Position papers

Joint position paper on a new role for the European Railway Agency (ERA)

CER, UNIFE, ERFA and UIP position on the Future role of ERA


One of the key targets of European transport policy is to achieve a Single European Railway Area. For this purpose four key objectives shall be pursued:
• Promoting the development of effective rail infrastructure;
• Establishing an attractive and genuinely open rail market;
• Removing administrative and technical barriers and developing easy and common (Member States neutral) procedures on European level;
• And ensuring a level playing field with other transport modes

In this context, CER and UNIFE call for setting the strategic target of aiming at achieving the single European railway area by incrementally establishing a single European railway vehicle authorisation. The Regulation establishing a European Railway Agency [(EC) No 881/2004] should be correspondingly amended. This is perfectly in line with the Commission objective of removing administrative and technical barriers, whilst contributing to establishing an attractive and open rail market.

In the first place however there is a strong need for the European Commission to push Member States to effectively transpose the Safety & Interoperability directives.
Two decades after the decision to revitalise European rail transport, and more than a decade after the publication of the first Directive on the Interoperability of the European railway system, the legal framework of the European railways has been deeply transformed.

In spite of this, we still face problems based on the gap between theory (the legal framework) and practice (diverging application by Member States).

Thus, in spite of the implementation of a basic legislative framework for the interoperability and safety of the European railway system, interoperability is still far from being achieved and measures have to be taken to reach this objective sooner, with all actors acting in a harmonised way.

It can be expected that a harmonised system will be reached step-by-step together with an increase in the quality and quantity of specifications as well as of the scope of application – while nevertheless taking into consideration economic realities. Interoperability is – to a large extent – “cross acceptance” and a “single process for placing into service of vehicles”. When looking at existing and long-lasting infrastructure subsystem/constituents, they will not meet the specifications for interoperability for another decade or even more - until they are renewed or upgraded.

A single European railway area cannot therefore be achieved without developing ERA’s role and without accelerated application of the TSIs through the extension of their geographic scope and the consequent reduction in national rules, coupled with more effective ERA engagement with the National Safety Authorities and the Member States.

Joint position paper on a European rail network for competitive freight

Joint Industry Position Paper on the Proposal for a regulation of the European Parliament and of the Council concerning a ‘European rail network for competitive freight’ 


Major global and European customers, shippers, forwarders, independent train operators and other representative interest groups are calling on the European Parliament Transport and Tourism Committee to support and strengthen the Commission’s proposed Regulation for the vote planned on the 31st March 2009. All share the merit of this proposal which aims to set reasonable priority rules for rail freight and are asking MEP’s and institutions to proceed in the direction of swift approval, while strengthening its content.

These groups and companies comprise the majority of the European transport and logistics industry, traders, manufacturers and many train operators, all wishing to increase their use of rail. They have been calling on the Commission, the European Parliament and the Council of Ministers for more than two years to create a rail network partly or wholly dedicated to freight so that they can obtain or provide efficient, cost effective and reliable services. They may compete with each other and with other modes but they all need a single market for freight on rail as should be the case for all modes of transport.

Such companies will invest to improve services and efficiencies if they can have the confidence that they can have fair and consistent access to tracks and terminals, sidings and last miles, service reliability for the whole chain (including trains, loading and unloading processes, dispatching), minimal technical and legal problems with frontiers and a reasonable priority for the goods being transported.

Recognising the great potential of rail freight corridors for increasing the competitiveness of rail freight transport, the Commission has invested € 4m in the New OPERA project intended to create a network of new and upgraded routes to enable rail freight to triple in volume by 2020. This draft Regulation is the first stage in implementing it on a wider scale.

It will make rail freight more competitive and genuinely seamless from one border of the EU to the other. This is what European industry at large needs and what Europe deserves. It is also one of the building blocks of any future European rail freight strategy.

We expect and hope that, because of the strategic importance of a single freight network for its users – but also for industry, environment and the citizens – the EU and the Member States will provide the necessary investment on these corridors to enable better quality and growth; it must include not only the infrastructure but also sidings, interior and sea ports, airports plus open access yards and terminals. It should be  included in individual Member States’ and the EU’s economic stimulus programmes.

Joint position on noise abatement

Consultation document of the Commission's Services - Rail noise abatement measures addressing the existing fleet

Sector representatives are pleased by the activity of the DG TREN since they support lowering of environmental impacts of transport system, including those of rail vehicles.

It is worth to mention that railways already procure new vehicles with composite brake blocks and bear the risk on their own account.

The cost efficiency of freight rail transport is one of the key issues and any one sided additional financial burden imposed to rail sector will affect its competitiveness and result in a potential modal shift from rail to road with an adverse effect on the environment which would be inconsistent with the EU’s transport and environmental policy objectives.

The retrofit process shall not create any new charges for wagon owners and consequently for their clients, in order to prevent any additional financial burden on the railway freight transportation market.

Our policy suggestion would be:

  • to favour European and national subsidies for the short term retrofitting, providing those national subsidies do not distort competition between rail freight operators. A part of the financial means could be transferred from infrastructure measures, provided the overall effects for infrastructure managers in terms of costs and benefits are neutral. Differential track access charges could be used at a later date to maintain a silent freight fleet, however not before the end of the migration phase.
  • not to impose legally binding measures on freight operators, especially since the type and cost of solutions vary considerably depending on the wagon-fleet considered and since important technological issues remain unsolved, Freight wagon owners shall be free to make the choice of technology for retrofitting.

More generally sector representatives consider a global cost-analysis should be performed taking into consideration the overall social efficiency of these measures, including their externalities and potential adverse effects on the modal shift between rail and road.