The EESC supports the initiative to render the combined transport concept more efficient and attractive and render transport more sustainable in accordance with the aims set out in the 2011 White Paper on transport policy and the undertakings made under the Paris Agreement.
The EESC takes favorable note of the efforts to simplify the Directive in order to improve legal certainty. The EESC finds particularly useful the simplification of the delimitation of road transport legs, including the flexibility option opened to Member States which enables adaption to local conditions.
To facilitate access to information on the implementation of the Directive in each Member State and facilitate planning of combined transport operations, the EESC suggests an obligation on each Member State to make all pertinent information regarding the implementation of the Directive available on a dedicated website.
The EESC approves the clarification and simplification of the documentation that should be available for compliance control as well as the provision that those documents may be produced in electronic form.
The EESC appreciates the proposed obligation on Member States regarding investment in transhipment terminals and in particular the obligation to coordinate investments with neighbouring Member States. The Committee nevertheless questions whether the objective of a maximum distance of 150 kilometres from any location in the EU to the nearest terminal is realistic. It also questions the usefulness of the provision which seeks to exclude certain inland waterway and maritime transport legs from being taken into account for combined transport operations.
The EESC finds it difficult to understand why the so-called "cabotage exemption" remains unchanged. The EESC also points to the general principle that service provision in a country other than that where the service provider is established should be done on a temporary basis.
The EESC also underlines the significant potential of digitalisation for facilitating and promoting combined transport. The potential for development in this field is considerable for transport as a whole, including in combined transport.