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CLECAT - European association for forwarding, transport, logistic and Customs services

CLECAT

CLECAT represents European freight forwarders, transport operators, logistics providers and customs agents across the supply chain.

Lobbying Activity

Meeting with Maria Luisa Cabral (Director Employment, Social Affairs and Inclusion)

27 Oct 2025 · CLECAT representatives presented their position paper on subcontracting.

CLECAT urges business-friendly rules for EU military mobility

24 Oct 2025
Topic — The EU is establishing a framework to harmonise rules for military mobility movements.
Message — The organization calls for a predictable regulatory framework that simplifies cross-border rules and integrates the private sector into planning. They request legal clarity for crisis situations and harmonised customs procedures to protect the civilian economy.123
Why — These measures would provide logistics firms with financial protection and greater operational flexibility.45
Impact — Civilian sectors may face supply chain disruptions if military transport is poorly coordinated.67
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CLECAT Urges Technology-Neutral CO2 Standards for Vans

10 Oct 2025
Topic — This consultation reviews CO2 emission performance standards for new cars and vans.
Message — CLECAT requests technology-neutral standards and financial incentives to support the freight sector. They also urge the rapid expansion of charging infrastructure for commercial vehicles.123
Why — Logistics firms would benefit from lower compliance costs and greater choice of vehicles.45
Impact — Environmental groups may find that using bridging technologies slows down full electrification.6
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Meeting with Susana Solís Pérez (Member of the European Parliament)

17 Sept 2025 · Count Emissions EU

CLECAT warns against mandatory zero-emission targets for truck fleets

8 Sept 2025
Topic — This consultation addresses setting minimum requirements for zero-emission vehicles in corporate fleets.
Message — CLECAT argues against mandatory zero-emission vehicle targets for corporate truck and van fleets. They propose alternative measures like tax incentives and improved charging infrastructure instead.12
Why — This would prevent market distortions and reduce the administrative burden on transporters.34
Impact — Small transport companies risk being forced out of business by high costs.5
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CLECAT calls for investment to bridge green fuel price gap

4 Sept 2025
Topic — The initiative provides a strategic framework for boosting investments in renewable transport fuels.
Message — CLECAT urges the EU to bridge the cost gap between conventional and renewable fuels. They call for better transparency in tracking fuels and earmarking carbon revenues for transport. The plan should also ensure small businesses and logistics hubs can access green solutions.12
Why — Closing the price gap would protect the competitiveness of freight services against rising costs.3
Impact — Large industry incumbents could lose their dominant market position to smaller competitors.4
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CLECAT Demands Fair Competition and Tax Reform in EU Ports

25 Jul 2025
Topic — The EU Ports Strategy aims to address security, competitiveness, and energy transition challenges.
Message — CLECAT calls for the enforcement of competition rules to ensure independent logistics providers have fair access to terminal services. They request a revision of maritime tax rules to prevent shipping lines from gaining unfair advantages through tonnage tax schemes. Furthermore, they advocate for improved digitalization and infrastructure investment to resolve persistent port congestion.123
Why — Freight forwarders would benefit from improved operational reliability and lower costs through reduced congestion and better transparency.45
Impact — Vertically integrated shipping lines would lose the significant financial advantage of applying maritime tax breaks to terminal services.67
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Meeting with Maroš Šefčovič (Commissioner) and

11 Jul 2025 · Implementation dialogue on customs legislation - Rules of origin

Response to Detailed specifications regarding functional requirements for eFTI platforms

8 Jul 2025

CLECAT's comments can be found in the attached document.
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Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Port Strategy

Meeting with Matthias Petschke (Director Taxation and Customs Union) and

5 Jun 2025 · Exchange of views on possible improvements to the functioning of the Trade Contact Group

Meeting with Hans Stausboll (Acting Director Directorate-General for International Partnerships) and

6 May 2025 · Shaping a new Team Europe approach towards Asia and Sub- Saharan Africa in order to develop rail projects in both regions while ensuring the competitiveness of the EU’s railways industry.

Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

29 Apr 2025 · To discuss several topics important for air cargo operations - the airport fitness check, review of Regulation 1008/2008, Sustainable Aviation Fuel (SAF), noise, sustainability of aviation.

Response to Establishing a list of “neighbouring container transhipment ports” for the FuelEU Maritime Regulation

7 Feb 2025

Please find attached the response from CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, to the call for feedback on the draft list of neighbouring container transhipment ports pursuant to FuelEU Maritime Regulation.
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Meeting with Nikolina Brnjac (Member of the European Parliament)

5 Feb 2025 · CLECAT’s strategic priorities

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur) and International Trademark Association

29 Jan 2025 · Customs Union

Meeting with Norbert Lins (Member of the European Parliament, Rapporteur) and Alstom

14 Jan 2025 · CountEmissions EU

Response to Digital Product Passport (DPP) service providers

9 Dec 2024

CLECAT, the European Association for Forwarding, Transport, Logistics, and Customs Services, welcomes the European Commissions initiative on the Digital Product Passport (DPP). We emphasise the need for ongoing trade involvement to ensure the DPP enhances transparency and sustainability without inadvertently creating non-tariff barriers to legitimate trade. In our attached submission we outline the key reasons why the logistics and customs brokerage sectors represented by CLECAT should be actively involved in shaping the DPP framework.
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Meeting with Dirk Gotink (Member of the European Parliament, Rapporteur)

9 Dec 2024 · EU customs legislation, e-commerce

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2024 · Accounting of greenhouse gas emissions of transport services 2023/0266(COD)

CLECAT urges automatic carbon tax status for trusted traders

27 Nov 2024
Topic — This consultation defines authorization procedures for importers under the EU carbon border tax.
Message — CLECAT recommends shortening application timelines and automatically approving companies with trusted certifications. They also seek exemptions for small-volume importers.123
Why — This would reduce administrative burdens and provide smaller companies with predictable costs.45
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Meeting with Mika Aaltola (Member of the European Parliament) and Nordea Bank Abp

19 Nov 2024 · EU Affairs

Meeting with Rosa Serrano Sierra (Member of the European Parliament) and European Transport Workers' Federation and Community of European Railway and Infrastructure Companies

2 Oct 2024 · Priorities for European Commission 2024-2029

Meeting with Daniel Attard (Member of the European Parliament) and Ryanair Holdings and

24 Sept 2024 · Introductory Meeting

Meeting with Andrea Wechsler (Member of the European Parliament) and BUSINESSEUROPE and

23 Sept 2024 · EU Energy and Industry Policy

CLECAT calls for airport rules prioritizing air cargo needs

6 Jun 2024
Topic — The European Commission is evaluating whether current airport legislation remains fit for purpose.
Message — CLECAT recommends establishing specialized slot allocation mechanisms that reflect the specific needs of air cargo. They advocate for increased competition in groundhandling and the introduction of minimum service quality standards.12
Why — Open markets and better standards would reduce delays and improve service quality for forwarders.3
Impact — Incumbent airlines and current groundhandling monopolies would face more competition for scarce airport resources.45
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Response to Interim Evaluation of the CUSTOMS 2021-2027 programme

13 May 2024

CLECAT, the European Association of Freight Forwarders, Logistics Service Providers, and Customs Agents, welcomes the opportunity to provide feedback on the Customs 2021-2027 Programmes progress. Please find attached our comments for the Interim Evaluation of the CUSTOMS 2021-2027 Programme.
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Meeting with Caroline Nagtegaal (Member of the European Parliament) and International Road Transport Union Permanent Delegation to the EU and

16 Apr 2024 · Biomethane in road transport

Meeting with Jakop G. Dalunde (Member of the European Parliament)

27 Feb 2024 · CountEmissions EU

Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and

7 Nov 2023 · Reform of the Union Customs Code

Response to Evaluation and revision of the Weights and Dimensions Directive

21 Sept 2023

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, welcomes the Commission proposal to revise the Directive 96/53/EC, setting standards for the maximum authorised weights and dimensions of heavy-duty vehicles used in national and international transport. In a context of structural shortage of drivers and the need to decarbonise freight transport, this timely initiative should help maximise the efficiency or road freight transport sector and incentivise the shift to zero-emission vehicles. The freight forwarding sector is committed to ambitious European decarbonisation goals and is willing to actively contribute to the substantial reduction of GHG emissions from its transport and logistics operations. However, the discrepancy between the maximum authorised weights in some Member States territory and maximum authorised weight for cross-border transport hinders the free movement of goods, leading to inefficiencies, higher emissions and legal uncertainty. It is therefore of utmost importance that the revision of the Directive should clarify these rules and open the door for certain the wider use of high-capacity vehicles. While certain provisions of the proposal such as allowing cross-border operations of EMS vehicles are particularly appreciated, CLECAT is concerned that some of the provisions would not permit to maximise the efficiency or road freight transport to its fullest, increasing the number of journeys and GHG emissions. The attached paper provides some suggestions for amendments to the proposal which CLECAT considers crucial to face the current and upcoming challenges of the road transport industry.
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Response to Count your transport emissions: CountEmissions EU

21 Sept 2023

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services welcomes the CountEmissions EU initiative. The freight forwarding sector is of the view that much can be achieved to support the transport and logistics sector to reduce its emissions but only with the correct market-based and supportive instruments. Given that logistics service providers, freight forwarders often have no transport assets of their own, their objective is to pursue an emissions reduction strategy which engages with many different sub-contractors as they are responsible for the large part of direct emissions. This timely Commission initiative would enable transport operators to accurately calculate, monitor and compare their emissions giving transport users an estimate of the carbon footprint for their different transport and delivery options, facilitating behavioural change. The attached paper provides some recommendations and suggestions for amendments to the proposal in order to maximise the potential benefits of a single EU framework for monitoring and reporting GHG emissions data from transport operations.
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CLECAT seeks annual updates to prevent shipping carbon evasion

18 Sept 2023
Topic — Identifying non-EU ports to prevent shipowners from evading carbon emissions costs.
Message — CLECAT calls on the Commission to closely monitor non-EU ports and revise the list annually. They warn more ports will soon meet the criteria for inclusion.12
Why — Frequent updates would help freight forwarders maintain connectivity and avoid operational delays.3
Impact — Mediterranean ports lose business to non-EU rivals that aren't subject to carbon pricing.4
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CLECAT slams unrealistic carbon reporting rules for customs agents

11 Jul 2023
Topic — Rules for reporting carbon emissions during the transition to new border taxes.
Message — CLECAT claims the three-month implementation window is inadequate and creates an enormous burden. They want to avoid being held liable for emission data provided by non-EU importers. They also propose using simplified default values for all goods during the transition.123
Why — This would protect freight forwarders from legal liability for inaccurate emissions data.4
Impact — Environmental monitoring suffers if the EU allows simplified default emission values.5
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CLECAT Urges Harmonized Transport Emission Standards in EU Reporting

7 Jul 2023
Topic — This consultation defines sustainability reporting standards that companies must use for mandatory disclosures.
Message — CLECAT recommends adopting the ISO 14083 standard for calculating transport-related greenhouse gas emissions. They also seek to delay further sector-specific standards and protect sensitive business data.12
Why — Uniform reporting methodologies would provide clarity and simplify carbon footprinting for logistics operators.3
Impact — Competitors could exploit disclosures that reveal sensitive business models or supply chain logistics.4
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Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

29 Nov 2022 · road and rail freight transport

Response to Review of EU rules on the allocation of slots at Union airports

21 Nov 2022

CLECAT, the European association for forwarding, transport, logistics and customs services, is the leading voice on freight forwarding and logistics at the EU level in Brussels. We represent and are supported by 24 member organisations, working to promote a sound approach to transport and logistics across Europe, in support of the competitiveness of our industry. Freight forwarders represent a vital link between exporters/importers of goods and transport operators, such as air carriers. They have a keen interest in a modern, innovative air freight sector which guarantees choice, quality, connectivity, transparency and fair competition. Freight forwarders are reliant on a fair and adequate slot allocation regime for full freighter aircrafts, to ensure its customers, shippers, are being served with timely and good quality service levels, which can be expected from air freight, which represents an economically strategic transportation service for the European economy. Summary: Recognising the importance of an appropriate slot allocation mechanism, as well as the drastic changes brought by the COVID-19 crisis, CLECAT considers Commissions initiative to review the EU Slots Regulation is now timely and urgent, as the current framework for the allocation of slots at EU airports, dating back to 1993, is inadequate to address the continuously increasing congestion at EU Airports and does not effectively address the needs of the air cargo sector. The EU Slot Regulation does not provide the much-needed flexibility to air freight. The reason for this is that the 80/20 use it or lose it rule is difficult to achieve for full freighters since passenger and cargo operate in a very different way. The European society cannot rely on the limited freight capacity in the belly of passenger aircraft only. CLECAT calls on the Commission to recognise the different needs of air freight by leaving a certain flexibility to Member States to legitimately and proportionately prioritise certain traffic segments in the determination and allocation of capacity on an objective, unambiguous and transparent manner. Air cargo is much more demand-driven than the supplier-driven passenger markets, it is imperative that air cargo needs a separate part of the capacity in order to be able to effectively respond to fast changing market situations. In particular, a dedicated number of slots for full freighter aircraft is needed at intercontinental hub airports, which connect Europe most efficiently to many regions around the globe. CLECAT is of the view that a revised EU Slot Regulation should ensure a system of fair, non-discriminatory and transparent rules for the allocation of landing and take-off slots to allow optimal utilisation and fair competition. Where the demand of landing and take-off slots exceeds the airport capacity, a mechanism to allocate slots is needed. To this extent CLECAT embraces market-based mechanisms for the trading of slots between airlines, as well as the introduction of local guidelines. CLECAT also calls for the extension of the use it or lose it rule, according to which currently 80% of the slots have to be used by an airline in order to keep their respective slots. An increase or the total implementation of this rule would even further increase airport capacities, whilst allowing more airlines to enter the market. This would again foster competition, ensure maximum flexibility and reduce prices. The rules for New Entrants should be amended to allow for more competition. Please find attached the full CLECAT Position Paper.
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CLECAT Demands End to Special Antitrust Exemptions for Shipping

3 Oct 2022
Topic — Evaluation of EU competition rules that allow liner shipping operators to cooperate.
Message — CLECAT requests that the Commission allow the existing shipping regulation to expire without renewal. They want it replaced by sector-specific guidelines to ensure the competition framework is transparent and enforceable.12
Why — This would stop shipping lines from unfairly favoring their own internal logistics services.34
Impact — Consumers and small businesses suffer from inflated shipping costs and reduced product availability.567
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Response to Union guidelines for the development of the TEN-T network amended proposal

20 Jul 2022

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, welcomes the opportunity to provide comments in response to the European Commission’s initiative to amend the legislative proposal for the revised TEN-T Guidelines from 14 December 2021. Taking into account Russia’s war of aggression in Ukraine, CLECAT agrees with the need to take into account geopolitical changes resulting thereof. This includes the reflection of the new status of external and trade relations with Russia and Belarus in the TEN-T maps, as well as a strengthened connectivity of Ukraine and the Republic of Moldova towards the EU, in line with the Action Plan on EU-Ukraine Solidarity Lanes. Considering the International Dimension of Freight Transport CLECAT advocates for the importance of considering the international dimension of freight transport and taking a holistic approach, extending beyond the EU-borders. In that regard, CLECAT has called in its recent position paper on the revision of the Combined Transport Directive (available here: https://www.clecat.org/positions/rail/clecat-position-on-the-revision-of-the-combi), for the improvement of extra-EU connections to the broad-gauge network and analysing how these could be connected to the EU’s TEN-T Network, considering the rising importance of the New Silk Road and China’s Belt and Road (BRI) initiative. Recent changes in the geopolitical situation require a new approach, focusing on the Middle- and Southern Corridors, instead of the Northern Corridor. Extension of European Transport Corridors To strengthen the connectivity of Ukraine and the Republic of Moldova towards the EU, in line with the EU-Ukraine Solidarity Lanes Communication of 12 May 2022, CLECAT believes that ensuring interoperability of the different railway systems is essential. When considering the urgent need to export agricultural goods from Ukraine via Poland, the different gauges between the EU and Ukrainian railway system posed one of the issues identified in April 2022, which hindered seamless transport operations. CLECAT therefore particularly agrees with the extension of four European Transport Corridors to Ukraine and the Republic of Moldova, as well as the adaptation of the TEN-T indicative maps of Ukraine for the rail, road and inland waterway network. Such an extension has the potential to ensure an increase in transport connections, as well as their efficiency. At the same time, it requires the fulfilment of technical and regulatory requirements on the entire corridor, which needs to be taken into account, e.g. in view of necessary investments. Challenges relating to a shift to European Standard Gauge In view of the difficulties relating to the different gauge systems, which became especially apparent during the efforts to support the export of agricultural goods from Ukraine, CLECAT also supports the inclusion of the requirement in the TEN-T Regulation on the development of the European standard nominal railway track gauge (1435 mm) for new railway lines and a migration plan to this nominal railway track gauge for lines on the European Transport Corridors. However, CLECAT notes that this will require significant investments and will have implications for those operations taking place on the rest of the network that are not covered by the European Transport Corridors and thus do not need to migrate to the European standard nominal railway track gauge. Considering the financial implications brought by as a result of these changes, CLECAT would strongly suggest that such proposals should undergo a proper impact assessment, including a cost-benefit analysis on the investment and operational costs, in view of determining the long-term effects of such a policy change. CLECAT remains at the disposal of interested parties for any further information.
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Meeting with Vlad Gheorghe (Member of the European Parliament)

14 Jun 2022 · Truck drivers safety

Response to Update of common rules for the allocation of slots at European Union airports

24 May 2022

The air freight sector continues to be highly impacted by consequences of national restrictions related to COVID-19 and the aggressive invasion of Russia into Ukraine. CLECAT, the European Associations of freight forwarders, logistics service providers and customs agents, therefore welcomes the opportunity to provide comments in response to the European Commission’s initiative to extend the slot relief rules in view of COVID-19 developments, as well as the consequences of the war in Ukraine, which both affect slot-use. Whilst acknowledging that air traffic levels have recovered substantially since the beginning of the COVID-19 pandemic, with forecasts indicating that the return to the 80% use rate could be possible as of the start of the winter 2022/2023 scheduling season, possible new travel restrictions and other sanitary measures connected to new COVID-19 variants, as well the impact of the ongoing war in Ukraine should be considered. In air freight, the impact of COVID-19 and the Russian invasion of Ukraine is particularly impacting long-haul flights, which are generally served by wide-body aircrafts, carrying significant amounts of cargo. The flight bans preventing EU carriers from flying into Russian and Belarussian airspace (and vice-versa), as well as the closure of the Ukrainian airspace, requires flights destined to the East to be re-routed, which are thereby significantly longer. The closure of air space also leads to an inefficient use of airport capacity. Regarding the unpredictable developments with the new COVID-19 variants, it has to be noted that airfreight continues to be affected by sanitary measures imposed due to COVID-19, particularly due the closure of entire cities in China, which has a disrupting effect on air travel and the overall economy. CLECAT considers the extension of the ‘justified non-use of slot’ (JNUS) exceptions essential to ensure that a potential loss of connectivity to long-haul markets is avoided. The JNUS will also be needed to address the impact of the war in Ukraine. In summary, CLECAT calls for the continued application of the justified non-use of slots (JNUS), as well as for flexibility in the application of the 80/20 rule, to consider the possible impact of emerging travel restrictions or other sanitary measures related to new COVID-19 variants and the impact of the aggressive Russian invasion into Ukraine. CLECAT supports the proposal to grant the European Commission the possibility to lower the slot-use rate by Delegated Act, if needed, as well as to extend the JNUS exception, where necessary, in light of developments relating to COVID-19 or the war in Ukraine and to ensure the consistent application of JNUS in the EU. Lastly, CLECAT would suggest the possibility to ‘freeze’ the historic rights for those flights that currently cannot be operated due to existing restrictions, such as the flights to the regions affected by EASA’s Conflict Zone Information Bulletin CZIB-2022-01R03, last revised on 24 March 2022, regarding the airspace of Ukraine, Russia, Moldova and Belarus.
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Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail

5 Apr 2022

CLECAT, the European association representing the interest of freight forwarders and logistics service providers, welcomes the European Commission’s initiative on improving the management and coordination of cross-border rail traffic, in view of increasing rail freight’s modal share. CLECAT considers that in view of the ambitious objectives of the European Green Deal and the Sustainable and Smart Mobility Strategy, aiming for a 30% modal share of rail freight by 2030, significant action will have to be taken as the modal share of rail freight has remained consistently low over the last two decades (around 18%). The integration of the TEN-T Core Network (CNC) and Rail Freight Corridors (RFC) into European Transport Corridors (ETC) provides the necessary momentum. The call for evidence identifies problems that need to be tackled, including the insufficient competitiveness of rail freight transport, based of inefficient management of capacity and problems of reliability and quality. It notes that the lack and inefficient use of available infrastructure capacity further decreases the attractiveness of rail freight. Whilst freight forwarders, representing the customers of rail freight services, are willing to make increased use of rail freight services, such a decision is conditional upon significant improvements in the current quality provided, both in terms of infrastructure and services. Should the provided quality of services remain unchanged, or even deteriorate further, the achievement of the modal share objectives will be practically impossible. The availability of high-quality infrastructure is an important aspect for increasing the use of rail freight transport, and represents a decisive element in multimodal transport. CLECAT observes that in some parts of Europe, sufficient terminal infrastructure is either lacking or not correctly used, with the number and distance of terminals differing greatly between the Member States. Equally, the reality remains that priority on the railway network is often given to passenger transport, which leaves a limited amount of capacity with little flexibility for freight transport. Additionally, the number of transhipment terminals with the necessary equipment varies widely in the EU. Having analysed the suggested policy options, CLECAT would express a preference for policy option 2 or 3, aiming for a comprehensive modernisation and harmonisation of rules, focusing particularly on capacity management, possibly paired with a stronger centralisation of decision-making and operational functions at EU level. Considering the existing situation on the market, CLECAT believes that a mere refinement of the existing legal framework for rail freight traffic (Option 1) will be insufficient to achieve the initiative’s aims of increasing cross-border rail freight traffic. The optimisation of rail infrastructure capacity and management can be a key aspect in increasing cross-border rail transport. Other elements proposed by the Commission are welcomed, including: • Improved cross border crisis or contingency management. • Capacity management should be improved, allowing for more priority allocated to freight trains, coupled with the necessary flexibility to respond to the market’s needs. Whilst multi-annual planning of capacity utilisation is useful, it is crucial to allow clients to obtain capacity also on short notice. • Stronger integration of rail freight transport in multimodal logistics chains: coordination and cooperation in the planning, operational and post-operational phases between rail sector stakeholders, as well as addressing issues in availability and efficiency of multimodal terminals. • Economic incentives, electronic exchange of information (eFTI regulation) and use of digital tools are welcomed. • Performance monitoring is welcomed to improve the performance of rail infrastructure and transport services in the post-operational phase.
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Response to Fight against counterfeiting

3 Mar 2022

CLECAT, the European Association for freight forwarding, transport-, logistics- and customs services is supportive of the Commission’s intention to set up an EU toolbox to step up the fight against counterfeiting. CLECAT represents the interests of more than 19.000 companies employing in excess of 1.000.000 staff in logistics, freight forwarding and customs services. Multinational, medium and small freight forwarders and Customs agents are all within its membership, making the organisation the most representative of its kind. The attached position paper sets out the views, concerns and recommendations of the European freight forwarding, transport and logistics industry on the EU Toolbox against counterfeiting. Executive Summary: • CLECAT is ready to continue to support the upholding of IP-rightsholders’ rights, provided rules are proportionate, consider market reality and do not impose undue burdens on the industry. • Logistics Service Providers (LSPs) handle hundreds of thousands of consignments daily for and behalf of their clients, the shippers. LSPs are only in exceptional situations allowed to open consignments or pallets on which goods are stored or packed for transport. • It is important to consider the different types of service providers on the market, as LSPs cannot be considered as intermediaries in the same way as online platforms or trade intermediaries. • Case law at national and EU-level shows that the services of an intermediary in relation to branded goods owned by a third party, i.e. the IP right holder, do not qualify as "use of the trademark in the course of trade”. Thus, the intermediary cannot be held responsible for an infringement of IP rights in that regard. • Physical controls of the goods to detect counterfeits must stay with national or EU authorities. It would be disproportionate to task LSPs to make informed, legally binding judgments on the authenticity of inspected goods, even for staff which is trained and employed to check goods for IPR infringements. • Whilst LSPs are supportive of due diligence by inspecting suspicious consignments, it is unreasonable, disproportionate, and impossible to oblige LSPs to proactively investigate, exchange information, supervise and implement systems for the detection of IPR infringements
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Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur) and Costa Cruises

3 Mar 2022 · AFIR

Response to Evaluation and revision of the Weights and Dimensions Directive

18 Feb 2022

CLECAT, the European association of freight forwarders, logistics services providers and customs agents, welcomes the initiative to revise Directive 96/53/EC, setting standards for the maximum authorised weights and dimensions of heavy-duty vehicles used in national and international transport. The revision of the Weights and Dimensions Directive should contribute to a more efficient and low-emission transport system and harmonised rules for cross-border operations. CLECAT would support amending the current 40-tonne weight limitation for border crossings (Annex 1, Article 2.2) to 44 tonnes. We would equally support an increase of the maximum weight on the entire EU road transport network, or at least along the TEN-T core and comprehensive network to 44 tonnes in all countries. Innovative solutions are required to further improve the efficiency of all transport modes, including road transport. One possible approach is optimising the transport chain by using multimodal solutions for the transport of greater quantities of goods. CLECAT therefore would welcome the increase of the maximum weight of lorries taking part in all multimodal transport operations across the EU, including intermodal and combined transport, to 46 tonnes. Such an extension of heavier load authorisations for multimodal transport operations would serve as a non-financial incentive to promote a shift to multimodal transport and thereby support reaching the ambitions of the European Green Deal. In this regard, it is essential that a scheme for authorising heavier loads for multimodal transport should be introduced uniformly throughout all Member States. Special attention should be paid to the cross-border application of such authorisations to avoid situations in which a Member State does not accept a heavier load authorisation granted by another Member State on its territory. CLECAT also highlights its long-standing support for longer combinations of standard vehicles (the ‘European Modular System’) with standardised modules. CLECAT believes that the wider use, including cross-border application, of EMS combinations in road freight will contribute to improved efficiency and reduced environmental impact through increased fuel efficiency and accompanying CO2 reductions. This will help operators and customers alike optimising the utilisation of trucks and trailers, road infrastructure capacity, and integration with other modes of transport such as rail, air, inland and short-sea shipping for the door-to-door total logistics solutions. The use of longer and heavier trucks would also bring more efficiency to supply chains by alleviating the structural shortage of drivers, which is expected to worsen in the coming years. Finally, CLECAT would support an extension of the scope of the directive to exceptional transport as this type of transport would benefit from harmonisation of legislation and rules.
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Response to EU standards for safe and secure parkings

10 Feb 2022

CLECAT, the European association representing the interests of freight forwarders and logistics service providers, highly appreciates the European Commission’s work on Safe and Secure Truck Parking Areas (SSTPAs) and welcomes the adoption of the draft Delegated Regulation on SSTPAs. Our members have a keen interest in advancing the standards for safe and secure truck parking areas in Europe. Freight forwarders have no financial interest in the setup and/or operation of the parking areas themselves. We fully support the EU SSTPA Standard and believe that it is needed to address the urgent demand for truck parking areas in the EU, by offering sufficient parking possibilities for drivers, which are of high quality and provide the desired amount of security. In that regard, we believe that a harmonised EU Standard will be key to successfully address the existing shortcomings. Whilst welcoming the draft Delegated Regulation, which has been the result of intense collaboration between the European Commission’s DG MOVE and the Expert Group on SSTPAs, of which CLECAT is a member, we have identified some areas which would require changes to appropriately address the problems posed by cargo theft in the EU. The attached position paper sets out the concerns and recommendations of CLECAT with regards to the draft Delegated Regulation on Safe and Secure Truck Parking Areas.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, welcomes the opportunity to provide comments in response to the public consultation on the European Commission’s proposal on EU Carbon Border Adjustment Mechanism (CBAM). CLECAT is supportive of the European Green Deal and its ambition to make Europe the first climate-neutral continent by 2050, and welcomes the objective of the CBAM proposal, aimed at preserving the EU’s high climate targets and protecting EU businesses from ‘carbon leakage’. CLECAT notes, however, that there are several challenges for the successful implementation of the CBAM that need careful navigation. Please find attached CLECAT’s Position Paper on the CBAM proposal, which provides an overview of the European intermediary sector’s main considerations and outstanding questions regarding the CBAM.
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Response to Revision of Combined Transport Directive

16 Sept 2021

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). CLECAT has long supported the revision of the CT Directive, which is outdated, ambiguous and creates barriers to the effective operation of combined transport. The CT Directive currently discourages some combined transport operations and disregards other forms of multimodal transport. The upcoming review would allow for new thinking on the legal conditions and possibilities to achieve the Union’s sustainability goals through a market-driven modal shift. In reviewing the impact assessment, CLECAT welcomes Options 2-4, and particularly Option 4. We particularly welcome and support an extension of scope of the instrument to all multimodal transport operations in the EU, provided that the longest leg of the journey is carried out by a sustainable mode of transport. This would support a market-driven modal shift. The existing lack of clarity on some definitions has led to significantly diverging interpretations of the CT Directive amongst the Member States. For example, the definition of a ‘combined transport operation’ itself is ambiguous and has led to diverging interpretations by various Member States. The lack of harmonisation distorts the level playing field and as a result imposes unjustified burdens on companies operating in certain Member States. Therefore, clear definitions are needed to ensure a common understanding and application throughout the EU of the CT Directive, leaving no room for interpretation. This should counter existing problems and ease combined transport operations. Additionally, CLECAT would support the change of the legislative instrument from a Directive to a Regulation. This would mean that the Regulation would have a more binding legal force throughout the Union and would avoid current problems caused by different interpretations. Generally, multimodal transport operations (including intermodal- and combined transport operations) are less cost-effective than road-only transport. Therefore, to ensure that the modal shift ambitions as outlined in the SSMS can be met in the transport sector, appropriate incentives should be created for the industry to move towards multimodal transport. Central elements in this regard include the continuation of the existing cabotage exemption (Article 4), which is currently undermined due to the introduction of a waiver contained in Regulation 2020/1055, support for mixed trains at EU level, as well as adequate financial support measures provided these do not lead to a distortion of competition. Moreover, the provision of high-quality reliable infrastructure, heavier load authorisations for multimodal transport, and a reduction of administrative burdens and costs should be taken into account. Finally, to ensure that the most sustainable mode of transport is chosen, CLECAT strongly believes that an accurate measurement and reporting of GHG emissions from freight movement and logistics operations should be introduced, as this bears the potential to accelerate the reduction of negative environmental impacts of transport. Measuring emissions from transport and logistics operations supports companies in making better-informed freight transportation decisions, thereby improving the carbon performance and cost-efficiency of their supply chains. Achieving Europe’s modal shift ambitions will only be realistic if the right framework conditions are put in place. To that end, CLECAT is looking forward to supporting the European Commission in its efforts to ensure a successful multimodal transport framework in Europe, which will be key to green freight transport operations through a realistic and market-oriented approach.
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Response to Revision of the NIS Directive

18 Mar 2021

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, considers that it is of key importance to ensure the security of logistics supply chains at all times and supports measures in the field of cybersecurity which can assist companies to become more resilient against cyberthreats. CLECAT welcomes the proposal for a revised NIS Directive as it seeks to address the deficiencies of the previous Directive, and to adopt it to current and future needs. This will support our members to become more resilient against cyberthreats. The revised Directive abolishes the obligation for competent authorities to identify Operators of Essential Services (OES) which is welcomed by CLECAT. The current Directive has led to significant inconsistencies amongst EU Member States and created a patchwork of national legislation. However, we consider the introduction of a clear size cap problematic. As the intention of the measures is to secure critical infrastructure, it would be inappropriate to apply the rules to SMEs. This would go significantly beyond the scope of the Directive and impose an unprecedented high level of regulatory burden on entities which, based on their size and activities, cannot be considered as an OES, as a disruption or breakdown in their activities would not have a noticeable effect on the supply chain at national or EU-level. CLECAT would instead support harmonised EU-wide thresholds going beyond a mere size cap. These should ideally be established by the European Commission, in cooperation with industry, to ensure that only those companies which can be considered as ‘critical’ fall within the scope of the Directive. We recommend the Commission to seek to ensure a fair level playing field throughout the EU, which can only be achieved if EU legislation is applied in a harmonised manner. However, the proposal for the NIS2 Directive again follows the principle of minimum harmonisation. This is problematic, as under the current Directive it has been one of the causes for an unlevel playing field. For example, Germany and France have now extended the scope and include logistics as OES. CLECAT believes that this extension is unjustified and distortive to the internal market. Therefore, a Regulation may be a more suitable legal instrument to ensure harmonisation and to avoid that Member States go beyond the entities identified by the Commission. The freight forwarding and logistics sector is crucial and relevant for the effective functioning of transport operations within the internal market. However, logistics services primarily serve as a support function in the supply chain, and therefore are reliant on the essential services provided by the transport operators and infrastructure providers, such as airports and infrastructure managers. The sector CLECAT represents consists of thousands of businesses operating in a heterogenous, highly competitive market, consisting of many market players of all sizes, but mainly SMEs. As the impact of an incident in the logistics sector is unlikely to have a significant disruptive effect on society (as services can be carried out by other operators), we consider that the freight forwarding and logistics sector should not be considered as OES. The existence of many alternatives significantly reduces the likelihood of a potential impact on the economy. This is different in the case of an incident disrupting the infrastructure the logistics sector relies on. CLECAT therefore particularly welcomes the fact that the logistics sector has not been included as an OES in the NIS2 proposal. Regarding jurisdiction, it has to be noted that a cyber-threat does not distinguish national borders. Placing entities under the separate and concurrent jurisdiction of Member States where they provide their services does not effectively address the problem at its core and will be difficult to apply in practice for a global industry like the logistics sector.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

CLECAT, representing European freight forwarders and logistics service providers, has broadly supported the sustainable finance workstream of the European Commission, noting that the EU legislative framework for facilitating sustainable investments should take appropriate account of the transport and logistics sector and guide the financial market actors, willing to invest in cleaner modes of transport, as well as zero-emission transport technologies, digital logistics solutions and further development of low-carbon transport infrastructure in the EU. Indeed, the ambitious European Green Deal decarbonisation objectives will require significant scaling-up of private investments in the transport and logistics sector. We therefore welcome the findings of the Technical Expert Group on Sustainable Finance (TEG) and the European Commission’s initiative of establishing a delegated act to set out the EU-level technical screening criteria (i.e. taxonomy) for determining which economic activities qualify as sustainable and environmentally-friendly. We hope that the proposed taxonomy will prove to be a key tool for the transition to a climate-neutral economy and help the industry achieve the 90% transport decarbonisation target, set out by the EU Green Deal and the new EU Strategy for Sustainable and Smart Mobility. With that in mind, we would like to offer a few comments on where further improvements are needed in the climate change mitigation and adaptation taxonomy: • It is noted that the technical screening criteria for the transport sector should focus on reducing the main emission sources from that sector, while also considering the need to shift the transport of goods to lower-emission modes. CLECAT continues to emphasise that forced modal shift ambition will not be successful if there are no reliable and economically viable alternative solutions, as well as sufficient capacity in rail and inland waterways. The taxonomy should therefore put more emphasis on steering capital flows towards investments in more accessible infrastructure and better intermodal connectivity. • With respect to road freight vehicles, biofuels/biogas are promoted in activities 6.5 and 6.6, provided that advanced biofuels or renewable liquid and gaseous transport fuels are used. Whereas biofuels/biogas will remain necessary for long-haul transport in the near future and also to ensure the backup for critical infrastructure, they should be largely regarded as transition fuels. Moreover, enforceability will also be an issue; for example, there is no way to monitor whether a truck is consistently filled up on biogas, as gas-fuelled truck can be run on both biogas and fossil gas. • The technical screening criteria for pollution and prevention control of road transport activities is expected to lead to measurable results. However, we are concerned about meeting pollution and prevention control requirements in scope 3 reporting, given the difficulties for companies to control all the indirect emissions that occur in their value chain. • The proposed criteria for infrastructure enabling low-carbon road transport is insufficient, as there is no way to ensure that only vehicles conforming to the taxonomy thresholds use the infrastructure. The transport infrastructure criteria should therefore be outlined in a way that low- and zero-emission transport enabling infrastructure is preferred. • The absence of technical screening criteria for aviation and maritime shipping reflects the long-term decarbonisation pathways these modes are facing, as well as the lack of commercially available climate-friendly alternatives. Any future criteria for these modes, based on the ongoing assessments of ‘green’ impacts of investment in maritime and aviation sectors, must respect the EU transport decarbonisation targets for 2030/35 and 2050.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

2 Jun 2020 · Meeting to discuss transport and logistics.

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

4 May 2020 · 1st Mobility Package and the Commission’s ongoing impact assessments, info sharing on national road transport developments with respect to COVID-19.

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

18 Mar 2020 · Consortia BER review and the early indication of the Commission to extend the BER with another 4 years, issues relating to the green deal (maritime/aviation related) and present the general policy objectives of our association, representing freight forwarders and logistics service providers, with regards to digitalisation

Response to Prolongation of the Consortia Block Exemption Regulation

31 Dec 2019

European freight forwarders, represented by CLECAT, express their disagreement with the European Commission’s proposal to extend the Consortia Block Exemption Regulation (CBER) with 4 years. The EC has indicated that an extension to the BER is justified based on the current market conditions and other factors such as enhanced economic efficiency, easier assessment of competition law, and greater legal certainty. In response to this CLECAT notes that 1. the reduced possibility of costs rationalisation by consortium members (by means of increased market concentration in liner shipping combined with the deployment of Ultra Large Container Vessels) has resulted in a continuous deterioration in the quality of service with the inability to secure reliable performance against agreed contract terms and therefore an erosion rather than increase in economic benefits to share with users. This in effect undermines the rational for the CBER. 2. when carriers – or any other industry - are exempted to perform legal assessments with normal competition rules then it is obvious that the costs of compliance decrease which makes that the criteria on legal certainty and efficiency are in effect self-fulfilling. 3. the CBER does not improve legal certainty because of the difficulties, even the Commission acknowledges it has, in establishing exact market shares. Collecting data would help to provide legal certainty, but carriers have never been required to perform a full assessment under Article 101. As outlined in the attached joint submission, providing a legal assessment of the Commission’s Staff working document (SWD) the Commission has failed: (1) to obtain the relevant price and market share data and information readily available from the carriers to enable it to review the operation of the CBER in the light of the major developments in the industry; (2) to recognize that a BER is the application of competition law by legislation of general application to a category of defined agreements but is not a self-standing law in the same way as standard EU legislation subject to the EU Better Regulation policy and the related Evaluation process; (3) to assess the five Evaluation criteria accurately, in any event, because of the failure to obtain the available relevant data, ignoring the market trends since 2014 CLECAT regrets that the EC has dismissed the position of the users of liner shipping services, but equally that is seems to have lost side of profound changes in the market in particular with the ULCV’s and Global Alliances, resulting in reduced sailing schedules, fewer direct ports of call, reduced choice and delays in ports which is impacting the hinterland transport discriminating freight forwarders in their hinterland services as they do not benefit of the CBER. There is little recognition that landscape of the liner shipping industry has changed in the sense carriers do not limit their services to port to port services; they also exchange data on services which relate to the port and land side which is made easier with developments in the area of big data and business intelligence and analytics – all of this not available to the liner shipping industry at the time of previous reviews of the BER. The impact of the ongoing vertical and horizontal integration is that the relevant market is no longer a port to port maritime transport service but can also relate to a door to door service. CLECAT contends that because of these significant shortcomings, it is not admissible for the European Commission to simply extend the CBER for another four years. CLECAT calls for ending these special privileges and an eventual return to normal competition conditions for the liner shipping industry.
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Response to The Information Management System for Official Controls regulation (IMSOC)

17 Jun 2019

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services, appreciates the opportunity to provide feedback on the draft ‘IMSOC’ Regulation. CLECAT welcomes the new single IT platform ‘IMSOC’ and recognizes its importance for streamlining the exchange of data in relation to official controls and ensuring the compliance and monitoring of consignments. Notably, the proposed data requirements for the CHED templates, as provided in Annex II of the proposal, deserve special attention. Given the important role of the CHED and the impact it will have on the daily operations of economic operators, it is crucial to ensure that the information required is available at that particular moment in time and that it has added value. Excessive data requirements might lead to unnecessary administrative burden and risk of errors that would lead to reduced data quality, increased costs and delays causing undesired consequences and even refusal of entry. Therefore, the data elements in the CHED model should not go beyond what is necessary for the performance of a risk-based approach to imports. CLECAT believes that a fair balance can be struck between ensuring compliance and facilitating legitimate trade. In this context, CLECAT would like to express particular concerns regarding entries I.7 and I.13/I.27 in the CHED templates. As regards I.7 Place of Destination, CLECAT would like to alert of the excessive administrative burden that would be imposed on operators when providing that information in cases where consignments are split following checks. There is a need to provide more flexibility. Also, in cases of indirect transit, details regarding the third country of destination are often neither available at the time of customs storage, nor relevant since the goods do not enter the EU. Regarding direct transit, the field should be left optional - the destination third country is already indicated in I.22. The data field also excludes control points – however, it has to be considered that often consignments (phytosanitary products) are unloaded, inspected and released for free circulation at a control point. As regards I.13 and I.27 Means of Transport (after BCP/storage), it should be noted that in practice, it often occurs that the specific identification of the means of transport is not available until a later point in time, there might also be changes during the transport itself. Such practical arrangements and realities of international transport and logistics should be taken into account when establishing the data requirements. The additional requirements for flight number, vessel name, train identity, truck/trailer number etc. should be made optional. Requesting data that is not yet available imposes unnecessary and excessive administrative burden on operators and increases the risk of errors. Attached you will also find the CLECAT Position Paper on the Official Controls Regulation, highlighting key elements that are considered crucial for the organisation of efficient border controls and that need to be duly taken into account in the development of the supplementing rules to the new Regulation.
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Response to Evaluation of Consortia Block Exemption Regulation

4 Jun 2018

CLECAT, the European association of freight forwarders and logistics service providers, would want to express its interest in the evaluation process of the Consortia Block Exemption Regulation (Commission Regulation 906/2009) which has been recently launched by DG Competition. The review of the Consortia Regulation has been launched during a period during which consolidation and the establishment of new alliances are ongoing and need to be properly assessed by the European Commission and stakeholders involved. We therefore are concerned that the time-lines as announced in the roadmap for comments do not provide sufficient opportunity for stakeholders to asses the impact of changes in the market. CLECAT therefore calls on the Commission to grant all parties sufficient time to be able to provide relevant insights at least until the end of the first quarter 2019 The Consortia Block Regulation, which is a generous exemption from competition rules, has an impact on a number of important actors of the logistics supply chain which needs to be properly assessed. CLECAT in general maintains that Consortia represent a legitimate business mechanism for otherwise competing liner shipping companies. However, we will question whether a block exemption itself is necessary as it will, by its nature, reduce competition.
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Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

23 May 2017 · Mobility package

Response to Heavy Duty Vehicles CO2 and fuel consumption certification

8 May 2017

We welcome the Commission Draft Regulation on Heavy Duty Vehicle CO2 and fuel consumption certification and the opportunity to provide comments to the TCMV. CLECAT has consistently supported the development of the VECTO tool and called for access to output data to be opened up to transport buyers and operators in order to facilitate the measurement of road transport emissions. CO2 emissions are an increasingly important factor in decision-making for freight forwarders and their customers, making transparency over emissions performance an essential step forward. We also support the development of CO2 standards for HDVs, based on measurement carried out using the VECTO tool. With regard to the Draft Regulation presented for consultation, we wish to register several comments, as outlined in the attached document.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

4 May 2016 · Land security, air cargo security

Meeting with Desiree Oen (Cabinet of Commissioner Violeta Bulc)

12 May 2015 · Logistics