Intermodal sector wants a simple and clear definition of combined transport 16/03/24

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Author: Łukasz Kuś



Intermodal sector wants a simple and clear definition of combined transport


In the amendment to the Combined Transport Directive currently being processed, the European Commission wants to change the definition of this type of freight transport. According to the International Union for Road-Rail Combined Transport (UIRR), an umbrella organisation for Europe’s intermodal transport sector, the definition proposed by the European Commission is too complicated.

Intermodal sector wants a simple and clear definition of combined transport


The amendment to the Combined Transport Directive is one of the elements of the legislative package on green transport. Among the EC’s proposals is to replace the current definition of combined transport with the not very precise term ‘closest appropriate terminal’. This formulation is criticised by entrepreneurs and experts because it is not known who is to choose the terminal and basing on which criteria. As a result, there is a risk that support for combined transport may finance services that are not necessarily sustainable transport.

According to the EC proposal, ‘intermodal transport’ is to be defined as the transport of goods carried out in closed cargo units, which are carried out with reloading between various modes of transport without packing and unpacking operations. However, ‘combined transport’ is a type of intermodal transport that reduces external costs by 40 per cent compared to activities related only to road transport. The calculation of these external costs will be performed using a special calculator available on the digital platform established under the Electronic Freight Transport Information Regulation (eFTI).

New definition

The calculator-based definition has been criticised by representatives of logistics companies and cargo shippers. There is a lot of uncertainty about the methodology for calculating external transport costs, which may change over time and depend on local conditions, such as the energy mix of a single country. For this reason, UIRR has proposed a simpler definition of combined transport, which is as follows:

“An intermodal transport operation where the non-road modes of transport carry out more than 50 per cent of the actual distance that the intermodal loading unit is carried. The 50 per cent should change to 60 per cent in 2035 reflecting the anticipated enhancements in terminal density and rail infrastructure development”.

Adopting such a definition will mean that the ‘combined transport’ category will include transport with the same share of individual modes of transport as in the EC proposal but calculating whether a given service meets the criteria will be much simpler. Moreover, the entry into force of the amendment to the Directive will not depend on implementing the eFTI platform in each member state, which may occur with delays. “Removing uncertainties and unnecessary complexity, while maintaining the principle of external cost advantage was the objective of the intermodal sector when devising its recommendation on how to improve the definition of combined transport operation”, explained UIRR President Ralf-Charley Schultze.