Duisburg: The Combined Transport Directive is back on the Commission’s work plan, confirmed in early September after a period in which the sector had largely written it off. The directive dates from 1992, was last meaningfully amended before the single market was complete, and governs the conditions under which a lorry journey that includes a rail or waterway leg qualifies for regulatory and fiscal advantages. It is short, old, and interpreted differently in almost every member state that applies it.
The revival matters because the definitions in the 1992 text no longer describe how freight actually moves. The directive was drafted around a picture of intermodal transport in which a container left a factory by road, travelled a specified minimum distance by rail, and finished its journey by road within a fixed radius of the terminal. Operators who meet that description qualify for exemptions from cabotage restrictions and, in some member states, reductions in vehicle taxes. Operators who move goods in ways the drafters did not anticipate – semi-trailer transfers, continental intermodal over shorter distances, flows that cross more than two modes – argue about whether they qualify, and national authorities give them different answers.
The industry association representing combined transport operators has pressed for three things: clarified definitions, digitalisation of the proof required to claim the advantages, and compatibility with the electronic freight transport information regulation. The third is the least glamorous and probably the most consequential. eFTI obliges member state authorities to accept freight data in electronic form, and a directive that still contemplates paper stamps at terminals imposes a documentary burden that exists only because nobody updated it. Aligning the two would remove a real cost from a mode of transport the Union spends considerable money promoting.
The modernisation arrives in a policy environment that has changed since the previous attempt. The rail infrastructure capacity regulation entered into force in June 2026, shifting how cross-border paths are allocated and planned. A combined transport regime designed around the assumption that rail capacity is allocated nationally, annually, and on a first-come basis is misaligned with a system moving toward coordinated multi-annual planning. Revising the directive without reference to the capacity regulation would produce two instruments pointing in different directions; revising it with reference to the capacity regulation requires the Commission to take a view on questions the capacity regulation deliberately left to implementing acts.
The harder political question is what the directive is for. The 1992 version treats combined transport as a mode deserving support because it is less polluting than road haulage over the same distance. That justification still holds, but the instrument for delivering it – exemptions from road transport rules – is an odd fit with a policy framework that now includes emissions trading for road transport fuels, weight and dimension rules that favour intermodal loading units, and infrastructure funding that goes directly to terminals. A directive that offers relief from cabotage rules is competing for relevance with instruments that price the externality directly.
The previous attempt at revision failed partly because member states with dense rail networks and member states without them wanted opposite things from the definitions. That divide has not closed. A short minimum rail leg helps continental intermodal in the Rhine-Alpine corridor and does nothing for peripheral states where the nearest terminal is 300 kilometres away. Whatever the Commission proposes, the number in the definition will be negotiated as a national interest rather than a technical parameter, which is how a two-page annex becomes an eighteen-month file.
