ABSTRACT
Combined transport, sometimes referred to as intermodal or multimodal transport, occurs where goods are transported successively by two or more different methods of transport. The general rule under Article 2(1) of CMR Convention is that where goods are carried by another mode of transport and the goods are not unloaded from the vehicle, then the whole carriage will be governed by the Convention, notwithstanding the fact of that different mode of transport. In an important Danish decision, a carrier was held able to rely on his trading conditions in relation to container transport between Denmark and England. Unloading the goods from the vehicle will not affect the operation of Article 2(1), however, where the unloading takes place in circumstances covered by Article 14. The greater part of the text of Article 2(1) is concerned with the position where the general rule, does not apply, so that the carriage by the other means will not be governed by CMR.
