TRANS ASSIST SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
Trans Assist
Trans Assist Sp.
ID: 982043192742-47
Lobbying Activity
Response to Detailed specifications regarding functional requirements for eFTI platforms
7 Jul 2025
As Trans Assist, a provider of digital logistics services and a platform for exchanging e-CMR documents, we are closely following the development of the eFTI Regulation and its technical specifications. As a company planning to become a certified eFTI platform, we welcome the draft Implementing Regulation but would like to raise the following points that require clarification to support practical implementation: 1. System integration (e.g. DIWASS): It is unclear what integration with DIWASS entails. Are eFTI platforms required to integrate with any specific national or European systems? If so, is technical documentation or an API specification available? 2. eFTI Gate specifications: Are there defined technical or functional guidelines for implementing the eFTI gate? Clarification would support proper development of the required interface layer. 3. Data access for authorities: We would appreciate guidance on how to technically provide access to competent authorities (e.g. customs, transport inspectors). Are there specific Member States or authorities we are expected to serve, and are there preferred methods or formats for data access? 4. Combined transport stamp: As a road transport platform, should we support the combined transport stamp? If so, could the Commission provide a definition and usage guidelines for this concept? 5. Offline access and authentication: Should our platform support offline access to data by competent authorities, and what are the expectations regarding offline authentication or access control? 6. Electronic identification systems: Which eID schemes (national or EU-level) are accepted as compliant with the minimum functional and security requirements? 7. Use of cloud-based external services: Can platforms like Trans Assist integrate with third-party services (e.g. CRM or analytics tools such as Salesforce or Hubspot) if those services are GDPR-compliant but hosted outside the EU? 8. Security provision user blocking (Article 5(5)(d)(III)): The Regulation states that access must be terminated after unauthorized actions. We seek clarification: should access be blocked permanently after a single incorrect input (e.g. wrong transport UID), or only after repeated failed attempts? 9. System availability requirements: The Annex mentions 8 hours of availability per day. Is this referring to the technical system, or to support availability? Wouldnt an annual availability metric (e.g. 95%) be more appropriate for ensuring reliability? We thank the Commission for the opportunity to contribute and would welcome further technical guidance to ensure successful onboarding of platforms like ours.
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