During the webinar, we will discuss with them what the current status of these policies is, how they changed for the worse since the first proposal and what can be done to avoid a disastrous scenario. Don’t miss out on this opportunity, sign up for the webinar and join the discussion. Only by sharing knowledge is it possible to bring about the best change possible, especially in this period of uncertainty for a fragile industry such as rail freight.

“Optimism dies last. We fight until the last man”, UIRR Chief Policy Advisor Akos Ersek told RailFreight.com. The association is urging co-legislators to change course and implement the amendments proposed in November 2023 by the European Commission. As UIRR pointed out, this has only been the third attempt at amending the 1992 Directive. The first two failed in 1998 and 2017. A new rejection would mean no new proposal for the foreseeable future.

The definitions

The CTD would introduce a new definition of combined transport, which is vital to decide who is eligible for exemptions and discounts. The 1992 definition is quite vague: “the transport of goods between Member States where the lorry, trailer, semi-trailer, with or without tractor unit, swap body or container of 20 feet or more uses the road on the initial or final leg of the journey and, on the other leg, rail or inland waterway or maritime services where this section exceeds 100 km as the crow flies and make the initial or final road transport leg of the journey”

The proposal brought forward by the Commission at the end of 2023 added that combined transport operation “shall reduce by at least 40% external costs compared to the alternative road unimodal transport operation”. These externalities would have been calculated with another tool of the Greening Freight Package: eFTI. However, the European Parliament always challenged this formula, claiming that calculating methods for such costs are too vague and pushing for a distance-based definition.

In a last attempt to save the Directive, UIRR has come up with yet another proposal for the definition of combined transport. “Every door-to-door intermodal freight transport operation should be defined as a combined transport operation, where the non-road leg reaches 60% of the total distance covered”, the association said in its latest position paper. They are also suggesting including domestic services in large EU countries such as France, Germany and Sweden.

Combined transport needs saving

Having a clear definition of combined transport is key for the distribution of subsidies. This mode of transport is usually not very profitable, but its benefits on society and the environment are significant. Lower emissions, safer roads which require less maintenance and a solution to the current truck driver shortages. All signs seem to point to the Directive being cancelled, but the industry will not give up.

However, this requirement will not be made mandatory, thus road freight companies will be allowed to use the extra space to transport more goods. This is bad news for rail freight for two reasons. First, it makes road transport even more attractive, as prices are likely to lower even more if one journey can transport more goods. Secondly, a significant number of rail wagons will not be able to accommodate EMS, hindering interoperability.

There is still a glimmer of hope

All these problems were (once again) highlighted by six sector associations, including UIRR, ERFA, CER, RFF, UIP and UNIFE. “The road transport sector can expect economic gains – but society will have to wait for any reduction of the environmental footprint of logistics”, they said in a joint statement in reaction to the Council’s adoption of the general approach. Not all is necessarily lost, though. According to the six signatories, there is still hope.

The vision of a real European, interoperable logistics ecosystem can still be achieved if three parameters are met. First, WDD incentives should only apply to zero-emission vehicles or vehicles involved in intermodal transport. Second, interoperability between different modes of transport should be ensured. Finally, Member States should be required to carry out studies on the potential impact of EMS on their roads. “Any outcome falling short of these parameters will trigger an undesirable reverse modal shift from rail to road”, they underlined.

The impact on society

Introducing EMS on European roads would not only hamper the rail freight sector, but also have a negative impact on society and our pockets, as RFF’s latest campaign We All Pay For highlights. More money for road maintenance and more and graver accidents are just the main problems. There would also be more pollution, especially if the reverse modal shift feared by the rail freight industry continues to grow.

What happens now?

The Council’s adoption of a general approach basically means that the EU Member States agreed on the current version of the WDD. This was a key step before the start of trialogue negotiations with the Commission and Parliament, after which the Directive can be adopted.

Kopczyńska also discussed the other pillars of the Package. Regarding the Weights and Dimensions Directive, she underlined the disappointment of the industry with a regulation that seems to hinder rail freight more than benefitting it. This sentiment is widely spread across associations in Europe, as the recently launched We All Pay For initiative shows.

Better paths are key

Another aspect analysed during the Summit was the availability of high quality paths and more accountability for infrastructure managers in case of last-minute cancellations. These are issues addressed in the third pillar of the Greening Freight Package: the Capacity Management Regulation.

Contrary to the Combined Transport Directive, the EU Parliament and Council managed to find a provisional agreement. However, not everyone is happy with how the Regulation panned out, highlighting how the benefits would be as helpful as initially expected, especially regarding the European Network of Infrastructure Managers.

The importance of the Greening Freight Package

There are some measures in the works that should boost combined transport, namely the Greening Freight Package and its components. For example, the Capacity Management Regulation “will be instrumental in delivering more and better-quality train paths, both during timetabling and when circumventing sections impacted by works”.

On the other hand, recent developments concerning the Combined Transport Directive have “surprised the Combined Transport Community”, as UIRR pointed out. The European Commission has in fact recently communicated its intention to withdraw the amendments to the Directive, something that everyone in the industry would prefer to avoid.

‘No public consultation’

In its Commission work 2026 programme, the EC said it wants to withdraw amendments on the “support framework for intermodal transport” and the “calculation of external cost savings and generation of aggregated data”. UIRR said it regrets this development, “about which the European Commission has not conducted any sort of public consultation”.

Tosim in addition, pointed out that the European Parliament already scheduled the presentation of a study, commissioned by the rapporteur himself, which “will provide an updated analysis of the situation of combined transport in Europe, providing new foundations for legislative work”. Another point raised by Tosi is that “the final decision will be up to the Commission, especially given the still divergent positions among Member States in the Council.”

Schultze, in addition, stressed the need for a long-term perspective, highlighting how Tosi and the TRAN committee should be given a chance before a final decision is taken. He also praised the work of the two EU Council presidencies of 2024, led by Belgium and Hungary, hoping that the current Danish one would continue their work on the Combined Transport Directive.

UIRR puts forward six points. First of all, it wants the proposed European Railway Platform (ERP) to act as the advisory body to the European Network of Infrastructure Managers (ENIM). Railway Undertakings, Authorised Applicants, Terminal Managers and their associations should make up the membership of the ERP. The ERP should then review the implementation documents produced by ENIM and in doing so, fulfill the coordination of stakeholders during strategic capacity planning.

Reassurance to customers

Second, UIRR wants a mandated minimum capacity for rail freight operations that “reflects the difficulty of deterring cargo carried by rail from being transferred to other transport modes.” The association adds that that is especially important when bypassing parts of railways that are impacted by infrastructure works.

In order to guarantee a certain level of reassurance to rail customers, infrastructure managers should notify of train path changes at least six months ahead of time. That should also give railway undertakings, authorised applicants and terminal managers enough time to change their plannings.

The money question

Point five and six concern money. UIRR wants penalty payments for short-notice changes or train path cancellations. Right now, there is a proposal to cap those penalty payments, but that would make changes relatively cheap for infrastructure managers. “The disincentivising impact of the penalty towards the infrastructure manager must be reinforced by removing the cap”, says UIRR.

What’s more, UIRR argues for compensations for excessive bypass routes, defined as 50 kilometres or longer. Compensation payments should depend on the length and restrictions caused by infrastructure works, as well as cover additional track access charges, traction electricity costs, locomotive and driver fees, wagon rental costs and terminal disruption charges.

Lastly, the combined transport association wants the scope of the strategic guidance and socio-economic and environmental cost-benefit analysis to be defined in an annex to the Capacity Regulation. It should explicitly list the types of instructions that an EU Member State can issue. “The Annex should contain a methodology description for the socio-economic and environmental cost-benefit analysis to be carried out in parallel. The practical rules pertaining to the two different inputs to capacity allocation should be detailed in the Regulation, primarily focusing on the issues of hierarchy, transparency and method of introduction (deadlines).”

Yet, Europe wants to boost its capacities. For that reason, UIRR has put forward its ideas on how to do that from a CT perspective. Firstly, it wants a clear designation of relevant transshipment terminals for military transports along the four EU military mobility corridors, among which is the Netherlands – Germany – Poland corridor.

Policy tools

Second, in the view of UIRR, those terminals should get priority when bidding for state aid schemes for upgrades. It also wants to update the EU’s Dual-Use Infrastructure Regulation, which specifies requirements for dual-use infrastructure, to cover all unmovable transshipment technologies installed at terminals.

Moreover, CT operators should be recognised in the EU’s Resilience Directive of 2022 as critical entities for organising military transports, and should be incorporated in strategies to enhance their resilience. Lastly, the Combined Transport Directive, Weights and Dimensions Directive, the TSI Telematics Standard, the eFTI Regulation and other policy tools should ensure the “efficient functioning and resilience” of CT operators.

Moreover, weather and construction works stopped an earlier process of recovery: “The good news of the Fréjus line reopening was tarnished by extreme weather, flooding and works-related disruptions throughout the European railway network, bringing the fragile recovery of Combined Transport volumes to a halt during the second quarter of 2025”, UIRR says. The Q2 quarterly performance of CT dropped slightly by 0.16%.

A recent policy change, namely the revised TSI Wagon, is also bound to affect CT negatively. It severely hinders trailer transport by rail. “Approval of the TSI Telematics on the other hand was postponed, giving the Combined Transport Community more time to present its arguments for a business-conform solution”, the CT association adds.

The 9th EU rail market report

At the same time, the European Commission came out with its 9th report on the development of the European rail market. The Commission sees growing competition and low emissions in rail compared to other transport modes, but also persistent challenges. Those include ageing infrastructure, of which 57% is electrified, and staff shortages. Around 40% of the total rail workforce was over 50 years old as per 2022 data.

The Commission also identifies congestion and slow deployment of digital systems, such as ERTMS, a challenge to be overcome for European rail.

Aftermath of the Great Belt Bridge accident

This poses a great problem, as the need for new and safer TSIs for the rail transport of semi-trailers comes from a deadly accident that killed eight people in Denmark in 2019. A semi-trailer loaded on a DB Cargo train crossing the Great Belt Bridge (Storebæltsbroen in Danish) was partially detached due to a weak interlocking mechanism trying to fight too strong winds. This caused the unit to ‘hang’ on the side of the train and be hit by a passenger train coming from the opposite direction, leading to one of the worst rail disasters in Danish history.

Not only safety issues

Other than the lack of testing under extreme conditions, Feyen identified some issues in the device itself and its connection to the wagons. These “requirements appear to be extremely impracticable for most of the wagons currently authorised”, he added. As a result, many wagons for the transport of semi-trailers, vital for the modal shift to rail in Europe, may no longer be used. “It’s an issue that could lead to much greater disruptions to semi-trailer traffic not only for Denmark but also for the whole of Europe”, Feyen alarmed.

Wagon manufacturers seem to share UIRR’s concerns. On multiple occasions, representatives of this industry brought forward various proposals to make the TSI Wagon clearer and make it have a positive impact on safety. Their suggestions included new requirements about crosswind and “a modern design following unified design cases”.

Another issue is that ERA and the European Commission focussed most of their attention on pocket wagons. However, there are other wagon types apt to the rail transport of semi-trailers. “To date there has been no evaluation on other types of wagons such as CargoBeamer, Lohr, Helrom etc…, this rolling stock is also within the scope of the TSI Wagon”, Feyen stressed, adding that “the wagon manufacturers clearly stated that a risk analysis has to be performed for every single series”.

Communication problems

Last but not least, the UIRR specialist underlined a few issues concerning communication between the institutions and the stakeholders. “Many flaws pre-date the starting of the procedure”, Feyen clarified. For example, right after the accident in Denmark, the Danish National Investigation Body asked the National Safety Authority to perform a risk analysis which was never performed. “UIRR has regularly pointed out that a detailed risk assessment on the Great Belt Bridge should be first carried out before proposing any changes to legislation and/or standards”, he said.

Then, there was the Full Impact Assessment, which was never properly discussed by the Joint Network Secretariat (JNS) as it was presented only at a very late stage. UIRR has also submitted a list of questions to ERA and brought them up in various instances. However, “UIRR has not received any official response to this list”, Feyen claimed. Finally, he stated that UIRR was informed of the EC’s revision of the technical document by various national associations rather than directly from the institution. This means that the JNS expert group was bypassed and their responses during public consultation were ignored.