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CTG policy statement on the Draft Report on the proposal for a European Parliament and Council directive on Intermodal Loading Units

CTG policy statement on the Draft Report on the proposal for a European Parliament and Council directive on Intermodal Loading Units COM (2003)155-C5-0167/2003-2003/0056(C0D

1. In your Explanatory Statement, you rightly point out to the importance of safety and security aspects.

1.1 The Combined Transport Group (CGT) of the UIC gladly welcomes the initiative to harmonise maintenance procedures of units and to introduce mandatory regular inspections for all units, in line with the principles already laid down by the Container Safety Convention (CSC). Once again, we reiterate our support for an alignment on those principles.

1.2 Your proposed amendment rightly takes into account the economic impact of maintenance procedures, thus recognising that a level playing field between the rail, road and maritime modes needs to be created.

2. In your Report you also clearly state your intention to promote intermodality.

2.1 We can only welcome initiatives going in that direction. However, under Amendment 3, Recital 6a, you propose to encourage the placing on the market and dissemination of European intermodal loading units (EILU) granting tax rebates and other assistance from the EU to those acquiring such units. We feel it is of utmost importance that the development of intermodality is not unduly constrained by legislation if it is to meet its full market potential.

2.2 More over, measures, such as the ones described under 2.1, would not create a level playing field in the intermodal business. It would constitute a clear support to short sea shipping and inland waterways.

2.3 As mentioned in our previous position paper, a new family of intermodal units, versatile enough so that it could be used by all transport modes, would be successful and trigger investment from the industry only if economically viable.

2.4 It should also be noted that harmonising in the field of intermodal units could mean the introduction on the market of a unit with a higher tare weight. This is an expensive price to pay for potentially very little benefit.

2.5 With regard to the need for stackable equipment, one should point out that for a significant number of flows within Europe, where road competition is fierce, customers tend to favour full side access or roof access equipment which is transhipped from rail to road in the terminal and therefore does only occasionally require stackability characteristics.

2.6 During recent years, various units have been developed by swapbody manufacturers. However, the transport market within the EU favours more traditional designs which are better suited to serve the needs of general cargo transport.

2.7 One should also bear in mind that, in Europe, combined transport essentially represents an alternative to road. Over the past 15 years, road has been devising new technical solutions. To ensure and encourage the growth and development of combined transport, it is felt necessary to allow it to develop a range of technical products which respond to market expectations.