IRU speaks up in support of the CTD

The Combined Transport Directive of the EU need to be adapted to eFTI

EU regulations on electronic exchange of information in transport were adopted in January 2025. Their goal is to replace paper transport documents with unified data exchange systems based on certified and standardized platforms. One of the benefits of the new system is expected to be more accurate monitoring of cargo flows and the external costs of transport, including its carbon footprint.

The new system is currently being implemented. The eFTI digital data exchange tools are expected to be certified by the end of 2026. The full implementation of the eFTI systems is scheduled for July 9th of next year, when the use of these digital data exchange tools will become mandatory for transport and logistics companies and public administration bodies.

The intermodal transport system may face unexpected difficulties related to the introduction of electronic data interchange (EDI), resulting from the incompatibility of current regulations governing the industry, particularly the Combined Transport Directive, with the eFTI Regulation. This will happen if the European Commission, announced last year, implements the option to withdraw the amendment to the Intermodal Directive, which aligns industry regulations with the eFTI system. Industry organizations and experts in rail and intermodal transport protested against the withdrawal of the amendment from the agenda of the European Parliament and the Council of the EU.

Unclear regulations

Why does the Intermodal Directive require amendments in the context of the entry into force of the eFTI Regulation? The International Union for Combined Road-Rail Carriage points to ambiguities regarding how the eFTI provisions should be interpreted in the intermodal transport system. One problem is the concept of "railway or port authority" in the current Intermodal Directive, which was created before the rail transport industry was liberalized and entities such as infrastructure managers and freight terminal operators emerged.

Another challenge is determining which participant in the intermodal supply chain should serve as the "contact point" for information to other parties involved in the transport network. Combined transport operators are tasked with collecting operational information on those portions of the transport that involve modes of transport other than road—primarily rail and inland waterway transport. It is intermodal operators who possess information demonstrating the benefits of reducing external transport costs. The problem is that these companies do not always have complete information about the entire supply chain, particularly who delivers first and last miles and how. This can hinder the transfer of necessary data to the eFTI platform.

UIRR experts point out that the party best placed to handle this obligation is the freight forwarder, who has a complete picture of how the transport service is being performed. However, delegating eFTI reporting responsibilities to freight forwarders may involve additional costs and requires mutual trust. 

Nearest terminal

Another problem is the definition of "closest suitable terminal." Current regulations do not specify how the terminal at which transhipments are to be performed should be selected for the service to be classified as combined transport. The amendment to the Intermodal Directive aims to address this issue.

Another unclear issue is the definition of the "railway authority" responsible for generating and transmitting digital messages. Under current regulations, it is unclear whether this authority should be the terminal manager responsible for transshipment, the infrastructure manager, or the rail carrier, which, through its inspectors, verifies safe loading and compliance with regulations before departure.

One of the users of eFTI will be authorities monitoring truck compliance with regulations such as the Weights and Dimensions Directive and the Combined Transport Directive. Currently, road waybills do not provide proof that a truck is headed to an intermodal terminal, and rail waybills are issued only after transshipment onto a train. This creates an administrative gap in the first and last mile, which the amendment to the Intermodal Directive aims to address. One proposed solution to this problem is to use terminal slots as proof that a road vehicle is participating in combined transport. 

What next with the amendment?

On January 27th, the European Parliament's Transport Committee met, during which MEPs rejected the European Commission's proposal to withdraw the amendment to the Intermodal Directive from the legislative agenda. The Commission's position emphasized that adapting EU regulations to new regulations such as the eFTI is crucial for seaports and terminal operators.

The International Road Transport Union, which represents road hauliers providing first- and last-mile deliveries, also called for continued work on the new directive. The IRU's position paper calls for simplification of the regulations, including a shift from a definition of combined transport based on external costs to a simpler, distance-based calculation.

"We cannot afford to consider forced modal shift. Rather, we must increase capacity and improve existing capacity, encouraging road freight operators and freight forwarders to use intermodal and combined transport to a much greater extent than they do today. This can only be achieved through better, simpler, and more transparent regulations that provide greater legal certainty," urged IRU representative Raluca Marian.