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TRANSPORTCEO - 19/01/2018
ESC Position Paper Mobility Package of the European Commission of 31 May 2017.

The European Shippers’ Council represents the interest of more than 75.000 cargo owners in the European Union, both SMEs and large multinational companies. For all of them, transport is an indispensable link to their customers. Efficient and sustainable transport & logistics are therefore critical for the competitiveness of the European industry and the socio-economic welfare in Europe.

In the first part of the Mobility Package published on 31 May 2017, the European Commission is proposing revisions to several directives covering road transport. This position paper addresses the proposals of the first part of the Mobility Package concerning social dimension issues and road charging.

Present-day logistics is based on reliable and seamless supply chains. The legislative initiatives proposed in the European Mobility Package should contribute to the efficient and sustainable road transport and logistics in Europe by avoiding market fragmentation and creating a level playing field across Europe. The initiatives should also ensure that truck drivers can work under fair conditions. A “lex specialis” as contained in the Mobility Package is necessary to meet the specific requirements of mobile workers, such as vehicle drivers, since the general rules on Posting of Workers cannot be applied to the transport sector.

In the past years, the industry was confronted with several national regulations in the field of transport. Examples are national rules on minimum wages and national rules on driving and resting times (weekend rest in the cabin). Differences in national interpretation and enforcement of existing European Directives reduce the benefits of the internal market in Europe, increase compliance costs for companies, and have a negative impact on efficiency in the supply chain.

•Clarity of legislation:
There are still big disparities in the level of wages across different European countries and the systems of social security are not harmonised throughout Europe. To make sure these disparities are not misused by a minority of companies that would engage in unfair practices, clarity of legislation is a prerequisite for a strict enforcement of the European rules.

It is, therefore, important that there is a clear definition of international transport and cabotage operations as well as a clear understanding of the differences between the two. For example, it should be clearly stated when an international transport is transitioned to a cabotage operation and when the rules for cabotage transport should begin to apply. ESC believes that implementation of consistent rules for international and cabotage operations is necessary, not in the least for the sake of simplicity and clarity. This applies, among other things, to the number of days before the minimum wage rules of the host country start to apply.

•Local minimum wages
The European Commission proposes to apply local minimum wages when a driver with his vehicle stays more than 3 days per month outside his home country (‘the same wage for the same service at the same location’ principle).

It is understood that the proposal aims at streamlining the application of minimum wages across Europe and not keeping the present-day patchwork of national wage rules.
However, in ESC’s view, this measure will be disproportionate as it will involve an enormous administrative burden for transport companies to implement it. In addition, it will become very difficult for transport companies to determine the transport costs in advance if these costs vary from month to month depending on the planning of voyages.

The Mobility Package does not take into account the likely future convergence of wages. If the wages across different Member States level out over time, the rules on the social dimension as proposed by the European Commission will become obsolete.

To allow drivers to have an acceptable standard of living during the performance of their job, an adjustment of the system of allowances would be more effective. The expenses coverage should be based on the local living standards/costs of the countries where the transport operation is carried out. It is important to implement an expense payment system that ensures that the allowances are used for increasing the comfort of the driver (e.g. hotel and catering, secure parking, ...) and prevents the use of the allowances as an extra salary.

• Co-liability
Aat present, in some cases, the shipper may be held co-liable if the rules are not respected by the driver, which, in general, is not acceptable. For shippers to assume this responsibility, it is critical that there is open and easily accessible information about transport service providers. This also requires increased information exchange between Member States.

•Long weekend rest In the ESC’s view, it is important that the measures restricting weekly rests in the truck cabin should enter into force only after the necessary measures and infrastructure allowing the secure parking of vehicles and allowing drivers to commute from the parking to a suitable overnight accommodation have been put in place.Despite existing requirements to provide secure parking spaces every 100 km of motorways (Regulation 1315/2-13), there is currently a lack of parking facilities. Moreover, the existing parking facilities are often not equipped with or connected to accommodation options.

•Consequences for driver shortage
Many countries in Europe are confronted with a serious shortage of drivers. In the years to come around 20% of the professional drivers will retire whereas the inflow of professional drivers from the younger generations is low. In addition, it is expected that the transport volume will further increase in the years to come. If not carefully implemented, the Commission’s proposals will further increase the shortage of drivers. It is, therefore, essential that the impact of the Commission proposals on driver shortage is first carefully assessed.

ESC applauds the extension of cabotage from three voyages in seven days to an unlimited number of voyages in five days.

Extended cabotage rules will diminish the percentage of empty running and contribute to solving the problem of the lack of drivers. Enforcement of the rules of cabotage (on which the Commission will put more emphasis) should be done in a stimulating way, for example, by exempting compliant companies. Intelligent control systems based on risk analysis should be applied to check the working schemes of drivers.

The proposed revision of the road charging system is based on the ‘user pays’ principle. This is the appropriate principle to start with aiming at incentivising behaviour towards lower emissions, fewer empty kilometres, more frequent use of alternative fuels, and an optimised payload. Although ESC agrees that the external effects of transport should be internalized, we also believe that the design of the system must be done in a manner that does not jeopardize economic growth and the competitiveness of the industry in different countries. The EU Member States differ and, therefore, should, in ESC's opinion, be able to choose how they want to implement different infrastructure charges and internalize external costs. Furthermore, it should always be possible for Member States to abstain from the implementation of a road charging scheme.

ESC welcomes the opening in the proposal for earmarking revenues from the road charging system for investments in infrastructure.

The option to remove the present minimum level for vehicle tax is a good thing as this tax does not include any incentive for behavioural change. In addition, the following avenues to reduce CO2 emissions and curb other negative effects of transport should increasingly be

•Incentives for fuel use management.
•Increased use of telematics.
•Transition to low-carbon fuels (electric, biofuels, LNG, hydrogen) through pricing mechanisms and development of recharging/refuelling infrastructures.
•Further revision of weights and dimensions of heavy-duty vehicles (to allow for higher payload).
•Permission to continue cross-border transport with longer and/or heavier trucks than the current EU
rules stipulate for the Member States that already allow this in a number of border crossings.
•Further testing of platooning.
•Harmonisation of GHG emissions measurement and reporting based on the GLEC through the Logistics Emissions Accounting and Reduction Network (LEARN) in which ESC is a stakeholder.

For road charging, it is important that all road users are contributing. Regrettably, the Commission in its proposals imposes only certain elements of road charging (such as a congestion charge) of which some apply only to lorries of 12 tons and higher. Before implementing road charging, the national tariff schemes should be analysed to calculate the percentage of costs already covered by the present taxes on mobility.

The introduction of a charging system should not intend to increase taxes. The actual cost of collecting the revenues should not exceed 10% of the total revenues collected by the new system. Depending on the specific national situation in a Member State, there should be on opt-out option.

In ESC’s view, the implementation scheme of the road charging principle is quite ambitious. The short implementation scheme, in particular, for trucks, is not realistic and ESC recommends implementation of the road charging principle simultaneously for private cars and for trucks.

Road charging should be a tool to meet clear objectives. If the idea is to generate funding for up-grading the infrastructural network, the revenues should be earmarked. This should be stated more clearly in the proposals.




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