Position paper – Revision of the Combined Transport Directive

Position paper – Revision of the Combined Transport Directive

ACEA — 2024-03-15

News from Brussels

ACEA commends efforts to enhance support measures for combined transport organisers and extend the Directive’s scope to all intra-EU intermodal transport. However, the Commission must ensure a level playing field between transport modes.

The revision of the Combined Transport Directive is a significant step forward to achieving the European Green Deal. Intermodal freight transport is important for reducing carbon emissions and other negative externalities from all transport modes. While the Directive’s revision is merited, we make recommendations for improvements in this position paper.  

1. Modal shift: ensuring a level playing field 

Modal shift policies often assume certain transport modes are more environmentally beneficial than others. Environmental performance cannot be generalised across modes, and external costs are not always lower for waterborne or rail transport.  

2. Externalities: consistency and complementarity of the future harmonised calculation methodology 

Policy makers should ensure a comprehensive methodology for calculating external costs, accounting for environmental, social, and economic factors across transport modes equally. The Commission should ensure accurate comparisons over time and consistency with related legislative initiatives. 

3. The 2019 edition of the Handbook on the external costs of transport: revise completely in line with the latest evidence  

The Handbook underestimates the external cost of non-road modes such as rail. We call for the Handbook to be urgently revised as it is not a reliable basis for policymaking as it is not consistent with the latest scientific evidence.  

4. Comparing the efficiency of transport modes: getting the data right  

Modal shift may be desirable in certain cases, but modal shift policies should first be extensively evaluated. We draw attention to the inconsistencies in how transport data is compiled, including differences in the definition of load across various transport modes.