C_202603240EN.000101.fmx.xml

Opinion of the European Economic and Social Committee

Proposal for a Regulation of the European Parliament and of the Council on establishing a framework of measures to facilitate the transport of military equipment, goods and personnel across the Union

(COM(2025) 847 final – 2025/0847 (COD))

(C/2026/3240)

Rapporteur:

Tomas ARVIDSSON

Legislative procedure	EU Law Tracker
Referral	European Parliament, 12.12.2025; Council of the European Union, 21.1.2026
Legal basis	Articles 91, 100(2) and 304 of the Treaty on the Functioning of the European Union
European Commission documents	COM(2025) 847 final
Section responsible	Section for Transport, Energy, Infrastructure and the Information Society
Adopted in section	9.3.2026
Adopted at plenary	18.3.2026
Plenary session No	604
Outcome of vote (for/against/abstentions)	204/5/12

1. RECOMMENDATIONS

THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE (EESC):

1.1.

welcomes the initiative to significantly facilitate military mobility within and between Member States in order to be able to achieve deterrence and defence more quickly and efficiently. The EESC stresses that for frontline and transit Member States on the EU’s eastern flank, military mobility is not a technical or administrative issue, but a core element of deterrence, defence readiness and collective security. The Committee therefore calls for the clear prioritisation of rapid military reinforcement of the eastern flank in the implementation of this Regulation. It should be pointed out in this context that efforts to simplify and harmonise logistics and transport rules should therefore be pushed forward, as a significant part of military mobility will be implemented with ordinary civilian resources and personnel. Simplification and harmonisation measures should also not come at the expense of workers’ rights, working conditions or safety standards;

1.2.

states, however, that security policy can only be effective, legitimate and sustainable if it is based on good, sound services of general interest and the business economy, social resilience, good working conditions and democratic participation. The EESC stresses that all measures adopted under the military mobility framework must fully comply with the Charter of Fundamental Rights of the European Union, rule of law principles and applicable international human rights and humanitarian law;

1.3.

underlines the need for any ‘crisis’ or ‘emergency’ framework to be well defined, with legal clarity and predictability on the applicable rules, and for emergency measures to be activated. Such frameworks need to incorporate provisions on the rights and protection of civilian workers carrying out military transport operations. Emergency or crisis derogations should include clear activation thresholds, written justification requirements, and transparency obligations where security allows. In this context, the EESC also takes note of the derogations foreseen under EMERS, including art 27 on driving and rest times, which, when activated, should remain justified, proportionate and limited in duration, while taking due account of driver wellbeing and timely consultation of social partners;

1.4.

points out that the transport sector in Europe is afflicted by severe structural shortages, which directly threaten transport resilience in times of crisis. There is ample evidence that these shortages are in great part driven by the unattractiveness of many transport jobs. The EESC stresses the importance of investing in the transport workforce in order to improve employment and working conditions, training opportunities and the overall attractiveness of the sector;

1.5.

emphasises even more the importance of the dual-use principle, both for the efficient allocation of financial resources when these fall short of needs and for purely civilian use, in order to make the EU more competitive, improve the internal market and generally increase resilience. For all generations, for our future, it is of the utmost importance that all work be carried out with transparency and understanding, aiming for growth and prosperity as well as sustainability in these matters. In this context, the EESC underlines that stable, predictable and sufficient EU-level financing is indispensable. Without a significant increase in dedicated funding for military mobility, implementation risks remaining fragmented and overly dependent on national budgets, disproportionately burdening frontline Member States. The EESC therefore calls for a substantial reinforcement of the Connecting Europe Facility (CEF) Transport envelope, with a clearly ring-fenced allocation for military mobility, and for the mobilisation of complementary instruments. Consideration should also be given to the establishment of a dedicated long-term investment vehicle for large-scale military mobility infrastructure;

1.6.

supports the goal of extending mobility corridors to Moldova and Ukraine. In this context, it should be pointed out that measures, including redundancy measures, should be analysed, planned and implemented as appropriate, while paying special attention to areas known to have challenges, such as the Suwałki corridor, the wider Black Sea area and the northern part of the Nordic countries;

1.7.

notes that it may seem obvious for military transport, as well as transport of essential supplies, to have a default general priority, with a top priority for special cases, but it is not unproblematic and not without consequences in peacetime. In several Member States, there is no legal basis for prioritising peacetime transport other than with financial incentives. If legislation is to be enacted regarding the prioritisation of certain transport in certain situations during peacetime, the EESC believes that logistics and transport operators, including their employees who suffer direct damage or regress, should be compensated on a tort law basis, preferably through insurance proceedings. Such cases should be handled by the Member States in accordance with jointly developed guidelines within the EU. The EESC calls for the establishment of a European digital one-stop shop for military mobility, allowing for harmonised documentation, simplified customs procedures and near-automatic activation of pre-approved movements once predefined threat thresholds are reached;

1.8.

contends that strict rules are needed regarding criteria for subcontracting military transportation to civilian operators. This is particularly true for road and maritime transport, where it will be necessary to ensure transparency over aspects such as whether the operator is a legitimate company and how good their compliance record is. The Commission’s legislative proposal must therefore set out clear selection criteria to be fulfilled by civilian operators qualified to carry out road and maritime transport operations for military forces;

1.9.

believes that a sector-specific approach is necessary, not least in road transport. Responsibility for cargo security cannot fall on the driver. Additional obligations more than those that already apply will have to be clearly specified in the regulation. Prolonging driving times and shortening rest periods will risk further loss of long-distance drivers. Concerning enforcement and controls, the EESC believes that roadside checks must include elements such as checks of licences and of driver and vehicle records for a period of 56 days (as per the current rules), as well as clear obligations for operators to correctly inform drivers when they are operating under derogations;

1.10.

believes that the international law aspects of the wider use of civilian support resources should be analysed and taken into account in the context of the ongoing war in Ukraine and other conflicts. To achieve acceptance and encourage the participation of civilians carrying out logistics and transport operations, they must be covered by life and health insurance that also covers surviving relatives, where appropriate, if the worst were to happen to them. Civilian and humanitarian actors providing logistic, medical, food, social or emergency support must not be subject to criminalisation, undue liability or administrative sanctions when acting in good faith and in accordance with humanitarian principles and applicable law;

1.11.

stresses the importance of successfully involving and gaining the acceptance (through social dialogue and civil dialogue) of social partners and other civil society players from the outset, including through training, exercises and stress tests, as well as planning and evaluation. Here the EESC draws attention to its previous opinions on Crises and crisis phenomena in modern Europe and civil society and the European Preparedness Union Strategy. The EESC agrees with the Commission regarding the importance of close cooperation between the public and private sectors as well as civil-military cooperation;

1.12.

calls for the utmost vigilance and for binding measures to ensure the full controllability, resilience and operational capability of critical infrastructure, particularly in the areas of transport, energy, data networks and ports. On the basis of Regulation (EU) 2019/452 (1) on the screening of foreign direct investments, existing regulatory gaps in the screening of investments in critical infrastructure – particularly with regard to ownership, control and governance structures – must be consistently closed. Investments that could lead to direct or indirect influence by non-EU countries or security-relevant players must be assessed as a security risk and, if necessary, prohibited or subject to strict conditions;

1.13.

would like to underline that in order to achieve full and flexible military mobility, aspects linked to infrastructure other than the more traditional ones (railways and roads) should also be taken into account, e.g. the provision of data and telecommunications, including satellite communications, payments, insurance and rapidly developing transport technologies, like drones and new propulsion systems based on innovative energy supply solutions, enabling extended operational range while minimising dependence on supporting infrastructure;

1.14.

calls for structured democratic oversight at EU and Member State level over the activation and use of military mobility derogations and priority mechanisms, including regular reporting to parliaments and public transparency obligations where compatible with security needs;

1.15.

stresses that accelerated procedures for procurement, contracting, infrastructure access and subcontracting under military mobility frameworks must include anti-corruption safeguards, transparency requirements, beneficial ownership disclosure, conflict-of-interest controls and auditability of subcontracting chains;

1.16.

stresses that the lack of sufficient dual-use capabilities to quickly perform military transport operations at large scale and the subsequent need to replenish these capabilities should be addressed as a priority. The solidarity pool provided for in the Military Mobility Regulation can help to address these capability gaps, provided it dedicates the appropriate level of resources to support fleet replenishment.

2. EXPLANATORY NOTES

Arguments in support of recommendation 1.1

2.1.

It is better to primarily simplify and harmonise existing regulations for logistics and transport, including customs services, and to adapt these for military mobility, than to introduce special regulations that increase the regulatory burden and the need for special training. General regulatory simplification must be a genuine effort to clarify and make rules more accessible for everyone, not a reduction of businesses’ obligations to respect crucial safeguards for workers, consumers or the environment.

Arguments in support of recommendation 1.2

2.2.

It should be noted that there are shortages in several large professional groups in the logistics and transport sector within the EU, such as lorry drivers. A deterioration in working conditions will further exacerbate the shortage, which will damage the EU’s competitiveness, efforts to strengthen the internal market and the EU’s resilience.

Arguments in support of recommendation 1.5

2.3.

Ensuring that the prioritised investments that are required for military mobility result in a very high degree of dual-use solutions, it could promote the movement of both people and goods within the bloc and boost EU competitiveness, the internal market and EU resilience. It is particularly important to promote multimodal transport. Moreover, facilities at border crossings are crucial for changing track gauges, where appropriate, and railway ferries are essential for bridging sea transport.

Arguments in support of recommendation 1.6

2.4.

It is necessary to focus on the here and now and encourage very rapid implementation, especially regarding support for Ukraine. The designated special military mobility corridors are a promising idea but do not cover everything from an overall dual-use perspective.

Arguments in support of recommendation 1.7

2.5.

In some Member States, there is legislation and a structure for insuring goods, equipment and personnel during transport in war or war-like conditions, when commercial insurance coverage ceases. When transport is prioritised for military purposes in peacetime, logistics and transport companies may claim damages or seek legal recourse vis-à-vis the services etc. that are then deprioritised or cancelled. It is reasonable here for the Member States to provide protection on a tort law basis, individually or bilaterally, that promotes military mobility even where special prioritisation is needed under peacetime conditions.

Arguments in support of recommendation 1.8

2.6.

The ‘letter-box business model’ persists in road transport. This comes with a lack of transparency over company ownership. We have seen road hauliers from non-EU countries operating via letter-box companies on EU territory. This represents a threat to the security of operations and of cargo.

Argument in support of recommendation 1.9

2.7.

The road freight sector has a number of specific features. Military cargo is of high value. The lack of secure parking areas in Europe poses a serious problem in terms of cargo security. These conditions will lead to exacerbated fatigue, a lack of access to basic facilities, a deterioration in working and living conditions and no security for drivers during rest periods.

Arguments in support of recommendation 1.10

2.8.

The ongoing war in Ukraine shows that respect for international law and the laws of war is low. It is therefore important that civil society support for military mobility be given the protection and security it needs, as well as support in the event of injuries and protection for surviving relatives if the worst were to happen. This also applies to participants from civil society who, for example, provide food, healthcare and nursing.

Arguments in support of recommendation 1.11

2.9.

Military mobility, including host country support, will be more efficient and better organised if civilian and civil society players are involved. Therefore, social partners should be appropriately involved in planning, training, exercises, stress tests and evaluation from the start.

Arguments in support of recommendation 1.12

2.10.

Critical infrastructure is the backbone of European security, public services and crisis resilience. There are currently shortcomings in transparency, ownership and control structures and in the coordination of national screening mechanisms, which encourage circumvention, fragmented responsibilities and security blind spots in the internal market. Only through strong, harmonised and closely coordinated national screening mechanisms can these issues be addressed. Disruptive clean mobility technologies resulting from European research should be supported, as they bring benefits for military as well as civilian use.

Arguments in support of recommendation 1.16

2.11.

Transporting large quantities of military assets in a minimum amount of time requires a substantial number of readily available capabilities. For example, moving a light division (15 000 soldiers and 7 500 vehicles) by train could require up to 200 trains, each with up to 42 wagons, or the equivalent of 8 400 loaded wagons. In case of crisis, a large-scale deployment of troops would require a substantial number of dual-use capabilities that are currently not readily available for use. Hence, the primary objective of the solidarity pool should be to support fleet replenishment through dedicated EU programmes.

3. PROPOSED AMENDMENTS TO THE LEGISLATIVE PROPOSAL OF THE EUROPEAN COMMISSION

Amendment 1

linked to recommendation 1.5

Chapter II, Article 21(7)

Text proposed by the European Commission

EESC amendment

When priority access is granted to military transport under paragraph 1, no compensation shall be due to other affected transport users. Member States and infrastructure owners, operators and managers or, as the case may be, related services or facilities providers shall make all reasonable efforts to limit the impact of such priority access by, for example, offering alternative routes, slots, transport services or facilities as appropriate and depending on availabilities and inform the transport users as soon as possible.

Reason

It is unreasonable under peace conditions for civilian players to fully bear the financial burden for such necessary prioritisation. Instead, it should be paid by the Member States. Otherwise, competitiveness and readiness to assist will be unnecessarily undermined.

Amendment 2

Linked to recommendation 1.13

Chapter III, Article 33(3)

Text proposed by the European Commission

EESC amendment

In addition to the strategic dual-use infrastructure referred to in paragraph 1, Member States shall also identify essential supporting infrastructure, amongst which transport-critical energy and communications infrastructure, meeting the following criteria as strategic dual-use infrastructure for the purposes of this Regulation:

(a)	infrastructure that has a strategic capacity to support large-scale military transport operations;

(a)	infrastructure that has a strategic capacity to support large-scale military transport operations;

(b)	infrastructure that provides or has provided a strategic contribution to planned or past military transport;

(b)	infrastructure that provides or has provided a strategic contribution to planned or past military transport;

(c)	infrastructure that plays a strategic role in providing services of transport of goods or persons to Member States or regions vulnerable to security threats;

(c)	infrastructure that plays a strategic role in providing services of transport of goods or persons to Member States or regions vulnerable to security threats;

(d)	infrastructure that disposes of very specialised dual-use services or facilities that are essential for military transport, and for which there are very few alternatives elsewhere in the same Member State or along the same military mobility corridor;

(d)	infrastructure that disposes of very specialised dual-use services or facilities that are essential for military transport, and for which there are very few alternatives elsewhere in the same Member State or along the same military mobility corridor;

(e)	infrastructure that plays a strategic role in storing dual-use assets that facilitate military transport along the military mobility corridors.

(e)	infrastructure that plays a strategic role in storing dual-use assets that facilitate military transport along the military mobility corridors ;

(f)	innovative technologies that enable military mobility while mitigating the need for strategic supporting infrastructure .

Reason

Innovative technologies with new designs can mitigate heavy reliance on supporting infrastructure and therefore speed up and secure military mobility.

Amendment 3

Linked to recommendation 1.16

Chapter V, Article 35(4)

Text proposed by the European Commission

EESC amendment

Member States may voluntarily register their own capabilities in the Solidarity Pool. Capabilities that have been acquired or contracted by Member States with the financing support of any Union funding shall be registered in the Solidarity Pool.

Member States may voluntarily register their own capabilities in the Solidarity Pool. It needs to be ensured that passenger services engaged in public service obligations (PSOs) are not impacted, and that the creation of market distortions between competitors is avoided. Capabilities that have been newly acquired or contracted by Member States through dedicated EU programmes or financial instruments with the aim of pooling dual use capabilities shall be registered in the Solidarity Pool.

Reason

We need to ensure that PSOs be kept out of the solidarity tool in order to preserve the smooth functioning of passenger civilian railway services, and to introduce safeguards in competitive markets. where all operators are equally impacted. Furthermore, only newly acquired capabilities through dedicated EU programmes or financial instruments with the aim of pooling dual use capabilities should be subject to the mandatory registration. In any case, existing rolling stock upgraded with EU funding should be excluded from compulsory registration in the solidarity pool.

Amendment 4

linked to recommendation 1.7

Chapter V, Article 41(4)

Text proposed by the European Commission

EESC amendment

The Military Mobility Transport Group may invite, where relevant, in accordance with its rules of procedure and with due respect to the security and defence interests of the Union and its Member States, Ukraine, Moldova and countries of European Economic Area to attend meetings as observers. The transport group shall also cooperate and consult, where relevant, with representatives of the EU’s economic and social partners and civil society players, through the EESC, to ensure the efficient use of resources and implementation where civil participation, cooperation and dual-use solutions are involved. Each Member State shall correspondingly embed cooperation between private and public players at different levels according to the conditions that apply in each Member State.

Reason

Implementation will be improved if economic and social partners and civil society players are involved from the beginning.

Brussels, 18 March 2026.

The President

of the European Economic and Social Committee

Séamus BOLAND

(1) Regulation (EU) 2019/452 of the European Parliament and of the Council of 19 March 2019 establishing a framework for the screening of foreign direct investments into the Union (OJ L 79 I, 21.3.2019, p. 1, ELI: http://data.europa.eu/eli/reg/2019/452/oj).