Road Transport Initiatives Report of Seminars with Stakeholders and Member States

Transcription

1 EUROPEAN COMMISSION Road Transport Initiatives Report of Seminars with Stakeholders and Member States Commission européenne/europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel

2 Table of Contents 1. INTRODUCTION INTERNAL MARKET ISSUES AND ORGANISATION OF ACTIVITIES IN ROAD TRANSPORT Road haulage Introduction Good repute and financial standing Letterbox companies and enforcement Cabotage Vehicles of less than 3.5 tonnes Hired Vehicles Passenger transport Introduction Access to Market for buses and coaches Driving, rest and working time rules and their enforcement Introduction Driving and rest time Working time Enforcement INCREASED ENERGY EFFICIENCY AND REDUCED EMISSIONS OF ROAD TRANSPORT Charging of road infrastructure (Eurovignette) Introduction Insufficient financing Vignettes Price signals and congestion Interoperability of electronic tolls

3 Introduction EU-Wide interoperability Cost of tolling systems WHAT'S NEXT? Disclaimer: The views set out in this report are those of the participants of the informal seminars organised by the DG MOVE. The informal seminars will not replace in any way the public consultations, which are part of the normal legislative procedure. Neither the Commission nor any person acting on the Commission s behalf may be held responsible for the use which may be made of the information contained in the report. 3

4 1. INTRODUCTION In the context of the planned road transport initiatives, as described in the Commission Work Programme , DG MOVE organised a series of five informal seminars during September and October The purpose of the seminars was to present the preliminary findings of the ex-post evaluations of the road transport initiatives and to have a first exchange of views at a very preliminary stage of preparation of the initiatives with stakeholders and with Member States. Ex-post evaluations are a tool to assess whether existing policies have delivered the desired objectives and are ultimately improving the economic, social and environmental conditions for European businesses and citizens. The presentation of the ex-post findings by DG MOVE was followed by comments and discussions with Stakeholders and Member States based on questions sent in advance of the seminars. Stakeholders and Member States were also asked to send their positions in writing after the seminars, which a large majority did. Formal public consultations are planned to follow in the near future, which will concentrate mostly on the following stages of the initiatives, namely on the impact assessments of possible policy options that are meant to address identified shortcomings of the current legislation. The report is structured along the Commission priorities under which the road transport initiatives formally belong, i.e. the Internal Market and the Energy Union. Chapter 2 'Internal Market issues and organisation of activities in road transport', will address issues related to market aspects and the rules on the organisation of work of drivers and their enforcement. Chapter 3 'Increased energy efficiency of reduced emission of road transport', will address road charging issues and Chapter 4 'What's Next?' will describe the next steps of the preparatory process. 1 2 COM(2015)610 final. See Annex 1 4

5 2. INTERNAL MARKET ISSUES AND ORGANISATION OF ACTIVITIES IN ROAD TRANSPORT 2.1. Road haulage Introduction While some progress has been made in terms of the objective to ensure a more level playing field between transport operators, particularly regarding the establishment of common minimum requirements for stable and effective establishment, the ex-post evaluation of the Commission identified remaining issues related to the presence of letterbox companies, differing national interpretations of current rules (including rules on cabotage) and uneven monitoring/enforcement. From a general perspective, Member States and stakeholders broadly supported the expost findings of the Commission. It was the general position of Member States that current market and social rules in road transport are sufficient in scope but that clarification and simplification are needed to ensure legal certainty, fair and adequate business and working conditions as well as reduced administrative burdens for users Good repute and financial standing It was identified during the ex-post evaluations that Member States apply rules related to good repute and financial standing differently. There are great variations between Member States in terms of the severity of violations of these rules. For instance, some Member apply the current rules strictly and declare several hauliers unfit leading to the loss of the good repute and the Community licence, while other Member States show no records of having declared any haulier for unfit. This situation creates uncertainty and different conditions among hauliers from different Member States, which results in an un-level playing field. It was the opinion of the Member States who commented on the issue that current rules are unclear and should be clarified. Stakeholders confirmed the opinion of Member States and reported on additional inconsistencies in application of the current rules. E.g. in some Member States the accountability for infringements potentially leading to the loss of good repute lies with the operator, while in other Member States drivers are held accountable Letterbox companies and enforcement The issue of letterbox companies, characterising companies with no real activity but established in a given Member States with the only purpose of benefitting from more lenient labour and social rules, was underlined by the vast majority of Member States and stakeholders. 3 Regulations (EC) No 1071/2009 and (EC) No 1072/2009 and Directive 2006/1/EC 5

6 Letterbox companies seem to be a growing phenomenon in several Member States across the EU as they potentially provide road hauliers with an economic advantage of up to 30%. The control of such companies is under the responsibility of the Member State where they are established. However, evidence suggests that Member States have mixed incentives to control letterbox companies, which frequently results in low levels of enforcement. Member States and stakeholders largely agreed that current EU rules on access to the profession of road transport operator, in particular the criteria on the establishment of road transport undertakings, have been ineffective in reducing the number of letterbox companies. It was the general opinion that there would be a need for further clarification related to the criteria applied on stable and effective establishment. Several Member States also mentioned that existing rules should be better enforced by host Member States but also via strengthened cooperation between Member States on exchange of information. For example, it was suggested that host Member States should be required to act quickly upon requests from other Member States to investigate potential cases of letter box companies. A few other Member States however considered that such requirements would put a strain on resources of enforcement officers. On the topic of strengthening administrative cooperation, it was considered by some Member States that priority should be given to improving already existing tools (i.e. European Register of Road Transport Undertakings - ERRU) to facilitate such cooperation. Responses from stakeholders suggested that the functioning of ERRU should be improved, both in terms of data exchange between Member States and to enable integration with the risk rating systems of transport undertakings Cabotage The ex-post evaluation showed that current rules on cabotage are unclear and hardly enforceable. Some Member States have decided to implement own rules in response to this situation. These national rules are in all cases different and more restrictive than current EU rules. Member States and stakeholders broadly confirmed that current rules on cabotage are unclear and unenforceable, which in the view of some Member States is leading to an abuse of current provisions. An example of an unclear rule, which was menrioned, was the definition of a cabotage operation and whether a cabotage operation can comprise several pick-ups and/or drops. Additionally, the non-obligation to carry documents onboard vehicles was considered an issue in terms of enforcing the number of permitted cabotage operations. Although there was a common agreement about the goal to fully liberalise cabotage in the long term, Member States were divided as to whether to relax current cabotage rules or whether to maintain or to restrict these in the shorter term. Some Member States stated that while social conditions are so different across the EU, current restrictions cannot be relaxed. Others emphasised that current rules are restricting the Internal Market for road transport and that different social conditions in particular levels of salaries always have been and will remain a reality in the EU Internal Market. 6

7 As a possible way of clarifying the current rules on cabotage, some Member States supported a reduced time limit within which cabotage operations would be un-restricted. A time limit would be easier to enforce using the tachograph to control operations and it would overcome most of the ambiguities of current rules, e.g. the definition of a 'cabotage operation'. A few other Member States, as well as some stakeholders, stated that current rules are adequate. Enforcement issues were considered to be a question of either resources or lack of adequate tools to control the current limitations to cabotage, which in the latter case could consist of the next-generation of digital tachograph having in-built geolocalisation. A few other Member States strongly insisted on the need to draw a line between combined transport and cabotage. It was considered that combined transport should not be exempted from cabotage rules as this may create a loophole for operators Vehicles of less than 3.5 tonnes Vehicles of less than 3.5 tonnes are not subject to EU transport rules on access to profession or market, or on driving and rest times. As a result, there seems to be evidence that these vehicles are becoming more competitive relative to Heavy Goods Vehicles and that they are increasingly used in international transport of mainly time-sensitive and high-value goods. Some Member States have adopted national rules on access to the profession and on driving/rest time for vehicles below 3.5 tonnes, and in a few cases also on access to the market (i.e. cabotage). The positions of these Member State were generally to extend the scope of at least some of the current EU rules to vehicles below 3.5 tonnes. Other Member States raised concerns related to subsidiarity and administrative burdens should vehicles below 3.5 tonnes be made subject to EU rules. It was voiced that any additional measures applying to these vehicles would have to be based on solid evidence and assessment. Stakeholders were divided on whether to support an extension of EU rules to vehicles below 3.5 tonnes. There was a general consensus however that, in the event of an extension of EU rules to vehicles below 3.5, it should apply to hire-and-reward operations only and not to own account operations Hired Vehicles The current rules on hiring of goods vehicles have been in place since 1990 (Directive 2006/1/EC was a codification of earlier rules). They liberalise the use of hired goods vehicles under certain conditions. At the same time, they allow Member States to restrict the use of hired goods vehicles (whenever the vehicle is not registered in the country where the undertaking hiring it is established or when a vehicle of more than 6 tonnes is to be used for own account purposes), which seems to go against current policy priorities of establishing a Single European Transport Area. As hired or leased vehicles are usually newer, cleaner and greener, possible restrictions on their use may also slow down the decarbonisation of transport. 7

8 The ex-post evaluation of the Commission confirmed that current rules on hiring goods vehicles may indeed go against central policy objectives of the EU. This was supported by some Member States who indicated that they would be in favour of removing at least some of the current possibile restrictions. Some other Member States had reservations regarding such a move, notably in view on the link with the registration of vehicles and the payment of vehicle taxes. Stakeholders were of the view that the growing market for hire and leasing of vehicles should be reflected by a change in EU rules. Stakeholders commented that it was almost impossible for a hire-and-reward company to hire a vehicle in a Member State other than the one where it is established and that this can cause difficulties when vehicles break down in other Member States. The majority of stakeholders were in favour of removing the possibility to forbid the use of hired heavy goods vehicles for international transport. A further suggestion was to introduce a time limit for the hire period, possibly up to six months. 2.2 Passenger transport Introduction It was established by ex-post findings that market access conditions for domestic regular passenger transport services by buses and coaches vary across the EU from being open to being closed, with several intermediate models. The state of market opening largely depends on national market traditions and on historical powers of the rail sector and on local monopolies. Recent examples of opening of markets for bus and coach services have shown a boom in service offerings at low fares benefitting mainly young people and lower-income segments. This has contributed to improving accessibility and mobility in general. Also, ex-post findings showed evidence that operators in many cases suffer from discriminatory access to bus and multimodal (road-rail and road-air) terminals, which prevents them from providing effective and competitive services. Furthermore, it inhibits the consolidation of large volumes of passengers for intercity travel and the enhanced integration of the modal networks. Currently, access to such terminals is not regulated by EU law Access to Market for buses and coaches A prevailing view of Member States confirmed that market access conditions differ significantly. While some Member States recommended common EU rules on access to the market for buses and coaches, other Member States advocated broad principles and the freedom for Member States to regulate according to national circumstances. It was mentioned by some that a one-size-fits-all model would not be appropriate. 4 Regulation (EC) No 1073/2009 8

9 A majority of Member States supported EU rules on access to terminals. Several Member States mentioned that such rules would ensure fair and equal access for operators, and that users ultimately would benefit from a wider choice of services. Stakeholders also confirmed the findings of the ex-post evaluation. It was noted that the international coach market is changing fast and that there is latent demand for bus and coach travel with a potential for transferring users from cars as has been seen from recent examples of market opening. However, different approaches between countries, and notably the protection of national railways, make it cumbersome for bus and coach operators to enter markets and to provide competitive services. 2.3 Driving, rest and working time rules and their enforcement Introduction The preliminary ex-post evaluation findings confirmed that certain rules in force are not sufficiently clear, which has given rise to different interpretations of EU rules and diverging enforcement practices between Member States. As a consequence of lacking clarity, Member States are increasingly taking own measures based on national interpretations. These own-rules are by nature uncoordinated and allegedly protectionist (such as those in France and Belgium imposing severe sanctions for taking the regular weekly rest in the vehicle). Drivers, operators, enforcement and public authorities are suffering from this situation which is leading to legal uncertainty, an un-level playing between operators and in some instances disproportionate regulatory burdens. Other problematic issues identified by the ex-post evaluation were: (i) poor administrative cooperation between Member States, which weakens the efficiency of cross-border enforcement and (ii) lack of flexibility of the rules on driving times, breaks and rest periods, which are not well-tailored to the specific needs of certain transport services and not reflecting market developments. From a general perspective, Member States almost unanimously called for stability of the existing legal framework while insisting on a targeted revision with the aim of clarifying certain provisions, which are considered unclear or difficult to enforce. Member States were generally of the opinion that the current situation leads to a fragmentation of the Internal Market, distortion of competition and to negative impacts on working conditions Driving and rest time A large majority of Member States supported the ex-post evaluation findings indicating that flexibility in the application of certain rules is necessary to meet the sector's specificities and needs. In particular, increased flexibility was requested for specific transport services, such as heating oil distributors and local constructions sites deliveries or the whole passenger transport segment. Also long distance international transport 5 Regulation (EC) No 561/2006, Directives 2002/15/EC and 2006/22/EC 9

10 operations, in particular those carried out from/to peripheral countries, would need more flexibility in taking the daily and/or weekly rest. Stakeholders noted that current rules are overly rigid and not well adapted to the current, competitive, business environment from operator and driver perspectives. Seasonal businesses in particular were considering needing more flexibility. As regards the issue of rest periods, Member States and Stakeholders raised the question of whether drivers should be allowed or not to spend their regular weekly rest in the cabin of the vehicle. It was the position of many Member States that the current rules on driving and rest time periods do not explicitly forbid taking the regular weekly rest in the vehicle. A few other Member States were of the opposite opinion, according to which current EU rules allow Member States to adopt national rules which forbid drivers from taking the regular weekly rest in the cabin of the vehicle. According to these, current practices lead to a deterioration of working conditions and jeopardise road safety. The majority of Member States agreed that the current EU rules should be clarified to avoid diverging national practices. Many Member States voiced that it would in particular be required to take account of insufficient resting facilities and secure parking areas as well as the freedom of drivers and operators to decide where to spend the regular weekly rest. Stakeholders agreed that current rules on regular weekly rest are unclear but they were divided on how rules should be clarified. Some stakeholders argued that a total prohibition of regular weekly rest in the vehicle would put the economic viability of many road transport SMEs at risk. It was also noted that the character of road transport naturally implies, in case of long-distance transport operations, the absence of drivers from their base for longer periods. Some other stakeholders mentioned that more than two weeks of consecutive rest taken in the lorry could be detrimental to occupational health and safety but that drivers should be allowed to take at least one regular rest in the cabin. Representatives of workers considered that the regular weekly rest should be taken outside the vehicle Working time The ex-post evaluation identified two main issues in relation to the working time directive, i.e. the extent of the value-added of the directive in combination with the existing driving and rest time rules and the general working time directive 6, as well as the justification and enforcement of working time rules for self-employed drivers, who were included in the scope of the directive in Several Member States were of the position that the working time directive provides little or no added value to the driving and rest time rules. It was stated that the driving and rest time rules were sufficient to ensure a level playing field as well as appropriate working conditions and road safety. It was also stated that the rules on working time were difficult, if not impossible, to enforce, especially for self-employed drivers who by nature - besides driving - have a number of other tasks than driving, which are in practice not recorded. Several Member States argued that self-employed drivers should be excluded from the working time directive. 6 Directive 2003/88/EC 10

11 A smaller group of Member States maintained that the working time directive provides added value, notably in terms of the specific definitions related to the transport sector in the directive. Reponses from stakeholders indicated a general agreement that there is a sufficient level of protection for drivers through the driving and rest time rules. There also appeared to be a general agreement among stakeholders that should the specific working time directive be retained, self-employed drivers should be excluded from its scope Enforcement Ex-post evaluations showed that current minimum EU requirements for controlling compliance with the social rules are not sufficient to ensure consistent and effective cross-border enforcement. National enforcement practices diverge widely, they are not cost-effective and the use of existing control tools and data exchange systems is unsatisfactory. Most Member States agreed that current control practices diverge and that they should be better coordinated. It was also the view of these Member States that coordinated controls are necessary to ensure more cost-effective cross-border enforcement. A smaller group of Member States highlighted that exchange of experience and best practices in enforcement as well as data on infringements should be improved. Stakeholders reported that country-specific and, in some cases, regional enforcement practices have developed in different directions, slowing down harmonisation and undermining regulatory clarity and competition. Most stakeholders considered that a road agency should be established to ensure better cooperation between Member States, in particular as regards enforcement of the current legislation and monitoring of market developments. However, with the exception of one Member State, there was no demand for a Road Agency as a support for more coordinated enforcement. 11

12 3. INCREASED ENERGY EFFICIENCY AND REDUCED EMISSIONS OF ROAD TRANSPORT 3.1. Charging of road infrastructure (Eurovignette) Introduction The rules on road charging, and in particular the so-called "Eurovignette" Directive 1999/62/EC, have been an important instrument to pave the way for fair and efficient pricing in transport and for infrastructure financing. Ex-post evaluation findings uncovered that (1) Only a small part of the total EU network is subject to user charges or tolls and revenues are not always reinvested in the tolled network, which may result in degrading infrastructure quality. (2) Although there has been some convergence, a great variety of different schemes exist (with some Member States having no road charging in place at all), which leads to inconsistent price signals, suboptimal transport behaviour, undue emissions and, in some cases, traffic diversion. (3) Time-based vignette systems may discriminate occasional users of both HGVs and light vehicles. (4) In addition, not only urban but also interurban congestion add great costs to the EU economy Insufficient financing Infrastructure deterioration is a growing concern in several Member States where infrastructure, built for a large part during the same period, is reaching a state where more structural and costly maintenance is becoming warranted. Member States were generally of the opinion that flexibility is required to spend revenues from road charging according to national priorities and according to national decisions. Others echoed that it is important to respect subsidiarity in the area of infrastructure and maintenance financing. Stakeholders on the other hand, and particularly road users, stressed that earmarking of revenues and proper maintenance of roads is a prerequisite for acceptability of user charges. It was also stressed that user charges and earmarking should be seen in a wider context of providing users with incentives to encourage improved economic and environmental performance of the road transport sector Vignettes Recent cases have indicated that vignettes, which are time-based user charges as opposed to distance-based tolls, can be discriminatory. This is mainly due to the nature of vignettes being inherently less reflective of infrastructure costs and of pollution, i.e. not fully respecting the user and polluter pays principles. Short-term vignettes, which are typically bought by foreigners, are proportionally more costly than annual vignettes. Private cars - for which no EU legalisation on road charging exists - are relatively more exposed to discrimination than HGVs. 7 Directive 1999/62/EC as amended by Directive 2006/38/EC and by Directive 2011/76/EU 12

13 Rates of vignettes for HGVs are currently capped by the Eurovignette Directive, which is limiting possible revenues and thus indirectly the funds available for maintenance. On the background of the identified issues above, some Member States advocated phasing out vignettes and replacing these with distance-based tolls collected with the help of interoperable on-board units. Several other Member States, however, thought that the flexibility of the current Eurovignette framework should be maintained, at least in the short to medium term. A positive aspect of vignettes was considered to be their relative simplicity and low administrative costs, in particular in countries having low volumes of transit traffic. Views were divided as to whether the issue of discrimination of passenger cars should be addressed by an extension of the Eurovignette framework. A slight majority were in favour of including passenger cars while others were against in order not to increase the cost burden. One particular stakeholder representing passenger car users stated that when discussing infrastructure funding, existing taxes should not be forgotten to ensure that passenger cars do not pay more than their fair share of total costs Price signals and congestion Price signals provided to road users are varying to a great extent between EU Member States, ranging from Member States having no user charges or tolls in place to Member States recovering 100% of infrastructure costs as well as external costs on parts of their road network. Between these two extremes, price signals differ widely due to various applications of notably differentiations according to EURO class of vehicles as well as due to variable infrastructure cost recovery rates and calculation methods. All these different price signals provided to road users engaged in international traffic create conflicting incentives and sub-optimal behaviour. Whilst most Member States expressed their support for the application of the user and polluter pays principles, only some requested measures to ensure clearer and more effective price signals. For instance, some Member States currently charging for external costs, or planning to do so, proposed to review caps currently imposed on external cost charges. It was also proposed by some to allow a differentiation of user charges and tolls based on CO2 emissions to incentivise the use of more climate-friendly and fuel-efficient vehicles. In addition, one Member State asked for a clarification of the interest rate used in infrastructure cost calculations considering that interest rates otherwise may be used to artificially inflate costs and thus to increase tolls. Views were divided on the possibility to allow Member States to charge for congestion as an additional charge rather than, as presently, a variation of user charges and tolls. Whilst some Member States were in favour, others did not consider that a congestion charge would impact behaviour given that international hauliers are unable to avoid main congestion centres at some stage of their international journey. As a consequence, it was considered by some that a congestion charge may add costs and not significantly contribute to reducing congestion. Stakeholders confirmed that clear and consistent price signals were important given the highly competitive nature of the road haulage sector. It was noted that recent evidence (Germany was cited) has demonstrated that clear price signals have contributed to 13

14 reducing empty running and to the use of more environmentally friendly vehicles. It was also noted that in view of vehicle investment decisions, advance warning of fluctuations of road user tariffs and circulation taxes would be beneficial Interoperability of electronic tolls Introduction The aims of having a European Electronic Toll Service (EETS) in place for trucks and buses in October 2012, and for passenger cars and light goods vehicles in October 2014 have not been reached. The lack of interoperability of toll services in the EU is source of unnecessary costs for users; it is also one of the reasons why setup and operation costs of electronic tolling system remain high. The main identified reasons for the failure of the EETS legislation are: (1) The incorrect application of EU law by the Member States and discriminatory treatment of new entrants; (2) Technological and procedural differences between national e-tolling systems, largely due to the lack of reference in the legislation to specific, mandatory standards; (3) The conditions defined by the EETS Decision do not create a fair and favourable business framework for EETS providers; (4) The level of ambition of the legislation was too high, creating expectations which cannot be met by EETS providers at reasonable costs (e.g. coverage of all toll domains in the EU within 24 months; obligation to offer EETS to private car users); (5) There are no specific provisions on cross-border co-operation for enforcement of tolls EU-wide interoperability The current situation of lack of interoperable tolling services in the EU is obliging road users to carry several different on-board units when engaged in international journeys. This situation is adding unnecessary costs to operators in terms of administrative burdens and time losses. Member States generally agreed that the current legislative framework is insufficient to provide for EU-wide interoperability of tolling services. In particular, market access conditions imposed on EETS providers are in some cases overly restrictive and do not allow entering markets on similar conditions to those applicable to incumbents service providers. A few other Member States were of the opinion that the current legislation framework is sufficient. A majority of Member States also felt that the scope of the current legislative framework could be reduced to facilitate the introduction of interoperable tolling services. For 8 Directive 2004/52/EC and Commission Decision 2009/750/EC 14

15 instance, the scope could be reduced to include HGVs only, as opposed to also passenger cars at least in the short run, and the scope could be reduced to no longer requiring coverage of tolling services in all Member States but rather a regional coverage. Stakeholders agreed that the current lack of interoperability significantly adds to administrative burdens and costs. It was noted that almost all trucks engaged in international haulage are equipped with at least three to four on-board units and the operators have to sign contracts and carry out separate transactions with this same number of service providers Cost of tolling systems The costs for developing, implementing and operating tolling systems are generally very high. This is due to Member States developing unique systems based on tailor-made specifications rather than seeking to use or to extend existing systems. Consequently, users have to pay high system costs in addition to road user costs, which results in higher tolls and in lower user acceptability. Another consequence is that some Member States refrain from implementing expensive tolling systems and rather opt for more basic vignette systems. In response, a majority of Member States accepted that further standardisation may be a solution to avoid tailor-making and to ensuring lower system costs. There were different opinions among Member States as to how standards should be developed, and in particular in which context. It was noted that either the Commission could be charged with the responsibility or that independent standardisation bodies could be involved. A few Member States were of the opinion that existing standards are sufficient. The issue of toll evasion was also identified during the ex-post evaluation. It can result in a loss of tolling revenues for Member States. A majority of them supported enhanced cross border enforcement. 15

16 4. WHAT'S NEXT? While not being part of the formal procedure for the preparation of legislative proposals, the informal seminars described in the report were very positively received by Member States 9 and by stakeholders, and they gave the Commission an important feedback on the preliminary results of the ex-post evaluations of current EU transport rules. The next steps in the preparation of the Road Initiatives will be: (1) A completion of the ex-post evaluations to confirm the findings presented and discussed during the seminars (2) Based on the ex-post evaluations, define policy options to be assessed in Impact Assessments. As part hereof, the Commission will organise public consultations (3) Prepare policy proposals based on the preferred policy options retained in the Impact Assessments to be adopted by the Commission In addition to the public consultations mentioned above, the Commission will continue to involve stakeholders and Member States. To this end, the Commission will organise a conference on the planned road initiatives on 19 April 2016 and it could be envisaged to organise further informal seminars. 9 The REFIT Meeting in De Hague on 15 January 2016 involving Member States referred to the seminars as best-practice and requested the organisation of such seminars to be repeated 16

17 Annex 1: Seminars and participants Title Date Participants Market and social affairs 28 September 2015 IRU ETF CLECAT ESC LeaseEurope UETR UEAPME UIRR Passenger transport 09 October 2015 Road charging 16 October 2015 Social issues 23 October 2015 EPF Eurolines EPTO UITP IRU T&E AETIS AGES ASECAP ERF FIA CEDR CLECAT IRU Business Europe UETR UEAPME FIEC ECR TISPOL IRU UETR ETF CORTE ETSC CER Seminar with Member States 29 October 2015 All Member States 17