5 February 2024


On the 7th of November 2023, the European Commission has presented a new revision to the Combined Transport Directive with a stronger emphasis on reaching a more sustainable transport methods and on increasing the competitiveness of intermodal transport compared to road transport.

The proposed revision is an important step to ensure the achievement of the European Union’s ambitious climate targets for 2030 and 2050. Combined transport can play an essential role in terms of reduction of emissions and road congestion.

On the 5th of February 2024, FEPORT submitted its reply to the call for feedback and underlined the following:

External costs savings:

The CTD revision put a focus on operations that reduce at least 40% of negative externalities compared to road-only operations with the same starting and end point.

The aim is to improve the use of terminal and other infrastructure capacity by allowing trucks carrying out the short feeder legs to reach terminals when they need to take the next mode of transport (train, barge, ship).

FEPORT supports the revision proposal on this point, as it advocates the approach based on the external cost savings rather than on the length of road and non-road transport operations and the distance to the most convenient terminal.

Before, support depended on the length of the (non)-road legs and proximity of nearest terminal.

Transparency requirements

FEPORT members will be impacted by art. 9b as this article mandates operators of intermodal transshipment terminals (including terminals in seaports) to make available on their website information about their services and facilities.

FEPORT recommends that information is required only if operators of CT are not able to properly evaluate the selection of terminals without them.

FEPORT advocates the exclusion of information about costs, as the information is commercially sensitive and is part of the contractual relationship between terminal operators and transport operators.

Clear and unified approach at European level

From FEPORT’s point of view, EU ports need a clear and unified approach at EU level. FEPORT calls for avoiding that divergences in national policy frameworks bring distortion in the level playing field.

FEPORT welcomes art.3a of the revision as it requires Member States to adopt a national policy framework aimed at achieving a cost reduction of 10% for combined transport operations. However, it should be clearly clarified that direct support should exclude distortions of the level playing field.

It is a positive signal that Member States are allowed to adapt planning and rental conditions for the land dedicated to intermodal transhipment terminal development. But support should be granted only if there is market demand for a new terminal.