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European Express Association

EEA

The European Express Association represents express delivery companies in Europe, employing 330,000 workers directly and supporting 1.1 million jobs across the EU while delivering over 450 million packages annually.

Lobbying Activity

European Express Association demands simpler EU delivery rules

13 Nov 2025
Topic — The EU is consulting on replacing postal and parcel delivery regulations.
Message — The association calls for a flexible regulatory framework that avoids expanding rules to the parcel market. They request simplified administrative requirements and the exclusion of environmental mandates from postal-specific legislation.12
Why — This approach would prevent new costs and maintain the industry's competitive market position.34
Impact — National postal providers might face financial strain if cross-industry funding for universal services is restricted.56
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Meeting with Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič) and DHL Group and

12 Nov 2025 · Customs Union Reform, e-commerce

Express industry urges harmonized EU cybersecurity reporting rules

14 Oct 2025
Topic — The Commission is consulting on simplifying digital laws to reduce business administrative burdens.
Message — The association proposes extending the initial incident reporting deadline to seventy-two hours. They also advocate for a central EU hub to handle all regulatory notifications.12
Why — Streamlined reporting would significantly lower compliance costs for cross-border delivery companies.3
Impact — National security agencies would lose immediate awareness of threats under longer reporting timelines.4
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European Express Association rejects mandatory zero-emission fleet targets

8 Sept 2025
Topic — A consultation on setting minimum zero-emission requirements for European corporate vehicle fleets.
Message — The association demands that mandatory purchase targets for zero-emission vehicles be avoided. They request focus on grid infrastructure and measures to lower vehicle ownership costs.12
Why — Lowering vehicle costs would help express companies offer competitive prices for sustainable transport.3
Impact — Small businesses could face exclusion from contracts due to the high cost of technologies.4
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European Express Association seeks green fuel flexibility and subsidies

4 Sept 2025
Topic — The initiative establishes a strategic framework for investing in sustainable aviation and maritime fuels.
Message — The EEA requests a 'book and claim' system to trade sustainable fuel certificates across Europe. They also urge the EU to expand financial subsidies for aviation and private electric charging.12
Why — A virtual fuel market and infrastructure subsidies would significantly reduce their operating costs.34
Impact — Fuel suppliers would lose the ability to charge extra fees for physical fuel distribution.5
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European Express Association opposes expanding carbon tax to downstream products

26 Aug 2025
Topic — Consultation on extending carbon border taxes to more imported downstream products.
Message — The association opposes expanding the carbon tax to more downstream goods. They demand that customs representatives be freed from liability for environmental data. The group calls for regulatory breathing space before any new rules.123
Why — This prevents delivery companies from facing legal liability for data they cannot verify.4
Impact — Environmental groups lose if companies move production abroad to avoid carbon costs.5
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European Express Association urges grid upgrades for electric trucks

5 Aug 2025
Topic — EU initiative to upgrade and expand energy infrastructure for a resilient system.
Message — The EEA calls for faster grid capacity expansion and streamlined permitting for vehicle charging stations. They also demand standardized grid connections and financial support for electrifying transport depots.123
Why — Streamlined permitting and standardized connections would reduce their administrative costs and operational delays.4
Impact — Granting priority access to transport depots could delay grid connections for other industrial sectors.5
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Meeting with Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič) and DHL Group and

25 Jun 2025 · Exchanges on the EU Customs Reform

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

European Express Association urges B2C and weight-based EUDR exemptions

13 May 2025
Topic — The consultation reviews the specific products covered by the EU Deforestation Regulation.
Message — The EEA requests excluding B2C imports and establishing a 100 kg weight-based exemption threshold. They also propose a positive list of keywords to clarify product scope and avoid manual checks.123
Why — This would lower administrative burdens and prevent operational delays at EU borders.45
Impact — Environmental monitoring is reduced as authorities focus only on high-impact commercial activities.6
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Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné)

25 Mar 2025 · Various policies affecting competitiveness of the express freight sector

Meeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto)

26 Feb 2025 · Presentation of EEA members activities and issues faced in relation to EU regulation

Meeting with Claire Depre (Head of Unit Mobility and Transport)

26 Feb 2025 · Exchange of views on upcoming and ongoing Commission initiatives, in relation to measures to facilitate the uptake and use of alternatively fuelled vehicles.

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

24 Feb 2025 · Exchange of views on SAF and aviation decarbonisation.

Meeting with Rosa Serrano Sierra (Member of the European Parliament, Rapporteur)

20 Jan 2025 · Weight and Dimensions Directive

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

11 Dec 2024 · Customs Union

Response to Digital Product Passport (DPP) service providers

9 Dec 2024

The European Express Association (EEA) is pleased to provide its feedback to the consultation regarding the "Digital product passport rules for service providers" in its attached letter. The EEA is available to address any questions or requests for clarification via our Secretariats functional email: tfc@euroexpress.org.
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European Express Association requests new CBAM Authorised Representative status

27 Nov 2024
Topic — This consultation covers the establishment of the registry for Carbon Border Adjustment Mechanism.
Message — The association proposes creating an Authorised Representative to help importers with technical reporting. They also insist that the registry be fully operational by December 2024.12
Why — This would allow delivery firms to provide technical assistance without assuming legal liability.34
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European Express Association seeks shorter CBAM approval timelines

27 Nov 2024
Topic — This consultation defines procedures and conditions for the authorisation of carbon border adjustment declarants.
Message — The EEA requests shorter assessment periods for applications and a higher threshold for small shipments. They also advocate for more flexibility regarding detailed import value forecasting for logistics providers.123
Why — Streamlined processes would help businesses avoid trade disruptions and reduce high administrative compliance costs.4
Impact — Regulatory authorities lose transparency when reporting requirements for indirect customs representatives are significantly eased.5
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Meeting with Dirk Gotink (Member of the European Parliament, Rapporteur)

13 Nov 2024 · EU customs legislation, e-commerce

European Express Association Urges Delay in Aviation Emissions Reporting

29 Jul 2024
Topic — The consultation updates rules for monitoring and reporting non-CO2 greenhouse gas emissions.
Message — The association requests a more realistic implementation timescale, arguing the current 2025 start date is impossible to meet. They also suggest reviewing high default fuel values and providing monitoring plan templates to simplify the process.123
Why — A revised schedule would reduce the immediate administrative burden and risk of non-compliance for delivery operators.4
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Response to Evaluation and revision of the Weights and Dimensions Directive

28 Jun 2024

The European Express Association (EEA) welcomes and supports the proposed revision of current Directive 96/53/EC on Weights and Dimensions (hereafter W&D). The EEA would like to highlight its key priorities and takeaways in the attached document.
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European Express Association Opposes Damaging Green Airport Slots

6 Jun 2024
Topic — The European Commission is evaluating whether current airport legislation remains fit for purpose.
Message — The association rejects linking slot allocation to environmental criteria and supports keeping the global 80/20 usage rule. They also demand full liberalisation of ground handling and more transparent, cost-related airport charges.123
Why — These measures would protect their operational flexibility and reduce the costs of essential airport services.45
Impact — Airlines with smaller fleets may lose out if dominant airports continue to misuse their market power.67
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Meeting with Magda Kopczynska (Director-General Mobility and Transport)

29 Jan 2024 · Implementation of Regulation ReFuelEU Aviation

Meeting with Rovana Plumb (Member of the European Parliament, Shadow rapporteur)

8 Jan 2024 · Count Emissions EU

European Express Association Calls for Simpler Parcel Reporting

1 Dec 2023
Topic — EU initiative to reduce administrative reporting burdens for businesses by twenty-five percent.
Message — The EEA requests alignment of national rules with EU standards to eliminate duplicative requirements. They argue current reporting formats reflect postal models instead of the express delivery sector.12
Why — This would significantly reduce administrative costs and simplify compliance for express delivery operators.34
Impact — National regulators would lose specialized data collected through domestic laws that overlap EU rules.5
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Response to Revision of the Union Customs Code

30 Oct 2023

EEA would like to express our appreciation for the proposals presented by the European Commission on 17 May 2023, which outline significant reforms to the Union Customs Code and related legislation. These reforms aim to address the shortcomings of the current legislation and improve the efficiency and effectiveness of customs procedures within the European Union (EU). In particular, the proposal introduces the European Customs Authority, the EU Customs Data Hub, and the Trust and Check Trader status. We commend the Commission for its dedication to enhancing customs operations and believe that these reforms could contribute to a more seamless and secure trade environment. EEA would like to welcome the opportunity to comment on the proposal on the reform of the EU Customs Union. We consider that the input from the express industry is not only valuable but critical. As we continue to closely cooperate on the IT developments under the current Union Customs Code and the related Work Program, it is equally important for EEA to contribute at the earliest possible time to the fundamental and wide-ranging customs reform that will shape the legislative framework and functioning of the EU Customs Union in the decades to come. EEA acknowledges the positive elements presented in the proposal for the reform of the Union Customs Code. However, all of these innovations need to be aligned with the realities and requirements of legitimate trade, or they will fall short of achieving their ambitious objectives. Furthermore, we raise concerns about the implementation timelines, the removal of De Minimis on duties, the reduction in temporary storage periods, and the need for a balanced approach that considers both compliance and facilitation. We would like to offer our full collaboration when developing Implementing and Delegated Acts, as well as guidelines and training material, for the future legislation to support a fair level playing field for all legitimate economic operators, safeguarding the interests of citizens, facilitating trade and allowing customs authorities to collect taxes and run the required risk assessment. We encourage the legislator to address these concerns and ensure that the final reforms provide tangible benefits for trade, streamline customs procedures, and foster a secure and efficient trading environment within the EU.
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Response to Revision of the Union Customs Code

5 Sept 2023

The European Express Association (EEA) will deliver its position on this subject in its forthcoming main public consultation response on the Revision of the Union Customs Code.
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European Express Association warns of undue burden from CBAM rules

7 Jul 2023
Topic — This consultation concerns reporting obligations for the EU's carbon border adjustment mechanism.
Message — The association requests a clear separation between customs and carbon reporting duties. They also want simplified default values used for all products to ease reporting.12
Why — This would reduce technical compliance costs and shield logistics firms from legal liabilities.3
Impact — Non-EU importers risk non-compliance if logistics companies do not notify them of rules.4
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Meeting with Henna Virkkunen (Member of the European Parliament)

28 Sept 2022 · The Alternative Fuels Infrastructure Regulation

European Express Association warns against removing customs duty exemptions

19 Sept 2022
Topic — Reforming the Union Customs Code to address e-commerce growth and fragmented national systems.
Message — They want to keep the current duty-free limit for low-value imports. They also propose a single digital window and simplified rules for trusted carriers.12
Why — Simplifying customs processes would lower operational costs and prevent delays for delivery businesses.34
Impact — EU member states lose potential tax revenue by not taxing smaller online purchases.5
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Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur)

20 May 2022 · Sustainable aviation fuels (ReFuelEU Aviation Initiative) 2021/020(COD)

Meeting with Mette Dyrskjot (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Penta

20 Apr 2022 · Digital labor platforms

Meeting with Sunčana Glavak (Member of the European Parliament, Rapporteur)

19 Apr 2022 · ETS Aviation and CORSIA Notification reports

Response to Evaluation and revision of the Weights and Dimensions Directive

17 Feb 2022

The European Express Association welcomes the opportunity to submit feedback on the revision of Directive 96/53/EC and welcomes the proposed initiative. The revision of the file will ultimately result in a greener, low-carbon transport system in Europe and as set out by the objectives in the Green Deal, should aim at improving the efficiency of logistics and road freight operations across Europe. Flexible Cross - Border Transport EEA members would like to obtain the legal possibility to cross internal EU borders with ecocombis between two consenting EU Member States and would therefore like to encourage the European Commission to consider incorporating a provision to facilitate such cross-border traffic when proposing a revised Weights and Dimensions Directive. Directive 96/53/EC provides for a limit of 18,25 metres and 40 tons for cross-border traffic between Member States. It is noteworthy that several member states nevertheless allow longer and heavier vehicles to circulate freely within their national territory. There are also currently derogations for international transport under Directive 96/53/EC for combined/intermodal transport up to 42 or 44 tonnes with containers or swap bodies up to 45 feet (under point 2.2.2 c) or d) in Annex I). However, anecdotal evidence suggests that in practice it is difficult to obtain such an exemption. This has a negative effect on transport efficiency and the environment. The EEA therefore urges EU policy-makers to allow 25.25 meter vehicles in international transport and to raise the current limit of 40 tons for international transport to 44 tons. In addition, the revised WDD should allow neighbouring EU Member States to mutually agree to raise further the maximum weights and dimensions of ecocombis in cross-border traffic according to their national maximum criteria. Moreover, the revised WDD should accommodate mutual recognition between EU Member States among others of driver training and certification and licensing procedures of the vehicle. The EEA would like to highlight the potential benefits of waiving restrictions on cross-border eco-combi operations between neighbouring countries which allow such vehicles to circulate within their national territory. Allowing the cross-border use of eco-combis would further contribute alleviating traffic and congestion challenges, as two eco-combis can replace three regular trucks, transporting more goods while saving vehicle kilometres. The European Modular System (EMS) is an innovative solution and the right response to reduce the impact of road transport on the environment. It allows Member States to decide on transport solutions fit for their road transport network and it reduces emissions and congestion on roads. Whether in the form of trials or by having foreseen the use of ecocombis in their legislation, Belgium, Czech Republic, Denmark, Germany, Finland, the Netherlands, Norway, Portugal, Spain, and Sweden have already embraced the EMS concept. It is only a logical step to further accommodate the decarbonisation through more efficient road transport operations.
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Rapporteur)

17 Feb 2022 · EU ETS Aviation

Response to Count your transport emissions: CountEmissions EU

17 Dec 2021

EEA members are committed to reducing their carbon footprint. The monitoring and calculation of GHG emissions can hereby be instrumental to improve companies’ environmental performance. EEA member companies are already measuring their carbon footprint in the context of non-financial reporting to identify hotspots in own operations and as part of commercial contracts with customers. EEA therefore supports continued efforts to fully align existing GHG measuring tools and methodologies in transport and logistics activities. EEA members have been promoting the GLEC framework as a voluntary and industry-led accounting standard as well as the European standard EN 16258. In this regard, using the expertise of NGO’s/ NPO’s such as the GLEC organization could aid in designing a reporting methodology with a better fit to industry. Having input from these organizations could also ensure continued development in reporting standards. A lot of logistics companies have adopted both of the GLEC framework and EN 16258 standard, which build the foundation for a global accounting standard for GHG emissions of transport services, i.e. the ISO 14083 standard, which is currently under development. Therefore, setting a common GHG calculation and reporting framework should be based on GLEC, and/or EN 16258 would recognize the efforts that operators have already made to develop measurement tools based on these standards. Building on existing EU industry-led standards while setting more accurate implementation parameters would favor the acceptance and use of a global approach to GHG calculation and reporting and could even set a precedent which other regions could follow. EEA members are multimodal companies by definition and the parameters used to opt for one or another (mix of) transport mode(s) are based on environmental impact but equally so on specific characteristics of the goods to be transported as well as size, volume, origin/destination, and on customer needs in terms of delivery times and others. The scheme shall not be used for policy deciding which mode(s) of transport to be used by an operator. Therefore, initiatives to improve GHG data collection, monitoring schemes and a common methodology framework at global level are greatly supported. We generally support a reporting system that is easy to use as well as on-going alignment between the Commission and our industry about this initiative.
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Response to EU strategy for Customs risk management

2 Nov 2021

The European Express Association (EEA) welcomes the opportunity to comment on the Roadmap detailing the proposed Communication on the EU Strategy for Customs risk management and its proposal to reshape and strengthen the current risk management framework, in order to achieve an ‘even more responsive and structured approach to customs risk management.’ The success of this proposed Strategy will depend on broad consultation and cooperation with the business community and other stakeholders, to ensure that the strengthening of the risk management framework does not compromise the flow of legitimate trade at the border or place unnecessary additional burden on traders. The core objective for the Strategy outlined in the Roadmap – to make controls more effective and reduce risk while ensuring the EU’s ongoing competitiveness – is to be commended. The safety, security and welfare of European businesses, workers and consumers is paramount. It also makes sense that the framework is updated to account for recent and upcoming initiatives. Nevertheless, it should be stressed that Express operators continuously upgrade their processes and supply chains to minimize risk and already cooperate extensively with customs. Global logistics and aviation security training programs, threat-based risk management, and significant investment in facility security and legal approved security screening equipment and methods demonstrate just some of the initiatives pursued by Express operators to ensure a secure network. Moreover, Express is the only delivery industry which provides end-to-end data coverage. At the same time, the Express industry has worked hand-in-hand with the EU and national authorities on a range of new initiatives designed to strengthen the risk management framework. In 2021, Express operators implemented the EU’s new ICS2 pre-load safety and security requirements, and now turn their attention to the upgraded pre-arrival requirements that will be enacted through to 2025. Meanwhile, our members have been working closely with EU and national authorities to implement the VAT e-commerce changes from 1 July 2021, enabling greater oversight and increased revenue collection on low value shipments. Considering the significant economic and resource burden imposed on Express operators, both to effectively comply with UCC and other policy developments and to meet the demands of our customers in today’s e-commerce-driven world, any upgrading of the risk management framework needs to be carefully managed. In recent years, the Express industry has been required to provide more and often duplicative data to customs, earlier and earlier in the process. The EEA will carefully monitor the development of this Strategy and awaits more concrete details, including the Roadmap’s stated approach to take a ‘low-risk’ approach to risk management, which will need to be carefully managed to avoid restricting the flow of legitimate trade. In our view, the updating of this framework should focus on harmonizing and streamlining current approaches and making better use of existing data to ensure an efficient system that applies EU-wide, rather than developing comprehensive new initiatives or establishing new data requirements that would add to an already complex risk-management environment that can vary from country-to-country. Finally, the EU should use this opportunity to enhance and further harmonise the Authorised Economic Operator (AEO) program in order to deliver more tangible benefits to businesses. The Express industry is looking forward to engaging on this important and timely project, and welcomes the opportunity to provide feedback and cooperation at each stage of the process.
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Response to Carbon Border Adjustment Mechanism

25 Oct 2021

The European Express Association (EEA) welcomes the opportunity to comment on the proposal for a regulation establishing a carbon border adjustment mechanism (CBAM); we greatly appreciate the consideration given to economic operators and EU citizens as part of this exercise. The focus of our feedback is mainly targeted on the potential impact of the new proposal at the border, from the perspective of the express industry and our customers. Our feedback is provided in the document attached.
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Response to Revision of Combined Transport Directive

14 Sept 2021

The European Express Association (EEA) - which represents express delivery companies and national express associations across the EU – welcomes the opportunity to provide feedback on the Commission roadmap about the Combined Transport Directive (CT Directive), as follows: Need more support for intermodal transport The EEA would welcome more support for intermodal transport operations but not in terms of forced modal shift initiatives that lack the right incentive schemes and support measures. Ambiguous terms and lack of adequate incentives The Directive is too ambiguous as it sets restrictions which do not adequately serve its own objective of supporting the shift from road freight to lower emission transport, and does not set the right incentive scheme to use intermodal/ combined transport in general. Inefficiency and inadequacy of limitation on distance In some combined transport operations, the initial and final road leg may be longer than 150 kilometers, but the costs and CO2 emissions of a door-to-door operation for the intermodal operation might be lower than for the sole road option, which is not taken into consideration by the Directive. Fragmented implementation leading to high administrative costs The current CT Directive entails administrative costs and bureaucratic hurdles due to the different implementation in the Member States and makes it difficult for EEA members to benefit from the CT Directive. Insufficiently applied cabotage exemption Effectively removing the remaining existing restrictions for cabotage would allow a more efficient use of capacities and reduce the number of trucks running empty. Therefore, the EEA welcomes the cabotage exemption in the CT Directive. Promote ecocombis/EMS Further, the use of ecocombis/EMS (European Modular System) should be promoted in combined transport operations. Need more customer orientation Also, a stronger customer orientation is needed which comes along with increased competition and will lead to an improvement of the existing services.
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Response to New EU urban mobility framework

25 May 2021

The European Express Association welcomes the Commission’s objective of creating a new EU framework for urban mobility whichis important to avoid excessive fragmentation whilst also allowing for flexibility for local usage, taking into account broad stakeholder consultations and local circumstances. Committed to reducing climate emissions in cities Sustainable, effective and efficient urban freight transportation is vital to businesses and citizens in European cities. The need to deliver goods and merchandise to shops which do not keep stocks, growth in e-commerce and demand for home deliveries, coupled with a growing urban population, indicates that urban delivery networks will need to continue expanding and improving. EEA members fully support a technology neutral regulatory framework for sustainable fuels and alternative drive systems to reduce the carbon footprint of transport activities by providing ever-more sustainable services: Not only by reducing traffic movements through bundling of shipments, but also by using alternative delivery methods and continuously upgrading to alternatively fueled vehicles. Such initiatives and solutions will go a long way towards addressing traffic congestion, air quality and road safety challenges. Promoting a coherent, holistic and integrated approach to urban mobility planning towards 100 carbon neutral cities objective Research and innovation funding should be dedicated to facilitating the delivery of new solutions for urban mobility challenges, exchanging best practices and enabling businesses to develop innovative transport and mobility services. Pilot programs, also under real life conditions, which encourage a shift to clean and energy efficient technologies should be supported. Encouraging the uptake of Sustainable Urban Mobility Plans (SUMP) guidelines remains important, taking into account a holistic approach and individual city-specific needs and characteristics. Access to EU funding should therefore be linked to the SUMP guidelines. Transitioning into zero-emission cities requires taking into account cross-cutting legislation, e.g. more ambitious CO2 standards for vans, quicker roll out alternative fuels infrastructure, broader offer of all types of alternatively fuelled cargo vehicles, obligatory implementation of drivers licence adjustment for e-vehicles >4.25t. Ensuring the smooth functioning of the internal market in urban, first- and last- mile segments of freight Greater coordination between public and private sector actors remains crucial in shaping effective and sustainable urban mobility solutions that address identified challenges and enable innovative solutions. However, cities and regions differ with respect to the necessary intervention. Coordination must remain on a local or regional level, aligned beforehand with the relevant stakeholders to identify local needs, in order to ensure sustainable, cost-efficient solution(s) for industry and citizens alike. A transparent communication of UVAR Access restrictions do not necessarily change customer behaviour, nor do they lead to better and more efficient transport. It remains crucial to ensure a smooth cargo flow into and out of the city so that customers can still be supplied efficiently. Any city access regulation needs to be preceded by a thorough impact assessment of traffic and goods volumes entering and leaving the city. Any further measures should be discussed and coordinated with all relevant stakeholders to avoid disruptions in the city supply chain. Route optimisation schemes, including measures such as the use of bus lanes by express companies, increasing the number of loading zones to compensate for scarce parking opportunities which lead to additional traffic, should always be prioritized over restricting policies. EU level guidance to local, regional and national authorities on access issues should focus on stakeholder engagement, foster cooperation and concentrate on best-practices.
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Response to Revision of the Directive on Driving Licences

21 May 2021

The European Express Association welcomes the opportunity to comment on the Inception Impact Assessment on the Revision of the Directive on driving licenses. We are particularly encouraged to see that the recognition of digital driving licenses across the EU is listed as one of the specific objectives of the revision. An EU framework for digital driving licenses that harmonizes and streamlines the process of applying/renewing licences would benefit all operators, most of whom are operating in more than one EU MS. Digitalisation, not only of driver licenses but also of other freight documents in B2A, would also benefit control agencies. In support of the stated policy objectives 2 and 4, such an EU harmonised approach should also allow driver training at the age of 17 years, accompanied by an experienced driver trainer. This would allow the instream of young drivers to start earlier and ensure that 18 year-olds are ready to obtain the professional driver license at the age of 18 years across the EU. Starting earlier decreases the risk of accidents, if one learns to drive with an experienced driver, and would help young drivers access the profession. In order to address the environmental objectives of the revision, the EEA supports an EU harmonised increase in maximum vehicle weights for B-license, both for alternatively fuelled vehicles as well as commercial vehicles. It is vital that this is applied in all EU Member States: • Whilst the Driver License Directive allows for holders of a B-license to drive alternatively fuelled vehicles up to 4.25t due to the excess of mass of the propulsion system, it is not mandatory for EU Member States to implement this provision – leading to fragmentation of the market and administrative burden for the industry to roll out their alternatively fuelled fleet of vehicles and support the EU’s climate goals. It would also speed up market uptake of alternatively fuelled vehicles. • In addition, commercial vehicles up to 5.5 t should be allowed to be driven by holders of a B-license if they are built on the same chassis with similar fundamental braking and suspension systems as used on the 3.5 t variant counterparts, ensuring similar driving characteristics in overall control of the vehicle. Allowing this limited flexibility in B-license, with safety a priority, will contribute to anticipating driver shortage issues and reduce the number of vehicle movements (given the slightly higher load). The EEA therefore supports mandatory implementation of these measures. Furthermore, there is a need to ensure coherence in this regard between EU and national legislations.
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Response to EU Single Window environment for customs

5 Jan 2021

The European Express Association (EEA) welcomes the opportunity to submit its feedback on the European Commission proposal on the Single Window Environment for Customs. The full text of the EEA’s contribution can be found in the document attached.
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Response to Sustainable and Smart Mobility Strategy

6 Aug 2020

EEA response to the Communication from the Commission on the EU Strategy for a Sustainable and Smart Mobility As an industry which makes considerable investments in its air cargo and road freight networks, hubs and stations, the EEA favours policies focused on incentivizing and developing market-driven solutions, rather than increasing the fiscal and regulatory pressure on operators. The EU’s approach should be subject to impact and feasibility assessments, taking into account the availability of necessary infrastructure and technological developments. This should be supported by targeted research and development programs, addressing specific objectives (e.g. alternative fuels, sustainable power generation, long-term technologies for aviation such as hydrogen and electrical engines, etc.). Air Cargo Sustainable Aviation Fuels The aviation industry is committed to limiting and further reducing its emissions—and Sustainable Aviation Fuels (SAF) have the potential for the biggest reductions in GHG emissions in the aviation sector; alternative propulsion options are not available in the short- or medium term. To achieve more significant reduction in emissions via the development of SAF (in all its forms including power based options), it is crucial for the EU to focus on the following key elements: • Develop incentives to boost the supply of all types of SAFs • Actively promote both European and wider global development of suitable raw materials for SAF • Prioritize sustainable fuel production for aviation over other industries for which suitable alternative options are available In addition to an EU policy focus on boosting the supply for SAFs that follow the highest sustainability standards, it will remain important for the industry’s decarbonisation to implement infrastructure and operational measures at the ground and in the sky (SES) to increase efficiency, and to support other technological advancements (such as new aircraft technologies) while applying market-based measures without distorting competition and without creating a double burden. To the contrary, aviation taxes or a potential kerosene tax would only limit the ability of operators to invest in newer, cleaner and quieter aircraft and technology such as SAF, thereby delaying the associated environmental benefits. Road Transport Decarbonising road transport Road transport is a key component of express operations’ (multimodal transport, and last mile delivery). The COVID-19 crisis has shown the importance of keeping transport flows moving to ensure the continuous circulation of goods and the proper functioning of the Single Market. To support industry in continuously increasing the sustainability of road transport operations – whether international and domestic linehaul or city logistics -, the following policy objectives should be pursued: • Building high-capacity electricity infrastructures • Introducing CO2 performance standards for all types of trucks and trailers • Providing dedicated funding schemes, also for users, for low and zero emission vehicles • Incentivizing rapid fleet renewal through long term funding programs and price incentives • Setting the right regulatory framework for the swift deployment of innovative solutions, e.g. platooning and ecocombis • Considering the objectives under the EU Green Deal, and subsequently deleting the return home of the vehicle provision from the new Driving and Resting Time Regulation • Supporting the adoption of a new Eurovignette Directive that brings harmonization and interoperability in charging schemes throughout the EU and leads to effective greening of fleets. Alternative mechanisms, such as EU ETS for Road, would only lead to double taxation and cumbersome complications of a system unfit for road freight.
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Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

23 Jul 2020 · EU-UK future trade relations

Response to Mid-term evaluation of the Union Customs Code

17 Jul 2020

The European Express Association (EEA) welcomes the opportunity to comment on the Commission’s Evaluation Roadmap. We greatly appreciate the consideration given to economic operators and EU citizens as part of this exercise. As in any project, the post-implementation phase is crucial to acknowledge the ‘lessons learned’ but also to steer the focus in the areas where it is really needed. The express industry, as one of the major trade sectors being impacted by the implementation of the UCC Package, would like to ask the Commission to view the EEA as an asset and a resource at its disposal. In this sense, we also take this opportunity to confirm our interest to become part of the Project Group mentioned in the Roadmap. Furthermore, under Section B (Data Collection and Methodology) a list of documents is provided as an example to showcase where the information will be collected. As the EEA has submitted observations to some of the documents in the past, these do not necessarily reflect the comments made by trade (i.e. European Court of Auditors’ Special Reports or Customs Action Plan). For that reason, we would like to know whether the input provided by trade during this evaluation exercise will be taken into consideration on an equal basis. In addition, we would like to propose some principles that should be incorporated in the strategy for the evaluation of the UCC Package: - Greater attention should be devoted to assess if the changes completed by the implementation of the UCC Package have resulted in a positive impact on trade facilitation. - Explicit acknowledgement of the complexity that the implementation of the UCC Work Programme has brought to economic operators. While we understand the existence of diverse deployment windows, the EEA believes this is a good opportunity to reflect on how trade is being impacted due to variation of data sets, diverse approach by MS, availability of information and overall transparency. The EEA would urge to look beyond what is reflected in the Annual Report as well as in the Consolidation of National Plans. - Explicit consideration of external factors, such as COVID-19 or Brexit that have a direct influence on the implementation of the UCC Package by Member States and operators. - Include as part of the evaluation factors the technical assistance provided by the Commission to key EU partners / third countries to understand the regulatory changes. - Assess the effectiveness of the EU’s communication strategy with respect to the UCC implementation, including to customs administrations, trade and consumers. We appreciate the huge commitment the Commission has shown in the last few years in regards to the implementation of the UCC. The EEA looks forward to providing further input in the next consultation phase.
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Response to Action Plan on the Customs Union

21 Apr 2020

Please find in separate file attached the main feedback submission from the European Express Association (EEA).
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

The European Express Association (EEA) welcomes the opportunity to comment on the Commission’s inception impact assessment on the Carbon Border Adjustment Mechanism (“CBAM”). The EEA agrees with the Commission that it is important to assess the impact of different options and supports the Commission’s climate change objectives. EEA members are taking initiatives to minimize their environmental footprint especially via the modernization of their aircraft and ground vehicles, and use of innovative technologies such as sustainable aviation fuels. The Commission’s proposed inception impact assessment raises many important points to be considered, including the likely economic impact and the likely impact on simplification and/or administrative burden. While the EEA understands the complexity of such a mechanism, we would like to stress that whatever form the CBAM takes, it must strive to avoid the potential for cascading barriers to trade. In this regard, the EEA would like to suggest the following points to be considered and added to the impact assessment: 1. Depending on the policy instrument, a CBAM could generate additional and cumbersome processes at the border, potentially leading to impact on operators (such as EEA members) supporting global supply chains of companies and taking care of customs’ processes and declarations. This would trigger more complexity and less transparency for EU customers and importers. To ensure a more simple and transparent process, calculation and/or collection of the CBAM should occur at the time of sales, not at the border. We would like to suggest including avoidance of the potential impact on border processes and operators in the impact analysis. 2. Under “likely impact on simplification and/or administrative burden” and “likely economic impacts”, the potential impact on SMEs should also be analyzed in the impact assessment.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

25 Feb 2020 · Rail and road transport topics

Response to 2019 Amendment to the Union Customs Code Delegated Act and Transitional Delegated Act

24 Feb 2020

European Express Association (EEA) members are pleased with the involvement of trade representatives at the various stages of discussion of the changes proposed. Nevertheless, as expressed in all meetings held so far, the EEA members have serious concerns with the provision of Article 143a(3)as it will create even more uncertainties and burden for economic operators to prepare for the new changes as from 1 January 2021. The process as such is already complicated enough and with so many still open questions that allowing Member States to use forms of customs declarations other than H7 will put us in a situation where we might not be ready with the various solutions in different MS. Therefore, as already said in previous meetings, we would at least ask for a wording in this new provision which will encourage MS to use data sets/forms of customs declarations with data as close as possible to the data set in H7.
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Response to Appropriate monitoring, reporting and verification for a global scheme for aviation emissions

17 Dec 2018

The European Express Association (EEA) welcomes the opportunity given by the Commission to comment on the draft delegated act to establish regulatory requirements for European operators under CORSIA. However, the EEA is concerned that the proposal merely extends the scope of the EU MRV requirements beyond intra-EU flights, rather than implement the MRV requirements for CORSIA in Annex 16, Volume IV. While the EEA expects the two other delegated acts to remove some of the differences between the EU ETS and CORSIA MRV requirements, the lack of full uniformity between the ETS and CORSIA requirements will risk undermining the environmental integrity of CORSIA. The Commission takes a different approach to how data gaps should be filled (by surrogate data, rather than CERT data), and risks that batches of sustainable biofuels are counted double under both the ETS and CORSIA. Moreover, it unduly restricts the number of fuel monitoring methods from five to two. The discrepancy also leads to market distortions. By making emissions reporting for flights between two non-EU countries voluntary, and by not including non-EU domestic flights, against CORSIA guidelines, emissions could be underestimated, which ultimately distorts the 2021 baseline scenario. Moreover, by opting for a divergence from the CORSIA requirements, the proposal could incentivise other ICAO states to do the same, further damaging the integrity of CORSIA. Ultimately, a wavering commitment from the EU to CORSIA would negatively affect the credibility of the first-ever global scheme to reduce aviation emissions and risks the participation of other ICAO States, including those with major air transport markets. The EU needs to show its intent to fully participate in CORSIA in order to generate momentum on a successful implementation. As the EEA has consistently argued in the past, any overlapping, separate or conflicting obligations between ETS and CORSIA should be avoided at all costs. Moreover, it expects CORSIA to eventually replace the EU ETS. Since operators (and States) will need to put in place (and test) the procedures necessary to comply with CORSIA long before its actual introduction, it is our firm view that the existing intra-EU ETS should be terminated well before CORSIA comes into effect. Such action would not only be consistent with the principles proposed for inclusion in the ICAO Resolution but would also end the existing discriminatory situation in which operators of intra-EU services are unduly penalised. Such action would also provide business and investment certainty for operators. In a more longer-term perspective, the proposal as such seems to suggest that the Commission, rather than replacing the EU ETS by CORSIA, seeks to selectively implement CORSIA provisions through the EU ETS, by extending the scope of the latter. This situation, for the aforementioned reasons, is not acceptable to the EEA. Lastly, the EEA regrets the fact that the Commission has waited until the very last moment to present this proposal, which effectively puts stakeholders in a situation of “take it or leave it”. Sound policymaking, particularly in this important piece of legislation that will, to a large degree, determine the credibility of the first-ever global market-based mechanism to reduce emissions from aviation activities, requires due consideration and deliberation, for which there is now very little time.
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Meeting with Silvio Mascagna (Cabinet of Commissioner Julian King)

8 Feb 2017 · Transport security

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

14 Jun 2016 · Aviation

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

23 Mar 2015 · Union Customs Code

Meeting with Antoine Kasel (Cabinet of President Jean-Claude Juncker)

6 Mar 2015 · Tax issues

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

6 Mar 2015 · Customs issues

Meeting with Lee Foulger (Cabinet of Vice-President Valdis Dombrovskis)

19 Feb 2015 · Union customs code

Meeting with Marjeta Jager (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

12 Feb 2015 · European Express Association

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

11 Feb 2015 · Parcel delivery

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)

5 Feb 2015 · TTIP Trade Facilitation Chapter and Developments of Union Customs Code

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

2 Feb 2015 · Customs Policy

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

18 Dec 2014 · Union Customs Code - implementing and delegated acts

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen) and Prime Collateralised Securities (PCS) UK Limited

9 Dec 2014 · Securitisation

Meeting with Valérie Herzberg (Cabinet of Vice-President Jyrki Katainen) and Assogestioni - Italian Investment Management Association

3 Dec 2014 · Capital Markets Union