European Rail Freight Association
ERFA
ERFA is the European organization representing private and independent rail freight companies.
Lobbying Activity
ERFA urges EU to open military logistics to private rail
24 Oct 2025
Message — ERFA requests smaller logistics tenders and faster security clearances to include private companies. They also seek a unified European rail area with common technical standards and English-speaking drivers.12
Why — Private rail operators would secure a larger share of the military logistics market.3
Impact — State-owned incumbent rail companies would face increased competition for military transport and equipment.4
ERFA urges EU Ports Strategy to prioritize rail connectivity
28 Jul 2025
Message — ERFA requests a sufficient landside perspective focusing on hinterland rail connectivity within the strategy. They argue that completing railway infrastructure according to TEN-T parameters, including 740m trains, must be a priority. The strategy should also outline investments for railway infrastructure to ensure rail supports port competitiveness.123
Why — Standardizing infrastructure for longer trains would improve the competitive environment for rail freight.4
Impact — Trucking companies may lose market share as ports prioritize rail for landside transport.5
Response to EU harmonised specifications for rail freight wagons
2 Jun 2025
ERFA is the European organisation representing the interests of private and independent rail freight companies active in the European Union. ERFA and its experts have continuously participated and contributed to the latest activities related to the revision of the TSI WAG to include new requirements on devices to secure semi-trailers, supported by a new technical document. ERFA does not believe there is consensus on this issue and there is significant need for clarifications before any decision can be taken. The 85kN locking force requirements appear to be unsuitable for most of wagon series. In particular, ERFA has concerns with the retroactive nature of the proposal. Retroactivity is not technically justified, is economically disproportionate, and risks seriously harming the competitiveness of intermodal rail freight. ERFA believes the proposal would lead to the early obsoletion of functioning wagons as the proposal is not economically viable. Even in the event of economic viability, ERFA would have serious concerns about the operational viability of having to retrofit the European wagon fleet. The inclusion of the "device to secure semitrailers" component as "Interoperable Component" should be further investigated, as this choice brings with it important economic as well as technical-operational impacts, with no real benefits and increasing bureaucratic management. Concerning the issue of crosswinds, ERFA strongly believes this should be addressed though infrastructure upgrades and operational procedures. ERFA believes that transposing local issues into the European legal framework will have a disproportionate impact and hamper European rail freight as a whole. ERFA firmly disagrees with the application of the new requirements in the TSI WAG regarding the device to secure semitrailers and strongly recommends to further investigate the actual impacts of the proposed recommendations for new and old wagons.
Read full responseResponse to Connecting Europe through high-speed rail
8 May 2025
As the voice of private and independent rail freight operators to the EU institutions, the European Rail Freight Association (ERFA) is pleased to contribute to the call for evidence prior to the publication of the Commissions Communication on Connecting Europe through High-Speed rail. First, it must be clearly emphasised that such a Communication shall not forget to include a rail freight component because rail freight and passenger traffic are closely intertwined, because rail freight operators are in many cases direct users of high-speed lines and because the project of linking EU capitals and major cities by high speed rail should be carefully addressed to make sure it clearly corresponds to the real needs of the rail sector and society as a whole. It must be said that the future Communication should not reinvent the wheel in mapping potential new high-speed lines while the EU recently adopted the revised TEN-T Guidelines Regulation which are already listing the infrastructure networks, corridors and parameters to be deployed throughout the EU and with a clear cross-border dimension. At the very least, the Communication should be fully TEN-T compliant. With only few exceptions, current high-speed lines have a clear national focus and are already well developed in many EU Member States, mostly from Western Europe. Additional projects would therefore imply a greater cross-border dimension. In that regard, it must be noted that rail freight accounts for 59% of international traffic within the EU. Half of freight trains cross an internal EU border during its journey, a figure rising to 90% for intermodal trains, the most dynamic section of the rail freight market. With this in mind, it appears clearly that at the moment rail freight operators have actually a larger interest in better cross-border rail infrastructure than passenger operators. Indeed, passenger operators have often demonstrated their lack of focus on establishing better international connections. Many examples across the EU of underutilised rail infrastructure by passenger operators despite sometimes excellent (even high-speed) infrastructure exist. When considering additional high-speed lines, the Communication should recall the need to carefully assess to what extent rail freight traffic could benefit from these lines as mixed high-speed lines accommodating both traffic exist, especially when crossing borders (Perpignan-Figueras line for instance). Building high-speed lines should also be an opportunity to free additional capacity for freight trains along parallel conventional lines rather than concentrating most funding on high-speed lines and disregarding most needed investment in maintenance and modernisation of conventional lines which concentrate most daily traffic for both passenger and freight, as alarmingly observed in many Member States during the last decades. Furthermore, as many countries are starting to renovate their existing high-speed lines now built several decades ago, more and more traffic will be temporarily transferred on parallel conventional lines, making their maintenance and modernisation even more crucial. In that regard, and as emphasised by a dedicated report of the European Court of Auditors, decision-makers should carefully assess whether high-speed or ultra-high-speed is really needed for new projects when sometimes, additional capacity and mixed traffic would be better accommodated at much lower cost on a new conventional line. Finally, the Communication shall highlight that when it comes to improving cross-border rail traffic, everything is not about infrastructure. It already exists a list of concrete, tangible and cheap progress that can be made quickly via a reduction of national rules, a better management of rail capacity across networks thanks to the Commission Proposal on Rail Infrastructure Capacity Management, and simplified language requirements in the upcoming revision of the Train Drivers Directive.
Read full responseMeeting with Apostolos Tzitzikostas (Commissioner) and Deutsche Bahn AG and
26 Feb 2025 · Intermodal Transport
Meeting with Tilly Metz (Member of the European Parliament, Rapporteur)
18 Dec 2024 · Railway capacity
Meeting with Magda Kopczynska (Director-General Mobility and Transport)
3 Jul 2024 · Exchange of views on Digital Automatic Coupling (DAC)
28 Mar 2024
ERFA, as the voice of private and independent rail freight undertakings, welcomes the opportunity to share its views on the call for evidence for an impact assessment on a new land transport block exemption regulation. As already expressed during the consultation before the adoption of the New Land Transport Enabling Regulation, ERFA is of the view that simplified State aid rules have the potential to make State aid more in line with the rail freight growth targets set for 2030 and 2050 in the Sustainable and Smart Mobility Strategy. ERFA supports State aid schemes that can be delivered on a fair, transparent and non-discriminatory basis, therefore not creating competition distortion between historic incumbent operators and new entrants. As the rail freight market is made of a significant number of small actors, it is crucial that support schemes are designed in a way that do not create artificial barriers of entry, such as a high level of administration burdens. The Fitness Check identified a number of categories of State aid schemes that frequently renewed by the Commission, such as aid for external cost reduction, aid for infrastructure use, aid for interoperability and aid for facilities such as intermodal terminals and private sidings. These are categories that can be supported under the new block exemption regulation. On the specific category of aid for interoperability which therefore relates to rolling stock, ERFA recommends a cautious approach as large State aid schemes for the purchase of new rolling stock could create competition distortions. The diversity of the rail freight market and the existence of a broad number of small operators suggest that there are no systematic problems related to accessing rolling stock. Therefore, State aid schemes related to rolling stock should be limited to cases where there is a clear and proven market failure. Legitimate application would include pursuing environmental goals (such as noise reduction), achieving market harmonisation and interoperability via the deployment of new technological developments (such as ETCS or DAC). Such schemes should be accessible to the whole sector in a non-discriminatory manner and be applied evenly to both railway undertakings and leasing companies. In regard to the threshold for aid that could fall under block exemptions, the general principle should be to avoid supporting unsustainable business practices by State aid schemes for infrastructure use and reduction of external costs. However, when it comes to aid for interoperability, a threshold raised up to 100% would be necessary as railway undertakings are currently mandated to invest significant amounts in ETCS on-board units whereas they do not have the necessary financial resources to do so, and they experience no operational improvements thanks to ETCS deployments. Therefore, such schemes should enter into the scope of the new block exemption regulation. The drafting of the new land transport block exemption regulation should go hand in hand with the revision of the Railway Guidelines. ERFA will keep sharing its views and guide policymakers in the drafting of both documents all over the coming months.
Read full responseResponse to Revision of fees and charges of the European Union Agency for Railways
28 Mar 2024
The railway sector stakeholders collectively represented by ERFA, 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 and registrations 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 responseResponse to Revision of Combined Transport Directive
5 Feb 2024
ERFA, as the voice of private and independent rail freight operators in the EU, welcomes the opportunity to react to the publication of the proposal amending the Combined Transport Directive. This revision process is a welcome move to update a 31-year-old text and a crucial opportunity to strengthen the support for rail-road combined transport, a key element in the decarbonisation of freight transport as to be able to reach the modal shift targets set for 2030 and 2050 in the Sustainable and Smart Mobility Strategy. ERFA would like to make the following remarks to decision-makers on the proposed text: 1) Any changes to the current system must not create additional administrative burden for operators without providing substantial benefits. The pillars of the Directive must be based on predictable, user-friendly and well-tested tools that offer the ability for users to know well in advance which operations enter into the scope of the Directive. 2) The policy objective of reducing the operating expenses of combined transport operations by at least 10% should be taken into account by policymakers in light of the ongoing revision of the Weights & Dimensions Directive where envisaged measures might increase the competitiveness of unimodal road operations by up to 20 to 40%. As to not undermine the market share of combined transport, the National Policy Frameworks objective should be significantly increased and mirror the effects of the envisaged measures in the revised Weights & Dimensions Directive. The proposed 90-month deadline needs to be shortened. 3) The Commission should acquire more scrutiny power to ensure that National Policy Frameworks are sufficient to reach their declared policy objective and the modal shift targets set for 2030 and 2050. 4) In giving to Member States the responsibility to design support measures, the Commission created the risk of complexifying cross-border combined transport operations due to a patchwork of diverging and sometimes even conflicting national schemes. As to reduce this risk, the Commission should clarify in detail how to implement each measure mentioned in the toolbox and ensure that there is a sufficient level of coordination between Member States, especially along the future European Transport Corridors. 5) As national support schemes in favour of combined transport are often patchy, temporary and uncoordinated, regulatory measures offer a stabler approach that is able to give more long-term certainty for the sector. This is why co-legislators must reflect on other regulatory measures to be put into the Directive such as additional exemptions, special treatments and conditions. 6) In that regard, the extension of the scope of the Directive to national combined transport and empty container transport operations, the exemption of driving bans for the road leg of combined transport operations during nights, weekends and holidays, and opening the possibility for Member States to reimburse taxes on road vehicles in combined transport operations are three very positive elements.
Read full responseMeeting with Tilly Metz (Member of the European Parliament, Rapporteur) and Community of European Railway and Infrastructure Companies and
29 Nov 2023 · Rail Capacity proposal
Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail
14 Nov 2023
As the voice of independent and private rail freight companies in the EU, ERFA is pleased to share its views on the proposal for a Regulation on the use of Railway Infrastructure Capacity in the Single European Railway Area. Whilst the draft Regulation provides a good framework, the text requires a number of improvements as to be able to deliver a railway capacity management system that meets the needs of rail freight. It should be make clear that numerous aspects of the current text should be supported by policymakers and the Commission should work to ensure that these points are maintained throughout the upcoming negotiations between co-legislators. These positive provisions include the establishment of rolling planning, multi-network capacity rights in a single place and in a single operation, reciprocal commercial conditions for infrastructure managers and railway undertakings, regular updating of infrastructure managers strategic planning, and the introduction of an independent performance review body and mechanism. ERFA would also like to highlight that improvements are required on different points of the text. First, on the right of infrastructure managers to refuse capacity requests. Under the current draft, infrastructure managers are allowed to reject annual timetable path requests which do not match its corresponding capacity supply plan (Article 32.5). Applicants must be informed of the intention of the infrastructure managers to refuse the request while similar provisions also exist for rolling planning. Rail freight undertakings require much more tailor made capacity offers in a system that is flexible, reflect the reality of rail freight traffic and allow the possibility of evolving market-demand changes. This is why infrastructure managers offer alternative solutions where railway undertakings demands do not align with capacity supply plans. It is only when there is no appropriate capacity available that infrastructure managers can be in a position to refuse the capacity requests. Second, on governance structure. ERFA truly supports the choice to maintain a decentralised approach to capacity management and approves the general function of ENIM. However, the role and function of the Network Coordinator must be questioned as he/she will lack a clear separation of powers by being directly appointed by ENIM and mandated to act on its behalf. In such a context, ERFA questions the added value the Network Coordinator offers beyond acting as a secretariat of ENIM. This is why we propose a neutral oversight body, namely ENNRB, responsible for monitoring ENIM performance, mediate conflict resolutions and act as a neutral party in the event of complaints. The neutral oversight body should be assisted by formal advisory groups representing railway undertakings. Third, on railway undertaking representation. Unlike in the current text, ENIM should be able to carry out meaningful consultation with users. A specific body should be introduced to offer the possibility for railway undertakings to provide active input at the beginning of strategic planning development. This body should also have the right to ask ENIM for process changes and make independent evaluations to ENIM, ENRBB and the Commission. And finally, on implementation date. Most elements of the current proposal will only enter into force in 2030. This is far too late for this Regulation to play any positive contribution in reaching an increase of 50% in rail freight volumes by 2030 as set by the EU. While the text should offer sufficient time to elements related to capacity planning, most of the text of the draft Regulation can be introduced in the next timetable after its adoption, including coordination of the allocation of multi-network capacity rights, framework agreements, compensation, performance review and regulatory oversight. ERFA will continue to play an active role in guiding policymakers to improve this draft Regulation.
Read full response20 Jul 2023
ERFA, the European Rail Freight Association promoting the interests and views of private and independent rail freight companies in Europe, welcomes the possibility to provide its members feedback on this open consultation. In agreement with the sister organisations CER and EIM, please find herewith our common statement: The Community of European Railway and Infrastructure Companies (CER aisbl), the European Association of Rail Infrastructure Managers (EIM aisbl) and the European Rail Freight Association (ERFA asbl) bringing together close to 100 European railway undertakings, their national associations, vehicle leasing companies as well as rail infrastructure managers support the proposal for a decision of the European Parliament and the Council empowering the French Republic to negotiate, sign and conclude an international agreement on the safety and interoperability requirements within the Channel Fixed Link (2023/0192 (COD)). CER, EIM, and ERFA call on all parties to find pragmatic arrangements ensuring safe, interoperable and free movement of trains from the European Union to the United Kingdom through the single, complex engineering structure that is the Channel Fixed Link. CER, EIM, and ERFA encourage the French Republic to work out a sound agreement for a coherent railway safety and interoperability framework under the conditions described in Article 2 of the aforementioned legal act. CER, EIM, and ERFA note that the guarantees provided by the agreement will be of special importance in the context of increasing rail services between the EU and the United Kingdom. For more information about ERFA, visit: erfarail.eu
Read full response27 Jan 2023
As the voice of private and independent rail freight undertakings to the EU, the European Rail Freight Association (ERFA) is delighted to share its comments about the draft implementing regulation revising the technical specifications for interoperability relating to control-command and signalling subsystems (CCS TSI). ERFA acknowledges that new technologies such as the digital automatic couplers (DAC) are included into the revised CCS TSI, as pointed out in Paragraph 6, and Paragraph 7. Development of a TSI on new technologies must be preceded by the development of a a sound migration and financing strategy. As mentioned in Paragraph 10, and in Subchapter 7.4.2.4, Subchapter 7.4.1.3 and in Appendix A, Table A2, two new systems versions of the ETCS (system version 2.2 and system version 3.0) are introduced in the revision of the CCS TSI, on the basis that it would be required by the updated needs of the rail sector. ERFA warns that such an introduction would be harmful to the competitiveness of the rail sector as a whole, and it will have a disproportionate impact on smaller freight operators. The introduction of higher systems version would indeed require a costly upgrade of on-board units in a very short period of time, as to comply with the newly revised CCS TSI. This will come at the top of already significant investments carried out by operators, supported in that efforts by national and EU subsidies, as to comply with previous system versions, investment and public subsidies that will be therefore completely nullified by the new requirements. In the meantime, road transport, the main competitor to rail freight traffic, is experiencing a cost-stable situation. In this context, the introduction of these higher system version will create a market imbalance to the benefit of the most-polluting, least energy efficient mode of transport, i.e. road transport, and to the very detriment of rail freight. An undesirable reverse modal shift from road to rail is therefore likely, endangering the ability of the EU to reach the growth target objectives for rail freight set in the European Green Deal and the Sustainable and Smart Mobility Strategy. The objective of an interoperable Single European Railway Area, fully shared by ERFA, should be implemented while taking into account the specific needs of smaller operators and the necessity of a normative stability and predictability of the evolution of TSIs, as to allow operators to have a long-term vision of the investments and modifications required. ERFA is looking forward to engaging with the Commission on the next steps of the TSI Revision process.
Read full responseMeeting with Colm Markey (Member of the European Parliament, Rapporteur for opinion)
12 Jul 2022 · Improving rail freight infrastructure
Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail
5 Apr 2022
ERFA, as the voice of private and independent rail freight companies in the EU, welcomes the opportunity to contribute to the call for evidence for an impact assessment on cross-border rail traffic – better management and coordination.
The European Commission is correct in acknowledging that cross-border freight services continue to face barriers limiting its competitiveness and attractiveness. Moreover, the cooperation mechanisms introduced in Regulation (EU) 913/2010 have been insufficient in increasing cross-border rail freight, as shown by developments since the introduction of the Regulation. On the contrary, railway undertakings are facing significant obstacles while crossing borders with substantial waiting times at cross-border points, uncoordinated actions between infrastructure managements, unharmonized rules, and irregular use of digital tools.
It is therefore necessary to introduce new measures to improve the management and coordination of cross-border rail traffic, in conjunction with the revision of the TEN-T Guidelines and significant investments in infrastructure.
ERFA calls for ambitious measures to solve long-existing problems for cross-border rail traffic. In that regard, ERFA favours option 2. This option will introduce new elements such as a forward-looking, multi-annual planning of capacity utilisation for different traffic segments, more flexible allocation processes, additional performance-related incentive schemes, reciprocal commercial conditions and stronger use of digital tools without creating new bodies or layers of administration.
As already stated, the current capacity management system is not meeting the needs of rail freight. It is therefore important that a new allocation system is introduced. Sector stakeholders have been progressing well towards the development of the redesign of the international timetabling process (TTR). For rail freight, it is essential that the agreed process is fully implemented thoughout the entirity of the European Union. ERFA believes this will require adjustments to the legal framework on top of ongoing sectoral work on capacity management. Crucially, a network approach is needed for capacity management as opposed to a corridor focus. Very few freight trains begin and end on a corridor and adopting a corridor focus may only lead to greater complexity in capacity management.
Overall, decision-makers must be guided by the need to ensure predictability and customer-oriented services in the use of infrastructure, offering guarantees in terms of path allocation to rail freight operators using infrastructure mixing passenger and freight traffic, whilst also taking into consideration existing good practices.
ERFA looks forward to contributing to all the next steps leading towards substantial EU actions to boost cross-border rail traffic, better management and coordination.
Read full responseResponse to Evaluation and revision of the Weights and Dimensions Directive
17 Feb 2022
ERFA, as the voice of private and independent rail freight companies, warmly welcome the call for evidence for an impact assessment on the directive 96/53/EC on the maximum weights and dimensions of heavy-duty vehicles.
ERFA especially welcomes the willingness of the European Commission to allow this directive to help meeting the climate ambitions of the European Green Deal, notably by setting rules that increase energy efficiency and drastically reduce the environmental impact of road transport.
In that regard, the European Commission is right to list among its non-exhaustive list of possible policy measures the need to adapt technical standards to the needs of intermodal transport and to take additional measures to promote intermodal transport.
By combining the best of all transport modes, intermodal transport is indeed an essential tool as it benefits from the immense advantage of rail in terms of carbon emissions reduction and energy efficiency. Rail is indeed about seven times greener than road in terms of greenhouse gas emissions and six times more energy efficient, without mentioning its ability to address congestion and the current labour shortages in the road sector.
It is therefore essential that the European Commission sets strict rules to ensure that road vehicles are fully compatible on all their technical standards with rail transport. Rules must facilitate transfer from one mode to another, including with cranability requirements.
While rail has already undertaken significant investments with long write-off periods to be compatible with road standards and is willing to continue to do so, road transport should further develop the potential for rail-road interoperability.
On the other hand, the European Commission should not allow modal trucks to be used outside of intermodal operations and, except for combined transport operations, should not increase the maximum rated weight limit for trucks. Both measures would further disadvantage rail transport and rail-road interoperability, further distant the EU with its modal shift objective, and benefit much more carbon and energy intensive transport options.
Overall, the revision of the Weights and Dimensions Directive should go hand in hand with the revision of the Combined Transport Directive. Both texts should highlight the consistent objectives of the EU in terms of promoting modal shift, ensuring a level playing field to the benefit of greener and less energy intensive options, and supporting rail-road interoperability.
ERFA and its members from across the EU look forward to further engage with the European Commission in each of the next steps related to the debate on the future of the Weights and Dimensions Directive.
Read full responseResponse to Regulation on train drivers’ certification
8 Feb 2022
ERFA, as the voice of private and independent rail freight companies, warmly welcomes the call for evidence for an impact assessment on the directive 2007/59/EC on the certification of train drivers.
ERFA firmly believes that an efficient labour market with real worker mobility across both railway undertakings and countries, and easier assignment of train drivers for operations in various Member States are two essential conditions to make the Single European Railway Area a reality, and therefore increasing the competitiveness of the whole sector and creating the necessary conditions for speeding up the modal shift.
Unfortunately, this is far to be case, which makes the revision of the present directive even more necessary. As representatives of rail freight companies, we are even more aware of the urgency of the matter as one freight train out of two crosses at least one EU internal border during its journey. This border crossing operations are often made even more complex because of lack of a common certification scheme for drivers and language issue. At the same time, new entrants are experiencing difficulties to find train drivers and are sometimes unable to recruit drivers from third parties.
The European Commission rightly described the challenges related to train drivers: cross-border barriers, increasing shortage and ageing of train drivers, lack of drivers able to carry out smooth cross-border operations, urgent need for reskilling and upskilling in the context of rapid digital transformations, insufficient harmonisation of certification requirements, challenging mobility of train drivers between employees.
Overall, the European Commission should not make things more complicated as they are at the moment. Maintaining working local solutions, especially for short-distance national traffic, wherever necessary is essential. Further harmonisation on training should go hand in hand with the deployment of new digital solutions (ERTMS, ETCS, DAC) and more harmonised techniques, but drivers should not be trained for technologies and materials whose deployment will take years or decades.
Regarding the four preliminary list of policy options, ERFA believes that the main issue is not who is certifying but rather how. However, it should be stressed that policy option 4 (i.e. ERA-led train driver certification under a common EU accreditation scheme) would only create further bureaucratic hurdles.
The revision of the directive should focus on further harmonising contents and principles, reducing training costs and scrapping unnecessary teachings, as time needed for training a driver can vary in the ratio of one to two depending on the Member States. A modular approach such as the common method called “Einheitliches Ausbildungsverfahren” (Common Training procedure) developed by NEE and VDV in Germany can be a source of inspiration (Cf: https://bit.ly/34rfoR9).
The increasing digitalisation of railways should encourage the European Commission to assess the many benefits that using a smart card combining licences and certificates for train drivers may bring, instead of the current outdated paper system.
Finally, when it comes to languages, ERFA believes that it is essential to push for bilingual infrastructure manager staff at cross-border stations. Overall, the increasing use of digitalisation and automation for train operations will reduce the need for interaction between train drivers and operating centres. It will therefore make easier to establish a common language for international traffic in the EU, as it is the case in air transport (Cf: https://bit.ly/3GyGt1N) but this long-term aim that will only concern the next generation of train driver will require a careful and step-by-step approach including building a common understanding on safety issues and standards and a standardisation of communication between train drivers and operating centres.
Read full responseResponse to Amendments to Regulation (EU) 2019/773 as regards the phasing out of specific cases for rear end signal
19 Nov 2021
As the voice of new market entrants in rail freight transport, the European Rail Freight Association (ERFA) dully takes note of the proposed amended rules on phasing out rear end signals for freight trains.
It is essential that railway stakeholders and EU decision-makers work towards harmonising interoperability standards to make the Single European Railway Area a reality. However, this harmonization process should not lead to excessive burden for Railway Undertakings, especially small ones. When it comes to the use of reflective plates for all freight trains, it is therefore crucial that implementation remains cost neutral.
As four Member States benefit from a deadline for accepting freight trains equipped with 2 reflective plates, railway industry must work towards a prompt implementation of this requirement. Any further delay would only contribute to maintain obstacles in running freight trains from a Member States into one of those concerned by the longer deadlines, as trains should be equipped with two steady red lights at the border crossing point. Given the highly international nature of rail freight in the EU, such requirements lead to an uneven playing field at the expense of rail transport.
In parallel, ERFA will continue to take part in the ongoing process led by ERA to further harmonise rear end signal and the possible future review of Appendix E of Regulation (EU) No 321/2013.
Read full responseResponse to Land transport enabling regulation
29 Oct 2021
ERFA, as the voice of private and independent rail freight companies, welcomes the publication of the roadmap leading towards a New Land Transport Enabling Regulation.
Simplified State Aid rules have to potential to help make State Aid more in line with the ambitious goals set out by the European Green Deal and the Sustainable and Smart Mobility Strategy. ERFA believes support measures to achieve modal shift to rail will play an important role in ensuring that rail freight can achieve 50% growth by 2030 and a doubling of volumes by 2050 as outlined in the European Commission’s Sustainable and Smart Mobility Strategy.
ERFA supports the process of simplifying State Aid procedures in relation to aid measures supporting modal shift of freight from road to rail and more broadly from more polluting to less polluting and more sustainable transport modes and solutions, in line with Article 93 of the Treaty. ERFA supports measures provided that they do not generate further competition distortion between historic State-owned operators and new entrants. Achieving the goals of EU policies and strategies is a derivative of proper support measures coupled with sufficient financing. ERFA is hopeful for the development of new tools which will help to develop the sector on the one hand, but on the other provide full transparency of the rules and procedures.
The European Commission must ensure that the establishment of any block exemption for certain aids include sufficient safeguards in place to ensure that financial support is delivered on a fair, transparent and non-discriminatory basis.
ERFA and its members look forward to further dialogue with the European Commission in each of the next steps of the making of the New Land Transport Enabling Regulation.
Read full responseResponse to Revision of the State aid Railway Guidelines
29 Oct 2021
ERFA, as the voice of private and independent rail freight companies, welcomes the launch of the process leading towards the revision of the Community Guidelines on State aid for Railway Undertakings.
ERFA believes it is the appropriate moment to revise the Railway Guidelines (RGL) as the Fitness Check on State aid modernisation package from October 2020 correctly highlighted that the RGL are “outdated and need a complete overhaul”. Written 12 years ago, the RGL are now obsolete as they do not take into account the last railway packages as well as the latest revision of State Aid legislation. The railway sector needs an update to ensure that RGL are aligned with existing legislation and provide legal clarity on when and where aid is admissible.
ERFA particularly calls to attention that the Incept Impact Assessment rightly pointed out that the RGL are not adapted to the opening of the rail markets with several problems identified that the revision process must address.
ERFA welcomes the revision of the RGL carried out in an integrated approach with the objectives set out by the European Green Deal and the Sustainable and Smart Mobility Strategy. The extension of the scope of the RGL to include all relevant transport operators in the intermodal chain that contribute to the modal shift of freight is a positive step that will help to unleash the potential of intermodal transport. The European Commission must ensure that the improvement of the toolbox of aid measures supporting more sustainable transport modes will lead to a fair, non-discriminatory and transparent distribution of support measures. ERFA can support measures which do not lead to competition distortion in favour of individual operators.
The European Commission noted that using block exemptions may help to simplify procedures for aid to coordination of transport. While there is a broad support amongst Member States and industry representatives for such a measure, ERFA believes that any block exemption for certain State Aids should be considered carefully and have sufficient safeguards in place to ensure support measures remain fair and transparent.
Read full responseResponse to Revision of ERA Fees & Charges
30 Sept 2021
ERFA, as the voice of private and independent rail freight companies, oppose the massive increase of fees and charges payable to the European Union Agency for Railways, proposed in the amendments of Commission Implementing Regulation (EU) 2018/764.
Such measures not only contradict the original aim of the text, but they also represent an unfair burden on operators, threaten the competitiveness of European railway actors, and contradict recent commitments. While the EU is celebrating the European Year of Rail, this proposal highlights the huge gap between the ambitious objectives set in favour of the development of railways and the burdens being placed upon operators.
The increase of the hourly rate by 80%, from EUR 135 to 235 is met with surprise and concern. It is way above the inflation rate and deeply contravene previous calculations made in agreement with National Safety Authorities in 2017. Furthermore, such a massive increase is not balanced with corresponding quality improvements, for instance by significantly reducing the time needed for processing applications.
It is unacceptable that applicants must pay for using the OSS IT tool. The Agency needed significant development costs for the OSS and this tool will also imply considerable maintenance, but this should be covered in the indirect costs. At the very least, users must be charged only once for the entire procedure.
ERFA appreciates the 20% reduction of the total amount for SMEs and the fixed rate for conformity to type authorisations, but this is completely insufficient to help the sector as major cost drivers are not addressed here.
Together with the Fourth Railway Package, this proposal will generate an administrative and financial burden never seen by the sector, as costs for single type authorisation of a freight wagon may multiply by 4 in comparison with the situation experienced under the Third Railway Package. On top of that, the conformity to type procedure is bringing additional charges for railway operators.
ERFA acknowledges the essential work carried out by the Agency, in a context of a reduced budget and a significant increase of workload corresponding to the implementation of the Fourth Railway Package. However, it would be totally unfair to put all the financial costs on railway operators because of misguided budgetary decisions made in the past. It is therefore urgent that the European Commission and the Member States do bring the necessary financial means to enable the Agency to properly assume the tasks that they rightly put on its shoulders.
Read full responseResponse to Revision of Combined Transport Directive
16 Sept 2021
ERFA, as the voice of private and independent rail freight companies, welcomes the launch of the revision of the Combined Transport Directive.
The Combined Transport Directive has always been an essential enabler for combined transport (CT) operators across Europe. Its objectives are fully in line with the European Green Deal, the Smart and Sustainable Mobility Strategy and the aim to make the continent climate neutral by 2050. It is therefore essential that the European Commission maintains the benefits generated by the current CT Directive for all operators while opting for greater ambition to unleash the full potential of CT as an essential tool to make inland freight transport more sustainable.
The key pillars of the CT Directive to be safeguarded in the upcoming revision include the legal equivalence of border-crossing CT with the comparable road-only journey and the 44-tonne gross vehicle weight allowance for trucks performing the positioning road legs of a CT operation.
The calculator mentioned in the Inception Impact Assessment should be quickly and easily usable for all users of combined transport. It must also be readily enforceable by the authorities. Its design must take into account sustainability in its whole dimension including carbon emissions, but also pollution, congestion and accidents. The European Commission should also further study the possibility to incorporate energy efficiency and labour intensity in the calculation.
In that regard, ERFA welcomes the extension of scope envisaged in the revision of the CT Directive as it will contribute to favour any intermodal or multimodal transport operation that bring a measurable contribution in reducing harmful externalities from road-only transport journeys. Furthermore, the European Commission must take into account the highly heterogeneous and unstandardised nature of multimodal transhipment in comparison to intermodal transport.
Moreover, CT traffic from and to third countries including the United Kingdom and Switzerland should enter into the scope of the revised Directive as it will help to favour modal shift on an even larger scale.
Every Member States should issue a decarbonisation plan of its inland freight transport sector. Such a plan must include a comprehensive description of the current situation, a detail of the set of measures envisaged for each externality and the expected outcomes. The European Commission must ensure that the economic and regulatory measures linked to this directive are implemented in a transparent and fair way and that their effectiveness is regularly checked. In that regard, regular reporting to the European Commission should be made mandatory.
ERFA and its members looks forward to working with the European Commission for the next stages of the revision of the CT Directive and will provide additional inputs during the public and targeted consultations.
Read full response5 Oct 2020
The 4th Railway Package’s Technical Pillar was adopted with the ambitious goal of facilitating the applications for vehicle authorisation and safety certification, with the European Union Agency for Railways (ERA) playing a central role in these processes and being the one-stop-shop for all applicants.
The upcoming withdrawal of the United Kingdom from the European Union creates particular challenges for railway undertakings offering services through the Channel Tunnel from the United Kingdom to France and beyond.
The European Rail freight Association (ERFA asbl) believes that in times of political uncertainty, the respective roles and responsibilities of the entities granting safety certifications for the “areas of operation” in the United Kingdom, the Channel Tunnel and France should be stable and reliable for the applicants.
As the Channel Tunnel is structurally and operationally a single piece of railway infrastructure, we recommend that a single safety authority responsible for the whole Channel Tunnel is maintained. Due to the fact that on a small part of the European railway network between the United Kingdom, three areas of operation require multiple applications for safety certificates, requiring complex applications based on vast safety management systems, we recommend to keep the status quo regarding the entities granting safety certification for the above described areas of operation for the sake of safety, legal certainty and business continuity.
Read full responseResponse to Sustainable and Smart Mobility Strategy
20 Jul 2020
The EU Green Deal foresees to reduce transport emissions by 90% by 2050. This will be achievable only with a considerable increase of rail freight transport. We call for a Sustainable and Smart Mobility Strategy that addresses the needs both of freight and passengers in order to face the challenges of tomorrow. Regarding rail freight transport it is of upmost importance that the Strategy for a Smart and Sustainable Mobility considers the lessons learnt from the COVID19 pandemic, that the strategy calls for a sound and timely revision of the Rail Freight Corridors and that the Staff Working document takes into consideration the conclusions of the 2016 Court of Auditors Report on Rail Freight.
1. The road map indicates to take into account the lessons learnt form the COVID-19 pandemic.
Shippers’ main concerns blocking the growth of rail freight are punctuality and reliability. However, over the past months the punctuality of international freight trains has increased from around 60% up to 80-90% due to the freeing up of capacity on the European railway network and the drastically reduced passenger traffic. If these rates can be sustained, rail freight will be in a position to offer increasingly more attractive services to shippers. Passenger traffic will return, but it is essential that policy makers also ensure that lessons are learnt from this crisis regarding the key success factors for rail freight – namely good quality and quantity of capacity for freight.
2. The 2011 White Paper already enshrined the objective to shift 30% of road freight transport over 300km to rail by 2030 and 50% by 2050.
ERFA continues to support this objective and calls for a sound revision of the Rail Freight Corridor Regulation in this context and more precisely to:
- Improve the quality of paths for freight trains: Infrastructure managers and corridor organization on international freight corridors must work to improve the quality of paths for freight trains. Quality measures must be consequently implemented, which increase the punctuality of rail freight, increased length (740m) and weight of trains as well as harmonized profile (P400).
- Give equal priority in slot allocation: Allocation rules for freight paths has to be defined, internationally harmonized and secured for freight trains. Freight trains must have equal priority in slot allocation as passenger trains in all countries of the corridors.
- Make sure that operational rules are internationally secured and harmonized: Freight trains must have equal priority in day to day operations as passenger trains. A punctual train – be that passenger or freight – goes first.
- Introduce a supranational traffic management: Infrastructure managers and corridor organizations should implement supra-national traffic management, which would have a specific focus on the quality of international freight trains. A measurement for international freight train quality should be implemented.
- Empower corridor organization: Give the corridor organizations equal decision and steering rights as the national infrastructure managers. Corridor investments should not be hindered by national interest. Railway Undertakings should have an equal position in the governance of corridor organization with defined decision rights.
3. The Roadmap states that “a fair and functioning internal market for transport is still not a reality.
Obstacles remain (…) the competition that is needed to boost innovation”. ERFA fully supports this statement and therefore calls to calls the Commission to build on the conclusions of the 2016 ECA Special Report on Rail Freight in the context of the Commission Staff Working Document. The following action plan should take account of the updated report and the ECA recommendations.
Read full response7 Mar 2019
Please find here below the ERFA High level recommendations for the revision of the Guidelines on State aid for Railway undertakings.
1. The gradual opening up of the rail freight transport market has been behind us for more than 10 years. The context of transition described in the 2008 Community guidelines on State aid for railway undertakings is outdated. The rail market must now abide by the rules of competition. There is no reason for a transitional tolerance vis-à-vis State guarantees. For the same reason, no more direct or indirect derogatory regime is justified for freight undertakings with respect to restructuring aid and debt cancellation.
2. A structural regional aid could be authorised in limited geographic areas for structurally unprofitable freight traffics, if it has been demonstrated that this structural aid is temporary and that it is the only solution to keep the traffics on the train. This aid can only be authorised on a non-discriminatory basis. For instance, a local rail operator could receive subsidies for a limited regional service in a well-defined territory like a port. Aid to purchase of rolling stock should be excluded anyways because it is not possible to guarantee that this rolling stock remains exclusively affected to a limited zone.
3. Aid to transport coordination should exclude aid to purchase of rolling stock for the same reason (not possible to guarantee that this rolling stock remans exclusively affected to a limited zone)
4. A specific category of aid could be created for the investments in retrofit of wagons or locomotives in order to make them more interoperable or more environmental-friendly. State aids for such goals could be authorized at a higher level.
5. State aids are welcome in the future in order to compensate unpaid environmental, accident and infrastructure costs.
6. The possible exportation of the notion of PSO on the liberalized freight market requires the greatest care and strict supervision.
7. For any support to the railway sector, the non-discriminatory nature must be guaranteed. This implies that any aid, whatever its nature, must be published sufficiently at European level and in all member countries, at least in English.
Read full responseResponse to Revision of language requirements for train drivers to allow pilots exploring alternative options
20 Jul 2018
ERFA welcomes the European Commission (EC) proposal to revise the Annex VI of the train driver directive, as a necessary step to pave the way for more flexibility in the rail sector. We ask the Commission to adopt a simple and pragmatic approach.
It is important to have the possibility to assess and try different solutions that could be implemented in the rail market, to overcome the remaining language barriers.
Please find attached our feedback on the EC proposal.
Read full response