Implications for European Regions The European Transport System (ETS) tax system has had a significant impact on transshipment activities within the port sector, causing shifts in operations and annual revenue losses along with investments in terminal facilities. This change in operational costs between competing hubs has allowed for the transfer of transshipment operations elsewhere while maintaining connections with Europe through feeder services. Scientific evidence has shown that anti-dodging measures are insufficient; they cannot counteract the diversion of transshipment operations outside the EU but can only shift them back into the EU via feeder services, thus preserving connections with Europe. The alarm was raised by the Assarmateurs, who presented to Brussels during the Maritime ETS Workshop: Safeguarding

European Transshipment, hosted by Eurodeputy Letizia Moratti, an analysis on the issue, carried out by Professor Giovanni Satta from the Department of Economics at the University of Genoa. According to the elaborations made by company TIM 10 under the supervision of Satta, short-term scenarios hypothesize that within five years, up to 7.5-15% of exposed risks will be transferred, corresponding to volumes between 2.85 and 6.3 million TEUs (20-foot containers). This results in annual losses ranging from €403 to €892 million, as well as investment dispersion between €1.43 billion and €3.6 billion required for moving those volumes. A situation leading to incomplete fulfillment due to their inability to manage these risks.

The transfer of activities related to a number of jobs with an annual capacity ranging from 2,005 to 4,431 is mandatory. According to the study, 'transshipment is particularly sensitive to differences in operational costs between competing hubs. Unlike local market traffic, it can easily be transferred among alternative ports within the same international network. When maritime services and investments in terminals move outside Europe, recovering them becomes almost impossible.' Scientific evidence has shown that 'anti-dodging measures have been insufficient.'

These provisions can counteract intermediate levels of evasion, but they cannot prevent the transfer of transshipment operations outside the EU, which allows goods destined for markets outside Europe to avoid transit subject to EU VAT, while maintaining connections with Europe through feeder services. According to the study, it is argued that without a complementary measure that incentivizes transshipment within the EU, this would not eliminate economic asymmetry at the root of relocalization.