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Thursday, 19 January 2017 - Strasbourg
Logistics in the EU and multimodal transport in the new TEN-T corridors

European Parliament resolution of 19 January 2017 on logistics in the EU and multimodal transport in the new TEN-T corridors (2015/2348(INI))

The European Parliament,

–  having regard to its resolution of 9 September 2015 on the implementation of the 2011 White Paper on Transport: taking stock and the way forward towards sustainable mobility(1),

–  having regard to its resolution of 2 December 2015 on sustainable urban mobility(2),

–  having regard to its resolution of 4 September 2008 on freight transport in Europe(3),

–  having regard to its resolution of 5 September 2007 on freight transport logistics in Europe – the key to sustainable mobility(4),

–  having regard to Regulation (EU) No 1315/2013(5) and Regulation (EU) No 1316/2013(6),

–  having regard to Regulation (EU) No 913/2010(7),

–  having regard to the Commission’s White Paper ‘Roadmap to a Single European Transport Area – Towards a competitive and resource efficient transport system’ (COM(2011)0144),

–  having regard to the Commission’s communication entitled ‘Accelerating Europe’s transition to a low-carbon economy’ (COM(2016)0500),

–  having regard to the Commission’s communication entitled ‘A European strategy for low‑emission mobility’ (COM(2016)0501),

–  having regard to the Commission’s communication entitled ‘Strengthening European Investment for jobs and growth: towards a second phase of the European Fund for Strategic Investments and a new European External Investment Plan’ (COM(2016)0581),

–  having regard to the Commission’s communication of 16 February 2016 entitled ‘An EU strategy for liquefied natural gas and gas storage’ (COM(2016)0049),

–  having regard to the Rotterdam Ministerial Declaration of 20 June 2016 on Implementing the Trans-European Transport Network (TEN-T)(8),

–  having regard to the issue papers prepared by the European Coordinators on the TEN‑T corridors for the 2016 Rotterdam TEN-T days(9),

–  having regard to the Corridor Work Plans, drawn up by the European TEN-T Coordinators,

–  having regard to Court of Auditors Special Report No 08/2016: Rail freight transport in the EU: still not on the right track(10),

–  having regard to Rule 52 of its Rules of Procedure,

–  having regard to the report of the Committee on Transport and Tourism and the opinion of the Committee on the Environment, Public Health and Food Safety (A8-0384/2016),

A.  whereas modern efficient transport and logistics are essential for the effective functioning of the EU’s internal market and important for ensuring competitiveness, creating new business and employment opportunities, protecting the environment and mitigating climate change by reducing carbon dioxide emissions in transport;

B.  whereas the third goal of the Commission’s White Paper on Transport aims to shift 30 % of road freight over 300 km to more sustainable modes such as rail and waterborne transport by 2030, and more than 50 % by 2050, requiring also the development of appropriate infrastructure; whereas the European transport policy and TEN-T can make an important contribution to achieving the Union’s climate goals and the objectives of the COP 21 Paris Agreement;

C.  whereas a forward-looking EU logistics policy should strive to help the logistics sector maintain its global competitiveness and contribution to the growth of the EU economy in the light of evolving economic, societal and technological trends and trade links worldwide;

D.  whereas the TEN-T policy aims at enabling efficient, smart and sustainable transport, and whereas future-oriented logistics and multimodal transport solutions call in a particular way for cross-sectorial cooperation;

E.  whereas multimodal transport links between ports, airports, multimodal platforms and the core TEN-T corridors and other sections should be prioritised to drive forward the EU’s economy and job creation;

F.  whereas the TEN-T core corridors stimulate synergies through strengthened emphasis on terminals and urban nodes as well as through the integration of intelligent and clean fuel transport systems, and whereas the complementarity access function of the comprehensive network is also vital;

G.  whereas there are still considerable differences between the Member States in the levels of transport efficiency and effectiveness, as they are a reflection of their economic strength, the role of industry in the countries, and their geographic conditions, infrastructure quality and population density;

H.  whereas transport drones present new possibilities for transporting goods in the logistics chain, but whereas, in order to fulfil their potential, a harmonised legal basis and seamless coordination with traditional modes of transport are necessary to guarantee European competitiveness in the future;

I.  whereas the current level of implementation of the priority corridors agreed in the European transport network could considerably benefit the economies of countries that have been severely affected by the economic crisis;

J.  whereas problems have been identified in freight transport linked to differing voltages in cross-border connections;

K.  whereas transport regulation is currently tied to the mode of transport and falls under the remit of different international bodies (such as the International Maritime Organisation (IMO) or the International Civil Aviation Organisation (ICAO));

EU logistics and the need for additional measures in the TEN-T programme

1.  Highlights the importance of ensuring free movement of persons, goods and services, including by an efficient and sustainable freight transport system, for the development of the internal market, prosperity and the economic, social and territorial cohesion of the EU;

2.  Considers that a seamless EU infrastructure system will only deliver its benefits to the logistics sector, and thereby also to regional development and growth, if implemented and consistent with EU legislation and with the TEN-T policy already adopted; urges the Member States to transpose legislation correctly into national law without hampering the free exchange of goods; calls on the Member States to increase their efforts to apply and abide by European legislation and to refrain from introducing new barriers; urges the Commission to bring to the Court of Justice Member States that delay or alter the implementation of EU law, and to boost the action of all other relevant actors in order to avoid such delays or alterations;

3.  Is concerned about the negative impact on the logistics sector, and thereby also on regional development and growth, of closures of internal borders in connection with the humanitarian and migrant crisis and the terrorist threat in the European Union; calls on the Member States and the Commission to prevent collateral damage on freight flows as much as possible when proposing such measures; calls on the Commission to take disciplinary action against Member States that impede free movement by deliberately preventing freight flows;

4.  Underlines that logistics plays a key role, not sufficiently recognised, in ensuring efficient and sustainable freight transport operations in the EU; highlights the need to formulate a renewed EU strategy for freight logistics,

   taking account of the new TEN-T infrastructure policy,
   aiming to further reduce regulatory, operational and technical barriers,
   designed to ensure optimal use of resources,
   aimed at applying and implementing new technologies and innovative solutions that will strengthen the sector’s performance and accelerate the shift towards a secure and low-carbon transport system,
   aiming to increase connectivity and develop infrastructure in areas where it is missing,
   promoting and supporting the European rail supply industry as well as boosting a European rail reindustrialisation policy, with the win-win perspective of making EU logistics more sustainable and obtaining a better competition position for rail products on the global market,
   taking into account from the outset drones as a future mode of transport,
   promoting continued development of academic research and education n the area transport and logistics, and
   presenting an independent scientific study detailing the extent to which road freight could be transferred to rail and inland waterways by 2030 and by 2050, the costs associated with this, and the extent to which environmental damage such as noise and air pollution can be avoided;

5.  Stresses that the implementation of the TEN-T network, with particular emphasis on cross-border connections and within the time-frames laid down and completed by 2030, will reduce bottlenecks, improve interoperability between the various modes of transport and contribute to delivering integrated multimodal freight transport in the EU; recalls that national planning of the comprehensive network, in line with the core network, needs to be put in place in order to integrate it with national, regional and local infrastructures, which should be completed by 2050 at the latest;

6.  Welcomes the strengthened emphasis, within the core network corridor approach, to enhance the quality of transport nodes and of their last-mile connections, to identify and overcome interoperability barriers, to enhance and innovate ICT solutions and to close any other gap (physical, technical or organisational) that may hamper seamless freight logistics services;

7.  Recalls, in this context, the importance of urban nodes – where a large part of transport modes (ports, airports logistics, hubs, terminals, etc.) are located and where transhipments and last-mile distributions take place – as they are key to the whole logistic chains, requiring greater attention if seamless city logistics are to be ensured; stresses the importance of investments in these urban nodes, as well as of the promotion of rail connections with industrial plants and improved interconnectivity of rail with seaports, inland ports and hinterland hubs; asks the Commission to prioritise these investments in the 2017 review of the Connecting Europe Facility (CEF);

8.  Notes that a lack of efficient harmonisation and on-time implementation on the part of Member States, and of fair political cooperation between neighbouring Member States, may hamper cross-border projects; welcomes the increasing interest of the EU institutions to support cross-border infrastructure and facilities, particularly railway cross-border regional links of significant importance and EU added value; stresses that missing links in rail infrastructure in cross-border regions should be tackled in order to allow efficient and successful rail transport; calls on the Commission, the European Coordinators and the other stakeholders involved to pay equal importance to small-scale and larger TEN-T projects and to short-, medium- and long-term benefits that may be generated through such projects; encourages actors to boost short-term wins; encourages the Commission to facilitate and ensure their inclusion in the CEF financing;

9.  Considers that while the comprehensive network is mainly a responsibility of the Member States, in order not to exclude connectivity of certain areas of the EU, both layers of the TEN-T are crucial to EU logistics, bringing capillarity to the core network, and performing last-mile distribution; takes the view that regional networks should not be left outside the European perspective, including in terms of financing and regulatory measures, in particular those measures pertaining to access to the railway network, slot allocation and charges; stresses that missing links in rail infrastructure in cross-border regions should be tackled in order to allow efficient and successful cross-border rail transport;

10.  Points out the key role of multimodality in freight logistics, and calls, therefore, for increased involvement of multimodal platforms in Member States’ planning and in the further development of routes;

11.  Notes that the distribution of a large number of nodes and freight traffic in the TEN-T network follows highly populated areas and dense networks, including cross-border zones that share capacity with passenger traffic; considers it necessary to optimise how freight infrastructure should be shaped in the TEN-T, in particular in highly congested areas, in an effort to include innovative urban logistic strategies; calls on the Commission, in coordination with the European Coordinators, to assess progress in the implementation of the projects and to urge Member States to deliver; calls, furthermore, on the Commission to reassess the methodology and criteria for establishing freight networks and to ensure, in particular, that investments are made in alternative freight routes with less congested nodes, terminals, airports and ports, also taking into consideration environmental protection and noise reduction;

12.  Regrets that Member States’ national infrastructure plans are too often decided without reference to the TEN-T objectives; urges the Commission to examine the reasons for such lack of cooperation and to increase the coordination between the two levels of planning, and suggests adding to the European Semester a chapter on supervising its coherence and clear effectiveness, with appropriate corrective measures; calls on the Commission to prioritise Member State projects that are in line with the TEN-T and that concentrate efforts on those with greater European added value, and to monitor cross-border transport projects; urges the Member States to decide on their national infrastructure plans in accordance with the TEN-T objectives;

13.  Notes that Member States experiencing economic and budgetary difficulties are unable to co-finance freight projects as a result of a strict interpretation of the Stability and Growth Pact (SGP); advocates the optimal use of the public and private funding schemes, also in the light of blending the CEF and Horizon 2020 with the European Fund for Strategic Investments and other financial instruments; takes the view that projects carried out as part of the CEF should not be taken into account in calculations of public debt; calls on the Commission to produce a study on whether such a measure would be a suitable means to noticeably increase investments in freight infrastructure;

14.  Considers that an efficient EU logistics system requires further coordination beyond physical connectivity and an operational TEN-T network; calls on the Commission to make logistics an integral part of the Core Network Corridors, to increase its coordination with national, regional and local authorities and, in this context, to focus as well on the interconnectivity between the different corridors and regional and urban freight transport networks; calls on the Commission to strengthen the sphere of action of the TEN-T European coordinators to look beyond the geographical scope of the corridors under their respective responsibility, and to cover horizontal policy issues such as multi-modality and efficient freight logistics; calls on the Commission to evaluate this work on logistics and multimodality in the corridors every two years;

15.  Consider that poor maintenance of the network can affect the sustainability and performance of TEN-T infrastructure; stresses that transport infrastructure needs not only to be renovated and modernised, but also to be regularly maintained; notes with concern that persistent lack of attention by infrastructure managers and Members States to maintenance is reducing the competitiveness of lines (speed restrictions, reliability, safety), in particular in the case of rail, leading sometimes to closure of lines; calls on the Commission and the Member States, together with the EIB, to study new funding schemes to facilitate investments in maintenance of the network;

16.  Asks the Commission to report back regularly to Parliament on the conclusions and measures taken in the Digital Transport and Logistics Forum in order to further support digitalisation of freight transport and logistics; calls for this forum to be continued as long as it remains useful;

17.  Stresses the need to guarantee that planned infrastructure meets the effective needs for sustainable logistics, and that it will not be an unsustainable burden on the environment; stresses, in this regard, that the protection of biodiversity and the achievement of EU conservation objectives should be much better integrated into TEN-T planning and implementation;

Improved simplification and a new framework for digitalisation 

18.  Stresses the urgency of greater simplification of documents and administrative and customs procedures across all modes and across the different stages in logistics chains; calls on the Commission and the Member States, under the ‘better regulation’ agreement, to analyse redundant EU legislation on transport and mobility, to monitor national, regional and local rules that could be in contradiction with EU law and, where such instances are found, to harmonise these rules with EU legislation as soon as possible; calls for a yearly progress report by the Commission on this sector;

19.  Urges the Commission to propose, by the end of 2017, a digital framework for electronic information exchange and transport management in multimodal transport (e-freight) with a view to facilitating a simplified, paperless, seamless, transparent, secured and trusted information flow between businesses, customers and authorities, building on established services (such as SafeSeaNet, RFD, e-Manifest, RIS, TAF, ITS); calls on the Commission to ensure a harmonised application of e-transport documents, anti-fraud systems and cyber-security;

20.  Calls on the Member States to accept electronic transport documents in general, and to ratify and apply the e-CMR protocol without delay;

21.  Underlines the importance of innovation in the use of new technologies, such as digitalisation (e.g. digital freight letters), access to data and data exchange, while maintaining a high level of cyber security and data protection, enabling more efficient transport and logistics solutions, provided interoperability and equal and non-discriminatory access are ensured; calls on the Commission to put forward proposals to ensure the integration, accessibility and protection of data underpinning logistics and freight transport;

22.  Calls, with a view to ensuring non-discriminatory treatment in the digital exchange of information, on the Commission and the Member States to develop a system of investment to provide initial IT training and ongoing refresher training on the platforms used for data exchange;

23.  Stresses the role that research and innovation can play in developing environmentally sustainable and digitised logistics and in ensuring greater interoperability and interconnectivity of IT systems and services;

24.  Highlights the need to further develop information and communication systems, fully deploying the potential of European satellite navigation systems Galileo and EGNOS and related traffic management and information systems in all transport modes and logistics, providing access to all available financial tools to encourage private investment;

25.  Calls on the Member States to ensure swift administrative procedures aimed at speeding up the implementation of TEN-T corridors; asks the Commission to ensure that the rules on SGP, State Aid and financial markets do not hinder investments;

Shaping and investing in the European Transport System with logistics as a focal point

26.  Underlines the need to ensure enough EU funding for the implementation of the TEN-T beyond the present MFF; expects the Commission to present the CEF mid-term review in 2017, proposing a streamlining of measures and resources for the implementation of the priority projects in good time; insists on the ‘use it or lose it’ principle, whereby unspent CEF funds are made available for upcoming calls for proposals; urges the Commission to assess a proposal for a specific call on logistics in 2017, including multimodal transport and freight as well as cargo solutions in urban nodes, including innovative and alternative transport (i.e. drones, cargo vehicles running on alternative fuels, biking, etc.);

27.  Calls on the Commission to urge Member States to make the requisite investments in order to finalise the connections of the EU’s core corridors;

28.  Recalls the importance of urban nodes in the whole logistic chain where an important part of transhipments and last-mile distribution takes place; invites the Member States, the Commission and project promoters to put a focus in TEN-T core network corridors on the coordinated development of projects that promote multi-modality in freight logistics, in particular terminal hubs, logistic platforms and urban nodes, based on actual and future transport demand and properly prioritised as regards local, cross-border and corridor-wide impact;

29.  Considers that reliability, frequency, flexibility, customer orientation, transport time and price are the main factors taken into account by shippers when choosing between the different methods of transport available;

30.  Considers that an efficient logistics system must also be oriented towards future technologies that provide fast, environment-friendly and efficient modes of freight transport; highlights the potential and growing role of automation and autonomation transport for logistics, including automated vehicles, drones and remotely controlled robots;

31.  Calls on the Commission to take fully into consideration automation and its impact in its logistic strategy, ensuring its smooth and efficient integration into the TEN-T, and to support research on, and investment in, the development of these key technologies;

32.  Stresses the potential of automated, autonomous transport as well as of remote controlled aircrafts (drones) for logistics; calls for measures to ensure, when deploying ITS systems in the network, that automated vehicles and systems interact smoothly with conventional vehicles and vulnerable users; is of the opinion that the future development and widespread use of remotely controlled robots and aircraft systems (drones) foresees new, fast, environment-friendly and efficient modes of freight transport; calls on the Commission to devise a new strategy that guarantees that drones can be integrated into the TEN-T programme efficiently, and to produce a guidebook on the matter for the Member States;

33.  Calls on the Commission to take account of the impact that the spread of just-in-time practices is having on the environment, owing to the fact that they increase vehicle traffic;

34.  Stresses the need, not least in view of the gradual move towards a circular economy, to integrate outbound and reverse logistics operations with a view to reducing overall vehicle movement volumes;

Urgent and more efficient integration of transport modes

35.  Stresses the need to concentrate major efforts on the revitalisation of railways and on the strengthening of inland waterways (IWW) as a priority for the EU’s sustainable transport strategy; recognises that railways, in particular, have been losing their market share constantly since the beginning of the economic crisis, and believes, therefore, that the Member States and the Commission should propose new and non-discriminatory initiatives aimed at supporting the development of this sector across Europe;

36.  Calls on the Commission to make rail freight services more competitive by means of fully interoperable and interconnected rail networks and by guaranteeing equal access to companies, and to do the same for inland waterway, sea-river, maritime and air transport, enabling each mode to operate on equal terms, and urges it to promote multimodal and intermodal transport;

37.  Regards the European Rail Traffic Management System (ERTMS) as a successful European project for the promotion of freight in the rail sector, and welcomes the efforts to accelerate its deployment by establishing milestones per corridor; is aware of the constraints that affect funding of multinational, multi-level (ERTMS) projects; invites the Commission and the European Investment Advisory Hub to come forward with specific funding solutions to ease access to European Fund for Strategic Investments (EFSI) funding for ERTMS deployment in favour of both infrastructure and locomotive installations;

38.  Considers that interoperability obstacles and constraints will be significantly reduced through the application by all Member States of the Interoperability Directive; underlines that, in addition, soft measures such as interoperable rolling stock (low wagons, multi-gauge locomotives, etc.) can also contribute to alleviating interoperability restrictions; urges Shift2Rail to analyse the EU market, as well as future developments, and to incentivise the availability of soft, multi-operable infrastructure and rolling stock solutions to support multimodal and combined transport;

39.  Points out the need to strengthen combined transport and modernise current EU rules, including those governing intra-Community cabotage and transport documents, so that they are clear, comprehensible and can be implemented by the authorities; welcomes the Commission’s commitment to review Council Directive 92/106/EEC, and urges it to submit the revision without delay;

40.  Calls on the Commission and the Member States, without compromising overall safety, to introduce stronger and more effective measures and incentives to encourage rail companies to tackle freight-rail noise, given the adverse health effects of noise pollution, especially as nearly seven million people in the EU are exposed to rail noise levels above the excess exposure threshold, particularly in urban areas; calls, in this regard, on the Commission to introduce freight-rail noise emissions limits;

41.  Considers that the shift to rail and water transport should be incentivised, as they reduce congestion and are less polluting than road traffic;

42.  Notes that inland waterways must play an increasing role in serving seaports as logistics centres, in particular by moving goods to hinterland and linking the European seas;

43.  Welcomes the Commission’s first steps to introduce fuel standards for heavy commercial vehicles (HCVs) and CO2 limits as well as a GHG reduction target for the road freight sector on the basis of the Paris Agreements; is of the opinion that measures that require a revision of the infrastructure and operational standards of the TEN-T network should only be considered when alternatives such as reducing ‘empty returns’, better use and availability of alternative fuels, better logistics and powertrains, could not achieve greater efficiency gains with less impact on the infrastructure and the environment;

44.  Asks the Commission to assess the feasibility of establishing a single standard method for measuring greenhouse gas emissions along the entire supply chain for all modal transport solutions;

45.  Calls on the Commission to foster the development of electric and alternative-powered modes of transport and the necessary infrastructure along the whole TEN-T network, and, especially in town centres, to foster the development of innovative transport schemes involving, for example, the use of electric vehicles and renewable energy sources, and the development of alternative fuels and the necessary infrastructure; stresses that the use of electric light-duty commercial vehicles in last-mile logistics reduces CO2 emissions in general, as well as local pollutant and noise emissions in particular, and thereby makes a positive contribution to urban air quality; stresses, therefore, the need for charging infrastructure at logistics hubs;

46.  Considers that further measures are needed to make road transport more efficient and environmentally friendly in the logistics chain; proposes easing traffic restrictions and ensuring continuity and fully efficient logistics in the core network corridors for HCVs running on clean alternative fuels compliant with the highest emissions, noise, safety and social standards; insists that the core network corridors be extensively provided with, at least, alternative filling stations and safe truck parking areas, including the requisite facilities allowing professional drivers to spend their rest times in decent conditions;

47.  Considers that the uptake of cleaner propulsion systems in freight transport should be reinforced by a coordinated and urgent deployment of alternative fuels infrastructure in TEN-T corridors, in line with EU legislation;

48.  Stresses the importance of improving the provision of, and access to information on, EU multimodal and logistics services, in particular to SMEs that have limited access to this information; calls on the Commission, in cooperation with network operators and Member States, to facilitate the exchange of current agreements, tools, conventions, legislation and best practices on multimodal transport in the EU, and to provide a handbook, to be available on the internet, to support economic operators;

49.  Notes that the digitalisation of services has a role to play in encouraging more environmentally friendly transport solutions; calls, therefore, on the Commission to facilitate, also through a coherent legislative approach at EU level, the access to and sharing of data concerning traffic flows along the corridors and the use of multimodal transport, especially for SMEs, and to secure greater involvement of local operators and public authorities in this sector, in order to improve supply-chain management and make more efficient use of resources and infrastructure, including by pooling best practices; underlines that access to such traffic flow data by actors such as digital map and navigation service providers is fundamental to enabling intermodal transport, more efficient routing, automated driving and intelligent transport systems, as well as ‘platooning’ (grouping various vehicles) in road freight transport, this latter allowing better use of slipstreaming and thereby reducing emissions and increasing the capacity of roads;

50.  Recommends that the fitting of alcohol interlocks – with a small, scientifically based range of tolerance for measurement – to all new types of goods transport vehicles be made compulsory;

Better training and job conditions to attract new professionals

51.  Notes that the working and living conditions of the workforce in the logistic chain have deteriorated substantially in the past years, making this sector less attractive for new generations, in particular for mobile workers;

52.  Notes with concern that the logistics sector is facing a workforce shortage, that technological development will create further challenges in the coming years and that slow adaptation of the workforce to new technologies, including digital technologies, could undermine the sector’s performance; calls on the Commission to identify training and learning needs at EU level, as well as to identify the working conditions, costs and barriers that discourage the workforce from entering the transport sector, and to propose, as a matter of urgency, measures to make it more attractive to young people and to future generations; regards this as an opportunity to increase the proportion of women, including through positive discrimination measures, and of new entrants on the transport labour market, including nationals from third countries; believes, furthermore, that strategic investment in training and better work conditions should include initiatives for knowledge development within the public sector, in order to include freight issues in a better manner in social planning, and the development of demonstration and test arenas, where research and innovation related to freight and logistics can be applied and tested under real conditions;

53.  Calls on the Commission to evaluate the possibility of financial investment in dual and vocational training in the transport sector;

54.  Urges Commission and the Member States to provide sufficient and safe parking space in the TENT-t corridors to avoid increasing security issues with mobile transport workers;

55.  Calls on the Commission and the Member States to take into consideration Parliament’s recent recommendations on social-economic aspects in the transport sector and on combating unfair practices in the labour market; notes that legislation concerning social and working conditions must respect all fundamental freedoms of the EU and may not restrict fair competition or create any further administrative burden;

Better statistical information on logistics needed

56.  Underlines the need for better intermodal transport and performance statistics for the logistics sector in order to facilitate forecast and review of policy and investment measures, as well as to provide valuable information for operators; calls on the Commission to work with stakeholders to develop an EU-wide framework for multimodal transport and logistics statistical data, including developing new indicators that better reflect real freight trends;

o   o

57.  Instructs its President to forward this resolution to the Council and the Commission.

(1) Texts adopted, P8_TA(2015)0310.
(2) Texts adopted, P8_TA(2015)0423.
(3) OJ C 295 E, 4.12.2009, p. 79.
(4) OJ C 187 E, 24.7.2008, p. 154.
(5) OJ L 348, 20.12.2013, p. 1.
(6) OJ L 348, 20.12.2013, p. 129.
(7) OJ L 276, 20.10.2010, p. 22.

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