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

Administrative cost 
savings for businesses 
(annual savings relative 
to the baseline) 

EUR 0.43 billion 

Recurrent administrative cost savings derive 
from simplified procedures thanks to the use 
of eFTI digital transport data platforms for 
proof of eligibility. The beneficiaries are 
transport organisers. 

II. Overview of costs – Preferred option (PO-B2a) 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

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 

Economic cost of support, 
expressed as present value 
over 2025-2050 relative to the 
baseline 

- 

- 

- 

- 

- 

- 

For operators 
in the 
intermodal 
transport: EUR 
0.3 million. 

- 

For the 
European 
Commissio
n: EUR 0.3 
million. 

For the 
European 
Commission: 
EUR 1.7 
million. 

For operators 
in the 
intermodal 
transport: EUR 
6.6 million 

- 

- 

- 

- 

- 

- 

For national 
public 
administratio
ns: EUR 7.5 
billion.  

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

77 

 
 
 
II. Overview of costs – Preferred option (PO-B2a) 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

- 

- 

- 

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

Total   

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting), 
annual costs 
relative to the 
baseline 

- 

- 

- 

For operators 
in the 
intermodal 
transport: EUR 
0.3 million. 

- 

- 

- 

- 

EUR 6,100 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option (PO-B2a) 
Relevant SDG 
SDG 9: Industry, 
innovation and 
infrastructure 

Expected progress towards the Goal 
PO-B2a is expected to result in 6.8% increase 
in intermodal volumes across all non-road 
modes relative to the baseline scenario 
(cumulative over 2025-2050).  

Comments 
This is largely attributed to PM9, PM10, 
PM11 and PM13, which are expected to 
engender an increase in intermodal 
freight transport using support tools. 
These measures are expected to drive a 
shift away from road freight and towards 
rail, IWW and SSS freight transport.  

This is largely attributed to PM9, PM10, 
PM11 and PM13, which are expected to 
engender an increase in intermodal freight 
transport using support tools. The shift 
away from road freight will support a 
reduction in CO2 emissions relative to the 
baseline scenario. 

This is largely attributed to PM9, P10, P11 
and PM13, which are expected to 
engender an increase in intermodal freight 
transport using support tools. The shift 
away from road freight will reduce energy 
consumption as rail, IWW and SSS freight 
transport is more energy efficient per tkm 
transported due to larger loading capacity.  

Indicator: 9.1.2: Passenger 
and freight volumes, by 
mode of transport 

SDG 13: Climate action 

Indicator: 13.2.2: Total 
greenhouse gas emissions 
per year 

PO-B2a is expected to result in a reduction in 
the CO2 emissions of freight transport by 0.7% 
of the CO2 emissions of freight transport in the 
2025-2050 period, relative to the baseline 
scenario.  

SDG 7 - Affordable and 
clean energy 
Indicator: 7.3.1 is the 
"Energy intensity measured 
in terms of primary energy 
and GDP". 

By replacing road-only transport with 
intermodal transport, energy consumption in 
freight transport per tkm transported is 
expected to reduce. Cumulatively over 2025-
2050 period, the energy consumption will 
reduce by 10.5 million of tonnes of oil 
equivalent.  

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1.  DESCRIPTION OF THE ANALYTICAL METHODS USED  

The analytical  framework used for the purpose of this impact assessment builds on the PRIMES-
TREMOVE, ASTRA and TRUST models, and the assessment of the administrative costs, etc.138. 

The baseline scenario has been developed using the PRIMES-TREMOVE model by E3Modelling. PRIMES-
TREMOVE 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’ 
package, the impact assessments accompanying the 2030 climate target plan139 and the staff working 
document accompanying the sustainable and smart mobility strategy140, the Commission’s proposal for a 
long term strategy141 as well as for the 2020 and 2030 EU’s climate and energy policy framework.  

ASTRA and TRUST are the main models used to assess the policy measures and options presented in this 
impact assessment. For the baseline scenario they have been calibrated on the results of the PRIMES-
TREMOVE model.  

The proposed measures are assumed to be implemented from 2025 onwards, so that the assessment has 
been undertaken for the 2025-2050 period and refers to EU-27. Costs and benefits are expressed as 
present value over the 2025-2050 period, using a 3% discount rate. 

1.1. 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 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.  

138 Ricardo et al. support study (2023), op.cit.  
139 SWD/2020/176 final. 
140 SWD/2020/331 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0331  
141 2050 long-term strategy (europa.eu)   

79 

 
 
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 TREMOVE142 modelling community. Part of 
the model (e.g. the utility nested tree) was built following the TREMOVE model143. 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 
figures’144. 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. 

1.2. TRUST - TRansport eUropean Simulation Tool 

TRUST is a European scale transport network model developed and maintained by TRT and simulating road, 
rail, inland waterways and maritime transport activity. TRUST covers the whole Europe and its 
neighbouring countries and it allows for the assignment of passenger and freight origin-destination (OD) 
matrices at NUTS3 level of detail (about 1,600 zones) on the multimodal transport network145.  

Road, rail, inland waterways and maritime transport modes are covered in separate modules, each with its 
own matrices that are then assigned simultaneously on the multimodal transport network.  

TRUST  is  built  in  PTV-VISUM  software  environment.  The  assignment  algorithm  used  is 
Equilibrium Assignment which distributes demand for each origin/destination pair among available 
alternative routes, according to Wardrop first principle. This principle assumes that each traveller is 
identical, non-cooperative and rational in selecting the shortest route, and knows the exact travel time 
he/she will encounter. If all travellers select routes according to this principle the road network will 
be at  equilibrium, such that  no one can reduce their travel  times by unilaterally choosing another 
route of the same OD pair. This principle has been extended to consider generalised travel cost instead 
of travel time, where generalised travel cost can include the monetary cost of in-vehicle travel time, 
tolls, parking charges and fuel  consumption costs. The impedance function is defined in terms of 
generalised time from an origin O to a destination D. Travel costs are defined separately by link types 
using  combinations  of  fixed,  time-dependent  and  distance-dependent  parameters.  Travel  time  is 
estimated endogenously by the model as result of the assignment. Speed-flow functions are used to 
model the impact of traffic on free-flow speeds, given links capacity. The model iterates until a pre-
defined convergence criterion for equilibrium is reached. 

TRUST can simulate various transport policy measures at network level and at European scale for 
road,  rail,  maritime  and  inland  waterways.  It  is  particularly  suitable  for  modelling  policies  in  the 
fields of infrastructure, infrastructure charging, etc.  

The TRUST model has an internal mode choice module which allows to estimate modal split for 
various  scenarios.  Future  trends  of  transport  demand  by  mode  coming  from  ASTRA  are  used  to 

142 https://www.tmleuven.be/en/navigation/TREMOVE.    
143 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. 
144 Statistical Pocketbook (2022), https://transport.ec.europa.eu/media-corner/publications/statistical-pocketbook-
2022_en . 
145 Further information on TRUST is available on http://www.trt.it/en/tools/trust/  

80 

 
 
estimate total demand and then split by mode according to new travel time and costs deriving from 
infrastructure development and policies implementation. 

The TRUST road model deals with the assignment of road transport origin-destination matrices for 
both passenger cars and trucks above 3.5t. The road network covers all relevant links between the 
NUTS-3  regions,  including  motorways,  primary  roads,  and  roads  of  regional  and  sub-regional 
interest. Ro-Ro ferry services are also explicitly modelled. TRUST rail network includes different 
link  types  (conventional,  high  speed,  border  rail  link,  by  user  group).  Rail  supply  includes  also 
intermodal  terminals  for  load  transfer  between  road  and  rail.  Interchange  with  maritime  mode  is 
modelled  where  existing.  Demand  is  segmented  according  to  different  train  types  (three  for 
passengers and two for freight). TRUST inland waterways network includes all main canals and 70 
inland ports across Europe. Each link has specific features on free-flow speed, class of the canal, 
draught and capacity. Inland waterways demand matrices are segmented in two categories (container; 
non-container).  TRUST  inland  waterways  assignment  is  performed  according  to  an  AON  (all  or 
nothing) algorithm.The maritime model includes almost 200 ports across Europe and all sea routes 
between ports. Access to maritime mode is direct for those zones with ports and by feeder modes 
(road, rail or inland waterway) for zones without ports. Thus, the model simulates complete freight 
origin-destination paths. Time and costs at ports are considered in the calculation of the generalised 
cost. Maritime demand matrices are segmented into container, bulk and general cargo.  

The TRUST model is a well established model that has been used for numerous impact assessments 
in the transport field over the past 15 years. So far, the model has not undergone a formal scientific 
review by a panel of external experts. 

In the context of this impact assessment, the TRUST network model was used for: 

•  Testing and fine-tuning some of the policy measures to be implemented and combining them in 

policy options. 

•  Analysing the eligibility criteria defined in the policy options based on the distribution of tkm by 

distance bands in the TRUST model. 

•  Assessing the share of traffic which cannot benefit from economic support. 

In addition, TRUST was used to quantify the modal shift expected over the time horizon of the impact 
assessment  (2030,  2040  and  2050)  resulting  from  the  implementation  of  those  policy  measures 
providing an operational economic support to the non-road modes. 

More  specifically,  the  model  was  used  to  assess  the  impact  of  reductions  in  transport  costs  and 
transhipment  costs  for  policy  measures  foreseeing  a  contribution  to  eligible  operations  (i.e.  those 
determining a reduction of cost for non-road modes) to transport operators or shippers . The impact 
was calculated in terms of percentage change in transport activity (tkm) relative to the baseline for 
each mode for the intra-EU27 flows. 

Intermodal transport chains are simulated by TRUST as “unitised” transport flows composed of:  

Initial road leg (from origin of goods to departure terminal) 

• 
•  Transhipment (at the departure terminal) 
•  Non-road main mode leg (either rail, inland waterway or short-sea shipping) 
•  Transhipment (at the arrival terminal) 
•  Final road leg (from the arrival terminal to the destination of goods) 

Figure 14: TRUST modelling of unitised transport flows 

81 

 
Source Ricardo et al. support study (2023) 

Therefore,  the  assessment  of  the  policy  measures  with  the  TRUST  model  entailed  applying  the 
reduction of the transport costs for non-road main mode legs (i.e. point c)) and of transhipment costs 
at terminals (i.e. points b) and d)). 

Data inputs 

The main data sources for inputs to the TRUST model are the EUROSTAT database and the Statistical 
Pocketbook ‘EU transport in figures’146, TENtec Information system147 and ETISplus database. 

1.3. ASTRA - ASsessment of TRAnsport Strategies 

ASTRA is a strategic model based on the Systems Dynamics Modelling approach simulating the transport 
system development in combination with the economy and the environment until the year 2050148.  

ASTRA consists of different modules, each related to one specific aspect such as the economy, transport 
demand or the vehicle fleet. The main modules cover the following aspects: 

1.  Population and social structure (age cohorts and income groups) 

2.  Economy (e.g. GDP, input-output tables, employment, consumption and investment both at aggregate 

and at sectoral level) 

3.  Foreign trade (inside EU and to partners from outside EU) 

4.  Transport (including demand estimation, modal split, transport cost and infrastructure networks) 

5.  Vehicle fleet (passenger and freight road vehicles by segment and drivetrain) 

6.  Environment (including air pollutant emissions, CO2 emissions, energy consumption). 

The economy module simulates the main economic variables. Some of these variables (e.g. GDP) are 
transferred to the transport generation module, which uses the input to generate a distributed transport 
demand. In the transport module, demand is split by mode of transport. The traffic performance by mode 
is associated with the composition of the fleet (computed in the vehicle fleet module) and the emissions 
factors (defined in the environmental module), in order to estimate total emissions. 

Several feedback effects take place in the ASTRA model. For instance, the economy module provides the 
level of income to the fleet module, in order to estimate vehicle purchase. The economy module then 
receives information on the total number of purchased vehicles from the fleet module to account for this 
item of transport consumption and investment. Furthermore, changes in the economic system 
immediately feed into changes of the transport behaviour and alter origins, destinations and volumes of 
European transport flows. 

The indicators that ASTRA can produce cover a wide range of impacts; in particular transport system 
operation, economic, environmental and social indicators. The environment module uses input from the 
transport module (in terms of vehicle-kilometres-travelled per mode and geographical context) and from 
the vehicle fleet module (in terms of the technical composition of vehicle fleets), in order to compute fuel 

146 Statistical Pocketbook (2022), op.cit. 
147 https://ec.europa.eu/transport/themes/infrastructure-ten-t-connecting-europe/tentec-information-system_en  
148 A detailed description of the model is available at http://www.astra-model.eu/index.htm 

82 

 
 
 
consumption, greenhouse gas emissions and air pollutant emissions from transport. ASTRA also estimates 
the upstream emissions (well-to-tank) due to fuel production and vehicles production. Therefore, well-to-
wheel emissions can be provided as well. 

Strategic assessment capabilities in ASTRA cover a wide range of transport measures and investments with 
flexible timing and levels of implementation.  

Geographically,  ASTRA  covers  all  EU  Member  States  plus  the  United  Kingdom,  Norway  and 
Switzerland. The model is built in Vensim software and is developed and maintained by TRT, M-
Five and ISI Fraunhofer. 

The ASTRA model is a well established model that has been used for numerous impact assessments 
in the energy, transport and climate action fields for the past 15 years. A dedicated version of the 
ASTRA model was developed by TRT and M-Five on behalf of JRC and is being used since 2013, 
when the first version was developed as part of the ASSIST project149.  

So far, the model has not undergone a formal scientific review by a panel of external experts. 

In the context of this impact assessment, the ASTRA model was used to estimate the wider impacts 
of the policy measures and options in terms of GDP, GHG emissions, air pollution emissions and 
other  external  costs  of  transport.  To  this  aim,  the  ASTRA  model  has  used  as  input  the  estimated 
increase in the unitised transport from the TRUST model. To monetise the external costs, the unit 
values from the Handbook on the external costs of transport150 have been used. 

Data inputs 

ASTRA is calibrated on the EUROSTAT database and data from the Statistical Pocketbook ‘EU transport in 
figures’151.  

1.4. Cost model  

The assessment of the transport costs by mode was performed on the basis of specific cost assumptions 
highlighting the contribution of the various legs of intermodal transport. They reflect the transport costs by 
mode and the costs of transhipments.  

The following modes have been considered separately 

1.  Long distance road transport (truck used as main mode or as long-distance feeder mode); 
2.  Short distance road transport (truck used as feeder mode); 
3.  Rail intermodal; 
4.  IWW intermodal; 
5.  SSS – Roll-on/roll-off (RoRo); 
6.  SSS – Lift-on/lift-off (LoLo). 

In order to provide reliable estimates of the average costs, costs have been assessed on representative 
distances. To this end typical cases have been represented by different distance thresholds: short (300 km), 
medium (600 km) and long (1000 km). In the case of short distances (300 km), RR is typically more costly 
than an all-road solution. The same 300km distance threshold can be suitable for IWW-intermodal 
combination, because the cost difference of the inland waterway leg and road transport per unit 
transported is bigger, and the road legs are very short and thus have little impact on costs. In the case of a 
medium distance range (600 km), intermodal solutions become more competitive with single mode road 

149 Assist-Project - ASSIST 
150 CE Delft et al. (2019). op.cit.  
151 Statistical Pocketbook (2022), op.cit.   

83 

 
 
transport while in the case of long-distance example (1000 km and more) intermodal in almost all cases is 
the best option.  

Other elements having an impact on the average costs are attributed to the average composition of traffic 
in terms (number of units carried on a train, balance of flows on the round trip, etc.). The objective of the 
cost model was to provide an assessment of the various components of the costs, to give an indication of 
the likely evolution of costs over time. The underlying assumption has been that costs represent a good 
approximation of transport prices. Regional differences in transport cost were considered to take into 
account for example differences in drivers’ wages or level of tolls and track access charge levied in the 
different countries.  

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 
REF2020152. The same assumptions have been used in the policy scenarios underpinning the impact assessments 
accompanying the “Fit for 55” package153.  

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 Eurostat154 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 2021155 by the Directorate General for Economic and Financial Affairs, which are 
based on the same population growth assumptions. 

Table 26: Projected population and GDP growth per Member State 

Population 

GDP growth 

EU27 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

2020 

447.7 

8.90 

11.51 

6.95 

4.06 

0.89 

10.69 

5.81 

1.33 

5.53 

2025 

449.3 

9.03 

11.66 

6.69 

3.94 

0.93 

10.79 

5.88 

1.32 

5.54 

2030 

449.1 

9.15 

11.76 

6.45 

3.83 

0.96 

10.76 

5.96 

1.31 

5.52 

2020-‘25 

2026-‘30 

0.9% 

0.9% 

0.8% 

0.7% 

0.2% 

0.7% 

1.6% 

2.0% 

2.2% 

0.6% 

1.1% 

1.2% 

0.8% 

1.3% 

0.6% 

1.7% 

2.0% 

1.7% 

2.6% 

1.2% 

152 EU Reference Scenario 2020, op.cit. 
153 Policy scenarios for delivering the European Green Deal (europa.eu) 
154 EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu)   
155  The  2021  Ageing  Report :  Underlying  assumptions  and  projection  methodologies  The  2021  Ageing  Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)   

84 

 
 
  
 
France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Population 

GDP growth 

2020 

67.20 

83.14 

10.70 

9.77 

4.97 

60.29 

1.91 

2.79 

0.63 

0.51 

17.40 

37.94 

10.29 

19.28 

5.46 

2.10 

47.32 

10.32 

2025 

68.04 

83.48 

10.51 

9.70 

5.27 

60.09 

1.82 

2.71 

0.66 

0.56 

17.75 

37.57 

10.22 

18.51 

5.47 

2.11 

48.31 

10.75 

2030 

68.75 

83.45 

10.30 

9.62 

5.50 

59.94 

1.71 

2.58 

0.69 

0.59 

17.97 

37.02 

10.09 

17.81 

5.44 

2.11 

48.75 

11.10 

2020-‘25 

2026-‘30 

0.7% 

0.8% 

0.7% 

1.8% 

2.0% 

0.3% 

1.4% 

1.7% 

1.7% 

2.7% 

0.7% 

2.1% 

0.8% 

2.7% 

1.1% 

2.1% 

0.9% 

1.4% 

1.0% 

0.7% 

0.6% 

2.6% 

1.7% 

0.3% 

1.9% 

1.5% 

2.0% 

4.1% 

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 package156.  

Table 27: Oil prices assumptions  
Oil 

in $'15 per boe 

in €'15 per boe 

Technology assumptions 

2015 

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 11 
November 2019. EU Member States representatives also had the opportunity to comment on the costs 
elements during a workshop held on 25 November 2019. The updated technology assumptions are 

156 SWD(2022) 230 final. 

85 

 
 
  
 
 
published together with the EU Reference Scenario 2020157. The same assumptions have been used in the 
context of this impact assessment. 

Other input data and assumptions for the base year   

Intermodal transport  

The size of the intermodal  transport market  in the EU27  is defined starting from the most recent 
studies available on the topic. The 2017 study by ISL, KombiConsult158 indicates that in 2015 the 
intermodal transport sector moved a total of 534 bn tkm, considering the EU27 only159. In terms of 
volumes of container transported, the same study estimates that approximately 56 million TEU per 
year were transported in the EU27. Most traffic is linked to maritime transport, followed by rail and 
inland waterways. In particular, SSS represents 68% of EU27 intermodal transport activity, and 57% 
of container traffic. RR covers instead 29% of all tonnes moved in EU27, and 32% of the volumes 
of containers. Transport by IWW, which is relevant only within a limited number of river basins, 
accounts for 3% of tonnes moved and 11% of container traffic, respectively (see Table 27). 

Table 28: EU 27 freight transport activity (billion tkm) and volumes transported (mTEU) in the intermodal transport 
sector (2015) 

Rail/road 

Freight transport activity 
% 
29% 

Gtkm 
152 

Volumes 

mTEU* 
18 

% 
32% 

IWW/road 
SSS/road 
Total 

3% 
68% 
100% 
Source: Ricardo et al. support study (2023); Note: * includes double counting of SSS-rail and SSS-IWW traffic (5%). 

11% 
57% 
100% 

6 
32 
56(1) 

16 
366 
534 

Compared  against  figures  on  the  total  freight  transport  activity  provided  in  the  Statistical 
Pocketbook160 it is estimated that intermodal transport accounted for nearly 27% of all EU27 (non-
road) freight transport activity in 2015. Considering the various modes, in 2015 the share of transport 
activity  carried  out  with  intermodal  units  was  estimated  to  be  31%  and  29%  for  rail  and  SSS 
respectively, while for IWW this share was lower, at around 9%. 

Taking into account the EU27 intermodal transport activities that meet the definition of CT of the 
current CTD161, it can be estimated that the scope of application of the current CTD is limited to 
about 12% of the total freight transport carried out by non-road modes. As shown in Table 28, the 
scope of application ranges from 19% for rail to 10% and 6% respectively for SSS and IWW.  

Focusing on the scope of application of the CTD within the intermodal transport sector only, the CTD 
covers approximately 45% of the overall EU27 intermodal (non-road) transport activity. The share for SSS is 
estimated to be much lower than that of rail and IWW, as only 36% of SSS intermodal operations comply 
with the CTD definition (compared to 60% and 68% for rail and IWW respectively). This is mainly due to the 
fact that many SSS intermodal operations are domestic and that, for those that are international (intra-EU), 
some involve a road leg of more than 150 km. 

157 EU Reference Scenario 2020 (europa.eu) 
158 ISL, KombiConsult (2017), op.cit. 
159 In this section, the intermodal transport market is  defined considering only intermodal transport activity in EU27, 
which as provided in  ISL, KombiConsult (2017) includes domestic and intra-EU intermodal transport activities only. 
International activities, including intermodal traffic between EU borders or ports and third countries such as deep-sea 
maritime transport, are also provided in the study but have not been considered.  
160 Statistical Pocketbook (2022), Op. cit. 
161 ISL, KombiConsult (2017), op.cit. 

86 

 
 
 
 
Table 29: Share of intermodal freight transport in total freight transport activity (billion tkm), and of intermodal 
transport activity covered by the current CTD (EU27, 2015) 

Freight transport activity (Gtkm) 

Shares (%) 

Total 

Intermodal 
(non-road legs) 

Covered by 
the CTD 

Intermodal in 
total activity 

(c) 
74 
9 
89 
172 
Source: Ricardo et al. support study (2023). Note: * includes only domestic and intra-EU27 transport 

(a) 
396 
147 
864 
1 407 

(b/a) 
31% 
9% 
29% 
27% 

Rail 
IWW 
SSS * 
Total 

(b) 
123 
14 
248 
385 

Covered by 
CTD as % of 
total activity 
(c/a) 
19% 
6% 
10% 
12% 

Covered by CTD 
as % of 
intermodal 
(c/b) 
60% 
68% 
36% 
45% 

Transhipment 

Transhipment between modes represent an additional key element in intermodal transport chains, and 
various studies analyse the volume of operations and the performance of intermodal terminals in the 
EU. In 2015, terminals in EU27 carried out an average of over 58 million transhipment operations 
per year, of which approximately 38 million (65%) are at seaports, 28% at hinterland rail terminals, 
and 6% in the IWW/road sector (see Table 29).   

Table 30: Transhipment operations in EU27 (2015) 

Annual number of transhipments (million) 

Share of total 

Rail/road 
IWW/road 
SSS/road 
Total 

Source: Ricardo et al. support study (2023). 

Cost of transport 

17 
4 
38 
58 

28% 
6% 
65% 
100% 

The cost of rail transport is estimated based on a bottom-up approach combining the following categories 
of costs: costs related to locomotives (including interest, depreciation, maintenance, etc.), driver costs, 
other operation costs such as electricity costs and track access charges (TAC). In order to get comparable 
data with the all-road transport, some assumptions had to made with respect to the composition of the 
trains (number of wagons and locomotive), load factors, weight of tares (container, semi-trailer, swap 
bodies), length and weight of the train, average speed (45-50 km/h), single trip/round trip. The cost per 
intermodal train-km is estimated in the range of 12-15 EUR/train-km, also depending on the country (there 
are differences with respect to driver wages, TAC and electricity costs). To this, shunting operations and 
terminal handling (included in transhipment costs) need to be added. Over the past years, changes have 
been observed in TAC (as in several countries they have been reduced to support the sector) and in 
electricity prices (in particular current price are far higher compared to a year ago). 

The average cost for container transport by inland waterway, taking into account a typical barge of 600 
TEU over a navigation distance of 250 km is estimated to be around 0.03EUR/t-km. The cost does not 
include terminal handling, which needs to be added. 

The average cost for container transport by short sea shipping, taking into account typical ships between 
600 and 2500 TEU mostly used for feeder services, is estimated to be around 0.13-0.14 EUR/TEU-km. In Ro-
Ro transport, the unit transported are trucks or semitrailer driven onto a ferry, which can be accompanied 
or not accompanied. The semitrailers as units are more commonly shipped unaccompanied, and ships carry 
between 150 and 200 units over an average distance of 500 km. The unit price is estimated to be around 
0.6 EUR per unit per km. Since the semitrailer can be considered equivalent to 2 TEU, the cost per TEU is 
estimated to be in the range of 0.3 EUR/TEU-km. For longer distances the unit price is decreasing. To this, 
the container handling in port terminal needs to be added the cost of container handling. 

87 

 
 
 
 
 
For road legs, the main input data included the costs related to vehicles (purchase/lease, interest/capital 
cost, taxes, maintenance), other operation costs (fuel and additives, tyres, lubricants), driver costs, tolls 
and other costs such as overheads, based on the following assumptions: 

1.  Yearly mileage: typically, heavy goods vehicles used for long distance transport travel 100,000-

120,000 km per year162.    

2.  The average speed, assumed in the 60-65 km/h range, is also affecting the unit cost as many cost 

components depend on the time spent. 

3.  Fuel consumption: current consumption rate is assumed on long distance at around 32 litre/100 
km163.  This is assumed to decrease over time following the baseline projections results provided 
by the PRIMES-TREMOVE model, taking into account the stricter limits set by emission standard 
regulations  and  the  use  of  alternative  fuels.  In  the  long  term,  the  projected  shift  to  electrified 
powertrains is expected to reduce this cost component.  

4.  Road transport assumptions for feeder services (pre and post haulage) see a higher unit cost per 
km. This is because of the higher time dependency of the cost (waiting times), and consequently 
on the shorter distance driven on a yearly basis.   

Finally, the cost of transhipments is based on input from a 2017 study by TRT164 and a more recent study on 
transhipment technologies by PWC165. An average cost has been considered taking into account the weight 
of the different type of units. In the former it was estimated e.g. that the costs per transhipment are on 
average EUR 51 in the RR sector, EUR 42 for IWW/road, and EUR 67 for SSS/road. More granular 
information on transhipment costs is provided in the latter, showing for instance how transhipment costs 
vary depending on the technology used, the type of loading unit, as well as the transport modes 
concerned. The study also provides information on the distribution of costs among different components 
(i.e. investment, operation, and ground costs).  

Policies in the Baseline scenario  

Building on the EU Reference scenario 2020, the impact assessments accompanying the ‘Fit for 55’ 
initiatives proposed by the Commission on 14 July 2021166 considered several scenarios relying on 
regulatory measures and carbon pricing. They took into account a broader range of policies (including this 
initiative as well as the initiatives on rail capacity, the revision of the Weights and Dimensions Directive and 
the CEEU), 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. The scenario reflecting the preferred policy options of the impact assessments accompanying 
the proposals considered a balanced approach, showing a combined approach of carbon pricing 
instruments and regulatory-based measures (including this initiative as well as the initiatives on rail 
capacity, the revision of the Weights and Dimensions Directive and the CEEU) to deliver on the increased 
climate ambition. The staff working document accompanying the REPowerEU initiatives167 took as a 
starting point the scenario of the ‘Fit for 55’ package showing a combined approach of carbon pricing 
instruments and regulatory-based measures and additionally included the proposed revision of the 
Renewable Energy Directive and Energy Efficiency Directive. All these scenarios share the same macro-

162 The value usually found in literature are between 100 and 130 thousand km. See for example the analysis performed 
by the Comité national routier (https://www.cnr.fr/en/espace-europe). 
163 This variable can be retrieved for example from CNR analyses, http://www.cnr.fr  
164 TRT (2017), op.cit. 
165 PWC, KombiConsult (2022), op.cit.   
166 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en 
167 SWD(2022) 230 final. 

88 

 
 
economic and technology assumptions and also include the policy measures part of the EU Reference 
scenario 2020. 

The baseline scenario for this impact assessment builds on the EU Reference scenario 2020 (similarly to the 
‘Fit for 55’ and REPowerEU scenario) and thus share the same macro-economic and technology 
assumptions. It also includes all the policy measures part of the EU Reference scenario 2020. In addition, 
the baseline scenario has been designed to include the ‘Fit for 55’ initiatives and the REPowerEU initiatives 
while excluding this initiative and other initiatives part of the forthcoming Greening Freight package 
(initiatives on rail capacity, the revision of the Weights and Dimensions Directive and the CountEmissions 
EU). In other words, the baseline scenario of this initiative does not include the proposed revision of the 
CTD but only the current CTD. 

The baseline also incorporates foresight megatrends168 and developments captured in the 2022 Strategic 
Foresight Report169. 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 2021170 by the Directorate General for Economic and Financial Affairs. 

Baseline scenario results 

EU  transport  activity  is  projected  to  grow  post-2020,  following  the  recovery  from  the  COVID 
pandemic. Road transport would maintain its dominant role, its activity going up by 29.1% by 2030 
relative  to  2015  (48.9%  for  2015-2050).  Rail  transport  activity  is  projected  to  grow  significantly 
faster than road, driven in particular by the gradual completion of the TEN-T network, supported by 
the  Connecting  Europe  Facility,  Cohesion  Fund  and  the  European  Regional  Development  Fund 
funding.  Measures of the ‘Fit for 55’ package also increase to some extent the competitiveness of 
rail and of waterborne transport relative to road transport. Freight rail traffic would increase by 42.2% 
by 2030 relative to 2015 (96% for 2015-2050), hence falling short of the milestone of the SSMS of 
increasing  the  traffic  by  50%  by  2030  and  doubling  it  by  2050.  Inland  waterways  and  short  sea 
shipping activity is projected to go up by 21.1% by 2030 relative to 2015 (49.5% for 2015-2050), 
also falling short of the milestone of the SSMS, in particular for 2030 (i.e. increase inland waterways 
and short sea shipping traffic by 25% by 2030 and by 50% by 2050).  

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 transport171 are projected to be 24% lower by 2030 compared to 2015, and 87% 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 initiatives172, showing a combined approach of 
carbon pricing instruments and regulatory-based measures to deliver on the increased climate ambition. It 
should be noted that the scenarios underpinning the impact assessments accompanying the ‘Fit for 55’ 
initiatives and the staff working document accompanying the REPowerEU initiatives took into account a 
broader range of policies (including this initiative) that were represented in a stylised way ahead of the 

168 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
169 COM(2022) 289 final of 29 June 2022. 
170  The  2021  Ageing  Report:  Underlying  assumptions  and  projection  methodologies,  The  2021  Ageing  Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu).   
171  Including international aviation but excluding international maritime. 
172  SWD(2022) 230 final. 

89 

 
 
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. The scenario reflecting the ‘Fit for 55’ initiatives, the 
REPowerEU initiatives and the forthcoming initiatives shows the need to reduce emissions from transport 
by 26% by 2030 relative to 2015 and by 94% by 2050. Therefore, this initiative contributes towards the at 
least 55% emissions reductions target by 2030 and achieving climate neutrality by 2050. 

NOx emissions are projected to go down by 56% between 2015 and 2030 (85% 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 52% relative to 2015 (90% by 2050). 

Intermodal transport 

Drawing on the baseline projections for the freight transport activity, other information available from the 
literature and modelling inputs, Table 30 presents the projected evolution of the intermodal transport 
activity for the different combinations of modes for EU27. Total intermodal transport activity is projected 
to grow by around 34% between 2015 and 2030 and 95% between 2015 and 2050. The largest growth is 
estimated to take place in the intermodal RR sector, which is expected to more than double between 2015 
and 2050 (170% increase), while the increase in the SSS and IWW intermodal sectors is expected to be 
lower, at around 60% and 37% respectively. 

Table 31: EU27 freight transport activity (billion tkm) and percent changes (2015-2030 and 2015-2050) in the 
intermodal transport sectors 

Intermodal freight 
transport activity 
(non-road legs)  
Rail/road 

IWW/road 
SSS/road 
Total 

2015 

2020 

2030 

2040 

2050 

123 

14 
248 
385 

134 

13 
274 
420 

191 

14 
310 
516 

271 

16 
355 
642 

334 

19 
398 
750 

2015-
2030 

55.1% 

3.6% 
25.0% 
33.9% 

2015-
2050 

170.5% 

37.4% 
60.2% 
94.7% 

Source: Ricardo et al. support study (2023)  

The projected growth in the different intermodal sectors is driven by two main factors: the increase over 
time in the overall EU freight transport activity, and the increasing role that unitised transport is expected 
to have within the EU freight market. There is a clear trend in the EU indicating that freight is increasingly 
moved in unitised loads, making intermodal one of the fastest growing segments in the EU freight 
transport market. A recent survey on the rail freight market suggests e.g. that between 2009-2019 
intermodal rail transport grew by almost 50% (compared to 16% growth for the overall rail freight) and 
predicts that this trend will consolidate in future years173.  

The baseline projections presented in Table 30 have been defined using a more conservative approach, 
considering in particular that, despite the strong potential highlighted by industry players, constraints in 
terminal capacity will likely remain an issue in future years especially in the rail sector174. As a result, the 
baseline projections show that intermodal transport will reach a share of nearly 34% of the overall EU rail 
freight market by 2030, and further up to 43% by 2050. Intermodal transport in the SSS sector is expected 
to perform just above average compared to the overall short sea shipping market, going up from the 
current market share (29%) to 31% in 2050. The growth for the IWW sector is projected to be more aligned 
to that of total inland waterway freight transport, i.e. maintaining a constant market share of 9%. 

173 According to UIC-UIRR (2020), in the period 2009-2019 intermodal rail transport activity (tkm) has grown by almost 
50% (compared to 16% of total rail freight transport). Such increasing trend is estimated to continue also in future years, 
with intermodal rail freight volumes growing by an additional 47% by 2049, reaching an annual volume of over 278 
Gtkm and a market share in the rail freight market of over 50%. 
174 The PWC, KombiConsult study (2022) estimates that terminal capacity in the EU will increase by only 18% untill 
2030, considering current plans for both terminal upgrades and new terminal constructions. 

90 

 
 
Finally, considering the share of activity covered by the current CTD as estimated by ISL, KombiConsult 
(2017)175, the volumes falling within the scope of the current CTD in the baseline were estimated (see Table 
31). Without EU level action, in the baseline scenario the scope of application of the current CTD is 
assumed to remain unchanged until 2050, so that the shares of freight transport activity covered by the 
CTD remain the same as reported in Table 28. This implies that the freight activity covered by CTD grows at 
the same rate as the intermodal freight transport activity (i.e. 170% increase for rail, 60% for SSS, and 37% 
for IWW).  

Table 32: EU27 intermodal freight transport activity (billion tkm) covered by the CTD, and percent changes (2015-
2030 and 2015-2050)  

Intermodal freight transport 
activity (non-road legs) 
Rail/road 
IWW/road 
SSS/road 
Total 

2015 

2020 

2030 

2040 

2050 

2015-2030 

2015-2050 

74 
9 
89 
172 

80 
9 
98 
187 

115 
10 
111 
235 

163 
11 
127 
301 

201 
13 
142 
356 

55.1% 
3.6% 
25.0% 
36.8% 

170.5% 
37.4% 
60.2% 
106.6% 

Source: Ricardo et al. support study (2023) 

Cost comparison 

In order to compare intermodal operations with road-only alternatives, costs were calculated for a 
range of cases. Fixed road legs distances were assumed based on the median distances established in 
the 2017 study by ISL, KombiConsult176:  

Figure  15  shows  the  distances  at  which  such  intermodal  operations  become  price-competitive  or 
break even with road-only transport, by modal combination.  

Figure 15: Cost comparison of select intermodal operations with road-only alternative 

Source: Ricardo et al. support study (2023) 

175 KombiConsult (2017), op.cit. 
176 Ibid. 

91 

 
   
 
 
3.  IMPACTS ON COSTS AND COSTS SAVINGS PER POLICY MEASURE 

This section provides an assessment of the impacts by policy measure or group of policy measures, 
where relevant. The synergies between the policy measures included in the policy options are also 
taken into account where relevant.  

3.1. Provide support to a wider range of operations under effective eligibility conditions (PM1-PM3) 

3.1.1. Measures PM1 and PM2 – eligibility conditions 

Under PM1 and PM2 the scope of eligibility for support is extended to all intermodal operations in 
the EU that deliver a minimum level of savings of external costs compared to road-only transport. 
Domestic, operations between Member States and the EU-part of international operations with third 
countries would be covered as long as the operation taking place within EU delivers the required 
savings. The eligibility for support is based only on actual socio-environmental merits avoiding the 
abstract leg-distance definition for eligibility in the current CTD. 

Socio-environmental merits 

For defining the socio-environmental merits, three main criteria were analysed: 
1. 

establish which externalities ensure meaningful eligibility today but also  in the future taking 
into account the projected changes in transport externalities per mode up to 2050;  
establish which level of external costs savings ensures that all three non-road modes (rail, inland 
waterways, short sea shipping) would be eligible at a reasonable level; 
establish which level of external costs savings ensures that major part of operation is on non-
road.  

2. 

3. 

Two policy measures were assessed with regard to the socio-environmental merits: one looking at 
the GHG emissions (PM1) and another one at a broader set of externalities including GHG emissions, 
air pollution, congestion, accidents and noise  (PM2) that an intermodal transport operation  would 
allow to save as compared to a corresponding unimodal road-only transport operation between the 
same starting and ending points.  

The level of externalities and the potential socio-environmental advantages of an intermodal transport 
operation vary depending on a wide range of factors, including transport-specific conditions (mode 
combinations, distance covered, etc.) and environmental and location-specific factors (geographical 
scope, level of congestion, etc.). As it is not possible to assess in detail the externalities related to all 
different  intermodal  and  road-only  transport  operations  in  EU,  the  impacts  of  PM1  and  PM2  are 
assessed based on average externality factors per unit of transport activity (e.g., GHG emissions per 
ton-km travelled by a certain mode or combination of modes). More specifically: 

a)  As regards PM1, average GHG emission factors were estimated for each mode considering 

the emissions per unit of transport activity (tkm) from the baseline scenario; 

b)  With respect to PM2, average externality factors beyond GHG emissions were derived from 
the 2019 Handbook on the external costs of transport177. In particular, the average (monetary) 
value of the external costs of freight transport can be used for a comprehensive comparison 
of the level of externalities linked to different types of transport activities. 

Table 33: Average external costs of freight transport (EUR-cent/tkm), 2016 values178 

177 CE Delft, 2019. 
178 Noise costs for inland waterway transport and maritime transport are not considered in the 2019 Handbook on the 
external costs of transport. The noise emission factors for these transport modes are relatively low as activity usually take 
place in sparsely populated areas. Maritime transport can also have an impact on habitats. However, the habitat damage 
costs have not been considered in the 2019 Handbook on the external costs of transport. Generally, there  are limited 
studies covering the external costs of habitat damage due to transport activities. 

92 

 
 
Cost category 
Accidents 
Air Pollution 
Climate change 
Noise 
Congestion 
Well-to-Tank 
Habitat damage 
Total 

HGV 
1.3 
0.8 
0.5 
0.5 
0.8 
0.2 
0.2 
4.2 

Rail 
0.1 
0.2 
0.06 
0.6 

0.2 
0.2 
1.3 

IWW 
0.1 
1.3 
0.3 

0.1 
0.2 
1.9 

Maritime 

0.4 
0.2 

0.1 

0.7 

Source: European Commission (2019) 

For the analysis of the impacts until 2050, the baseline projections for the evolution of the level of 
externalities produced by the different modes of transport were considered, which acccouts for the 
use  of  less  polluting  and  more  energy  efficient  vehicles  in  EU  freight  transport  operations.  The 
evolution of the well-to-wheel GHG intensity for each mode of transport in the baseline scenario for 
2015-2050 is provided in Table 33179.  

Table 34: Evolution of GHG intensity by transport mode for 2015-2050 in the baseline scenario (2015=100) 

Mode 

Road 

Rail 

Inland waterways 

Short sea shipping 

Source: Ricardo et al. support study (2023)  

2015 

2030 

2040 

2050 

100 

100 

100 

100 

64 

36 

76 

89 

39 

7 

59 

60 

17 

2 

34 

12 

Furthermore,  the  level  of  externalities  of  intermodal  transport  also  varies  depending  on  the 
combination of modes used and on the share of distance covered with each mode within an operation. 
The  weighted  average  length  of  road  transport  within  the  intermodal  operations  in  EU  has  been 
defined based on average single road leg distances established in the study by ISL, KombiConsult180 
and  taking  into  account  the  different  market  segments  and  types  of  operations  within  modal 
combinations as shown in Table 34.  

Table 35: Weighted median road distances in EU intermodal transport, in km 

Type of operation  Assumptions 

Weighted average road leg per operations* 

Rail-road 

55% of cases one road leg, 45% two road legs 

IWW-road 

SSS-road 

one road leg 

80% one road leg, 20% two road legs 

116 

21 

156 

Source: Ricardo et al. support study (2023); *Including average empty containers pick-up/delivery to/from depot. 

Savings thresholds - level of external costs savings that ensure that all three non-road modes (rail, 
inland waterways, short sea shipping) would be eligible  

An analysis was carried out to establish at which level of external cost savings would it be ensured 
that  all  modal  combinations  are  eligible  for  support.  It  was  established  that  for  PM1  (GHG 
emissions), all modal combinations could be eligible up to a threshold of 25% in case of minimum 
road transport, i.e. one road leg with median distance. In case of 2 median road legs, the non-road 
distance would have to be double in order to be eligible. Above this threshold, IWW would not be 
eligible taking into account the legislative framework included in the baseline181. SSS would still be 
eligible at 40% and rail would be always eligibile even at shortest distances as rail transport already 

179 The indicator considers the ratio between total emissions and transport activity. For inland waterways, the average 
emissions intensity of domestic navigation (inland waterways and national maritime) has been assumed.  
180 KombiConsult (2017), op. cit. 
181 Non-eligibility applies to sector average. Operations where cleaner barges such as for example solar barges are used, 
would be individually still eligible.  

93 

 
 
 
 
 
 
 
 
 
has lower GHG emissions than road (Table 32) and is expected to further reduce GHG emissions 
quicker than road (Table 33). However, possibly as soon as of 2035, but certainly before 2040 the 
waterborne transport and IWW in  particular  would not  be eligible at  any  savings  thresholds. The 
eligibility of rail in the future would depend on the actual speed of decarbonisation of road transport 
relative to other modes (on well-to-wheel basis).  

For PM2 (wider set of externalities including GHG emissions, air pollution, congestion, accidents 
and noise), all modal combinations would be eligible up to a savings threshold of 50% based on the 
baseline  projections  up  to  2050  (in  case  of  one  road  leg).  At  55%,  IWW  would  not  be  eligible 
anymore, while reasonably long rail would lose eligibility at 65% and SSS at 75%. 

Table 36: Door-to-door distance with one road leg necessary for eligibility under PM1 and PM2 

GHG savings (PM1) 

Wider externalities savings (PM2) 

Rail 

IWW 

SSS 

Rail 

IWW 

SSS 

-20% 

-25% 

-30% 

-35% 

-40% 

-45% 

-50% 

-55% 

-60% 

-65% 

-70% 

-75% 

102 

109 

118 

128 

139 

154 

171 

193 

222 

260 

315 

398 

63 

137 

N 

N 

N 

N 

N 

N 

N 

N 

N 

N 

217 

261 

326 

436 

657 

1333 

N 

N 

N 

N 

N 

N 

-20% 

-25% 

-30% 

-35% 

-40% 

-45% 

-50% 

-55% 

-60% 

-65% 

-70% 

-75% 

113 

125 

141 

162 

190 

229 

289 

392 

608 

1349 

N 

N 

32 

38 

47 

60 

84 

140 

416 

N 

N 

N 

N 

N 

171 

186 

203 

224 

249 

282 

324 

381 

461 

586 

803 

1273 

Source:  Ricardo  et  al.  support  study  (2023).  Note:  The  cells  marked  with  “N”  refer  to  savings  thresholds  at  which 
operations are not eligible at any distance 

Level of external costs savings that ensures that major part of operation is on non-road 

Taking into account the objective to shift major part of the operation away from road, the analysis 
further established at which savings thresholds is it ensured that the non-road transport is indeed more 
than 50% of the eligible operations door-to-door distance.   

For  PM1  (GHG),  this  would  be  ensured  only  as  of  savings  threshold  of  50%  for  rail,  but  at  that 
threshold, IWW and SSS would not be eligible. At 25%, where IWW and SSS are eligible at least in 
2030,  rail  legs  could  be  as  low  as  27%  of  the  total  distance  of  the  operation.  PM2  (wider  set  of 
externalities) would ensure that the non-road leg is always the major part of operation already at a 
40% savings threshold for all modal combinations.  

Table 37: Percentage share of the non-road leg from total door-to-door intermodal operation distance at different 
savings thresholds 

PM1 – GHG 

PM2 - EXT 

Rail 

IWW 

SSS 

Rail 

IWW 

SSS 

25% 

27 

85 

50 

36 

47 

30 

30% 

32 

never 

60 

43 

57 

36 

35% 

37 

40% 

43 

never 

never 

70 

51 

67 

42 

80 

65 

86 

54 

50% 

53 

never 

never 

72 

83 

75 

Source: Ricardo et al. support study (2023).  

Share of eligibility of total intermodal transport 

94 

 
  
  
  
The minimum reduction threshold of external costs that will be set will directly impact the share of 
intermodal operations in the EU that would benefit from support. Roughly, the lower the reduction 
required,  the  more  intermodal  operations  will  be  eligible  for  support.  Similarly,  the  higher  the 
reduction required, the longer distance the eligible operations have to be as saving comes from the 
difference  of  socio-environmental  merits  between  the  non-road  part  of  the  operation  and  road 
transport. By applying the above criteria and comparing the intermodal solutions with the road-only 
solutions, the shortest eligible door-to-door distances were established as presented in Table 37.  

Table 38: Door-to-door distance thresholds for eligibility criteria (km) 

Policy measure 

Rail 

IWW 

SSS 

PM1 (GHG - 25%) 

184  

 194  

 244  

73  

 never    never  

 268  

 273  

 243  

2030  2040  2050  2030  2040  2050  2030  2040  2050 

PM2 (EXT - 40%) 

 292  
Source:  Ricardo  et  al.  support  study  (2023);  Note:  ‘GHG  -  25%’  stands  for  extending  the  scope  to  all  intermodal 
operations in EU that save 25% GHG when shifting from road-only to intermodal; ‘EXT - 40%’ stands for extending the 
scope to all intermodal operations in EU that save 40% external cost when shifting from road-only to intermodal. 

 299  

 287  

 275  

 281  

 299  

82  

84  

87  

It must be noted that the figures presented are  the theoretical shortest eligible operation distances 
notwithstanding  whether  intermodal  operations  of  such  distances  exist  in  reality.  The  simulations 
have been carried out taking into account existing non-road transport operations in general and not 
specifically  intermodal  operations  for  which  such  granular  data  does  not  exist.  The  break-even 
distances of intermodal transport with respect to costs are normally higher than those for unimodal 
rail, inland waterways or short sea shipping, do not involve transhipment costs, high organisational 
costs nor road-legs that are priced often per time and not per distance and have considerably higher 
costs  per  tkm  than  non-road  transport.  As  a  matter  of  fact,  when  comparing  with  the  break-even 
distances presented in Figure 15 above, it can be assumed that the operations below the break-even 
distances even if saving a sufficient amount of externalities would not widely take place today as 
they would not be cost-efficient. 

For the same reasons, it is not possible to empirically establish with precision the share of intermodal 
operations that would be eligible due to PM1 and PM2. However, by using the data on distance bands 
from the TRUST model, it is possible to establish how much of rail, IWW and SSS operations in 
general are longer than the calculated minimum eligible distance. The minimum eligible distances 
were calculated using weighted average road-leg distances. No exact data exists on the distribution 
of road leg distances in intermodal transport, but it is clear that a certain amount of operations within 
the above shares would not fulfil the saving threshold as the road legs would be too long compared 
to the non-road leg. Taking into account that the non-road legs of economically viable intermodal 
operations  are  normally  longer  on  average  than  unimodal  rail,  inland  waterways  and  short  sea 
shipping operations as they also involve transhipment costs, and using normal (Gaussian) distribution 
for establishing the share of road legs that are above the weighted average road leg distances and 
would thus in combination with minimum calculated non-road leg distances not deliver the required 
savings, the estimated share of intermodal operations that would be eligible under PM1 and PM2 are 
presented in the Table 38.  

95 

 
 
Table 39: Estimated share of intermodal operations eligible per mode for PM1 and PM2  

Policy measure 

Rail 

IWW 

SSS 

2030  2040  2050  2030  2040  2050  2030  2040  2050 

PM1 (GHG - 25%) 

88%  87%  83%  57% 

0% 

0% 

70%  70%  70% 

PM2 (EXT - 40%) 

81%  81%  80%  56%  56%  56%  73%  73%  73% 

Source:  Ricardo  et  al.  support  study  (2023);  Note:  ‘GHG  -  25%’  stands  for  extending  the  scope  to  all  intermodal 
operations in EU that save 25% GHG when shifting from road-only to intermodal; ‘EXT - 40%’ stands for extending the 
scope to all intermodal operations in EU that save 40% external cost when shifting from road-only to intermodal. 

Taking into account the shares of different modal combinations in total intermodal transport and the 
eligibility from total intermodal transport under the current CTD, it can be established that the policy 
measures would result in an overall extension of the eligibility of 33.4% in 2030 for PM1 and 33.5% 
for PM2, and 30.2% in 2050 for PM1 and 33.3% under PM2.  

PM1 and PM2 alone are not expected to result in an increase in the total intermodal traffic volumes. 
In theory if no other changes would be made to current CTD, PM1 and PM2 would result in wider 
application of today’s support and current schemes for support (Article 4 and 6) would have to be 
extended to wider set of operations as shown above. However, as Article 6 is ineffective no impact 
on the total intermodal traffic volumes is expected. In addition, a very small increase in the intermodal 
traffic  volume  has  been  observed  due  to  the  extended  scope  of  today’s  regulatory  measures, 
essentially  Article  4  (equivalent  treatment  of  road  hauliers  carrying  out  road  legs  with  road-only 
transport).  

The costs for national public administrations linked to the extended eligibility are reflected in the cost 
calculations for PM7-PM12 below, due to the synergies between the measures. There are no costs 
attributed to the industry (i.e. there is no obligation on the industry to use the CTD). 

3.1.2. Measure PM3 – proof of eligibility 

PM3 establishes new and adequate data set obligations for proof of eligibility with implementation 
via eFTI platforms. This  measure will update which data needs to  be provided and how proof of 
eligibility by the industry who wants to benefit from the support measures should be provided. It is 
important to acknowledge that as today, this measure will not imply obligations or adjustment costs 
on all economic operators in the intermodal transport sector, but only on those that are eligible under 
respective Member States schemes and choose to benefit from the support measures. Overall, the 
impact of PM3 will be mainly linked to the proof of eligibility required to hauliers at road checks.  

PM3 will make it mandatory to use an eFTI platform in case the organiser wants to benefit from 
support measures. The  eFTI Regulation182 entered into force in August 2020 and will apply  from 
2025. The eFTI platforms will already cover the current CTD dataset. However, using eFTI is not 
mandatory in general nor for CTD today. In PM3, the updated dataset will be integrated into the eFTI 
platforms and a dedicated functionality will be added so that the platform can automatically calculate 
the eligibility. Thus, the organisers will enter into the eFTI platform usual transport data, required by 
other modal EU and national legislation as well as some limited additional data specific for CT, in 
particular linking the different legs of one operation and adding vehicle or vessel and fuel data. The 
dedicated  functionality  will  pull  together  the  data  needed  to  establish  eligibility  from  different 
datasets and inform both the organiser as well as controlling authorities in case of road-side checks 
whether an operation is eligible or not. The eFTI platform can also be used to assemble information 
or  reports  of  all  eligible  operations  carried  out,  for  submitting  to  authorities  for  application  of 
economic support. The impact of the latter is covered under PM7-PM11. 

182 Regulation (EU) 2020/1056. 

96 

 
 
 
The exact methodology and input data for externalities needs to be established separately by other 
legal acts (CEEU and its implementing acts in case of PM1) or by implementing or delegated acts 
for PM2 based on the Handbook of the external costs of transport183. In case of PM2, it would be 
necessary  to  continue  updating  the  Handbook  on  a  regular  basis,  taking  into  account  the  latest 
scientific evidence as well as integrating the results of CEEU.  

Adjustment costs for the private sector 

The costs for the private sector are mostly covered by the implementation of the eFTI Regulation and thus 
part of the baseline. Additional adjustment costs are expected due to PM3 for the eFTI platform providers 
in the form of initial investments for developing the required dedicated functionality (one-off adjustment 
costs). They are estimated at EUR 0.05 million in 2025 relative to the baseline.  

Table 40: Adjustment costs for the private sector due to PM3 relative to the baseline (in million EUR, 2021 prices) 
Costs (in million EUR) 
0.05 

Adjustment costs for eFTI platform providers (one-off costs in 2025) 
Source: Ricardo et al. support study (2023) 

Administrative costs savings for the private sector 

As in PM3 the proof of eligibility is implemented via the eFTI platforms, the operators engaged in 
intermodal transport will benefit from not having to manage paper-based transport documents, in 
particular for road-side checks. In addition, the operators will benefit from updated data requirements 
that allow to check the eligibility faster at road-side checks. The costs savings due to the use of electronic 
data and appropriate data requirements are estimated to be on average 5 EUR per shipment184. This also 
takes into account the eFTI platform fees for platform users. In order to derive the total administrative 
costs savings for the private sector, the unit cost savings are multiplied by the number of intermodal 
operations carried out under the different policy options. The costs savings for the private sector for 2025, 
2030 and 2035 relative to the baseline are provided in Table 40.  It must be noted that costs savings are 
assumed to occur until 2035 as post-2035 eFTI platforms are expected to be widely in use among EU 
operators; so there will be little case for PM3 to induce costs savings compared to the baseline. 

Expressed as present value over 2025-2050, the administrative costs savings are estimated at EUR 3.35 bn 
in PO-A, EUR 4.08 bn in PO-B1, EUR 4.12 bn in PO-B2a, EUR 3.16 bn in PO-B2b and EUR 5.31 bn in PO-C.  

For the purpose of the application of the ‘one in, one out’ approach, the average number of eligible 
operations per year during the 2025-2035 period is estimated at 0.071 bn in PO-A, 0.086 bn in PO-B1, 
0.087 bn in PO-B2a, 0.067 bn in PO-B2b, and 0.112 bn in PO-C. Applying the unit costs savings of 5 EUR per 
shipment, the administrative costs savings per year for the ‘one in, one out’ are estimated at EUR 0.35 bn 
in PO-A, EUR 0.43 bn in PO-B1 and PO-B2a, EUR 0.33 bn in PO-B2b, and EUR 0.56 bn in PO-C.   

Table 41: Administrative cost savings for the private sector due to PM3 in different policy options, relative to the 
baseline (in billion EUR, 2021 prices) 

Cost elements 
EUR saved/check for operators (A) 
PO-A 

Number of intermodal operations, in billion (C1) 
Total cost saving per year (A*C1)  

PO-B1 

Number of intermodal operations, in billion (C2) 
Total cost saving per year (A*C2)  

PO-B2a 

Number of intermodal operations, in billion (C3) 
Total cost saving per year (A*C3)  

183 CE Delft (2019). 
184 SWD (2017) 194 final. 

2025 
5  

0.065 
0.32 

0.078 
0.39 

0.078 
0.39 

97 

2030 
5  

0.071 
0.36 

0.086 
0.43 

0.086 
0.43 

2035 
5  

0.076 
0.38 

0.094 
0.47 

0.097 
0.48 

 
 
 
 
 
 
 
 
 
 
 
 
Cost elements 
PO-B2b 

Number of intermodal operations, in billion (C4) 
Total cost saving per year (A*C4)  

PO-C 

Number of intermodal operations, in billion (C5) 
Total cost saving per year (A*C5)  
Source: Ricardo et al. support study (2023) 

2025 

0.060  
0.30  

0.101 
0.51 

Administrative costs savings for national public authorities 

2030 

0.067  
0.33  

0.111 
0.56 

2035 

0.073  
0.37  

0.124 
0.62 

As regards public authorities, no additional adjustment costs for using the eFTI platforms are expected as 
the use and acceptance of eFTI platforms is already mandatory for all public authorities under the eFTI 
Regulation and thus part of the baseline.  

On the other hand, due to PM3 the national authorities will benefit from faster procedures for road-
side checks in case road-hauliers are using one of the regulatory benefits established by the CTD. 
The availability of digital transport information will significantly reduce the time spent by officers 
for inspections. For authorities, these benefits can be quantified based on the number of road checks 
carried out in the EU (the number of checks is considered fixed, i.e. it is not affected by the CTD 
provisions), and the fact that the use of digital transport data allows to cut the duration of road-side 
check by 10% (a time savings valued on average at 2.4 EUR per check)185. Considering that pre/post 
haulage operations  (i.e.  road legs of intermodal  transport)  represent  nearly 10% of road transport 
operation in EU27, the administrative cost savings for public authorities are estimated at EUR 0.24 
million per year from 2025 onwards. Expressed as present value over 2025-2050, they are estimated 
at EUR 2.29 million relative to the baseline.  

Table 42: Administrative cost savings for public authorities due to PM3, relative to the baseline (EUR million, 2021 
prices) 

Administrative cost savings (recurrent) 
Source: Ricardo et al. support study (2023) 

Annual 

0.24 

Present value over 2025-
2050 

2.29 

It must be noted that costs savings are assumed to occur only until 2035 as post-2035 eFTI and the 
digitalisation of transport information is expected to be widely in use among EU operators; so there 
will be little case for PM3 to induce costs savings compared to the baseline. 

No impact is expected on intermodal traffic volumes due to PM3. 

3.2. Ensure better support by improving reporting on the multimodal/ intermodal transport 
(PM4-PM6) 

3.2.1. Measure PM4 – Replace the Commission reporting with Member States’ voluntary analysis 

and strategic planning for sustainable freight transport 

Adjustment costs for national public authorities 

In PM4 the existing reporting mechanism is replaced with a new system where Member States carry 
out analysis and strategic planning on sustainable freight transport on a voluntary basis while the 
Commission reporting is abolished. The voluntary system proposed under PM4 is expected to bring 
limited adjustment costs for authorities. More specifically, it is expected that five Member States who 

185  The  Mobility  Package  I  IA  study  (https://transport.ec.europa.eu/system/files/2017-06/2017-04-support-study-ia-
revision-haulage.pdf; page 120) indicates expected cabotage checks under the baseline scenario of 1.35 million/year and 
savings of EUR 3.2 million/year from the use of the e-CRM (linked to a 10% time reduction). 

98 

 
 
 
 
 
 
 
 
 
today do not carry out such analysis (AT, CZ, NL, PT and SE) would do so in the future. The one-
off  effort  in  2025  is  estimated  at  98  to  198  man-days  per  country,  depending  on  the  number  of 
transport modes and on the size of the freight transport sector of the country. In addition, every five 
years the effort required is estimated at 147 to 297 man-days per country. To estimate the costs, the 
tariffs per hour from the Eurostat Structure of earnings survey, Labour Force Survey data for Non-
Wage Labour Costs (i.e. ISCO 2 – professionals) have been used. The total one-off costs in 2025 are 
estimated at EUR 0.2 million, while the recurrent costs from 2025 onwards at EUR 0.3 million every 
five years (see Table 42). Expressed as present value over the 2025-2050 horizon, the total adjustment 
costs for national authorities are estimated at EUR 1.4 million, of which one-off costs of EUR 0.2 
million. 

3.2.2.  Measure  PM5  –  Replace  the  Commission  reporting  with  Member  States’  mandatory  
analysis  and  strategic  planning  for  all  freight  transport  system  (cross-modal).  An  obligation  to 
regularly review the measures will be included.  

Adjustment costs for national public authorities 

PM5 introduces an obligation on MSs to prepare on a regular basis, e.g. every 5 years, an analysis 
and strategic planning covering the entire freight transport system (i.e. covering both road and non-
road  modes).  This  new  mechanism  will  allow  a  systematic  assessment  of  the  effectiveness  and 
efficiency of the CTD and a review of the economic support measures according to the evolution of 
framework conditions in the transport sector. PM5 is expected to lead to adjustment costs for national 
authorities, as Member States will be required to collect data and transport statistics on a regular basis 
and prepare or commission a report to be published.  

For  the  quantification  of  the  adjustment  costs  for  Member  States,  it  has  been  assumed  that  each 
Member State will incur an initial effort to set-up the data collection system estimated at 40 to 264 
man-days for 2025, and between 60 and 396 man-days every 5 years for data consolidation and report 
preparation, with efforts varying depending on the number of transport modes and on the size of the 
freight transport sector of the country. To estimate the costs, the tariffs per hour from the Eurostat 
Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs (i.e. ISCO 2 – 
professionals) have been used186.  

The total one-off adjustment costs are estimated at EUR 1.1 million, and the recurrent adjustment 
costs at EUR 1.6 million every 5 years from 2025 onwards compared to the baseline (in 2021 prices). 
Expressed as present value over 2025-2050, total adjustment costs for public authorities are estimated 
at EUR 7.8 million, of which one-off costs of EUR 1.1 million (see Table 42).  

3.2.3. Measure PM6 – Revise the Commission reporting obligation. Include a review clause and 

ex-ante notification and publication of Member States support schemes. 

Adjustment costs for national public authorities 

PM6 proposes a more limited revision of the monitoring and reporting obligations defined in Article 
5 of the current CTD. The reporting will be done by the Commission as today, but the revision will 
involve a review of the list of data to be reported, in particular as regards outdated provisions, as well 
as an extension of the reporting from 2 to 5 years. Less frequent analyses allows a more meaningful 
analysis of the effects of the support measures and also leaves the time needed to adjust measures 
based on the evidence collected and the analysis produced. 

In  order  to  ensure  transparency  of  support  schemes  to  industry,  PM6  also  includes  an  ex-ante 
notification requirement for Member States to share with the Commission information on upcoming 

186 For EU-27 these are estimated at EUR 37.5 per hour in 2021 prices. 

99 

 
 
support schemes so that the Commission could make this information public on a central Commission 
gateway  (linked  to  Member  States  own  published  information).  The  notification  should  be  made 
sufficiently early to allow the Commission to publish the information prior to opening of the scheme 
and to allow operators to prepare, where appropriate, their applications before the scheme’s opening, 
in  particular  if  application  is  time  or  budget  limited  (may  run  out  of  budget  in  short  time).  This 
notification requirement is not expected to bring along any additional costs relative to the baseline as 
it is expected that Member States by default publish information about upcoming support schemes.  

The  current  provision  in  Article  5  already  requires  Member  States  to  assist  the  Commission  in 
preparing  the  report.  Thus  no  new  obligations  on  Member  States  are  established  under  PM6.  A 
summary of the adjustment costs for the national public authorities due to PM4-PM6 compared to 
the baseline is provided in Table 42. 

Table 43: Summary of adjustment costs for national public authorities due to PM4-PM6 compared to the baseline 
(million, 2021 prices) 

Cost element 
One-off costs   
Recurrent costs (every 5 year) 
Present value over 2025-2050 

Source: Ricardo et al. support study (2023) 

PM4 
0.2 
0.3 
1.4 

Adjustment costs for the European Commission 

PM5 

1.1  
1.6 
7.8 

PM6 
0 
0 
0 

The cost for the European Commission to commission a dedicated study to gather and analyse the 
intermodal transport market is  estimated at around EUR 300,000 per report.  Expressed as present 
value over 2025-2050, total adjustment costs for the European Commission are estimated at EUR 1.7 
million.  

Administrative cost savings for the private sector 

Operators are expected to enjoy administrative costs savings under PM6 (included in PO-B1, PO-
B2a and PO-B2b) thanks to Commission centrally publishing the information on upcoming support 
schemes and thus saving operators time to monitor Member States plans in this regard. These savings 
come in addition to the costs savings for the preparation of the applications discussed under PM7-
PM9 (see section 3.3.5 of Annex 4) and are estimated to represent 20% of these costs savings. The 
administrative costs savings depend on the number of applications for support in PO-B1, PO-B2a 
and PO-B2b. The total administrative cost savings for the private sector are estimated at EUR 23.1 
million in PO-B1, EUR 23.9 million in PO-B2a and EUR 10.3 million in PO-B2b relative to baseline, 
expressed as present value over 2025-2050.  

Table 44: Administrative cost savings for the private sector due to PM6, relative to the baseline (EUR million,  2021 
prices) 

Policy option 

PO-B1 

PO-B2a 

PO-B2b 

2030 

1.1 

1.1 

0.5 

2050 

1.6 

1.7 

0.8 

Present value over 
2025-2050 

23.1 

23.9 

10.3 

Source: Ricardo et al. support study (2023) 

No impact is expected on intermodal traffic volumes due to PM4-PM6.  

3.3. Support measures to  increase the competitiveness of intermodal transport (PM7-PM13) 

Measures  included in  this category aim to  provide a direct  operational  and other direct  economic 
support to favour the uptake of more intermodal operations. The main effect of PM7-PM9 is through 

100 

 
a reduction of costs and thus a reduction of the average distance at which it becomes profitable to use 
intermodal solutions as compared to road-only transport (break-even distances). PM12 is a top-up 
measure  reflecting  the  State  aid  rules  to  ensure  the  efficiency  of  both  PM7  and  PM9  and  is  thus 
analysed  together  with  these  policy  measures.  PM10,  PM11  and  PM13  are  enabling  measures 
addressing specific issues in the sector and creating preconditions for intermodal operations to grow.  

Beneficiaries of the economic support can be either the transport organisers, connection organisers 
or carriers (for explanations see Annex 3). In order to maximise the leverage of the measures, the 
direct contribution should go to those economic operators who take the decision for modal choice 
and bear the related  commercial risk.  For PM7-PM9, it is  the shippers or freight forwarders who 
decide on which mode to use and are thus seen as more effective beneficiaries than contributions to 
carriers. For PM10, the commercial risk is taken by economic agents who arrange a new connection 
for  the  non-road  leg.  Depending  on  the  circumstances,  these  “connection  operators”  can  be  the 
carriers, the shippers, logistics companies or their consortiums or dedicated companies organising 
intermodal  connections  on  non-road  legs,  but  not  carrying  them  out  themselves.  For  PM11,  the 
beneficiaries will depend on the specific support tool to be used.  

3.3.1.  PM7-PM9 - direct operational support’s impact on traffic volumes 

PM7-PM9  entail  an  operational  support  to  intermodal  transport  operators  in  the  form  of  a 
reduction/reimbursement  of  the  cost.  The  application  of  the  PM7  would  be  mandatory  and 
harmonised  across  all  Member  States.  In  PM8  it  would  be  voluntary  and  in  PM9  it  would  be 
mandatory for Member States to apply operational support, but design of support tool would not be 
harmonised. Both for the purposes of PM8 as well as PM9 (but also for PM10-PM11), a Toolbox 
with a list of possible support tools with more detailed minimum conditions would be included. A 
preliminary example of the measures in the Toolbox is included in Annex 9.  

The change in the relative costs beween transport operations by transport mode is estimated to lead 
to higher uptake of intermodal transport, as assessed with the help of TRUST model. As explained 
in  section  1  of  Annex  4,  TRUST  is  a  European  scale  transport  network  model  developed  and 
maintained by TRT and simulating the road, rail, inland waterways and maritime transport activity. 
TRUST covers the whole Europe and its neighbouring countries and it allows for the assignment of 
passenger and freight origin-destination (OD) matrices at NUTS3 level of detail (about 1,600 zones) 
on the multimodal transport network. Evidence of the effectiveness of financial support measures on 
the uptake of intermodal transport and modal shift can be found in various applications across EU. 
More explanations are provided in Annex 14. 

Modelling assumptions 

The support is to be provided as a percentage of the door-to-door transport cost. As the first step, the 
analysis had to establish the percentage of cost reduction that would induce sufficient modal shift. 
Consultation with the stakeholders, desk research and model simulations identified that on average 
10% reduction of door-to-door costs to the operator who decides which mode to use (the organisers) 
would make intermodal options attractive to them187.  

A  limited  cost-benefit  analysis  was  carried  out  to  establish  what  levels  of  support  would  provide 
which  decrease  in  the  break-even  distances  and  which  impact  on  volumes  of  modal  shift,  while 
keeping  also  in  mind  that  increased  support  means  higher  budgetary  burden  to  Member  States. 
TRUST model simulations were used to estimate the stand-alone impact of reducing the costs on the 
break-even distance and on modal shift (i.e. without considering any eligibility condition). The first 
analysis was carried out on reducing the door-to-door costs by 5%, 10%, 15% and 20%, and their 

187 Industry stakeholders suggested reductions depend mostly on the modal combination, with rail lowest (5 out of 10 
suggested less than 10%) and IWW the highest (3 out 5 suggested more than 25%). SSS was in the middle with 2 out of 
4 respondents suggesting less than 20%. 

101 

 
 
impact on the distances at which the intermodal operation would become cost-competitive with road-
only transport. For the analysis, the weighted average road leg distances (see Table 34) and average 
transhipment costs were used as fixed costs and organisational costs for multimodal chain where not 
taken into account. It is important to keep in mind that in real life the price conditions and operational 
characteristics can be very different and thus the relative shares of cost components diverge quite 
widely depending on the market segment, geographical areas, number of road legs and number of 
transhipments, type of loading unit and several other technical characteristics188.   

Figure 16: Impacts of different levels of door-to-door cost reduction (% increase in intermodal transport activity 
compared to the baseline) 

12

10

8

6

4

2

0

5%

10%

15%

20%

Source: Ricardo et al. support study (2023) 

Rail

IWW

SSS

This modelling supported stakeholders’ view that aid intensity level between 10% and 15% would 
induce reasonable level of modal shift as can be seen in Figure 16. A lower level of support would 
not result in sufficient price reduction to motivate large number of shippers (organisers) to shift their 
operations to intermodal transport or would only make a very small number of operations attractive. 
The remaining high break-even distance would mean that large number of operations that are still 
below the new break-even distance would continue to rely on road-only transport. A higher level of 
support will bring the break-even distances down and ensure more modal shift, but it also needs to 
be kept in mind that the higher the support level the higher the budgetary costs for Member States. 
Furthermore, at certain shorter distances the intermodal operations are not competitive for reasons 
other than price. In particular transit time and inconvenience of organising and following a multiparty 
operation outweigh the pure cost-competitiveness, meaning that it may result in a situation where 
higher support is available, but operators are nevertheless not interested in shifting to intermodal. 
Thus increasing the support to make also very short operations cost- competitive is not effective.  

Considering that higher support levels also bring along higher budgetary costs for Member States, 
10% has been chosen for the purpose of this impact assessment. The following graph illustrates how 
a 10% support granted under PM7-PM9 to intermodal transport reduces the break-even distances of 
the  different  modal  combinations.  Without  operational  support  the  break-even  distances  are  on 
average (door-to-door) 740 km for rail, 260 km for IWW and 775 km for SSS. With a 10% support 
for door-to-door costs, the break-even distances are reduced to 535 km for rail, 200 km for IWW and 

188  Detailed  analysis  on  cost  comparison  of  different  types  of  intermodal  operations  has  been  carried  on  PWC. 
KombiConsult  (2022).  However,  this  study  did not  take  into  account  geographic differences  and  assumed  also  fixed 
distance road legs.  

102 

 
 
 
610  km  for  SSS  (Figure  17).  This  demonstrates  the  effectiveness  of  these  measures  in  terms  of 
making  more  (shorter)  operations  economically  competitive  with  road-only  transport  and  thus 
increasing the potential for modal shift.  

Figure  17:  Average  price-competitive  door-to-door distances  in  intermodal  transport  without  and  with  the  economic 
support of 10%, per modal combination (cost in EUR and distance in km) 

Source: Ricardo et al. support study (2023) 

For modelling purposes, the 10% reduction of door-to-door costs was translated into a reduction of 
different cost components of the intermodal operation; in particular non-road leg costs as road leg 
and transhipment costs do not depend on the total door-to-door distance – it is the length of the non-
road leg that is variable. Transport chain organisation costs were not included in the modelling as 
they vary widely from sector and operator. For rail, the 10% door-to-door reduction translates into a 
non-road leg cost reduction of 15-25%, for IWW into a cost reduction of 21-33% and for SSS of 23-
35% depending on the distance of operation ceteris paribus. Variability can be greater when other 
characteristics are included. As regards transhipment cost reduction, the range can be quite large as 
transhipment costs vary greatly between modes and geograpic locations. A 10% reduction of door-
to-door costs can thus vary between 35-70% of transhipment costs, but in most cases remains between 
45-55%. 

For the mandatory harmonised approach in PM7, in order to reflect the harmonisation, a reduction of 
non-road cost was considered that translates into 10% reduction of the door-to-door price. The exact 
reduction of the non-road cost  varies  depending  on modal combination, distance of non-road leg, 
type of technology used and geographic location as well as who are the beneficiaries. For this impact 
assessment, it was assumed that the organiser  who decides on modal choice will receive the 10% 
reduction.  For  modelling  purposes,  the  reduction  of  non-road  transport  costs  was  used  as  proxy, 
assuming a reduction of 20% of rail costs and 30% of waterborne costs. 

For the mandatory but flexible support in PM9, it is also assumed that the organisers who choose the 
mode of transport will benefit directly from support, at the more-or-less same aid intensity. However, 
as Member States will have the possibility to design their own schemes, the modelling assumptions 
were adapted to reflect the possibility that not all support is paid to organisers and not all support is 
thus passed through to decision makers. For modelling purposes, a mix of reductions of non-variable 
transhipment cost and variable non-road leg costs was considered based on Member States current 

103 

 
 
practices resulting in approximately 81% of intermodal transport activity being supported through 
variable costs’ reduction and the remaining 19% through a reduction of transhipment costs. For the 
non-road  cost  reduction,  same  assumptions  were  used  as  for  PM7,  while  for  the  reduction  of 
transhipment costs, 50% reduction was used.  

In  case  support  is  voluntary,  as  in  PM8,  Member  States  are  unlikely  to  change  much  the  current 
approach,  maintaining  the  support  provided  to  the  intermodal  transport  sector  around  the  level 
currently provided. Thus, no specific modelling assumptions were made for PM8.  

Limiting operational support to market failure/necessity condition 

PM12 aims to ensure that the operational support given in relation to PM8/PM9 is not provided to 
operations that are already financially self-sustained to reflect more clearly the State aid rules and in 
particular the condition of necessity in relation to a specific market failure189. PM12 is not applied in 
combination with PM7 as the support in PM7 is harmonised. For PM10, PM11 and PM13, the limit is not 
applied directly, but where these measures result in additional eligible operations to be supported under 
PM8/PM9, the limit applies the same way it applies to all other eligible operations.  

For the modelling purposes, PM12 limits the direct economic support to operations with door-to-door 
distance below average mode-specific break-even point. The TRUST model output was used to assess the 
share of traffic which would be eligible for support under PM8-PM11 but would not benefit of economic 
support due to PM12. Specifically, the share of transport activity (in tkm) operated on distances longer 
than break-even points was estimated considering analogous transport activity by distance bands extracted 
from the TRUST model. 

Based on the TRUST model data, the support was modelled to be limited to operations that for rail 
and SSS imply a travel distance shorter than 900 km door-to-door while for IWW this threshold is 
fixed  at  400  km  door-to-door.  The  weighted  average  road  legs  length  were  assumed.  The 
corresponding share of operations that would not meet the necessity condition is 20% for rail-road 
intermodal, 48% for IWW and 64% for SSS. The overall contribution modelled for Member States 
budgets to support PM8/PM9 was consequently lowered proportionally to the demand that exceeds 
the distance threshold.  

Impact on modal shift and intermodal transport volumes 

As PM7 ensures uniform harmonised application on all eligible operations, the impact of this measure 
is assessed to be the highest while the impact of voluntary support under PM8 is the lowest. The 
elasticity of support is higher for rail than for the waterborne modes, partly because of accessibility 
of rail-road operations across EU and partly due to other factors such as delivery time.   

The  estimated  stand-alone  impact  of  PM7  in  terms  of  additional  intermodal  transport  activity 
(without considering the limitation due to eligibility criteria or other measures included in PO-C) is 
in the range of +4.2% for rail, +0.9% for IWW and +1.3% for SSS in 2030, and +8.2%, +1.4% and 
+2.1% respectively in 2050, and amounts to a 2.8% increase for 2025-2050 compared to baseline.  

189 Condition of necessity of State aid is assessed in all State aid cases. Respective State aid rules establish the conditions 
at which aid is considered necessary to tackle the identified market failure.  

104 

 
 
Table 45: Impacts of PM7 on intermodal transport (door-to-door) activity (billion tkm and percentage change 
compared to baseline) 

2030 

9.9 

0.2 

6.1 

% change 
to the 
baseline 

+4.2% 

+0.9% 

+1.3% 

16.1 

+2.3% 

2050 

% change to 
the baseline 

2025-2050 

33.7 

0.3 

12.4 

35.9 

+8.2% 

+1.4% 

+2.1% 

+3.5% 

570.8 

5.1 

221.2 

616.8 

% 
change 
to the 
baseline 
+7.1% 

+1.1% 

+1.7% 

+2.8% 

Rail 

IWW 

SSS 

Total 

Source: Ricardo et al. support study (2023) 

The  stand-alone  impact  of  PM9  in  terms  of  additional  intermodal  freight  transport  activity  is 
estimated at approximately +4% for rail, +1% for IWW and +1.7% for SSS in 2030, and +7.8% for 
rail, +1.5% for IWW and +1.8% for SSS in 2050.  

Table 46: Impacts of PM9 on intermodal transport (door-to-door) activity (billion tkm and percentage change 
compared to baseline) 

2030 

9.4 

0.2 

7.7 

17.2 

% 
change 
to the 
baseline 
+4% 

+1% 

+1.7% 

+2.4% 

2050 

32.3 

0.3 

10.3 

42.9 

% 
change 
to the 
baseline 
+7.8% 

+1.5% 

+1.8% 

+4.2% 

2025-2050 

550.4 

5.7 

231.4 

607.7 

% 
change 
to the 
baseline 
+6.9% 

+1.2% 

+1.8% 

+2.8% 

Rail 

IWW 

SSS 

Total 

Source: Ricardo et al. support study (2023) 

The stand-alone impact of PM8 on the intermodal transport competitiveness and on the modal share 
of intermodal transport is expected to be negligible.  

3.3.2. PM10 – start-up support 

PM10 and PM11 are enabling measures creating pre-conditions for intermodal transport to take place 
and accelerating supply-side investments.  

PM10  foresees  start-up  support  for  establishing  new  non-road  connections  between  points  where 
such connections do not yet exist (see section 2 in Toolbox, Annex 9). This is particularly necessary 
to support the objective of new terminal creation under the proposed revision of TEN-T Regulation. 
New intermodal non-road connections/services often do not have sufficient client base to fill the train 
or vessel to allow it to be profitable, which creates a considerable hindrance to start new services. 
However, over time services become established and fill-ratio increases and thus such support should 
be  temporary  and  diminishing  where  necessary.  Such  a  support  is  particularly  important  in  areas 
where intermodal links are less dense and/or demand and financial risk are higher.  However, new 
connections/services are not required everywhere and thus this measure cannot be mandatory, but 
should rather be optional.  

Previous  studies  clearly  indicate  that  the  costs  of  setting  up  new  intermodal  routes  or  services 
(including costs of new equipment, market analysis, transactions, additional management/staff time, 
etc.) can be significant, and influence both the willingness of market operators to expand the market 
supply  and  also  indirectly  the  overall  competitiveness  of  intermodal  vs.  road-only  transport190. 

190 A study by TRT (2017) estimates e.g. that the average cost of setting up a new scheduled service to a new destination 
is on average in the range of EUR 20,000 and EUR 173,000, while the cost of organising a new CT route (i.e. a service 
to a new destination not previously covered) is on average between EUR 200 and EUR 1,000, with values that can of 
105 

 
 
 
 
Various examples exist in the EU of start-up support measures for new intermodal services and modal 
shift actions, including e.g. the Marco Polo programme(s), and other aids established for example in 
Italy, Germany and the Netherlands191. Those existing schemes have different features in terms of 
budget available, targeted sector, conditions and aid intensity levels. The current practice seems to 
suggest that Member States tend to provide start-up support proportional to operational cost per tkm 
or  units  transported  per  new  services,  rather  than  providing  direct  financing  of  start-up  capital 
investments  (e.g.  one-off  capital  financing).  The  current  examples  suggest  that  the  intensity  of 
support provided to establish new intermodal services is typically in the range of EUR 0.3-0.8 million 
per service. This amount should be sufficient to cover not only start-up costs but also the operational 
losses  during  the  first  years  of  operation  (i.e.  before  demand  fully  materialise)  and  could  be 
considered a reference value for the voluntary application of PM10. 

Table 47: Examples of start-up programmes in EU-27 

Start-up 
programme 

Country 

Sector 

Budget  

Economic support 

Marco Polo II 

EU27 
plus UK 

Rail, IWW, 
SSS 

Marebonus 
Ferrobonus 

IT 
IT 

SSS 
Rail 

Twin Hub rail 
network 

NL 

Rail 

Modal shift aid 

NL 

Rail, IWW 

35 EUR million/year, 
260-800 EUR million per 
modal shift action funded 
56 EUR million/year 
25 EUR million/year 
Total 1.06 EUR billion, 
0.3-0.4 EUR million 
transferred to each rail 
operator 
EUR 5.6 million/year 

Eco-incentive to 
SSS 

ES 

SSS 

EUR 20 million/year 

2 EUR per 500 tkm shifted  
(i.e. 0.004 per tkm) 

30% of operating cost 
2.5 EUR per train-km 

Financing for new pilot train 
services 
(50% coverage of losses) 

EUR 20 per TEU 
100% of external cost savings 
by using SSS instead of road 
(EUR/HGV shifted) 

Source: INEA (2020) Marco Polo II Programme; 2022 IA study on State aids for railways undertakings. 

Different outcomes have been observed e.g. with respect to the response of market operators to the 
available subsidies. As shown in the table below, the Marcopolo II programme evidence that each 
new intermodal service can shift between 815,000 and 846,000 tkm off the road (to rail and SSS 
services), and about 260,000 tkm in the case of IWW services.  

Table 48: Marco Polo II – modal shift impacts 

Sector 

Average tkm shifted per action  

Tkm per EUR funded 

Rail 

IWW 

SSS 

Total 

815,176 

260,862 

845,993 

792,571 

Source: INEA (2020) Marco Polo II Programme, Final report 

309 

360 

552 

364 

course vary largely depending on the specific case and context considered (quality and scale of operations to be arranged, 
operator’s capacity, mode sector, etc.). The same study indicates that such capital costs indirectly impact on the relative 
competitiveness  of  intermodal  services,  estimating  an  additional  cost  of  EUR  50-100  of  organising  an  intermodal 
compared to road-only transport. Source: TRT (2017), op.cit. 
191  For  instance,  scheme  N  640/08  offered  in  Saxony  (Germany)  from  2009  to  2015,  offering  start-up  aid  for  new 
combined  transport  services  for  a  maximum  of  3 years;  the  scheme  N449/2008  offered in  Italy  subsidizing road-rail 
transport of containers in between Naples and the Nola freight village; the SA.54990 aid made available recently in Italy 
by the Emilia-Romagna region, subsidising logistics undertakings and multimodal transport operators by compensating 
the difference in external costs of road transport; and the SA.38639 aid providing financing for pilot train services within 
the “Twin hub” railway network. Also in the Netherlands, a new aid scheme has been recently adopted to promote modal 
shift from road to rail and inland waterways. 

106 

 
 
Although uncertainties related to the adoption by Member States (in terms of intensity and duration of the 
support) do not allow a consistent quantification of its effects on the level of intermodal transport activity, 
possible outcomes from the application of PM10 were analysed based on the evidence/examples 
previously described and assuming that a specific group of Member States decides to adopt PM10. The 
assumptions are based on the experience and the statistics collected during the Marco Polo II programme, 
as reported by INEA192. 

For the purpose of the assessment, it is assumed that a start-up programme has a duration of 5 years, and 
that every 6th year either same country or a new country starts a new start-up programme cycle. The start-
up measure is used between 2025 and 2039193. Reference countries have been selected focusing mostly on 
middle-size countries and aiming for a diverse sample in terms of transport modes coverage194.  

It is then assumed that each programme cycle leads to the activation of 10 new services in the rail sector 
(i.e. 10 for each country covering rail), 5 new services for IWW, and 7 new services for SSS. In total, 427 
new services would be created between 2025 and 2039. 

Moreover, the average traffic operated by the start-up services has been determined based on Marco Polo 
II statistics on the operational performance of the “modal shift” actions, which is considered a reference 
for the operation of new intermodal services in EU-27195. As explained later, closed actions should be 
representative of successful start-up services, while terminated actions are considered in order to reflect 
the inefficiencies actually characterizing the ramp-up phase of new services. 

For the quantification of impacts until 2050, the following additional assumptions are used: 

• 

In the first 5 years of existence (ramp-up phase), these services are assumed to operate only a share of 
the  average  traffic  estimated  from  Marco  Polo  II  statistics,  namely  60%  in  the  first  year,  70%  in  the 
second year, and 80% from the third to the fifth year. 

•  When a program cycle ends, a share of the activated services is assumed to terminate (to account for 
the risk that services may not prove successful or economically feasible), while the ones that survive will 
continue to operate at normal volume levels. Also based on Marco Polo II statistics, the survival rate is 
assumed to be 70% for rail and SSS services, and 50% for IWW services. Finally, it is assumed that a part 
of new connections would be created under market conditions in any case, only at a later stage. The 
start-up  support  accelerates  the  opening  of  new  connections  and  thereby  the  additional  uptake  of 
intermodal transport. The share of traffic on the new connections assumed to have been accelerated 
corresponds to 50% for rail and SSS, and 100% for IWW. 

The stand-alone impacts of start-up support are comparable in magnitude to direct operational support 
under PM7/PM9 in 2030 but are considerably lower for 2025-2050 as the impact is mainly observed at the 
introduction of new routes, in the beginning of the period. The impact of start-up support over 2025-2050 
is estimated at 1.9% increase in the intermodal transport activity relative to the baseline.  

192 INEA (2020), Marco Polo II Programme, Final report. 
193  The  assumption  that  programmes  last  until  2039  is  driven  by  planned  expansion  of  terminal  capacity,  which, 
consistently  with  TEN-T  plans,  should  occur  mainly  over  the  next  decade  (implying  that  demand  for  new  links  and 
services to/from terminals will likely concentrate in the years before 2040). 
194  The  overall  assessment  does  not  involve  country-specific  assumptions  related  e.g.  to  funding  capacity  or  service 
parameters (start-up costs, traffic volumes, etc.). The selection of reference middle-size countries (covering nearly a third 
of EU27) is made merely for the purpose of building a hypothetical scenario where different shares of intermodal services 
in rail, IWW and SSS receive start-up support. The reference countries selected are the following: In 2025, DK, ES, HR, 
IT, NL for rail, NL for IWW and DK, ES, HR, IT, NL for SSS. In 2030, the same countries are assumed to continue the 
scheme and the following additional countries are expected to introduce the measure: CZ, FR, PL, SI, SK for rail, FR for 
IWW and FR, PL, SI for SSS. In 2035, all the countries using the measure in 2030 are expected to continue with the 
measure.   
195 In particular, the average traffic operated per year corresponds to the weighted average of the ton-km operated by 
terminated and closed modal shift actions, while the maximum traffic corresponds to the average ton-km operated by 
closed actions only. 

107 

 
 
Table 49: Impacts of PM10 on the intermodal transport (door-to-door) activity (billion tkm and percentage change 
compared to the baseline) 

2030 

8.2 

0.1 

4.9 

% 
change 
from 
baseline 
+3.5% 

+0.9% 

+1.1% 

2050 

10.7 

0.5 

5.9 

13.2 

+1.9% 

17.1 

% 
change 
from 
baseline 
2.6% 

2.1% 

1% 

1.7% 

2025-2050 

254.5 

11.2 

146.2 

411.8 

% 
change 
from 
baseline 
+3.2% 

+2.3% 

+1.1% 

+1.9% 

Rail 

IWW 

SSS 

Total 

Source: Ricardo et al. support study (2023) 

The modal shift effects of start-up support can vary depending on the intensity and the duration of 
the  support  as  well  as  on  context-specific  factors,  in  particular  the  structure  of  the  road  transport 
activity  potentially  shifting,  the  competitiveness  of  intermodal  market  operators,  prevailing  road 
transport prices etc.196. It is thus important to reiterate that PM10 is not designed as an alternative to 
PM7-PM9, but rather as a complementary measure for specific situations. The beneficiaries of PM10 
would not be the same as in PM7-PM9. The aim of this support tool is not to reduce the market price 
to shippers, but rather to compensate the new connection’s provider for lower load factors/operational 
losses allowing thus the service to operate at market prices. Any shippers and transport organisers 
using the new services would be nevertheless eligible for operational support under PM7-PM9. This 
is  particularly  important  to  ensure  that  the  modal  shift  effects  are  not  temporary  and  transport 
organisers continue to use the intermodal services after the temporary start-up support expires, thus 
not forcing the connection operators to terminate the connection that previously received support. 

3.3.3. PM11 – technological upgrade support’s impact on traffic volume 

PM11 foresees additional support tools for providing support to technological upgrade investments 
and actions that enable the take-up of intermodal transport. The measure aims to influence the uptake 
of modern equipment  across different stakeholders in intermodal transport chain (see section 3 in 
Toolbox, Annex 9). For example, transport organisers and operators could benefit from State aid to 
upgrade their loading units, support for integrating connected systems and for acquiring devices for 
automation and digital logistics.  

The limited competitiveness of intermodal vs. road-only transport represents a hindering factor for 
operators to invest in new equipment and innovative solutions, since compensating for the investment 
through a price increase for final users would expose them to the risk of losing demand and market 
share.  Providing  economic  support  can  thus  be  essential  for  unlocking  investments  in  innovative 
solutions and upgrade of the equipment used in the intermodal transport sector. Such investments can 
in turn create the conditions for a potential increase in the efficiency and productivity of different 
parts of the intermodal transport chain, with relevant knock-on effects on the overall competitiveness 
of  intermodal  transport  vs.  road-only  alternatives  both  in  terms  of  services  costs  and  quality  and 
reliability. PM11 will not cover any support to investment into infrastructure.  

Support tools of this type have been established in various MSs, receiving a relatively strong demand 
from the industry and being among the support actions with the higher  share of budget absorption197. 

196 In some cases, financial support contributed only partially to attract new investments or induce modal shift, particularly 
when operators are confronted with high risks and/or constraints at infrastructure level (rail network, terminal, etc.). The 
way the support is designed is another relevant aspect to consider, with flexible schemes generally more effective thanks 
to  the  possibility  of  adjusting  the  support  according  to  the  specific  capacity  of  the beneficiary  and  to  changes  in  the 
economic and transport market outlook. 
197 An example is the Austrian Programme of Aid for Innovative Combined Transport (SA.60132), which is in place 
since 1999 and proved as an efficient instrument to unlock investments that otherwise would have probably not occurred, 
thanks to well-designed eligibility criteria and a strong capacity at the level of the granting authority. In Germany the aid 
programme to support innovation in rail freight transport (SA.55353) has been established to support the development 
108 

 
 
 
Considering that an increase in the overall efficiency of intermodal transport is to be expected as a 
result of the provision of economic support for different technological upgrades, but that quantifiable 
evidence is very limited as regards the effectiveness of the PM11 list of measures and the impacts 
that such innovations can produce on modal shift, it has been assumed that the stand-alone impact of 
PM11  would  be  in  the  order  of  a  4.5-5.9%  increase  of  the  effect  of  PM9,  with  impacts  varying 
depending on the mode and period considered. The impact of PM11 over 2025-2050 is estimated at 
0.1% increase in the intermodal transport activity relative to the baseline.   

Table 50: Impacts of PM11 on the intermodal transport (door-to-door) activity (billion tkm and percentage change 
compared to the baseline) 

2030 

0.5 

0.01 

0.4 

0.9 

% 
change 
to the 
baseline 
+0.2% 

+0.1% 

+0.1% 

+0.1% 

2050 

1.6 

0.01 

0.5 

2.2 

% 
change 
to the 
baseline 
+0.4% 

+0.1% 

+0.1% 

+0.2% 

2025-2050 

27.9 

0.3 

12.9 

41.1 

% 
change 
to the 
baseline 
+0.3% 

+0.1% 

+0.1% 

+0.1% 

Rail 

IWW 

SSS 

Total 

Source: Ricardo et al. support study (2023) 

Similarly to PM10, the additional volumes, to the extend they are eligible, would also receive the 
operational economic support under PM7-PM9. 

3.3.4. PM13 – exemptions from driving bans 

PM13 establishes an exemption from fixed weekend, night and holidays driving bans for intermodal 
transport road legs. For this reason, it applies only in those MS where driving bans exist. At least 13 
Member States198 are using some types of driving bans for HGVs, with public holidays driving ban used 
most commonly, followed by weekend driving bans. Several Member States already apply exemptions for 
CT road-legs. However, these exemptions are very heterogeneous, and some are discriminatory. They do 
not follow the definition established in the CTD. Five Member States do not have any exemptions for 
intermodal road legs from driving bans.  

While driving bans for road-only transport may be justified, they are creating – on top of ineffective 
logistics chain management for shippers – considerable problems for intermodal transport both as 
regards terminal  yard congestion (and  road congestion in  areas  around terminals  before  and  after 
driving ban periods) as well as ineffective use of non-road transport. Removing driving bans for road 
vehicles carrying intermodal units and part of an intermodal solution would allow to exploit unused 
capacity during the period of driving ban for running more services. For example, an intermodal rail 
service running 5 times per week can benefit from the driving ban exemption to add an additional 
run during the weekend. Currently this is hindered in many areas due to terminal yard congestion – 
the terminal would need space to store during the duration of the driving ban both the arriving loading 
units that need to be first unloaded to storing area as well as waiting loading units that need to be 
loaded onto departing service. Due to lack of such storing space, this results today in HGVs waiting 
outside and around the terminal, creating the need for building additional safe and secure parking 
areas for trucks.  

The estimate of additional intermodal traffic generated by the measure is obtained by considering the 
number of terminals operating in countries where driving bans exist, and assuming that for each of them 

and testing of innovative, including for automated cargo handling. Innovation in intermodal transport is supported as well 
within broader support programmes for investment in freight terminals, rolling stock renovation, etc. showing that varied 
innovation and efficiency gains can be triggered in rail, IWW, SSS and road legs of intermodal transport when financial 
support are available to potential investors. 
198 AT, CZ, DE, LU, SI, PL, HU, SK, FR, EL, IT, RO, ES. 

109 

 
 
 
one additional run per week can be created. The effect of the measure is expected to be observed from 
2027 onwards because the adaptation of processes to get additional slots may take some time. The impact 
of PM13 over 2025-2050 is estimated at 0.4% increase in the intermodal transport activity relative to the 
baseline.  

Table 51: Impacts of PM13 on the intermodal transport (door-to-door) activity (billion tkm and percentage change 
compared to the baseline) 

2030 

1.4 

0.1 

1.2 

2.6 

% 
change 
to the 
baseline  
+0.6% 

+0.3% 

+0.3% 

+0.4% 

2050 

2.2 

0.1 

1.5 

3.7 

% 
change 
to the 
baseline 
+0.5% 

+0.2% 

+0.3% 

+0.4% 

2025-2050 

45.4 

0.1 

33 

78.5 

% 
change 
to the 
baseline 
+0.6% 

+0.01% 

+0.3% 

+0.4% 

Rail 

IWW 

SSS 

Total 

Source: Ricardo et al. support study (2023) 

These additional volumes, if eligible, would also receive the operational economic support under PM7-
PM11. 

3.3.5. Impacts of PM7-PM13 on costs 

PM7-PM13 result in three types of effects: additional intermodal transport (modal shift), updated or 
new  minimum  aid  requirements  for  existing  operations  that  are  already  supported  voluntarily  by 
Member States (included in the baseline) and new support in Member States that do not currently 
support intermodal operations. This is expected to translate into increased budget expenditures for 
Member States, for providing economic support.  

In addition, administrative costs for operators who wish to apply for economic support (application 
preparation  and  ex-post  reporting)  are  expected.  These  costs  are  only  relevant  for  the  additional 
applicants relative to the baseline scenario. At the same time, as explained under PM3, costs savings 
are expected thanks to the use of eFTI platforms. 

Costs for PM7-PM9 

Budget expenditures for public authorities, for providing economic support  

For PM7-PM9, the additional intermodal transport activity created by these measures as stand-alone 
measures is provided in sections 3.3.1-3.3.4 above. However, PM10, PM11 and PM13 also lead to 
additional volumes of intermodal transport that would be supported under PM7-PM9. Furthermore, 
as  support  is  not  limited  only  to  newly  created  operations,  but  has  to  be  applied  to  all  eligible 
operations, the volume supported needs to take into account the extension of eligibility resulting from 
PM1/PM2. At the same time, PM12 will reduce the operations actually receiving economic support. 
Furthermore, it is expected that the vast majority of theoretically eligible operations that are shorter 
than the break-even distance will in reality not take place and thus will not apply for support. Figure 
18 shows the process  of arriving to  total  volume of intermodal  operations supported under PM7-
PM9.  

110 

 
 
Figure 18: Process of establishing the volume of traffic supported under PM7-PM9 

Eligible volumes
under PM1/PM2

Addition of new
volumes due to
PM7-PM9, 
PM10, PM11 
and PM13

Subtraction of 
not supported
operations based
on PM12

Subtraction of 
operations that
are unlikely to
take place (under
new break-even
cost)

Total volume to
be supported 
under PM7-PM9

The TRUST model was  used to establish the amount of support to be paid under PM7 and PM9, 
considering the synergies with other support measures included in the policy options. The economic 
support for 2030 and 2050 relative to the baseline by policy measure and policy option, as well as 
the present value over 2025-2050 relative to the baseline are provided in Table 51.  

Table 52: Economic support provided by public authorities due to PM7 and PM9, by policy option compared to the 
baseline (million EUR, in 2021 prices) 

Policy option 

PO-B1 (PM9) 

PO-B2a (PM9) 

PO-B2b (PM9) 

PO-C (PM7) 

2030 

246.7 

262.0 

200.3 

2050 

352.2 

437.9 

269.0 

1,665.3 

2,394.1 

Present value over 
2025-2050 
5,924.1 

6,177.1 

3,995.2 

34,825.2 

Source: Ricardo et al. support study (2023) 

For PM8, as no significant increase in the intermodal transport activity is expected relative to the 
baseline there is no impact on economic support provided by the public authorities.  

The  cost  of  support  by  policy  measure  and  Member  State,  relative  to  the  baseline,  expressed  in 
million EUR and as percent of GDP, is provided in the tables below. As explained in section 6.1.2, 
it should be noted that due to the nature of the Combined Transport Directive, where the support 
provided also depends on the applications for support by transport operators, the outcome by Member 
State may turn out to be different than estimated in this impact assessment. However, the estimates 
below provide an indication of the order of magnitude of the cost of support. 

Table 53: Estimated economic costs (cost of support) for public authorities due to PM7 in PO-C in 2030 and 2050, 
by Member State, compared to the baseline (million EUR, in 2021 prices, and percent of GDP)  

Economic support (EUR million) 

Economic support as percent of GDP 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 
FR 

2030  
36.9 
100.4 
31.4 
11.0 
0.0 
247.7 
30.7 
4.4 
130.7 
47.2 
66.1 
177.3 

2050  
69.5 
136.4 
38.4 
27.0 
0.0 
387.1 
51.5 
7.1 
200.0 
63.1 
80.2 
259.1 

111 

2030  
0.01% 
0.02% 
0.05% 
0.00% 
0.00% 
0.01% 
0.01% 
0.01% 
0.01% 
0.02% 
0.02% 
0.01% 

2050  
0.01% 
0.02% 
0.05% 
0.01% 
0.00% 
0.01% 
0.01% 
0.01% 
0.01% 
0.02% 
0.02% 
0.01% 

 
 
  
Economic support (EUR million) 

Economic support as percent of GDP 

HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
    EU-27 
Source: Ricardo et al. support study (2023) 

2030  
25.7 
33.1 
0.2 
149.1 
16.1 
17.7 
0.4 
0.0 
293.3 
64.9 
46.8 
39.2 
62.7 
22.6 
9.6 
1665.3 

2050  
26.5 
53.1 
0.3 
208.0 
38.0 
25.6 
1.0 
0.0 
345.3 
115.9 
62.5 
57.8 
97.7 
27.4 
15.6 
2394.1 

2030  
0.05% 
0.02% 
0.00% 
0.01% 
0.04% 
0.03% 
0.00% 
0.00% 
0.03% 
0.01% 
0.02% 
0.01% 
0.01% 
0.04% 
0.01% 
0.01% 

2050  
0.04% 
0.02% 
0.00% 
0.01% 
0.08% 
0.04% 
0.00% 
0.00% 
0.03% 
0.01% 
0.02% 
0.01% 
0.01% 
0.03% 
0.01% 
0.01% 

Table 54: Estimated economic costs (cost of support) for public authorities due to PM9 in PO-B1 in 2030 and 2050, 
by Member State, compared to the baseline (million EUR, in 2021 prices, and percent of GDP)  

Economic support (EUR million) 

Economic support as percent of GDP 

2030  
7.2 
13.4 
4.3 
2.2 
0.0 
41.9 
4.1 
0.7 
17.4 
5.7 
9.0 
26.5 
3.7 
6.4 
0.0 
21.7 
2.7 
3.4 
0.1 
0.0 
37.5 
10.2 
6.0 
7.0 
9.9 
3.5 
1.9 
246.7 
Source: Ricardo et al. support study (2023) 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 
FR 
HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU-27 

2050  
13.3 
17.8 
4.8 
5.2 
0.0 
62.9 
6.8 
1.3 
26.1 
7.4 
10.8 
39.8 
3.9 
10.1 
0.1 
29.5 
6.6 
4.9 
0.2 
0.0 
41.7 
17.8 
7.8 
9.9 
15.9 
4.7 
3.0 
352.2 

112 

2030  
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.01% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 

2050  
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.01% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 

 
  
  
Table 55: Estimated economic costs (cost of support) for public authorities due to PM9 in PO-B2a in 2030 and 
2050, by Member State, compared to the baseline (million EUR, in 2021 prices, and percent of GDP)  

Economic support (EUR million) 

Economic support as percent of GDP 

2030  
7.7 
14.3 
4.6 
2.3 
0.0 
44.4 
4.4 
0.8 
18.5 
6.1 
9.6 
28.2 
3.9 
6.8 
0.0 
23.0 
2.9 
3.6 
0.1 
0.0 
40.0 
10.8 
6.4 
7.4 
10.6 
3.8 
2.0 
262.0 
Source: Ricardo et al. support study (2023) 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 
FR 
HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU-27 

2050  
16.4 
22.3 
6.2 
6.4 
0.0 
79.6 
8.3 
1.6 
31.9 
8.9 
13.2 
49.1 
4.8 
12.4 
0.1 
36.4 
8.1 
5.9 
0.2 
0.0 
52.9 
22.0 
9.5 
12.8 
19.4 
5.7 
3.7 
437.9 

2030  
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.01% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 

2050  
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.02% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 

Table 56: Estimated economic costs (cost of support) for public authorities due to PM9 in PO-B2b in 2030 and 
2050, by Member State, compared to the baseline (million EUR, in 2021 prices, and percent of GDP)  

Economic support (EUR million) 

Economic support as percent of GDP 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 
FR 
HR 
HU 
IE 
IT 

2030  
4.6 
13.5 
3.7 
1.2 
0.0 
31.9 
3.6 
0.4 
16.3 
5.2 
8.0 
21.3 
2.8 
2.7 
0.0 
20.9 

2050  
6.7 
16.7 
4.3 
3.2 
0.0 
48.6 
6.8 
0.6 
21.1 
7.3 
8.9 
32.1 
3.0 
4.5 
0.0 
24.4 

113 

2030  
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 

2050  
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

 
  
  
Economic support (EUR million) 

Economic support as percent of GDP 

2030  
1.5 
0.6 
0.1 
0.0 
38.9 
7.0 
6.3 
2.0 
3.8 
2.7 
1.3 
200.3 
Source: Ricardo et al. support study (2023) 

LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU-27 

2050  
1.9 
1.0 
0.2 
0.0 
45.1 
10.6 
8.1 
3.1 
5.9 
3.1 
2.1 
269.0 

2030  
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

2050  
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Administrative costs savings for the private sector 

PM7-PM9 are expected to lead to administrative costs saving for the private sector. Operators who 
decide to apply for economic support will be subject to administrative costs related to the preparation 
of the application. These costs are only relevant to new applicants relative to baseline. However, the 
application  process  for  the  support  under  PM7-PM9  will  be  considerably  simplified  relative  to 
baseline thanks to clear eligibility rules (PM1/PM2) and the use of eFTI platforms (PM3) that will 
simplify the retrieval and submission of information to authorities for those operators that choose to 
apply  for  economic  support  –  it  will  be  possible  to  download  the  information  about  eligibile 
operations  directly  from  the  eFTI  platform.  Furthermore,  ensuring  the  same  eligibility  conditions 
across EU will allow the organisers of international operations to considerably save time and cost 
from application preparation as an eligible operation will be eligible across EU the same way. All 
applicants are assumed to save 4.2 hours per request199. The Labour Force Survey data for Non-Wage 
Labour Costs (i.e. ISCO 3 – Technicians and associate professionals) has been used (31.1 EUR/hour) 
to quantify the costs. This is expected to lead to administrative cost savings for all current applicants 
(and reduce the costs for future applicants compared to the baseline costs). The administrative costs 
savings for the private sector due to PM7-PM9, by policy option, are shown in Table 56.    

Table 57: Recurrent administrative costs savings for the private sector due to PM7-PM9 compared to the baseline 
(millions EUR, in 2021 prices) 

Policy option 

PO-A 

PO-B1 

PO-B2a 

PO-B2b 

PO-C 

PM7 

2030 

PM8 

12.4 

PM9 

PM7 

11.4 

11.5 

14.7 

2050 

PM8 

10.9 

PM9 

9.2 

8.5 

13.2 

Present value over 
2025-2050 
PM8 

PM7 

PM9 

220.1 

196.4 

192.6 

260.6 

10.5 

7.0 

172.2 

Source: Ricardo et al. support study (2023) 

Costs for PM10 and PM11 

Budget expenditures for public authorities, for providing economic support  

The budget expenditures for public authorities from starting 425 new services thanks to PM10 have 
been calculated using the final funding absorbed on average by the modal shift actions financed in 

199 In the baseline scenario the application preparation is assumed to take 16 hours.  

114 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Marco Polo II. In particular, as the budget is meant to cover the start-up investments for new services 
(new vehicles, organisational costs, etc.) and the possible losses during the first years of operation 
(i.e.  before  demand  fully  materialises).  It  is  assumed  that  SSS  requires  relatively  more  start-up 
funding than rail (EUR 0.87 million for SSS and EUR 0.60 million for rail per year per supported 
new service), and that IWW requires a lower level of support (EUR 0.40 million on average per year 
per supported new service). Based on this, it has been assumed that a Member State would allocate 
on average EUR 6 million per year for start-up measures targeting the rail and SSS sector, and EUR 
2 million for IWW. 

Table 58: Economic support provided by public authorities due to PM10 (million EUR, in 2021 prices) 

Sector 
Rail 
IWW 
SSS 
Total 

2030 
60 
4 
48 
112 

Source: Ricardo et al. support study (2023) 

Present value over 2025-2050 
596.3 
39.8 
505.3 
1,141.3 

The support for technological upgrade (PM11) foresees a list of various support tools to terminals 
and carriers, with all the support tools in the list requiring only relatively limited investments. The 
need for these investments is assessed to relate to between 1-10% of operations depending on mode 
of transport and year, with a cost of approximately 0.1% of total cost of intermodal operations. The 
support tools provided under PM11 are thus estimated to be around 0.5% of total cost of intermodal 
operations depending on mode of transport and year. 

Table 59: Economic support provided by public authorities due to PM11 (million EUR, in 2021 prices) 

Sector 

Rail 
IWW 
SSS 
Total 

2030  
3.0 
0.1 
2.0 
5.1 

Source: Ricardo et al. support study (2023) 

2050 
10.6 
0.1 
2.4 
13.1 

Present value over 2025-2050 
116.2 
1.4 
40.2 
157.9 

The cost  of support  for  PM10 and PM11 by Member State, relative to  the baseline, expressed in 
million EUR and as percent of GDP, is provided in the tables below. As explained in section 6.1.2, 
it should be noted that due to the nature of the Combined Transport Directive, where the support 
provided also depends on the applications for support by transport operators, the outcome by Member 
State may turn out to be different than estimated in this impact assessment. However, the estimates 
below provide an indication of the order of magnitude of the cost of support. 

Table 60: Estimated economic costs (cost of support) for public authorities due to PM10 in PO-B1, PO-B2a and 
PO-B2b in 2030 and 2050, by Member State, compared to the baseline (million EUR, in 2021 prices, and percent 
of GDP)  

Economic support (EUR million) 

Economic support as percent of GDP 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 

2030  
0.0 
0.0 
0.0 
6.0 
0.0 
0.0 
12.0 
0.0 
12.0 
0.0 
0.0 

2050  
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 

115 

2030  
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

2050  
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

 
  
Economic support (EUR million) 

Economic support as percent of GDP 

2030  
14.0 
12.0 
0.0 
0.0 
12.0 
0.0 
0.0 
0.0 
0.0 
14.0 
12.0 
0.0 
0.0 
0.0 
12.0 
6.0 
112.0 
Source: Ricardo et al. support study (2023) 

FR 
HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU-27 

2050  
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 
0.0 

2030  
0.00% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.02% 
0.01% 
0.00% 

2050  
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Table 61: Estimated economic costs (cost of support) for public authorities due to PM11 in PO-B1, PO-B2a and 
PO-B2b in 2030 and 2050, by Member State, compared to the baseline (million EUR, in 2021 prices, and percent 
of GDP)  

Economic support (EUR million) 

Economic support as percent of GDP 

AT 
BE 
BG 
CZ 
CY 
DE 
DK 
EE 
ES 
EL 
FI 
FR 
HR 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU-27 

2030  
0.2 
0.3 
0.1 
0.1 
0.0 
1.0 
0.1 
0.0 
0.3 
0.1 
0.2 
0.6 
0.1 
0.2 
0.0 
0.4 
0.1 
0.1 
0.0 
0.0 
0.7 
0.2 
0.1 
0.2 
0.2 
0.1 
0.0 
5.1 

2050  
0.7 
0.5 
0.1 
0.3 
0.0 
2.9 
0.2 
0.1 
0.7 
0.1 
0.3 
1.6 
0.1 
0.5 
0.0 
1.0 
0.3 
0.2 
0.0 
0.0 
1.1 
0.7 
0.2 
0.5 
0.7 
0.2 
0.2 
13.1 

116 

2030  
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

2050  
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

 
  
  
Source: Ricardo et al. support study (2023) 

Administrative costs for the private sector 

Both  PM10  and  PM11  would  bring  along  recurrent  administrative  costs  to  those  operators  who 
choose to benefit from these measures due to the application process and the need to compy with the 
potential ex-post reporting. These costs are only relevant for additional applicants relative to baseline 
scenario.  As  regards  start-up  support  applications  (PM10),  it is  assumed  that  the  applicant  has  to 
spend 11.8 hours200 on application for support and 8 hours for any subsequent reporting and payment 
requests. To estimate the costs, the tariffs per hour from the Eurostat Structure of earnings survey, 
Labour Force Survey data for Non-Wage Labour Costs (i.e. ISCO 2 – professionals) have been used 
(31.1 EUR/h). Total costs are derived by multiplying the cost per application with active supported 
services in any given period. The total administrative costs for the private sector due to PM10 and 
PM11, by policy option, relative to the baseline are reported in Table 61.  

Table 62: Recurrent administrative costs for the private sector due to PM10 and PM11, by policy option compared to 
the baseline (million EUR, in 2021 prices) 

PO-B1 

PO-B2a 

PO-B2b 

2030 

2050 

Present value over 2025-2050 

PM10  PM11  PM10 

PM11 

PM10 

PM11 

0.103  0.28 

0.104  0.27 

0.104  0.11 

0.00 

0.00 

0.00 

0.39 

0.42 

0.19 

0.55 

0.56 

0.56 

5.8 

6.0 

2.6 

Source: Ricardo et al. support study (2023) 

3.4. Data and transparency related measures (PM14-PM17) 

Costs for PM14 and PM15 

PM14  and  PM15  introduce  rules  on  data,  common  data  set  and  data  set  exchange  protocols 
respectively,  for  improved  communication  between  the  different  stakeholders  in  the  intermodal 
chain. These measures do not create obligations to use electronic transport data, but set common rules 
in  case  electronic  data  is  used.  These  measures  are  not  expected  to  create  additional  intermodal 
volume on their own.  

Adjustment costs for the private sector 

Estimating the costs for these measures is difficult. First, the number of stakeholders who will have 
to bear the costs is not known. Second, the effort that is required per company is unclear. In relation 
to the first issue, no reliable data source is available for the number of operators active in intermodal 
transport. In the EU, there about 1.2 million land transport companies alone201. Large part of these 
companies  are  not  active  in  intermodal  transport,  but  are  rather  independent/self-employed  truck 
drivers. Therefore, it has been assumed that only companies in the road or rail transport with more 
than 50 employees act in intermodal transport. According to Eurostat202 there are 11,080 companies 
with more than 50 employees in the land transport and 144 companies in the rail freight transport 
sector.  In  addition,  there  are  several  thousand  companies  in  IWW  and  SSS.  For  example,  in  the 
Netherlands  there  are  over  3,000  IWW  companies.  In  Germany  there  are  about  750  IWW 
companies203. Since the Netherlands and Germany cover a large part of the EU inland navigation, 

200 Similarly to PM7-PM9, the applicants are assumed to save 4.2 hours per request relative to the baseline (16 hours) 
due to the use of eFTI platforms (PM3). Therefore, the time per application is estimated at 11.8 hours in PM10.  
201 https://ec.europa.eu/eurostat/databrowser/view/sbs_sc_1b_se_r2/default/table?lang=en  
202 https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_1B_SE_R2/default/table?lang=en&category=sbs.serv. 
sbs_sc_sc  
203  https://www.binnenschiff.de/pressemitteilung/statistiken-zur-binnenschifffahrt-in-der-bdb-broschuere-daten-fakten-
ueber-205-mio-tonnen-gueter-auf-deutschen-fluessen-und-kanaelen/  

117 

 
 
 
one could extrapolate the number of companies to 8,000 at the EU level. In addition, the number of 
SSS companies is estimated to be similar to that in the IWW sector. 

According to  these estimations,  there  are about 27,224 companies  in  total potentially  involved  in 
intermodal transport. A survey204 asking stakeholders how much it would cost to switch to electronic 
freight documents established inter alia that two-thirds of multimodal operators were already using 
electronic transport data in intermodal shipments.  

The  Digital  Transport  and  Logistics  Forum  has  been  working  for  several  years  with  industry  on 
related questions. The most common data exchanged in transport chains has been established and 
considerable work has been done on establishing the data exchange protocol parameters. It can thus 
be  assumed  that  large  part  of  operations  would  already  meet  new  requirements  or  would  need 
minimum  adjustments.  It  is  thus  assumed  that  maximum  one  third  of  the  operators  active  in 
intermodal  transport (around 9,000 operators) would actually  be faced with  additional adjustment 
costs in PM14 and PM15.  

The effort required for revising the IT systems is estimated at 20 hours for PM14 and 80 hours for 
PM15 per company. To estimate the costs, 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 (31.1 EUR/hour). The total one-off adjustment costs are thus 
estimated at EUR 5.6 million for PM14 and EUR 22.4 million for PM15.  

Costs for PM16 and PM17 

PM16-PM17 are measures to improve transparency on terminal services and quality. PM16 foresees 
an obligation on terminal operators to publish information on services and facilities available in their 
terminal and keep it updated. A similar but not identical obligation exists on rail facilities, but no 
obligation exists to make the data available free of charge on public homepage. PM17 establishes a 
framework  for  terminal  categories  based  on  available  services  and  facilities,  based  on  a  self-
assessment. The requirements for each category would be published in a secondary EU act. A one-
off obligation would be put on the terminal operators to make their terminal categorisation visible on 
their homepage.  

Adjustment costs for the private sector 

There are 980 intermodal terminals in the EU, of which 851 have rail connection and 129 do not205. 
While rail connected terminals already have to fulfill some data requirements for rail facilities, these 
data requirements are overlapping only partially. In addition, rail facilities are not required to make 
this information available on their homepage. Under PM16, all terminal operators will have to make 
the  information  available  on  their  homepage  and  bear  the  initial  adjustment  costs  as  well  as  the 
recurrent  administrative  costs  (discussed  below)  for  updating  their  homepage.  As  the  data 
requirements are basic information readily available for the terminal operator (see Annex 10), it is 
thus  assumed  that  gathering  the  information  will  take  2  hours  of  work  initially  plus  1  hour  for 
updating  the  homepage  every  5  years.  To  estimate  the  costs,  the  tariffs  per  hour  for  ISCO  3 
(Technicians and associate professionals) have been used (31.1 EUR/hour). The one-off adjustmnet 
costs are estimated at EUR 0.18 million. The administrative costs related to updating the homepage 
are discussed in the following section.  

204 TRT (2017), op.cit. 
205 PWC, KombiConsult (2022). Note that some terminals with rail connections can be in ports and provide transhipment 
services without rail link.  

118 

 
 
As regards PM17, the obligation to self-assess the category and make it visible on their homepage is 
assumed to take not more than 1 hour of work at the initial introduction, equivalent to one-off costs of 
EUR 0.03 million.  

Table 63: Adjustment costs for the private sector due to PM14 - PM17, in millions EUR (2021 prices) 

Adjustment costs (one-off) 

Source: Ricardo et al. support study (2023)  

PM14 

5.6 

PM15 

22.4 

PM16 

0.18 

PM17 

0.03 

No costs are expected on public authorities for PM14-PM17.  

Administrative costs for the private sector 

As explained above, under PM16 all terminal operators will have to make the information available 
on their homepage and  bear the initial  adjustment costs  (dicussed above) as  well as  the recurrent 
administrative costs for updating their homepage. It is not possible to assess with precision how often 
terminals upgrade their services and facilities, but the costs are expected to be limited, amounting to 
not more than 1 hour of work every 5 years for gathering the information and updating the homepage. 
To estimate the costs, the tariffs per hour for ISCO 3 (Technicians and associate professionals) have 
been used (31.1 EUR/hour). As explained above, there are 980 intermodal terminals in the EU. The 
recurrent administrative costs are thus estimated at EUR 0.03 million (every 5 years). Expressed as 
present value over 2025-2050, total administrative costs for the private sector are estimated at EUR 
0.10 million.  

For the purpose of the application of the ‘one in, one out’ approach, the annual average cost per terminal, 
spreading the 5-years costs annually, is estimated at 6.2 EUR. Considering the 980 intermodal terminals in 
the EU, the average annual costs are estimated at EUR 6,100. 

Adjustment costs for the European Commission 

PM17 is also expected to lead to adjustment costs for the European Commission as there is a need 
for a further study to establish the most appropriate criteria for terminal category framework for all 
modal combinations. The one-off cost for the European Commision are estimated at EUR 300,000.  

119 

 
 
ANNEX 5: COMPETITIVENESS CHECK 

1. OVERVIEW OF IMPACTS ON COMPETITIVENESS  

Dimensions of Competitiveness 

Impact of the 
initiative 
(+ +/+/0/-/- -/n.a.) 

References to sub-sections of the main report 
or annexes 

Cost and price competitiveness 

International competitiveness  

Capacity to innovate 

SME competitiveness 

++ 

0 

+ 

++ 

Section 6.1.1 of the SWD, Annex 4 

N/A 

Annex 4 (methodology) and Annex 6 (retained 
measures)  

Sections 6.1.1 and 6.1.5 of the SWD, Annex 13 

2. SYNTHETIC ASSESSMENT  

2.1. Cost and price competitiveness 

The objective of the revision is to reduce negative externalities from transport through modal shift, which 
is achieved by increasing the cost and price competitiveness of the intermodal sector as compared to the 
road-only sector in the EU. Intermodal operations below a certain distance are not price-competitive with 
road only transport resulting in road-only transport still being the preferred transport option for freight 
with its resulting negative external effects. Until external costs are full internalised in the EU, regulatory 
and economic support can help to make intermodal transport price-competitive.  

The preferred policy option (PO-B2a) increases the share of intermodal that is eligible for support and 
ensures that all intermodal combinations (rail, IWW and SSS) will be eligible for support. It also increases 
the level and types of support available. In summary, it makes more operations more price competitive vis-
à-vis road only transport.   

Without operational support, the door-to-door break-even distances are on average 740 km for rail, 
260 km for IWW and 775 km for SSS. With a 10% support from total door-to-door price, the break-
even  distances  are  reduced  to  535  km  for  rail,  200  km  for  IWW  and  610  km  for  SSS.  Thus,  the 
support  provided  by  CTD  makes  shorter  operations  economically  competitive  with  road-only 
transport and thus increases the potential for modal shift. Operations shorter than these new break-
even distances will not be price-competitive with road only transport and thus are likely to remain on 
road-only transport.  

A higher percentage of support would result in even shorter break-even distances.  

Start-up support and technological upgrade support, provided for under PM10 and PM11, as well as 
exemption from driving bans provided for in PM13 are not aimed at increasing price competitiveness, but 
are enabling tools to make intermodal transport possible. However, as regards flexibility and availability, 
they make intermodal transport more competitive by allowing it to take place in more places and more 
frequently.  

120 

 
 
 
Figure  19:  Average  price-competitive  door-to-door distances  in  intermodal  transport  without  and  with  the  economic 
support of 10%, per modal combination (cost in EUR and km) 

Source: Ricardo et al. support study (2023) 

The increase in the competitiveness of intermodal transport operations is expected to have knock-on 
effects throughout the entire economy, leveraging the initial impact on the transport sector. This is also 
expected to lead to positive impacts on GDP. The impact on GDP is however estimated to be small as the 
proposal does not bring along new transport activity, but rather induces redistribution of operations 
between the modes. The changes are expected mostly due to positive effects on logistics organisers, 
terminal activity and engagement of more companies in one transport operation. PO-B2a is estimated to 
lead to 0.1% increase in GDP in 2030 and 0.3% increase in 2050 relative to the baseline.  

2.2. International competitiveness 

This revision has no impact on international competitiveness of intermodal transport as it applies strictly to 
operations within the EU.  

2.3.  Capacity to innovate 

This proposal has limited impact on capacity to innovate. By making intermodal transport more 
competitive, investment into new technologies can become interesting for the sector. Technology and 
mode-neutral, non-discriminatory support to intermodal transport and removal of limits of eligible loading 
units can trigger innovation as regards loading units and transhipment technology, or wider roll-out of 
currently marginal innovative technologies. Several stakeholders have already shown interest to invest in 
intermodal transport for loading units that are not eligible and thus competitive today (smaller containers 
suitable for urban transport, universal aviation loading units, horizontal transhipment technologies etc.). 
Furthermore, the support to technological upgrade will allow to support innovation and technological 
upgrade in general.  

2.4. SME competitiveness 

Given that SMEs represent a substantial part of the transport market, including the intermodal market, 
the assessment on the overall cost and price competitiveness aspect as provided in section 2.1, to very 

121 

 
 
 
large  extent  shall  be  applicable  also  here.  In  this  regard,  the  revision  has  an  impact  on  the 
competitiveness of SMEs providing  services in the intermodal chain or wishing to enter this market. 
For further details on SME impacts, see Annex 13.  

As explained in section 6.1.5, PO-B2a is expected to result in net costs savings for businesses, estimated at EUR 
4.33 billion, expressed as present value relative to the baseline. Considering the large share of SMEs estimated to 
operate in the intermodal transport sector, a significant share 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). 

122 

 
 
ANNEX 6: RETAINED MEASURES 

No 

Categories of measures by 
thematic area 

Problem 
drivers 
and spec. 
objective
s   

Short description 

PM1 

PM2 
all-
intra-
EU 

Include in the scope all 
intermodal operations in EU that 
save 25% GHG when using 
intermodal operation instead of 
road-only; calculation of GHG 
savings is based on common EU 
methodology (CEEU) 

Include in the scope all 
intermodal operations in EU that 
save 40% external costs when 
using intermodal operation 
instead of road-only; calculation 
of external costs is based on 
common EU methodology based 
on the unit values from the 
Handbook207, established by 
means of an implementing act. 

PD1 
SO1 

PD1 
SO1 

Establishes which operations are eligible for support provided under the CTD. The 
distance limits for different transport legs and to nearest suitable terminal, as 
used in the current CTD will be removed. There would be no size limits on loading 
units. All intermodal freight operations in the EU, including domestic operations, 
that achieve a 25% reduction of CO2e (GHG), compared to a road only transport 
between the same points, are eligible. GHG calculations will be based on the 
methodology established in the CEEU206. 

Establishes which operations are eligible for a support provided under the CTD. 
The distance limits for different transport legs and to nearest suitable terminal, 
as used in the current CTD, will be removed. There would be no size limits on 
loading units. All intermodal  operations in the EU, including domestic operations, 
that achieve a 40% reduction of negative externalities, compared to a road only 
transport between the same points, are eligible. Calculations of external costs will 
be based on a common EU methodology which uses the unit values from the 
Handbook on the external costs of transport208. References to the methodology 
will be provided in an implementing act, facilitate the update of the reference 
values to take into account the future updates of the Handbook.  

PM2 
cross- 

Include in the scope only cross-
border intermodal operations in 
EU that save 40% external costs 

PD1 
SO1 

Establishes which operations are eligible for a support provided under the CTD. 
The distance limits for different transport legs and to nearest suitable terminal, 
as used in the current CTD, will be removed. There would be no size limits on 

206  CountEmissionsEU proposal is part of the Greening Freight Package. It aims to establish a harmonised methodology to measure door-to door GHG remissions of transport operations, 

allowing for reliable results, and enable a fair comparison of different transport options. 

207 The Handbook on the external costs of transport CE Delft et al. (2019). op.cit.  
208  CE Delft (2019), Handbook on the external costs of transport, available at : https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1 

123 

 
 
 
No 

Categories of measures by 
thematic area 

Problem 
drivers 
and spec. 
objective
s   

Short description 

borde
r 

when using intermodal operation 
instead of road-only; calculation 
of external costs is based on 
common EU methodology based 
on the unit values from in the 
Handbook, established by means 
of an implementing act 

PM3 

Establish common data set for 
proof of eligibility with 
implementation via eFTI 
platforms  

PD1 
SO1 

PM4 

Replace reporting by the 
Commission with Member 
States’ voluntary analysis and 
strategic planning for sustainable 
freight transport  

PD2 
SO2 

loading units. Like in the current CTD, only cross-border intermodal freight 
operations in the EU that achieve a 40% reduction of negative externalities, 
compared to a road only transport between the same points, are eligible. 
Calculations of external costs will be based on a common EU methodology which 
uses the unit values from the Handbook on the external costs of transport. 
References to the methodology will be provided in an implementing act, facilitate 
the update of the reference values to take into account the future updates of the 
Handbook.  

This is a measure to implement PM1 and PM2s. It establishes a clear and 
harmonised definition of data required for the proof of eligibility, including in case 
of road-side checks. Data should cover the whole chain of the transport activity 
and make it possible to follow the operation door-to-door. The list of data 
elements builds on the compromise reached in the negotiations on the previous 
revision  of CTD in 2019.  

All eligible operations have to provide transport data electronically using eFTI 
platforms209. The eFTI platforms will include a dedicated option for intermodal 
transport and a ‘plug-in’ calculator of external costs, to reduce administrative burdens 
to operators. This will enable both, the transport organiser as well as authorities 
carrying out road-side checks to immediately see if an operation is eligible or not. 

Establishes a regime for the market monitoring and analysis, where the Members 
States are invited to conduct an analysis of their transport system and 
sustainable freight transport (rail, IWW, SSS) to allow design their support based 
on empirical evidence. Based on the analysis, Member States would be invited to 

209  Regulation (EU)  2020/1056  of  the  European  Parliament  and  of  the  Council  of  15  July  2020  on  electronic  freight  transport  information  (he  eFTI  Regulation)  establishes  a  legal 
framework that allows economic operators to share information in an electronic format concerning the transport of goods in the EU hinterland by road, rail, inland waterways and air, 
to prove compliance with applicable transport legislation. 

124 

 
 
 
No 

Categories of measures by 
thematic area 

Problem 
drivers 
and spec. 
objective
s   

Short description 

PM5 

PM6 

PM7 

Replace reporting by the 
Commission with Member 
States’ mandatory analysis and 
strategic planning for all freight 
transport system (cross-modal). 
An obligation to regularly review 
the measures.  

Reporting by the Commission 
with revised monitoring data and 
reporting period, including a 
review clause for reassessing the 
support regime established in 
the CTD.  
Obligation for Member States to 
notify ex ante their support 
schemes, which the Commission 
has to make available in a 
common website  
Mandatory harmonised support, 
does not constitute State aid: 
Harmonised obligation on 
Member States to provide 
support with an aim to reduce 
door-to-door costs of intermodal 
operations at a level that 
induces modal shift; remove all 

PD2 
SO2 

PD2 
SO2 

PD3 
SO3 

prepare a plan on how to best support modal shift and address the specific 
problems in their transport system.  

Establishes a regime for the market monitoring and analysis, where Members 
States are obliged to conduct an analysis of their transport system, with a special 
focus on trends for intermodal transport and bottlenecks for increased uptake. 
The regular analysis has to cover all modes of transport (including road-only) and 
analyse inter alia the cross-modal trends, issues and projections. Based on the 
analysis, Member States have to prepare a plan on how to best support modal 
shift and address the particular problems in their transport system. This plan and 
related measures are updated regularly (every 5 years).  
Establishes a regime for the market monitoring and analysis, by retaining the 
current obligation in Article 5 for Commission to report about the market 
situation of intermodal transport in EU. The list of data to be reported will be 
updated and the reporting period will be extended from current 2 years to 5 
years, to allow sufficient time for measures to have impact between reports. 
Member States have to notify to the Commission a link where they publish ex-
ante information on the opening new support schemes. The Commission will 
make all these links available on its homepage. 

Establishes a regime for mandatory harmonised support, where the Member 
States will be required to provide economic support through co-financing the cost 
of the non-road leg by a fixed percentage. The scheme is established in detail as 
regards the eligibility, eligible costs, level of support (aid intensity) as well as 
beneficiaries, without leaving any discretion to the Member States. Such a 
scheme would be considered not constituting State aid as it would not be 
imputable to the Member State. Therefore, the measure would not be subject to 
the obligation under article 108(3) TFEU that requires Member States to notify all 

125 

 
 
No 

Categories of measures by 
thematic area 

Problem 
drivers 
and spec. 
objective
s   

Short description 

PM8 

PM9 

existing regulatory measures 
(Articles 2, 4, 7, 8, 9) 
Voluntary non-harmonised 
support, the State aid rules 
apply, where relevant: call on 
Member States to use 
operational support tools from 
the Toolbox with an aim to 
reduce door-to-door costs of 
intermodal operations at a level 
that induces modal shift 

State aid to the European Commission for prior authorisation210. Existing 
regulatory support measures (articles 2, 4, 7, 8, 9) would be deleted.  
Establishes a regime for voluntary support, where the CTD includes a non-binding 
aim for inducing sufficient modal shift. In order to achieve this aim, Member 
States are invited to implement support tools chosen from a list provided in the 
CTD.  

PD3 
SO3 

A Toolbox of support tools will be annexed to the revised CTD, from which the 
Member States will be free to select support tools suitable to particular Member 
State’s situation. Any support should be provided to operations eligible under the 
CTD.  

Mandatory non-harmonised 
support, the State aid rules 
apply, where relevant: obligation 
on Member States to have at 
least one operational support 
tool from the Toolbox with an 
aim to reduce door-to-door costs 
of intermodal operation at a 
level that induces modal shift 

PD3 
SO3 

The measures would have to be notified under State aid rules, where relevant. 
Simplified procedures or block exemptions may apply to schemes that meet 
relevant conditions. 
Establishes a regime for mandatory non-harmonised support, where the CTD 
includes an obligation to Member States to adopt at least one support scheme for 
operational support with the main characteristics defined in the Toolbox in the 
annex to the CTD. Member States have the flexibility to choose the type of 
measure best suitable for local conditions. The Toolbox includes options such as 
support to transhipment costs as well different options for supporting operational 
costs of different legs. The support measures in combination should aim at 
reducing the overall door-to-door operational costs by 10%.  

Any support scheme needs to comply with State aid rules, where relevant. 
Simplified procedures or block exemptions may apply to schemes that meet 
relevant conditions.  

210  Commission Notice on the notion of State aid as referred to in Article 107(1) of the Treaty on the Functioning of the European Union, 2016/C 262/01, paragraphs 44-46, https://eur-

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

126 

 
 
 
No 

Categories of measures by 
thematic area 

PM10  Voluntary support, the State aid 
rules apply, where relevant: call 
on Member States to provide 
start-up support 

PM11  Mandatory non-harmonised 
support, the State aid rules 
apply, where relevant: obligation 
on Member States to have at 
least one technological upgrade 
support measure from the 
Toolbox 

Problem 
drivers 
and spec. 
objective
s   

Short description 

PD3 
SO3 

PD3 
SO3 

Establishes a regime for voluntary support, where Member States are invited to 
provide economic support for setting up new rail, IWW or SSS routes to 
connection organisers or such scheduled routes (shuttles) with open access to all 
shippers/chain organisers where such routes carry a majority of operations 
eligible under the CTD. The support should be limited to routes that are currently 
not served or where no similar intermodal routes exist in the vicinity. Such 
support is in particular useful in case of new terminals. The start-up support 
should be limited in time and be reduced gradually. 

This policy measure cannot be mandatory, given that need for such support is 
not universal. 

Start-up support will be part of the Toolbox annexed to the CTD. Any support 
scheme needs to comply with State aid rules. Simplified procedures or block 
exemptions may apply to schemes that meet relevant conditions.  
Establishes a regime for mandatory non-harmonised support, where the CTD 
includes an obligation to Member States to adopt at least one technological 
upgrade scheme for operational support with main characteristics defined in 
Toolbox in the annex of the CTD, while leaving the flexibility to choose the type 
of measure best suitable for local conditions to the Member States. 

The measure refers to upgrades for loading units, machinery and digital 
equipment with a limited budget impact, but acting as important enablers. This 
support will also facilitate innovation in intermodal sector. The beneficiaries will 
be carriers of different intermodal legs, organisers or terminal operators, 
depending on the specific support tool. The support will be provided when it is 
shown that the vehicles, vessels or terminal equipment is used for eligible 
operations. 

Any support scheme needs to comply with the State aid rules, although most of 
the support in this category might be below of the de minimis threshold 
(currently EUR 200 000 per Member State to a single undertaking over any 

127 

 
 
No 

Categories of measures by 
thematic area 

Problem 
drivers 
and spec. 
objective
s   

Short description 

PM12 

Limit the direct financial support 
only to short and medium-long 
operations that are normally not 
cost-competitive with road-only 
transport (mode specific 
thresholds) 

PM13  Exempt road-legs of eligible 

operations from weekend and 
holiday driving bans  

PD3 
SO3 

PD3 
SO3 

PM14  Define a data set for information 
to be shared between parties of 
transport chain by means of an 
implementing or delegated act 

PD4 
SO4 

period of three fiscal years, EUR 100 000 in case of undertakings performing road 
freight transport for hire or reward) and thus would not need to be notified.  
Sets an upper door-to-door distance limit for operations, which can benefit from 
the mandatory economic support.  

Intermodal operations become competitive with road-only transport at certain 
longer distance. This average distance is different for different modal 
combinations. This measure allows to limit the mandatory support only to 
operations that are not competitive with road -only operations and would thus 
not take place without a support. This will reduce the budgetary burden to 
Member States and would ensure more efficient use of resources. Different cut-
off distances are established for each modal combination with rail, IWW and SSS.  
An obligation to exempt the road legs of eligible intermodal transport from fixed 
(night, week-end and holiday) driving bans.  

Such driving bans cause considerable problems for logistics chain as road legs 
cannot be carried out directly before or after the non-road leg. This results in 
terminal yard congestion, larger traffic jams just before and after the driving ban 
times and inability to efficiently fill the rail, IWW or SSS vehicle/vessel during 
such driving bans limiting the time non-road leg timetables.  
This measure provides for an obligation to Member States and private parties to 
ensure that a defined set of harmonised data will be established to ensure 
enhanced data interoperability between the railway, inland waterways (IWW), 
short sea shipping (SSS) sectors, road sectors and terminals. The data sets could 
be developed based on existing modal initiatives and data sets defined therein 
(TAF TSI for rail, RIS for IWW and TIS for SSS). The details, including the 
definition of the data set, will be left for an implementing or delegated act.  

There is currently no obligation in EU law that would specify and/or require the 
data in an intermodal chain to be interoperable between different operators and 

128 

 
 
No 

Categories of measures by 
thematic area 

Problem 
drivers 
and spec. 
objective
s   

Short description 

PM15  Establish an obligation to use 

common data exchange 
protocols for operations covered 
by this Directive by means of an 
implementing or delegated act 

PM16  Require terminal operators to 

publish information on services 
and facilities available in each 
terminal. List of mandatory 
information to be established in 
an implementing act. 

PM17  Provide a possibility to establish 
a framework of terminal 
categories based on minimum 
requirements on 
services/facilities available at 
terminals, by means of an 
implementing act. 

PD4 
SO4 

PD4 
SO4 

PD4 
SO4 

modal-specific systems. Lack of this interoperability results in inefficiencies and 
inability to plan and follow a loading unit.  

This measure provides for an obligation to Member States and private parties to 
use common data exchange protocols between transport modes and different 
parties. The data exchange protocols would be based on the work of the DTLF211, 
which is in the process of developing main elements for constructing an open and 
neutral data sharing infrastructure for freight transport and logistics based on a 
federation of platforms, not limited to any specific mode or modal combination. 
The details, including the definition of the data set, may be left for an 
implementing or delegated act. 
A common list of information relevant specifically to intermodal operations and 
applicable to all modal combinations would be established with an obligation to 
make it publicly available and keep up to date. The details (list of information) 
would be established in an implementing act. This relates especially to available 
services and facilities but also to information on access by transport modes, 
number and length of operation tracks, type of loading units handled, crane 
technology AGV, electrification and value added services. 
A simple framework of quality level (categories) of terminals will be established. 
Terminal categorisation would be based on a selected list of the main 
characteristics on availability of facilities and services, based on the list of 
information established by PM16. Given that the characteristics reflect facilities 
and services, which can be easily observed, the categorisation would not entail 
accreditation or centralized regular assessment. Such a categorization would 
allow quick comparison of terminals. It will be motivating the operators to 

211  Digital  Transport  and  Logistics  Forum  is  an  expert  group  of  the  European  Commission  bringing  together  public  and  private  stakeholders  from  various  transport  and  logistics 
communities to support the European Commission in promoting the digital transformation of the transport and logistics sector. https://transport.ec.europa.eu/transport-themes/digital-
transport-and-logistics-forum-dtlf_en 

129 

 
 
 
No 

Categories of measures by 
thematic area 

Problem 
drivers 
and spec. 
objective
s   

Short description 

upgrade the quality of their terminals, and can be used as benchmark for 
investors. 

The list of categories with required characteristics would be established in an 
implementing act.  

130 

 
 
ANNEX 7: DISCARDED MEASURES 

Problem 
drivers 
and spec. 
objectives   

Categories 
measures by 
thematic area 

Extend the scope 
to all multimodal 
operations 

PD1 
SO1 

PD1 
SO1 

PD1 
SO1 

PD4 
SO4 

Extend the support 
to all intermodal 
operations, 
including to the 
parts taking place 
outside of EU 
territory 

Encourage support 
to eligible 
operations, without 
a list of tools 

Establish common 
data standards for 
eligible operations 

Short description and reason for 
discarding 

All support under the CTD would have been 
available not only intermodal but for all 
multimodal operations that save externalities.  

Legally, identifying the eligible multimodal 
transport activities and distinguishing them 
from unimodal non-road transport would have 
been very difficult. Enforcement of application 
on multimodal transport would not have 
allowed to use the eFTI shipment-based data 
sets, given that goods are often regrouped at 
loading and unloading points between the 
modes. It would have been impossible to follow 
one load, e.g. a parcel or bulk goods, from 
door-to-door. It was also assessed that with 
multimodal transport, and in particular for 
some types of goods such as heavy bulk goods 
like coal, grain, oil, dangerous goods, etc., 
there would be high risk of deadweight profit 
seeking. Finally, extending the scope of 
support to almost all non-road transport would 
bring along considerably increase in expected 
budget contributions, which was assessed to be 
politically unacceptable. 

The measure would have extended support, 
including economic support also to the parts of 
intermodal operations that take place outside 
of EU territory.  

This measure was considered not acceptable 
both due to high financial costs as well as due 
to difficulties for implementation.  

The measure would have called Member States 
to provide support to intermodal transport, but 
leaving the choice, type and design of the 
support entirely to the Member States, 
including abolishing current fiscal support 
tools. 

This measure was considered as ineffective for 
achieving the objectives.  
The measure would have established common 
data standards for only the supported 
intermodal operations. On-going horizontal 
policy work is ongoing for all transport 
operations aiming to establish harmonized 
rules for interoperable information sharing 

131 

 
 
 
Categories 
measures by 
thematic area 

Problem 
drivers 
and spec. 
objectives   

Short description and reason for 
discarding 

across all segments of the transport and 
logistics sector. These initiatives, including the 
common European mobility data space, and 
the Digital Transport and Logistics Forum 
(DTLF) are expected to provide for generic 
solutions to be further customized for 
individual applications, such as the combined 
transport. 
The measure would have included a call to 
industry to elaborate voluntary terminal 
categories framework. The value added of such 
a call in EU legislation is limited. 
The measure would have created one or more 
centralised platforms for improving freight 
transport stakeholders’ cooperation. Horizontal 
cooperation for load sharing and vertical 
cooperation for chain organisation would have 
been covered. Such private initiatives exist but 
mandating them at centralised level is not 
following subsidiarity principle.  

Call for industry-
driven terminal 
categories 
framework 

Establishment of 
EU freight 
transport horizontal 
and vertical 
cooperation 
platforms 

PD4 
SO4 

PD4 
SO4 

132 

 
 
ANNEX 8: HISTORICAL CONTEXT FOR CTD 

The CTD was first adopted in 1975. The main political objective for the CTD has been since the adoption 
of the first CTD improvement of the environmental performance of the transport system212.The original 
Directive was amended five times to extend the beneficial regime to a wider set of operations. The 
general EU climate and environmental objectives were reconfirmed over the years at more ambitious 
levels resulting inter alia in several amendments and amendment proposals for this Directive.  

In 1992 the Commission published the White Paper on Transport and accompanying legislative package 
that led to today’s CTD entirely liberalising the CT market in EU and providing today’s support framework. 
The accompanying proposal on strategic combined transport terminal network was not adopted.  

In 1997, The Commission published a dedicated strategy on intermodal transport in Europe213. Since then, 
there have been two attempts to amend the CTD, in 1998214 and 2017215.  

The 1998 revision proposed an extension of eligibility to domestic operations, a road leg limit based on a 
20% share in total operation and exclusion of island transport. It also proposed exempting CT road legs 
from weekend driving bans. The proposal was stalled in European Parliament, and the Commission 
withdraw the proposal in 2001.  

In 2011, the Commission published the Transport White Paper216, which set a specific goal of shifting by 2030 30% of 
long-distance road freight (over 300 km) to rail or waterborne transport, and more than 50% by 2050.  

The European Parliament highlighted in 2015 that a European sustainable mobility policy needs to build 
on a broad range of policy tools to shift towards the least polluting and most energy-efficient modes of 
transport in a cost-efficient manner217.  

A REFIT evaluation218 of the CTD was published in 2016 that concluded that the CTD continues 
to  be  a  relevant  instrument  for  supporting  CT.  It  was  estimated  that  the  shift  from  road-only  to 
intermodal  transport  has  brought  along  an  annual  saving  of  up  to  €2.1  billion  in  external  costs 
(2011). While not all of this saving can be attributed to the CTD, it was established that without EU 
action,  cross-border  CT  services  would  likely  have  been  faced  with  barriers  of  different  legal 
systems, making CT services less attractive and possibly unfeasible. The evaluation also showed 
that there is significant margin for further improving the effectiveness of the CTD as some of its 
provisions are outdated or unclear. The shortcomings relate in particular to the narrow eligibility 
and too low economic support. In addition, the evaluation concluded that the transposition is not 
always homogenous and allows contradictory or misleading interpretation and implementation (see 
section 2.2.1).  

In 2017, the European Parliament requested a revision of the CTD to increase multimodal transport, 
eliminate unfair practices and ensure compliance with the social legislation relating to CT.219  

212 Preamble of 75/130/EEC states: “Whereas the use of the road/rail method for the international carriage of goods by 
road is economically advantageous over long distances,  whereas it reduces road traffic and thus enhances road safety; 
whereas at the same time it contributes to the protection of the environment;…” 
213 COM(97) 243 final. 
214  COM(98) 0414 final. 
215 COM(2017)0648 final. 
216 COM(2011) 144 final. 
217 https://www.europarl.europa.eu/doceo/document/TA-8-2015-0423_EN.html  
218 SWD(2016) 140 final. 
219 https://www.europarl.europa.eu/doceo/document/TA-8-2017-0009_EN.html  

133 

 
 
 
As a result, the Commission adopted a proposal in 2017 to amend the CTD with a focus on clarifying the 
definition and increasing the support to be provided. The 2017 impact assessment accompanying the 
amendment proposal established that the goal in 2011 Transport White Paper will not be met without 
additional intervention. The proposal clarified the existing definition in light of existing case law and 
complaints without changing the approach based on fixed distances for different parts of the operation. It 
also proposed to promote investment into terminal infrastructure and considerably improve the fiscal 
and economic support tools.  

While  all  Member  States  welcomed  the  amendment  and  supported  the  objective  to  improve  the 
competitiveness of CT, any proposals to extend the eligibility were met with resistance220. Similarly, 
many Member States were against an obligation to facilitate the increase of terminal capacity221.As 
regards  increased  support  to  CT  operations,  Member  States  views  diverged222.  This  was  further 
challenged  by  some  Member  States’  efforts  to  abolish  the  equivalent  treatment  for  use  of  non-
resident  road  hauliers  in  all  international  intra-EU  transport.  The  European  Parliament  broadly 
supported  the  proposal,  proposed  further  ambition  as  regards  the  economic  support,  but  also 
requested some exemptions. Progress was made in two trilogues, but the Council was unable to 
agree on a mandate for a third trilogue, which resulted in the European Parliament adopting its first 
reading  outcome  not  reflecting  the  progress  made  in  the  trilogues.  Consequently,  several 
amendments introduced by the co-legislators modified the proposal in a manner which, if adopted, 
would  have  significantly  reduced  the  effectiveness  of  the  Commission  proposal.  Therefore,  the 
Commission withdrew its proposal, concluding that the necessity of increasing the share in total 
transport of sustainable transport modes under the European Green Deal required stronger support 
for multimodal solutions.  

The EESC adopted an opinion in 2021 questioning the need for the financial promotion and regulatory 
support.223  

220 18 Member States supported retaining the scope only on operations between Member States.  
221  No  Member  State  supported  the  obligation  to  promote  terminal  investment.  15  Member  States  could  agree  on 
obligation to encouraging to promote terminal investment. 9 Member States were against any obligation in this regard.  
222 No Member State supported harmonised mandatory support. The rest of the Member States supported an obligation 
to provide support when the choice of support tool was left to Member States. 
223 https://www.eesc.europa.eu/lt/our-work/opinions-information-reports/opinions/intermodal-transport-and-
multimodal-logistics-making-modes-complementary-greening-transport-own-initiative-opinion  

134 

 
 
 
ANNEX 9: TOOLBOX OF SUPPORT TOOLS 

Below preliminary list serves as an example of types of support tools that can be included in the 
Toolbox to be annexed to the revised CTD  

Without prejudice to State aid rules and in particular conditions for eligible costs, beneficiaries and 
aid intensities, the support provided in this Directive, and contributing to the objective to ultimately 
reduce the cost to shippers by 10%, falls into the following categories:  

Part 1: operational support for eligible intermodal operations 

(a)  Support  to  reduce  the  costs  borne  by  intermodal  transport  organisers  (shippers,  logistics 
companies), such as total transport (door-to-door) costs, transhipment costs or transport costs 
for non-road legs;  

(a)  Support to reduce the costs borne by operators who organise the intermodal transport operation, 
such  as  transport  costs  per  loading  unit  transported,  external-cost  charges  or  congestion, 
charges for the use of certain infrastructure; 

Part 2: Start-up support 

The financial start-up support to cover, for limited time period, costs related to operating  a new 
intermodal transport scheduled route on rail, IWW or SSS 

Part 3: Technological upgrade support 

Support  to  reduce  the  costs  borne  by  operators  for  investments  in  technological  upgrade  for 
intermodal transport, such as: 

(a)  investments  to  identify the semi-trailers used in  intermodal  transport in accordance with  the 
identification regime established pursuant to international standards ISO6346 and EN13044,  

(b)  investments to make the non-cranable semi-trailers to become cranable 

(c)  investments  for  the  integration  of  connected  systems  and  the  automation  of  operations  in 
intermodal transport, digital logistics, related information and communication technologies and 
intelligent  transport  systems  that  are  necessary  for  the  smooth  functioning  of  intermodal 
transport  operations,  in  particular  support  for  investments  into  terminal  photogates  and 
automatic check-in/check-out booth,  

(d)  investments  into  low-emission  vehicles  or  vessels  or  transhipment  technology  in  intermodal 

transport,  

(e)  investments for the purchase of equipment to allow transhipment of semi-trailers, such as gantry 

crane grapple arms for vertical transhipment of semi-trailers 

135 

 
 
 
 
ANNEX 10: TRANSPARENCY REQUIREMENTS ON TERMINALS 

Below preliminary list serves as an example of types or information potentially required to be made 
public by terminal operators for each terminal on their homepage.  

Information  

Information 

Terminal  and 
operator 

Non-road 
connections 

Loading units 

•  Name, address and coordinates of the terminal  
•  Contact details of the operator of the terminal  
•  Opening times 

List the destinations that are directly connected to the terminal, including mode/transport 
system and name of operators of such connections and frequency and days of departures 
per destination 
•  Types of loading units handled, description of limitations 
•  Service facilities for loading units (repair, maintenance, cleaning, weighing of containers, 

stuffing/stripping)) 

Handling 

•  Technical equipment for loading and unloading, including type and number of handling 

equipment 

•  Number and length of handling tracks (rail)/No. of loading berths, total (usable) length 

and draught (IWW/SSS) 

•  Priority rules 
•  Maximum load for handling 
•  Handlings per hour 
•  Access conditions 
•  Waiting areas 
•  Facilities 
•  Waiting times 
•  Weighting of vehicles 
•  Available storage capacity 
• 
Time limits for storage 
•  Applicable restrictions (dangerous cargo (incl. class), reefer and reefer power supply, 

Services for 
road hauliers 

Storage 

IT systems 

Other facilities 

etc.)  
• 
Empty container depot 
•  Use of photogates, OCR 
•  Use of digital check-in and check-out 
•  Data exchange main systems 
•  Customs, phytosanitary inspections 
•  Packing 

136 

 
 
 
 
ANNEX 11: TERMINAL CATEGORIES – RAIL 

Below  list  of  terminal  categories  for  rail  serves  as  an  preliminary  example  of  conditions  to  be 
included in the terminal categories.  

Category 

Conditions 

A 

B 

C 

D 

E 

All types of intermodal loading units can be transhipped/handled 
740m long tracks exist under the crane 
Possibility to enter/exit the terminal with the main/electric locomotive via continuous tracks (no 
shunting required) 
At least 10 daily rail departures. At least 5 rail destinations 
Daily theoretical handling capacity in 600 ILUs and 15 trains  
Digital photogates are in use. Automatic check-in and check-out booths are in use.  
All types of intermodal loading units can be transhipped/handled 
740m long tracks exist under the crane 
Possibility to enter/leave the terminal with the main/electric line locomotive (no need for 
shunting).  
At least 8 daily rail departures. At least 4 rail destinations 
Daily theoretical handling capacity 450 ILUs and 12 trains. 
Digital photogates are in use. Automatic check-in and check-out booths are in use.  
All types of intermodal loading units can be transhipped/handled 
740m long trains can be handled with a reasonable efficiency even though 740m tracks are not 
there 
Shunting is needed as main locomotives cannot enter the terminal 
At least 4 daily rail departures. At least 2 rail destinations 
Daily theoretical handling capacity 300 ILUs and 8 trains. 
Digital photogates are in use. Automatic check-in and check-out booths are in use.  
Not every type of intermodal loading unit can be transhipped/handled at the facility 
740m long trains can be handled with a reasonable efficiency even though 740m tracks are not 
there 
Shunting is needed as main locomotives cannot enter the terminal 
At least 5 weekly rail departures. At least 3 weekly rail destinations. 
Daily theoretical handling capacity 200 ILUs and 6 trains. 
Digital photogates and automatic check-in and check-out booths are not in use.  
Not every type of intermodal loading unit can be transhipped/handled at the facility 
740m long trains cannot be handled efficiently 
Shunting is needed as main locomotives cannot enter the terminal 
One weekly connection, one rail destination.  
Daily theoretical handling capacity 80 ILUs and 1 train. 
Digital photogates and automatic check-in and check-out booths are not in use.   

137 

 
 
 
 
 
ANNEX 12: EFFECTIVENESS OF THE POLICY OPTIONS 

The following table summarises the expected effectiveness of each policy option, complementing the description in section 7.1. 

Strongly negative 

Weakly negative 

No or limited impact 

Weakly positive 

Strongly positive 

Unclear 

PO A 

PO B1 

PO B2a 

PO B2b 

PO C 

General objective: Facilitate an increase in the share of rail, short sea shipping and inland waterways in total intra-EU freight transport to contribute to reducing negative 
externalities as well as energy consumption of transport 

Impact on volume of 
intermodal transport in 
the EU 

Very small positive impact 
on the volume of intermodal 
transport: cumulatively over 
the 2025-2050 period, PO-A 
is expected to result in a 
0.11% increase in intermodal 
volumes  (door-to-door) 
relative to the baseline 
scenario. 

Strongly positive impact on 
the volume of intermodal 
transport: cumulatively over 
the 2025-2050 period, PO-B1 
is expected to result in a 
6.41% increase in intermodal 
volumes relative to the 
baseline scenario. 

Strongly positive impact 
on the volume of 
intermodal transport: 
cumulatively over the 
2025-2050 period, PO-B2a 
is expected to result in a 
6.43% increase in 
intermodal volumes 
relative to the baseline 
scenario. 

Positive impact on the 
volume of intermodal 
transport: cumulatively 
over the 2025-2050 
period, PO-B2b is 
expected to result in a 
4.96% increase in 
intermodal volumes 
relative to the baseline 
scenario. 

Positive impact on the 
volume of intermodal 
transport: cumulatively over 
the 2025-2050 period, PO-C 
is expected to result in a 
3.83% increase in intermodal 
volumes relative to the 
baseline scenario. 

Reduction in external 
costs of transport 
(including CO2 
emissions, air pollutant 
emissions, fatalities and 
injuries, noise, and road 
congestion) 

Very small positive impact 
on external costs of 
transport: PO-A is expected 
to save EUR 753.8 million 
worth of external costs 
expressed as present value 
over 2025-2050, relative to 
the baseline scenario (in 

Strongly positive impact on 
external costs of transport: 
PO-B1 is expected to save 
EUR 14.4 bn worth of external 
costs expressed as present 
value over 2025-2050, relative 
to the baseline scenario (in 
2021 prices).  

Strongly Positive impact 
on external costs of 
transport: PO-B2a is 
expected to save EUR 15.3 
bn worth of external costs 
expressed as present value 
over 2025-2050, relative 
to the baseline scenario (in 

Positive impact on 
external costs of 
transport: PO-B2b is 
expected to save EUR 
10.7 bn worth of 
external costs expressed 
as present value over 
2025-2050, relative to 
the baseline (in 2021 

Medium positive impact on 
external costs of transport: 
the PO-C is expected to save 
EUR 6.6 bn worth of external 
costs expressed as present 
value over 2025-2050, 
relative to the baseline 
scenario (in 2021 prices).  

138 

 
 
 
 
 
 
 
 
Strongly negative 

Weakly negative 

No or limited impact 

Weakly positive 

Strongly positive 

Unclear 

PO A 

PO B1 

PO B2a 

PO B2b 

PO C 

2021 prices).  

2021 prices).  

prices). 

Specific objective 1: Provide support to a wider range of operations under effective eligibility conditions 

Impact on the share of 
intermodal operations 
eligible for support 

Positive effect on the share 
of operations that are 
eligible for support provided 
under the Directive.  

Positive effect on the share of 
operations that are eligible 
for support provided under 
the Directive.  

PO-A is expected to increase 
the volume of eligible 
intermodal operations by 
33.4% in 2030 and 30.2% in 
2050, compared to the 
baseline scenario (reflecting 
the current CTD).  

PO-B1 is expected to increase 
the volume of eligible 
intermodal operations by 
33.4% in 2030 and 30.2% in 
2050, compared to the 
baseline scenario (reflecting 
the current CTD). 

However, eligibility based on 
GHG only will result in part 
of waterborne transport and 
all IWW not being eligible for 
support as of 2035 onwards. 

However, eligibility based on 
GHG only will result in part of 
waterborne transport and all 
IWW not being eligible for 
support as of 2035 onwards.  

Strongly positive effect on 
the share of operations 
that are eligible for 
support provided under 
the Directive.  

Positive effect on the 
share of operations that 
are eligible for support 
provided under the 
Directive.  

PO-B2a is expected to 
increase the volume of 
eligible intermodal 
operations by 33.5% in 
2030 and 33.2% in 2050, 
compared to the baseline 
scenario (reflecting the 
current CTD). 

Eligibility conditions 
ensure that all modal 
combinations have 
equivalent accessibility to 
support (technology 
neutral). 

PO-B2b is expected to 
increase the volume of 
eligible intermodal 
operations by 27.1% in 
2030 and 26.9% in 2050, 
compared to the 
baseline scenario 
(reflecting the current 
CTD). 

Eligibility conditions 
ensure that all modal 
combinations have 
equivalent accessibility 
to support (technology 
neutral). 

Positive effect on the share 
of operations that are 
eligible for support provided 
under the Directive.  

PO-C is expected to increase 
the volume of eligible 
intermodal operations by 
33.5% in 2030 and 33.2% in 
2050, compared to the 
baseline scenario (reflecting 
the current CTD). 

Eligibility conditions ensure 
that all modal combinations 
have equivalent accessibility 
to support (technology 
neutral). 

Suitability and clarity of 
eligibility conditions 

Positive effect on clarity and suitability of eligible conditions: the new data set for proof of 
eligibility and the use of eFTI platforms will simplify the process and reduce the cost and 
time, requiring less effort from operators and making it easier for authorities to verify 

139 

 
 
 
 
 
 
 
 
 
Strongly negative 

Weakly negative 

No or limited impact 

Weakly positive 

Strongly positive 

Unclear 

PO A 

PO B1 

PO B2a 

PO B2b 

PO C 

eligibility, thereby reducing risk of fines and administrative procedures.  

Specific objective 2: Ensure better support by improving reporting on multimodal / intermodal transport 

Impact on availability of 
information and analysis 
of intermodal market 

Small positive effect. Under 
PO-A, some additional 
Member States are expected 
to start carrying out regular 
analysis and strategic 
planning for intermodal 
transport. 

Positive effect. Centralised analysis by the Commission ensures better accessibility to 
information about the overall EU market for industry from different Member States. 
The 5 year period ensures  that analysis can capture the impact of measures. 
Notification and publication on Commission homepage of upcoming support schemes 
allows equal access to support for all EU operators. Automatic review clause of the 
Directive ensures that support will be kept up to date.  

Positive effect. Ensures 
Member States are well 
aware of the intermodal 
market and cross-impacts 
between different modes 
and the impacts of their 
support schemes.  Does not 
ensure equally easy access 
to information for all EU 
operators (language 
barriers). 

Support is appropriate 
and effective 

Small positive effect may 
take place in the longer run 
and due to peer pressure. 
While in the first part of the 
period, Member States are 
not expected to change their 
existing support schemes or 
to introduce new ones, upon 
their expiry, Member States 
are expected to design new 
measures in compliance with 

Strongly positive effect. Member States are expected to 
design new measures in compliance with eligibility 
conditions under CTD, but keeping in mind local conditions 
and problems. They are expected to follow the guidance on 
eligible costs as established in the Toolbox. These 
conditions are expected to ensure that support is 
appropriate and effective to achieve the reduction of break-
even distance and ensures comparable outcome in all 
Member States and for all operators notwithstanding the 
modal combination.  

Additional start-up support ensures that new non-road 

Positive effect. Member 
States are expected to 
design new measures in 
compliance with 
eligibility conditions 
under CTD, but keeping 
in mind local conditions 
and problems. They are 
expected to follow the 
guidance on eligible 
costs as established in 

Small to medium positive 
effect. Harmonised support 
ensures that support is 
appropriate and effective to 
achieve the reduction of 
break-even distance. 
However, as starting position 
in different Member States 
are heterogeneus, single 
type of support is expected 
to have also varying effect in 

140 

 
 
 
 
 
 
 
 
 
 
Strongly negative 

Weakly negative 

No or limited impact 

Weakly positive 

Strongly positive 

Unclear 

PO A 

PO B1 

PO B2a 

PO B2b 

PO C 

eligibility conditions under 
CTD and follow the guidance 
on eligible costs. These 
conditions are expected to 
ensure that support is 
appropriate and effective.  

connections/services can be easier established, in particular 
to new terminals, thereby enabling the use of intermodal 
transport and considerably increasing the effectiveness of 
the option.  

different Member States and 
for different modal 
combinations and in some 
Member States could result 
in reduction of support.   

the Toolbox, but only for 
international operations. 
Some Member States 
may opt for less or no 
support for the domestic 
operations. Therefore 
the support could be less 
effective in achievinb the 
reduction of break-even 
distance. The outcome in 
all Member States and 
for all operators may not 
be always comparable.  

Additional start-up 
support ensures that 
new non-road 
connections/services can 
be easier established, in 
particular to new 
terminals, thereby 
enabling the use of 
intermodal transport 
and considerably 
increasing the 
effectiveness of the 
option. 

Distance at which 

No or limited positive effect 

Positive impact. Reduces the 

Positive impact. Reduces 

Positive impact. Reduces 

Positive impact. Reduces the 

141 

 
 
 
 
 
 
 
 
 
Strongly negative 

Weakly negative 

No or limited impact 

Weakly positive 

Strongly positive 

Unclear 

PO A 

PO B1 

PO B2a 

PO B2b 

PO C 

intermodal transport is 
price-competitive with 
road-only transport 

compared to baseline as 
Member States are mostly 
expected to continue with 
current support schemes.  

distance at which intermodal 
transport is price-competitive 
for operations eligible for 
operatioal support under this 
option.  

The break-even distances are 
reduced from 740 to 535km 
for rail, from 260km to 200km 
for IWW and from 775km to 
610km for SSS. 

the distance at which 
intermodal transport is 
price-competitive for 
operations eligibile for 
operatioal support under 
this option.  

the distance at which 
intermodal transport is 
price-competitive for 
operations eligibile for 
operatioal support under 
this option.  

The break-even distances 
are reduced from 740 to 
535km for rail, from 
260km to 200km for IWW 
and from 775km to 
610km for SSS. 

The break-even distances 
are reduced from 740 to 
535km for rail, from 
260km to 200km for 
IWW and from 775km to 
610km for SSS. 

distance at which intermodal 
transport is price-
competitive for operations 
eligibile for operatioal 
support under this option.  

The break-even distances are 
reduced from 740 to 535km 
for rail, from 260km to 
200km for IWW and from 
775km to 610km for SSS. 

Specific objective 4: Improve transparency and cooperation and simplify entry to the market 

No effect  

No effect  

Ease of data exchange 
between parties in 
intermodal transport 
chain 

Positive impact on exchange 
of data along the intermodal 
transport chain: harmonised 
data set would ensure that 
minimum data is 
interoperable between all  
modes and Member States.  

However, a common dataset 
for all modes would mean 
that data specific to modal 
operations would not be 
covered and this would 

142 

Positive effect on exchange 
of data along the intermodal 
transport chain: common 
data exchange protocol set 
would ensure flexible and 
effective way for ensuring 
data is interoperable 
between all  modes and 
Member States.  

Obligation applicable only to 
operations eligible under this 
directive would however 

 
 
 
 
 
 
 
 
 
Strongly negative 

Weakly negative 

No or limited impact 

Weakly positive 

Strongly positive 

Unclear 

PO A 

PO B1 

PO B2a 

PO B2b 

PO C 

seriously limit the effect. 

Data obligation applicable 
only to operations eligible 
under this Directive would 
limit the effect of such data 
rules. 

limit the effect of such data 
rules. 

Ease of access to 
terminal information 

Positive effect to shippers, intermodal transport organisers and in parrticular new entrants: the new requirements for terminal operators proposed by 
PM16 would ensure that essential information on terminal operations, their facilities and services would be easily and freely available, allowing 
potential users to assess if modal shift is a possibility for them.  

Categorisation of terminals (PM17) would provide a better overview of the quality level of terminals, to shippers, authotiries and financiers. The 
visibility of such categorisation would provide a motivation for terminal operators to upgrade the most important facilities and services and tehreby 
improve the efficiency of total intermodal chain.  

143 

 
 
 
 
 
 
 
 
See sections, 6 
(Economic 
impacts), 8 
(Preferred option) 
and Annex 4 

See annex 2 
(Stakeholder 
consultation) 

See sections 6.1 
(Economic 
impacts) and 
Annex 4 

ANNEX 13: SME TEST 

Step (1) of the SME test (identification of affected businesses). 
Directly affected. SMEs active in intermodal transport would fall under the scope of this initiative. 
The exact number of involved SMEs is not known, but SMEs are estimated to dominate its subsectors, 
with 99% of the total road-hauliers224,225 and IWW sector being SMEs. In rail 93% of companies are 
SMEs and in maritime 98%. Based on desk research, it has been assessed that approximately 27,000 
companies could be involved in intermodal transport, most of them SMEs in the road sector. It should 
be noted however that as access to terminals requires often special training of drivers and large road 
vehicle fleets, dedicated companies dominate the intermodal road sector and micro-companies are not 
that active in intermodal transport, though they are sometimes subcontracted.  
Road-hauliers currently carrying out road-only transport will also be impacted when operations shift 
from road-only to intermodal.  
In addition, SMEs as shippers are a major beneficiary of the CTD support. While many larger shippers 
already use intermodal transport. Their large volume of transported goods allows them to benefit from 
the more competitive sub-segment of intermodal transport on rail, the block trains.  For the SMEs 
however the volumes remain low and access to intermodal transport often requires the use of 
consolidator, either a logistics company or a multimodal transport organiser. These services are less 
competitive vis-à-vis road transport and thus the support to increase the price-competitiveness of 
intermodal transport is important for attracting SMEs to use these services.  
Indirectly affected. The number of SMEs indirectly affected will be larger but is not quantifiable. 
Increased use of intermodal transport often results in creation of new supporting services, in particular 
around terminals (hospitality sector).  
Step (2) of the SME test (consultation of SME stakeholders). 
The methodological approach used in consultation activities consisted in gathering specific data on 
SMEs and micro-enterprises from the stakeholders consulted (OPC, targeted questionnaires and 
targeted interviews), SMEs were asked to identify themselves. It should be noted that most SMEs 
were represented in the consultations by the sector associations.  
Targeted consultations. 19 out of 39 respondents to the survey questionnaire in the targeted 
stakeholders’ consultation identified themselves as SMEs.  
Open Public Consultation. The OPC was organised from to 08 March to 30 May 2022. 6 out of 23 
companies that responded to the OPC identified themselves as SMEs (1 small and 5 medium-sized 
companies). 
Step (3) of the SME test (assessment of the impacts on SMEs). 
Direct impacts on SMEs. It has not been possible to quantify the impact specifically for SMEs.   
An increase in intermodal transport will have positive economic impact on all SMEs other than 
road hauliers. The SME shippers will have a wider choice of transport options and easier 
access to the market, thanks to new terminal transparency obligations. The SMEs logistics 
operators engaged in organising intermodal transport operations as well as SME transport 
operators in rail and waterborne transport are expected to experience increases in business 
opportunities as volumes increase. The technological upgrade support (PM11) is expected to 
particularity benefit SMEs, though it will remain in Member States’ competence to decide if 
they limit the support to SMEs only or not. 
As regards road hauliers, those engaged today in intermodal transport will benefit from 
increased transport volumes. For those engaged today in long-distance road-only transport that 
would be replaced by intermodal transport, two options are present (continue on other 
routes/clients or switch to intermodal road legs), leaving it up to hauliers themselves to choose 
the action (no mandatory obligations to shift). Where modal shift occurs, road hauliers can 
decide to also shift from long-distance road transport to intermodal road legs. However, it 
should be noted that the modal shift predicted is small compared to remaining road freight 
transport. In 2030, only 1.2% of road freight transport will be replaced by non-road transport 
(26 bn tkm in 2030), while 9 bn tkm of new intermodal road legs will be created.  
As explained in section 6.1.4, all policy options are expected to result in net costs savings for 
businesses, estimated at EUR 5.46 billion in PO-C, followed by PO-B2a with net costs savings 
estimated at EUR 4.33 billion, PO-B1 with net costs savings of EUR 4.30 billion, PO-A with 

224https://eur-lex.europa.eu/resource.html?uri=cellar:9d5c61bf-4629-11e7-aea8-
01aa75ed71a1.0001.02/DOC_1&format=PDF   
225 https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_1B_SE_R2__custom_3493320/default/table  

144 

 
 
 
net costs savings estimated at EUR 3.57 billion, and PO-B2b with net costs savings estimated at 
EUR 3.43 billion, expressed as present value relative to the baseline. Considering the large share of 
SMEs estimated to operate in the intermodal transport sector, a significant share 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). 
Indirect impacts on other SMEs. Indirect impacts on other SMEs such as hospitality sector will be 
positive due to new business opportunities.  
Step (4) of the SME test (minimizing negative impacts on SMEs). 
Minimising negative impacts.  
An intermodal transport operation usually involves two different road transport operators 
carrying out the road legs at each end of the operation. While the total number of kilometres 
driven on road will reduce – as is the objective of the CTD - the price for intermodal road legs 
is not per kilometre, but rather per time and intermodal road legs are considered more 
profitable per kilometre. The road carriage price is quoted per time or per operation, because a 
considerable amount of waiting is involved both at loading and unloading and in terminals for 
the drivers. In addition, there are less empty truck operations which will also increase the 
profitability for hauliers.   
Alternative options. None. 

See section 6.1 
(Economic 
impacts), 7 (How 
do options 
compare), 8 
(Preferred PO), 
Annex 4 and 
Annex 5 

145 

 
 
 
ANNEX 14: FINANCIAL SUPPORT MEASURES AND MODAL SHIFT 

Ex-post evidence on the effectiveness of financial support measures on the uptake of intermodal 
transport is generally limited. Member States are not required to evaluate their measures, but some 
evaluation reports are available. They typically provide an overview of the measure, its objectives, results 
achieved for the period of assessment, the budget spent and key result or performance indicators (which 
vary depending on the desired output and type of beneficiaries). 

The most commonly used measure for effectiveness is an estimate of the transport volumes that have 
been shifted to intermodal transport during the assessment period. In some cases, other indicators have 
been considered to proxy the extent to which the scheme has been successful in promoting a modal 
shift226. 

Marco Polo II (2007-2013) 

The Marco Polo programmes were mostly performance based and provided funding to the transport and 
logistics sector to support certain actions aiming to shift transport off the road. The final report on the 
Marco Polo II programme227 discusses the effectiveness of both Marco Polo programmes but with focus 
on Marco Polo II. 

In Marco Polo I (2003-2006), the final funding amounted to EUR 41.8 million, which is 41% of the funding 
initially available. The funded actions resulted in a modal shift of 21.9 billion tonne-kilometre (tkm), i.e. 
about 46% of the initial modal shift target.  

Marco Polo II (2007-2013) had longer duration and higher budget available than Marco Polo I, and 
included two new types of actions (Motorways of the Sea and traffic avoidance). Furthermore, besides 
introducing changes to procedures to facilitate participation from applicants, the funding intensity was 
doubled from 1 to 2 EUR for each 500 tkm shifted off the road (i.e. from 0.002 to 0.004 Euro per tkm 
shifted). 

The modal shift target for Marco Polo II was also higher (20.5 billion tkm per year, or 143.5 billion tkm 
during the entire programme), in line with the increase in EU freight transport that was expected over the 
programme duration. However, the initial target became out of reach because of the financial crisis and 
the economic context.  

The level of target achievement for Marco Polo II actions differed depending on transport mode, with rail 
actions having the highest level of achievement. Rail actions represented 46.5% of the program’s total 
achieved modal shift followed by maritime transport (35.3%), and IWW (1.7%), while traffic avoidance 
actions and mixed actions contributed to the remaining 16.5%. The lower level of success for IWW 
actions was mainly explained by stronger competition from road transport on shorter distances, unstable 
water levels and infrastructure limitations.  

The table below shows the overall results achieved by modal shift actions (both closed and terminated 
actions) funded under Marco Polo II.  

226 E.g. the correlation between the goods moved under the scheme and the change in transported volumes across the 
desired  modes;  traffic  volumes  shifted  as  a  proportion  of  total  transported  volumes  across  the  desired  modes; 
comparison between  the  change  in  transported  volumes  for  a  specific  Member  State  and  the  change  in  transported 
volumes for the rest of the EU (to show how the scheme worked in a country relative to the rest of the EU). 
227 INEA (2020), Marco Polo II Programme, Final report. 

146 

 
 
 
 
Mode 

Table 64: Results from all modal shift actions funded under Marco Polo II 
Final funding 
(million EUR) 
67.6 
1.8 
30.4 
99.8 

68% 
2% 
30% 
100% 

Rail 
IWW 
SSS 
Total 

Share 

Modal shift impact 
(billion tkm) 
19.5 
0.7 
14.8 
35.0 

Share 

56% 
2% 
42% 
100% 

Source: INEA (2020) 

Additional insights about the Marco Polo II outcomes were collected through questionnaires replied by 
programme beneficiaries, including: 

•  Overall, beneficiaries commented that their actions and services were very successful, and 
that the programme was instrumental in their decision to set up a new intermodal service. 
The  main  reason  for  the  success  was  that  the  financial  support  helped  to  increase  their 
business capacity and minimise the financial risks. However, some also highlighted that this 
came  with  overcomplicated  administrative  procedures  and  cumbersome  requirements  in 
particular in recording costs. 

•  The programme had sustainable impact given that 97% of the services supported continued 
their operations after the end of the grant and became self-sustained financially. Moreover, 
the  programme  had  a  spillover  effect  as  it  was  used  by  many  beneficiaries  (60%  of  the 
respondents) as a model for the development of similar services, not supported by grants. 
•  For  almost  all  responding  beneficiaries  the  benefits  of  Marco  Polo  II  are  wider  than  the 
modal  shift  effect  itself  and include improved market  conditions,  optimised load factors, 
more  opportunities  for  rail  transport,  a  more  stable  and  efficient  supply  chain,  improved 
know-how  in  the  area  of  intermodal  transport  and  enhanced  collaboration  between  ports 
across countries. 

•  Finally,  the  responding  beneficiaries  consider  that  the  co-funding  (2  EUR  per  500  tkm 

shifted) was broadly adequate. 

Evidence from other support measures for intermodal transport 

Ex-post evaluations of national support schemes for intermodal transport are quite rare, which makes it 
difficult to draw conclusions on how the schemes have performed in terms of modal shift impacts and 
uptake of intermodal transport. The measures that have been evaluated are mostly subsidies/grants at 
the national level, where MS valuation was mainly driven by a commitment at EU level or the need for 
permission by the Commission for measures classified as State aid. Overall, the evaluations produced 
tend to differ in terms of methodology and type of performance indicators considered, which makes 
cross-comparison of policy performance difficult. 

Considering the support provided to end users of intermodal transport service (i.e. demand-side support), 
descriptive evidence on policy performance is available for two Italian support schemes, i.e. Ferrobonus 
and Ecobonus. Ferrobonus aid was given to users of railway services to optimise the use of intermodal rail 
freight transport and enforce a modal shift from road to rail, while Ecobonus aimed to implement a 
modal shift from road to short-sea transport. Considering feedback from the Commission decisions and 
academic literature, both these schemes succeeded in achieving a modal shift from road to rail or SSS and 
a positive effect on freight volumes transported by the desired modes: 

•  The Commission decision on the Ferrobonus prolongation of 2016 already indicates that the 
first edition of the programme achieved its goals. The aid amounts to 1.05 EUR per total train-
km and led to an increase of rail intermodal transport by 3.8 million train-km (+17.3%) between 

147 

 
 
2009-2010 and 2010- 2011228. Moreover, focusing on the rail connection Genoa-Barcelona, a 
2015 study229 reckons that Ferrobonus created a shift of 1.13% of transported tons off the road, 
and an increase of rail transport activity of 55,838 tonnes per year. 

•  As for the Ecobonus, a report from Italian authorities230 concludes that this scheme created an 
increase of RoRo traffic volumes between Italy and Spain of 12.1% between 2007 and 2010, 
compared to pre-scheme volumes. In absolute terms, 87,564 trailers shifted from road network 
to SSS routes. Moreover, the report observes that Ecobonus has sustained RoRo traffic demand 
also after the end of the scheme, estimating that 14% (1.332 million tonnes out of the 9.409 
million) of freight transported over the 2011-2013 period on Italian-Spanish RoRo routes have 
to be credited to the Ecobonus. 

Considering supply-side support to intermodal transport, evaluation of modal shift impacts has been 
produced for two Austrian support schemes, which were offered to railway undertakings to compensate 
for additional costs faced by rail and so shift freight from road to rail. The first aid targets the “provision 
of certain intermodal transport services by rail”, while the other targeted investments in “Innovative 
Combined Transport” technologies and equipment.  

•  The  EC  State  aid  decision  of  2017231  on  the  Aid  for  transport  of  goods  by  rail  in  certain 
combined transport services for 2018-2022 suggests that the initial scheme proved effective in 
delivering modal shift. According to estimates from Austrian authorities, the scheme led to an 
increase of 2.8% of transport services in tkm in the supported production forms232 during the 
period 2013-2015.  

•  According  to  the  evaluation  report  from  the  Austrian  authorities233,  the  Aid  for  Innovative 
combined  transport  achieved  a  shift  of  road  transport  to  other  modes  of  transport  of  58.12 
billion  tkm  for  2009-2014  and  of  47.74  billion  tkm  for  2015-2020.  Considering  that  such 
volumes represented approximately 24% and 36% of the total freight volumes transported via 
rail and IWW in the respective evaluation periods, the scheme was deemed highly effective in 
terms of modal shift outcomes. 

The following table summarizes the evaluation of State aid effects in the aforementioned four schemes. 
Note that the effects are observed during the period covered by the evaluation reports, while long-term 
effects are not included. Moreover, the reported modal shift impact should be read as an indication of 
effects rather than hard evidence, since none of the evaluation reports used methods allowing for the 
identification of causal effects. 

Table 65: Results from support measures at Member State level 

Support measure 

Type of measure 

Financial 
support 

Total 
amount 

Modal shift 
volume 

228 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52017XC0317(01)&from=EN  
https://ec.europa.eu/competition/state_aid/cases/264873/264873_1872028_67_2.pdf  
229 Tsamboulas, D., et al. (2015), The Ferrobonus Incentive for  Achieving Modal Shift to Rail: A Socio-Economic 
Evaluation (No. 15- 2839). 
230 RAM Spa (2019) “Analysis of practices to support multimodality”. CHARGE – Interreg Italy-Croatia: Deliverable  
5.1.1. 
231 https://ec.europa.eu/competition/state_aid/cases/269839/269839_1971628_105_5.pdf  
232 The scheme provides for support to rail services in the following three production forms of freight rail transport: 
i) single wagonload traffic ("SWT"), ii) unaccompanied combined transport ("UCT") and iii) accompanied combined 
transport ("RoLa") by compensating additional costs which are faced by rail transport but not by road transport. 
233 https://www.bmk.gv.at/themen/innovation/publikationen/evaluierungen/ikv.html. 

148 

 
 
 
 
Ferrobonus (2010-11) 

SA.32603 

Direct grant users 
of rail service  

1.05€ per 
train-km 

Aid for rail transport in 
certain intermodal 
transport services 

Direct grant to 
railway 
undertakings 

Up to 26.71 
per 1000 tkm 

23.3 
million 
EUR 

3.8 million train-
km (+17.3%) 

1,118  

+2.8% tonne-km 

Rail  

(IT) 

Rail  

(AT) 

Rail 

(AT) 

Rail 

(AT) 

(2013-17) 

SA.33993 

Aid for Innovative 
combined transport 

(2009-14) 

Aid for Innovative 
combined transport 

(2015-20) 

SA.41100 

Subsidy to railway 
undertakings for 
acquisition of 
technologies and 
equipment 

n.a. 

n.a. 

15.1 
million 
EUR 

10.8 
million 
EUR 

67.0 
million 
EUR 

58.121 billion 
tkm (+36%) 

47.74 billion tkm 

(+24%) 

87,564 
semitrailers 
(+12.1% vs. pre-
scheme levels) 

SSS 

(IT) 

Ecobonus (2007-10) (aid 
for international Ro-Ro 
routes between IT-ES) 

Direct grant to 
truckers 

30% of the 
RoRo fare 
charged to 
truckers 

Source: Impact assessment support study for the review of the Community guidelines on State aid for railway 
undertakings (2023), State aid decisions, national authorities evaluation reports. 

Finally, more general conclusions on State aid for rail freight are also provided in the recent “Impact 
assessment support study for the review of the Community guidelines on State aid for railway 
undertakings”, drawing from existing evidence from rail sector policy support. Relevant conclusions for 
design and assessment of support measures for intermodal freight include:  

•  Granting authorities could specifically target routes and segments that show greatest potential 

for the modal shift. 

•  Reducing  costs  in  an  intermodal  transport  chain  could  incentivise  a  substantial  number  of 
customers to move from road to intermodal transport. Most demand for transport is on short 
routes where trucks are predominant. Therefore, State aid which reduces the distance at which 
rail becomes more competitive than road would likely be effective in fostering a modal change. 
•  National rail transport in small countries also needs to be supported to compete with road, since 
it cannot  exploit  economies of scale. Yet  another example of services in  need of support is 
IWW transport, where distance travelled is typically shorter than that travelled by rail and the 
tonnages transported are lower due to higher instances of the transport of empty containers. 
•  Compared to investment State aid, operational aid has greater potential to distort competition 
within the rail freight segment, but it can more effectively facilitate a modal shift to rail in the 
short term. Investment State aid for infrastructure and rolling stock can be expected to reduce 
operating  costs  in  the  long-term  by  supporting  the  use  of  modern  and  efficient  technical 
solutions. Compared to operating State aid, such aid has less potential to distort competition 
within the rail freight segment, but it would likely take longer to facilitate a modal shift to rail. 
•  To learn about the effectiveness and efficiency of various scheme designs, evidence is required, 
but ex-post evaluations for State aid schemes under the Railway Guidelines are very rare. The 
introduction  of  the  requirement  to  evaluate  schemes  could  facilitate  the  generation  of  such 
evidence, and allow for better informed choices of scheme design in the future. 

149