Position papers

Roadmap of the Sustainable and Smart Mobility Strategy

The International Union of Wagon Keepers (UIP) strongly supports the Commission’s plan to adopt a comprehensive strategy to meet the Green Deal target of a 90% reduction in transport-related greenhouse gas emission by 2050. This target can only be achieved by significantly increasing rail freight transport in Europe and by coming up with newer and more innovative measures than in the past. To do so, we recommend the following measures:


Higher priority must be given to rail freight in terms of capacity allocation

The COVID-crisis and the freeing up of capacity on the European railway network have shown that the quantity and quality of capacity which is offered to rail freight matters and can render rail freight more punctual and reliable, hence making it an attractive option to shippers. Therefore, higher priority must be given to rail freight on the whole network when it comes to the allocation of capacity. The revision of the Regulation (No) 913/2010 on Rail Freight Corridors (RFCs) should aim to correct the current imbalance and simplify operations and procedures.


Financial incentives for shippers to facilitate the modal shift

Until the preconditions for more efficiency in rail freight are given, financial incentives should be given to shippers to facilitate the modal shift to rail as the greenest mode of transport. Here the right financing instruments should be created, and the revised European Commission State Aid guidelines should not obstruct such national subsidies.



COVID–19 - Creating a Fair and Balanced Temporary State Aid Framework for Rail Freight

Rail freight will face significant challenges to continued operations over the coming months, particularly in light of a significant slowdown in industrial output due to national measures taken to control the outbreak of COVID-19. These short-term measures could cause longer term damage to the sector, namely the disappearance of operators and capacity, if measures are not taken to support the industry. ERFA and UIP therefore call for State support measures to be granted to Infrastructure Managers coupled with a short-term waiving of Track Access Charges and Energy Charges for rail freight undertakings.

The outbreak of COVID-19, and national responses to stem to spread of the virus, have created significant challenges to the short-to-medium term viability of rail freight operations. Industrial output is limited and this is leading to a reduced demand for freight movement, including rail freight. These national responses are merited and supported, but it must still be recognised that measures are warranted to support the industry.

Given the exemptional circumstances, ERFA and UIP believe it is appropriate to use Article 107(2)(b) and Article 107(3)b of the TFEU to allow Member States to assist the sector over the coming months. Any mechanism must be horizontal, sectoral and compliant with existing competition rules. The objective of any aid must solely be to assist all operators on a short-term basis and solely address difficulties directly or indirectly related to the slowdown of economic input and reduction of traffic.

ERFA and UIP strongly believe that short-term support is essential in order to ensure that rail freight undertakings are in a healthy condition once industrial output resume. Without government actions there is a risk that operators will cease to exist or have to significantly reduce their capacity which would have a longer lasting impact on Europe’s modal shift objectives.

We therefore believe that state support is warranted and necessary, but must be done in a way that benefits the rail freight industry equally and only addresses short-term issues related to COVID-19.



GRB Position on the route compatibility check

This position paper sets out the Group of Representative Bodies’ (GRB) view on the general principles for the route compatibility check (RCC) before the use of authorised vehicles as outlined in Article 23 of the Interoperability Directive (EU) 2016/797. 

The Group of Representative Bodies asks the European Union Agency for Railways to adopt the RCC principles set out in this paper. The GRB asks for clear guidance documentation to be developed by the Agency for how the route compatibility process should be implemented in the day to day business where appropriate, either in a dedicated RCC application guide or in a section of existing guide documents.

The two concepts of technical compatibility with the network on one hand (article 21) and route compatibility on the other hand (article 23) as laid out in the interoperability directive shall be respected and kept separately. However, clear guidance is necessary to understand the content and responsibilities included and to ensure the route compatibility check performed by the railway undertaking is as easy, lean and straightforward as possible.