Brussels, 11.02.2026
eFTI Regulation: intermodal business use cases to be defined
UIRR welcomes the opportunity offered by the eFTI Regulation to accelerate the digitalisation of business-to-authority information exchange. By digitising this type of communication, the regulation supports the efforts of freight transport operators investing in digital information exchange, allowing end-to-end digital transport document use.
Since the connection to eFTI platforms is not mandatory for economic operators, the regulation must fulfil its promise of “reducing administrative costs and improving enforcement capabilities of competent authorities”0F[1] to convince businesses to become a user. In this spirit, the proper identification of “authorities”, as well as the costs incurred by the implementation must be carefully investigated. Additionally, eFTI should not increase the legal reporting obligations of intermodal transport stakeholders1F[2], and the current B2B digital communication processes must be acknowledged to be harnessed within the framework of eFTI.
The purpose of this position paper is to assist the implementation of the eFTI Regulation for Combined Transport, by discussing the main shortcomings that need to be addressed.
Summary of intermodal needs and considerations
The UIRR Combined Transport Community wishes to bring the following points to the attention of everyone involved in implementing the eFTI Regulation:
The Combined Transport Directive 92/106 (CTD) in its current from is unsuited for the implementation of the eFTI Regulation
a. It is unclear which actor of the combined transport chain should be in charge of providing which component of the eFTI data-record;
b. It is ambiguous which entity should provide the required “stamps” (proof of completion).
c. The eFTI implementation of the current CTD does not address the lack of evidence provided for the destination or origin terminal being the “nearest suitable transhipment facility”.
- For the Commission’s proposed 2023 revision of the CTD, the eFTI implementation should have offered a tool for calculating and simulating the required 40% external cost savings of Combined Transport in comparison to its unimodal road alternative.
- The optional use of eFTI means that thoroughly tested eFTI business use cases must be presented to convince Combined Transport stakeholders to use the new eFTI solution.
Loopholes in the Combined Transport Directive 92/106
The eFTI Regulation specifically covers Article 32F[1] of the Combined Transport Directive 92/106 (CTD), its objective being to define the conditions for an intermodal transport to be recognised as Combined Transport. However, the “digital transformation” of a definition dating from 1992 will come as a challenge as it has become subject to several interpretations:
- The article mentions “rail or port authorities in the railway station or inland waterway ports”, which cannot be clearly identified using current terminology. Ever since the liberalisation of rail freight transport, former monopolies that could have been understood as “rail authorities” may now either be railway undertakings, infrastructure managers, or perhaps even terminal managers.
- As proof of compliance before the operation takes place, the article mentions an undefined “transport document” providing the information laid down in Article 6 of Council Regulation No 11 of 27 June 1960, as well as information on “the loading and unloading of units at non-road mode stations”. Because it was left undefined, the choice of transport documents to be used has been left to the Combined Transport Operator (CTO). However, they must sometimes abide by specific document formats requested by certain Member States, thus creating a disharmonised administrative environment. In addition, the information requested in the article does not effectively prove that a transport operation is eligible under the definition.3F[2]
The legal uncertainty described above has not yet been addressed by the European legislator, meaning that intermodal operators have had to self-check their conditions for proof of eligibility. According to the impact assessment of the CTD amendment proposal of November 2023, this legal uncertainty led many Member States to apply fiscal incentive schemes as laid down in Article 6 of the CTD without notification. This limits the opportunities for Member States to coordinate their efforts for greater impact.