SME Chamber

GRTU updated position: Eurovignette Directive

 General remarks

GRTU is critical of the European Commission's proposal on the revision of the Eurovignette Directive 1999/62/EC.

The Commission was asked in 2006 to propose a strategy for stepwise implementation of the model for all transport modes, accompanied if appropriate by a proposal for revising the Eurovignette Directive.

The impact assessment analysis carried out shows a negative impact on growth in the EU from internalisation, but it does not consider whether the same environmental benefits could be achieved in a different, perhaps better way through other political measures.


Furthermore, the impact analysis shows that all modes of transport should be covered by internalisation while the proposal only applies to road freight transport.

The proposal introduces new ways of charging lorries, however, GRTU questions if increasing the cost of road freight transport will lead to the aimed result. The main disadvantage will be more expensive transport without having taken into account the effects on employment, regional development, differences in location, etc. The adjustment costs can be substantial for the economy, particularly when no alternatives are available.

Increasing the cost of road transport will not make transport greener in Europe unless alternative modes or fuels are available.

Specific remarks

Methodology and calculation

The analysis also shows the immense difficulties of collecting and applying correct and precise data. This means that determining the existing degree of internalisation is difficult, but also establishing the correct level of charges to achieve an improved sustainability at local and national level is extremely difficult, if not impossible. Furthermore a charge for noise should be based on the noise effect from the specific vehicle.

Levels charged

It is important that any EU rules puts a limit on how much Member States can charge. It is also important that full transparency exists and the calculations, methods and values applied by Member States are checked by the Commission. A procedure for complaints about the levels of charges must be established.

Congestion charging

The proposal suggests introduction of a congestion charge, but only for heavy good vehicles (HGVs). There is a provision that will allow for extended application of congestion charge  

from 2012, but Member States will still be able not to apply the charge if they are concerned about the effect.

Congestion is caused by all vehicles using the road. A congestion charge only on part of the vehicles will not contribute significantly to a reduced congestion.

Other externalities

For the proposal to have an effect, any further charging must be linked to the existing taxes and charges to determine the overall level of internalisation. To want to introduce CO2 in this proposal, will require that the fuel duties already being paid are taken into consideration. Calculations show, that on that basis road transport already pays more for a ton of CO2 than the existing market price for emission of a ton of CO2.


The revenues from any charges for externalities must be used to reduce the externalities. If the externalities disappear the charges must also disappear. The earmarking of the proposal is in this context an integrated part of the policy instrument and cannot be rejected.

The revenues from external costs should go to the mode of transport that has been charged or taxed. As stated in the impact assessment analysis it is a prerequisite for the achievement of sustainable transport that the revenue is used to improve the conditions that cause the charges in the first place. GRTU is against cross-subsidising particularly in a situation, where road infrastructure is already scarce – leading to congestion and even more pollution and noise.

Expected impact

GRTU finds that co-modality is essential in order to solve the problems of many externalities in transport. However, to make the switch to other transport modes or to promote co-modality in the supply chain, there must be alternatives available which are efficient and effective; at present this is often not the case. Furthermore, alternative modes of transport often only prove to be an option for longer distances and in other places of the supply chain. The "last mile" transport, in particular in city centres, clearly remains road transport.

The commerce sector is continuously put under pressure even more so these days with the already increasing food and fuel prices. The result of the proposal will be more expensive transport rather than a reduction of road freight transport or shift to other modes of transport. In a period of increasing energy and food prices the consumers will be the main victim as the commerce sector will have no alternative than to pass on the costs down the supply chain.

As regards tackling environmental nuisances, more emphasis should be put on infrastructure and technological development. Measures aiming at reducing the negative aspects of freight transport by the commerce sector exist already and the sector continues to achieve effective and cost-efficient solutions. Introducing more charges will not result in less traffic. Instead, the Commission should encourage the taking up of, for example, clean and efficient solutions for vehicles, to provide fiscal advantages for the users of cleaner/efficient/less noisy vehicles, and to increase the use of new technologies and innovative solutions for improved traffic flow.


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