Road Legislation Proposal harms Intermodality 29/01/14

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29 January 2014

Road Legislation Proposal harms Intermodality

European transport associations in the road-rail, rail and inland waterway sector are increasingly worried about the upcoming vote in the European Parliament on the amendment of Directive 96/53 on the weights and dimensions of road vehicles, as well as the commencement of the proposal's deliberation in the European Council.

Whilst the title of the legislation suggests that it should cover road transport, it includes a number of issues that affect combined transport. This concerns in particular the introduction of a new definition for "intermodal transport", as well as particular rules on short sea shipping. These changes are being proposed without a relevant impact assessment and without adequate consultation of the affected stakeholders involved in combined transport operations. This is particularly striking as Directive 92/106 on Combined Transport is coming up for revision in the near future and preparatory work on this proposal has already started within the Commission. It makes very little sense, therefore, to create legal uncertainty by introducing conflicting definitions of combined and intermodal transport in two different sets of legislation.

The European Union has a long history of supporting multi-modality and combined transport with the aim of improving the overall environmental performance of the EU’s transport system. This is reflected in a number of policies, such as the Transport White Paper, the TEN-T Guidelines and the Combined Transport Directive. In many Member States, this has also been the basis of financial investment in infrastructure that serves the needs of combined transport. Introducing random changes to the EU’s approach to combined transport through a piece of legislation ostensibly addressing a single mode risks rendering the EU’s transport policy inconsistent and jeopardising the success of past investments.

Multimodal transport should be dealt with in a “multimodal” legislation

We would therefore urge decision makers to return to the original definition of combined transport included in Directive 92/106 and to consider any changes they may wish to make in this area in the framework of the revision of the Combined Transport Directive on the basis of a thorough impact assessment.

In this context, we would also like to point out that the use of 44t gross vehicle weight trucks is currently restricted to combined transport operations in line with Annex I of Directive 96/53. This encourages users to choose transport solutions for the transport of heavy goods that involve rail and inland waterways, i.e. sustainable modes that are naturally suited to carry large and heavy loads. The fact that circulation of 44t gross vehicles is taking place for non-combined transport operations within the territory of a small number of Member States should not lead decision-makers in the European Parliament and in the Council to allow these heavier trucks in border crossing traffic (which is presently limited to 40t). This would be likely to adversely affect international competition as well as the delicate balance of modes in longer distance land transport. Any such changes should therefore be subject to a prior impact assessment.


Description of issuing organisations:

UIRR: Founded in 1970, the International Union for Road-Rail Combined Transport (UIRR) represents the interests of European road-rail Combined Transport Operators and Transhipment Terminal Managers. Road-Rail Combined Transport (CT) is a system of freight forwarding which is based on efficiently and economically inserting electric rail into long-distance (road) transport-chains through the use of intermodal loading units (ILU).

EFIP: The European Federation of Inland Ports (EFIP) is the official voice of nearly 200 inland ports in 19 countries of the European Union, Moldova, Switzerland and Ukraine. EFIP highlights and promotes the role of European inland ports as real intermodal nodal points in the transport and logistics chain, combining inland waterway transport with rail, road, and maritime transport.

CER: The Community of European Railway and Infrastructure Companies (CER) brings together more than 80 members - European railway undertakings, their national associations as well as infrastructure companies. The membership covers long-established bodies, new entrants and both private and public-sector organisations. CER members represent about 70% of the rail network length, more than 85% of the rail freight business and over 96% or rail passenger operations in EU, EFTA and EU accession countries.

UIP: Founded in 1950, the UIP – International Union of Wagon Keepers, with its seat in Brussels, is the umbrella association of national associations from fourteen European countries, thus representing more than 250 keepers with approximately 180.000 freight wagons, performing 50 % of the rail freight tonne-kilometres throughout Europe. UIP represents the members’ concerns at international level. By means of research, lobbying and focused cooperation with all stakeholders and organisations interested in rail freight transportation, the UIP wants to secure on the long term the future of rail freight transport.

EBU: The European Barge Union (EBU) represents the majority of the inland navigation industry in Europe. Its members are the national associations of barge owners and barge operators of meanwhile 9 leading European inland navigation countries. EBU’s main objective is to represent the interests of the inland shipping industry at a European and international level and to contribute to the development of a sustainable and efficient European transport system.

Related documents
Common Statement on Weights and Dimensions EN