The Swedish Forest Industries Federation (Skogsindustrierna), thanks for the opportunity to participate in this call for evidence. We look forward to the Commission's public consultation on the coming revision on European Directive 96/53/EC later this year.
The Swedish Forest Industries Federation is one of the largest industry branches in Sweden. The industry is also one of the largest cargo owners, also called shippers, with 25 million tons of finished goods exported every year, mainly to European destinations but also worldwide. Besides exports, the forest industry also transports raw materials to the mills and factories and account for almost 25 percent of all lorry transport within Sweden. Therefore, the sector has for a long time worked at minimizing transport costs and emissions, and actively participates in research programs that focuses on efficiency. In 2009 the Swedish Forest Industries Federation launched a trail with a vehicle that was 30 meters long and with a Gross Vehicle Weight of 90 tons. Numerous studies have been conducted on this vehicle with regards to safety and reduced emissions. As a result of research and trails, vehicles of Gross Vehicle Weight of 74 tons and a length of 25.25 meters have been implemented in Sweden on specific roads from 2018.
With more than a decade of research by highly qualified research institutes in Sweden as well as government funded studies it can be concluded that longer and heavier vehicles are safer and reduces emissions substantially. Also, the vehicles are cost-effective and optimize supply chains.
As the EU Green Deal also points out the urgency to reach climate ambitions and lower emissions from transport, it is essential that efficiency and innovation is implemented in all modes of transportation as part of the Sustainable and Smart Mobility Strategy and its action plan. Several member states have already implemented longer and heavier vehicles within national transportation as it is a way of reaching lower emissions and reach higher efficiency in transport. This is a very important work that has been carried out in member states and the EU COM should encourage more of these schemes.
The Swedish Forest Industries proposes the following changes in the Directive 96/53/EC:
- The European Modular System should be the basis for combinations in the directive, which gives harmonization and flexibility with innovation at the same time.
- The current limitations for border crossing should be amended. There should be no limitations on weights and dimensions if the countries of both sides of the borders allow the weight and dimensions. Also width should be set to 2.6 for safety reasons.
- There should be no restrictions on number of border crossings if countries passed allow the weights and dimensions.
- EU COM should harmonize what the modules are part of European Modular System, with the aim of adding more modules already in use.
- Use of larger high-capacity vehicles, should not be tied to alternative fuels or zero emissions as it could lead to a negative effect. Incentive or other directives is more suitable to regulate that.
