Position papers

Joint position paper on noise abatement and Swiss ban

CER – UIP – ERFA comments on the consultation - Swiss federal law on railway noise

CER, UIP and ERFA understand and support the intention of the Swiss government to reduce the problem of railway noise and speed up the processes of retrofitting the old and noisy brake block types of freight wagons. However, the measure foreseen (de facto ban of cast-iron brake blocks by January 1st 2020) in the draft law would cause severe problems for the European single market and will create intermodal as well as intra-modal distortion of competition.

CER, UIP and ERFA strongly believe that noise reduction measures should respect the single market. The ban of cast iron brake blocks as foreseen by the federal law from 2020 on would be a barrier to the single market.

Contrary to what is stated in the explanatory note of the Swiss Federal Office for Transport (BAV), it is unlikely that enough wagons and type of wagons (i.e. non-Swiss) will be equipped with composite brake blocks by 2020 in order to compose trains within, to, from and through Switzerland containing silent wagons only. Given the high percentage of non-Swiss wagons (50%) used today for the supply of Swiss shippers (import, export, internal) or running in transit through the country, the actual amount of wagons complying with the provisions laid down in the TSI Noise, the potential capacity of the manufacturing industry for new wagons and the difficult economic situation in general and of rail freight operators in particular it is even too optimistic to expect that the number of new wagons reaches 100 000 in 2020 (only 50% of the amount assumed by the BAV).

Furthermore it will not be economically possible for current foreign wagons to be retrofitted in time. In fact, it will prevent the majority of European wagons to be operated within, to, from or through Switzerland. As a result, rail freight traffic through or within Switzerland will most likely be negatively affected, with a massive impact not only on customers and foreign undertakings but also on Swiss railway companies which operate trains and foreign wagons.


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.