The EESC reiterates its support for the entire Mobility Package. It therefore welcomes the aims of the current Proposal to ensure a level playing field in an unfragmented internal road transport market, avoid excessive administrative burdens on businesses, improve the clarity and enforcement of the regulatory framework and address abuse, such as the use of letterbox companies, non-transparent business models and illegal cabotage.
The EESC supports the objectives of the Proposal to introduce into Regulation (EC) No 1071/2009 establishment requirements that will prevent the use of letterbox companies for road transport operations and strengthen compliance monitoring. It also supports the improved rules on infringement procedures and on the assessment of sanctions involving the risk of loss of good repute, both of which improve legal certainty.
The Committee also welcomes the introduction of time limits for answering requests for information and the improvement of information available in national registers; it would welcome real time access for control authorities. Moreover, it considers that the data to be entered in national electronic registers should also include information regarding the drivers employed by an undertaking.
At the same time, the EESC welcomes the main thrust of the amendments proposed to Regulation (EC) No 1072/2009 to simplify and clarify rules on cabotage and strengthen compliance monitoring.
The EESC takes note of the potential of the digital tachograph as an efficient means of compliance control and supports its early installation, including on existing vehicles.
However, the Committee strongly stresses that the proposed amendments regarding cabotage can only be successfully and fairly introduced if provisions are introduced to make clear when provision of cabotage services ceases to be temporary and an obligation of establishment arises, and if the complete set of posting of workers rules applies to every cabotage operation without any exemptions.
The EESC regrets that the legislation remains unclear and open to different interpretation on a number of points regarding cabotage rules. Similarly, it regrets that Directive 92/106/EEC on combined transport, which in practice provides a parallel market access, is not addressed at the same time as Regulations (EC) No 1071 and No 1072/2009. In order to have effective legislation, cabotage in all forms should be subject to similar rules.
Finally, the EESC considers that light commercial vehicles should be fully covered by Regulations (EC) No 1071/2009 and 1072/2009, albeit possibly in an alleviated form. The EESC supports the creation of a European Road Transport Agency.