OpenLobby.EU
Explore

UIRR, International Union for Road-Rail Combined Transport

UIRR

UIRR represents European road-rail combined transport operators who organize sustainable freight transport using containers, swap bodies and semi-trailers that transfer quickly between transport modes.

Lobbying Activity

Meeting with Valérie Hayer (Member of the European Parliament) and Amazon Europe Core SARL and

28 Jan 2026 · Politique commerciale de l'UE

Meeting with Jens Gieseke (Member of the European Parliament)

10 Nov 2025 · Austausch zu EU-Verkehrspolitik

Meeting with Eric Von Breska (Director Mobility and Transport)

21 Oct 2025 · Meeting with UIRR on TEN-T Regulation

UIRR urges intermodal rail priority in EU military mobility

30 Sept 2025
Topic — The proposal establishes a regulatory framework to harmonise national procedures for military movements.
Message — The organization requests that rail-road transfer terminals are identified and given priority funding. They also ask that transport operators be legally recognized as essential critical entities.123
Why — The sector would secure priority access to state aid and infrastructure investments.45
Impact — Non-designated transport facilities may face reduced access to limited state aid budgets.6
Read full response

Meeting with Sandro Santamato (Head of Unit Mobility and Transport)

5 Sept 2025 · UIRR input on the implementation of the Directive 2012/34/EU and military mobility

Response to EU harmonised specifications for rail freight wagons

27 May 2025

The International Union for Road-Rail combined transport (UIRR) is the industry association representing the interests of intermodal operators and freight terminals in Europe. The UIRR members have transported more than 4.5 million consignments in 2023, of which 15% are semi-trailers. They are also owners and/or keepers of more than 14,000 intermodal wagons, of which 30% are pocket wagons specifically designed to carry those semi-trailers. UIRR and its experts have continuously participated and contributed to the latest activities related to the revision of the TSI WAG to include new requirements on devices to secure semi-trailers, supported by a new technical document. UIRR disagrees with the fact that these new requirements are the result of a common consensus by the experts of the sector . UIRR has continuously raised its concerns and opposition regarding for example the retrofitting and the new markings . Before to speak about retrofitting, the backbone of documents and rules to be used for retroactivity shall be clarified. Without clarification, the scope of TSI WAG obliges all the parties to perform activities only following the TSI WAG. By considering the partial application of TSI WAG, no benefit about standardisation will be achieved, because the application is covering only some aspects. The results of the current ongoing work on the holistic methodology for the risk assessment of crosswind is absolutely crucial and shall be the starting point for any amendments to the TSI WAG. These results can lead to completely other requirements than those proposed. In order to make a serious declaration about design state following the TSI WAG, a calculation or testing following EN12663-2 shall be performed to quantify the strain state - a simple lifting of the wagon is not enough to demonstrate the fulfilment of TSI WAG, that has to be fulfilled under all possible condition in operation. The 85kN locking force requirements appear to be unsuitable for most of wagon series. A great number of wagons could consequently no longer be used. The key designers and manufacturers of pocket wagons have identified critical issues for implementation of retrofitting or exceptions to existing fleet of wagon, issue that may lead to much greater disruptions of traffic volumes of semi-trailers not only for Denmark, but also for overall Europe. UIRR is fully aware that with the climate change, the occurrences of more frequent and stronger crosswinds will not be limited to one country. However, UIRR strongly supports the idea that those occurrences should be managed locally with adequate mitigation measures for all. Currently, infrastructure managers and railway undertakings are adapting their local operational procedures in case of crosswinds. In this context, there is no need to transpose local issues into the European legal framework. Wagon keepers are used to manage their wagons with local restrictions. Under these circumstances, UIRR firmly disagrees with the application of the new requirements in the TSI WAG regarding the device to secure semitrailers and strongly recommends to further investigate the actual impacts of the proposed recommendations for new and old wagons in order to ensure that the competitiveness of the intermodal freight sector is not jeopardised by new unrealistic requirements without a sound scientific foundation. The semi-trailer market is a growing segment that needs a stable and coherent EU legal framework. Attached you will find a study that UIRR commissioned for examining the current safety standards for semi-trailers on pocket wagons and the implications of the proposed changes to the TSI WAG. Given that the proposed changes to the regulations do not address the root causes of past accidents (Great Belt Bridge), they are found to lack proportionality as a pan-European measure.
Read full response

Meeting with Sandro Santamato (Head of Unit Mobility and Transport)

9 Apr 2025 · Updates on the status of current Commission’s rail files and UIRR’s subjects of interest

Meeting with Herald Ruijters (Deputy Director-General Mobility and Transport)

20 Mar 2025 · TEN-T, CEF and AFIR

Response to Technical specification for interoperability relating to the telematics subsystem of the rail system

14 Mar 2025

UIRR is the voice of the intermodal freight in Europe and represents the interests of the intermodal freight operators and the terminal managers in Europe. UIRR welcomes the initiative of the Commissions draft Implementing Regulation on TSI Telematics, which aims at intensifying and improving the digital data sharing among the telematics stakeholders based on standardised data messages and alternative access options allowing IT platform solutions as an alternative to peer-to-peer connections. The need for consistent and complete digital information exchange at an affordable cost across the entire supply chain is a key prerequisite for improving data quality and subsequently overall service quality, and paves the path to increased competitiveness of road-rail intermodal freight transport. The intermodal terminals, defined in the draft Regulation as operators of rail service facility, are a key physical interface between the different transport modes. As such, they should transmit and receive specific data. UIRR therefore welcomes the fact that their data exchange with other actors in the rail sector is extended and described in the new TSI Telematics. However, the role of terminals is not comparable to that of an infrastructure manager and they should therefore not be considered as such. In this context, they should not be required to publish - publicly and free of charge - the working timetables, the train composition messages and the wagon movement messages. There is a clear need to adapt and scale down the data exchange requirements for intermodal terminals, bearing in mind that the majority of the approximately 800 intermodal terminals in Europe are SMEs. Terminals can contribute with the relevant information in their responsibility to a centralised EU-wide platform if the interfacing and running costs are cost effective. According to UIRRs first rough estimations, a significant total investment would be required to cover the set-up and running costs over a five-year period. The transitional period currently set at. 24 months, including an additional 12 months for the intermodal terminals, is therefore not appropriate if all the new obligations remain unchanged. UIRR will provide ERA with detailed cost implications as part of the impact assessment by early April 2025 at the latest. The new draft Capacity Regulation will impose a new obligation on infrastructure managers to develop a European framework for capacity management. This framework will define common principles and procedures for the management of rail infrastructure capacity and for coordination between infrastructure managers and stakeholders, including terminals. It is clear that this development will also require data exchange with terminals, which is the subject of the TSI Telematics. UIRR considers, however, that it is premature to involve the terminals in the path management, as provided for in the current draft TSI Telematics. It should be set as an open point until the new capacity regulation is fully adopted and the common rules are defined and established, since other stakeholders may be better positioned to exchange the path requests depending on the context. The currently applicable specifications and technologies for the so-called Common Interface are outdated, technically complex and economically unsustainable, particularly for SMEs. UIRR welcomes the Commissions proposal to push forward APIs as a substitute or an add-on to the existing common interfaces in order to reduce the total costs of data sharing. It is important to mention that the cost and efficiency benefits of modernised APIs will only materialise if the complete integration architecture is changed for the purpose of exchanging data between stakeholders. UIRR strongly advises to mandate the specification of of a fit-for-purpose API interface for SME terminals. Attached, you will UIRRs amendments to the Act and its Annex.
Read full response

Meeting with Joachim Luecking (Head of Unit Mobility and Transport)

22 Jan 2025 · Introductory meeting - new Head of Unit MOVE C4

Meeting with Lukas Sieper (Member of the European Parliament)

20 Nov 2024 · Networking Meeting

Meeting with Johan Danielsson (Member of the European Parliament)

18 Nov 2024 · Järnvägskapacitet och intermodala transporter

Meeting with Sophia Kircher (Member of the European Parliament)

24 Oct 2024 · Combined Transport, Weights & Dimensions

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and EUROPEAN RAIL INFRASTRUCTURE MANAGERS

22 Oct 2024 · Railway capacity

Meeting with Vivien Costanzo (Member of the European Parliament, Shadow rapporteur)

11 Sept 2024 · Exchange of views on the Combined Transport Directive

Response to Block exemption regulation on the application of Articles 93 and 108 of the Treaty to State aid for the land transport sector

2 Apr 2024

Intermodal freight transport is an important provider of inland freight transport services. The combination of the various modes of land and waterborne transport brought together under the intermodal banner is based on the best qualities of each. Combined Transport, where the road legs are kept to a minimum, is the most resource efficient and environmentally sustainable form of intermodal freight transport. The Combined Transport Directive is a part of EU law since 1975. The empirical facts presented in the Transport Externality Cost Handbook of the European Commission confirm the legislative recognition of the beneficial and desirable qualities of Combined Transport. An extensive number of man-made and unforeseeable occurrences have undermined the cost competitiveness of Combined Transport since late 2021: (1) a traction electricity price crisis multiplied energy bills, (2) the tripling of infrastructure works on the rail infrastructure - exacerbated by the lack of coordination between Member States - resulted in substantial additional costs and a reduction of quality, (3) accidents, strikes, extreme weather and natural disasters caused major prolonged disruptions and additional costs, (4) track access charge-increases exceeded inflation, (5) the implementation of recently adopted EU law, which aimed to correct the imbalances of the regulatory playing field in transport suffers delays - as manifested in numerous infringement procedures launched by the Commission. A regulatory framework should be in place to enable effective short-term state aid intervention in case of an unfortunate cumulation of events like the intermodal freight transport sector is experiencing today. A block exemption for these kinds of immediate relief measures should be enacted into European law.
Read full response

Response to Revision of fees and charges of the European Union Agency for Railways

29 Mar 2024

The railway sector stakeholders represented here by AERRL, ALLRAIL, CER, EIM, ERFA, UIP, UIRR and UNIFE - consider any cost increase as a major challenge for the competitiveness of the European rail sector. The increases should be offset against the efficiency improvements promised with the 4th Railway Package. Especially since the railway stakeholders face corresponding costs within their own companies and from their contractors. While we acknowledge an overall cost increase in the limits of inflation, for the sake of transparency we request the calculation method of these costs be made publicly available. The new fixed fee of 26500 proposed under Art 3(3)a and item 4 in table B of the Annex (authorising a vehicle type - freight wagons when the area of use is whole Union) actually exceeds the experienced costs under the currently hourly rate method. We also recall that the fees for a wagon type authorisation under the 3RP were significantly lower than today under the 4RP. Given the objective of the European Commission to boost the efficiency, sustainability and competitiveness rail freight services across the European Union, we recommend to lower the fees for freight wagons either via a revised fixed fee proposal or by keeping the hourly rate method for the type authorisation. The wording for Art 2(2)h and item 8 in table B of the Annex (Processing of notifications, including decisions of the Agency in accordance with Article 16(4) of Implementing Regulation (EU) 2018/545) needs to be refined. It shall be made clear that the amount of 3.710 is a lump sum for all notifications of a type of vehicles and not for individual vehicles. This would lead to enormous costs otherwise. The 3710 is also significantly higher than experiences of an applicant when exchanging information according with Article 16(4) with the German NSA, in the range between 600 to maximum 1200. We do not support the possibility for NSAs to delay their input and ERA to issue an invoice without the associated NSA costs proposed under Art 5(3). Allowing NSAs to recover costs directly with the applicants at an undefined time passes the administrative burden over to the applicants and contradicts the principle of one OSS application one invoice as established when drafting of (EU) 2018/764. The new 20 calendar days period for the NSAs to provide their cost statements to the ERA should be sufficient and the second half of the proposed Art 5(3) should be deleted. Art 5(1) now gives ERA 60 days rather than 30 to solve this. The fixed fees for conformity to type (CTT) authorisations found in item 1 in table B of the Annex have now undergone two indexations, standing at 11,6% higher than those established by (EU) 2021/1903. We believe these fixed fees need to be recalibrated to reflect the efficiency gains in the CTT process reported by the Agency in subsequent years and quality improvements of the applications following 3 more years of experience. It is understood that the hours required to process the CTT applications are now lower than in 2021 and as such the fees should also be adjusted to reflect this and incentivise continued improvement in the processes. For Special Vehicles we should consider that the IMs yellow fleets are far smaller compared to the commercial ones, and so their authorisation costs cannot be distributed across a large number of vehicles. The EC and ERA should consider how to mitigate that impact the authorisation costs have on these vehicles. If we add up all the cost elements for vehicle authorisation and registrations on a case-by-case basis, we conclude that the accelerated roll-out of European Rail Traffic Management System (ERTMS) both on the side of Infrastructure Manager and Railway Undertakings as well as the Digital Automatic Coupler (DAC) is at risk. We recommend addressing the issues of vehicle and trackside authorisation in the framework of the accelerated ERTMS rollout and DAC deployment.
Read full response

Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur) and Community of European Railway and Infrastructure Companies

17 Jan 2024 · Weights and dimensions directive

Meeting with Markus Ferber (Member of the European Parliament, Shadow rapporteur)

17 Jan 2024 · Weight and Dimension Directive

Meeting with Ciarán Cuffe (Member of the European Parliament) and Duisburger Hafen AG

28 Nov 2023 · European Intermodal Summit Panel

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

22 Nov 2023 · Weights and Dimensions Directive

Meeting with Thomas Rudner (Member of the European Parliament)

15 Nov 2023 · Combined Transport

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur) and Glass for Europe

9 Nov 2023 · Weights and dimensions directive

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur)

7 Nov 2023 · CountEmissionsEU

Meeting with Barbara Thaler (Member of the European Parliament)

7 Nov 2023 · Weights and Dimensions

Meeting with Ciarán Cuffe (Member of the European Parliament, Shadow rapporteur) and Community of European Railway and Infrastructure Companies

24 Oct 2023 · Rail Forum Event on Greening Transport Package

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

24 Oct 2023 · Count Emissions EU

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

24 Oct 2023 · Weights and dimensions directive

Meeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Alstom

20 Oct 2023 · Rail Capacity Proposal

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

3 Oct 2023 · Greening freight package

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

3 Oct 2023 · Greening Freight Transport Package

Meeting with Markus Ferber (Member of the European Parliament, Shadow rapporteur)

25 Sept 2023 · WDD

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

12 Jul 2023 · Combined transport

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

14 Mar 2023 · Green freight package

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

The freight transportation market has been opened to competition over 30 years ago, hence price signals determine shipper preferences. Combined Transport (CT) offers a proven freight transport solution to replace road haulage on an industrial scale over longest sections of transportation. CT evidently requires a greater effort than using trucks (which basically function as a taxi: order one, it come to the address to collect the subject to be transported and takes it to the address it is given as a destination). CT users must coordinate the intermodal loading unit, which holds the cargo, dispatch the truck to collect it and forward it to he nearby transhipment terminal. The transhipment must there take place to the non-road mode which carries out the longest segment of the journey. A similar process then completes the transport operation on the receiving side. The complexity would make a smaller dent on price-competitiveness it if the long-distance trucking rates would reflect the pollution (harmful emissions) of trucks, ranging from climate gases (CO2, NOx, ozone), pollutants (PM10, PM2,5) and noise --- in line with the polluter-pays principle. ---evidence of CT's current performance and future potential can be found in the three studies here: https://www.ct4eu.eu/studies The EU legislation that should address the issue are: (i) the fuel excise duty directive (Council Directive 2003/96/EC), and (ii) the recently revised Eurovignette Directive (Directive (EU) 2022/362). Fuel excise duties should reflect the emission of pollutants as a consequence of burning on board of a vehicle, while the Eurovignette (e-Toll) should contain a component for the pollutants emitted by the circulation of the vehicles (tyre powder, clutch powder, noise), which comes on top of internal combustion. ---both of the above cited legislations fall short of this mission. Combined Transport technologies are dominantly powered by electricity taken directly from the grid. The harmful emissions of electricity generation are effectively internalised through the ETS. The overall result is the unduly limited uptake of clean Combined Transport, while the overuse of polluting trucking in the inland transportation of freight throughout Europe.
Read full response

Meeting with Barbara Thaler (Member of the European Parliament, Rapporteur)

12 Jul 2022 · TEN-T

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

19 May 2022 · Keynote on Zero-Carbon Combined Transport

Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

1 Apr 2022

UIRR applauds the Commission’s proposal to amend the TEN-T Regulation. The proposal can be further refined from the perspective of the European intermodal freight transport sector, which is outlined in the position paper published today [attached to this comment]. The following 6 points are recommended to the EU legislators by UIRR: 1. Refocus the underlying policy principle of the proposal to devote investment resources uniquely to those low-risk solutions, which have already demonstrated their capability to deliver the policy objectives of the European Union. 2. Elevate the standing of rail freight in line with its results under the socio-economic cost-benefit analysis. 3. Mandate the creation of a Transport Information Portal as part of the TEN-T digital infrastructure and make the compliance with the quality criteria for freight part of this Transport Information Portal. 4. Review the line and terminal designations contained in the annexes of the proposal, and define a simple administrative process to amend these annexes after the adoption of the legislation. 5. Adjust the punctuality criteria for freight trains to those of passenger trains, applying the principle of equivalence: reference measurement at 5 minutes. 6. Specify the CT-related infrastructure parameters (CT profiles for all types of loading units) and strengthen the concept of network resilience by introducing mandatory interconnections between corridors as well as bypass options, with the aim of improving the reliability of transport services. UIRR regrets that the modal silo approach, whereby each mode is enabled to do the best it can to meet the policy objectives, has extensively influenced the Commission proposal. The silo-approach, despite all technology improvements, caused the substantial increase of every category of transport externality that Europe has been battling. Moreover, it exacerbated the energy dependency of the continent, while creating a significant truck driver shortage. The notion of shifting the balance of modes, which has been a secondary driver of European transport policymaking since 2001, has been subordinated despite relentlessly delivering tangible results. According to a study released in November 2021 , door-to-door Combined Transport uses 40-70% less energy per tonne-kilometre, while leaving behind a 60-90% smaller carbon footprint than its equivalent end-to-end unimodal trucking operation. Combined Transport has proven that it works, delivers results, while not requiring scientific breakthroughs or exorbitant and risky public investments. Moreover, intermodality is an effective tool to reduce Europe’s dependency on external energy supply. TEN-T policy should also focus on the cohabitation of passenger and freight transportation on the infrastructure. Socio-economic cost-benefit analysis should be used to decide the primary objectives of infrastructure development.
Read full response

Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail

30 Mar 2022

Largely agreeing with the diagnosis provided with the initiative, UIRR would hereby express its preference for Option 2 with the following annotations: 1. Option 1 has been the path pursued for the past decade, and it has clearly failed. Member State (+sector)-driven initiatives did not deliver the desired results. The regulatory framework provided by the European Union has clearly been insufficient to produce the required solutions. 2. Option 3, while seemingly efficient and attractive, is not thought to be realistic. We do not believe that Member States and national infrastructure managers would be willing to sign over the amount of power and competence to the envisioned European-level entities. 3. This leaves Option 3, which should include as a minimum the following: (i) a European categorisation of train path types for both passenger and freight trains, complemented by a hierarchy for such train paths; (ii) a European register for train-path owners, which would designate the entity taking the commercial risk for a train (the authorised applicant) to be the owner of the train path needed to enable the train to run; (iii) the use-it or loose-it principle in rail: in case an applicant would be found to have cancelled train paths or not run trains on train paths in excess of 3% of train paths reserved by the applicant for a calendar year period, the applicant should be restricted to reserving not more than 97% of the train paths of the previous period during the following year; (iv) the declaration of socio-economic-cost-benefit analysis to serve as the basis for capacity allocation, where the actual contents and method of the socio-economic cost-benefit analysis should be placed into an EU Implementing Regulation; (v) a single European, or regional capacity allocation bodies, to be put in charge of all cross-border train paths, overseen by a European organisation (agency) with regulatory capacities; (vi) a single European train numbering (identification) system, whereby the same trainset is identified as a single train throughout the entirety of its journey. UIRR will provide its input throughout the public consultation process to help create the regulatory framework that will deliver more cross-border freight trains in Europe.
Read full response

Response to Evaluation and revision of the Weights and Dimensions Directive

16 Feb 2022

We fully support the overall objectives pursued by the European Commission in its Sustainable and Smart Mobility Strategy (1) to make all transport modes more sustainable and (2) to make current sustainable alternatives such as railway widely available in intermodal end-to-end logistic supply chains with the aim to shorten the road operations as much as possible. Sustainability is a balance to be found between environment, society and economy that meets the needs of the present without compromising the ability of future generations to meet their own needs. In this context, it is essential to focus the efforts on reducing the CO2 emissions and on making more efficient use of our planet's increasingly scarce energy and non-energy resources. A recent study on the carbon footprint and energy efficiency of door-to-door Combined Transport (CT) has provided evidence that it emits up to 90% less CO2 and reduces energy requirements up to 70% compared to the corresponding state-of-the-art unimodal trucking. Consequently, the planned revision of this Directive is no longer to be considered as a pure road legislative initiative, but should be the basis for a new approach based on intermodal compliance between all transport modes. Today, in CT, 80% of the traffic is based on boxes whereas 20% of the volumes are semi-trailers, a market that has been growing for more than 10 years. It is therefore of absolute necessity that the European legislator sets strict rules on the types of road vehicles that are allowed on the European market in terms of weights, dimensions and additional equipment, in order to ensure that they are fully - technically and operationally - interoperable with the other modes particularly railway transport. The concept of intermodal compliance was initiated in the last revision of the Directive by integrating aerodynamic devices for commercial road vehicles. Having set clear specifications for such devices in intermodal operations ensures that the future generation of road vehicles fitted with such features will continue to be compatible with the railway wagons. This Interoperability was further investigated in the AEROFLEX project, in which an intermodal test was included to demonstrate compatibility between road, rail and handling technologies. The basic philosophy of CT is that everything that can be transported by road should also be transportable by CT. The CT sector has innovated by developing multipurpose wagons (with a period of amortization of up to 30 years) to accommodate all types of loading units. The success of Combined Transport is based on a three-level standardization: ILUs, wagons and infrastructure. UIC and UIRR have jointly conducted the CACTUS study in order to identify gaps and to propose recommendations ( e.g. a semi-trailer should be considered as an intermodal loading unit). The revision of the Weights and Dimensions Directive might significantly impact the current interoperability with the potential risk of a reverse modal shift. Previous studies have already demonstrated this risk in the event that, for example, longer road vehicles are allowed on the entire European road network. The European legislator must carefully analyse the impacts of modifying dimensions and weights in the framework of intermodality: (1) a first evaluation clearly shows that increasing the length of a semi-trailer beyond 15.0m is not technically and operationally possible. In addition, longer road combinations, as already tested in several Member States, are de facto not compatible with railway assets. A demand for containers longer than 45-feet is also to be assessed. Height and width should not be modified. (2) a simplification on the weight parameter is needed: 40t for road and a 44t single rule for all types of Combined Transport. If the intention is to increase these thresholds, the benefits for the road sector should be clearly identified and possible balanced measures for Combined Transport should be proposed.
Read full response

Meeting with Henrik Hololei (Director-General Mobility and Transport)

31 Jan 2022 · Rail freight

Meeting with Henrik Hololei (Director-General Mobility and Transport)

2 Dec 2021 · Intermodal transport

Response to Revision of Combined Transport Directive

8 Sept 2021

UIRR as the industry association of European Combined Transport welcomes the launch of the revision of the Combined Transport Directive. The extension of scope concerning the benefits granted in the Directive to any intermodal or multimodal transport operation that delivers a meaningful contribution in savings of harmful externalities of road-only transport is to be greeted. We would like to draw the attention to the highly heterogeneous and unstandardised means of multimodal transhipment, as opposed to intermodal transport, to which the impact assessment should pay particular attention. The calculator mentioned should include every externality measured in the EU Commission Internalisation Handbook developed by CE Delft. The savings targets should be laid out until 2050 in a progressively increasing manner within the revised Directive. The calculator mentioned in the IIA should be designed in a way as to avoid becoming an additional administrative burden, and it should also enable quick and easy enforcement by the authorities too. The revised Directive – on the decarbonisation of inland freight transport – should be clear that sustainability includes not only carbon emissions, but externalities such as pollution, congestion and accidents. Moreover, the pro-rata energy efficiency and labour intensity of the transport operation could also be factored in since the efficient use of resources should also be part of a sustainable freight transport future for Europe. The benefits contained in the current CT Directive – addressed to Combined Transport operations – should be maintained, especially the legal equivalence of border-crossing Combined Transport with their equivalent road-only operation – embedded in Article 4 of the Directive – and the 44-tonne gross vehicle weight allowance for trucks performing the positioning road legs of a Combined Transport operation. Both of these provisions have become fundamental pillars of existing Combined Transport business models over the several decades of their existence. The impact assessment should confirm this to the Commission – just like the previous impact assessment for the 2017 amendment proposal of the Directive did – based on which these benefits should be adequately guarded in the revised Directive. Under the auspice of decarbonisation, every member state should be required to prepare a master plan for achieving the envisioned sustainability boost from its inland freight transport sector. This should include every externality category and should comprehensively describe the status quo, before detailing the measures to be taken and the desired effects to be achieved by them. The economic and regulatory support measures to be extended under the framework of the directive should be transparently linked to these objectives and their effectiveness periodically controlled against these objectives. An annual, or worst-case biennial, reporting obligation is seen as essential from this perspective. UIRR and its members look forward to collaborating with the Commission in its impact assessment efforts, by participating in the public and targeted consultations.
Read full response

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

22 Apr 2021 · Combined transport in the European Green Deal

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

4 Mar 2021 · Meeting to discuss the latest developments of the EYR, the SSMS and the TEN-T guidelines

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

29 Sept 2020 · Meeting to discuss the intermodal developments

Meeting with Adina-Ioana Vălean (Commissioner) and

24 Sept 2020 · Presentation meeting on rail policy developments

Response to Sustainable and Smart Mobility Strategy

30 Jul 2020

When it comes to longer distance freight transport, the system based on the use of intermodal loading units - containers, swap bodies and craneable semi-trailers - offers the easiest way of inserting energy efficient electric rail as well as maritime solutions with the lowest externalities into presently truck-based transport-chains. Intermodal transport is capable of the most efficient transhipment between the different modes of transport of the cargo that is typically carried in trucks in truckload quantities. Combined Transport is the version of intermodal, defined in the Combined Transport Directive (92/106), where the first and final road legs of the transport-chain are consciously kept to the minimum, therefore it is the form of intermodality that maximises the benefits from every perspective. Sustainable and Smart mobility can not be imagied in Europe without Combined Transport.
Read full response

Meeting with Henrik Hololei (Director-General Mobility and Transport)

19 May 2020 · future of intermodal transport

Response to European Year of Rail (2021)

16 Mar 2020

UIRR supports the initiative for designating 2021 the European Year of Rail, and recommends that the European Parliament and the European Council uniformly endorses the idea. Combined Transport delivers increasing amounts of cargo for freight trains to carry at a time when demand for the shipping of classic (bulk) rail freight commodities is on a decline. The intermodal technique - through the use of intermodal laoding units - enables the quick and efficient transhipment of any type of cargo (typically carried in trucks) to trains and waterborne vessels. This way Combined Transport opens the door for rail freight to take part in the longer distance sections of the most dominant transport chains that make up majority of freight haulage needs in the European economy today. Rail transport is much more than just passenger trains. Rail is ideal to facilitate the forwarding of 740m long 2000t freight trains that can each carry the same amount of cargo as 50 heavy goods vehicles, while being powered by (renewable) electricity, offering regenerative braking and superior energy efficiency, safety and minimal harmful external effects. At the same time easing the pressure on an otherwise overloaded road transport infrastructure, reducing congestion, accidents, injuries and fatalities. Therefore UIRR proposes that the European Year of Rail (in 2021) offers a focus balanced equally between passenger and freight trains.
Read full response

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

5 Mar 2020 · Transport and green Deal

Response to Revision of Non-Financial Reporting Directive

12 Feb 2020

The environmental impact of large companies - especially in the manufacturing and commercial sectors - is significant. Their choice of logistics practices and freight transport services has an immense impact. Energy efficiency, carbon-, pollutant- and noise emissions should be used as the major indicators. ---Therefore, an explicit obligation should be formulated under the 'environmental impact' title, where these companies must discuss the choices they made during the organisation of their supply chains, the logistics services that these entail, the transport infrastructure connections that their current and planned sites have, and the freight transport services that they have used, or are planning to use. Organising a carbon-neutral (high energy efficiency) supply-chain is of immense importance to the overall carbon- and (harmful) emission-footprint of any major economic operator. The upgrading of human resources tasked with these is a pre-requisite of success. ---Therefore, the reporting should also entail a description on how environmental-consciousness penetrates throughout the organisation when designing their future supply-chains, as well as during the daily operation and updating of their existing supply-chains. The reporting should extend to the training that these ompanies extend to their logistics and planning staff, or any other human resource (external contractors, consultants, experts) that they use in the process of desigining and oeprating their supply-chains.
Read full response

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

20 Jan 2020 · Combined Transport in the Green Deal

Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 Nov 2019 · Combined transport

Response to Rear aerodynamic devices according to the amended directive 96/53/EC on maximum weights and dimensions

18 Mar 2019

UIRR welcomes the draft Commission’s Implementation Regulation laying down detailed provisions as regards the use of rear aerodynamic devices pursuant to Directive 96/53/EC in particular in taking into consideration the specifications of any kinds of intermodal transport combinations (rail, inland navigation and short-sea-shipping) when operating those rear devices not only in pure road transport. We would like however to stress the following comments: 1) As DG GROW decided to postpone the adoption to its Implementing Act on “Type Approval” to the next legislative period, UIRR wonders if a similar decision should not be taken with this draft Regulation. A full alignment and synchronisation between both Regulations (DG MOVE and DG GROW) is absolutely necessary for a full road and intermodal compatibility. 2) Definition of intermodal transport and intermodal loading unit: we propose to specify further the definition set in the Directive 96/53 and to make sure that the Regulation covers any types of intermodal loading units (semi-trailer, swap bodies and containers). 3) Codification system in Combined Transport (rail-related requirement): the current system is based on codified wagons, lines and loading units. The current width limitation of 2 600 mm is based on railway infrastructure specific calculations. Beyond this width, the loading units cannot be certified neither codified for railway. In other words, technically, it is acceptable to design aerodynamic elements that might protrude but, in railway operations, they shall never protrude by more than 2 600 mm. The same principle shall be applied for any other types of protruding equipment. 4) Additional impact analysis is needed on special routes: (1) the RoRo/short-sea-transport (impact of additional width on overall ship capacity) and (2) Channel routes (compatibility of the railway cars). 5) Test in real railway operations use: UIRR participates in the AEROFLEX project in which an intermodal test is to be expected: (1) transferability test of semi-trailers equipped with aerodynamic features on different railway wagons and (2) train running performance test on a single route (positioned on two directions).
Read full response

Response to Type-approval requirements for elongated cabs and rear flaps for trucks/trailers

26 Feb 2019

The overall aim should be to ensuring “COMPATIBILITY with INTERMODAL TRANSPORT” as per Dir. 96/53 - Art. 8b-3(c). The following 6 conditions MUST be fulfilled: CONDITION 1 – AIR PRESSURE RESISTANCE When retracted/folded, devices must RESIST AIR PRESSURE under RAIL OPERATING CONDITIONS, e.g. crossing trains in tunnels, lateral winds… Proposal: (1) ANNEX I to be amended, especially Part A, Part B (presumably Point 1.3.1.2.4), Part C (presumably Point 1.3.1.2.4), Part D (presumably Point 1.4.1.2.4) (2) A provision to be added in ANNEX 1 requiring that “a calculation method is agreed upon and tested on a first set of prototypes “in situ” (in various rail-operating conditions). These test values may become the reference for the testing of future prototypes in laboratory conditions. “Field tests” are foreseen in the AEROFLEX project funded by the European Commission. UIRR will ensure the coordination of this railway test. (3) EN standards 12663-2:2010 (Railway applications. Structural requirements of railway vehicle bodies. Freight wagons) and 14067-4-5-6:2010 Railway applications. Aerodynamics. Requirements and test procedures for aerodynamics on open track, tunnels and cross wind assessment) should be considered as input for such a provision. CONDITION 2 – TOTAL WIDTH The TOTAL WIDTH of trucks and (semi-)trailers (including added devices) must not exceed 2,60m. Proposal: ANNEX I to be amended, esp. Part A + Part B (presumably Points 1.3.1.1&1.3.1.2) + Part C (presumably Points 1.3.1.1&1.3.1.2) + Part D (presumably Points 1.4.1.1&1.4.1.2) with addendum to clause “… in a such a way that the maximum authorised width of the vehicle […] is not exceeded by more than 25 mm on each side of the vehicle” the following text “and remains within the limit of 2600 mm permissible on rail (as part of an intermodal transport)”. CONDITION 3 - THE ADMISSIBLE HEIGHT OF THE DEVICE The HEIGHT of the added devices from the ground must not be below 830 cm over a certain length. Proposal: ANNEX I to be amended, esp. Part A + Part B (presumably Points 1.3.1.1&1.3.1.2) + Part C (presumably Points 1.3.1.1&1.3.1.2) + Part D (presumably Points 1.4.1.1&1.4.1.2) with addendum to clause “… in a such a way that the maximum authorised width of the vehicle […] is not exceeded by more than 25 mm on each side of the vehicle” the following text “and remains within the limit of 2600 mm permissible on rail (as part of an intermodal transport)”. CONDITION 4 - SAFETY CRITERIA FOR LOCKING Safety criteria regarding LOCKING must be detailed. Proposal: ANNEX I to be amended, esp. Part A + Part B (presumably Point 1.3.1.2.2) + Part C (presumably Point 1.3.1.2.2) + Part D (presumably Point 1.4.1.2.2): Add provisions on safety criteria (to be “type-approved) including LOCKING in both FOLDED & UNFOLDED positions CONDITION 5 – DEFINITION OF INTERMODAL TRANSPORT A “technical” definition of Intermodal Transport is lacking Proposal: Suggested definition to be added: “For the purposes of this regulation, an “Intermodal Transport” means the transport of one or more transport units (containers, swap bodies, TRACTORS, TRAILERS, SEMI-TRAILERS, etc… or any combination of these) where the unit(s) concerned use(s) road on at least one leg of the journey and rail or inland waterway or maritime services on at least one other leg of the journey.” CONDITION 6 – TOLERANCES Tolerance for devices to be excluded from the determination/calculation of outermost dimensions is questionable. Proposal: The existence of Point 1&2 of Appendix 1 and of Tables I, II and III is questionable. German translation may be understood differently from French & English versions.
Read full response

Response to Combined Transport

23 Jan 2018

UIRR, the International Union for Road-Rail Combined Transport, has analysed the Commission proposal to amend the Directive 92/106 and provided its enhancement suggestions in the attached position paper.
Read full response

Response to Evaluation Energy Taxation Directive

26 Sept 2017

UIRR has published a position paper in 2011 to greet the Barroso Commission's attempt to amend the ETD; unfortunately this proposal, while essentially correct, was withdrawn some years ago... UIRR maintains that: 1. The ETD is necessary, but substantially outdated. 2. Taxation should be based on the energy content of the fuel (=the amount of CO2 + the various pollutants released when burning a unit of the fuel). Energy products from renewable sources (i.e. wind, solar, hydro, etc) should not be subject to energy taxation under the ETD. Biofuels and other agricultural/horticultural gases should be separately considered. 3. The minimum tax level should be devised based on an algorithm, which allows the annual valorisation of the minimum tax level as an automatism. A protocol to this extent should be defined in the ETD. 4. Energy taxation, as an 'excise duty-type' of tax, should related to the external effects that occur when using the subject of the tax: i.e. harmful substances are released when burning a litre of diesel such as CO2 and various other pollutants; and the revenues from the tax should be used to compensate for these external effects. Users of equipment, which is certified - through its Euro emission classification for instance - to be equipped with pollutant traps such as particulate filters, or ad-blue additive, etc.and thus emit fewer pollutants should be entitled to a rebate to the extent they emit fewer harmful matter. 5. Energy taxation should NOT be used as a means to collect financing for infrastructure access. Fuel tax revenues should be clearly earmarked for expenses to compensate pollution (i.e. health-care funding), cleaning of the air and other climate-change mitigation measures (if modal-shift is identified as a 'means to mitigate climate-change' than measures to this effect should also be available to be funded with fuel tax revenues). 6. Electricity (used in transport) is already internalised through its inclusion in the ETS. Subsequently, there is no justification for including electricity under the scope of the ETD. 7. No specific mode of transport (rail, road, aviation, navigation) or its fuels should be exempt from energy taxation - the ETD should equally apply to these. 8. Non-transport use of energy products (heating, agriculture, etc.) should not be exempt from the ETD, but a different taxation regime should be possible though this should also be based on the principle of CO2 and pollutant emissions and should incentivise efficient use of the energy product. The clear distinction of the energy product of this type should be defined in the legislation. 9. Should there be a desire to collect any form of infrastructure access fee component within the energy tax this should be clearly and transparently declared by the Member State that desires to apply it. Only VAT charged on energy products should constitute a general revenue of public budgets. UIRR looks forward to the elimination of market distortions - mainly in the field of transport - caused by the current intransparent, confusing and outdated energy taxation regimes.
Read full response

Response to Access to service facilities and rail-related services

14 Aug 2017

UIRR has participated in the drafting process of the Implementing Act as the representative of intermodal terminals (a sub-category of freight terminals), as well as speaking for Combined Transport Operators, who are users of intermodal terminals throughout Europe. ---The process of drafting must be praised as it was conducted in an exemplary professional manner by the Commission. The final draft of the Implementing Act reflects most comments presented by UIRR and its members. ---It is UIRR's conviction that the changes to be brought about by the Act to the already business-like and competitively functioning intermodal terminals will be positive, mostly from the perspectives of transparency and standardization. These should build further confidence among users of intermodal terminals, as well as provide reinforcement to investments. Two final comments: 1. The definition of 'freight terminal' was introduced fairly last minute into the text and therefore has not been adequately considered. If a mobile bagger loads gravel onto a wagon alongside a track (siding) does that (temporarily) turn the siding into a 'freight terminal'? Not in our opinion. ---In UIRR's view: a 'freight terminal' is a DISTINCT FACILITY ELABORATELY ESTABLISHED FOR THE PERMANENT PURPOSE OF 'loading, unloading and transhipment of goods' AND/OR INTERMODAL LOADING UNITS HOLDING GOODS OR EMPTY. 2. Operators of intermodal terminals remain at unease concerning the obligation to collaborate in identifying a 'viable alternative' in case of a rejected application. Intermodal terminals are fiercely competitive entities, especially with the ones in their closest geographic proximity. ---In UIRR's view: in case a single European web portal achieved (a near) complete coverage in a particular service facility category in a well defined area, a simple reference to the portal should satisfy the obligation to assist the applicant to identifying a 'viable alternative'.
Read full response

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

28 Feb 2017 · Introductory meeting with Mr Ralf-Charley SCHULTZE, President of UIRR

Meeting with Henrik Hololei (Director-General Mobility and Transport)

25 Feb 2016 · REFIT, Combined Transport Directive

Meeting with Violeta Bulc (Commissioner)

24 Feb 2015 · Meeting with UIRR