Achive of FEDEMAC's Position Papers

Find beneath the Position Papers that had been launch by FEDEMAC during the 7th Mandate of the EU Parliament (2009 - 2014).

FEDEMAC Position paper on the European Commission Study on Vehicles below 3.5 Tonnes, in the Road Transport Market of the European Union (update 2014)

In a snapshot:

Drivers of LGVs are not subjected to the driver training Directive due to their seize thus creating unfair competition as they may not respect any such as trade law, tax law, driving time limits or social/labour law.

Flexible legislation

No requirement for further regulation for LGVs, shortage of drivers is already too important

SMEs would be burdened with additional costs

Would encourage illegal activities as it would be cheaper to hire a non-regulated driver

Re-evaluation on ban of trucks circulating on weekend. A study based on countries such as the UK, Spain, Irelands and the Netherlands will provide the required information to analyse the real need for such a ban

Pleases download the complete Position Paper here. 

FEDEMAC Position paper on the European Commission proposal “Revision of the Sectoral Road Transport Working Time Directive (No 2002/15/EC). (Update 2014)

In a snapshot:

The inclusion of self-employed drivers should be decided at EU-level

Better law enforcement would be more effective at addressing the issue of “illegal” drivers as supposed to more regulation.

Better definitions of tax regulations and employment regulations would be better suited to tackle illegal work

Pleases download the complete Position Paper here. 

FEDEMAC Position paper on Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain infrastructures, “Eurovignette III” (update 2014)


In a snapshot:

Need for sound legislation, looking after the interest of the environment without hampering the

competitiveness of businesses

All polluters and therefore all vehicles types should be included in the Directive

Using several small trucks pollutes more than one bigger truck

Possible alternatives

Higher taxes on fuel would make an even playing field between all polluters

Tolls on motorway would put in practice “polluters-pay” system

Pleases download the complete Position Paper here. 

FEDEMAC Position paper on the VAT compliancy procedures (update 2014)


In a snapshot:

FEDEMAC appreciate the efforts of the European Commission on the current VAT system in the Europe and calls for further action with the aim to tackle the following difficulties that SMES face:

register with the tax authorities in up to 27 different EU countries;

keep abreast of differing VAT rates in each of those countries;

maintain separate accounts/records for transactions in all those countries;

obtain and complete VAT return forms from each finance authority in all EU languages;

know when VAT payments are due in each of those countries as well as their threshold limits

The consequences being that:

there is a distortion of competition especially between multi-national companies and SMEs

most removal companies are unable to fully comply with the present VAT legislation

national and regional VAT officers are, more often giving incorrect advice

customers/the general public are receiving both conflicting information and different VAT tax charges.

Pleases download the complete Position Paper here. 

FEDEMAC Position paper on Imports from third countries (outside EU) to be delivered into the E.U. Territory.

Present situation and solutions

Pleases download the complete Position Paper here.

Find beneath the Position Papers that had been launch by FEDEMAC during the 6th Mandate of the EU Parliament (2004 - 2009).

FEDEMAC Position paper on EU Import of household goods and personal effects

Updated 01.03.09 (version No 9)

Situation apropos of the import of household removal consignments into the E.U the from countries outside the E.U.

EU Legislation

Quote ‘The Movement of Household Effects imported by natural persons transferring their normal place of residence from a third country to the customs territory of the community are admitted free of import duties and value added tax when the criterion set out in Articles 3 to 10 of Council Regulation (EEC) No 918/83 and Council Directive 83/1281/ (EEC) are met’.

Pleases download the complete Position Paper here. 

FEDEMAC Position pager on security – International Road Transport (update 2008)

Updated 09/10/2008 (‘Security’ - Position Paper No 2)

In the aftermath of 11 September 2001, the Madrid & London bombings and more recently the bombings elsewhere much attention has been focused on improving security in transport and logistics. Initial measures focused on air and maritime transport, attention is now turning to the whole logistic and supply chain, which covers all modes of transport, including the road mode. This is understandable and important to us all but it is only part of an ever worrying concern over safety and security.

Pleases download the complete Position Paper here. 

FEDEMAC Position paper on Urban Mobility (update 2014)


In a snapshot:

FEDEMAC request for the following points be taken into account in relation to Urban Mobility planning:

‘Free-flowing towns and cities’

Approving/harmonising standards, rules, signposting, information

Coordinating best practice

Controlling unfair restrictions on mobility, access or service providers

Ensuring that any ‘charges’ imposed on ‘transport’ are ring-fenced for future development and improvement.

Developing and promoting walking and cycling and the use public transport.

‘Smarter urban transport’

Better dissemination of good practice/information and better use and creation of ‘Intelligent Transport Systems’

Improving parking areas

Interoperable ‘smart cards’ that can be used between transport modes, between various functions (parking/transport related payments/customer loyalty schemes etc), between areas and, in the longer term, between countries.

Informed choice – via better information

Integrated systems that combine intelligent route planning, driver assistance systems, ‘intelligent vehicles’ and interaction with infrastructures

Urban planningcustomers/the general public are receiving both conflicting information and different VAT tax charges.

Pleases download the complete Position Paper here.