Combined transport: support framework for intermodal transport of goods; calculation of external costs savings and generation of aggregated data

You will find CNR's contribution in the document attached (in English) CNR, concessionary of the Rhône river and producer of only renewable electricity (water, wind & sun) supports the development of the territories in line with the Green Deal. We have in our historical missions the development of river transport on the Rhône river.

ERFA, as the voice of private and independent rail freight operators in the EU, welcomes the opportunity to react to the publication of the proposal amending the Combined Transport Directive. This revision process is a welcome move to update a 31-year-old text and a crucial opportunity to strengthen the support for rail-road combined transport, a key element in the decarbonisation of freight transport as to be able…

The Swedish Transport Industry Association welcomes proposals for a revised directive on combined transport. We are generally involved in multi-modal transport, as part of a more efficient and greener transport Europe, and we welcome support that is socio-economic and effective in this direction.

Filed in Swedish · English published by the European Commission

The Spanish Government has set up an initiative to boost sustainable rail transport, the Secure, Sustainable and Connected Mobility Strategy 2030, whose three pillars are safety, sustainability and connectivity. This is why the Goods 30 initiative, which is part of axis six of this proposal, called Intermodal and Smart Logistics Chains, is launched.

Filed in Spanish · English published by the European Commission

The impact of much EU regulation on our Island Members has got little consideration thus far. The return of the vehicle in the mobility package being a prime example. The revision of the Combined Transport Directive is an opportunity for Island Nations to get onto the level playing field the EU so proudly presents as its Modus Operandi.

Condition for the application of the combined transport rules: It appears that, instead of applying the current requirements (minimum length/closest to suitable railway terminal), a reduction of 40 % compared to external costs must be met in the future. This requirement may seem difficult for both the transport undertaking and the purchaser of transport.

Filed in Danish · English published by the European Commission

Alis Association for Sustainable Intermodality welcomes the proposed revision of the Combinated Transport Directive, considering it a significant step towards achieving the European objectives of the European Green Deal and sustainable mobility. The proposal aims to enhance the competitiveness of intermodal transport compared to road transport alone.

Filed in Italian · English published by the European Commission

DHL Group welcomes the opportunity from the European Commission to provide feedback on the proposed revision of Directive 92/106/EEC on the support framework for intermodal transport of goods and Regulation (EU) 2020/1056 on the calculation of external costs savings and generation of aggregated data - The so-called Combined Transport Directive (CTD).

Positive aspects The updating of the Intermodal Transport Support Framework is crucial. The Combined Transport Directive creates a support framework to increase the competitiveness of intermodal and combined transport. Intermodal operations fall within the scope of the planned aid to achieve a higher proportion of intermodal transport. The door is open to State aid.

Filed in Spanish · English published by the European Commission

EIM, the association of European Rail Infrastructure Managers, welcomes the publication of the Commission's proposal to revise the Combined Transport Directive. The proposal aims at cutting negative externalities and energy consumption levels in transport by encouraging, most notably, an increase in the share of rail freight as well as other freight transport modes (e.g short-sea shipping and inland waterways).

Central positions of the BGL: Application of the CT Directive only to cross-border transport operations within the EU and only for EU companies No exemption from the EU licensing obligation for lorry road shares in combined transport and intermodal transport for non-residents as regards the calculation of external costs, the administrative burden cannot currently be estimated.

Filed in German · English published by the European Commission

The DSLV Bundesverband Spedition und Logistik e.V. welcomes the European Commission’s proposal to revise the Combined Transport Directive 92/106/EEC. The proposal contains many positive approaches, but raises fundamental questions on practical applicability on some aspects. An initial assessment of the proposal can be found in the attached DSLV Position Paper.

Filed in German · English published by the European Commission

Combined transport has played a pivotal role in the development of rail freight volumes over the past 30 years. However, the untapped potential for Combined Transport remains massive. If done properly, updating the CT Directive can definitely help unleash this potential, thereby achieving modal shift.

Located on the Atlantic Corridor connecting the Iberian Peninsula to the north of the EU, New Aquitaine (NA) is a major transit route, implying that environmental and other transport related problems are particularly acute.

Filed in French · English published by the European Commission

HAROPA PORT – the Major river-sea Port of the Seine axis, safeguarding the three ports of Le Havre, Rouen and Paris – appreciates the opportunity to submit its comments on the revision of the Combined Transport (CT) Directive. (A) We generally welcome the initiative of reviewing the existing Directive. An update of the (currently obsolete) legal framework is strongly needed.

Filed in French · English published by the European Commission

The opinion of the UECC The current proposal for a Directive addresses important aspects which can make the combined transport system more competitive and efficient over medium distances than road-only transport. The UECC supports: — Reductions in costs for the combined transport system, e.g.

Filed in German · English published by the European Commission

UNIFE, the association representing the European rail supply industry, would like to welcome the update of the Combined Transport Directive included in the Greening Freight package. The amendment of Directive 92/106/EEC is a step towards reaching the goals of the Sustainable and Smart Mobility Strategy and the European Green Deal objectives with regards to rail freight transport, set by the European Commission.

Combined transport (KV) is of great interest to the German economy. The aim of the revision of the 1992 Directive is to strengthen the importance of the combined transport system and to contribute to greater sustainability in the transport sector. This fundamental objective is shared by the majority of companies.

Filed in German · English published by the European Commission

In principle, we welcome this new EU directive on combined transport and intermodal transport, but we see an urgent need for improvement on several points. The central issue here is the new definition of combined transport (KV), which is not yet operational in the proposed form: As long as the eFTI database and the calculation of external costs for transport chains based on the data entered in the eFTI database are…

Filed in German · English published by the European Commission

With the proposal of 7 November 2023, the European Commission presented a recast of Directive 92/106/EEC on common rules for combined transport of goods. The railway and transport union EVG is Germany’s largest trade union for railway workers and represents more than 187.000 members. Please find below our comments on the proposal for a directive.

Filed in German · English published by the European Commission

Updating the intermodal transport support framework is essential. The proposal aims to provide a coherent intermodal transport support framework as, so far and according to the REFIT evaluation, this framework has had an insufficient impact. The proposal includes three provisions to promote intermodal transport in general: All intermodal transport is exempt from authorisations and quotas.

Filed in Spanish · English published by the European Commission

The Baden-Württemberg Ministry of Transport considers it questionable whether the objective of strengthening the competitiveness of intermodal transport can be achieved by means of the proposed amending Directive.

Filed in German · English published by the European Commission

The Alliance for International Transport and Logistics (TALA) attaches its position on the revision of the Combined Transport Directive proposed by the European Commission. The TTLA’s main suggestions are as follows: support the definition of combined transport proposed by the European Commission; support the European Commission’s proposal to extend the scope of combined transport to intermodal transport operations…

Filed in Lithuanian · English published by the European Commission

Transport operators welcome proposals for a revised directive on combined transport. We are generally involved in multi-modal transport, as part of a more efficient and greener transport Europe. However, the proposal is too vague and non-concrete and the Transport Companies wonder whether it is in a position to have a substantial impact on the ground and to justify the increased administrative burden involved in the…

Filed in Swedish · English published by the European Commission

ACEA welcomes the Commissions proposal to increase the choice and level of support measures for combined transport organizers, but challenges the statements on modal shift, raises concerns on how the Commission will ensure sufficiently precise comparison of operations overtime and how the Commission intends to ensure consistency and complementarity of the common harmonised calculation methodology for externalities…

Danish Shipping expresses gratitude to DG MOVE and the European Commission for the opportunity to provide comments on the revision of sustainable transport - revision of Combined Transport Directive. Overall, Danish Shipping urges the EU to continue to be ambitious in ensuring better coordination between modes of transport and an increased use of combined transport solutions.

thank you for the opportunity to comment on the proposal. The amendment of the Combined Transport Directive was our long-standing wish to ensure that combined transport and transport operators and customers can use it efficiently. Unfortunately, in our view, the Commission’s proposal does not reflect the realities of the world and the market at all.

Filed in Czech · English published by the European Commission

As a cyclist organisation, we salute the purpose of this Directive. In order to reduce externalities caused in urban environments caused by last mile delivery, in a context of growing online commerce, we believe the scope of the Combined Transport Directive should explicitly include the "last mile" infrastructure required to shift modal share from vans and trucks to lighter vehicles (cycles such as cargo bikes…

(A) Reference to the proposal section (4): There are two different ways for freight to travel over water - by accompanied ferry traffic (tractor + trailer + goods + driver, also known as "RoRo" roll-on-roll-off) or unaccompanied ferry traffic (only trailer + goods). The latter has a much lower ghg emission footprint and is used for combined traffic. Road transport mostly uses accompanied traffic.

Since the entry into force of the 92 Directive, several initiatives have been introduced by the EC in the transport sector, with the aim of encouraging the modal shift of goods from road to alternative modes of nuisance. With the regulatory measures put in place to reduce carbon emissions, shippers and logisticians subject to them, like carriers, meet the obligation to report emissions caused by their activities.

Filed in French · English published by the European Commission

The Danish Chamber of Commerce supports the vision of the European Green deal and the Sustainable and Smart Mobility Strategy. Climate and environmental challenges are a major challenge for this generation, and clear pan-European solutions, instruments and regulation are needed if the EU is to achieve targets of at least 55 % greenhouse gas emission reductions by 2030 and climate neutrality by 2050.

Filed in Danish · English published by the European Commission

Enagás welcomes the revision of the Combined Transport Directive; combined freighting offers a unique opportunity to cut down emissions through the reduction of duplicated and scattered means of transport that cannot easily scale. At the same time, this effort can drive down transport costs per ton substantially.

Voies navigables de France (VNF) operates inland waterways (IWW) in France. It welcomes the Commission’s inception impact assessment on the revision of the Combined Transport Directive, which is critical to accelerating a significant modal shift from the road to the river. - VNF strongly supports Scenario 4 put forward by the Commission in its Inception Impact Assessment.

From UOTC (Union of Coodal Transport Operators), the intermodal, combined or co-modal transport section of ASTIC, we provide the following contributions, in relation to the requested ideas, problems and key issues that guide the Commission’s future tasks. 1.-Cost reduction in rail transport, i.e. longer trains with higher axle weight, higher total weight per train and much cheaper for freight.

Filed in Spanish · English published by the European Commission

CLECAT, the European association representing the interest of freight forwarders and logistics service providers, welcomes the possibility to provide feedback on the European Commission’s Roadmap for the review of Directive 92/106/EEC on the establishment of common rules for certain types of combined transport of goods between Member States (CT Directive).

The underlying principle in combining two or more modes of transport is efficiency. To stay competitive with respect to costs, all modes have to improve their efficiency. The achievement of a true internal market for rail, short sea and inland waterways transport services and the improvement of their full potential in terms of productivity is essential for a true intermodal or multimodal transport based on…

The Studiengesellschaft für den Combined Transport e.V. (SGKV) expressly welcomes the efforts made at European level and by the Member States to revise Directive 92/106/EEC in a practical way. The aim of these efforts must be to facilitate and promote a shift from transport to the environmentally friendly rail and inland waterway transport modes.

Filed in German · English published by the European Commission

The underlying principle in combining two or more modes of transport is efficiency. To stay competitive with respect to costs, all modes have to improve their efficiency. The achievement of a true internal market for rail, short sea and inland waterways transport services and the improvement of their full potential in terms of productivity is essential for a true intermodal or multimodal transport based on…

Kombiverkehr Deutsche Gesellschaft für kombinierten Güterverkehr mbH & Co. KG is a logistics service provider that develops, organises and markets a Europe-wide network for rail-road combined transport. As the leading operator for combined transport in the EU Kombiverkehr welcomes the launch of the revision of the Combined Transport Directive.

The Bundesverband Spedition und Logistik (DSLV) is in principle in favour of a revision of Directive 92/106/EEC on the establishment of common rules for certain types of combined transport of goods between Member States. The performance of combined modes of transport is important for the economic efficiency of freight transport as well as for the overall environmental efficiency of logistics.

Filed in German · English published by the European Commission

SNCF welcomes the publication of the inception impact assessment regarding the revision of the Combined Transport directive. Combined transport is one of the main drivers for achieving the ambitious growth targets for rail freight. In the context of the forthcoming revision of the Combined Transport Directive, the potential of intermodal solutions must be exploited.

All in all, the revision of the present directive is welcomed by the ÖBB including the extension of the scope of the CT Directive. ÖBB very much welcomes the goal to shift transport to more sustainable means of transportation such as rail and to provide incentives to support this modal shift.

The Verband deutscher Verkehrsunternehmen e.V. (VDV) welcomes the planned revision of the Combined Transport Directive. Combined transport (CT) is a success model. Its share of the German rail freight market has increased to almost 40 % over the past 30 years.

Filed in German · English published by the European Commission

In the view of the Austrian Ministry of Climate Change (BMK, Federal Ministry of Climate Protection, Environment, Energy, Mobility, Innovation and Technology), the revision of the existing Directive 92/106/EEC on combined transport, in particular in the light of the European Green Deal, the Sustainable and Smart Mobility Strategy and the Austrian objective of a climate-neutral transport system in 2040, is to be…

Filed in German · English published by the European Commission

Confartigianato Imprese is the largest association representing micro, small and craft enterprises in Italy (around 700.000 micro and SMEs). Confartigianato Imprese represents, through the national trade association for road haulage and logistics, ‘Confartigianato Trasporti’, around 20.000 undertakings operating in road transport.

Filed in Italian · English published by the European Commission

NLA agrees that a multimodal approach is important in the transition towards greener mobility and eventually zero-emission mobility. However, we strongly contest that this transition can only happen by shifting goods from road to rail and inland waterways. It is too simplistic to assume that shifting goods from road to rail and inland waterways will automatically result in an immediate lowering of CO2 emissions.

Key messages SMEunited supports a shift to rail (or other means of transport) but a call for a massive shift to rail is a noble but unattainable goal as the rail network in rural areas is not well developed. A shift to rail can only take place if there is sufficient rail capacity. If combined transport is to be promoted from public funds, this must not be done to the detriment of SMEs.

ERFA, as the voice of private and independent rail freight companies, welcomes the launch of the revision of the Combined Transport Directive. The Combined Transport Directive has always been an essential enabler for combined transport (CT) operators across Europe.

Dear Sirs, on behalf of Terminal Service Austria, we think Option 4 grants the most potential and benefits to everyone involved in the supply chain. It sets the right incentieves to switch to intermodal transport units and decreases the cost benefits of geniuine road transport.

FEPORT, the European organization representing private port companies and terminals who perform operations in European seaports, welcomes the possibility to provide feedback on the upcoming revision of the Combined Transport Directive.

The Platform for Electromobility welcomes the opportunity to give its feedback on the Inception Impact Assessment for the revision of the ‘’Combined Transport Directive’’. Directive 92/106/EEC is the only EU legal instrument directly targeting combined transport (CT), incentivising a more sustainable operational model for freight transport.

ALIS considers that an amendment to Directive 92/106/EEC is a concrete and present need precisely because of the reasons expressed by the Commission itself when withdrawing the previous proposal, namely ‘the need to increase the share of sustainable transport modes in the European Green Deal [and the fact that increasing the share] requires more support for multimodal solutions’.

Filed in Italian · English published by the European Commission

1. All amendments to Directive 92/106/EEC, as well as any extension of the scope of this Directive to intermodal/multimodal transport, must be considered in the light of the persistent wage and social cost gap within the EU. Social and environmental concerns must not be balanced against each other.

Filed in German · English published by the European Commission

New Aquitaine is a transit region, where 39 % of greenhouse gas (GHG) emissions come from transport, compared to a quarter in the EU. This is due to the fact that 97 % of freight transport is carried by road and the situation of a mandatory crossing point for New Aquitaine between the Iberian Peninsula and the rest of Europe along the Atlantic Corridor.

Filed in French · English published by the European Commission

SPC Spain welcomes the revision of the Combined Transport Directive under the European Green Deal as a way to favour an efficient and sustainable freight transport system, ensure a level playing field for all transport modes and promote more transport alternatives to suppliers, users and customers.

Filed in Spanish · English published by the European Commission

ANAVE welcomes the revision of the Combined Transport Directive under the European Green Deal as a way to favour efficient intermodal freight transport services, providing a level playing field for all modes of transport and better promoting modal alternatives to suppliers, users and customers.

Filed in Spanish · English published by the European Commission

JOINT INTERPORT UNION — U.I.R. The revision process of Directive 92/106/EEC aims to increase the competitiveness of combined transport, which cannot be without prejudice to the implementation of long-term targeted policies to overcome existing regulatory barriers at national level and to create a single European rail market.

Filed in Italian · English published by the European Commission

The European Express Association (EEA) - which represents express delivery companies and national express associations across the EU – welcomes the opportunity to provide feedback on the Commission roadmap about the Combined Transport Directive (CT Directive), as follows: Need more support for intermodal transport The EEA would welcome more support for intermodal transport operations but not in terms of forced modal…

The State Ministry of Housing, Construction and Transport of the Free State of Bavaria welcomes the revision of the Combined Transport Directive with the aim of increasing the modal shift from freight to rail and shipping.

Filed in German · English published by the European Commission

Option 2 seems to us to be the best option. Subsidies should also remain possible for the road operator who chooses to switch (part of) its trades to other modes. It is not intended that this financial support would go only to the shipper or to the chosen mode. Multimodal transport at shorter distances (also within one Member State) should also be encouraged.

Filed in Dutch · English published by the European Commission

POSITION OF THE INLAND WATERWAY TRANSPORT (IWT) SECTOR ON THE ROADMAP TO REVISE THE COMBINED TRANSPORT DIRECTIVE CTD Aim to boost Inland Waterway Transport through intermodal transport Intermodal transport under the current Directive 92/106/EEC is mainly perceived as a combination of road/rail.

CER SUPPORTS the Commission’s objective and approach... CER welcomes the launch of the work on the revision of the Combined Transport Directive and the draft roadmap which the Commission published on 19 August 2021 outlining its intended actions until a legislative proposal comes out in Q4 2022.

Road transport within land transport occupies an excessive and predominant place in Europe and in some cases such as Spain accounts for 98.3 % of the total tonnes transported. This unprecedented fact in the EU is due to the lack of political will of our administration so far.

Filed in Spanish · English published by the European Commission

There is no doubt about the environmental advantage of combined transport over “any road”. This is sufficiently demonstrated by various studies. However, when talking about the environment, different aspects need to be taken into account, not only CO2 emissions. The environmental aspect also covers energy supply, type of energy, external environmental costs, etc.

Filed in French · English published by the European Commission

Combined transport (KV) is the rail segment with the highest growth potential. Therefore, CT has an important role to play in strengthening intermodality in Europe and in catching up rail. The privileges existing or possible for transport today are crucial and fundamental incentives for the choice of transport modes and should therefore be maintained and expanded.

Filed in German · English published by the European Commission

Insbesondere die 44 to Regelung ist ein großer Vorteil des kombinierten Verkehrs. Aber dauerhaft mehr Verkehr auf die Schiene zu bringen, benötigt es neben dem Ausbau der Terminalinfrastrukturen auch dringend mehr attraktive Trassen für die Güterzüge. Insbesondere auch der Verkehr not und durch Frankreich könnte wesentlich ausgedehnt werden.

Filed in Irish · English published by the European Commission

Article 1 of Directive 92/106/EE ‘on the establishment of common rules for certain types of combined transport of goods between Member States’ established constraints on the initial or final road leg combined transport operations.

UIRR as the industry association of European Combined Transport welcomes the launch of the revision of the Combined Transport Directive. The extension of scope concerning the benefits granted in the Directive to any intermodal or multimodal transport operation that delivers a meaningful contribution in savings of harmful externalities of road-only transport is to be greeted.

The proposed revision of the Combined Transport Directive is in line with the measures advocated and supported by the Commissioner of the Spanish Government for the Mediterranean Corridor: (1) Economic and regulatory support for multimodal transport operations that save negative road externalities. 2) Eco-incentives and support policies for rail transport are among the lines of action we most strongly advocate.

Filed in Spanish · English published by the European Commission

The development and improvement of rail and waterborne freight transport is undoubtedly an essential element in making transport more sustainable in the EU, improvement must take place in three areas: 1.- Improvement of times and journeys. 2.- Improvement of the nodes with road 3.- improvement of costs. 4.- Increasing sustainability and efficiency.

Filed in Spanish · English published by the European Commission

Transportföretagen shares the view of the European Economic and Social Committee in its opinion on Intermodal transport and multimodal logistics – making modes complementary in greening transport, adopted with broad support on 25 March 2021 (TEN/747) that a long term viable solution to developing efficient and sustainable multimodal transport and logistics can only be achieved by dealing with the problems that make…

In order to achieve more modal shift to the waterways ( inland and shortsea) there is a need to radically renew the fleet of the vessels to operate with zero emission propulsion as demanded by the shippers and to bring the operation of the vessels in line with the performant planning needs of the shippers. These new vessels will have new propulsion systems.

Finally, by promoting the use of combined transport, we will build a new, more virtuous transport system in the sense that we will use a multi-criteria analysis based on environmental impact and not just cost. When purchasing the goods, the consumer, whether a private individual or business, will have to be aware of the impacts and choose a mode of transport.

Filed in French · English published by the European Commission