Combined transport: quota-free road legs and vehicle-tax relief under Directive 92/106/EEC

Directive 92/106/EEC defines combined transport as the carriage of goods between Member States in which the road vehicle or loading unit (lorry, trailer, semi-trailer, swap body or container) travels the initial or final leg by road and the other, main leg by rail, inland waterway or maritime service. Two distance tests govern eligibility. First, the non-road leg must exceed 100 km as the crow flies. Second, the road legs must stay within a defined limit: for a rail main leg, between the point of loading and the nearest suitable rail loading station (and, at destination, between the nearest suitable rail unloading station and the point of delivery); for an inland-waterway or maritime main leg, within a radius not exceeding 150 km as the crow flies from the port of loading or unloading. A movement that breaches these limits is ordinary road transport, and the directive's benefits do not attach to it.

For trips that qualify, Article 2 required Member States, by 1 July 1993, to liberalize the operation from all quota systems and systems of authorization — the controls that would otherwise apply to road haulage. Article 4 reinforces this by granting every haulier established in a Member State the right to carry out the initial and/or final road legs that form an integral part of a combined transport operation. The practical effect is that the short road legs are treated as part of the intermodal chain rather than as separate national carriage, so a movement that would otherwise run into quota or authorization limits can proceed. Whether a specific movement benefits depends on it satisfying the Article 1 conditions and being evidenced accordingly, so the exemption should be treated as conditional rather than automatic.

Article 6 requires Member States to reduce or reimburse the taxes applicable to road vehicles when those vehicles are routed in combined transport, either by a standard amount or in proportion to the journeys the vehicles make by rail. Because the measure is implemented nationally, the amount and mechanism differ by country, and relief is likely to be available only where the national administration has actually put Article 6 measures in place and where the operator can show the vehicle was used on a qualifying combined-transport trip. Operators should therefore verify the specific national scheme in each Member State concerned rather than assume a uniform EU-wide reduction applies to their fleet.

Article 3 makes the benefits contingent on proof. A transport document must specify the rail loading and unloading stations for the rail leg, or the inland-waterway or maritime loading and unloading ports for the water leg. Those particulars must be recorded before the operation is carried out and confirmed by a stamp affixed by the rail or port authorities once the rail or waterway section has been completed. Without this documentary trail, a haulier stopped in a roadside inspection is unlikely to be able to demonstrate that the movement is combined transport, in which case the exemptions are likely to be refused. The stamped document is therefore the practical hinge on which eligibility turns, and it should be prepared as part of the booking rather than reconstructed after the fact.

In 2023 the Commission proposed amending the directive (COM(2023) 702 final, procedure 2023/0396(COD)) to add a support framework for intermodal transport. The proposal would set a target of reducing the total cost of combined transport operations by at least 10% within 90 months of entry into force, redefine eligibility around environmental performance — requiring an operation to produce at least 40% lower external costs than the equivalent road-only journey — and shift evidencing onto electronic freight transport information (eFTI) platforms in place of stamped paper. However, co-legislators have not agreed the text. The European Parliament's Legislative Train Schedule (status 20 June 2026) records that the file was included in the Commission's 2026 Work Programme list of proposals to be withdrawn, that a formal withdrawal decision is expected, and that Parliament's TRAN committee coordinators objected. Until any successor is adopted, Directive 92/106/EEC in its current form remains the governing framework, and the 10% and 40% figures describe a proposal that may never enter into force.

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