Parcel and courier companies need to check more carefully who actually carries out their transport. The Dutch Human Environment and Transport Inspectorate, ILT, and licensing authority NIWO found that clients generally include licensing requirements in contracts, but do not always verify whether licences remain valid or which subcontractors are used.

ILT and NIWO spoke with six clients and freight forwarders for their joint study, bringing 274 carriers into scope. A valid licence was found for 122 carriers, or 45% of the group. No valid licence was found for the other 152. This does not automatically mean that all of those carriers broke the rules: the licensing requirement depends on factors including the vehicle, its registration category and how the transport is performed.

The inspectors mainly found gaps in periodic verification. Licence numbers and expiry dates were not always recorded in full. Checks on vehicle registrations, drivers and subcontractors were often limited as well. This makes it difficult to establish who actually delivers a parcel after it has been transferred to a carrier or depot.

Responsibility does not end with the carrier. The Dutch Road Haulage Act also makes consignors and freight forwarders jointly responsible for a fair transport chain. A company that outsources transport must therefore take reasonable steps to prevent the use of a carrier without the required licence. A contractual clause helps, but it does not replace an effective control process.

For an online retailer or fulfilment provider, that process starts with a current carrier register. Record the licence number, expiry date, vehicles used and permitted subcontractors for each party. Require advance notice of changes and recheck the data at fixed intervals. This prevents a sound paper agreement from becoming detached from the daily parcel flow.