ECG - The Association of European Vehicle Logistics - represents over 100 leading automotive logistics companies (ranging from family-owned SMEs to multi-nationals) from 27 countries across Europe, including the Western Balkans, Norway, Switzerland, the Russian Federation, Ukraine, and Turkey. Effectively using all modes of transport (though with a particular focus on a unique product, namely finished vehicles), ECG members own or operate over 500 car carrying ships, 16,000 purpose-built railway wagons, 25 river barges and over 22,000 specialist road transporters.
We therefore very much welcome a Commission initiative to look at how it could support the further development and uptake of electronic documents for freight transport, of which this IIA is a first step, especially considering that 2018 has been designated the Year of Multimodal Transport.
Overall we agree with the problem statement and proposed solutions to be studied further, as well as the main focus being on the lack of recognition and acceptance (mainly by Member States) as well as the need to further standardise e-documents to ensure the interoperability of different (modal) systems.
While the use of e-documents in all modes should be looked at, we believe the current "low-hanging" fruit lies within the road transport sector which is why we have published a joint statement with the IRU on e-CMR (available on our website and also attached to this feedback form). In it we call for all European countries to ratify the 2008 e-CMR Protocol without delay, as there is no excuse - political or technical - not to do so.
Some of the obvious benefits we see, which also count for all modes of transport:
• A digitised transport chain requires less paper, so it is better for the environment.
• e-documents save on printing costs.
• The electronic application is multi-lingual, facilitating international transport and controls by national authorities.
• Electronic documents are cheaper to process, with no costs implied for archiving.
• Currently, paperwork gets processed only when drivers return to the office, whereas electronic documents can be handled in real time.
• Improved supply chain visibility with electronic consignment notes could help enforce European laws, such as those in the road transport sector.
ECG will continue supporting this Commission initiative, and aims to contribute with more specific input at the later stage of the stakeholder consultation.
The views and opinions expressed here are entirely those of the author(s) and do not reflect the official opinion of the European Commission. The Commission cannot guarantee the accuracy of the information contained in them. Neither the Commission, nor any person acting on the Commission’s behalf, may be held responsible for the content or the information posted here. Views and opinions that violate the Commission’s feedback rules will be removed from the site.