Europe needs connectivity through Combined Transport
Don’t withdraw the Combined Transport Directive revision proposal - there is a solution!
The EU co-legislators are hereby encouraged to implement the changes to the Combined Transport Directive (92/106) proposed by UIRR and the Intermodal Community to transform it into an efficient framework legislation for Door-to-Door Combined Transport (D2DCT) as a mode of freight transport on its own right and the backbone of the transport system. D2DCT should be viewed as an effective tool to deliver on a range of transport policy objectives including competitiveness, resilience, energy, labour, infrastructure and environmental efficiency, military mobility, road accident prevention, fossil fuel decoupling, and road congestion reduction.
Every fourth tonne-kilometre of long-distance land freight transport is performed by Door-to-Door Combined Transport (D2DCT) that uses rail freight or inland barges already today. Adding maritime intermodal transport by coastal navigation and when supplying islands using short sea shipping vessels the ratio of D2DCT climbs even higher. Intercontinental commercial links by deep sea shipping is effectively supported by port hinterland Combined Transport to and from all major seaports. In performing these missions, D2DCT is the only alternative to unimodal trucking.
90% of the consignments carried by D2DCT today are part of a cross-border European supply chain. D2DCT, as a European freight transport service, is essential to enable the competitive functioning of the European Single Market and the supply of European citizens. This cross-border angle justifies the need for a harmonised European regulatory framework, much alike the unimodal road sector regulations on access to the profession (1071/2009) and access to the market (1072/2009) as recently amended by Regulation 2020/1055.
European transport policymakers recognised the need to develop this alternative to trucks already in the early 1970s when Europe encountered the oil crises. Minimising the road component of transport chains using non-road modes of transport, such as electrified rail freight and waterborne means made possible by efficient intermodal transhipment techniques, distinguishes D2DCT as the backbone of the transport system. D2DCT should therefore be recognised as a mode of freight transport on its own right.
The modernised Combined Transport Directive should contain
- An updated, improved and simple definition of combined transport operation and a new definition of combined transport operator that would support effective digitalised enforcement (eFTI) and reduce the administrative burden.
- Harmonised framework rules that place D2DCT on an equal competitive footing with cross-border trucking through a maintained equivalence clause (contained in Article 4 of the current CTD), as well as introduces an intermodal waybill and homogenised information provision obligations, while addressing some technical details to daily operations, like codification.
- A study-based industrial policy requirement to base promotional and compensatory measures for D2DCT on sound policy-objectives within each Member State, while ensuring discrimination-free access to every qualifying actor.
- A toolbox of acceptable policy-measures of both in-kind and financial nature to eliminate unnecessary bureaucratic authorisation procedures, while delivering a robust, reliable and effective impact on D2DCT.
The UIRR Combined Transport Community calls on
- The European Parliament and every political group led by Rapporteur Flavio Tosi to declare their intention to provide the European Combined Transport Community with a modern harmonised European regulatory framework in the form of an updated and improved Combined Transport Directive;
- The Council of the European Union, consisting of the Member State governments, currently led by the Cyprus Presidency, to express their strong desire to agree on a set of up-to-date European framework rules on D2DCT as a crucial facilitator for the European Single Market in the form of an improved Combined Transport Directive; and
- The European Commission, whose 2026 Work Programme indicated the intention to withdraw the CTD amendment proposal of 2023, to listen to the Combined Transport Community calling for an updated and improved regulatory framework, as well as the EU co-legislators who wish to provide a better legislation and refrain from executing the withdrawal of its proposed revision.
The first European framework legislation for Combined Transport dates back to 1975, when the Directive 75/130/EEC was adopted to enable the emergence of D2DCT, this vital alternative to unimodal road haulage on the continent. The European Commission’s current proposal to amend the Combined Transport Directive (CTD) was published on 7 November 2023. This revision would be the second to the original Combined Transport Directive 75/130/EEC after the one in 1992 (92/106/EEC). Two further attempts failed in 1998 and 2017.
The annex of this paper has been drawn up with a view on the exchanges of Member State representatives in the Council Land Transport Working Party throughout 2024 – under the Belgian and Hungarian Presidencies – as well as on the discussions with members of the European Parliament Transport Committee, including with the rapporteur and shadow rapporteurs. It also reflects on the two papers issued by UIRR0F[1] upon the adoption of the Commission’s revision proposal in 2023 and the recently published EP study on Combined Transport.
[1] https://www.uirr.com/press-releases-position-papers/position-paper-ct-directive-necessary-modernisation-preconditions and https://www.uirr.com/press-releases-position-papers/position-paper-definition-combined-transport-operation