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UNIFE

UNIFE

UNIFE represents the European rail manufacturing industry and its leading supply companies.

Lobbying Activity

Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

16 Jan 2026 · Challenges of the European railway and bus industry, and exchanges on the Foreign Subsidies Regulation and public procurement

Rail suppliers demand streamlined EU Taxonomy reporting rules

4 Dec 2025
Topic — The European Commission is reviewing environmental criteria within the sustainable finance taxonomy framework.
Message — UNIFE proposes merging rail component manufacturing into vehicle manufacturing to ensure reporting consistency. They also request centralized, free platforms for climate and environmental risk assessments to reduce technical burdens. Finally, they seek to align pollution criteria with existing transport directives.123
Why — This would reduce their compliance costs and simplify sustainability reporting requirements.45
Impact — Commercial data providers lose business as companies shift to free public tools.6
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Meeting with Oihane Agirregoitia Martínez (Member of the European Parliament, Rapporteur)

4 Dec 2025 · Mecanismo de compensación

Meeting with Peteris Ustubs (Director Directorate-General for International Partnerships)

21 Nov 2025 · Follow-up with UNIFE Vietnam

Meeting with Kai Tegethoff (Member of the European Parliament, Shadow rapporteur)

18 Nov 2025 · CEF

Rail Industry Urges EU Preference and Tied Aid in Global Europe Funding

17 Nov 2025
Topic — EU's post-2027 budget for external action and Global Gateway infrastructure projects worldwide.
Message — UNIFE requests EU preference requirements, tied aid mechanisms, and restrictions on high-risk suppliers in the Global Europe Instrument. They want grants for rail projects, stronger support for Export Credit Agencies, and alignment with EU competitiveness objectives.1234
Why — This would reduce competition from subsidized foreign rail manufacturers and secure EU taxpayer-funded projects for European suppliers.567
Impact — Developing countries lose access to cheaper non-EU suppliers for infrastructure projects funded by European aid.89
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Meeting with Rosa Serrano Sierra (Member of the European Parliament)

17 Nov 2025 · MFF 2028-2034

Meeting with Mika Aaltola (Member of the European Parliament, Shadow rapporteur for opinion)

13 Nov 2025 · EU affairs

Meeting with Kristian Schmidt (Director Mobility and Transport)

12 Nov 2025 · European rail transport policy

Rail Industry Urges Tailored Recycling Targets and Harmonised EU Waste Rules

6 Nov 2025
Topic — EU Circular Economy Act to enhance resource efficiency and recycled materials supply.
Message — UNIFE requests recycled-content targets tailored to specific technologies and products, harmonised EU waste classification to enable cross-border material movement, and green-listing of textile and electronic waste to reduce administrative burdens.123
Why — This would reduce compliance costs and enable efficient recovery of materials from 40-year-old rolling stock.456
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Response to Terms and conditions for delaying dissemination of notifications

6 Nov 2025

The delegated act is overall a positive clarification, providing grounds and proedures for notified CSIRTs to delay notifying the CSIRT network of a found vulnerability. From the perspective of the rail supply industry, more clarity is needed on the communication between the notifying manufacturer and notified CSIRT: the CSIRT should inform the manufacturer of the decision to delay the notification and its grounds to do so. Similarly, manufacturer and CSIRT should dialogue regarding the manufacturer's decision to notify a wider audience beyond the CSIRT network, or to make the vulnerability public altogether.
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UNIFE calls for strong synergies between research and deployment funding

31 Oct 2025
Topic — Future EU budget supporting research, innovation and competitiveness through Horizon Europe and European Competitiveness Fund.
Message — UNIFE requests continuation of Europe's Rail Joint Undertaking with minimum €3 billion for research and innovation and €15 billion for pre-deployment. They seek strong coordination between Horizon Europe and the European Competitiveness Fund work programmes to support rail technologies from research through market uptake.12
Why — This would secure long-term funding for rail innovation and accelerate commercial deployment of new technologies.34
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European Rail Industry Urges Strong ECF Support for Rail Technologies

31 Oct 2025
Topic — EU budget proposal establishing European Competitiveness Fund and Horizon Europe for 2028-2034.
Message — UNIFE requests strong ECF support for rail technologies in coordination with CEF, using ECF as pre-deployment fund for technologies from Europe's Rail Joint Undertaking. They call for alignment between high-risk supplier concepts, EU preference provisions and public procurement revision, emphasizing grants for rail sector and EU guarantees with Export Credit Agencies.1234
Why — This would provide funding for market deployment of their railway technologies and reduce administrative burdens for industry members.567
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Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas) and Siemens AG and Alstom

22 Oct 2025 · Cyber Resilience Act (CRA), Data Act, and Artificial Intelligence (AI) Act in the scope of the Digital Omnibus

European rail industry urges procurement reforms in EU cohesion fund

21 Oct 2025
Topic — New EU multiannual budget framework covering cohesion, agriculture, and infrastructure for 2028-2034.
Message — The association requests reforms to procurement rules and entity eligibility requirements for EU-funded projects. They want changes based on lessons from the Recovery and Resilience Facility, including remedy mechanisms for identified shortcomings.12
Why — This would streamline access to EU funding and reduce procurement barriers for rail suppliers.3
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UNIFE calls for stronger EU preference in rail infrastructure funding

21 Oct 2025
Topic — EU funding for trans-European transport networks and cohesion policy 2028-2034.
Message — UNIFE requests clearer eligible activities for rail projects, particularly ERTMS deployment funding. They want EU preference provisions introduced in CEF to match the European Competitiveness Fund, and alignment of high-risk supplier definitions across all EU programmes.1234
Why — This would protect European rail manufacturers from non-EU competition and ensure predictable funding for their products.56
Impact — Non-EU rail suppliers would face restricted access to European infrastructure projects and funding.78
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Meeting with Sofia Munoz Albarran (Director Trade) and

15 Oct 2025 · Interplay between the trade anti-dumping and anti-subsidies regulations and the EU Regulation on Foreign Subsidies (FSR) to ensure that the two regimes combined deliver their maximal effect, complementing each other, while remaining accessible.

Meeting with Vivien Costanzo (Member of the European Parliament)

15 Oct 2025 · Exchange of views

Meeting with Hildegard Bentele (Member of the European Parliament, Rapporteur)

25 Sept 2025 · Global Gateway

UNIFE supports 2040 target and urges rail infrastructure funding

11 Sept 2025
Topic — The European Commission's legislative proposal to include a 2040 climate target.
Message — UNIFE supports the 90% reduction target to provide long-term investment predictability for companies. They urge that ETS revenues and carbon credits prioritize funding for rail infrastructure and modernization. The association also suggests that high-polluting sectors like aviation fund low-carbon rail projects.123
Why — This approach secures new funding for rail projects and incentivizes a modal shift.45
Impact — Aviation and other high-emission sectors lose revenue to fund their direct rail competitors.6
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Meeting with Herald Ruijters (Deputy Director-General Defence Industry and Space)

10 Sept 2025 · Military Mobility

Meeting with Sergio Oliete Josa (Head of Unit Directorate-General for International Partnerships)

5 Sept 2025 · Meeting to review the state of preparation of three EU-co-financed railway initiatives in Southern Africa.

Meeting with Rosa Serrano Sierra (Member of the European Parliament)

4 Sept 2025 · MFF Priorities Rail Sector

Meeting with Virginijus Sinkevičius (Member of the European Parliament, Shadow rapporteur)

4 Sept 2025 · Military mobility

Meeting with Mārtiņš Staķis (Member of the European Parliament, Shadow rapporteur)

4 Sept 2025 · Military Mobility

UNIFE urges specific rail support in EU transport investment plan

3 Sept 2025
Topic — This strategic framework prioritises public and private investment in sustainable transport solutions.
Message — UNIFE requests support for rail electrification, hydrogen trains, and battery technologies. They also suggest mobilising unused pandemic recovery funds.12
Why — Increased funding would help European rail suppliers leverage their current technological leadership.34
Impact — Manufacturers and operators of diesel-powered vehicles face displacement as fossil fuels phase out.5
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Meeting with Kai Tegethoff (Member of the European Parliament)

3 Sept 2025 · MFF and Military Mobility

Meeting with François Kalfon (Member of the European Parliament)

27 Aug 2025 · Financement et décarbonation des transports

Meeting with Pierre Jouvet (Member of the European Parliament)

27 Aug 2025 · marchés publics

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

9 Jul 2025 · Shaping a new Team Europe approach towards LAC in order to increase the success rate of EU Railways industry on tenders on the region.

UNIFE urges EU to create independent rail cybersecurity database

20 Jun 2025
Topic — A review of the EU Cybersecurity Act and ENISA's operational mandate.
Message — UNIFE requests a European vulnerability database to replace reliance on US sources. They also want a dedicated information sharing center for the rail sector.12
Why — This would provide rail companies with a more stable and reliable security resource.3
Impact — The US National Vulnerability Database could lose its global influence and usage.4
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Meeting with Roberts Zīle (Member of the European Parliament, Rapporteur) and European Sea Ports Organisation

10 Jun 2025 · Military Mobility

Meeting with Hans Stausboll (Acting Director Directorate-General for International Partnerships) and

6 May 2025 · Shaping a new Team Europe approach towards Asia and Sub- Saharan Africa in order to develop rail projects in both regions while ensuring the competitiveness of the EU’s railways industry.

Meeting with Sophia Kircher (Member of the European Parliament)

28 Apr 2025 · Europe´s Rail Joint Undertaking

Response to Technical description of important and critical products with digital elements

18 Apr 2025

As representative of the rail supply industry, UNIFE is very active in making the implementation of the CRA in the railway sector streamlined and efficient. Collaborating to the production of implementing acts and guidelines for the CRA is a key part of this process. The CRA encompasses a very broad ensemble of products in very different sectors, all with their own specificities. It is therefore necessary for the definitions and their wording to be as precise as possible to avoid cases where a definition - while suitable for most applications - may cause unforeseen ambiguities in one or a few specific sectors. UNIFE considers the proposed definitions a notable improvement in clarity compared to the CRA text itself. To further reduce ambiguity, the use in the implementing act of terms already defined in the CRA text would be preferable to additional terminology. As an example, the term "core functionality" is used but not defined in the CRA, More detailed comments are found in the attached document.
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Meeting with Rosa Serrano Sierra (Member of the European Parliament)

10 Apr 2025 · Key challenges sector

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Siemens AG and

9 Apr 2025 · Rail Supply Industry challenges and opportunities

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

31 Mar 2025 · Shaping a new Team Europe approach towards LAC in order to increase the success rate of EU Railways industry on tenders on the region.

UNIFE urges deletion of burdensome chemical reporting requirements

26 Mar 2025
Topic — The initiative amends Taxonomy Delegated Acts to simplify sustainability reporting for companies.
Message — UNIFE recommends deleting burdensome requirements for reporting chemical substances in final products. They advocate for aligning rules with existing regulations like REACH and maintaining current exemptions.12
Why — Proposed changes would ensure business certainty and improve official taxonomy alignment rates.34
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Meeting with Lena Schilling (Member of the European Parliament)

20 Mar 2025 · MFF/FP10, Bahnindustrie F&E

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Alstom and

25 Feb 2025 · Preparatory meeting to mission to Mexico

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Feb 2025 · Exchange of views with UNIFE CEOs on the margins of the 18th European Railway award event

Meeting with Kristian Schmidt (Director Mobility and Transport)

17 Feb 2025 · Main EU initiatives of relevance to the railway supply industry and the deployment of new rail technologies.

Meeting with Joachim Luecking (Head of Unit Mobility and Transport)

7 Feb 2025 · Presentation new Head of Unit DG MOVE.C4 Presentation of the work of UNIFE Overview of UNIFE position on main challenges of the sector

Meeting with Kai Tegethoff (Member of the European Parliament)

4 Feb 2025 · Rail Financing

Meeting with Rasmus Nordqvist (Member of the European Parliament, Shadow rapporteur)

30 Jan 2025 · Transport and the future MFF

Meeting with Pierre Jouvet (Member of the European Parliament, Shadow rapporteur) and Alstom

22 Jan 2025 · Marchés publics

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur) and Vereniging VNO-NCW

22 Jan 2025 · Public procurement

Meeting with Karlo Ressler (Member of the European Parliament)

21 Jan 2025 · Multiannual Financial Framework (MFF)

Meeting with Martine Kemp (Member of the European Parliament)

21 Jan 2025 · Introduction Meeting

Meeting with Peter Liese (Member of the European Parliament)

16 Jan 2025 · Climate Policy

Response to Amendment of LOC&PAS and WAG Technical Specifications for rail Interoperability and of register of rail infrastructure

9 Jan 2025

Clarification comment on point 7.1.1.6.3, on behalf of UNIFE - The European Rail Supply Industry Association Current Text: 7.1.1.6.3 Conditions applicable to personnel carriages intended to be included in passenger trains. (4) While included in passenger trains, instead of point 7.1.1.6.1 (23), the following point applies: (a) For each band of the frequency management defined in the specification referenced in Appendix J-2 index [A] and in the specific cases or technical documents referred to in Article 13 of TSI CCS when they are available. Pending the notification of specific cases referred to in Article 13 of CCS TSI, the notified national rules remain applicable: (1) Maximum interference current (A), and applicable summation rule, (2) Maximum magnetic field (dBμA/m) both radiated field and field due to the return current, and applicable summation rule, Comment: UNIFE would like to remind that there is currently no validated summation rule/procedure for magnetic fields, see § 7.1.1.6.3 (4), a) (1) & (2); this could only be part of a future version of the EN 50728. The summation rules for the return currents are well defined, you can apply the summation rules for magnetic fields, which are the direct cause of the return current, in the same way. Although the EN 50728 was written mainly for the scope of track circuits, the physical principles behind the summation rules are still valid for other applications. However, it is not yet defined whether and how the field caused by the return current and the field caused by other local sources under the train would add up. It is also not defined how fields caused by other currents than the return currents might app up either, e.g. fields caused by common mode/capacitive currents under the train or in/between the bogies. Proposal for rewording: (2) Maximum magnetic field (dBμA/m) both radiated field and field due to the return current.
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and Siemens AG and

12 Dec 2024 · RAIL SUPPPLY INDUSTRY PRIORITIES

Meeting with Alexandra Mehnert (Member of the European Parliament)

5 Dec 2024 · rail transport policies

Meeting with Virginijus Sinkevičius (Member of the European Parliament)

27 Nov 2024 · Discussion on issues related to rail transport (decarbonisation of transport, financing for rail, fair competition between European and non-European companies, etc.).

Meeting with Pierre Jouvet (Member of the European Parliament)

27 Nov 2024 · marchés publics

Meeting with Raphaël Glucksmann (Member of the European Parliament, Rapporteur)

27 Nov 2024 · Foreign Investments screening regulation

Meeting with Valérie Devaux (Member of the European Parliament)

27 Nov 2024 · enjeux industriels du ferroviaire

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

26 Nov 2024 · general exchange on the current challenges in the rail industry

Meeting with Hanna Gedin (Member of the European Parliament)

26 Nov 2024 · Public Procurement

Meeting with Tom Berendsen (Member of the European Parliament)

26 Nov 2024 · Rail supply industry

Meeting with Sophia Kircher (Member of the European Parliament)

30 Oct 2024 · Funding, CEF

Meeting with Markus Ferber (Member of the European Parliament, Rapporteur for opinion)

30 Oct 2024 · Revision of the foreign direct investment (FDI) screening regulation

Meeting with Lena Schilling (Member of the European Parliament)

22 Oct 2024 · Rail Policy

Meeting with Dariusz Joński (Member of the European Parliament)

22 Oct 2024 · Presentation of the association priorities for the new legislature and the challenges the industry faces.

Meeting with Ondřej Krutílek (Member of the European Parliament)

18 Sept 2024 · EU policy on rail transport (2024-2029)

Meeting with Elena Nevado Del Campo (Member of the European Parliament)

18 Sept 2024 · UNIFE's priorities

Meeting with Vicent Marzà Ibáñez (Member of the European Parliament)

18 Sept 2024 · Introduction, presentation and greeting

Meeting with Tilly Metz (Member of the European Parliament)

18 Sept 2024 · Challenges for rail sector

Response to Ex-post evaluation of the Connecting Europe Facility 2014-2020

17 Sept 2024

UNIFE acknowledges that CEF grants have provided crucial support to the achievement of the Trans-European Transport Network (TEN-T) policy objectives and the development of sustainable transport system. In this context, the CEF programme should continue to be the cornerstone of the EU Investment Policy in the transport sector also in the post-2027 period. Financial support through CEF grants will be vital for the development of the TEN-T Core Network Corridors that are key to bridge the gaps and bottlenecks, thus increasing the competitiveness of the European rail system. As a building blocks for the configuration of the next EU MFF 2028-2034, UNIFE is convinced that a continuation of the CEF programme with a substantial budget increase is fundamental to accomplishing the TEN-T network. In this sense, we also provide key considerations for the future of CEF. As a building blocks for the configuration of the next EU MFF 2028-2034, UNIFE is convinced that a continuation of the CEF programme with a substantial budget increase is fundamental to accomplishing the TEN-T network. In this sense, we also provide key considerations for the future of CEF, notably on: the budget earmarking that should be dedicated to rail, the importance of solid budget lines for ERTMS, DAC and FRMCS, the need to increase support to urban rail transport as well as the need for a stronger military mobility budget. Other recommendations pertain to the need to support alternative fuels infrastructure for rail, the possibility to support the acquisition of rolling stock, the simplification through disbursement of lump sums and budgets front loading.
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Response to Interim evaluation of the Connecting Europe Facility 2021-2027

17 Sept 2024

UNIFE acknowledges that CEF grants have provided crucial support to the achievement of the Trans-European Transport Network (TEN-T) policy objectives and the development of sustainable transport system. In this context, the CEF programme should continue to be the cornerstone of the EU Investment Policy in the transport sector also in the post-2027 period. Financial support through CEF grants will be vital for the development of the TEN-T Core Network Corridors that are key to bridge the gaps and bottlenecks, thus increasing the competitiveness of the European rail system. As a building blocks for the configuration of the next EU MFF 2028-2034, UNIFE is convinced that a continuation of the CEF programme with a substantial budget increase is fundamental to accomplishing the TEN-T network. In this sense, we also provide key considerations for the future of CEF. As a building blocks for the configuration of the next EU MFF 2028-2034, UNIFE is convinced that a continuation of the CEF programme with a substantial budget increase is fundamental to accomplishing the TEN-T network. In this sense, we also provide key considerations for the future of CEF, notably on: the budget earmarking that should be dedicated to rail, the importance of solid budget lines for ERTMS, DAC and FRMCS, the need to increase support to urban rail transport as well as the need for a stronger military mobility budget. Other recommendations pertain to the need to support alternative fuels infrastructure for rail, the possibility to support the acquisition of rolling stock, the simplification through disbursement of lump sums and budgets front loading.
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Meeting with Christophe Grudler (Member of the European Parliament) and RENAULT

17 Sept 2024 · Politique industrielle européenne

Meeting with Leila Chaibi (Member of the European Parliament)

17 Sept 2024 · Public procurement

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

13 Jun 2024 · - Technical specifications for interoperability - Foreign Subsidies Regulation for rail projects - Recovery and Resilience Facility

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

24 May 2024

UNIFE, the European Association of the Rail Supply Industry welcomes and supports the establishment of the SCF to address the social impacts arising from the new emission trading system for buildings and road transport (ETS2) on vulnerable groups in the EU, especially those affected by energy poverty or transport poverty. In this sense, the SCF offers an opportunity for Member States to finance zero- and low-emission mobility & transport, including public transport. Thus, an opportunity to support Member States in further developing rail transport solutions, including at the urban level, through the developing of interoperable rail infrastructure and the acquisition of zero and low-emission rolling stock. Over the last years, the Commission has developed a DNSH Technical Guidance C(2023) 6454 for the Recovery and Resilience Facility (RRF), the Explanatory note on the Application of the DNSH principle under Cohesion Policy, as well as the InvestEU Sustainability Proofing Guidance for the repayable support under the InvestEU Fund. UNIFE believes that to further apply the DNSH principle in the new SCF and future EU programmes from the next EU Multiannual Framework (MFF) 2028-2034, it would be beneficial to apply Technical Guidance for the RRF and improve the climate tracking methodology for the different rail intervention categories. This approach could also be extended to other potential off-the-EU budget instruments, such as NextGenerationEU, that might be introduced in the future. In parallel, the application of the DNSH principle should be based on a risk-based approach, as per regulatory provisions on the use of chemicals. Acknowledging the crucial role that rail has to play in order to deliver on the EU Green Deal by recognizing the rail sectors environmental assets and energy efficiency is vital to transitioning to a low-carbon economy and reducing the EUs dependency on imported fossil fuels. Therefore, following the RRF approach on the DNSH and improving the methodology for climate tracking will be necessary so that rail investments can feature prominently in the Member States plans to be supported under the upcoming SCF. Hence contributing to the alleviation of transport poverty by providing rail mobility solutions with rail as the backbone of sustainable mobility in Europe. More detailed information can be found in the attached document.
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Response to Revision of fees and charges of the European Union Agency for Railways

28 Mar 2024

The railway sector stakeholders represented here by UNIFE, AERRL, ALLRAIL, CER, EIM, ERFA, UIP and UIRR - 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.
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Meeting with Tom Berendsen (Member of the European Parliament)

1 Feb 2024 · NZIA - Definitions and public procurement

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

30 Jan 2024 · - TSIs - Skillful staff shortage - EU funding for rail - ETCS

Meeting with Maroš Šefčovič (Executive Vice-President) and Community of European Railway and Infrastructure Companies

29 Jan 2024 · Railway

Meeting with Jakop G. Dalunde (Member of the European Parliament)

29 Jan 2024 · European railway award 2024

Response to Voluntary cybersecurity certification for ICT products, based on a Common Criteria set of security requirements

30 Oct 2023

UNIFE - the European Rail Supply Industry Association - welcomes the opportunity to give feedback to the European Commission's public consultation on Cybersecurity security requirements for ICT product certification under CSA (EU) 2019/881. UNIFE's reply to the public consultation is attached. We remain at your disposal for any further clarification. UNIFE thanks the European Commission for considering our views, and we remain at your disposal should you have any further questions.
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

UNIFE The European Rail Industry Association - advocates on behalf of more than 100 of Europes leading rail supply companies, from SMEs to major industrial champions, active in the design, manufacture, maintenance and refurbishment of rail transport systems, subsystems and related equipment. UNIFE members invest significant efforts into the standardisation of rail products within numerous Technical Committees at National, European and International level, as well as help shape the extensive link between the European Standards and European legislation. When evaluating the Regulation (EU) 1025/2012, UNIFE would like to highlight several areas of importance found in the attached paper.
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Response to Evaluation of the European Union Agency for Cybersecurity (ENISA) and the European Cybersecurity Certification Framework

15 Sept 2023

UNIFE - the European Rail Supply Industry Association - welcomes the opportunity to give feedback to the European Commission's public consultation on the evaluation of ENISA and the European Cybersecurity Certification Framework. UNIFE's reply to the public consultation is attached. We remain at your disposal for any further clarification. European rail manufacturers look forward to work together with the EU institutions, ENISA and ERA to address the current and upcoming challenges in cybersecurity.
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Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

14 Jul 2023

The European Rail Supply Industry Association (UNIFE) welcomes the opportunity to express its view on the EUs Foreign Direct Investment Screening Regulation (EU/2019/452). More detailed information can be found in the attached file.
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Response to Ecodesign for Sustainable Products - Product priorities

4 May 2023

UNIFE, the association of the European rail supply industry - welcomes the opportunity to provide feedback on the first working plan on the proposal for a regulation establishing a framework for setting eco-design requirements for sustainable products and repealing Directive 2009/125/EC. - Unleash the benefits of the EU internal market and further enhance European harmonisation for economic and environmental benefits. - Preserve the Commissions approach of defining product-specific requirements in secondary legislation (no horizontal/one-size-fits-all approach). - Clarify the substance of concern definition and better outline suppliers-customers responsibilities. - Clarify the definition of intermediate products and end-use products. - Clarify the requirements for end-use products not prioritised in the proposal but which rely on some prioritised intermediate or end-use products. - Rely on robust scientific methodologies and international standards. - Develop a decentralised and interoperable Digital Product Passport (DPP). - Improve the implementation timeline of the work plan. Please find attached the UNIFE contribution to this file.
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Rail industry urges streamlined reporting and fair transport competition

3 May 2023
Topic — Update to EU rules defining which economic activities qualify as environmentally sustainable.
Message — The association asks to avoid double reporting between different environmental rules. They want rail components clearly included and consistent criteria for all sector participants.123
Why — Streamlined rules would simplify compliance and reduce the administrative burden of reporting.4
Impact — Competing transport modes would lose green funding if stricter eligibility rules apply.5
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Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

27 Feb 2023 · Stakeholder consultation on the Cyber Resilience Act

Meeting with Marie-Pierre Vedrenne (Member of the European Parliament)

14 Feb 2023 · Marchés publics et politiques commerciales de l'UE

Meeting with Izaskun Bilbao Barandica (Member of the European Parliament) and Community of European Railway and Infrastructure Companies

31 Jan 2023 · European Railway Award Ceremony

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament) and Community of European Railway and Infrastructure Companies

31 Jan 2023 · Railway Award

Response to Revision of technical specification for interoperability relating to the ‘control-command and signalling’ subsystems

25 Jan 2023

Please find attached the public consultation comments on the CCS TSI on behalf of UNIFE The European Rail Industry Association. Although we appreciate the consideration of a more relaxed transition regime for CCS On-Board Modularity, unfortunately no relevant progress has been achieved on the other critical topics. This is disappointing after the numerous EC Expert Group meetings were held in Q4 2022. Therefore, with one exception, our concerns and recommendations expressed in the joint CER/UNIFE letter dated 12th of December 2022 remain valid. The first comments shown at the beginning of our comment sheet explain more in detail the status of the current CCS TSI in relation to the recommendations expressed in the joint letter. As a summary, we are still facing unacceptable economical burdens for the entire railway sector, generated by the current CCS TSI draft. In the second part of our comment sheet, detailed comments on the CCS TSI follow, with a focus on the most important issues. Significant progress remains necessary on the CCS TSI before it can be considered ready for a RISC opinion. We are fully committed in supporting the European Commission and RISC members to improve the CCS TSI on the remaining critical points, making it acceptable for all railway sector stakeholders.
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Response to Revision of seven Technical Specifications for rail Interoperability: LOC&PAS, WAG, INF, ENE, NOI, PRM and RINF

25 Jan 2023

Please find attached the public consultation comments on the TSI Mega Pack on behalf of UNIFE The European Rail Industry Association. The attached comments address multiple change requests (CRs) found within the TSI Mega Pack public consultation proposal, notably regarding referenced standards, transitional arrangements, special vehicles and PRM Passenger external doors audible signals, DDD/DDF, as well as multiple other technical CR corrections and editorial errors found. UNIFE asks for the attached comments to be considered and sufficiently addressed in the TSI Mega Pack proposal prior to adoption by the Railway Interoperability and Safety Committee (RISC). It must be noted that the multiple technical annexes and interface documents of the TSIs remain unavailable and to be finalised at the time of this public consultation. In addition, the public consultation versions of the TSI documents do not take into account all points discussed and agreed in the EC Expert Group meetings. It is therefore still not possible to give conclusive comments on the content or assess the full impact of the TSI package texts. UNIFE is concerned the consultation phase 30.12.2022 27.01.2023 will not allow sufficient time for proper consideration and implementation of the comments received before the RISC on 08-09 February if the TSI Mega Pack remains scheduled for RISC opinion during this meeting. Significant progress remains necessary on the CCS TSI before it can be considered ready for opinion, as demonstrated by the numerous EC Expert Group meetings held in Q4 2022 and outlined in the CER/UNIFE communication and recommendations sent to the EC and RISC members 12 December. The TSI documents are heavily interrelated and the TSI requirements interlinked, it is therefore essential to have the full and final picture of all texts combined before an opinion can be given. Splitting the RISC opinion process would contradict the long-standing concept of packaging all TSI documents together and increase the risk of the introduction of inconsistencies and errors. Full alignment between the CCS TSI, the OPE TSI and RINF on the one hand and the CCS TSI, the LOCPAS TSI and the WAG TSI on the other hand remains necessary. As a result, UNIFE ask the European Commission and RISC members to: - keep a strong focus on achieving substantial progress on the critical CCS TSI issues and economic impact as highlighted in the December CER/UNIFE communication (incl. the above mentioned interfaces) and take the chances for further alignment in bilateral meetings and during the RISC meeting in February - keep the principle of the one package for the TSI revision and delay the foreseen February RISC opinion on the TSI Mega Pack until the RISC opinion can be requested on a single complete, mature and consistent set of TSIs -> one package, one opinion date, one date of publication and entry into force. UNIFE continue to be committed in supporting the European Commission and RISC members to reach these goals and to help find solutions on the remaining critical points that are acceptable for all, both for the decision makers and the railway sector stakeholders.
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European rail industry urges exclusion from Cyber Resilience Act

19 Jan 2023
Topic — A consultation on cybersecurity requirements for products with digital elements.
Message — UNIFE calls for the exclusion of the rail sector from the proposed legislation. They argue the rules should be integrated into existing rail regulations to avoid double certification and burdensome overlaps.12
Why — This would prevent significant financial burdens and maintain the international competitiveness of rail manufacturers.3
Impact — Rail passengers would face higher ticket prices due to the significant cost of compliance.4
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Meeting with Elena Lizzi (Member of the European Parliament, Shadow rapporteur)

9 Dec 2022 · Data Act

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

23 Nov 2022 · TEN-T, AFIR, ERTMS deployment, funding for rail, results of the 2022 UNIFE World Rail Market Study

Meeting with Dominique Riquet (Member of the European Parliament, Rapporteur)

23 Nov 2022 · Infrastructures de transport

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and APPLiA (Home Appliance Europe)

20 Oct 2022 · Data Act

Meeting with Maria da Graça Carvalho (Member of the European Parliament, Shadow rapporteur for opinion)

19 Oct 2022 · Data Act

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

4 Oct 2022 · Sustainable finance & EU Taxonomy

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

4 Oct 2022 · Sustainable finance & EU Taxonomy

Meeting with Elena Lizzi (Member of the European Parliament, Shadow rapporteur)

28 Sept 2022 · Data Act

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

22 Sept 2022 · exchange

Meeting with Isabel García Muñoz (Member of the European Parliament, Shadow rapporteur)

14 Sept 2022 · TEN-T Revision

Meeting with Jakop G. Dalunde (Member of the European Parliament)

14 Sept 2022 · AFIR

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and REWE ZENTRALFINANZ eG and LKQ Europe

13 Sept 2022 · Data Act

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Lufthansa Group

20 Jul 2022 · Data Act

Meeting with Isabel García Muñoz (Member of the European Parliament, Shadow rapporteur)

24 Jun 2022 · TEN-T Revision

Response to Sustainable Products Initiative

21 Jun 2022

• UNIFE - the association of the European rail supply industry - welcomes the opportunity to provide a feedback on the proposal for a regulation establishing a framework for setting eco-design requirements for sustainable products and repealing Directive 2009/125/EC. • UNIFE supports the European Green Deal’s ambition to make Europe a climate neutral continent by 2050 as well as the Circular Economy Action Plan’s objective to foster to the development of lead markets fit for climate-neutral and sustainable products, in the EU and beyond. • The Commission’s intention to extend the scope of the previous Eco-design Directive (2009) both in terms of products and new kinds of requirements to ensure a better level of consistency with existing policy provisions will indeed further contribute to the achievement of the ambitious goals of climate neutrality and circularity by 2050. • UNIFE welcomes the EC intention to use a product-by-product approach and ensure the full involvement of the key industry stakeholders, for the definition of the Ecodesign legal framework aiming to achieve more harmonized EU requirements. • With this feedback the European rail suppliers industry wish to express some key recommendations on how and to what extend the proposed regulation shall deal with rail-related products and systems to ensure its successful implementation in the future and avoid any unexpected rail market distortions (see attachment).
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Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur) and Kreab Worldwide and

21 Jun 2022 · TEN-T

Meeting with Dominique Riquet (Member of the European Parliament)

16 May 2022 · Infrastructures de transport

European rail industry demands sector-specific data sharing rules

12 May 2022
Topic — The EU is consulting on legislative rules for sharing data among businesses and governments.
Message — UNIFE proposes sector-specific regulations instead of a horizontal approach for the railway sector. They request excluding derivative data and software services to protect intellectual property and trade secrets.12
Why — This approach would protect their proprietary technology and maintain current business models based on bilateral contracts.3
Impact — Third parties and public authorities may face limited data access if access requirements are strictly defined.4
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Meeting with Izaskun Bilbao Barandica (Member of the European Parliament)

10 May 2022 · TEN-t regulation

Meeting with Jens Gieseke (Member of the European Parliament)

4 May 2022 · Austausch zur Verkehrspolitik

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament)

4 May 2022 · Exchange about AFIR

Meeting with Sandra Bartelt (Cabinet of Commissioner Jutta Urpilainen)

27 Apr 2022 · Global Gateway, EFSD+

Meeting with Wioletta Dunin-Majewska (Cabinet of Commissioner Elisa Ferreira)

25 Apr 2022 · Investment in rail in new programming period.

Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

12 Apr 2022

UNIFE, the European Association of the Rail Supply Industry, shares its views and concerns on some concrete aspects of the new proposed Regulation, namely on the Credit Conversion Factor (CCF) for Technical Guarantees and Effective Maturity recognition for Trade Finance. UNIFE agrees with a wide range of stakeholders including the International Chamber of Commerce (ICC) that: • the proposed increase of the CCF from 20% to 50% is overly punitive and; • the implementation of a minimum 2.5 year rule for the effective maturity recognition for Trade Finance is not justified based on past experience. Both measures will create significant price increases for European corporates and SMEs, which will also impact the capacity of public authorities to invest in sustainable transport projects. Therefore, the European rail supply industry is concerned that these two provisions will have large negative consequences for the provision of cost-effective trade finance to the real economy. Given that international trade will be a vital form of relief for many companies – particularly SMEs – in the wake of the Covid-19 pandemic but also in the uncertainty and challenges derived from the war in Ukraine, we call on EU policymakers to carefully consider the proposed amendments, so trade finance assets are not regulated in a penalizing manner under the final Capital Requirements Regulation. The potential impact of the changes contemplated by the draft regulation could have far-reaching consequences for the global level playing field, the competitiveness of EU-based companies trading (or seeking to trade) internationally, and, moreover, for the achievement of the ambitious targets set out in the European Green Deal.
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Response to Measures to better manage and coordinate international rail traffic to increase the modal share of rail

5 Apr 2022

UNIFE feedback to Cross-border rail traffic – better management and coordination initiative UNIFE - the association of the European rail supply industry - welcomes the European Commission (EC) decision to proactively work on a proposal aiming at a better management and coordination of cross-border rail traffic. As rightly mentioned in the sustainable and smart mobility strategy and in line with the European Green Deal objectives, more competitive cross-border rail services would help fight climate change, reduce local air pollution and congestion, increase safety and the energy efficiency of transport. UNIFE believes that a more efficient and adaptable system is required for an optimal capacity management that takes into consideration all relevant elements, for both passenger and freight traffic, as recalled by the European Commission in its recently published Action Plan to boost long distance and cross-border passenger rail. With regards the TEN-T regulation revision, as far as the freight traffic is concerned, the creation of European Transport Corridors (ETCs) through the integration of Core Network Corridors (CNCs) and Rail Freight Corridors (RFCs) is fully supported and welcomed by UNIFE as this will improve the cooperation between the governing bodies of RFCs and CNCs. The rail industry welcomes the ambitious operational requirements to be achieved by 2030, notably that the dwelling time of all freight trains crossing the border does not exceed 15 minutes on average and that at least 90% of the freight trains crossing at least one border of a European Transport Corridor arrive at their destination, or at the external Union border if their destination is outside the Union, at their scheduled time or with a delay of less than 30 minutes. This improvement will be supported by much needed innovations e.g. integrated international timetable planning and cross-border real-time traffic management, standardised European Railway checkpoints, Digital Automated Couplers and others. In relation to multimodal freight terminals, UNIFE considers very important that the infrastructure components listed under Art. 36 include the infrastructure related to facilities for alternative fuels. In relation to rail freight and urban nodes, UNIFE also supports the requirement by 2040 of having in place at least one multimodal passenger hub and one multimodal freight terminal allowing for sufficient transhipment capacity within or in the vicinity of the urban node. These efforts will further contribute to shifting road freight to rail and achieving the sustainable and smart mobility strategy objective of doubling rail freight by 2050. It is important to point out that a lot of the currently discussed freight improvements are dependent on capable national systems and their interaction with each other to enable effective coordination and improvement. This includes high quality and throughgoing planning for yards, terminals and accession lines as well as cross-border aspects to cover the whole train run. The same complete scope must be enabled for the traffic management and any other aspect of management the rail services. Improvements for international traffic depends on innovative national systems which improve the large share of basic national traffic, which has a positive effect on international traffic. Upgraded national systems will allow better planning, coordination, and management of international flows, either through direct dynamic interaction between each other using the new functions and components, or via improved data provision to central systems which can be used as bridging solution for a limited set of functions. A complete centralization in one tool is regarded difficult, but the aim must be that the distributed national systems act as one. This dynamic interaction is part of the goals of the Flagship Area 1 work in Europe’s Rail Joint undertaking.
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Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

21 Mar 2022

UNIFE, the Association of the European Rail Supply Industry, welcomes the Commission’s proposal for a revised Regulation on Union guidelines for the development of the Trans-European Transport Network (TEN-T), published on 14 of December 2021. UNIFE agrees with the Commission’s assessment that revising the Regulation offers a real opportunity to make the TEN-T Network fit for the future, and to align its development to the European Green Deal objectives and the climate targets of the EU Climate Law. Rail is the most environmentally friendly mode of transportation and has a key role to play to achieve the decarbonisation of the economy. It is worth highlighting that rail accounts for less than 0.4% of GHG emissions from transport although it carries 17.9% of inland freight and 8.4% of passengers in Europe. . Therefore, UNIFE believes that the revision of the TEN-T guidelines must enhance the role of rail as the backbone of sustainable mobility in Europe. This endeavour will require further boosting investments to complete the TEN-T rail network and facilitating the deployment of rail innovative and climate friendly technologies. This will be essential to cut greenhouse gas emissions from the transport sector by 90% by 2050, compared with 1990 levels, hence a key element to achieve climate-neutrality.
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Meeting with Adina-Ioana Vălean (Commissioner)

17 Mar 2022 · Meeting with President

Meeting with Jakop G. Dalunde (Member of the European Parliament) and ÖBB-Holding AG and

23 Feb 2022 · Speaker: Symposium on the renewal of night trains in Europe

Meeting with Marie-Pierre Vedrenne (Member of the European Parliament, Shadow rapporteur) and AEGIS Europe

13 Jan 2022 · Lutte contre les subventions étrangères et instrument anti-coercition

Response to Count your transport emissions: CountEmissions EU

15 Dec 2021

• UNIFE - the association of the European rail supply industry - welcomes the European Commission (EC) decision to proactively work on a proposal aiming to set up a framework for calculating greenhouses gases (GHG) emissions of transport operations in the freight and passenger transport sectors. This initiative is indeed consistent with the objectives set in the European Climate Law and Sustainable and Smart Mobility Strategy, which are fully supported by UNIFE. • UNIFE members follow the Life Cycle Assessment (LCA) methodology which is defined as the systematic analysis of the potential environmental impacts of products or services during their entire life cycle (also considering GHG emissions). • UNIFE believes this initiative represents an opportunity to accelerate the decarbonisation of the transport sector, which still accounts as whole for 25% of Europe's greenhouse gas emissions, even though rail sector is responsible for less than 0.5% of transport-related greenhouse gas emissions. • UNIFE members support EC’s objective to tackle the fragmented situation at European level related to the different methodological approaches for GHG emissions calculation. Indeed, this is leading to a lack of available information that prevents companies, customers and passengers from taking the most environmental friendly choice. • European rail manufacturers, representing a worldwide leading industry whose business dimension and outreach are global, have chosen ISO 14025 for environmental footprint communication. Accordingly, UNIFE established relevant Product Category Rules (PCR) document in the framework of the International Environmental Product Declaration EPD® System, operating in accordance with ISO 14025:2006. • The PCR describes how to perform the underlying Life Cycle Assessment (LCA) according to ISO 14040 and other environmental assessments for the development of an (EPD)® according to ISO 14025. • Since its finalization in October 2009, the PCR document has allowed European rail manufacturers to communicate comparable and verifiable information to customers on their products’ environmental impacts (including emissions of greenhouse gases). • This document is periodically updated and verified by an independent body according to the EPD system to make sure that all the latest technological developments are taken into account. Rail customers are, by now, well used to rely on the PCR document as reliable source of international data quality information taking into consideration their specific needs. • As this initiative could possibly lead to deliver a framework enabling further alignment on a global scale, existing well-functioning methodologies, like LCA and prerequisite PCR process, shall be taken into account as reference. • Likewise, the expected outcome of the ISO/CD standard 14083, setting a methodology for the quantification and reporting of greenhouse gas emissions arising from operations of transport chains, shall be considered as this standard, once issued, is expected to be applied to the entire transport sector globally. • In addition, UNIFE believes that this initiative shall ultimately lead to a modal shift towards low-emission transport modes, like rail, by establishing a level playing field for GHG emissions accounting in the transport and logistics sectors and by facilitating more eco-friendly behavioural change. • Finally, UNIFE expects as well this initiative to be fully consistent with other proposal currently being discussed such as the Carbon Border Adjustment Mechanism (CBAM) and the EU emissions trading system (ETS) reform, aiming to curb the GHG emissions.
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Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur)

8 Dec 2021 · AFIR

Response to Carbon Border Adjustment Mechanism

10 Nov 2021

Please find attached our key-messages on CBAM.
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Response to Multimodal Digital Mobility Services

28 Oct 2021

UNIFE - the association of the European rail supply industry - welcomes the European Commission (EC) decision to proactively work on a proposal on Multimodal digital mobility services (MDMS) aiming to improve the sustainability, resilience, efficiency and comfort of the transport system. UNIFE acknowledges this action is indeed fully in line with the flagship 6 ‘Making connected and automated multimodal mobility a reality’ of the Sustainable and Smart Mobility Strategy (SSMS) - notably action 37 – and with the list of legislative proposals for 2022 announced by EC President Ursula von der Leyen during her State of the Union speech in September 2021. For the European rail supply industry, priority should be given to multimodal mobility paradigm based on sustainability – naturally with rail and public transport as the backbone. In this regard, priorities such as ‘’multimodal digital mobility services’’ and ‘’enhanced traffic/mobility management’’ appear to be good instruments to ensure the uptake of ITS services and applications across different modes of transport and hubs. UNIFE welcomes the announced revision of current Delegated Regulation (EU) 2017/1926 to address limited accessibility of dynamic data. Indeed, the main issue being observed by the suppliers is the access to mobility data, especially dynamic data set. These are essential to enabling Mobility as a Service (MaaS), reacting to incidents, adapting services to evolving demand (eg. frequency) and optimizing investments. Transparency and data sharing will also help authorities and public entities to enable journey continuation by data analytics and regulation actions. While reviewing the delegated regulation (EU) 2017/1926, it is indeed key to consider other related initiatives such as the revision of the Telematics Applications for Passenger services (TAP TSI) in the rail sector. In this regard, UNIFE, together with other main Rail associations (CER, EIM, EU Travel Tech) expressed its clear stances on a joint Position paper published back in June 2021. This paper outlines the views and priorities of the European Rail sector with regard to the ongoing 2022 TAP TSI revision package. Data is at the centre of the ongoing digital transformation, being the backbone which enables the digitalization of our economies and societies. Access to data is even more crucial for the creation of multimodal, integrated transport information as well as - possibly - ticketing and payment systems. This would allow the combination of different modes to enable door-to-door journeys, which is the basis of the Mobility as a Service (MaaS). UNIFE encourages EC intention to develop a consistent and harmonized European legal framework for the development of Mobility as a Service (MaaS) applications which varies from one country to another, ultimately leading to the creation of an open and harmonized European market for mobility services. Finally, UNIFE fully supports the Specific Objective 3 (SO3) aiming to ensure that MDMS enhance the efficiency and sustainability of the transport system. A real sustainable transport transition will only be possible when passengers will be provided with clear and complete comparative information on the greenhouse gas (GHG) emissions of a trip, giving them the possibility to opt for the less polluting transport mode. In addition, authorities and public entities shall also establish standards and data exchange transparency principles for monitoring the impacts of regulations, policies, and investments on sustainability. This approach is in line with the objective of accelerating National Access Point (NAP) development in real-time. In this respect, the development of dedicated initiatives for GHG and environmental emissions accounting, such as the future EU framework for harmonized measurement of transport and logistics emissions is strongly supported by the rail industry. More information about UNIFE vision on digitalization can be found on UNIFE website.
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Response to Revision of the Energy Tax Directive

22 Oct 2021

UNIFE, the association of European trains-metros-trams builders and rail equipment manufacturers, would like to bring to the attention of the European Commission our comments and reccomendations on the recast ETD proposal. You will find our Position Paper attached. For all information and questions, please contact Mr. Jonathan Cutuli: Jonathan.Cutuli@unife.org
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Response to Revision of Alternative Fuels Infrastructure Directive

22 Oct 2021

UNIFE, the association of European trains-metros-trams builders and rail equipment manufacturers, would like to bring to the attention of the European Commission our comments and reccomendations on the Regulation (AFIR) proposal. You will find our Position Paper attached. For all information and questions, please contact Mr. Jonathan Cutuli: Jonathan.Cutuli@unife.org
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Response to Revision of ERA Fees & Charges

29 Sept 2021

UNIFE, the association representing Europe’s rail supply industry, acknowledges the updated proposal from the EU Agency for Railways (ERA) and European Commission for the increase to the 4th Railway Package Fees and Charges, also noting the current context of the budget and resource constraints experienced by the Agency. UNIFE continues to express our great concerns about the significant reduction of the EU contribution to the 2021 budget of ERA and has called on the European Institutions to ensure the necessary support, funding and resources are made available to the EU Agency for Railways from 2022 to match its level of expectation and ambition and allow it to perform its key role for the development of the single European railway area and achievement of the EU Green Deal objectives. As a strong supporter for the 4th Railway Package Technical Pillar, we must highlight that today the rail supply industry has not witnessed its original objectives of a 20% reduction in time and cost of the vehicle authorisation procedure but rather a significant increase in efforts and costs caused by the increased level of documentation required and practical procedural issues. Therefore, we would rather all stakeholders focus efforts on removing the real cost drivers on the sector, namely streamlining the 4RP process (notably the Conformity to Type concept and IT tool integration) and addressing the regulation stability. UNIFE understands the requirement for ERA to cover their costs, however an 80% increase in the hourly rate (from 130 to 235 euro) is a clear demonstration that either the complexity of the 4th Railway Package was underestimated, or that the processes as currently established are more complex than originally intended or needed to be – we believe the latter. The fees proposed endanger the aims set out in recital 16 of ERA Regulation (EU) 2016/796 where “…Those fees and charges should be equal to or lower than the current average for the relevant services and should be set in a transparent, fair and uniform manner in cooperation with Member States. They should not jeopardise the competitiveness of the European railway sector…”. Steps must be taken to reduce the time and efforts needed per application rather than simply increasing the fees and charges to match the current time and requirements which do not meet the needs of the industry or the original objectives of the 4th Railway Package. In addition, UNIFE does not support the proposal to charge the applicants for the use of the OSS IT tool. The use of the OSS is mandatory and cannot be considered as a “service”. While we acknowledge the significant maintenance and development costs for the OSS, we consider that the OSS and indeed all ERA registers must be sufficiently funded within the ERA budget. A shortfall in ERA’s budget cannot be compensated by increased fees and charges collected by the Agency under their new 4th Railway Package tasks. The use and population of multiple IT tools is necessary as part of a vehicle authorisation application, charging for these would place undue financial burden on the applicants.
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Response to EU Standard for Green Bond

23 Sept 2021

Green bonds play an increasingly important role in financing assets needed for the low-carbon transition. Delivering on the European Green Deal requires significant massive investment across all sectors and industries, including transport, to accelerate the transition towards a climate-neutral economy and reach the EU’s environmental sustainability objectives – enshrined in EU law and aligned with the Paris Agreement. These efforts will also require a dedicated infrastructure for green financial instruments. UNIFE, the European Association of train builders and rail equipment manufacturers, welcomes the European Commission’s proposal to establish a European Green Bond Standard (EuGB) to further increase investment opportunities and facilitate the identification of environmentally sustainable investments for financing sustainable transport infrastructure, where rail and its digital and energy efficient low carbon related technologies can play a decisive role. The recent developments in sustainable finance appears to be an opportunity for rail-related Green Bond issuers but also for investors. However, concerns about greenwashing do exist. Additionally, very often the control and supervision on reporting on the use of the proceeds, project’s impact and issuer disclosure are not efficiently conducted. Particularly on the issuers side, reporting could become quite a burden that should be overcome through the EuGB as it is conceived with the aim of tackling this lack of transparency and supervision. The principles of the Green Deal recognise the importance of facilitating for investors and companies the identification of environmentally sustainable investments and stresses the need for the credibility of such investments. In this respect, the European Commission has designed a solid Taxonomy framework which sets out a classification of economic activities as environmentally sustainable, according to specific technically screening criteria. Incorporating the EuGB in the capital markets must enable the rail industry to leverage the benefits of climate finance due to its potential to further decarbonise the economy. UNIFE supports the EC proposal for an EuGB since the standard will set out uniform requirements for bond issuers that wish to use European Green Bonds for financing economic activities that have a lasting positive impact on the environment. Most importantly, UNIFE stresses the importance, as proposed by the European Commission, that the EuGB is coherently anchored to the EU Taxonomy to avoid greenwashing practices. Besides their positive environmental impact, green bonds are also increasingly seen as a way to reduce financing costs for the issuers. UNIFE believes that an increased market share of high quality European green bonds – if used and applied properly – will become an additional and useful source of significant green investment. With rail at its centre – as the backbone of sustainable transport – this will significantly contribute to meet the European Green Deal targets.
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Response to Addressing distortions caused by foreign subsidies

15 Jul 2021

As previously explained in previous contributions, there is an increasing influx of bidders from third country economic operators. In the rail supply sector, significant price differences (ranging from 20 to 30%) have been observed in projects awarded to certain rail State-owned Enterprises, in the EU and in other continents/countries. This is all the more problematic as EU funds can be involved and de facto awarded to economic operators distorting competition based on price. This situation is detrimental to the European Rail Supply Industry in the long term. UNIFE welcomes very much the proposed Regulation on foreign subsidies distorting the internal market and believes that this instrument could significantly contribute to level the playing field between European and third country economic operators active in Europe. UNIFE supports the main features of the proposal and acknowledges that many aspects reflect or take into account its contributions on the White Paper. The following are especially welcome: ► The basis for the Commission to act is the fact that an economic operator is “engaging in an economic activity in the internal market”. ► The overall architecture of the proposal balances out efficiency and administrative burden. ► The investigative competence lies exclusively on the Commission, which will lead to more efficiency and less risks of foreign interference. ► Intergovernmental agreements are in the scope. However, UNIFE would like to point out a few aspects of the proposal that should be clarified or amended in order to reinforce its effectiveness: ► Despite a legal basis partly on trade, it is unclear how important trade questions such as reciprocity are addressed. Similarly, the nature of economic operators should be taken into account: Investigations on SOEs should more systematically lead to the presumption that there are financial contributions of a distortive nature, and the burden of proof should be on the SOEs. ► The scope of the foreign subsidies instrument and link with other tools should be clarified.It should be ensured that even though the ASCM relates to trade in goods, the instrument on foreign subsidies can be used against producers of goods by another WTO Member. ► Indicators on distortions on the internal market should be refined, in particular privileged access to a (significant) domestic market by a given economic operator should be included. ► Ad hoc requests for notifications (below thresholds) for concentrations and public procurement are likely to create legal uncertainty for European companies. The possibility to dissolve a merger or acquisition ex post could prove costly for investors and disruptive for investees, even though UNIFE acknowledges that it might be necessary for certain strategic cases that would be below notification thresholds. ► The role of the EU industry should be clarified and enhanced. The investigation procedure must be transparent and must allow the information and participation of the industrial stakeholders active in the sector/procedure under investigation. ► Ex officio reviews should be able to address public procurement not only based on a specific individual procurement procedure but also more transversally, looking at the practices of a given economic operator in a sector, with potential remedy being exclusion from EU procurement market for a certain period of time. ► Coordination between the different tools should be ensured, for instance experiences related to the public procurement notification-based tool should at some point feed in a more transversal ex officio review. ► The key question of access to EU funds is partially addressed in so far as shared management is concerned (i.e. Cohesion and Structural Funds). UNIFE welcomes this, but regrets the lack of visibility and reciprocity of this issue in the proposed Regulation. The attached position paper proposes a deep-dive into the main chapters of the proposed Regulation.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

11 May 2021 · Mobility, industrial strategy

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and The European Steel Association and

3 May 2021 · Carbon Borden Adjustment Mechanism

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and Alstom

16 Apr 2021 · Current policy issues for the European railway industry

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean) and Transport and Environment (European Federation for Transport and Environment) and

13 Apr 2021 · Meeting to discuss the state of play of the Eurovignette

Response to Evaluation of the European Union Agency for Railways (ERA)

28 Mar 2021

UNIFE, the association representing Europe’s rail supply industry, welcomes and supports the roadmap of the evaluation of the EU Agency for Railways. UNIFE appreciates the purpose and scope of the evaluation and the methodology described. Nevertheless, we would like to share the following comments: 1) As the official representative body for the European rail supply industry, UNIFE supports this evaluation initiative and is ready to contribute to it. 2) UNIFE strongly supported the adoption of the Technical Pillar, which we see as being of paramount importance for the rail industry’s competitiveness as it should remove the remaining technical barriers to the creation of a Single European Rail Area (SERA). 3) A harmonised European authorisation process ran by the ERA should result in a convergence and greater certainty of requirements. It should also result in a more consistent, quicker and cheaper process with less duplication of checks and testing. The reduction of costs and time for the delivery of authorisations is key for the European Rail Supply Industry. 4) UNIFE is involved in many ERA’s activities (e.g. Revision of TSIs) and is interacting regularly with the ERA Team. 5) UNIFE members have to apply the new vehicle authorisation process and are cooperating with the ERA Team. Since the first transposition from 8 Members States in 2019 to today, UNIFE has collected a number of feedbacks and return of experience from its members and shared these with ERA. 6) Regarding the evaluation Roadmap proposed, UNIFE fully supports the methodology proposed, especially the five criteria proposed: 1) effectiveness 2) relevance 3) efficiency 4) EU added value and 5) coherence of the Agency’s regulatory framework. 7) We consider that it is important to get from this evaluation an analysis on the impacts of the new role of ERA and new process implemented compared to the initial objectives, notably in terms of reduction of cost and time for the rail sector. The analysis should evaluate the agility and flexibility of the new process and assess particularly its impacts on rail stakeholders. Moreover it would be appreciated to get some recommendations in case some gaps are identified and there is a need to improve the process implemented. 8) We recommend the efficiency criteria also considers the efficiency of the different systems (IT tool, registers etc.) put in place by the Agency to assess their functioning, value added and where improvement or streamlining can be achieved. 9) The assessment should also take into account the impact of the ERA 2021 budget cut on the ERA Team work (including reactivity to manage rail sector’s requests). 10) The assessment should also address the ERA staffing topic: How to attract skilled staff for the upcoming ERA’s challenges? 11) Regarding the “consultation of citizens and stakeholders”, we would recommend to consult the on-going Shift2Rail Joint Undertaking and not its successor as highlighted in the text as the evaluation covers the period from May 2016 until end of 2021. Indeed it would be interesting to get an assessment of the cooperation between Shift2Rail Joint Undertaking and ERA and get some recommendations on potential improvements (if needed) for the successor of Shift2Rail Joint Undertaking. 12) We would suggest also to consult European standardisation bodies (e.g. CEN/CENELEC/ETSI), who are also cooperating with ERA. 13) We would be also interesting to get an assessment of ERA activities dealing with international cooperation (outside of Europe). 14) Regarding the “Data collection and methodology”, we would propose to consider also the cooperation agreements between all the safety authorities and ERA
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Response to Revision of the NIS Directive

8 Mar 2021

UNIFE – the association of the European rail manufacturing industry – acknowledges that a revision of the ‘’Network and Information Security’’ Directive (‘’NIS’’) is nowadays necessary to make it fitter vis-à-vis current cyber-risks. Unprecedented pace in digitalisation, including a huge rise in the use of IoT devices, has substantially increased cyber security risks. The adoption of mass remote working caused by COVID-19 has also led to a significant growth in the use of the cloud services. The NIS Directive’s impact fell short mostly due to both regulatory fragmentation – i.e. lack of harmonisation among Member States in the transposition – and its limited scope not fully reflecting the versatility of cyber threats. The new proposal contains several steps in right direction, especially to overcome national differences in the implementation. Hereby a few points supported by UNIFE included in the proposal: a) The broadened scope including a larger number of sectors and services (Article 2). We positively acknowledge that public telecom communication networks are listed within the Directive’s scope as ‘’essential entities’’: they are a key elements of rail operations. b) The introduction of a ‘’size cap’’ to cover medium and large companies, within a given sector, pursuant to a common definition under EU law (Article 2). This replaces a contradictory identification of individual operators at a national level. c) The concepts of ‘’Operators of essential services’’ and ‘’Digital Service Providers’’, subject to different regulatory regimes, are replaced with those of ‘’essential entities’’ and ‘’important entities’’ (Articles 1-2). Both entities are subject to the same cybersecurity management and reporting requirements. UNIFE had questioned the light-touch regulatory approach applied solely towards DSPs – as they are key suppliers to rail’s OESs. d) ‘’Important entities’’, among which ‘’Manufacture of other transport equipment’’, would be subject to lighter supervisory and compliance regime than ‘’essential entities’’ (Articles 29-30). We highlighted the need to strike a balance between enhanced compliance prescription and avoiding excessive administrative burden for companies – especially SMEs. e) Enhanced risk management requirements for both essential and important entities, through measures focusing on incident response and safeguarding of business continuity (Article 18) – a good basis to foster a cybersecurity culture across companies and industries. f) Mandatory certification of ICT products and solutions based on EU CSA schemes (Article 21). Also, we add, horizontal cybersecurity requirements based on the principles of the New Legislative Framework should be considered. The concept of security of the entire supply chain is introduced in the revision’s proposal. We shall reflect further on its significance for the rail supply industry. Also, both essential and important entities would have to take into account cybersecurity practices of their suppliers and service providers through technical and organisational cybersecurity management measures (Article 18(2)(d): a clarification on possible costs incurred by SMEs must be made. Considering the Encryption (Number 54) as relevant backbone of cybersecurity where confidentiality and Integrity of data and information is needed . But as any other security measure based on secrets, the secure management of these (distributed) secrets is to understood as a precondition of the solution Therefore we encourage to avoid being refrained from measures that could weaken encryption. We also recommend the necessity of having appropriate cryptographic code signing and associated validation infrastructure, as well as to be prepared for the rapid deployment of expected new standards for postquantum digital signatures (and crypto agility in products. European rail manufacturers look forward to work together with the EU institutions to make the NIS2 Directive a success.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

10 Feb 2021 · Taxonomy draft delegated act

Meeting with Frans Timmermans (Executive Vice-President)

4 Feb 2021 · Rail in the European Green Deal

Meeting with Pauline Weinzierl (Cabinet of Commissioner Thierry Breton)

27 Jan 2021 · Public procurement and the White Paper on foreign subsidies

Meeting with Adina-Ioana Vălean (Commissioner) and Community of European Railway and Infrastructure Companies

25 Jan 2021 · Perticipation of the Commissioner to the European Railway award ceremony

Response to Revision of Regulation on Union guidelines for the development of the trans-European transport network (TEN-T)

17 Dec 2020

The TEN-T policy is of fundamental importance as it supports and symbolises connectivity and accessibility for all regions of the Union. It also plays a key role in achieving the Green Deal objectives. The EU’s climate neutrality goals can only be fulfilled with the decarbonisation of the transport sector, which accounts for nearly ¼ of overall emissions in the EU. Rail stands as the exception – reducing steadily its carbon footprint while improving its energy efficiency – and therefore aims at being part of the solution in the EU aspiration to connect all regions in the most climate-friendly manner. In this sense, rail accounts for less than 0.4% of GHG emissions from transport although it carries 17.9% of inland freight and 8.4% of passengers in Europe. In line with the new EC Mobility Strategy in which the Commissions requests investments to “be geared towards upgrading the necessary TEN-T infrastructure to enable the shift towards more sustainable links”, UNIFE calls on the Commission to increase EU backed up investments both in additional rail track kilometres (Core & Comprehensive network), further electrification of the existing network, and alternative energy efficiency solutions as part of the TEN-T revision. This will allow rail to become the backbone of the TEN-T network, perform a key role as the cleanest mode of mass transportation; and advance on the multimodality objectives. These actions will positively contribute to completing the TEN-T network by 2030-2050 while at the same time achieving the Green Deal objectives. ERTMS has many benefits for the operators as well as the passengers: increased capacity of the currently existing infrastructure of up to 40%; higher speeds up to 500 km/h; higher reliability rates; and improved safety for passengers. In order to improve the preparedness of the TEN-T network for the digital transition in the rail transport sector, UNIFE considers that ERTMS should be fully deployed to become the backbone of rail digitalisation. The uptake of other digital technologies such as 5G and cybersecurity in rail should be also boosted through the TEN-T revision. The European rail sector’s innovation efforts have found continuity, stability and long-term vision through the Shift2Rail JU established under Horizon 2020. In order to leverage the potential of R&I in the TEN-T network, UNIFE calls the Commission to reflect and showcase the activities of the Shift2Rail JU and its successor programme by deploying those innovations on the network. Thus, increasing synergies between EU funded programmes such as Horizon Europe and the Connecting Europe Facility should be promoted in the revision of the TEN-T guidelines. To conclude: (1) UNIFE calls on significant financial envelopes to be dedicated to TEN-T implementation at EU, national and regional level and reminds of the importance of CEF and Cohesion Policy Funds for boosting rail investments; (2) UNIFE also believes that it is essential to keep the 2030 and 2050 completion targets, respectively for the Core and the Comprehensive Networks; (3) UNIFE calls on the European Commission to carefully consider the economic impact of further changes in the Technical Specifications for Interoperability (TSIs) and plan for transition rules in line with the asset life in the industry; (4) The TEN-T policy should be used as an opportunity to promote the implementation of the MEAT principle in rail procurement; and (5) UNIFE asks the European Commission to be particularly vigilant on the proper enforcement of EU public procurement and competition rules in case of investment from non-European actors and entities on TEN-T infrastructure.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

16 Dec 2020 · Sustainable and Smart Mobility Strategy Shift2Rail

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

27 Oct 2020 · Sustainable and Smart Mobility strategy

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

21 Oct 2020 · Updates on the rail sector

Response to Addressing distortions caused by foreign subsidies

20 Oct 2020

UNIFE appreciates the possibility to comment on the Inception Impact Assessment (IIA) of a Commission proposal(s) for Regulation(s) to address distortions caused by foreign subsidies in the internal market generally and in the specific cases of acquisitions and public procurement. While the European rail industry is a top exporter on world markets, suppliers are increasingly concerned by the increasing lack of level playing field between EU and non-EU competitors on the internal market. As demonstrated in UNIFE position paper on the White Paper on levelling the playing field as regards foreign subsidies (hereby attached again for reference), major distortions related to bidding prices have been observed in EU projects awarded to Chinese rail State-owned Enterprises (SoEs). A correlation between significant price differences (ranging from 20 to 30%) and price as the main or sole criterion for contracting authorities to award contracts has also been witnessed. The Commission itself, in Chapter 3 the White Paper, acknowledges that gaps exist in the EU legal framework, in particular for public procurement. Indeed, contracting authorities do not have the information necessary to investigate on the existence or the distortive effects of foreign subsidies, and ‘may also have a short-term economic incentive to award contracts to such bidders, even if the low prices offered result from the existence of foreign subsidies’ (p. 11-12, White Paper). Against this background, and given the different policy options proposed in the IIA, UNIFE strongly supports ‘Option 2: Take legislative action at EU level’. Given the current absence of disciplines regarding foreign subsidies (as opposed to EU State aid rules), it is essential that the EU takes actions in order to counter the distortive effects of foreign subsidies on the internal market and achieve a level-playing field between all players. In this respect, adapting the existing EU acquis will be needed to strengthen rules e.g. on abnormally low tenders (Article 84, Directive 2014/25 and Article 69, Directive 2014/24). However, this approach will be insufficient to create a solid system with crucial new elements (e.g. compulsory notification mechanism for Module 2, adequate redressive measures). Therefore, developing new legal instrument(s) complementing existing EU acquis should be an essential part of the initiative. While UNIFE agrees that the three presented options are not mutually exclusive, Option 2 should be the cornerstone of the EU strategy to tackle foreign subsidies on the internal market. Option 1 could provide guidance to the Member States and contracting authorities in the field of public procurement, but it should be on top of Option 2. Indeed, Option 1 only would not create any incentive for contracting authorities to act and to tackle distortive effects of foreign subsidies, which would only increase in time. This is all the more important in the aftermath of Covid-19 crisis and of an unprecedented reduction in urban and mainline ridership, as public contracting authorities will even more be tempted to go to the lowest bidder. Similarly, UNIFE supports the strengthening of international rules for the granting of subsidies both at WTO and bilateral levels outlined in Option 3, however this is a long-term task with uncertain results. Putting all players on an equal footing on subsidy rules in the EU requires to first develop unilaterally an ambitious and workable system that can then be promoted to our trading partners. As a conclusion, the legislation derived from the White Paper represents a one-time opportunity for the EU to achieve a level-playing field for the years to come, in an uncertain global context of recovery and increasing trade tensions. The response to these tensions is not protectionism, but a systemic fight against unfair competition on the single market and worldwide.
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Meeting with Carlos Morais Pires (Cabinet of Commissioner Mariya Gabriel)

2 Oct 2020 · Transforming Europe's rail system European

Response to Revision of the NIS Directive

13 Aug 2020

UNIFE – the association of the European rail supply industry – welcomes the Commission’s initiative to review the Network and Information Security (NIS) Directive, in the framework of the ‘’Shaping Europe’s digital future’’ masterplan. The NIS Directive in 2016 marked one of the most important steps towards a more coherent and harmonised cybersecurity management in Europe. As far as rail is concerned, the Directive identifies rail transportation as ‘’essential service’’, setting obligations on rail operators and infrastructure managers to implement risk management practices as well as to report cyber incidents. We agree that a review of the NIS Directive’s effectiveness and implementation should be carried out, in order to make it fitter vis-à-vis the current cyber-risks. The digital transformation and increasing flow of Big Data are creating unprecedented opportunities for all sectors – including rail – to enhance overall operational and technical efficiency. Such technological progress keeps on redefining the security environment as systems become vulnerable to new types of threats. Cyber threats are as versatile and dynamic as the digital world and its applications. Therefore, the NIS Directive is expected to put in place a robust, up-to-date cybersecurity framework to counter cyber-attacks becoming ever-more sophisticated. We fully agree with the identification of the problems illustrated in the Roadmap. There is a fragmentation in the regulatory landscape due to a lack of harmonisation, among Member States, in the implementation of the Directive. Moreover, for the technological progress moves forward significantly fast, some sectors, services or industries may have been left out of scope. Finally, we share the reference to the sanitary crisis caused by COVID-19 which has seen a growth in the demands for internet-based solutions and – consequently – increased the chance of hacks and cyber-attacks. Among the policy options presented in the Roadmap, UNIFE considers Option 3 (i.e. ‘’the 2nd option of regulatory intervention’’) the most appropriate one, combining it with some elements of Option 2. We would support specific, targeted changes to the current NIS Directive. The priority should be the clarification of certain provisions and fostering consistent harmonisation of the Directive’s current rules across Member States. We stress that such alignment of NIS Directive’s implementation in Member States is essential for protecting the development of the EU Single Market for Data. Furthermore, the opportunity of broadening the Directive’s scope to more sectors and services should be attentively considered, having the goal to reflect the ever-evolving cyber-threats landscape. UNIFE understands the complexity of amending the legal text making it more prescriptive while, at the same time, avoiding unnecessary burdens for sectors and services falling within the Directive’s scope. Administrative burden – e.g. when it comes to reporting obligations – should be mitigated as much as possible especially for SMEs working in sectors and services within the NIS’s scope. In this regard, some measures mentioned under Option 2 could be considered, namely for what concerns the use of guidelines to address less harmonised areas of the Directive and fix inconsistencies in the application of provisions. Finally, we recommend that any review of the NIS Directive is made consistent with other cybersecurity-related initiatives in the latest years, particularly the GDPR and the so-called ‘’Cybersecurity Act’’. The European rail supply industry is keen to work with the Commission and EU institutions on the NIS Directive review. Embracing the need for robust cybersecurity measures and being prepared to deal with cyber-attacks are key priorities for the rail sector. Protection against cyber threats is a vital element of maintaining a safe, reliable railway - ensuring the integrity of rail systems and maintaining operational continuity standards.
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

UNIFE, the association representing the European rail supply industry, welcomes the opportunity to give feedback on the forthcoming ‘’Sustainable and Smart Mobility’’ strategy. We share the Roadmap’s identification of transport’s shortcomings. A frictionless internal single market for mobility is yet to be achieved, a flaw further exposed during the Covid-19 crisis. Moreover, transport still accounts for a quarter of EU’s greenhouse gas emissions – projected to increase upon a post-pandemic return to business-as-usual. Therefore, the climate-neutrality goal, to be reached by 2050 according to the EU Green Deal, cannot be fulfilled without a decisive decarbonisation of the transport sector. Rail stands out as the solution to overcome the ‘’problems’’ identified in the Roadmap. UNIFE joined forces with rail associations CER and EIM to prepare a ‘’Joint Statement’’ (attached), outlining common views & priorities for the forthcoming strategy. Therein, the EU rail sector calls for a ‘’Sustainable and Smart Mobility’’ strategy with modal shift to sustainable and healthy rail – both for passenger & freight – at its core. Rail is the only mode which reduced its emissions, while increasing passenger and freight volumes and improving its energy efficiency. Europe's rail sector pledged to reduce total CO2 emissions for passenger and freight transport by 30% by 2030 – on 1990 levels. According to data by the International Energy Agency (IEA), rail is on track to meet this target, even outperforming it. Sustainable mobility solutions offered by rail are broad and include classical electrification as well as battery-powered trains and hydrogen trains. Moreover, during the Covid-19 crisis, rail and urban rail systems continued to ensure the circulation of goods and passenger working in essential jobs. This has been made possible also thanks to major EU investments in rail projects over the past years – e.g. through Connecting Europe Facility – modernising the European infrastructure, eliminating bottlenecks and bridging missing links along the TEN-T Network. The strategic role played by rail during the Covid-19 crisis has shown the importance of strengthening the future transport systems with rail as its backbone. Looking at metropolitan mobility, urban rail systems running on green electricity can tackle effectively congestion and climate challenges in cities and their outskirts. We consider essential to ensure appropriate funding for urban rail solutions, both at EU and national levels. UNIFE Vision Paper on Urban Mobility (2019) describes the convincing benefits for society provided by smart and clean urban mobility based on rail. Following this further, we support the goal to enable European transport to take full advantage of the opportunities that digitalisation and automation (incl. ERTMS) bring. The strategy should set the pathway for a regulatory framework which enables faster uptake of digital technologies in rail. In our Vision Paper (2020) ‘’Rail fit for digital age’’ (www.unife.org/component/attachments/attachments.html?id=1120&task=download), we outline some of the digital trends the rail sector has been focusing on – e.g. Cybersecurity, AI, 5G connectivity. Finally, UNIFE highlights R&I as a powerful enabler of technological progress and economic growth. Through the activities of Shift2Rail Joint Undertaking, the whole sector worked towards a more digital, integrated & cleaner transport system – especially in key areas such as energy efficiency. ‘’Sustainable and Smart’’ mobility is at the heart of rail’s collaborative research; the strategy should support the continuation of Shift2Rail within Horizon Europe with a strong budget. The whole rail sector looks forward to work together with EU and national institutions to shape Europe’s mobility’s future. Building on the longsighted 2011-Transport White Paper, the coming strategy must set a forward-looking EU policy framework for transport with modal shift at its heart.
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Meeting with Adina-Ioana Vălean (Commissioner) and

7 Jul 2020 · Meeting to discuss rail industry

Meeting with Thierry Breton (Commissioner) and

28 May 2020 · Impacts of COVID-19 on rail industry

Meeting with Frans Timmermans (Executive Vice-President) and Community of European Railway and Infrastructure Companies and ALLIANCE OF RAIL NEW ENTRANTS

14 May 2020 · Recovery and Green Deal in Transport

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

3 Mar 2020 · The European Green Deal and the rail supply chain

Meeting with Henrik Hololei (Director-General Mobility and Transport)

18 Feb 2020 · 4th Railway Package, Shift2Rail, European Green Deal

Response to Climate Law

6 Feb 2020

UNIFE, the association representing the European rail supply industry, would like to thank the European Commission for the opportunity to comment on the Roadmap for the Climate Law - the first concrete step following the publication of the European Green Deal Communication. We fully acknowledge that climate change requires urgent action. Over the latest months, people across the World – and notably the younger generations – have mobilised to demand for a steep change in the way we live, produce and consume on the Planet. Therefore, UNIFE strongly supports what the initiative aims to achieve: making the transition to climate neutrality irreversible. We fully agree that all EU policies must be consistent with the climate-neutrality objective and that all sectors play their part in relation to their emissions contribution. In particular, UNIFE welcomes the principle of having intermediate targets as well as with the plan to increase the EU’s greenhouse gas emission reductions target for 2030 to at least 50% and towards 55% - at least, and not below - compared with 1990 levels. We retain that such step-approach, with intermediate targets, would accompany the transition to 2050 in a more ordered yet effective way, giving the chance to both the European Commission, the sectors (and also citizens) to adjust their decarbonisation efforts more easily. Within this framework, and In more general terms, UNIFE would like to highlight the fundamental role of rail transportation in the framework of the Green Deal. Whilst the transport sector accounts for 24% of emissions as the 2nd biggest polluter after energy production, rail is the only mode which lowered its environmental impact and became more energy-efficient. No Climate neutrality-objectives by 2050 can therefore be achieved without a decisive decarbonisation of mobility, and Rail stands as one essential part of the solution to answer the Climate emergency in Europe and in the World. Finally, UNIFE would like to conclude with a remark on the way the ‘’just'' transition to climate neutrality will be financed. We understand that the issue will be dealt with at a later stage, however we stress that the fulfilment of the climate-neutrality objectives – through i.e. the activation of investments-attracting mechanism – shall not translate into a reduction of the resources of other funding instruments, notably the successor of Connecting Europe Facility (CEF) – as it has been the case with the EFSI, European Fund for Strategic Investment. The CEF is, indeed, one of the financial lifeline for supporting rail and sustainable infrastructure and is therefore instrumental to enable clean mobility to play its role within the Green Deal Framework. Granted, the European rail supply industry is ready to work together with the European Commission over the next months on a number of initiatives linked to the European Green Deal. We are eager to contribute actively and decisively to the fulfilment of Europe's climate ambitions.
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Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

6 Feb 2020 · EU industry strategy and follow-up to the strategy / Indust / issues linked to the global competition

Meeting with Lucia Caudet (Cabinet of Commissioner Thierry Breton)

4 Feb 2020 · Exchange of views on EU industrial policy

Response to Rules for rail vehicle extension of area of use and specifications on standards and transition under Union requirements

20 Dec 2019

Text regarding EC type or design examination certificates: UNIFE believes the new TSI text proposal would have a serious negative impact on the daily business of the European railway sector and jeopardise the goals of the Fourth Railway Package in improving the competitiveness of the railway sector by providing a simplified and cheaper vehicle authorisation and stable management of vehicle and vehicle types. Regulatory stability for rail vehicle projects is essential for the successful delivery of fleets of vehicles at a competitive price. The goal of stable project management is not to delay the application of the latest legislation but to carefully manage each individual project delivery. As it stands the new text proposal, limiting the validity period of a new EC type or design examination certificates, would jeopardise the ability of the rail supply industry to deliver on standard long-term contracts as well as vehicle platform concepts and introduce unacceptable levels of industrial risk at the expense of the stability necessary for complex railway projects. More detail on the UNIFE position can be found in the attached paper. UNIFE asks the European Commission and Member States to reconsider the current text proposal in light of the adverse impact it would have on the competitiveness of the sector. UNIFE proposes the following text for the LOC&PAS and WAG TSIs: “The validity period of additional EC types or design examination certificates shall be limited to 7 years (LOC&PAS) / 10 years (WAG), without exceeding 7 years (LOC&PAS) / 10 years (WAG) after the end of the validity period of the original EC type or design examination certificate”.
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Sept 2019 · Shift2Rail, 4th Railway Package

Meeting with Jean-Eric Paquet (Director-General Research and Innovation) and Community of European Railway and Infrastructure Companies and EUROPEAN RAIL INFRASTRUCTURE MANAGERS

4 Sept 2019 · Joint meeting CER-EIM-UNIFE to discuss future of transportation in Horizon Europe

Response to European Partnership for transforming Europe’s rail system

26 Aug 2019

UNIFE – the association representing the European rail supply industry – strongly supports the proposal of the European Commission to include rail as one of the sectors being fit for the establishment of a European partnership within Horizon Europe Framework Programme. Following the achievements of Shift2Rail, the proposed instrument – ‘’Transforming Europe’s rail system’’ – shall enable rail to become the backbone of an integrated and sustainable mobility system in Europe. To this extent, UNIFE agrees with the economic, environmental, social and scientific impacts that the future instrument is expected to trigger. Among the policy options outlined, UNIFE firmly advocates for ‘’Option 2 – Institutionalised partnership’’, pursuant to Article 187 TFEU, continuing thus the present Shift2Rail Joint Undertaking in its current form. As in the case of Shift2Rail JU, working in an Institutionalised partnership will prove to be an efficient way – for the ‘’Transforming Europe’s rail system’’ instrument – to tackle the fragmentation hurdles identified in the inception impact assessment. UNIFE agrees with the European Commission that rail sectorial challenges are better addressed at EU level by means of a common strategic research agenda and coordinated public and private R&I activities. Indeed, the opportunity to embrace the widest spectrum of the innovation ecosystem across different Member States represents an indisputable European added-value. An institutionalised partnership will be able to bring together the rail supply industry – SMEs, large companies, start-ups – , with operators, infrastructure managers, academics and Research Technology Organisations. Furthermore, the establishment of an institutionalised partnership will likely foster both medium and long-term commitment by all actors involved. For rail, such commitments are fundamental and consistent with the 2030 & 2050-Visions supported by the European Rail Research Advisory Council (ERRAC). Finally, the management-model of an Institutionalised partnership will ensure the timeliness of the projects’ delivery and quality. triggered by high project accountability – through transparency and liability –, ecosystem peer pressure, central knowledge management and staff’s high dedication. With regard to the mentioned objectives, UNIFE supports the reference to the strengthening of the global technological leadership of the European rail supply industry. In fact, one of top objectives of the partnership should be fostering the world’s competitiveness of the rail supply industry in a context of fierce international competition. In this regard, our technologies cannot be developed only in support of the Single European Railway Area, because the business objectives of the companies we represent have a global dimension. Therefore, the future rail’s partnership should also be conceived as a key tool to help the European rail supply industry gain a technological “advantage on international markets. Attached, we would like to bring to your attention the following Document: a ''Policy Note'' summarizing some of the most important points, for UNIFE, in relation to the future rail's collaborative-research instrument.
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Response to Evaluation of the 2011 White Paper on Transport

6 Mar 2019

UNIFE – the association representing the European rail supply industry – welcomes the initiative of the European Commission to start the procedure toward a comprehensive evaluation of the 2011-Transport White Paper. UNIFE fully shares the 2050-long-term strategy and objectives enshrined in the White Paper. As a matter of fact, the 2011-Transport White Paper formulates an integrated vision of how transport should look in the year 2050 – with concrete intermediate goals for the year 2030 to make the scope of the transformation task more tangible. Modal shift toward sustainable modes of transport – notably, including rail – is a cornerstone of this vision. Granted, UNIFE believes that with a modal shift to low-emission modes, such as mainline and urban/suburban rail, the EU transport sector would achieve efficient decarbonisation, contributing in a crucial way to the accomplishment of the objectives set in the Paris Agreement – COP 21. UNIFE would like to call on the European Commission to use the opportunity of the forthcoming evaluation of the White Paper to foster its actual implementation, preparing Transport sector to 2050 carbon neutrality global objective, confirming in legislation at least 60% reduction target for transport emissions by 2050 compared to 1990 levels, with an additional binding target for 2030. Furthermore, corollary to this main objective, the achievements goals such as at least 40% cut in shipping emissions; a 50% shift of medium distance intercity passenger and freight journeys from road to rail and waterborne transport, shall be convincingly boosted. These goals and targets would be reached even faster if the rail sector is able to fully deploy its potential through, notably, the completion of the TEN-T Core and Comprehensive Networks as well as the implementation of the ERTMS Deployment Plan. Eventually, UNIFE – on behalf of the European rail supply industry – is ready to support the European Commission throughout the whole evaluation phase of the 2011-Transport White Paper and looks forward to giving its decisive contribution to such process. Attached, you would find our Position Paper - jointly prepared with the fellow associations CER and EIM - on the EU long-term strategy for greenhouse gases emissions reductions.
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Meeting with Violeta Bulc (Commissioner) and

20 Feb 2018 · Meeting with Ms Sabrina Soussan, CEO of Siemens Mobility and Chairwoman of UNIFE

Meeting with Elżbieta Bieńkowska (Commissioner) and

24 Jan 2018 · Exchange of views on Industrial Policy

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and European Chemical Industry Council and EUROPEAN APPAREL AND TEXTILE CONFEDERATION

11 Jan 2018 · Industrial policy

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and European Chemical Industry Council and EUROPEAN APPAREL AND TEXTILE CONFEDERATION

7 Dec 2017 · Industrial policy

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and European Chemical Industry Council and EUROPEAN APPAREL AND TEXTILE CONFEDERATION

10 Nov 2017 · Politique industrielle

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis)

30 May 2017 · EU-China trade relations

Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)

3 Mar 2017 · CEF, Structural Funds, EIB instruments, EFSI

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

10 Feb 2017 · EU Public Procurement

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

12 Jan 2017 · Competitiveness and challenges for the European Rail Supply Industry

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

25 Nov 2016 · ESI Funds for Rail

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

27 Sept 2016 · Situation of European Rail Supply Industry

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

27 Sept 2016 · Defending European interests in negotiations with Japan notably.

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

30 Aug 2016 · China rail market

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

4 Mar 2016 · aviation

Meeting with Henrik Hololei (Director-General Mobility and Transport)

27 Nov 2015 · 4th Railway Package, Shift2Rail, Horizon 2020

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström) and Alstom

4 Nov 2015 · Governmental procurement markets

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

13 Oct 2015 · Meeting board of UNIFE

Meeting with Maroš Šefčovič (Vice-President)

27 Apr 2015 · Railway transport + Energy Union

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis), Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis)

23 Mar 2015 · Discussion on EU-Japan Free Trade Agreement negotiations, EU-China Investment Agreement and Transatlantic Trade and Investment Partnership (TTIP) negotiations

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

23 Feb 2015 · Trade

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

9 Feb 2015 · Rail Industry

Meeting with Mikel Landabaso Alvarez (Cabinet of Commissioner Corina Crețu)

21 Jan 2015 · Cohesion Policy and investments in railway

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

15 Jan 2015 · Decarbonisation of road transport

Meeting with Cecilia Malmström (Commissioner) and

15 Jan 2015 · EU-Japan FTA negotiations, China's policy on railways within China, within the EU and in third countries' markets and TTIP negotiations

Meeting with Jocelyn Fajardo (Cabinet of Commissioner Violeta Bulc)

6 Jan 2015 · EU rail policy

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

18 Dec 2014 · The European Rail Industry in Trade Negotiations

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

16 Dec 2014 · EU regional transport policies and funds. Forthcoming meeting of UNIFE with Commissioner Crețu.