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Interferry Inc.

Interferry

To represent the Ferry industry vis-à-vis the European institutions and the International Maritime Organization

Lobbying Activity

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

Interferry welcomes this opportunity to provide evidence in relation to the review of the EU taxonomy climate delegated act. In summary we find that the TSC within the Taxonomy are in part not realistic and in part not fit for purpose. We have outlined our detailed comments in the attached document.
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Response to Sustainable transport investment plan

4 Sept 2025

Interferry would like to stress that the energy transition of the shipping sector as a whole will require immense quantities of low- and zero carbon affordable fuels, so every investment in Onshore Power Supply (OPS) will alleviate some of the pressure on yet to be developed and produced fuels of the future for the rest of the shipping industry. Please see our expanded comments in the attached file.
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Response to European grid package

5 Aug 2025

Interferry is a shipping association representing the ferry industry world-wide. Our key message in relation to the European grid package is the importance to factor in the total electricity demand that ships will need in European ports due to FuelEU Maritime requirements to use Onshore Power Supply, both for hotel load and to charge onboard batteries. Our comments are provided in the attached file.
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Response to EU industrial maritime strategy

28 Jul 2025

European Maritime Industrial Strategy Call for evidence Interferry is a shipping association representing the ferry industry (passenger ferries, High Speed Craft, ro-ro passenger ships, ro-ro cargo ships) world-wide. There are currently more than 280 member companies, representing more than 1,000 individuals from 40 countries. Please find attached our feedback on EU industrial maritime strategy.
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

7 Jul 2025

Interferry is a shipping association representing the ferry industry world-wide. Regulation of international shipping should primarily be done under the auspices of the International Maritime Organization (IMO) and not on a national or regional basis. Given the recent agreement at the IMO for a Net-Zero Framework, it is clear that an alignment between EU ETS & FuelEU Maritime and the NZF is imperative, not the least for ferry operations between EU countries, as these voyages would otherwise fall under the burden of paying for the same emissions not once, not twice but three times! The revenues from funds collected by EU (or the IMO) should be directed towards the development of clean fuels and the reduction of the price differential. This is necessary in a transitional phase to avoid an increase in external trade costs without real emission reductions. Additionally, the documentation and reporting requirements for EU ETS are very burdensome and frustratingly not identical to those at the IMO level. Operators have had to employ additional staff just to cope with reporting. Expansion of the EU ETS to ships under 5,000 GT may be relevant for other segments where competition might be affected by such a threshold effect, but for ferries this is typically not the case. Smaller ferries, i.e. <5,000 GT almost exclusively operate life-line services on short domestic routes, where they are in competition with other ferries <5,000 GT. Typically such services are supported financially by national or local bodies so including them in the EU ETS would to a large extent hit the tax payer, without generating any significant GHG improvements. Smaller ferries are much better dealt with by national regulations, not the least to avoid adding significant administrative burden onto operators who are often SME:s.
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Response to Better protection for passengers and their rights

5 Mar 2024

Interferry is a shipping association representing the ferry industry world-wide. ECSA represents 21 national shipowners associations based in the EU and Norway. In November 2023, the European Commission presented a series of proposals designed to improve the experience of passengers and travellers by strengthening their rights. Interferry and ECSA welcome the discussion on clarification of passenger rights in the different transport modes but notes a lack of any proposal addressing the ferry industrys concerns over the existing regulation 1077/2010. Additionally, stressing the concept multimodal journeys will inevitably address certain aspects of the existing Maritime Regulation. Such overlaps will not necessarily be managed in the same legislative process in the future, further complicating matters. Multimodal journeys & Package Travel Interferry notes the proposals to enhance protection for multimodal journeys and package travels, but cautions that while a passenger may choose to book several tickets on subsequent modes of transport, that must not be a considered a multimodal journey in a regulatory context. It is not clear which journeys at sea would be covered by the proposal. Interferry have made these comments earlier in the consultation process and, looking forward, all stakeholders would benefit from some clear examples of journeys / ticket types that would be within the remit of multimodal. To that end, any requirements should focus on the obligations held by the issuer of multimodal tickets rather than the carrier of the passenger, which is most commonly not the same entity. It is not unusual that a ferry operator does not know the identity of a package-traveller until said person shows up at the terminal for embarkation. Such elements have to be considered more carefully in the legislative deliberations. European Mobility Data Space Among the proposals we also find the creation of a common European mobility data space. Interferry and ECSA are cautiously supportive of exploring such opportunities but caution against developing complex IT setups that warrant more maintenance than they provide benefits. Interferry has been engaged in the review process that commenced already in 2019, where a targeted consultation was held in 2022. None of the issues raised then have been addressed by this proposal. Maritime Passenger Rights Regulation 1177(2010) The aforementioned series of proposals from the European Commission do not address any of the serious concerns the ferry industry has over the Maritime Passenger Regulations as set out in EC 1177/2010. Considering the above, Interferry and ECSA would like to point out that: We support efforts to improve the fairness of the Maritime Regulation 1177/2010 where improved awareness and clarity will assist passengers to claim and understand what they are entitled to and not entitled to
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Meeting with Dominique Riquet (Member of the European Parliament, Rapporteur)

9 Nov 2022 · Politique fluviale

Response to Better protection for passengers and their rights

17 Jan 2022

Interferry would like to share the following views: Aim 1) We support efforts to improve clarity of the Maritime Regulation (the MarReg). The MarReg has not been tested in the CJEU to the same extent as the Aviation Regulation and principles remain unclear. Aim 2) Improved awareness and clarity will assist passengers to claim and understand what they are entitled to and not entitled to. All stakeholders would benefit from a clear timebar for claims. Aim 3) and First Specific Objective Enforcement regimes vary widely across Member States. Aim 4) and the General Objective Regulations are inconsistent. The compensation burden on Aviation differs greatly with Maritime. Aviation’s two weeks’ notice period creates an unlevel playing field for Aviation and Maritime Carriers operating in the same market and often facing similar operating and scheduling challenges. This also causes passenger confusion. Aim 5) and the Second Specific Objective Difficult for Regulations to address all possible situations and the emphasis should be on ensuring Regulations are clear, consistent and cognisant of the uniqueness of some routes. Aim 6) Regulations should be applied in the same way for mass and individual disruptions. Extraordinary Circumstances should protect Carriers from burdens in Circumstances beyond the Carrier’s actual control. Extraordinary Circumstances should not require the Circumstances to be not inherent in the normal exercise of the activity of the Carrier. Policy Option 1 MarReg requires clarification through the adoption of recommendations and interpretive guidelines. Policy Option 2 There should be targeted amendments to the MarReg including the following: - A notice period that relieves Carriers of the obligation to compensate where a service is cancelled with sufficient notice. - Allow Carriers to offer a choice of re-routing options. Where an early or on time option is offered this should relieve the Carrier of the burden of compensation if a later arrival is preferred by the the passenger. - Remove the requirement that Extraordinary Circumstances not be inherent in the normal exercise of the activity of the Carrier. - Exclude consumed onboard extras from the Ticket Price to avoid a disparity of compensation between passengers depending on services purchased and still availed of. - Clarify costs to be considered when re-routing passengers at no additional cost. - Timebar for claims against Carriers. Likely Impacts on Industry Negative impacts must be considered and not assumed to be balanced by positives. Additional burdens on Carriers lead to increased prices and reduced choice. We urge the Commission to consider the unique circumstances of some routes, and in particular the routes between IRELAND and Continental Europe. IRL as an island nation on the periphery of Europe is reliant on viable routes for not only for passengers but also for critical freight services that are provided by the same ships. Any threat to the viability of these routes is therefore a critical risk for IRL and EU. On such long overnight routes often operated by a single ship per Carrier, Carriers do not have spare ships to provide re-routing options. In disruption, options for re-routing are extremely limited, particularly during Summer periods when services are significantly booked. We welcome the CJEU’s finding in the recent Irish Ferries case that “Landbridge” across Great Britain is comparable. However, Landbridge is often not passengers’ preferred option. In order to offer re-routing at the earliest opportunity we expect that Landbridge will be the only option that can be offered. The alternative will be a refund. Where Articles 18 and 19 apply concurrently the MarReg does not allow Carriers to engage with passengers and allow them to choose a preferred re-routing option without the burden of compensating passengers with 50% of their fare if the passengers’ considered and preferred choice is to travel a day or more later.
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Response to Evaluation of rights of passengers when travelling by sea and inland waterway

6 Sept 2019

INTERFERRY welcomes the review of the EU Directive concerning the rights of passengers when travelling by sea and inland waterway. Representing the ferry industry, INTERFERRY notes the a very low incidence of delays and cancellations within this passenger transport segment, but also some distinct discrepancies between this 'Maritime' Directive as compared to e.g. the 'Aviation' Directive. There are inherent differences between these segments and the provisions should therefore not be identical, but there are certain unintended consequences prompted by the Maritime Directive in relation to early communication of itinerariers and the introduction of new tonnage to the market. INTERFERRY is looking forward to contributing to help furthering the intent of the Passenger Ship Directive.
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