UIRR Position Paper - Directive 92/106 amendment: a good proposal 23/01/18

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UIRR Position Paper - Directive 92/106 amendment: a good proposal

The European Commission proposal to amend Directive 92/106[1] is viewed positively by the intermodal sector.  During its review, no conceptual flaws were identified, however a number of suggestions – technical in nature – are offered in this paper to complement and to further enhance the Commission proposal.

UIRR, the industry association of the European Combined Transport sector, has been calling for the amendment of Directive 92/106 since many years.  The latest such request was issued in a position paper titled “Intermodal transport warrants for an EU initiative” published on 19 May 2016.

On 8 November 2017 the European Commission adopted its proposal to amend the Directive.  In this position paper UIRR analyses the proposal in respect of the impacts on the Combined Transport sector, the aims of its suggestions being to foster the continued development of Combined Transport and to contribute to sustainable freight transport.

The Commission’s proposed amendments are the product of nearly four years of preparation:

  • A comprehensive 639-page study was prepared by a consortium of consultants[2]
  • Under the guise of the study, an extensive public consultation of stakeholders[3] was carried out (between 23 May and 15 August of 2014)
  • The Directive 92/106 was put through the Regulatory Fitness and Performance Test (REFIT)[4] that was initiated in November 2014 under the Juncker Commission’s better regulation agenda.
  • A second public consultation to prepare the amendment was carried out between 23 January and 23 April of 2017[5]

The entire preparatory process leading to the amendment proposal was actively assisted by UIRR.


  1. Overview of the Commission’s amendment proposal    p.  2
  2. UIRR suggestions    p.  3
    • Definition of a ‘combined transport operation’   p.  3
    • Provision of evidence of a ‘combined transport operation’   p.  6
    • Monitoring and reporting   p.  7
    • State-aid provisions   p.  8
  3. Summary and UIRR recommendations  p.10


[1] http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52017PC0648&from=EN

[2] https://ec.europa.eu/transport/sites/transport/files/themes/strategies/studies/doc/2015-01-freight-logistics-lot2-combined-transport.pdf

[3] https://ec.europa.eu/transport/sites/transport/files/media/consultations/doc/2014-combined-transport/summary.pdf

[4] https://ec.europa.eu/info/law/law-making-process/evaluating-and-improving-existing-laws/refit-making-eu-law-simpler-and-less-costly_en

[5] https://ec.europa.eu/transport/themes/urban/consultations/2017-CTD_en

Related documents
UIRR Position paper Dir 92/106 EN