Position paper: The definition of Combined Transport Operation 27/02/24

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The definition of Combined Transport Operation: good logic, but it needs to be simplified

The European intermodal sector asks for the replacement of the calculator-definition in the European Commission proposal with the approach presented in this position paper. The uncertainties arising from an implementing act to be drawn up by the Commission and the updating process of the Transport Externality Handbook could this way be eliminated.

The term of "combined transport operation" is a creation of European law dating back to 1975. Criticisms of the current definition were collected from several actors during the impact assessments carried out as part of prior attempts to amend the Directive. Consequently, the European Commission determined that there is a need for the definition of “combined transport operation" to be reformed.

Bearing in mind that the sector has always called for a level playing field between the various modes of transport based on the internalisation of external costs, factoring in the external cost advantage of door-to-door intermodal freight transport over its unimodal road haulage alternative is a logical and a relevant choice.

The resulting proposal of the European Commission, replacing the combined transport definition with an external cost calculator and a 40% threshold is theoretically possible. Nevertheless, the intermodal transport sector is highly sceptical of its practicability in everyday use.  On this basis, the calculator received several criticisms from intermodal customers, shippers and logistics service providers.  The definition should give a simple, harmonised and undisputed Europe-wide solution, while eliminating uncertainties.

The European intermodal freight transport sector proposes the following definition to be used in the revised Combined Transport Directive:

The reference values contained in Table 69 of the current edition of the Transport Externality Handbook - the same as in the European Commission impact assessment study – have been used to model the ratio of non-road modes to road needed in an intermodal transport operation to qualify as a combined transport operation that saves 40% of external costs compared to its unimodal road haulage alternative.  The result over long distances is a ratio of 60:40 non-road sections to road sections of a single intermodal transport operation, which should be possible to derogate from wherever the terminal density and the available transport capabilities do not support it.  The applicable ratio should be at least 50% for the non-road modes until 2035.

The definition proposed above is based on modelling with the following assumptions:

  • The end-to-end road alternative covers a distance that is 15% shorter than the door-to-door combined transport operation;
  • A Euro 6 diesel truck is used for both the combined transport road legs and the unimodal road haulage; and
  • 40% of the external costs of the end-to-end unimodal road haulage operation had to be saved.


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UIRR Posiition paper: CT operation Definition EN