Association of European Rail Rolling Stock Lessors
AERRL
The main purpose of the association is to promote interoperable and safe European rail rolling stock (passenger trains and cargo/passenger locomotives ) by addressing technical, operational, economic, legal and scientific issues and matters relating, directly or indirectly to locomotives, passenger trains, (multiple-units and coaches) operated in the European Union and Switzerland.
ID: 240800342616-10
Lobbying Activity
Response to EU’s next long-term budget (MFF) – EU funding for competitiveness
12 Nov 2025
In the first half of 2025, the Commission initiated the public consultation regarding the next MFF. Consequently, AERRL replied to this consultation by filling in the respective questionnaires. Now, after the Commission published its proposal for the next MFF on 16 July, the Commission has opened a new consultation period following the adoption of the proposal. This consultation covers EU funding for competitiveness and particularly targets two relevant Proposals, namely: the European Competitiveness Fund (ECF), and Horizon Europe (HE), the Framework Programme for Research and Innovation, for the period 2028-2034. The Association of European Rail Rolling Stock lessors is a representative body of the railway sector at EU level. In 2023, a record 3650 locomotives were leased in Europe. This represents 20% of the total main-line vehicles circulating. Lessors are at the forefront of the railway sector development, by investing in the most in modern & cross-border motorised rolling stock in EU. Within the last decade they bought 42% to 45% of newly manufactured locomotives. Lessors are the first investors in locomotive procurement in Europe with ~800 million acquisition per annum for the past 10 years. As these amounts increase, we expect an investment of one billion euros a year by 2027. These numbers surpass the volume of incumbent operators. Lessors own almost half of the ERTMS European fleet. If we consider the European locomotive fleet as 31/12/2023, we see that 61 % of the lessors fleet is electric, while railway companies achieve only 47 %. Considering the 2025 leased fleet, 80% of the newly ordered are electric. We urge the Commission to consider the following factors: - Innovation is important to ensure the future of European rail, but standardisation and simplification are much more significant priorities, as they are a prerequisite for the commercial success and enhance the survival of today's railways. Without standardisation, the cost of European rail becomes untenable as a competitive mode of transport, risking an ever-growing reverse modal shift. In this context, innovation could be of a strategical asset. The adoption of a different deployment plan for key technologies like ERTMS, based on the deployment of a single and stable technology at a European level, would be a great strategic innovation that would provide a significant boost to the European rail sector, putting an end to the unsustainable fragmentation undermining the whole sector. -The preparatory work for the deployment of new technologies must in any case consider the interests of all European stakeholders. On-board migration strategies should be designed based on product strategies, developed by OEMs, with backwards compatibility guaranteed to existing ETCS equipped locomotives, as a key principle. Stable technologies (for ETCS, FRMCS and DAC) are needed to ensure standardisation and an economic viable model for the deployment of rolling stock. We need Technical Specifications of Interoperability regulations that support the use of existing locomotives and not limiting it, therefore innovations shall be on an optional basis and not binding to all vehicles. We also need a strategy to achieve a zero-emission fleet in 2050, by supporting a European roadmap based on the dual-mode battery-electric technology with partial electrification as game-changing technology.
Read full responseResponse to Circular Economy Act
29 Sept 2025
AERRL welcomes the Commissions call for evidence to the circular economy act. This act is vital to the European economy but specifically for the rail sector as well. It creates vast opportunities both in terms of competitiveness but also strengthening the environmental credentials of the sector and further reducing costs to create a more vibrant and resilient sector. As major investors in locomotives and new technologies across Europe, lessors are keen to make sure that their products have a lifespan of at least 30 years. The need to develop legislation that ensures lifespans of at least thirty years for locomotives is critical to the sector for the following reasons: - Environmental sustainability: Rail transport is a very environmentally friendly mode of transport; however, the environmental performance of the production phase of its main assets must be continuously improved. - Competitiveness: Maintainability and obsolescence risk of locomotive secured over at least 30 years after delivery are key to achieve sufficient competitiveness of rail transport. - The sector needs to reap the benefits of the circular economy in terms of both product longevity and the reuse and recycling of parts. - As rail rolling stock lessors, we ask the European Union to edict rules contributing to guaranteeing a lifespan of at least 30 years after delivery for locomotives, through - By law guaranteed access until 30 years after delivery to spare parts, product expertise, obsolescence remediation solutions, - By law guaranteed access to the source code for software installed in the locomotives. The longevity and continuation of production of spare parts is vital to the sector. The ability to recycle and reuse parts could also be promoted because it further creates business opportunities and creates a new space within the sector therefore strengthening its resilience as well as creating an atmosphere of competitiveness.
Read full responseResponse to European Research Area (ERA) Act
8 Sept 2025
AERRL welcomes the Commissions call for on the European Research act. We are particularly sensitive to the objective of reducing fragmentation. In the rail sector, fragmentation is a scourge that we are fighting in order to achieve the simplification and harmonisation of standards and procedures at European level. This is essential in order to finally build the single rail market. The Association of European Rail Rolling Stock lessors is a representative body of the railway sector at EU level. In 2023, a record 3650 locomotives were leased in Europe. This represents 20% of the total main-line vehicles circulating. Lessors are at the forefront of the railway sector development, by investing in the most in modern & cross-border motorised rolling stock in EU. Within the last decade they bought 42% to 45% of newly manufactured locomotives. Lessors are the first investors in locomotive procurement in Europe with ~800 million acquisition per annum for the past 10 years. As these amounts increase, we expect an investment of one billion euros a year by 2027. These numbers greatly surpass the volume of incumbent operators. Lessors own almost half of the ERTMS European fleet. If we consider the European locomotive fleet as 31/12/2023, we see that 61 % of the lessors fleet is electric, while railway companies achieve only 47 %. Considering the 2025 leased fleet, 80% of the newly ordered are electric. We urge the Commission to consider the following factors: - Innovation is important to ensure the future of European rail, but standardisation and simplification are much more significant priorities, as they are a prerequisite for the commercial success and enhance the survival of today's railways. Without standardisation, the cost of European rail becomes untenable as a competitive mode of transport, risking an ever-growing reverse modal shift. In this context, innovation could be of a strategical asset. The adoption of a different deployment plan for key technologies like ERTMS, based on the deployment of a single and stable technology at a European level, would be a great strategic innovation that would provide a significant boost to the European rail sector , putting an end to the unsustainable fragmentation undermining the whole sector. - The preparatory work for the deployment of new technologies must in any case take into account the interests of all European stakeholders. On-board migration strategies should be designed based on product strategies, developed by OEMs, with backwards compatibility guaranteed to existing ETCS equipped locomotives, as a key principle. Stable technologies are needed to ensure standardisation and an economic viable model for the deployment of rolling stock. We need Technical Specifications of Interoperability regulations that support the use of existing locomotives and not limiting it, therefore innovations shall be on an optional basis and not binding to all vehicles
Read full responseResponse to EU vision for enhancing global climate and energy transition
8 Sept 2025
AERRL welcomes the Commissions call for on EU strategy to boost global climate and energy transition. This act is vital within the European economy but specifically for the rail sector as well. It creates vast opportunities both in terms of further enhancing the environmental credentials of the sector as well as strengthening the competitiveness of the rail sector. The Association of European Rail Rolling Stock lessors is a representative body of the railway sector at EU level. In 2023, a record 3650 locomotives were leased in Europe. This represents 20% of the total main-line vehicles circulating. Lessors are at the forefront of the railway sector development, by investing in the most in modern & cross-border motorised rolling stock in EU. Within the last decade they bought 42% to 45% of newly manufactured locomotives. Lessors are the first investors in locomotive procurement in Europe with ~800 million acquisition per annum for the past 10 years. As these amounts increase, we expect an investment of one billion euros a year by 2027. These numbers greatly surpass the volume of incumbent operators. Lessors own almost half of the ERTMS European fleet. If we consider the European locomotive fleet as 31/12/2023, we see that 61 % of the lessors fleet is electric, while railway companies achieve only 47 %. Considering the 2025 leased fleet, 80% of the newly ordered are electric. We urge the Commission to consider the following factors: - Environmental sustainability- With rail making up less than 1% of total EU emissions the rail sector it is the most sustainable way to boost the climate and energy transition. Further on that regard investment needs to be made as rail infrastructure is the most affected by climate change. An advanced, interoperable, safe and resilient transport infrastructure network - as outlined in the TEN-T Guidelines Regulation - is therefore fundamental to the European Union's security and global competitiveness. - Competitiveness- Innovation is important to ensure the future of European rail, but standardisation and simplification are much higher priorities, as they are a prerequisite for the commercial success and hence the survival of today's railways. AERRL advocates for consistent and European Technical Standards that promote compatibility all across the Union. Standardisation can greatly help in achieving a one locomotive fits all countries model, which would reduce costs at all levels and for all stakeholders involved. To achieve this objective the TSIs must be implemented in a harmonised way. - Net Zero fleet- AERRL remains committed to ensuring that the sector continues to strengthen its role in sustainable mobility committing to a net zero fleet being a major part of this commitment. We strongly believe that the technological swap from diesel traction towards more sustainable energies and technologies must be supported by a European framework which should include support to innovation, definition of standards and investment to the benefit of an open access fuelling network.
Read full responseResponse to Connecting Europe through high-speed rail
5 May 2025
The Association of European Rail Rolling Stock Lessors (AERRL) welcomes the European Commissions commitment to further developing high-speed rail across Europe. As major investors in cutting-edge rail technologies, the leasing sector plays an increasingly active role in passenger rail, with high-speed rail becoming a growing area of interest. Our ability to invest in advanced safety and interoperability solutions positions us as a key partner in realising Europe's high-speed rail ambitions. Our vision for a truly efficient, competitive, and sustainable pan-European high-speed network is built on two fundamental priorities: interoperability and standardisation. We firmly believe that the successful deployment of high-speed rail is intrinsically linked to the deployment of the European Rail Traffic Management System (ERTMS). High-speed services can only grow within an interoperable network underpinned by stable and harmonised technological frameworks. However, past experiences have shown that fragmented regulatory frameworks and a lack of coordinated trackside deployment have made technologies implementation excessively costly often outweighing the benefits. To address this, we strongly advocate for the adoption of a single, stable variant of ETCS across Europespecifically, Baseline 3.4. This version is currently the most stable and widely deployed, and its long-term use would provide the certainty required for large-scale investment and deployment. Aligning all efforts around a single standard will ensure that interoperability becomes a driver of high-speed rail expansion. In parallel, we stress the urgent need for greater standardisation of high-speed rolling stock. As demonstrated in the aviation sector, standardisation would have a strong potential for efficient and secure investments in high-speed. For the high-speed rail leasing market to flourish, a shared technical framework for train models is essential. Drawing on the success of standardisation initiatives in the rail freight sector, the leasing industry is willing to invest in a standardised high-speed train model. This would not only accelerate deployment but also reduce costs, improve safety, and stimulate cross-border operations. Standardisation would therefore become a powerful enabler of a solid, interconnected European high-speed network. In conclusion, we urge the European Commission to make interoperability through a unified ERTMS deployment, and standardisation of high-speed rolling stock, central pillars of its strategy. These priorities will ensure that high-speed rail becomes a true backbone of European connectivityefficient, sustainable, and future-ready.
Read full responseMeeting with Joachim Luecking (Head of Unit Mobility and Transport)
4 Feb 2025 · Introductory meeting new Head of Unit DG MOVE C.4 Presentation of the membership and work of AERLL + Overview of AERLL position on main challenges of the sector
Meeting with Joachim Luecking (Head of Unit Mobility and Transport)
4 Feb 2025 · Introductory Meeting
Response to Interim evaluation of the Connecting Europe Facility 2021-2027
19 Sept 2024
AERRL, the association representing European Railway Rolling Stock Lessors, welcomes this evaluation aimed at measuring the progress made in achieving CEF 2s objectives and assessing whether the rules are working as intended. Being active in the railway sector, the projects of most importance to us are the ones related to improving cross-border connectivity and interoperability, mainly through ERTMS and FRMCS implementation and other technologies. We support the funding mechanism and have been able to assess its benefits for ourselves. Nevertheless, we believe that as far as support for investment in rolling stock is concerned, these mechanisms should be used exclusively for the deployment of ERTMS, FRMCS, DAC and all research and development projects likely to facilitate cross-border operations or prepare for the end of diesel traction. We believe that the allocation of CEF to the financing of new equipment constitutes a major risk of market distortion, that it will have the effect of making the market less competitive. At a time when our industry needs private investment to develop, a lack of a level playing field could seriously harm the sector. As we have said, we are aware that ERTMS requires subsidies because it is a proven market failure. Without the CEF, it would be impossible to achieve the EU's objective. AERRL therefore urges that the CEF be increased to include funding for ERTMS modernisation and rolling stock modernisation at 100% of total costs. Newly delivered vehicles with ETCS that have received funding through the CEF are competing with existing modern and efficient rolling stock. This older equipment requires renovation or upgrading. While many retrofit projects are not co-financed by the EU, those that are eligible benefit from complex support mechanisms that cover just 20%. For more than 10 years, leasing companies have been investing in more than 40% of the locomotive fleet delivered in Europe. Our equipment accounts for more than 60% of the ERTMS-equipped fleet in Europe. Over the last few years, we have been pioneers who have catalysed the market and contributed to the emergence of numerous ERTMS projects for freight by financing most of the prototypes and tests. We also believe that the sector could benefit -from a more synchronised deployment and better prevention of overlaps in research and development (mainly between the ERJU, the CEF and the Member States); -from clearer ultimate decisions regarding the beneficiaries; - from level of funding better proportionate to the significant number of applications submitted and the needs.
Read full responseResponse to Revision of fees and charges of the European Union Agency for Railways
2 Apr 2024
The railway sector stakeholders represented here by AERRL, ALLRAIL, CER, EIM, ERFA, UIP, UIRR and UNIFE - consider any cost increase as a major challenge for the competitiveness of the European rail sector. The increases should be offset against the efficiency improvements promised with the 4th Railway Package. Especially since the railway stakeholders face corresponding costs within their own companies and from their contractors. While we acknowledgean overall cost increase in the limits of inflation, for the sake of transparency we request the calculation method of these costs be made publicly available. The new fixed fee of 26500 proposed under Art 3(3)a and item 4 in table B of the Annex (authorising a vehicle type - freight wagons when the area of use is whole Union) actually exceeds the experienced costs under the currently hourly rate method. We also recall that the fees for a wagon type authorisation under the 3RP were significantly lower than today under the 4RP. Given the objective of the European Commission to boost the efficiency, sustainability and competitiveness rail freight services across the European Union, we recommend to lower the fees for freight wagons either via a revised fixed fee proposal or by keeping the hourly rate method for the type authorisation. The wording for Art 2(2)h anditem 8 in table B of the Annex (Processing of notifications, including decisions of the Agency in accordance with Article 16(4) of Implementing Regulation (EU) 2018/545) needs to be refined. It shall be made clear that the amount of 3.710 is a lump sum for all notifications of a type of vehicles and not for individual vehicles. This would lead to enormous costs otherwise. The 3710 is also significantly higher than experiences of an applicant when exchanging information according with Article 16(4) with the German NSA, in the range between 600 to maximum 1200. We do not support the possibility for NSAs to delay their input and ERA to issue an invoice without the associated NSA costs proposed under Art 5(3). Allowing NSAs to recover costs directly with the applicants at an undefined time passes the administrative burden over to the applicants and contradicts the principle of one OSS application one invoice as established when drafting of (EU) 2018/764. The new 20 calendar days period for the NSAs to provide their cost statements to the ERA should be sufficient and the second half of the proposed Art 5(3) should be deleted. Art 5(1) now gives ERA 60 days rather than 30 to solve this. The fixed fees for conformity to type (CTT) authorisations found in item 1 in table B of the Annex have now undergone two indexations, standing at 11,6% higher than those established by (EU) 2021/1903. We believe these fixed fees need to be recalibrated to reflect the efficiency gains in the CTT process reported by the Agency in subsequent years and quality improvements of the applications following 3 more years of experience. It is understood that the hours required to process the CTT applications are now lower than in 2021 and as such the fees should also be adjusted to reflect this and incentivise continued improvement in the processes. For Special Vehicles we should consider that the IMs yellow fleets are far smaller compared to the commercial ones, and so their authorisation costs cannot be distributed across a large number of vehicles. The EC and ERA should consider how to mitigate that impact the authorisation costs have on these vehicles. If we add up all the cost elements for vehicle authorisation on a case-by-case basis, we concludethat the accelerated roll-out of European Rail Traffic Management System (ERTMS) both on the side of Infrastructure Manager and Railway Undertakings as well as the Digital Automatic Coupler (DAC) is at risk. We recommend addressing the issues of vehicle and trackside authorisation in the framework of the accelerated ERTMS rollout and DAC deployment.
Read full response2 Apr 2024
AERRL and its members are committed to promoting the modal shift to rail by increasing the availability of modern, affordable, and safe locomotives as well as passenger coaches and multiple units for railway undertakings. We believe that in order to apply to the least distortive forms of aid Public Funds should not be aimed at the Railway Rolling Stock Market and we vouch for prior control by the European Commission as always preferable. When distorting aid is granted it is often too late or too difficult to correct the situation and repair the damage. Please find attached our full position on the consultation related to State aid for sustainable land transport block exemption regulation.
Read full response