For the 15th BiH Congress on Transport Infrastructure and Transport in Sarajevo we co-wrote a paper asking whether this region is actually ready for the electronic consignment note. Legally and technically, it is. The only thing still on paper is the consignment note itself.
On 21–22 September 2026 our paper will be presented at the 15th BiH Congress on Transport Infrastructure and Transport in Sarajevo. Željko Bajšanski, our founder and CEO, wrote it with Prof. Dr Pavle Gladović of the Engineering Academy of Serbia and with Aleksandar Pavlović, director of CIS inženjering d.o.o.
It rests on the feasibility study CIS inženjering wrote this June, which you can download in full. The paper puts one narrow question to it: is this region actually ready for the electronic consignment note, or is this still a subject for later?
The legal ground moved faster than the conversation about it
When we stood in the chamber hall in Novi Sad on 22 June, our own slide said Serbia had not ratified the 2008 Additional Protocol. That slide was out of date within weeks.
As things stand in the region today (current status here):
- Serbia and Montenegro ratified in July 2026
- North Macedonia and Albania in April 2026
- Slovenia in 2017, Hungary in 2024
- Bosnia and Herzegovina and Croatia have not ratified yet
Forty-two countries are party to the Protocol in all. An eCMR carries the same legal and evidential weight as paper on routes where both countries have ratified.
Quite apart from the international framework, Serbia's own Law on Electronic Document, Electronic Identification and Trust Services in Electronic Business already says an electronic document cannot be denied legal validity for being electronic. It is closely aligned with the EU's eIDAS framework. Nothing there needs writing.
The technology was never the obstacle either
The paper works through the technical prerequisites one by one, and the honest finding is that they are boring. Broadband, 4G and 5G coverage, smartphones in drivers' hands, cloud hosting, electronic signatures, digital identity, QR verification — all of it is mature, deployed and in daily use in other parts of the same business.
The clearest evidence is what this region has already digitalized. In Serbia, 99.72% of customs declarations are filed electronically. GPS tracking and fleet management are near-universal. E-invoicing keeps climbing. Transport management systems are widespread among mid-size and large operators.
And then, in the middle of that, sits the CMR consignment note — on paper.
Only the consignment note is still on paper
There is no official statistic for how many CMRs are issued, so the study estimated it indirectly from customs, transport and trade data: roughly 1.5 million a year in Serbia, and about 3.25 million across the six Western Balkan economies — of which Bosnia and Herzegovina alone accounts for 0.6–0.8 million.
Every one of those is printed in several copies, carried by hand, signed by hand, posted back and filed in a box.
What the waiting costs
This is the part of the study I care about most, so let me put the figures plainly.
Processing one paper CMR takes about 23 minutes; processing an electronic one takes about 9. The cost of handling one paper document works out at about €7.20 — data entry, printing, physical exchange, checking and correcting, archiving, and the administrative time around all of it — against about €2.00 for the electronic equivalent. The difference, €5.20 per document, is the conservative net benefit the study builds everything on.
At 1.5 million documents a year, that is €7.8 million a year in Serbia; at the region's 3.25 million, roughly €16.9 million — direct, hard cost, before anything softer is counted. Add the wider economic effects the study values at a deliberately cautious €6.00 per document — time saved, fewer errors and disputes, higher productivity — and the total reaches €16.8 million a year in Serbia and €36.4 million regionally.
There is a paper number too: about 6 million sheets a year in Serbia, some 13 million across the region, printed and posted and stored.
Then there are the borders. The study's indicative waits are 30–90 minutes at Horgoš, 20–60 at Batrovci, 30–60 at Preševo, and anywhere from 10 minutes to 3 hours at Karasovići. An eCMR does not dissolve a queue — but the share of that queue that is document handling, manual checking and the same data being read off paper three times is exactly the share it removes.
What this looks like in money
The study models a national platform at €3 million of investment and €400,000 a year to operate, over a ten-year horizon at a 5% discount rate, with adoption climbing from 25% in the first year toward 95%. It pays back in about a year and a half.
The headline return ratios in the study are enormous. I am not going to parade them, because a ratio that large tells you less than it appears to: it is what arithmetic does when you divide a modest, one-off platform cost by a benefit that recurs across a million and a half documents every year. The number to trust is the payback period and the €5.20.
What I do find persuasive is the sensitivity test. The study pushed investment up 20%, operating costs up 20%, benefits down 20%, and adoption slower than planned — one at a time, as the European Commission's guidance requires. Nothing reversed the conclusion. The two scenarios that actually bite are lower benefits and slower uptake, and both of those are adoption problems, not technology problems.
The middle road is the expensive one
The study weighed three options: change nothing, digitalize partially, or build the platform.
Changing nothing is easy to price — it is the €7.8 million a year, every year, plus arriving at the EU's eFTI deadline of 9 July 2027 unprepared.
Partial digitalization is the one that looks prudent and is not. It keeps a hybrid operation in which some data is digital and the document is still paper, so the same information still gets typed more than once, and none of it is interoperable with anyone else. It spends real money to preserve the exact problem it was meant to solve. In our experience that middle road is where most companies genuinely intend to stop, and it is the most expensive place to stand.
What "ready" still needs
Four things, none of them software:
- Ratification finished where it is still outstanding — Bosnia and Herzegovina and Croatia, in this region.
- Inspectors equipped and trained. A document an inspector cannot verify at the ramp is not yet a document.
- Interoperability, not just digitalization. A platform that digitalizes only inside its own four walls has moved the paper, not removed it.
- Carriers who start before the deadline. Companies that begin in 2026 will meet 9 July 2027 comfortably. The ones that begin in 2027 will meet it at the same moment as their competitors, and at the same border.
In conclusion
The answer to the question in the title is yes. The legal framework is in place and has improved sharply across this region in the last year; the technology has been mature and proven for far longer; and the cost the paper carries with it runs to millions of euros a year — €7.8 million in Serbia alone, before a single wider effect is counted.
What is left is not a technical question but a question of decision and timing. Moving to the electronic consignment note asks nobody to invent anything. It asks us to stop printing.
Move freight, not papers.
Photo by Boris Hamer on Pexels
