Letter to the European Commission on unjustified restriction for ECMs in Italy

Joint letter from ERFA and UIP to the European Commission

The UIP and ERFA have been informed by the Italian Member Association (ASSOFERR) about the introduction of an illegal and unjustified restriction for ECM (Entity in Charge of Maintenance) by Trenitalia implying a limitation of the free movement of dangerous goods vehicles (RID wagons) in Italy (see attached letter, as appendix 1 and the corresponding answer from our Italian member association as appendix 2).

Despite the entry into force of legislation 445/2011/EC on a system of certification of entities in charge of maintenance for freight wagons and amending Regulation (EC) No 653/2007, Trenitalia introduces in its own safety management system requirements which clearly violates Article 12 (6) of the EU regulation, according to which the socalled "Self-declaration of conformity of ECM" are recognized equivalent to the certification under either the directive 445/2011/EC or the ECM Memorandum of Understanding till 31st May 2013. This alternative is valid since May 2011 as direct EU law also in Italy and was agreed by the sector as well as by the member states through the RISC decision. Furthermore, a given time limit of less than 1 week to organize the situation for all Self-declared ECM is totally impractical and unrealistic.

1st letter

2nd letter:



Letter to European Commission asking for direct funding of LL blocks

Letter from UIP to the European Commission


In preparation of the workshop on “NDTAC and other rail noise developments” on 27th April 2010 and with reference to the final report “Analysis of pre-conditions for the implementation and harmonisation of noise-differentiated track access charges” Oct. 2009 by KCW , Steer Davies Gleave and TU Berlin for EC DG TREN, as well as with reference to the CER / EIM letter to Mr Castelletti in December 2009 regarding the same topic, UIP has formed the following positions:

It is well known that rail noise affects the neighbours of rail traffic and therefore it must be the common goal of all players in the sector to reduce noise emissions in order to insure the environmental friendly character of rail transport and to maintain the high and favourable levels of acceptance of the rail in society.

However, no additional cost burden must be given to the rail transport mode.

Joint letter to the European Commission for more interoperability and stronger ERA

Joint letter from CER, EIM, UNIFE, UITP, ERFA and UIP to Commissioner Siim Kallas

The rail sector associations have jointly reflected upon the current framework within which safety and interoperability legislation is produced.

As you know, the sector associations work very closely with the European Railway Agency which we recognise has, over the past four years, developed the capacity to support the management of the European rail system.

We believe, however, that there is a need for interoperability in the European railway network to be developed more quickly and for the National Safety Authorities (NSAs) to act in a harmonised way.

In the attached paper you will find more detailed information related to these key points. This paper has been prepared by the rail sector representative bodies and is also supported by the UIC