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Nordic Logistics Association

NLA

The Nordic Logistics Association represents Danish, Norwegian, Swedish and Finnish road transport companies in Brussels, promoting their interests in EU transport policy decisions.

Lobbying Activity

Meeting with Tomas Tobé (Member of the European Parliament)

8 Dec 2025 · Transport Policy

Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

3 Dec 2025 · Current issues in transport

Response to Delegated Regulation on effective and secure access to On-Board Diagnostic and Repair and Maintenance Information

2 Dec 2025

On behalf of the Nordic Logistics Association, please find attached the feedback to the consultation on effective and secure access to on-board diagnostic and repair & maintenance information (delegated act).
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

18 Nov 2025 · Transport

Meeting with Jean-Louis Colson (Head of Unit Mobility and Transport)

28 Oct 2025 · (1) Weights & Dimensions (WDD) revision; (2) Implementation & enforcement of Mobility Package I, (3) Military mobility, (4) Clean Corporate Fleets

Nordic Logistics Association urges higher weight limits for electric vans

10 Oct 2025
Topic — This consultation reviews CO2 emission standards for new passenger cars and vans.
Message — NLA requests raising the weight limit for electric vans to 4,250 kg. They want these vehicles exempt from truck rules to maintain loading capacity. A testing environment should evaluate how weight changes affect road safety.123
Why — This would reduce administrative costs and improve efficiency for road transport companies.45
Impact — The public could face higher risks if heavier vehicles compromise road safety.6
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Nordic hauliers reject mandatory zero-emission vehicle purchase targets

8 Sept 2025
Topic — EU initiative to increase zero-emission vehicle registrations within corporate and commercial fleets.
Message — The association strongly opposes mandatory purchasing requirements for electric trucks. Instead, they want the EU to provide better charging infrastructure and tax breaks. They also ask for higher weight limits for electric vans to maintain loading capacity.123
Why — This prevents companies from being forced to buy expensive trucks that are not operationally viable.4
Impact — The general public faces potential road safety risks from heavier electric vans operating under lighter regulations.5
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Response to Detailed specifications regarding functional requirements for eFTI platforms

3 Jul 2025

Please find attached our comments to the eFTI consultation on behalf of the Nordic Logistics Association.
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

22 May 2025 · Transport issues

Meeting with Stine Bosse (Member of the European Parliament)

22 May 2025 · Sustainable transport policy

Meeting with Stanislav Stoyanov (Member of the European Parliament, Shadow rapporteur)

19 Mar 2025 · Animal transport regulation

Meeting with Valérie Deloge (Member of the European Parliament, Shadow rapporteur)

19 Mar 2025 · Transport des animaux

Meeting with Benoit Cassart (Member of the European Parliament, Shadow rapporteur)

7 Mar 2025 · Transport des animaux

Meeting with Thomas Waitz (Member of the European Parliament, Shadow rapporteur)

6 Mar 2025 · Animal welfare during transport

Meeting with Tomas Tobé (Member of the European Parliament)

4 Mar 2025 · Transport Policy

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and Bundesverband Güterkraftverkehr Logistik und Entsorgung (BGL) e.V. and

4 Mar 2025 · Debate the challenges of road freight policy

Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur)

19 Feb 2025 · Animal Transport

Meeting with Tomas Tobé (Member of the European Parliament)

5 Dec 2024 · Transport Policy

Meeting with Asger Christensen (Member of the European Parliament) and Landbrug Fødevarer - Danish Agriculture and Food Council and

4 Nov 2024 · Animal Transport

Meeting with Tomas Tobé (Member of the European Parliament)

15 Oct 2024 · Transport Policy

Meeting with Anders Vistisen (Member of the European Parliament)

15 Oct 2024 · Logistics

Meeting with Asger Christensen (Member of the European Parliament)

1 Oct 2024 · Transport

Meeting with Johan Danielsson (Member of the European Parliament)

1 Oct 2024 · Efterlevnad av vägpaketet

Meeting with Kristoffer Storm (Member of the European Parliament)

1 Oct 2024 · Transportation

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur)

10 Jul 2024 · Weights and Dimensions

Nordic hauliers urge shifting animal fitness liability to keepers

13 Mar 2024
Topic — The European Commission is revising regulations regarding animal welfare during commercial transport journeys.
Message — They want to limit liability to the transport leg and shift fitness assessments to keepers. They argue that space requirements need further impact assessment due to environmental concerns.123
Why — Shifting liability protects drivers from being unfairly penalized for pre-existing animal health issues.4
Impact — The environment loses as increased space requirements necessitate more trucks, raising emissions per animal.5
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Meeting with Asger Christensen (Member of the European Parliament) and Landbrug Fødevarer - Danish Agriculture and Food Council and

8 Dec 2023 · Agriculture/Transport

Meeting with Marianne Vind (Member of the European Parliament)

25 Oct 2023 · Transport

Meeting with Marianne Vind (Member of the European Parliament, Rapporteur for opinion)

16 Nov 2022 · Platform

Response to Type approval of motor vehicles regarding access to in-vehicle generated data

20 Jul 2022

On behalf of the Nordic Logistics Association, please find attached our feedback to the call for evidence on the upcoming initiative on access to vehicle data, functions and resources.
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Meeting with Marianne Vind (Member of the European Parliament, Rapporteur for opinion)

11 May 2022 · Platform

Meeting with Jytte Guteland (Member of the European Parliament) and European Heat Pump Association and Norsk Hydro

28 Apr 2022 · ETS revision

Meeting with Jytte Guteland (Member of the European Parliament)

13 Apr 2022 · ETS Revision

Meeting with Nils Torvalds (Member of the European Parliament)

15 Mar 2022 · Fit for 55

Response to Evaluation and revision of the Weights and Dimensions Directive

18 Feb 2022

Consultation response in attached file.
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Meeting with Asger Christensen (Member of the European Parliament)

29 Jan 2022 · Dyrtransport ANIT

Response to Revision of the Energy Tax Directive

17 Nov 2021

NLA welcomes the objective for more uniform taxation for EU Member States, industries and energy products, to ensure a level playing field, including across competing modes of transport in the freight transport sector. The vast majority of heavy duty vehicles involved in goods transport are diesel driven today. And the production of electrified heavy duty vehicles is not expected to lead to a broad and competitive offer of vehicles in the coming decade. This means that the many millions of trucks running on combustion engines will still rely on liquid fuels in the short and medium term. It is thus important that the ETD gives incentives for biofuels, biogas and other low carbon based solutions. Tank tourism: The importance of uniform rates is not least important to avoid so-called tank tourism within the EU. This element should also be taken into consideration when looking at the impact of the new proposal on the competitive level playing field with companies established in third countries. Third country transport operators could be used for EU transports; their vehicles could enter the EU with larger tanks containing cheaper motor fuel. Double/triple taxation: It is crucial that the ETD proposal is looked at in conjunction with the ETS proposal where the road transport sector will be included in the Emission Trading System in a parallel system. We see a significant overlap between these two proposals, which risks resulting in double taxation. NLA believe that the Commission’s justification for choosing option 2 over option 3 in the ETS proposal fails to recognise that the ETS proposal is in essence a CO2 tax. It is argued that option 2 is based on environmental performance and energy content. We find this conclusion too simplistic as it fails to recognise that option two is in essence a CO2 tax. To this end we note that the Impact Assessment of the ETS proposal states the following in part 2/4 page 138: ”Energy taxation and ETS coverage highly overlap, as they both provide a price incentive to consumers to reduce the CO2 impact of their mobility behaviour” In addition, we recall that the Eurovignette proposal is expected to be adopted soon adding a new layers of costs to road transport operators. It is therefore crucial that the impact of these proposals is looked at together in order to avoid penalising the road transport sector excessively.
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Response to Revision of Alternative Fuels Infrastructure Directive

17 Nov 2021

NLA welcomes the aim of the AFIR proposal to spread out infrastructure for alternative fuels in Europe by setting binding minimum targets and changing the Directive to a Regulation. This is an important step in enabling the green transition of the transport sector. We note that the minimum requirements covering the TEN-T network is a starting point. It should then be up to the market and EU Member States to ensure further roll out of green infrastructure. Overall, it is important for hauliers and our members that new green alternatives such as hydrogen and charging facilities for electrified heavy-duty vehicles are made available at competitive prices, and that a technology neutral approach is taken where transport operators can also choose between other low carbon based fuel options. Not least since we do not know today, which will be the alternative fuels that will be used in the future, and therefore the Regulation should include some degree of flexibility. It must therefore also be possible to rely on low carbon based options, such as biofuels and electrofuels, for combustions engines in the coming decades. Such fuels can still play an important role in bringing down emissions. Not least since we do not know when or to what degree electrified heavy duty vehicles will become the dominant solution in the future. Moreover, it will take time before electrified heavy duty vehicles become available at competitive prices with the infrastructure needed to support long haul goods transport. To this end we note that in many cases renewable liquid and gaseous fuels, such as biogas can use the same infrastructure as fossil fuels, and also play a role in reducing emissions in the short and medium term. However, in some cases some degree of adaptation of the infrastructure is needed, for example in the case of alcohol-based fuels such as ED95. This is regrettably not addressed in the AFIR proposal. It is important to ensure that infrastructure for liquified fossil free fuels and biogas remains in place, even as the number of combustion engine driven trucks are expected to decrease in coming decades, so we still have supply for those vehicles that will not be electrified by 2030 and beyond. Charging facilities: NLA believes that the most important element is to ensure availability and flexibility for hauliers to choose between alternative charging points. It is thus important to avoid that drivers end up queuing and spending lots of waiting time before being able to charge. A possible way to avoid this would be by looking into information systems that show the capacity and availability at the separate charging stations. Another option is to encourage a standardised booking system, whereby a driver can book charging facilities in advance. Without this hindering availability for ‘drop-in’ to charge heavy duty vehicles.
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Response to Revision of the Roadworthiness Package

1 Nov 2021

The Nordic Logistics Association (NLA) representing approximately 16.000 hauliers from the Swedish Association for Road Transport Companies (SÅ), the Danish Transport and Logistics Association (DTL), the Norwegian Road Transport Association (NLF) and its associated member Finnish Transport and Logistics (SKAL) is pleased to give its feedback to the roadmap on the revision of the Directives of the Roadworthiness Package. NLA welcomes the revision to improve road safety, make mobility more sustainable and smarter, and to simplify the free movement of goods in the Union. NLA fully agrees with the difficulties in enforcing road safety measures in EU cross-border traffic and vehicle trade and believes that sharing vehicle register data and other safety-relevant information of vehicles between Member States is key to make the enforcement of road safety measures more efficient. By sharing relevant data between authorities, double and even triple checks can be avoided, and resources can be put where they are needed. Concerning the revision of Directive 2014/45/EC on the periodic roadworthiness tests for motor vehicles NLA wants to highlight the importance of having a consistent way of testing across the Union, to the highest possible extent. Coherence in testing ensures that the vehicle safety is high across the Union. Concerning the revision of Directive 2014/47/EC on the technical roadside inspections of commercial vehicles, NLA wants to highlight the importance of electronic data exchange and storage as well as granting cross-border access to RSI authorities. This will prevent drivers who have already undertaken a successful roadside inspection from being checked again when crossing borders. It will also make it more efficient for the RSI-authorities since they will know which vehicles that are newly inspected in other Member states. Concerning the revision of Directive 1999/37/EC as amended by Directive 2014/46/EC, the set up of electronic tools and platforms must ensure that it becomes easier to inspect vehicles. Since the inspection of vehicles today needs special competence, digital tools should make the inspection easier so the inspection can be carried out without special competence being needed. Through electronic tools and platforms, inspection should also become faster so that valuable time is not misused for the carrier. This will also mean that more inspections can be carried out.
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Response to Revision of Combined Transport Directive

16 Sept 2021

NLA agrees that a multimodal approach is important in the transition towards greener mobility and eventually zero-emission mobility. However, we strongly contest that this transition can only happen by shifting goods from road to rail and inland waterways. It is too simplistic to assume that shifting goods from road to rail and inland waterways will automatically result in an immediate lowering of CO2 emissions. Instead, we encourage the EU-legislator to take a more holistic look at how all modes in Europe can lower their emissions, be it road, rail or inland waterways, and to this end we fully welcome the Fit for 55 Package. We also want to reiterate that the infrastructure in Europe does not necessarily support a modal shift, in particular when it comes to rail. There is limited capacity on European rail networks, and the goods transports on these networks, have to share the space with passenger rail transport. It is thus a much less flexible transport mode that often requires that goods are reloaded and transported by truck for parts of the transport distance due to lack of interoperability. This leads to an increase in costs and transport time and increase the likelihood of damages to the goods. Road transport and heavy duty vehicles are set to become greener and reduce emissions with time. The Fit for 55 package will be an important step in this direction, and NLA fully support the objectives behind this package. We thus therefore encourage legislators to focus on modal cooperation rather than modal shift in the coming decades. Congestion: The inception impact assessment focus on the need to battle congestion, and it is understood that the modal shift will play a role in this regard. However, there is a general misconception that congestion can be associated to road transport, as this approach fails to recognise that passenger cars take up the vast majority of space on roads in Europe. Again, we wish to promote modal cooperation and an overall aim to reduce emission in all different transport modes. Economic impacts: It is important that the revision of the Combined Transport Directive does not undermine Mobility Package 1, and the measures to fight social dumping practices. It is thus important that the revised Directive does not open up for using low cost labour from one EU country to carry out the road leg of a combined transport in another EU/EEA country. Environmental societal impact: It is important to look at how the energy used for the different transport modes is produced. We cannot automatically assume that rail or waterways is greener per se, without a closer life cycle analysis having been carried out on the source of the energy. Again, we believe a holistic approach is needed, and the Fit for 55 package is a good example of how we can reduce emissions across industry sectors and transport modes, without singling out one mode. To this end we also recall the societal impact that road transport has played during the covid-19 pandemic in ensuring that goods and essential product have reached citizens and companies across the European continent in a time of need.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

NLA welcomes the opportunity to provide feedback to the first delegated acts to be issued under the Taxonomy Regulation 2020/852. We fully support the European Commission’s aim to promote green financing to meet the EU’s climate and energy targets. It is essential to incentivise industry and Member States in the EU to make green investments that will bring down emissions across industry sectors. This is not least the case for the transport sector where lots needs to be done, to give operators a real incentive and possibility to choose the greener solutions. Today there is not a viable business case for a haulier to invest in green alternatives, such as electric or hydrogen driven trucks. Electrification of heavy duty vehicles is only at a very early stage and therefore the role of low carbon fuels needs to be recognised such as e.g. sustainable biofuels and Power-to-X. This we believe must also be reflected in the delegated act and in the taxonomy deciding what technologies should be classified as eligible for financing, as the green transition will not happen overnight. We therefore believe it is important to also recognise alternatives to zero emission technologies in the short and medium term, since low carbon fuels will continue to play a role, while we strive for a broad rollout of electrified, hydrogen and other such technologies. In this regard we note that the technical screening criteria in the draft delegated act for infrastructure enabling low-carbon road transport (point 6.15 of annex 1) specifies that such infrastructure must be “dedicated to the operation of vehicles with zero tailpipe CO2 emissions: electric charging points, electricity grid connection upgrades, hydrogen fuelling stations or electric road systems (ERS)”. While these are important elements that certainly need financial support we also recall that other low-carbon alternatives will play a role such as sustainable biofuels and Power-to-X fuels (such as but not limited to hydrogen). On biofuels we moreover recall that they provide important climate benefits compared to fossil fuels and that they are relevant complements to electrification and hydrogen. Moreover, biofuels can be produced in a sustainable way in accordance with the sustainability criteria in the Renewable Energy Directive 2018/2001.
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Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

Nordic Logistics Association (NLA) represents around 17.000 road transport operators and companies in the Nordic countries. NLA welcomes a revision of the CO2 emissions performance standards for cars and vans in line with the revised 2030 climate target. Measures to reach 2030 targets and measures in revision of CO2 emissions performance standards shall be based on best result in cost/benefit analyses for society. EU action is imperative as the reduction of global emissions require actions beyond national policies. Standards and norms have proven to be effective when applied in the right way. The spectacular results on other emissions from the application of the EURO-norms prove the point. However, unrealistic standards risk expecting more from the manufacturers than is possible or put financial burdens on road transport operators by making them pay a significant part of the costs. Setting high levels in the standards will come with significant economic costs. Financial incentives to promote the uptake of new technology in the market is therefore crucial. In order to incentivise and increase the use of low and zero-emission commercial vans, their usage must be made economically sound in the long-term. Financing should be ensured to assist in the gradual and realistic increase of low emission vehicles. We believe that the development of standards based on the vehicle details must take a broad approach by e.g. also taking into account reductions achieved via use of sustainable biofuels or other alternative fuels such as biogas, LBG or hydrogen. And electrification of road transport needs to be taken into account. Moreover, NLA believes that applying the CO2 emission standards in synergy with a comprehensive EU-wide infrastructure for alternative fuels, including electrification, is crucial to encourage demand for low and zero-emission commercial vans. The road transport sector needs economic support to make the green transition a just transition. It is thus essential that the spread out of alternative fuels is supported and that the infrastructure to secure broad deployment is made available. As highlighted in this note, a green road transport sector is not achieved by the vehicles alone, but also by the roll out of green infrastructure and by ensuring that several technologies and types of green fuels can help to bring down emissions.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

The Nordic Logistics Association (NLA) represents around 17.000 road transport operators and companies in the Nordic countries. NLA welcomes the green transition and is keen to be a constructive part of the climate solution. To this end, it is crucial with measures to support decarbonisation of road freight. Important measures have already been put in place and will be supported in the upcoming Sustainable and Smart Mobility Strategy and the new EU Climate Plan. This goes especially for measures set out in the European Commission Work Programme for 2021, such as the Energy Taxation Directive, and the Alternative Fuels Infrastructure Directive, that in addition to the Next Generation EU fund, will be vital in facilitating the green transition. Reiterating the important aim to reduce emissions from road transport, NLA does not believe that absorbing the road transport sector in the ETS is the right measure to achieve this policy objective. As the Incept Impact Assessment rightfully points out, any expansion of the ETS must act in synergy with other EU and national policies. The transport sector is already subject to taxation thus, given that the additional costs per tonne from the ETS is lower than national tax rates, ETS will not incentivise any further cut of emissions. Moreover, double taxation would unfairly hurt the transport operators, especially as the majority of operators in the Nordics are Small to Medium Size Enterprises (SMEs). To obtain the policy objective, focus should instead be given to measures that are more fitted to permanently reduce and remove emissions. The deployment of alternative fuels infrastructure and financial support to scale up the use of zero to low emission vehicles (LZEV) are examples of such measures where EU action is essential. Moreover, High Capacity Vehicles (HCV) is an efficient way to decarbonise transport, which must be considered. Increasing the weights and dimensions for heavy duty road freight vehicles within EU will bring down fuel consumption and reduce emissions per unit of cargo transported. In addition, expanding the ETS to road transport does not provide the necessary incentives for the sector to foster the green transition. In order to meet the goals of the European Green Deal, focus should be on reducing the costs for alternative fuels, ensuring deployment of green infrastructures and encourage the development and scale of LZEV. Hauliers need incentives that foster investments in LZEV and support those that need help to make the shift. Finally, involving road transport in the ETS might add an administrative burden on SME’s and self employed hauliers. Such hauliers, which make up a significant majority of road hauliers in the Nordic region alone, do not have the means to pay for, trade and administer the ETS. If expanded, the ETS should ensure an upstream system focusing on the providers of fossil fuels instead of vehicle owners. To conclude, NLA does not see that an expansion of the ETS is the right way forward to decarbonise the transport sector. Instead we see existing EU initiatives on the roll out of infrastructure and deployment of alternative fuels as the more relevant staring point. In practice, an expansion of the ETS to road transport will most likely result in an economically and socially unfair policy that does not provide the necessary gamechanger for carbon reduction in the road transport sector. Thus, NLA welcomes a thorough examination of the issue and encourages that the solutions and policies already at hand are prioritised.
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

NLA welcome the aim to provide more affordable, accessible, and cleaner transport alternatives to contribute to the EU goal of becoming climate neutral. NLA believe that the preparation of the EU Strategy for a Sustainable and Smart Mobility, and its accompanying legislative initiatives should be based on a cost/benefit approach analysing the climate impact of a vast palette of alternative measures to support decarbonisation of road freight such as: • High capacity vehicles/high capacity transport • Fossil free diesel fuel • Battery • LBG • Hydrogen • Electro mobility While we fully agree that a broad roll out of more sustainable fuels is needed in Europe to bring about the green transition, we also recall that the ambitions of the EU must be in line with the everyday realities that operators in the road freight sector are dealing with. Currently the majority of hauliers in the Nordics are made up of small or medium sized companies for whom investing in new trucks and vehicles represent a significant investment. Such investments need to be made with long term economic stability in mind. It is thus essential that the EC set out a roadmap of the technologies and measures that will be supported in the short and long term. Currently we lack economically feasible fuel alternatives for heavy-duty vehicles including long range transport and in many cases also short and medium range transport (e.g. different types of specialised transports, heavy construction transport and heavy transport in rural areas). Initiatives to put in place economic incentives as well as the infrastructure needed for roll out of new technologies in Europe are therefore very welcome. Moreover, we believe that it is not sufficient to simply define a “clean truck” according to the fuel used by the operator, be it hydrogen, battery-electric, natural gas or liquid biofuels. Such an approach does not take into account clean transport achieved through logistics, such as optimising payload, using longer and heavier trucks and using bio-fuels. A lifecycle analysis approach with the complete CO2 emission profile is therefore needed, from not only the energy efficiency of the vehicle, but also emissions from battery production and recycling and possible emission reduction benefits from different fuels. In addition, recognition for operators using smart and sustainable logistics solutions is needed. High capacity vehicles: The more goods and people we can transport with a single vehicle the better for the environment. Going to high capacity and longer trucks is the best and fastest way to reduce emissions. The EU should encourage national and cross-border use of high capacity vehicle combinations, especially, in the framework of multimodal and combined transport to further improve the efficiency of all transport modes. Modal cooperation rather than modal shift: All freight transport modes should be used to establish a resource-efficient and sustainable EU transport system. The significant and essential contribution made by the road freight sector during the covid-19 crisis has only further underlined the key societal role played by our sector. NLA thus therefore call strongly on the Commission to abandon the forced modal shift policy and to re-establish a co-modality approach at the heart of EU transport policy with the objective to increase the efficiency and capacity of every mode of freight transport. Driver shortage: Europe is facing the most acute driver shortage in decades. In 2019, the freight sector had a driver shortage of 23%. Action is thus needed to improve the image of the industry and attract a more diverse workforce. Skilling and re-skilling is an important aspect that needs necessary policy support. One of the most important steps to attract drivers and new companies to the road haulage industry will be the implementation of the Mobility Package giving a fair and level playing field for the road haulage companies and avoiding social dumping
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Response to Fitness Check of the EU legislation on animal welfare

29 Jul 2020

NLA welcomes the fitness check of the legislation on animal welfare as part of the Farm to Fork Strategy, in order to revise the rules, including the legislation on animal transport under regulation 1/2005. It is our view that animal welfare during transport is very important and that the rules on animal transport ought to rest on a common European legal and factual basis where the responsibility for animal welfare must be clearly and logically placed. To this end, it is necessary to point out that the current interpretation of the Regulation 1/2005 suffers from a lack of logic regarding the division of responsibility between the parties regarding the animals’ fitness for transport. Currently, the transporter bears a great deal of responsibility to make sure that the animals are fit for transport, even though the transporter have no previous information of the animals and only a limited opportunity to check on them during the short period of the loading phase. It is thus desirable that the revision of the regulation includes a clarification on the shared responsibility between the parties, which clearly sets out the responsibility of the transporter vis-à-vis the farmer. Specifically, the transporter should bear full responsibility for the loading and the unloading of the animals, in addition to the condition and legality of the vehicle, the correct training and instruction of the driver and the actual transport of the animals. Similarly, the farmer on account of his prior knowledge of the condition of the animals should be solely responsible for the animals being fit for transport before the transport begins. The responsibility for whether the animals may have existing or old injuries should be placed with him since he knows the history of the animals and has real opportunity to observe them. In order, to raise animal welfare in connection to transport it is crucial to have a division of responsibility where the party with the real capability to check on the animals before the transport is also charged with doing so. It is unreasonable and illogical that a driver of animal transports should bear the responsibility for the animals before they enter the transport, when he typically only observes them in a herd during the short time in which the loading takes place. The revised transport regulation should state clearly that it is the farmer, who has known the animals during the longest time-period and is the one deciding that they are fit to be transported, who should be solely responsible for their fitness prior to transport, possible along with a veterinarian who may have issued a transport fitness statement. Similarly, the transporter today bears responsibility to ensure gender sorting of livestock for the transport operation, unlike the sender of the animals who is not required to do so. This creates several undesirable challenges both for the transporter and not least for the well-being of the animals. Separating adult male and female animals is not always the best solution. An example of this is the transport of animals consisting of a breeding bull that already walks on the farm with a group of females. Separation of such animals can entail both serious safety risks for the driver involved and create unnecessary and dangerous tension for the animals. In such cases where animals are already used to each other, exemptions for separating the gender should be allowed. Today, the transporter risks being subject to heavy fines for injuries on the animals that are outside his power to control or prevent. Fines that can be detrimental for the business of hauliers and it is thus essential that the legislator reviews the current rules as early as possible. We thus encourage that Regulation 1/2005 is taken up for revision much earlier than Q2023, which is currently foreseen under the Farm to Fork Strategy. NLA looks forward to being included in the review and thanks for the opportunity to provide comments to the roadmap.
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Response to A EU hydrogen strategy

8 Jun 2020

The Nordic Logistics Association (NLA) is pleased to give its feedback to the roadmap on A EU Hydrogen Strategy. NLA welcome the EU commissions proposed road map on “A Hydrogen Strategy” and agree that there are some barriers to solve such as lack of production, infrastructure, high cost and low efficiency to address, and a need to look at the whole value chain in order to advance towards a hydrogen ecosystem at a scale that contributes to meet the 2030 and 2050 climate and energy goals in a timely and cost-effective way. NLA propose that work with the hydrogen strategy should include advice to decisionmakers based on analyses to address climate impact and cost/benefit by implementing different alternative measures to support decarbonisation of road freight such as: • high capacity vehicles/ high capacity transport • fossil free diesel fuel • battery • LBG • electric road We agree that clean hydrogen can potentially make a significant contribution to achieving climate neutrality in the long term. And while we fully agree that a broad roll out of more sustainable fuels is needed in Europe to bring about the green transition, we also recall that the ambitions of the EU must be in line with the everyday realities that operators in the road freight sector are dealing with. Currently the majority of hauliers in the Nordics are made up of small or medium sized companies for whom investing in new trucks and vehicles represent a significant investment. Such investments need to be made with long term economic stability in mind. To this end it is essential that the European Commission set out a clear roadmap of the technologies and measures that will be supported in the short and long term. As also stated in the roadmap there is currently a lack of economically feasible fuel alternatives for heavy-duty vehicles including long range transport. Initiatives to put in place economic incentives as well as putting in place the infrastructure needed for roll out of new technologies in Europe are therefore very welcome. Hydrogen holds a number of promising advantages. It can be refueled on vehicles as fast as gasoline and diesel, and hydrogen also gives a comparable range per refueling. The same productivity can thus be achieved with a hydrogen fueled vehicle compared to a combustion engine vehicle. Hydrogen is also very energy dense per. weight unit. However, hydrogen requires dedicated vehicles, which are currently significantly more expensive than conventional trucks. Moreover, a dedicated hydrogen tank infrastructure is currently lacking in Europe to be established. Lastly, the hydrogen itself is also currently more expensive than diesel. The major challenge for hydrogen is thus lack of infrastructure, lack of availability of hydrogen fueled vehicles that are at the same time are very costly. In that regard we take good note of the Commission’s intention to make hydrogen an important element in the effort to achieve climate neutrality in Europe. We also welcome the initiative to create a European Clean Hydrogen Alliance and recall that involving the end users in the discussions, i.e. the hauliers, will be vital in order to ensure feasible solutions for the road freight sector, and we look forward to being included in the discussions.
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

24 Apr 2020

The Nordic Logistics Association (NLA) representing approximately 17.000 hauliers from the Swedish Association of Road Transport Companies (SÅ), the Danish Transport and Logistics Association (DTL), the Norwegian Road Transport Association (NLF) and its associated member Finnish Transport and Logistics (SKAL) is pleased to submit its feedback to the roadmap on the Development of post-Euro 6/VI emission standards for cars, vans, lorries and buses. NLA and its members from the Nordic haulier associations are keen to make a positive contribution to reducing emissions of air pollutants in the transport sector. As the demand for freight transport in Europe is expected to grow substantially in the coming decades, it is essential to ensure EU policies that further incentivise the road transport sector to become a part of the solution in addressing the challenges created by climate change. Acknowledging the success of the Euro-norm strategy to combat air pollution, NLA also stress the importance of enforcement of the emission standards of the individual vehicles in operation. Importantly we should avoid too complicated technical solutions for reduction of regulated emissions. To this end it is key with reliable and durable equipment to avoid high maintenance costs and risk of non-compliance hampering fair competition. However, before introducing a new euro 7 standard, which focus both on reduced non-greenhouse gas emissions as well as local pollutants, it is important to closely analyse the solutions that are already at hand. To this end, NLA strongly advocate for EU-wide introduction of High Capacity Vehicles (HCV). Increasing the weights and dimensions for heavy duty road freight vehicles within the EU will bring down fuel consumption and reduce emissions per unit of cargo transported. In this regard it is important to underline that rather than focusing on fuels, the legislation should also focus on the relative emission levels for vehicles related to the work done, such as emissions in gram per tonnes*km. Noting in this regard that in gram per tonnes*km the use of energy and emissions of carbon dioxide can be up to 100 times more for small vehicles compared to HCV. We therefore encourage the Commission to take the following step by step approach: 1. Postpone approval of EURO 7 until step 2, 3, 4 and 5 are in place. Then analyse if Euro 7 is needed or will be obsolete. 2. Develop directive 96/53 EC to boost implementation of HCV in more Member States for more efficient road freight based on the modular concept. 3. Implement optimal use of all available capacity in existing road and bridge infrastructure by legal use of HCV for road freight including for cross border traffic. This means that permitted gross vehicle weight should be accepted to be different in different member states because available or possible maximum loading capacity in bridges and roads are different. Utilisation of possible capacity in infrastructure are a key measure to boost decarbonisation of road freight by use of more efficient HCV. 4. Develop the Energy Taxation Directive and State aid legislation to support implementation of fossil free fuel and energy technology for heavy duty road freight vehicles. Including development of battery and electric road technology for road freight. 5. Improve logistics by use of best practice and the most optimal road freight vehicles for each individual transport operation in terms of emissions in gram per tonnes*km. 6. Euro 7 may be obsolete and not needed any more. Cost benefit analysis from all stakeholders’ point of view shall be done prior to approval of EURO 7. Finally, of the different policy options laid out in the roadmap we would thus recommend policy option 1 opting for a narrow revision of Euro 6/VI.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

NLA and its members from the Nordic haulier associations are keen to make a positive contribution to bringing down the CO2 emissions of the transport sector. As the demand for freight transport in Europe is expected to grow substantially in the coming decades, it is essential to ensure EU policies that further incentivise the road transport sector to become a part of the solution in addressing the challenges created by climate change. Hauliers have already by their own accord taken significant steps to innovate and implement greener and more sustainable high-performance technologies and solutions. Examples are investments made into cleaner engines and introduction of High Capacity Vehicles (HCV), which have brought down fuel consumption and led to reductions in emissions per unit of cargo transported. The road haulage sector finds itself in a very competitive environment nationally within the Nordic countries and internationally. Fuel prices are thus an important factor for hauliers, and it is essential that new EU legislation gives hauliers a real incentive to choose greener solutions. Today fuel accounts for a significant part of a hauliers’ costs of road transport. And given that there is not a strong customer demand for a greener transport of goods the incentive to choose the more expensive greener fuels in a very competitive sector is today limited. Similarly, hauliers lack incentives to make green investments in e.g. fossil free trucks, as these are not competitive under the current price structure. Being locked into costly energy and fuels solutions can come at a very high price for hauliers. It is therefore imperative that the alternative and more sustainable green fuels are made economically attractive compared to traditional fossil fuels. Moreover, future climate policies should give hauliers a long-term perspective in order for them to make safe and secure investments while planning to replace existing fleets with new vehicles in the long term. The market for energy products for the transport sector has to be competitive and leave room for several green options to ensure that relevant technologies are brought into the mix, such as gas, hydrogen, electrofuels, biofuels and electrified mobility including batteries, and electric roads. It is important not to bind the market to one specific technology or fuel type. The revision of the Energy Taxation Directive provides an opportunity to address these issues. Decarbonization of road freight should also be further addressed, by revised state aid legislation to support biofuels, by revision of Directive 96/53/EC about weights and dimensions to support HCV, by revision of the Directive on road charging, and by improved logistics. Concretely the following measures can be considered in the upcoming review: • Overall, the tax burden on fuels should be based on the CO2 emissions. • The percent of fossil free carbon content should be increased in blended diesel used in heavy road freight vehicles step by step. Blended diesel and bio diesel can be used in existing and future diesel engine vehicles for road freight. The target of 100 percent bio diesel in due time should be set for EU member states. • To ensure broad uptake of low-carbon alternative technical solutions and fuels, their higher purchase price must be compensated by incentives to ensure rapid returns of investment. Different types of alternative technical solutions and fuels or energy for road freight should be addressed in cost/benefit analyses. Analyses should include but not be limited to performance on environment, safety, security, economy, durability and availability. • If the green transition is to be fully promoted, barriers needs to be removed, by e.g. investment and financial support for the implementation of low-carbon road freight vehicles. • Addressing the depreciation of existing vehicles by giving hauliers sound economic incentives to replace their fleet with low-carbon trucks.
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Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

22 Jan 2019 · Road transport issues

Meeting with Desiree Oen (Cabinet of Commissioner Violeta Bulc)

27 Jan 2015 · Logistics