UIP - International Union of Wagon Keepers
UIP Rail
Founded in 1950, the UIP - International Union of Wagon Keepers, with its seat in Brussels, is the umbrella association of national associations from 14 European Countries, thus representing more than 250 keepers with approximately 238,000 freight wagons, performing more than 50 % of the rail freight tonne-kilometres throughout Europe.
ID: 231975310234-07
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
5 Dec 2025
(more detailed and comprehensive feedback in the file attached) UIP, the association representing the interests of wagon keepers and entities in charge of maintenance in Europe, would like to make several recommendations regarding the technical screening criteria for climate change mitigation for the economic activity 6.2. freight rail transport. As the main asset managers of rail freight wagons in Europe, wagon keepers have a vested interest in promoting rail freight as a key activity to reduce logistics emissions and other externalities, in line with the modal shift objectives of the EU. The main concern of European wagon keepers is the criteria to have trains and wagons [] not dedicated to the transport of fossil fuels to qualify as making a substantial contribution to climate change mitigation. UIP recommends deleting this criteria, for the following reasons: - Implementation: There is no such thing as wagons dedicated to the transport of fossil fuels over their entire lifespan. Wagons used for the transport of fossil fuels are usually designed to also transport other non-fossil minerals. The main activity of most wagon keepers is to lease/rent out wagons to industries and railway undertakings, in accordance with market demands. They do not intervene in the transport operation. As these customers are in charge of organising and performing transport operations, wagon keepers do not have the ability to control, monitor and manage the actual use of their assets and which types or cargo/minerals are transported. Furthermore, the requirement is not audit-relevant, as wagon keepers have no lawful access to operational transport data held by railway undertakings. This would make auditing or verification in accordance with taxonomy virtually impossible. - Political alignment: Rail freight is statistically the safest and cleanest means of transport. As such, it is considered by the European institutions as a key solution to reduce the GHG emissions and other externalities of transport and contribute to the climate objectives of the EU. The 2020 Sustainable and Smart Mobility Strategy most recently sets an objective for rail freight traffic to double by 2050. Although the demand for the transport of fossil fuels is expected to decrease in the future, using rail rather than less sustainable alternatives such as road transport while the European economy is still partly reliant on fossil fuels, remains an undeniable choice that should qualify as mitigating the impact of climate change. Therefore, the existing fleet and new investments eligible for EU Taxonomy purpose should not be limited to specific wagon types, as this would run counter to the EUs objective to increase the use of rail freight. In addition, the EU Taxonomy must remain technology-neutral and mode-neutral. A restriction based on the type of transported goods could create a competitive distortion in favour of road transport. - Financial implications: Investments in new wagons designed for the transport of minerals, chemicals and liquids, including fossil fuels, carry significantly higher financing risks and costs for asset managers. This is due to these investments being considered as not eligible for EU Taxonomy under the current rules, expected potential further regulatory tightening and declining demands in the long term as a consequence of the accelerated energy transition. Investors expect less profitability over the lifespan of a wagon (potentially stranded assets, shorter lifespan, lower utilisation rates and limited redeployment options). Given a wagons expected lifespan of 40+ years, Taxonomy criteria must consider long-term lifecycle impacts. Artificially limiting the eligibility of assets with long renewal cycles contradicts the EUs lifecycle-based sustainability framework.
Read full responseMeeting with Herald Ruijters (Deputy Director-General Defence Industry and Space)
1 Oct 2025 · Military Mobility
Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas)
30 Sept 2025 · MEETING WITH UIP
Meeting with Andreas Schieder (Member of the European Parliament)
2 Sept 2025 · Exchange of views
Meeting with Joachim Luecking (Head of Unit Mobility and Transport)
2 Sept 2025 · Main challenges for the rail freight sector and wagon keepers
Response to EU Ports Strategy
28 Jul 2025
UIP welcomes the European Commissions plan to define an EU Ports Strategy and herewith would like to contribute its view with the attached position paper.
Read full responseResponse to EU harmonised specifications for rail freight wagons
30 May 2025
Transfer of technical requirements from RID to WAG TSI: UIP is concerned that the inconsistencies noticed between the transition regimes of the Regulation concerning the International Carriage of Dangerous Goods by Rail (RID) and the draft Commission Implementing Regulation (WAG TSI) might create uncertain situations for the subsequent certification of wagons by NSAs. For wagons in production phase, the draft transitional date of application for 4.2.7 (RID Chapter 7.1 General Provisions) and 7.1.2 (g) (WE marking) is 1 January 2029, whereas the RID provides for a general transition period of 10 years for production under valid approvals. To increase legal and operational certainty and reduce administrative burden and costs, UIP proposes that the date of 1 January 2029 is replaced with 1 January 2033, at the earliest. The existing TE marking is indeed equivalent to the WE marking, technically and in terms of requirements. Coming back on valid RID approvals after a 2-year transition period would create unnecessary burdens for the sector. In addition, UIP will advocate for the inclusion of a footnote and/or clarification note in the RID 2027 establishing the equivalence of the TE and WE markings, with the support of the Standing Working Group. Regarding the application of the ATEX framework to freight wagons, and in particular of Directive 2014/34/EU (equipment directive) which would require wagons to be authorised for ATEX zones, UIP considers that it would prove an impractical solution, as zone requirements are product-, loading- and location-specific. From experience, loading stations are satisfied with the provisions of the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) which offer and guarantee satisfactory levels of prevention, protection and safety, without the need for any additional certification process. UIP will propose that the relevant provisions of the ADR are adapted to the use of wagons in potentially explosive atmospheres and included in RID/TSI, with supplemental information in the relevant reference standards. Requirements on spark arresters: UIP would appreciate an explicit clarification that the new requirements on spark arresters, and the related marking: - Only apply to new wagons, including units in design phase at the date of application of the amendment to the Commission Implementing Regulation (WAG TSI). - Does not apply to units in operation, whether they are already fitted with spark arresters or not, nor to units in production phase at the date of application of the amendment. Requirements related to hitches / Devices to secure semi-trailers: UIP supports the introduction of a EU-wide rule in the Commission Implementing Regulation (WAG TSI), if it ensures that the unilateral national rules imposed by Denmark are withdrawn. However, UIP opposes the general principle of retroactivity of the EU rule to the whole European pocket wagon fleet. It is neither suitable nor proportionate, and risks negatively impacting the competitiveness of the intermodal freight transport sector. No evidence regarding the technical feasibility of retrofitting all types of units was provided in the framework of the JNS. As a compromise, UIP proposes to introduce a specific rule for Denmark, which would provide that 4.2.2.4.2 applies to all units in operation in Denmark with a 1-year transition regime. The application of the rule to the rest of the European pocket wagon fleet, which might never be used in Denmark, must remain voluntary. Regarding the marking of pocket wagons, UIP alternatively proposes to use electronical means and digital marking. The enhancement of the current Rolling Stock Reference Database (TAF TSI Baseline 3.5.1), with the appropriate data and information could be done and implemented on short notice and would provide a better solution when it comes to making sure that data can be shared and exchanged.
Read full responseResponse to Technical specification for interoperability relating to the telematics subsystem of the rail system
14 Mar 2025
We, the International Union of Wagon Keepers (UIP), do support activities that are aiming at improving efficiency in the exchange of standardized data between relevant actors to increase the competitiveness and reliability of rail transport. However we have significant concerns as regards several proposed measures in the current legal draft text. Please find a joint position of CER, EIM, ERFA and UIP that outlines the various serious risks that the adoption of such draft text will bring to the sector.
Read full responseMeeting with Sophia Kircher (Member of the European Parliament)
25 Nov 2024 · Combined Transport
Response to European Sustainability Reporting Standards
7 Jul 2023
UIP is the umbrella association of national associations from fourteen European countries, representing more than 250 freight wagon keepers and more than 234000 freight wagons. The feedback of UIP is enclosed in the PDF file attached.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
UIP provides some feedback in the attached file.
Read full responseMeeting with Barbara Thaler (Member of the European Parliament, Rapporteur)
8 Mar 2023 · TEN-T
Response to Revision of Combined Transport Directive
16 Sept 2021
UIP, the industry association representing the interests of private freight Wagon Keepers and ECMs, welcomes the Inception Impact Assessment on the revision of the Combined Transport Directive 92/106/EEC and attaches herewith its position.
Read full response16 Dec 2019
The International Union of Wagon Keepers (UIP) has identified the need of a clarification on the non‐application of 7.2.2.4 for RIV and RIC vehicles in point 7.2.2.4 in Appendix 1 of TSI WAG 321/2013 as a critical topic which was raised as feedback from concrete applications of our members under the new VA process.
The reason for this is that the definition of RIV as an area of use equivalent to 'Go Everywhere' (GE) vehicles according to Art. 3 (c) is missing in the current TSI WAG. As there is no legal base providing a reference to RIV in the chapters relating to the area of use, the Agency has to request from the applicant, for changes to already authorised RIV vehicles (Art. 16 of 2018/545) and classified under Art. 15 (b) –(d), a new authorisation AND an extension of the area of use.
This creates an unnecessary additional burden for both the Agency and the applicant and additional costs while it’s clear for everyone that the use of fully interoperable RIV or RIC vehicles is not limited to a single national network.
Instead the area of use covers the technical compatibility of existing units with a broad range of network networks in accordance with clause 7.1.2. on the mutual recognition of the first authorisation of placing on the market.
UIP would therefore like to propose the following clarification on the non‐application of 7.2.2.4 for RIV and RIC vehicles:
"For existing units put in operation before 19 July 2010 and marked ‘RIV’ or ‘RIC’, the authorisation is not limited to a national network. Changes to existing units falling under Art. 15 (1)(b)-(d) of Commission Implementing Regulation 2018/545/EC do not require an extension of the area of use as long as the use of those units remains within the area for which the authorisations have been granted."
Read full responseResponse to Multiannual Financial Framework: Connecting Europe Facility 2021-2027
13 Jul 2018
The International Union of Wagon Keepers (UIP) welcomes the new Commission proposal on the Connecting Europe Facility for 2021-2027.
First of all, UIP welcomes that with proposing a CEF budget for transport of around € 30,615 bn, the Commission has acknowledged the important role transport plays in the European economy and that continous EU financial support is essential. Any cuts to the proposed budget would be detrimental to digitalisation and decarbonisation.
However, even though the completion of the core-TEN-T network remains important, it is of essence to focus also on the modernisation of the infrastructure, which would improve efficiency and Europe’s competitiveness. UIP would therefore like to see an increase in the budget share relating to smart, sustainable, inclusive, safe and secure mobility to at least 50% instead of the current proposed 40% of the CEF transport budget.
The focus on digitalisation in the new CEF is welcomed and timely. We consider that it would further enhance our interest in sharing data in the railway sector and support investments in sensors and telematic devices for smart, safer and more efficient freight transport.
Furthermore, UIP welcomes the simplifcation efforts by the Commission when it come to applying for funding. Besides reducing the role of the Member State when it comes to approving project applications or certifying reports and incurred expenses, UIP would also like to see further simplification of the rules to apply for grants. For example, UIP would welcome if smaller amounts would be eligible as well and that the administrative requirements to be fullfilled would be introduced. This would also give small undertakings the chance to participate at calls.
Finally, UIP urges the Austrian presidency as well as the European Parliament to swiflty start the negotiations and the conclusion of an agreement before the new European Parliament election in May 2019. Otherwise there is a high risk that the new budget is not adopted in time.
Read full responseResponse to MFF: 9th Framework Programme for Research and Innovation and Rules for Participation and Dissemination
10 Jul 2018
With rail standing out as the most carbon-conscious transport mode, the Modal shift to rail is an opportunity to reduce the impact of mobility on the environment and human health. This is why, it is important that the 9th Framework Programme continues to fund rail research projects in order to foster the rail sectors competitiveness through new innovative solutions.
As a member of ERRAC and the Users Group of IP5 of Shift2Rail, UIP fully underlines that any future Shift2Rail2 budgeting must be coherent with the scope and depth of the rail research programme as described in the ERRAC 2050 vision paper.
Shift2Rail showed that the committed stakeholders of the Joint Undertaking were able to invest and carry out the work and that the financial resources were well invested. More results could be achieved with additional resources. Consequently, a significantly larger adequate budget is needed to ensure continuity between Shift2Rail and Shift2Rail2 and that the results of the on-going Joint Undertaking are picked up and further developed. Improved mechanisms need to be inroduced to facilitate the dissemination and adoption of results. Moreover, what role the European Union Agency for Railways (ERA) has with regards to resarch also needs to be further clarified.
The budget dedicated to Cluster 4 'Climate, Energy and Mobility’ is essential to fulfil the ERRAC 2050 vision and the ambitious EC goals formulated in the Transport White Paper. This is why, it is essential that mobility receives its fair share of the funding. We like to draw special attention to the following projects which will help the rail freight sector to deliver on the White Paper objectives:
• Intelligent wagon and predictive maintenance with a focus on cargo condition
monitoring, wagon design, predictive maintenance;
• Freight Automation on lines and in yards with a focus on automated guided vehicles, automation of disposition processes in marshalling yards;
• Development of functional requirements for sustainable and attractive rail freight with a focus on KPIs for freight, wagon specifications for condition-based maintenance and real time yard management;
• Start‐up activities for freight automation with a focus on automation processes in marshalling yards and terminals, time table simulation of the effects of faster and more flexible freight trains.
However, the €15 bn budgeted for Cluster 4 'Climate, Energy and Mobility’ has not increased compared to the combined budget dedicated to these areas under Horizon 2020. Especially when taking into account the transport sector’s contribution to Europe’s economic priorities, as well as the investment intensiveness of the rail sector, the overall budget increase of 27% to €97.6 bn for Horizon Europe should be reflected in the budget share of Cluster 4.
Against this background, UIP calls upon the relevant institutions to ensure that the the budget for Cluster 4 is increased to €19 billion and that the funds are being clearly earmarked for rail and other transport modes.
Read full responseResponse to Electronic documents for freight transport
5 Jul 2018
The International Union of Wagon Keepers (UIP) welcomes the new Commission proposal on electronic freight Transport information adopted on 17th May 2018. The proposal is an important first step to move from paper documents to digitally exchanged information in the transport sector. Digitalising the transport sector would contribute to more efficient transport operations and would simplify the process and organsiation of transport operations for shippers and forwarders.
The adoption of this legislation would allow all stakeholders and national authorities to gather experience on a limited scale and then move on to further digitalise e.g. the consignment notes other information required, which could lead to the introduction of a Single European Digital Transport Market.
Read full responseMeeting with Violeta Bulc (Commissioner) and
20 Feb 2018 · Meeting with Dr. Heiko Fischer, president Internationl Union of Wagon Keepers