The Commission has presented a legislative proposal on Combined Transport, which aims to make European freight transport more sustainable. In simple terms, Combined Transport refers to the transport of goods in a lorry or in loading units (e.g. containers), which is carried out by rail, inland waterway or sea vessel for the majority of the entire journey and by motor vehicle for the other, shortest possible part. This proposal updates the existing Directive and supplements the Greening Freight Package from July 2023.

Mix of measures to reduce the costs of Combined Transport by 10 %
The aim of the amendment to the Directive is to promote the modal shift from road transport to Combined Transport. The starting point for the funding should be the external costs caused by freight transport. External costs include all consequential costs that were previously borne by the general public, but not by the polluter. These include, for example, greenhouse gas emissions released by transport. To be eligible for funding, Combined Transport should generate 40 per cent lower external costs than pure freight transport by road. In addition, electronic transport information platforms (eFTI) must be used. In return, the new proposal removes the requirement to travel to the nearest transhipment terminal. Overall, these measures should reduce the costs of Combined Transport by 10 per cent in seven years.

Concerns about the proposed method for calculating external costs
The intention to make freight transport more environmentally friendly on the basis of external costs is to be welcomed in principle. However, the problem with the proposal is that this tool for calculating external costs such as noise pollution, air pollution and accident-related costs has yet to be created. In addition, greenhouse gas emissions are to be calculated using the method defined in another Commission proposal on "CountEmissionEU". However, this method does not take into account the entire carbon footprint of freight transport and therefore underestimates the actual external costs.

The use of electronic transport information platforms is a further development of Combined Transport that is to become mandatory according to the proposal. However, from AK’s point of view, funding conditions can only be based on this once all stakeholders, including the authorities, have access to a practical digital platform. Furthermore, the promotion of Combined Transport must not serve as a means of promoting the digitalisation of freight transport.

Exemption from weekend driving ban for lorries viewed critically
The proposal also provides for a general exemption of Combined Transport from truck driving bans such as weekend, night and public holiday driving bans. AK takes a critical view of this. For example, a lorry journey through the entire Tyrolean corridor can be exempted from the driving ban if the journey begins outside Austria and the rail part of Combined Transport also takes place outside the country's borders. Therefore, either mountain areas must be excluded from this provision or a restriction to a maximum of one border crossing per lorry section must be prescribed.

The Commission proposal provides for the Member States to submit binding action plans to promote Combined Transport. The AK welcomes this in principle. However, it must also be ensured that the targeted cost reduction of 10 per cent is not achieved at the expense of employees. Wages and working conditions in freight transport urgently need to be improved. In addition, the shift of freight transport to rail should not only be promoted by means of price incentives, but rail-friendly bulk goods should also be shifted to rail on a mandatory basis.

Drive forward the decarbonisation of freight transport more effectively
In order to drive forward the decarbonisation of freight transport more effectively, AK believes that further legislative initiatives must follow. So far, for example, there are no legal requirements for the rail compatibility of road vehicles. The currently discussed introduction of Gigaliners, on the other hand, is not compatible with the climate targets and should be urgently withdrawn. Last but not least, there is a need for action with regard to road controls. The inspection standards and equipment of the officers must be improved and the inspection density increased.

Further Information:
AK EUROPA Position Paper: Common rules for certain types of Combined Transport of goods between Member States
EU Commission: Commission adopts new proposal on combining transport modes for more sustainable freight
EU Commission: The Green Deal – Greening freight for more economic gain with less environmental impact
EU Commission: Count your transport emissions – “CountEmissionEU”
EU Commission: Accounting of greenhouse gas emissions of transport services