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Finnish Freight Forwarding and Logistics Association - Suomen Huolinta- ja Logistiikkaliitto

FIFFLA

The purpose of the Association is to improve conditions for members operating in Finland in the freight forwarding and logistics service business and to increase recognition and appreciation of the industry.

Lobbying Activity

Response to Evaluation of the Consortia Block Exemption Regulation

3 Oct 2022

Finnish Freight Forwarding and Logistics Association (FIFFLA) joins the positions expressed by several European and global forwarding and transport organizations such as CLECAT, FIATA etc. FIFFLA is calling for a change of the legislative framework in which the container shipping lines are able to cooperate and therefore not for an extension of the Consortia Block Exemption Regulation (CBER). The conduct of carriers during the pandemic, in particular the drastic deterioration of services and unprecedented price increases have demonstrated that the CBER no longer plays the role of providing moderation and stability, for which it was designed. The benefits of the exemptions from general competition law enjoyed by the shipping lines are not being shared fairly between the lines and the rest of the economy, and this in itself constitutes a compelling reason why the CBER should be reviewed urgently. Also in our view the exemptions are defined too loosely and are unbounded. The regulation does not seem to be able to accommodate major changes in this market over the past few years, like vertical integration. The exemptions allow shipping lines which have acquired other supply chain functions, like freight forwarding, to exchange information on issues that do not relate to maritime transport. There are no limits placed on the exchange of information between carriers that are now vertically integrated. Information leakage into forwarding and inland distribution functions seems possible and inevitable. All in all, the CBER is no longer fit-for-purpose due to market developments such as an increase of rates, a poor level of services, consolidation of carriers, vertical integration and the amounts of data being shared without supervision. This leads to the conclusion that the CBER is no longer effective, efficient, coherent or relevant nor it brings EU added value. FIFFLA calls on the European Commission not to renew the CBER. FIFFLA also calls the Commission to signal the ending of these special privileges and an eventual return to normal conditions of competition for the liner shipping industry. The CBER should be replaced by sector-specific guidelines to ensure that all stakeholders have legal clarity on the parameters of the future regime.
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