Despite hopes to the contrary, the European Commission’s long-overdue legislative proposal to amend the Combined Transport Directive could harm efficient intermodal cooperation, instead of boosting it, due to the ambiguous incentive framework for combined and intermodal freight.
The European Commission has proposed a fundamental overhaul of the current legal framework for combined transport. This would set incentives for combined and intermodal transport on an operation’s ability to reduce its external costs by 40% compared to a pure road goods transport operation.
The Commission did not provide any clarity on what will be considered an external cost and how these will be calculated. Member States will also have to develop policy plans that make combined and multimodal transport more efficient and reduce costs by at least 10% within seven years.
IRU Director EU Advocacy Raluca Marian said, “We appreciate the Commission’s efforts to finally address the combined transport rules. But we see the proposal as a missed opportunity to set a simple and transparent incentive framework for combined and intermodal freight transport users.”
“IRU is not convinced that linking combined transport incentives to the external cost performance of road freight operations is the right approach. It could slow down the reduction of road freight transport’s air quality and carbon dioxide footprint,” she added.
The proposal leaves the determination of a framework for the external cost calculations to an implementing act. The proposal only includes a vague reference to the Commission’s External Cost Handbook. The Count Emissions EU initiative is not considered at all.
The mandatory use of the Electronic Freight Transport Information (eFTI) framework is another condition to benefit from the incentives. It should be noted that the actual implementation of eFTI has only started at the EU level. Without any further delays, complete application is only foreseen for mid-2026. The mandatory use of eFTI should not become a barrier to accessing combined transport incentives.
“Additional complexity and legal uncertainty may not convince road hauliers to use more combined and intermodal transport and therefore the proposal could miss its objective of decarbonising freight transport and logistics,” she added.
“In real life, it’s about efficient transport, cooperation and complementarity between modes. This is what legislators should keep in mind when setting rules, instead of pinning different modes against each other and setting artificial hierarchies disconnected from the day-to-day reality. Better cooperation between the different modes is required and we need a modern legal framework at the EU level to enable this,” concluded Raluca Marian.
