COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council establishing a European Maritime Single Window environment and repealing directive 2010/65/EU

EN EN
EUROPEAN
COMMISSION
Brussels, 17.5.2018
SWD(2018) 181 final
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT
Accompanying the document
Proposal for a Regulation of the European Parliament and of the Council
establishing a European Maritime Single Window environment and repealing directive
2010/65/EU
{COM(2018) 278 final} - {SEC(2018) 230 final} - {SWD(2018) 182 final}
Europaudvalget 2018
KOM (2018) 0278
Offentligt
1
Contents
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT ...............................................................5
1.1. Background: the Reporting Formalities Directive .......................................................................5
1.2. Legal context................................................................................................................................7
1.3. Policy context ..............................................................................................................................7
1.4. Economic and trade context.........................................................................................................9
2. PROBLEM DEFINITION...................................................................................................................10
2.1. What is the problem? .................................................................................................................10
2.2. What are the problem drivers?...................................................................................................13
2.3. How will the problem evolve?...................................................................................................20
3. WHY SHOULD THE EU ACT?.........................................................................................................21
3.1. Legal basis .................................................................................................................................21
3.2. Subsidiarity: necessity of EU action ..........................................................................................21
3.3. Subsidiarity: added value of EU action......................................................................................22
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?................................................................................23
4.1. General objectives......................................................................................................................23
4.2. Specific objectives .....................................................................................................................23
5. WHAT ARE THE AVAILABLE POLICY OPTIONS?.....................................................................25
5.1. What is the baseline from which options are assessed (option 0)? ............................................25
5.2. Design of policy options ............................................................................................................28
5.3. Description of policy measures and options ..............................................................................30
5.4. Overview of main differences between the harmonisation solutions.........................................44
5.5. Discarded policy options............................................................................................................46
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ...........................................................47
6.1. Economic impacts......................................................................................................................47
6.2. SME impacts..............................................................................................................................54
6.3. Social impacts............................................................................................................................55
6.4. Environmental impacts ..............................................................................................................56
6.5. Other impacts.............................................................................................................................57
7. HOW DO THE OPTIONS COMPARE? ............................................................................................58
7.1. Stakeholder preferences.............................................................................................................58
7.2. Effectiveness..............................................................................................................................59
7.3. Cost-efficiency...........................................................................................................................60
7.4. Coherence ..................................................................................................................................61
7.5. Proportionality ...........................................................................................................................62
7.6. Summary: comparison of options ..............................................................................................62
8. PREFERRED OPTION.......................................................................................................................64
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9. REFIT (SIMPLIFICATION AND IMPROVED EFFICIENCY) .......................................................64
10. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?..................................65
3
List of Annexes
Annex 1: Procedural information 61
Annex 2: Stakeholder consultation 68
Annex 3: Who is affected and how? 79
Annex 4: Analytical methods 81
Annex 5: Reporting Formalities Directive 101
Annex 6: Policy options 104
Annex 7: Connected policy areas 112
Annex 8: Trade and economic patterns 118
4
Glossary
Term or acronym Meaning or definition
Back-end entities The authorities and IT systems receiving data via the National
Single Windows
DEM Data Exchange Mechanism
ECSA European Community Shipowners’ Association
EMSA European Maritime Safety Agency
EMSWe European Maritime Single Window Environment
ESPO European Sea Ports Organisation
ENS Entry Summary Declaration
EU European Union
FAL Convention on Facilitation of International Maritime Traffic
Front end users The shipping operators providing data into the National Single
Window in connection to a port call
ICT Information and Communication Technologies
IMO International Maritime Organisation
IPCSA International Port Community Systems Association
ISC Inter-Service Consultation
MOVE Directorate General for Mobility and Transport
NSW National Single Window
PCS Port Community System - an electronic platform connecting the
systems operated by the organisations and entities making up a
seaport community. The Port Community System facilitates
exchange of operational or administrative information between
different actors in the port; it can also include systems for
optimisation of processes (e.g. “smart port” systems). The PCS can
be operated and maintained either by a public, private or
public/private organisation.
RFD Directive 2010/65/EU on Reporting Formalities for ships
Shipping operator Subject to specific reporting requirements set in the EU legal acts
and international agreements, the operator may be a shipping
company, a ship master or the representative of the shipping
company/ship master
SSN SafeSeaNet
SSS Short Sea Shipping
VTMIS Vessel Traffic and Monitoring Information System
WCO World Customs Organisation
5
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT
Maritime transport operators face a wide range of reporting obligations every time a ship calls
a port. Since the adoption of the Reporting Formalities Directive (RFD)1
in 2010 within the
context of the European maritime transport space without barriers2
, some of this reporting is
channelled via National Single Windows. The purpose of the RFD was to harmonise and
simplify the administrative procedures for shipping operators, thus improving the efficiency
and competitiveness of intra-EU maritime transport. The National Single Windows should
give shipping operators the benefit of simplified reporting, more efficient clearance and
thereby shorter release times for faster turnaround in ports.
An evaluation of the RFD performed as part of the fitness check of the EU maritime transport
policy in 2016-20173
, found that these objectives have not been reached, although they remain
highly relevant. Ultimately, the current RFD has been found ineffective: it does not provide
the tools, incentives or requirements to achieve EU-wide harmonisation of reporting. The
voluntary nature of the measures has also proven insufficient. Further, the provisions of the
RFD are too vague to be supportive of improvements, as it does not have mechanisms for
updating the framework to address these shortcomings in either delegated or implementing
procedures. The problem analysis has been confirmed in consultations with the shipping
industry and Member States. This impact assessment therefore assesses several options for
improving the situation and for creating a more effective and efficient reporting environment
to facilitate maritime transport and trade.
1.1. Background: the Reporting Formalities Directive
The RFD was intended as a tool to establish a simplified reporting environment for ships by
asking Member States to provide a single reporting entry point for a number of reporting
formalities for ships.
The RFD did not introduce any new reporting obligations for shipping but aimed at reducing
administrative burden deriving from EU legal acts or from international legislation:
 by simplifying and rationalising information requirements set in different legal acts;
1
Directive 2010/65/EU on reporting formalities for ships arriving in and/or departing from ports of the Member
States (RFD), 20 October 2010, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32010L0065;
Replacing at that time Directive 2002/6/EC
2
European Commission, Communication and action plan with a view to establishing a European maritime
transport space without barriers, 21 January 2009, COM(2009)10 final, http://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=COM:2009:0010:FIN
3
European Commission Staff Working Document: Evaluation of Directive 2010/65/EU on reporting formalities
for ships arriving in and/or departing from ports of the Member States, 2018 (referred to hereafter as
Evaluation of the RFD)
6
 by replacing paper submissions with harmonised digital submissions; and
 by harmonising reporting on national level and establishing a single entry point for
multiple formalities, the National Single Windows.
The RFD is not concerned with the processing or content of the reported data; only with
streamlined reporting procedures and formats for the data requested from ships by the
underlying legal acts4
. The data sets under the RFD scope are defined by the basic acts
referred to in the RFD annex.
The National Single Windows could be organised in different ways: e.g. centrally in the
Member State or in a distributed system of National Single Window entry points. The
National Single Windows channel the data submitted by the data providers (shipping
operators) to the back-end data recipients (connected authorities and systems requiring these
formalities). The National Single Windows thus perform two bundles of functionality: a) data
collection from data providers, i.e. the functionality associated with receiving and validating
the reported data set and sending back responses (reporting gateway); and b) data
distribution to the authorities, i.e. the functionality associated with rearranging the
information into specific data sets, sending them to the relevant authorities, and taking care of
any related message exchanges.
The RFD states that the same information (static data or data already reported and unchanged)
should have to be reported by the shipping operator only once. The RFD also calls for
coordinated and harmonised reporting at EU-level5
. The deadline for Member States to apply
the new reporting regime was 1 June 20156
. Among the main achievements of the RFD are
the largely completed digitalisation of reporting and the connection of a number of data
recipient authorities to the National Single Windows, creating a shared national entry point
for certain ship reporting.
However, the current RFD does not provide any binding specifications for the interfaces, data
formats or reporting procedures for the National Single Windows. The consequence is that
each Member State has developed a unique technical interface for reporting. There is no
harmonised front-end (reporting interface/entry point) towards the shipping operators. In
addition, much reporting is still requested via other channels. This is further discussed in the
Problem description below.
More information about the current ship reporting environment is found in Annex 5.
4
EU and international legislation referred to in RFD Annex
5
RFD, Article 3.2
6
RFD, Article 5.1
7
1.2. Legal context
Maritime transport is subject to complex administrative procedures even if vessels sail only
between EU ports (intra-EU maritime transport) and the cargo consists only of goods in free
circulation ("Union goods"). These procedures involve a wide set of international and EU
legislation on transport safety and security, environment protection, customs, veterinary and
plant-protection, and national and local formalities for vessels arriving in or departing from
ports.
The RFD complements other EU legislation by providing a tool for streamlined reporting
from shipping operators to data recipients (authorities). The directive covers a set of 14
digitalised reporting formalities resulting from international agreements and EU legal acts on
vessel traffic and monitoring information and on transport of dangerous goods7
, on
registration of persons sailing on board passenger ships8
, on the Schengen Border Code9
, on
management of waste and cargo residues10
, on ship and port security11
, and on the Union
Customs Code12
.
The RFD also builds on the international level legislation and notably the International
Maritime Organisation (IMO) framework for international ship reporting formalities. The
IMO FAL Convention13
sets out some internationally agreed reporting formalities for ships.
The RFD provides the European framework for electronic reporting according to these
standards. The IMO however does not establish standards for all ship reporting formalities,
nor does the international framework provide any guidance for simplified, digital reporting
procedures and interfaces.
1.3. Policy context
The RFD is part of the EU maritime transport policy, contributing to the overall Commission
transport policy goal of completing the internal market for transport by removing remaining
7
Directive 2002/59/EC of the European Parliament and of the Council of 27 June 2002 establishing a
Community vessel traffic monitoring and information system (OJ L 208, 5.8.2002, p. 10)
8
Council Directive 98/41/EC of 18 June 1998 on the registration of persons sailing on board passenger ships
operating to or from ports of the Member States of the Community
9
Regulation (EC) No 562/2006 of the European Parliament and of the Council of 15 March 2006 establishing a
Community Code on the rules governing the movement of persons across borders (Schengen Borders Code)
(OJ L 105, 13.4.2006, p. 1)
10
Directive 2000/59/EC of the European Parliament and of the Council of 27 November 2000 on port reception
facilities for ship-generated waste and cargo residues (OJ L 332, 28.12.2000, p. 81)
11
Regulation (EC) No 725/2004 of the European Parliament and of the Council of 31 March 2004 on enhancing
ship and port facility security (OJ L 129, 29.4.2004, p. 6)
12
Regulation (EU) No 952/2013 of 9 October 2013 laying down the Union Customs Code (OJ L 269, 10. 10.
2013) (only part of customs formalities currently covered by the RFD scope)
13
International Maritime Organisation, Convention on Facilitation of International Maritime Traffic (FAL),
adopted 9 April 1965
8
bottlenecks, barriers and administrative burden14
. It supports the Commission priorities of a
deeper and fairer internal market and the digital single market and indirectly contributes to
the priority of jobs, growth and investments.
The objectives of the European maritime transport space without barrier15
, of harmonising
and simplifying administrative procedures remain highly relevant for EU policy. This was
confirmed by the European Council in its Valletta declaration on the EU's maritime policy16
and its conclusions on 8 June 201717
on the priorities for the EU's maritime transport policy
until 2020, both underlining the need to reduce administrative burden for maritime transport
by ensuring simplified and digitalised reporting procedures for ships and inviting the
Commission to introduce measures for EU-level harmonisation of the reporting environment.
The Council repeated this request again in its conclusions on digitalisation of transport on 8
December, 201718
.
The industry and maritime transport stakeholders also support the need to reduce the
administrative burden through harmonisation. In a joint statement on 1 March 201719
, ten EU
industry associations called for a "a true European single window environment for maritime
carriers that fully ensures the ‘reporting once’ principle and which shares all necessary cargo
and conveyance data between governments and all relevant authorities". More recent
statements e.g. by the European Community Shipowners’ Association have echoed this same
position20
. A submission to the REFIT platform was done by Finland, as a survey amongst
Finnish public administration, business and stakeholders identified the RFD as an example of
EU legislation raising particular concerns.21
The proposal for a revised legal framework for
reporting formalities is part of the Commission’s third mobility package, together with,
among others, a proposal for a regulation on electronic freight transport information. These
14
European Commission, White paper: Roadmap to a Single European Transport Area, COM(2011) 144 final,
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0144&from=EN
15
Communication and action plan with a view to establishing a European maritime transport space without
barriers, COM(2009)10 final
16
Valletta Declaration: Priorities for the EU's Maritime Transport Policy until 2020: Competitiveness,
Decarbonisation, Digitalisation to ensure global connectivity, and efficient internal market and a world-
class maritime cluster, Valletta, 29 March 2017,
https://www.eu2017.mt/en/Documents/Valletta_Declaration_on_the_EU_maritime_transport_policy.pdf
17
Council conclusions on Priorities for the EU's maritime transport policy until 2020: Competitiveness,
Decarbonisation, Digitalisation to ensure global connectivity, an efficient internal market and a world-class
maritime cluster, adopted by the Council at its 3545th meeting held on 8 June 2017,
http://data.consilium.europa.eu/doc/document/ST-9976-2017-INIT/en/pdf
18
Council conclusions on the digitalisation of transport, adopted by the Council at its 3581st meeting held on 5
December 2017 http://data.consilium.europa.eu/doc/document/ST-15431-2017-INIT/en/pdf
19
Joint industry statement, 1 March 2017, https://www.europeanshippingweek.com/joint-industry-statement-
clia-europe-eba-ecasba-ecsa-empa-eta-etf-euda-interferry-wsc/
20
European Community Shipowners’ Association, Newsletter 22 December 2017: A single market for shipping
– time to make it happen, http://www.ecsa.eu/news/single-market-shipping-time-make-it-happen
21
https://ec.europa.eu/info/sites/info/files/mobility_and_transport_1.pdf
9
two initiatives share the same main objective, which is to facilitate the communication of
regulatory information to authorities in electronic format, but differ in various respects. Such
differences and similarities are further outlined below.
The information concerned by the two initiatives has its source in different international, EU
and Member States legal acts. These legal acts do not overlap between the two initiatives and
the information sets are different. For example, the information required for fulfilling
maritime reporting formalities includes cargo description, alongside a wide range of other
information elements on the ship, its crew and passengers. The information requirements
under the scope of the initiative on electronic freight transport information, while also
containing elements of cargo description, are focused primarily on the transport operation
itself – on the identity of the consignor, carrier and consignee, places of pick-up and delivery,
route and several others. However, the two initiatives will ensure the interoperability of the
electronic data concerned, concretely, by prescribing the same data model and syntax for the
common data elements.
Geographically, the scope of the electronic transport document initiative begins where the
maritime reporting environment initiative ends. The initiative on electronic freight transport
information concerns the transport of goods within the EU once these have been cleared for
entry in the Union, following the process of maritime and customs reporting formalities. The
proposal on freight transport information will allow the use of electronic documentation not
just at the point of entry and exit of the EU – where it is already mandatory – but also in the
following (or preceding, in case of export) phase of inland transport. Together, they will
ensure appropriate coverage of information, for the entire travelling span of whatever the
freight concerned.
In terms of technical solutions envisaged, the two initiatives require however a different
approach. This is because in the case of reporting formalities in ports, information must be
submitted at a specific point in time to a pre-defined set of authorities; in the other case
(electronic freight transport documents), information only needs to be available in case it is
required for inspection. The two initiatives are therefore complementary and mutually
reinforcing.
The proposal for a revised legal framework for reporting formalities follows on the Fitness
check of the Maritime Transport Policy initiated in 2016 under the Commission REFIT
programme, which found the RFD framework inefficient and ineffective. The new proposal
will be aligned with and supportive of the implementation of the Union Customs Code and its
connected customs IT systems.
More details on connected policy areas is found in Annex 7
1.4. Economic and trade context
Maritime transport is a backbone of trade and communications within and beyond the single
market. Almost one third of all intra-EU and three quarters of the internationally traded goods
(in tonnes) are seaborne. In terms of value, about half of EU international trade in goods is
transported by sea.
10
The number of port calls by passenger or freight vessels in main EU-28 ports in 2016 was
estimated at almost 2.1 million. Each year, around 400 million passengers embark and
disembark at EU ports. Sea transport turnover was EUR 106 billion in total for EU28 in
2014.22
There are around 11 000 maritime transport enterprises in the EU28 and around 178 000
people directly employed in the maritime transport sector23
, with another 1.5 million jobs in
EU ports24
, indirectly linked to the sea-borne trade and transport.
Furthermore, the smooth functioning of port calls is one link in a longer transport chain. Ports
are not the final destination of goods. The efficiency of the ship port calls, as affected e.g. by
the efficiency of the reporting environment, will impact on the entire logistics chain and the
hinterland transports of goods and passengers to and from the ports, notably by rail, road,
inland waterways or pipelines.
More details on the economic context can be found in Annex 8.
2. PROBLEM DEFINITION
2.1. What is the problem?
This initiative addresses the problem of the current inefficient port call reporting environment
for maritime transport operators (legal reporting requirements for when a ship is to arrive in or
depart from a port – a port call).
Vessels in international traffic (generally larger vessels, shipping around 63% of all
transported goods and 6% of the passengers going into or out of EU ports25
) are subject to
both customs and maritime transport formalities. They need to submit a series of declarations
and notifications at different points in time, starting with the Entry Summary Declaration
(ENS) with cargo-related information, normally submitted even before departure from the
third country port. Approaching the port call, they must also submit information and data
relating to border controls, environmental controls, safety/security and traffic management.
Some of these data elements are requested following legal requirements in EU or international
law, other reporting is requested based on national legislation. Via the port reporting the ships
may also arrange various port services such as pilotage and logistics for goods management
(reporting not based on legislative requirements).
22
European Commission, Statistical pocketbook 2017: EU transport in figures,
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en
23
Statistical pocketbook 2017: EU transport in figures
24
https://ec.europa.eu/transport/modes/maritime/ports/ports_en
25
Eurostat, Maritime ports freight and passenger statistics, January 2017
11
Vessels in intra-EU traffic ship around 25% of all goods and 33% of the passengers to or from
EU ports. They too may have to complete customs formalities: if they have left EU territorial
waters (twelve nautical miles from the coast), if they carry non-EU goods or if they sail under
a non-EU flag. They must also complete most of the maritime transport reporting formalities
required for the international traffic vessels as described above, with possible exemptions
from e.g. border controls within the Schengen zone.
For vessels in national traffic (shipping 9% of the transported goods and 57% of all
passengers to or from EU ports) there are normally less customs formalities applying, unless
the vessel meets one of the criteria mentioned above (non-EU flag, departing from EU
territorial waters or carrying non-EU goods). The border control reporting normally does not
apply. Other maritime transport reporting formalities and port service information
submissions must usually be completed.
Some of the underlying legal acts to the RFD also have exemptions for vessels depending on
their size, e.g. the Vessel Traffic Monitoring and Information System which does not apply to
ships of less than 300 gross tonnage. There are also exemptions and simplifications for some
vessels in regular services calling exclusively in intra-EU and/or national ports (e.g. ferries,
cargo or cruise ships operating on a fixed route).
The current RFD makes it mandatory for Member States to request the maritime reporting
based on certain EU and international legislation via the National Single Windows. The
national reporting requirements may also be channelled via the National Single Window while
the large majority of customs formalities are done via separate IT systems.
Some shipping companies prefer to do their port call reporting via automated machine-to-
machine reporting if available in the port they call. This is especially common among the
large shipping operators. Other shipping companies prefer reporting via graphic user
interfaces and uploading information using spreadsheet files, if available in the port they call.
Many companies also use ship agents to deal with the reporting formalities and/or cargo
agents to deal with the customs formalities.
The use of ship and/or cargo agents is often needed because of the diverging reporting
systems in each Member State and in some cases in each port.
The current legislative framework was evaluated in 201726
. The evaluation concluded that the
RFD is inadequately effective and efficient, in spite of the objectives remaining highly
relevant and valid. The evaluation concluded that there is potential for further simplification
and burden reduction in this area. This is also the strong messages repeatedly sent by
stakeholders, calling for measures to urgently address the situation.
26
Part of the Fitness check of the Maritime Transport Policy (initiative under the Commission Work Programme
(REFIT) for 2016)
12
The main barrier emphasised by the shipping operators and stressed in the evaluation, is the
lack of harmonisation of the maritime National Single Windows and the overall lack of EU-
level harmonisation of all reporting required by a carrier calling a port27
. Today, each National
Single Window looks different. Data formats are different, reporting procedures are different
and the scope of reporting through each National Single Window differs. Some Member
States accept machine-to-machine reporting, others provide graphic user interface and accepts
uploading of spreadsheets (or receives spreadsheets per e-mail). Some Member States allow
reporting via port community systems into the National Single Windows or have delegated
National Single Window functions to each port (decentralised system). The shipping operators
thus have to adjust their reporting and their IT software and data sets for each Member State –
or even for every individual port they call.
The non-harmonised reporting environment makes reporting a very burdensome and time-
consuming task for shipping operators. Indeed, the current legal act provides no guidance or
binding specifications to guarantee the development of common data models, front-end
interface or reporting procedures for shipping operators.
The consequence is an unnecessary high administrative burden on shipping operators. The
majority of the shipping companies replying to the open public consultation on the evaluation
considered that administrative burden was reduced either not at all (61% of all shipping
companies and ship-owners’ associations) or only to a limited extent by the adoption of the
RFD. According to more than half of all responding shipping operators, the burden has in fact
increased rather than decreased28
, as an effect of the old reporting requests via separate entry
points often remaining in place in parallel to the new National Single Windows.
For the national authorities and port operators, this is not a major problem. From the view of
an individual port, the information exchange with ships is normally perceived as smoothly
functioning. From the side of shipping companies and maritime transport operators however,
as they call to different ports, the multitude of different and sometimes
duplicating/overlapping reporting requests becomes a burden. This is the message repeatedly
sent from shipping companies and their EU-level associations.
Every year, more than 2 million port calls are made in the EU. For these port calls, the
maritime transport operators are obliged to submit a large set of information. The evaluation
found that on average, the time spent on reporting for one single port call ranges between one
and three hours. This translates into around 4.6 million staff hours spent on reporting per year
for all EU port calls. The large majority (90%) of all stakeholders consulted for the evaluation
27
There is however EU-level harmonisation of data requirements within respective sectors, e.g. the harmonised
customs data requirements following the implementation of the Union Customs Code legislative package,
Regulation (EU) No 952/2013 of 9 October 2013 laying down the Union Customs Code (OJ L 269, 10. 10.
2013).
28
55% of shipping company respondents: Evaluation of the RFD
13
and the impact assessment consider that this time spent on reporting could be substantially
further reduced by harmonisation and simplification of the reporting environment.
As a consequence of the unnecessary administrative burden facing the shipping operators,
maritime transport is less competitive than other transport modes. Moreover, the
attractiveness of the profession is reduced and has been reported as an important cause for
employee dissatisfaction in the sector29
. The lack of harmonisation of maritime transport
reporting creates an obstacle to an efficient and optimised movement of ships and cargo and
thereby hampers the smooth functioning of the internal market. In the wider perspective, this
mismatch of administrative proceedings and their low efficiency affects the whole EU logistic
chain, beyond maritime transport (multimodal transport links; rail, road and inland waterway),
since the overly burdensome administration of reporting results in less efficient logistic
planning and increased lag time in ports.
The issue is of relevance primarily for the maritime Member States30
and their authorities
linked to the maritime National Single Windows; for the maritime transport operators; and for
all stakeholders involved in and around port operations and port management. The problems
impact in first hand on the maritime transport sector and the shipping operators. See also
detailed table in Annex 6.
2.2. What are the problem drivers?
The evaluation identified the following drivers:
Figure 1: Problem tree
P1. Diverse ship reporting formats, interfaces and procedures used throughout
the EU
29
Targeted consultations for the Impact Assessment
30
Austria, Czech Republic, Hungary, Luxembourg and Slovakia as non-maritime states are not directly affected
by the directive.
14
The RFD did not introduce binding technical specifications for electronic interfaces, but left
the implementation of the National Single Windows to Member States. According to the
Directive, the Commission should develop mechanisms for the harmonisation and
coordination of reporting formalities within the Union, together with the Member States31
.
This was done: an expert group on maritime administrative simplification and electronic
information services (the eMS group32
) developed some definitions, business rules and
guidelines33
and a standard data set34
in 2015. The European Maritime Safety Agency
(EMSA) also developed a prototype of a National Single Window and the results are
transparently shared and made available, including user manuals and templates. These
guidelines and support activities have however not proved very effective. They are not
binding, nor very detailed; the guidelines have not hindered fragmented implementation of
different National Single Window set-ups at Member State level. Furthermore, the RFD has
no mechanisms to continuously develop and improve provisions for harmonisation and no
tools for update of the legal framework in step with technical or political developments (e.g. a
governance system, delegated/implementing acts35
).
The absence of binding common standards has led to the introduction of reporting interfaces
which are technically different for practically each port call36
. Data sets and reporting formats
differ, sometimes even within a Member State. Data models and interfaces are not aligned
even between Member States who participated in coordination projects such as AnNa37
. The
European shipping industry association ECSA concludes on the reporting formats
encountered by their members: “These are not only complex and repetitive, but even worse,
they are completely unharmonised throughout the EU”.38
The non-harmonisation is especially
burdensome for vessels calling into several EU ports (as compared to vessels in national
traffic or going in liner traffic between the same two ports – although those vessels are also
affected by inefficiencies and duplication of reporting beyond the non-harmonisation issue).
The non-harmonisation is in particular an issue for vessels in tramp/non-fixed routes traffic,
calling always into different ports. Tramp traffic vessels make up around 60% of all port calls,
with around 40% of all port calls being by vessels in liner traffic.
31
RFD, Article 3:2
32
http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=2593
33
National Single Window Guidelines, 17 April 2015,
https://ec.europa.eu/transport/sites/transport/files/modes/maritime/doc/2015-06-11-nswguidelines-final.pdf
34
eMS Data Mapping Report, 25 February 2015,
https://ec.europa.eu/transport/sites/transport/files/data_mapping_report_2010_65_eu_0.pdf
35
RFD, Article 10: possibility only to adopt delegated acts for the update of the Annex related to the FAL forms
under IMO.
36
Evaluation of the RFD, p.16
37
http://www.annamsw.eu/about.html
38
European Community Shipowners’ Association: A single market for shipping – time to make it happen
15
Furthermore, there are many different channels or interfaces with which the maritime
operators need to adapt their systems in order to provide all information required for a port
call. For one port call, they might have to send data through National Single Windows in
XML, through a port community system in EDIFACT and use a third format or data model
for national customs system. This creates an expensive technical environment to maintain.
This is not a matter of harmonisation of data formats; with the introduction of the new Union
Customs Code legislative package, customs reporting formalities have already undergone a
process of harmonisation at EU level. However, since the harmonised customs formalities are
requested in a separate reporting channel from the maritime reporting formalities, shipping
operators state that the total time spent on reporting for them is affected negatively (see
further information below in chapter on impacts of options).
The existence of several additional reporting entry points in parallel to the National Single
Window limits the actual harmonisation of reporting. It reduces the added value of the
National Single Window for the industry, who is faced with multiple reporting channels
simultaneously.
The situation of non-harmonisation is highly unlikely to be solved only by full
implementation of the current Directive. The RFD lacks the instruments for achieving
harmonisation: crucially, it lacks the possibility of adopting binding specifications. When
asked in the consultations, no single Member State replied that they intend to change current
systems towards harmonisation on the basis of the voluntary guidelines.
In such context, full compliance of Member States with the requirements of the existing
Directive might consolidate a situation of nationally harmonised but EU differentiated
reporting systems, which might render even more difficult a further evolution towards a single
EU approach, as demanded by the industry.
P2. Diverse ship reporting requirements throughout the EU
Currently, the RFD reporting rules only concern some of the formalities envisaged by EU
legislation and international maritime agreements. National requirements are only reported via
the National Single Window on voluntary basis while some EU formalities, e.g. related to
customs aspects, are only partially included. Currently, some 230 data elements fall under the
14 formalities for mandatory RFD reporting (RFD Annex 1, part A: EU legislation and B:
international obligations). This includes the core maritime transport reporting elements for
e.g. safety, security, traffic management, border controls and waste control (environmental
objectives), as well as the seven standardised IMO forms39
relating to e.g. dangerous goods,
crew and passenger lists and the general and cargo declarations. The data reported via the
39
The so called “FAL forms”,
http://www.imo.org/en/OurWork/Facilitation/FormsCertificates/Pages/Default.aspx
16
National Single Windows thus serve several purposes and covers a broad spectrum of policy
areas.
However, in addition to these EU and international reporting obligations, ships are obliged to
send many additional information elements when calling a port. A large part of the reporting
burden comes from the non-harmonised national reporting requirements that are not
mandatorily channelled via the National Single Windows. These requirements also differ
from Member State to Member State. A Member State sub-group40
, together with the
Commission services, is currently mapping the additional data elements derived from national
legislation (RFD Annex 1, part C), estimated to make up at least 200 additional data elements.
Moreover, maritime operators must provide transport-related information required for
statistical purposes41
.
In addition, data related to the ships’ cargo are required, primarily by customs authorities but
also by maritime transport authorities. This data has recently been mapped by the so called
eManifest pilot project. The project has identified a cargo data set of another 150 data
elements possibly required for the fulfilment of customs formalities42
related to the
arrival/departure of a ship from/to an EU port43
. The list of customs formalities/functionalities
requiring this information includes: Entry Summary Declaration, Arrival Notification,
Presentation Notification, Declaration for Temporary Storage, Customs Goods Manifest,
Electronic Transport Document for simplified transit, Re-Export Notification, Export
Summary Declaration, and Exit Notification for Export. These customs formalities are
currently not channelled via the National Single Windows but mainly through customs IT
systems (national or upcoming EU-level systems). Customs authorities are currently
establishing a harmonised data set under the implementation of the Union Customs Code44
and an EU-level single access point (the ICS2 shared trader interface for the Entry Summary
Declaration) is being developed.
All data elements listed above have already been mapped out by the Commission in
cooperation with EMSA and Member States in a single data set, providing an overview of all
data that may be requested from ships in EU port under the current RFD scope and beyond.
40
“Correspondence group on Part C data” under the Single Window subgroup to the High-level Steering Group
for Governance of the Digital Maritime System and Services
41
Directive 2009/42/EC
42
The exact number of data elements required will depend on the formalities the ship has to fulfil which in turn
depends on the previous port and on the nature of goods (union or non-union).
43
Reported by the carrier or other persons identified by the Union Customs Code as responsible for completion
of customs formalities It should be noted that the cargo-related data elements must be reported for each
consignment/item and could thus amount to a huge reporting load, especially for container ships and general
cargo ships with a multitude of different consignments on-board.
44
Customs formalities are harmonised via the implementation of the Union Customs Code legislative package.
17
Finally, another aspect which presents a smaller problem: today, paper copies of a set of at
least 100 ship certificates such as Certificate of Registry and Certificate of Class are kept on-
board ships to provide proof that the vessels are compliant with various regulations and
conventions. The management and keeping of paper certificates is often seen as an
administrative burden and an area where digitalisation could bring further benefits. Paper
certificates are also exposed to forgery and fraud which could be avoided with digitalisation,
provided that relevant cyber-security measures are introduced.
Bringing in a more comprehensive data set into the coordinated and harmonised reporting
environment would require changes to the RFD. The current legal framework does not have
the update mechanisms to allow a broadening of the data set.
More detailed information on the data elements within and beyond the current scope of RFD
can be found in Annex 5.
P3. Unclear legal framework for sharing and using reporting information
Today, data flows are suboptimal and duplicate reporting takes place because of lack of data
sharing between authorities.
The data provider – e.g. the carrier or the agent appointed as their representative for these
purposes – today submits through the National Single Windows a set of data including both
static and dynamic data. The static data can be broken down into two subcategories:
permanent static and temporarily static data elements. Information which does not commonly
change (identification and particulars such as tonnage) is considered permanent static. The
information which does not usually change between the departure and arrival ports, such as
crew and passenger lists, or hazardous cargo information, is considered temporarily static
information. The dynamic information, such as waste on board, cargo or estimated arrival
time, is the one that changes regularly.
There are two main aspects of reporting the same data only once. First, there is the issue of
the same data often being requested several times within the same port call. Respondents in
the consultations (in particular shipping companies and ship agents) stressed that multiple
reporting is a fact. In some ports (28% of respondents even claim: in most ports), maritime
operators are required to report the same information (static and dynamic) separately to
different authorities when calling a port.45
Sometimes the reason is vertical silos: the
authorities act independently without coordination. Sometimes there is a horizontal issue
where central authorities fail to share data with local ones. This means that many Member
States and ports still have an inefficient data sharing environment where reported data is not
sufficiently channelled to all relevant data recipients. Reporting only once within the same
port supports efficiency of reporting but also to some extent contributes to burden reduction
45
Evaluation of the RFD, p.36
18
for the shipping operator by minimising duplication of work, as described in the Commission
Study on eGovernment and the Reduction of Administrative Burden by EY and DTI from
201446
. The reporting-only-once was an objective mentioned already in the current RFD but
not achieved; the poor implementation of the current provisions is at least partly a result of
unclear Directive provisions providing insufficient instructions.
The second aspect is the “reporting only once” enabling the re-use of static data from one port
call to another (also not sufficiently addressed in the current RFD). This is not taking place at
all today, except in a few pilot project cases of exchange services between ports with
connected systems. These pilot projects show that the re-use of unchanged data would in
principle be possible, assuming that data protection and data quality rules are respected
throughout the data exchange chain4748
. Lack of re-use of data between ports is a missed
opportunity for simplified reporting for shipping operators (e.g. enabling pre-filled forms or
transforming the departure form from one port into the arrival form for next port). This
especially makes some difference for smaller shipping operators reporting manually (via
graphic user interface) where any duplication in reporting obligations means some time lost. It
also increases the complexity of port calls for ships with small crews. In the consultations,
81% of all respondents expect to have some or high benefits from data re-use, with highest
focus on the need for data re-use among shipping operators and ship agents.
However, the reporting only once between ports is also about missed opportunities for the
wider chain of transport logistics. The current lack of data sharing between ports (within and
beyond a Member State) means that business potential for more efficient procedures for ports
and for authorities is untapped. Access to this information would in many cases be quicker for
these stakeholders by way of interconnecting the existing reporting systems rather than only
requiring all updates directly from the vessels.
It should also be noted that some information reported to the National Single Windows today
is already exchanged between the Member States through SafeSeaNet49
. However, the
Member States have reported that they do not use this data for reduction of reporting
duplications by ships, in spite of the possibility offered in the RFD50
.
46
https://ec.europa.eu/digital-single-market/en/news/final-report-study-egovernment-and-reduction-
administrative-burden-smart-20120061
47
See for example the IPCSA Network of Trusted Networks project with web service for exchange of port to port
exchange of data.
48
See also “The Once Only Principle” (TOOP) project within the EU eGovernment Action Plan 2016-2020. The
aim of TOOP is to ensure that information can be supplied to public administrations only once regardless of
the company's country of origin. This principle is promoted to eliminate unnecessary burdens for European
businesses by avoiding that they are asked to present the same data and documents repeatedly.
49
RFD: Article 6
50
RFD: Article 9
19
Re-use and efficient sharing of data within the context of the RFD is today hampered
primarily by unclear or missing specifications on data definitions and use/re-use. Authorities’
obligation to share data, even for the same port call, is not clearly enough specified. The
vague provisions of the RFD have therefore not supported the objective of moving towards
the “reporting only once”; this is a clear shortcoming of the current Directive.
Furthermore, recipients of cargo or ship information are reluctant to share data since the legal
framework – as regards aspects of data control, confidentiality, liability and access rights – is
perceived as unclear. The current RFD does not provide sufficient specifications and support
on this. For example, concerns regarding the interpretation of the General Data Protection
Regulation have been voiced in several of the consultation events51
, with data recipients
uncertain about how to deal with potentially sensitive personal data elements such as
passenger lists or crew personal data. Clear rules for accessing data are also missing,
according to consulted stakeholders52
.
This has an impact also on the information which is commonly considered as open data, such
as departure and arrival times which could be of value for efficiency gains throughout the
multimodal transport chain. There is today no uniform application on how this data should be
treated. Some Member States make it public but only locally through port information boards,
other share it via Internet. The inconsistent approaches reduce the possibility of using this data
for multimodal transport management.
These issues would not be solved by full implementation of the current Directive; the RFD
does not provide sufficiently clear provisions to achieve these objectives on its own and in its
current form.
P4. Inadequate implementation of current legislation
The unspecific definitions and provisions of the Directive have in turn also hampered
implementation and enforcement of the directive. The slow implementation of the RFD is not
the core problem for shipping operators (and full implementation would not solve problem
drivers 1-3, as described above), although it does contribute to the complexity of the reporting
environment.
It is telling that operational National Single Windows are still under implementation in eight
of the 23 maritime Member States. In addition, even where there are National Single
Windows implemented, there are not always national procedures, national technical standards,
or an actual single entry point for reporting. A likely reason for the diverse interpretations of
51
E.g. Report from consultation event with the HLSG expert sub-group meeting on Single Window, Brussels,
26th October 2017; Consultation synopsis report, Annex 2
52
Consultation workshop: Moving towards a European Maritime Single Window environment – what road to
take? Digital Transport Days, Tallinn, 8 November 2017; Consultation synopsis report, Annex 2
20
the current RFD is that the provisions are extremely vague, giving very little guidance or
direction to Member States, who could reasonably claim they are not in principle failing their
obligations.
Ultimately, Member States have not had sufficiently hard incentives to establish their national
single windows in a harmonised way. Considering that technical assistance and voluntary
guidelines have been offered but not widely applied, lack of resources, know-how or time are
not assessed to have been the main barriers to implementation. It seems rather to be the
absence of binding specifications and clear instructions causing the uncertainties.
Furthermore, the provisions have been too vague to support the Commission in pursuing
infringements or other follow-up procedures.
The effect of the slow and uneven implementation of the RFD was to create additional
differences between the reporting environments from one Member State to the next,
aggravating the core problems as described above under drivers 1-3.
2.3. How will the problem evolve?
The RFD does not provide binding technical specifications for harmonised reporting
interfaces or to include new or missing EU or national reporting obligations. The current
situation with diversity of reporting procedures, formats and interfaces is unlikely to change
in the future without EU level interventions53
.
The existing structures for exchange of best practices between the Member States54
have not
so far been effective for delivering harmonised implementation of the National Single
Windows. Guidelines have been developed in close cooperation with Member States and
technical assistance for implementation has been offered via EMSA. Quantitative estimates of
the impact of these initiatives, in particular the uptake effect of the EMSA prototype, are not
available but the Member States indicated in the consultations that no further changes to
current systems are planned as a result of these activities. For the shipping operators, the
administrative burden linked to lack of harmonised single entry point(s) and lack of
harmonisation of data requirements will therefore remain high: in total 50 million staff hours
53
At international level, the IMO application of Standard 1.3 bis to the FAL Convention should be in place by 8
April 2019, requiring all IMO member countries to establish systems for electronic exchange of information
by that date (Source:
http://www.imo.org/en/OurWork/Facilitation/Electronic%20Business/Pages/default.aspx). This will
however not affect EU Member States since this electronic reporting is already mandatory under the RFD
and the IMO Standard does not introduce any common technical requirements. The Commission has offered
to assist the IMO in developing a harmonised reference system by donating the National Single Window
prototype specifications and documentation to the IMO. However, no decision has been taken on their side
to pursue that development.
54
The High Level Steering Group on Governance of the Digital Maritime System and the eMS group
21
are estimated to be spent on reporting during the baseline period (EU28). In addition, new
challenges and issues will emerge, risking render the current legal framework out of date.
More information on how the situation is likely to evolve until 2030 can be found in section
5.1.
3. WHY SHOULD THE EU ACT?
3.1. Legal basis
Article 100 (2) of the Treaty stipulates that "The European Parliament and the Council, acting
in accordance with the ordinary legislative procedure, may lay down appropriate provisions
for sea and air transport."
3.2. Subsidiarity: Necessity of EU action
The legitimate rights of Member States to manage and develop their port reporting systems
must not unduly restrict the proper functioning of the internal transport market. Maritime
transport is to a large extent a single market concern; only 9% of the seaborne trade in the EU
is national, compared to 25% and 66% for respectively intra-EU trade and extra-EU trade.
Moreover, the ports are not the final destination of the goods and via the hinterland
connections a large part of the goods going through ports either comes from or continues to
another Member State. It is therefore in the interest of the Union to ensure the smooth
functioning of ship port calls, for the sake of the wider internal transport market and for the
considerable economic investments and cross-border business interests linked to the sector.
The problems addressed by this initiative – inefficient reporting environment for shipping
operators in connection to a port call, resulting in cumbersome administration for transport
operators – are unlikely to be solved sufficiently by Member States in the framework of their
national constitutional systems (necessity test) as the maritime transport is a highly
international sector. Policies developed and implemented on a national or sub-national level
are unlikely to produce solutions harmonised at the EU level (compare with successfully
harmonised customs formalities thanks to Union Customs Code EU-level legislative package)
and cannot efficiently address the cross-border information exchanges. Fragmented national
legislation and transport systems, often incompatible with each other, lead to a sub-optimal
situation as far as the Internal Market in maritime transport is concerned.
The inadequacy of voluntary harmonisation measures has also been clearly shown in the past.
The existing non-binding guidelines and the regular interaction between Member States have
not improved the situation and have not resulted in less fragmentation.
22
Stakeholders widely agree with this assessment, as expressed in the consultations where a
majority of respondents (74%) in the open public consultation stated that these issues should
be addressed on the EU level (87% of the shipping companies and ship masters; 69% of
responding Member States). 82.5% of the respondents believed that the actions should be
mandatory (97% of shipping companies and shipmasters; 67% of Member States). Most
respondents believed that only soft measures will have low effectiveness, and hence bring
very limited benefits.55
It could in principle also be considered to act on the matter primarily on the international level
and via the IMO. However, the IMO only works by voluntary implementation and non-
detailed specifications and has no mechanism for enforcement. While the IMO does address
some of the ship reporting aspects such as the reporting formalities specified under the FAL
Convention, the IMO does not address other of the policy areas covered by EU law56
. Action
only at international level will not bring added value for EU maritime transport operators with
regard to the reporting environment. On the contrary, it is usually the EU that pushes the
development of the IMO framework by being a forerunner in adopting more effective,
efficient and harmonised rules; going further than the lowest common denominator
agreements in the international forum. The harmonised reporting environment was not
achieved by voluntary action at EU-level and it is highly unlikely that better results could be
achieved by similar non-binding action via the international organisations.
3.3. Subsidiarity: Added value of EU action
The proposed action can be better achieved at Union level than at national level as substantial
results can only be achieved by a coherent framework addressing pan-European needs.
The development and implementation of common standards and facilities need to be
coordinated and aligned along with the other relevant EU and international initiatives and
technological developments as well as socioeconomic developments. This work would
normally primarily be done in the context of the underlying legal acts and the resulting data
requirement agreements subsequently taken up in the RFD framework for the coordination of
reporting. Such a framework permitting and ensuring the required connections and
complementarity with the various existing reporting systems as well as development towards
common data definitions can only be created at EU level. No international body provides an
alternative forum for creating the coordination mechanism for the comprehensive body of
ship reporting requirements under international, EU and national legislation.
55
Consultation synopsis report, Annex 2
56
The IMO reporting standards do not cover all specified requirements set in the EU law. For example, FAL 5
and 6: crew and passenger lists do not include the Schengen Border Code visa requirements and FAL 2:
Cargo declaration is missing the information required by the Union Customs Code on the Union status of
the goods.
23
The European Union is in a privileged position to offer leverage and propagate best practices
and common standards for harmonisation, to promote cross-border cooperation, and to
facilitate the establishment of a wide market for digitalised transport services.
The competition between ports is strong and the port community often protective of its
independence and individual competitive advantages. Only by acting at the EU level can the
level playing field and the European Maritime Transport Space without Barriers be ensured.
As is shown in the analysis of impacts below, action at EU level to achieve full harmonisation
could result in an administrative burden reduction of 50-75%57
of the staff hours currently lost
on overly cumbersome reporting procedures, with additional indirect benefits in terms of
possible faster turn-around time in ports, better logistics chain predictability, higher job
satisfaction among staff and gains in terms of more staff hours released for e.g. safety and
business related processes on-board.
In addition, the initiative offers potential for further contributing to the efficiency of the entire
Single Market multimodal transport chain by enhancing information flows and reducing
potential bottle-necks in connection to port calls. There are, in particular, opportunities for
added value in exploiting the data sharing aspects of the proposal to enable future cross-modal
information exchanges and by ensuring that the harmonised data formats support
interoperability across the transport modes.
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?
4.1. General objectives
The general objective of the initiative is to contribute to the smooth functioning of the single
market and facilitate trade and transport by addressing the currently cumbersome and diverse
reporting procedures for ships calling EU ports.
This means a well-functioning, harmonised and future-proof digital reporting environment
enabling interconnectivity and coordination of transport and customs related reporting, to
improve the efficiency, attractiveness and environmental sustainability of maritime transport
while contributing also to the integration of the sector to the digital multimodal logistics
chain.
4.2. Specific objectives
The initiative will contribute to the general objective by pursuing the following specific
objectives:
57
Depending mainly on traffic type: fixed route or non-fixed route transports, affecting average reporting times
and expected benefit of harmonisation. For more information on methodology, see Annex 4
24
 To harmonise reporting procedures, interfaces and data formats in order to
support the European Maritime Transport Space without Barriers. This objective
addresses the problem driver of diverse ship reporting procedures, interfaces and
formats.
 To reduce administrative burden in ship reporting by providing a single entry point,
thereby boosting efficiency, competitiveness, jobs and growth in maritime transport,
ports and in connected sectors along the entire logistics chain. This objective addresses
the problem driver of diverse ship reporting.
 To contribute to increased efficiency of digital reporting for maritime operators by
facilitating data sharing/reuse for the application of the “reporting only once”
principle. This will in turn contribute to the establishment of the Digital Single
Market by removing legal uncertainties in the digital maritime transport environment,
such as access to and transfer of open data, data liability, interoperability and
standards, while taking in account relevant legal frameworks such as the General Data
Protection Regulation (GDPR)58
and the Regulation on electronic identification and
trust services (eIDAS)59
. This objective addresses the problem driver of unclear legal
framework for data sharing.
 By adopting a clearer legal framework in line with the objectives above, with detailed
provisions and binding technical specifications, the main barriers to implementation of
the current RFD will be removed and the success rate of the new proposal is expected
to be substantially higher than for the RFD.
58
Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data
and on the free movement of such data (General Data Protection Regulation)
59
Regulation (EU) No 910/2014 on electronic identification and trust services for electronic transactions in the
internal market
25
Figure 2: Objectives
5. WHAT ARE THE AVAILABLE POLICY OPTIONS?
5.1. What is the baseline from which options are assessed (Option 0)?
Under this option the Commission would continue to rely on the existing framework, without
undertaking further action to address the weaknesses identified. Without EU level
harmonisation, the reporting burden from a non-harmonised reporting environment is
expected to remain unchanged. The baseline period has been set to 2020-2030, in line with
that of other initiatives of the 3rd
Mobility Package. There is no possibility of implementation
earlier than 2020; beyond 2030 technical developments are expected to substantially change
the overall reporting environment in unforeseeable ways.
The soft measures assumed to be continued in the baseline scenario (e.g. technical assistance,
voluntary guidelines) would not be effective on their own, as already proven by past
experience. In the consultations, Member States were asked whether they plan to develop
their existing systems towards a more harmonised format on the basis of the existing support
mechanisms from the EU.
In this respect, it is noteworthy that no single Member State replied that they planned any
such changes. Harmonisation is therefore not expected to take place in the baseline period
without additional EU action and the current problem are therefore unlikely to be solved in
this scenario. This includes exchanging and using data and information for reduction of
administrative burden and improving efficiency. Data re-use is expected to remain low due to
the continued legal uncertainties on rights to use and share the information and the lack of
clear mandatory obligation on Member States to enable such data re-use.
26
In the baseline scenario60
, the significant growth of the overall activity of the transport sector
including shipping is projected to continue, driven by global economic and trade growth.
These developments concern both passenger and freight transport with maritime freight
transport projected to grow at higher rates than passenger transport, following more closely
the GDP developments and the increasing demand for traded goods. International maritime
activity (including both intra-EU and extra-EU) would grow by more than 70% between 2010
and 2050 (1.4% per year). For the cruise sector, a steady growth has been reported during the
last decade and is expected to continue based on data from CLIA61
. In addition, a 50% growth
of cargo handled in EU ports is projected by 2030 according to a study of the European
Parliament62
. The modal share of maritime transport has remained fairly steady over time and
is not projected to change significantly by 2050.
The expected growth of trade and, subsequently, in volumes, is however not expected to
increase the number of port calls. The trend towards growing average ship size is likely to
continue, with large-capacity and large-scale ships being increasingly in demand, notably for
sake of economics of scale. This development will affect the total number of future port calls:
larger ships will be able to carry the increased volume of cargo; therefore, the number of port
calls will slightly decrease over time: by about 2% from 2020 to 2025 and by 1.3% from 2025
to the projected 2.02 million port calls in 2030. Growth of ship size is most visible in the
container segment, with an average ship size increase of about 5%63
, and in the cruise
segment, with an annual increase of about 4%.64
For other ship types, the size is projected to
remain relatively stable over time, in line with the historical developments. For authorities,
continued digitalisation of government services and systems, as monitored via the EU Digital
Economy and Society Index65
, is expected to continue, generating some benefits in terms of
efficiency and simplification for ship reporting. The adoption rate however commonly varies
with some Member States significantly more prone to quickly apply digital frameworks and
others lagging behind. EU level digitalisation initiatives such as on eDelivery66
for secure and
60
The baseline scenario used for this impact assessment draws on an update of the EU Reference scenario 2016
and has been developed with the PRIMES-TREMOVE model by the ICCS-E3MLab.
61
CLIA, 2017 State of the Cruise Industry outlook and Cruise Travel Trends Outlook,
https://www.cliaeurope.eu/index.php?option=com_content&view=article&id=102:clia-releases-2017-state-
of-the-cruise-industry-outlook-and-cruise-travel-trends-forecast&catid=8&Itemid=111
62
European Parliament; Directorate General for Internal Policies, Modal share of freight transports to and from
EU ports, 2015, p.38,
http://www.europarl.europa.eu/RegData/etudes/STUD/2015/540350/IPOL_STU(2015)540350_EN.pdf
63
Eurostat; UNCTAD shipping statistics; https://www.statista.com
64
ISL (2016), Shipping statistics and market review 2016, volume 60 - No. 8;
http://www.cruiseindustrynews.com/cruise-industry-analysis/orderbook-data.html
65
Digital Economy and Society Index 2017, https://ec.europa.eu/digital-single-market/en/desi
66
https://ec.europa.eu/cefdigital/wiki/display/CEFDIGITAL/eDelivery
27
reliable exchange of data and documents as well as Horizon 2020 Information and
Communication Technologies67
, may help push a more even implementation rate.
The average time estimated by shipping stakeholders in the current system is 1-3 hours per
port call.68
The wide range is explained by the very different reporting burden notably for
vessels in tramp traffic69
(60% of all port calls; mainly general cargo and bulk vessels of less
than 10 000GT) compared to fixed route traffic (40% of all port calls; mainly other types of
vessels and larger bulk vessels). These tramp /non-fixed route operators typically make port
calls in multiple ports and multiple Member States, facing a higher burden of non-harmonised
reporting (estimated average 3 hours per port call). Fixed route transport (e.g. ferries) and
large liner vessels typically call in same and few ports and have lower average reporting times
(estimated average 1 hour per port call). The non-fixed route operators typically run smaller
vessels but make up 60% of all the port calls and a very high share of the total time spent on
reporting in the EU.
When applying the more specific reporting time estimates for these different vessel and traffic
types, the resulting estimate is a total of 4.6 million hours spent currently on reporting per
year for all EU port calls. Despite the slight reduction in the total number of port calls over
time (see section 2.4), the number of hours spent for reporting is projected to remain high, at
4.4 million hours by 2030. For the entire baseline period 2020-2030 and for EU2870
, 50
million hours are estimated to be spent on reporting, equivalent to around EUR 1.5 billion
expressed as present value in 202071
.
The current National Single Windows cost on average 265 000 per Member State and year in
operational and maintenance costs. Taking into account the above presentation of projected
problem evolution, development of number of port calls and the time spent on reporting in
each port call, the baseline cost for the National Single Windows for EU28 over the entire
baseline period is estimated at EUR 108 million (for the detailed cost calculations, see
Annex 4).
The option of remaining at status quo also received very low support (7%) by all respondents
in the consultations.
67
Horizon 2020: Information and Communication Technologies,
https://ec.europa.eu/programmes/horizon2020/en/h2020-section/information-and-communication-
technologies
68
Depending primarily on type of traffic and vessel: fixed route/liner or non-fixed route/tramp traffic.
69
Non-fixed route traffic
70
Only actually impacting the maritime Member States in a EU28 scenario; all costs have also been calculated
for an alternative non-UK EU27 scenario, see chapter 6 and Annex 4.
71
Calculation based on a value of staff hour estimated at 38.35 € according to ECSA.
28
5.2. Design of policy options
A number of decisions were made as point of departure for identifying viable policy options.
These choices have been made as a result of the consultations and following discussions with
Commission and external experts. The purpose was to define at an early stage what solutions
would solve the problems identified, be realistic and sufficiently acceptable to the main
stakeholders.
1. In order to address the problem of inefficient reporting environment for ships, the main
options considered here are building on the already existing framework (National
Single Windows structure). This was a demand from Member States in the consultation
event in October 201772
. Options that would require an entirely different set-up have
therefore been discarded from consideration as it would be inefficient – and unacceptable
to a main stakeholder group – not to make use of the investments and efforts already
made. As mentioned in chapter 1, the National Single Windows perform two bundles of
functionality: data collection from the front-end users (shipping operators) and data
distribution to the back-end authorities (data recipients). The present initiative is
concerned with the harmonisation of the reporting gateways, but does not change the
connections to the back-end authorities beyond enabling more efficient data distribution
and data sharing.
2. The new and harmonised reporting gateway should be offered as a reporting path
always available for shipping operators and accepted by authorities, in line with the
strong request from the shipping industry and as a trade facilitation measure. This does
not mean that other reporting entry points must be banned, but only that if data providers
choose to use the EU-level harmonised maritime transport gateway to submit their
reporting formalities, data recipients must accept those submitted reports and refrain
from requesting additional and separate reporting.
There are two main reasons for not forcing the closure of all other reporting entry points
beyond the digital harmonised maritime reporting gateway. First, it would be highly
difficult to determine e.g. who should be included in the scope for reporting via this
harmonised reporting gateway for maritime transport and who may use e.g. the customs
IT systems directly. The maritime transport sector is highly heterogeneous and reporting
requirements differ: some report all of the data elements, some (e.g. small vessels or
operators on regular lines) have exemptions. Some split their data sets by having the
cargo data reported via cargo agents, other report everything together. There is no sharp
line between economic operators primarily affected by the maritime transport reporting,
those primarily managing the customs formalities, and those concerned with both. For
72
Consultation with the High Level Steering Group: Single Window Subgroup, 26 October 2018
29
those actors mostly working with the cargo issues, it will be easier to continue reporting
straight into the customs IT systems; this possibility must therefore remain for them.
Second, Member States may want to offer a national entry point for the vessels only
active in national traffic (9% of maritime freight transport). If they find this convenient
there is no reason for the Union to forbid such duplication. It may serve a purpose to give
SMEs in national traffic a more local reporting path, especially in the case of an EU-
level central gateway option. It is assumed that such national alternatives would
primarily be interesting in the short-term and as a transition period since, following the
consultations, it is clear that the great majority of shipping operators will prefer the
offered EU-harmonised option. For the possibility to report directly to the individual
back-end authorities and IT systems, this would not entail duplication of systems. A
decision to maintain alternative reporting systems in the National Single Windows will
rest entirely with the Member States.
3. The National Single Windows should remain a coordination mechanism, serving
primarily as a router (with technical converter between data formats where needed) to
pass two-way information between the maritime transport operators and the data
recipients (e.g. port authorities, customs interfaces and IT systems, border control
authorities, the SafeSeaNet, statistics authorities) with the aim to facilitate reporting for
the maritime industry. The harmonised reporting gateway will not process data beyond
data format translations/transformation, first data quality checking, certain (temporary)
data storage for technical purposes or other procedures necessary to smoothly link the
data from providers to recipients. All final processing will continue to be done by the
specialised systems of the connected data recipients. The reason for this assumption is
first, to avoid building new systems on top of the already functioning ones for the sake of
costs and proportionality, and second to avoid incoherence and interference with the
back-end systems where the data processing normally takes place. The objective of
adding the harmonised reporting gateway is not to change the functionalities that
National Single Windows and specialised systems already perform satisfactorily, but
only to ensure a simplified and harmonised front-end of reporting to reduce shipping
operators’ burden.
4. The initiative will not create new reporting requirements but will coordinate the
reporting between the data providers in the maritime transport sector and the data
recipients as specified in the underlying legal acts referred to in the revised legal act.
This may require translation of data formats in order to ensure a harmonised front end
reporting (from the maritime transport operators) as well as reporting output at the back-
end (to the connected entities and authorities receiving the data). Any reporting requests
via the harmonised reporting gateway shall fully respect the applicable technical
specifications of the underlying legal acts and IT systems supporting these underlying
legal acts (e.g. customs legislation, SafeSeaNet requirements specified in the VTMIS
Directive, etc.). This design principle follows on clear demands from both shipping
operators and Member States.
5. The new reporting environment must ensure clear and fair division of responsibility
and accountability for all connected entities, including guarantee of the National
30
Competent Authorities’73
full responsibility and liability for the intermediary
services of the National Single Windows vis-à-vis both the data providers and the
connected data recipients (e.g. functional and legal responsibility, high availability,
ensuring two-way flows of information, etc.). This is a logical point of departure for
enabling a comprehensive scope and the well-functioning interconnection of maritime
and customs reporting environments.
5.3. Description of policy measures and options
Taking into account the principles mentioned above and following the results of the
consultations with the relevant stakeholders, a number of possible measures were identified.
To address the first and the second driver, several possible mutually exclusive solutions have
been identified. In addition, some measures are necessary to ensure a proper and well-
functioning framework. These measures are common for all the options (complementary
measures).
Mutually exclusive measures (alternative)
Problem Driver 1: Diverse ship reporting formats, interfaces and procedures used throughout
the EU
No. Policy measures A-D
Alt. A Harmonised reporting gateways as front-end to the National Single Windows (NSWs):
based on binding technical specifications
Introduce binding harmonised requirements and technical specifications for the front-end
reporting gateway in the existing NSWs in the Member States. The specifications would
cover e.g. data content, message structure format, exchange protocols, user interface
requirements and other rules as necessary for ensuring the necessary information exchanges
business rules. They would be set at EU level but responsibility for implementation and
operation would be fully on the Member States. The result would be a decentralised system
of NSWs with identical reporting gateway functionalities for ship reporting.
Alt. B Harmonised reporting gateways as front-end to the National Single Windows (NSWs):
based on common IT solution
Develop a mandatory common harmonised reporting gateway/ front-end interface
component (IT solution) at EU level, for installation in every NSW. Regular updates as
required would be supplied via the EU. The operational responsibility would be on Member
States but with helpdesk functions for the software installation at EU level. The result would
be a decentralised system of identical reporting gateways in every Member State.
Alt. C Central European level reporting gateway: introduction of a centralised European
Maritime Single Window
Introduce a centralised, EU-level reporting gateway / front-end interface (European
Maritime Single Window). The centralised reporting gateway would offer one single
reporting entry point for all port calls throughout the EU including the necessary two-way
73
The Member State authority charged with hosting and operating the National Single Window
31
information exchanges between the data providers and the back-end connected entities and
systems. The NSWs would remain in place as the router between the centralised reporting
gateway and the national level data recipients. Member States would be responsible for
ensuring connection of their National Single Windows to the centralised gateway.
Alt. D Mandatory Port Community Systems (PCS) as basis for harmonised reporting
gateways in Member States (technical specifications)
Build the EU level harmonisation requirements and binding technical specifications on
mandatory PCS reporting gateways in the Member States (all other details same as in
alternative A above).
Problem Driver 2: Diverse ship reporting information requirements throughout the EU –
several parallel reporting entry points
No. Policy measure
Alt. 1 Comprehensive single entry point solution (introduction of a mandatory
comprehensive Maritime Single Window data set)
Set a wide scope for the reporting by ships in connection to a port call to be accepted via
the harmonised reporting environment: covering the current scope of RFD, the national
reporting requirements and channelling of customs formalities for ships into (and return
messages from) the customs IT systems at national and EU level.
Alt. 2 Separate entry points customs / maritime (introduction of a mandatory limited
Maritime Single Window data set)
Set a limited scope for the reporting by ships in connection to a port call to be accepted via
the harmonised reporting environment: covering the current scope of RFD and the national
reporting requirements. Customs formalities to be reported via the parallel and harmonised
customs IT systems.
Common/complementary set of measures (enabling framework)
Problem Driver 2: Diverse ship reporting information requirements throughout the EU –
several parallel reporting entry points
No. Policy measure
I Introduction of specifications for acceptance of e-certificates
Enable development of e-certificates acceptance by initiating processes for specifications
and technical solutions (e.g. common registries).
Problem Driver 3: Unclear legal framework for sharing and using reporting information – no
“reporting only once”
No. Policy measure
II Establishment of data re-use principles for “reporting only once”
A set of clear principles, rules and rights for data sharing and reuse will be developed to
ensure correct and smooth data management and “reporting only once” for carriers, as a
minimum first step within the same port. Clear definitions for different requirements will be
provided. Definitions and specifications concerning the processing and management of
personal or commercially sensitive data will be addressed.
III Development of common databases to support the system
This includes a common exemption database, a common (federated) user database(s) and a
common ship repository for improved data flows and data exchanges.
32
Problem Driver 4: Inadequate implementation
No. Policy measure
IV Introduction of a governance mechanism
A governance mechanism will be created to ensure timely and appropriate legal and
technical updates. Implementing and/or delegated powers for maintenance of e.g. the
technical specifications are proposed. This will be accompanied by the set-up of the required
expert groups for coordination and consultation with Member States and with industry
stakeholders as needed.
V Development of a complaint/feedback mechanism
A complaint/feedback mechanism will be offered to maritime transport operators as a tool to
alert authorities if the harmonised reporting and the reporting only once principles are not
respected or if any technical fault is found in the reporting systems.
VI Development of helpdesk function
To facilitate implementation, technical support to Member States on the reporting
environment specifications and possible IT solution in the form of e.g. helpdesk functions,
technical advice or development of application guidelines will be developed.
The measures have been packaged in policy options along the two main dimensions: to
address the harmonisation requirements (mutually exclusive measures A-D) and to define the
scope of what shipping operators can report via the harmonised reporting environment
(mutually exclusive measures 1-2). Six measures (I – VI) are common for all policy options.
As a result, eight policy options have been considered and six of them have been retained for
in-depth analysis, in addition to the baseline (see section 5.1):
A: Harmonised
NSW gateways:
technical
specifications
B: Harmonised NSW
gateways: common
IT solution
C: Central
reporting gateway
D: Mandatory PCS
(discarded)
1. Comprehensive
single entry point
solution
Option A1:
Measures A, 1 and
I-VI
Option B1:
Measures B, 1 and I-
VI
Option C1:
Measures C, 1
and I-VI
Option D1:
Measures D, 1 and I-
VI
2. Separate entry
points customs /
maritime
Option A2:
Measures A, 2 and
I-VI
Option B2: Measures
B, 2 and I-VI
Option C2:
Measures C, 2
and I-VI
Option D2: Measures
D, 2 and I-VI
Table 1: Policy options
The main difference between the options is in terms of roles and responsibilities and the
division of tasks between Commission and the Member States, as is further described below.
5.3.1. Policy option A1: Harmonised reporting gateways as front-ends to the
NSWs: binding technical specifications and requirements
(decentralised/distributed) - comprehensive scope
Harmonisation
Policy option A1 is to introduce binding requirements and technical specifications for
harmonising the reporting gateways (front-end interfaces) of existing National Single
Windows in the Member States. The specifications would cover data content, message
structure format, exchange protocols, user interface requirements and other rules as necessary
33
for ensuring the necessary information exchanges. They would be set at EU level but
responsibility for implementation and operation would be fully on the Member States. It
would also be the responsibility of Member States to prepare and perform updates,
maintenance and support services as required. Coordination and overview of updates for
permanent alignment with relevant legal and technical developments should be led by the
Commission with support of relevant experts. The technical specifications will be designed
with a view to enable full interoperability between the National Single Windows, future-
proofing for next phases of more access and exchange of relevant data (see also section on
data re-use below).
The result would be a decentralised system of very similar (subject to possible nuance
interpretations of the specifications at Member State level) National Single Window front
ends, allowing the shipping operators to adjust their reporting systems only once for being
able to report in any EU port in the same way.
The technical specifications for data and interfaces will be designed to enable both machine-
to-machine reporting and reporting via graphic user interface to meet the needs of all kinds of
shipping operators. In the longer term, specifications for reporting from autonomous ships
could also be introduced74
.
The option requires a connection between the National Single Window and all entities and
systems assigned by the underlying legal acts to connect as back-end data recipients; e.g. by
connecting the National Single Window as a user to the relevant customs trader interfaces.
The back-end technical specifications, from a National Single Window to a relevant local,
national or EU level system, would be derived from the requirements in the underlying
reference legal acts to ensure all relevant entities continue to receive the data, reports and
notifications in a useful and timely manner and in compliance with the functional
requirements and technical specifications of the recipient systems (i.e. customs systems).
Coordination or data format translation efforts will be needed if several connected entities
require the same information in different formats. The National Single Window would thus
have a routing and, where/if needed, a technical data format translation function.
The data and notifications/declarations received from shipping operators would be split so
that each data recipient only receives specific data elements ("need to know" basis).
Information flows shall follow the timelines for fulfilment of respective reporting needs;
notably the timelines for customs formalities as prescribed in the customs legislation.
Declarants (shipping operators) will remain liable and responsible for the correct and timely
submission of their reports and notifications. For any potentially personal data, the data
recipient will be responsible and accountable for managing the data in line with all applicable
74
Likely not needed as the reporting is location agnostic from a technical point of view.
34
data protection rules (e.g. GDPR, national requirements) to ensure proper data privacy
including no storage of sensitive data beyond prescribed timelines.
Any feedback provided by relevant authority, port operator or port service provider should be
send to the declarant via the same channel as received. To facilitate reporting from maritime
carriers, where internet connection is sometimes lacking, offline options for reporting will be
considered, where appropriate and possible.
Figure 3: Data flows in option A1
75
Scope of reporting
The body of data elements which are, on basis of EU, international or national law, asked
from a ship at a port call, must be clearly defined for the European Maritime Single Window
environment. The data elements agreed for this scope must then be coordinated and
harmonised into an agreed format for the shipping operators at front-end, to avoid
duplications and to ensure harmonised reporting.
The new legal proposal should therefore include references to this wider set of underlying
legal acts for the scope. In addition, a more detailed data set would be needed as a technical
tool to aid the front-end interface set-up and as a service and business guidance to the
maritime transport operators. This technical tool data list would be a living document to
reflect – not prescribe – the data requirements following any legislative updates or updates of
technical specifications of the underlying back-end systems. Authorities must not request
these data set elements in non-harmonised format nor ask for additional data outside of the
75
The figures illustrating the data flows via National Single Windows in chapter 5.3 are simplified illustrations
of the policy options; more detailed diagrams showing connections, interlinkages between IT systems and
other potential reporting paths can be found in Annex 6
35
single window reporting environment. The aim is to protect shipping operators from excessive
administrative burden.
In option A1, the scope of the European Maritime Single Window environment covers the
comprehensive set of all reporting for a vessel to perform a port call. This would include e.g.
all entry/exit formalities and notifications required from the carrier by customs76
(under the
Union Customs Code; reference to UCC to be included into the new RFD legislation) and all
national level data elements (Part C of the current RFD, Annex 1).
This is in line with stakeholders' opinions reported in the consultations. 82.5% of all
responders to the public consultation (93.5% of all shipping companies and ship masters; 50%
of all Member States77
) stated that national requirements should be included in the new
framework in order to harmonise all information required for a port call. 6.5% of all open
public consultation respondents did not agree the national requirements should be included
(0% of shipping companies and ship masters; 19% of Member States) and 11% had no
opinion or felt neutral to the proposal.
These results are also in line with those obtained during the evaluation78
when a large part of
the shipping stakeholders specifically ask also for a more comprehensive approach to
maritime transport and customs reporting. The European Community Shipowners’
Association stressed that: “It goes without saying that we want the customs reporting to be
part of it as well. Only in this way shipping can finally enjoy the single market.”79
For
rationalisation and simplification, the scope of the fully harmonised Maritime Single Window
data set – notably the national data elements from current RFD, Part C – will be scrutinised in
a process together with Member States and connected authorities to ensure that unnecessary
(e.g. traditionally requested but now redundant) data elements are over time cleared from the
reporting requests.
In order to enable this comprehensive data set, timelines and data requirements must be
aligned in detail with the current developments of the customs IT systems. The IT systems
related to the customs formalities proposed to be included in the scope of the RFD successor
(e.g. ICS2) are scheduled to be ready by 2024-25. The implementation of the comprehensive
European Maritime Single Window environment should be prepared with technical set-ups
and test runs to align with this time frame. All customs reporting via the European Maritime
Single Window environment should then be in direct correspondence with the rules,
specifications and requirements derived from the Customs legislation and technical
76
Currently: Entry Summary Declaration, Arrival Notification, Presentation Notification, Declaration for
Temporary Storage, Customs Goods Manifest, Electronic Transport Document for simplified transit, Re-
Export Notification, Exit Summary declaration and Exit Notification
77
For further detailed breakdowns of all these statistics, see Consultation synopsis report in Annex 2
78
Evaluation of the RFD, p.47-48
79
ECSA, A single market for shipping – time to make it happen
36
specifications of the underlying customs IT systems, and reflect any amendments and updates
in these underlying legal acts and specifications.
Initiate development towards e-certificate acceptance
Just above 80% of respondents to the open public consultation also stated that the new
framework should include provisions on certain e-certificates (notably ship certificates) to
allow for future fully paperless ships. This issue will be addressed in the revised reporting
formalities framework with appropriate references and links to the parallel initiative on
electronic transport documents. IMO has also issued Guidelines for the Use of Electronic
Certificates80
promoting the use of secure e-certificates for maritime transport.
The common databases and registries anyways established in the European harmonised digital
reporting s environment could in later steps be exploited to also allow and enable future
secure use of e-certificates and reference numbers for EU port calls.
Development of clear data re-use principles for step-wise process towards “reporting
only once” of same data
In its Council conclusions on Digitalisation of transport on 5 December 2017, the European
Council specifically called on the Commission to apply the 'once only’ principle when
developing new or revising existing legislation, in order to keep it fit for the digital age. The
“once only” principle aims to reduce administrative burden by avoiding that the same
business actor is required to supply the same information more than once to the authorities, as
first priority within the same port. The goal is to “get the data to circulate, not the user”81
:
authorities may not request that an operator submits again the same, unchanged data as
already sent, unless for corrections or updates. This does not imply that the transport operators
will not be obliged to report at several different points in time (e.g. customs formalities
required by law at several phases: e.g. early stage before a planned port call, formalities
required closely before calling a port and formalities upon departure from port). New or
changed data must always be reported again.
There has been a strong message from consulted stakeholders that the reported information
should be more efficiently shared and reused, both to reduce the burden of reporting and for
the sake of maximising multimodal transport facilitation.82
Better access to data contributes to
facilitating digital solutions for “smart ports”, significantly speeding up ports procedures with
indirect cost-savings and business opportunity improvements for the entire multimodal
80
FAL.5/Circ.39/Rev.2, April 2016
81
EY and DTI for the European Commission, Study on eGovernment and the Reduction of Administrative
Burden, 2014, p.29, https://ec.europa.eu/digital-single-market/en/news/final-report-study-egovernment-and-
reduction-administrative-burden-smart-20120061
82
Consultation workshop: Moving towards a European Maritime Single Window environment – what road to
take? (80% of those who voted in the session poll)
37
transport chain.83
80.5% of all respondents stated in the open public consultation that they
would have some or high benefits from more data sharing and data re-use (75% of the
Member States, 83.5% of the shipping companies and ship masters, 100% of the ship agents).
11% of the consulted stakeholders expected related benefits to be low (12.5% of the Member
States, 10% of shipping companies and ship masters) and 7.5% expressed no opinion on this
question. According to the respondents, the benefits would be increased productivity and time
savings from avoiding duplicate reporting.
A set of clear principles, rules and rights for data sharing and reuse will therefore be
developed to ensure correct and smooth data management and “reporting only once” for
carriers. As a minimum first step, the data re-use within the same port must be addressed.
Clear definitions for different requirements will be provided, filling the gaps of the current
legal framework. Clear roles, responsibilities and accountability for all entities connected to
the system will be defined, together with legal obligations/enablements set out in the
legislative framework together with the necessary business rules, common standards and
procedures. Coordination and technical support should be offered to the connecting entities if
needed.
The protection of personal data must be well covered in the system, e.g. by ensuring that
personal data is erased without delays once not needed, in compliance with the General Data
Protection Regulation. A distinction will be made between non-personal and personal data
including with clarity in definitions of e.g. data reports including the name of the responsible
data provider (e.g. ship master). Definitions and guidelines concerning the processing and
management of commercially sensitive data will be addressed.
For supporting and enabling real, efficient and secure application of the “reporting only once”
principle, common eGovernment building blocks84
e.g. for eID and eSignature should be
exploited.
The aim is to enable the application of "reporting only once". To achieve this, a step-wise
approach will be taken, with the requirements for sharing of static information and sharing
within the same port as a first priority. In subsequent steps, data re-use and data sharing in
support of multimodal transport services and more efficient functioning of the logistics chains
will be addressed including increased data sharing for "reporting-only-once" at Member State
and EU level. Reuse of declarants’ own historical data submitted earlier to another node in the
reporting environment should be facilitated where possible.
83
Boston Consulting, The Digital Imperative in Container Shipping, 2018,
https://www.bcg.com/publications/2018/digital-imperative-container-shipping.aspx
84
EU eGovernment Action Plan 2016-2020 Accelerating the digital transformation of government,
COM/2016/0179
38
Development of common databases
For a new legislative framework under policy option A1 to work smoothly, it would be
necessary to introduce certain common databases to support the interconnected system. This
will include a common exemption database, a common (federated) user database(s)85
and a
common ship repository. These common tools would ensure efficient flows and exchanges
within the European Maritime Single Window environment (decentralised or centralised).
eGovernment building blocks and existing tools for e.g. digital signature and eID would be
applied; Horizon 2020 Information and Communication Technologies86
and relevant industry
guidelines87
will be taken into account.
Introduction of a governance mechanism
To ensure flexibility and to keep the legislation relevant for the long-term in view of technical
and legal developments over time, a governance mechanism must be created. This is
especially the case to ensure the system remains maximum efficient also with a view to ICT
innovations and new technical possibilities developing. Implementing and/or delegated
powers for maintenance of the technical specifications and control of related updates, for the
harmonised technical data set and for the data reuse rules and rights will therefore be needed.
This will be accompanied by the set-up of the required expert groups for coordination and
consultation with Member States and with industry stakeholders as needed. The governance
mechanisms should be coordinated by the Commission transport sector but would closely
involve relevant Commission services/agencies from all involved policy areas.
Development of a complaint/feedback mechanism
The Commission is responsible for appropriate follow-up and possible infringement
procedures in case of Member States non-compliance, in order to ensure business continuity
and equal access to harmonised services for the maritime transport operators. With more clear
and specific legal provisions of the new legal proposal (in particular: detailed binding
specifications), the Commission will have the possibility of pursuing effective infringement
procedures, unlike under the current RFD.
Member States and their National Competent Authorities in charge of the National Single
Windows will in turn be responsible and accountable for the implementation of the
harmonised reporting gateway/front-end. They will also be responsible for the connection to
the back-end entities at EU and national level.
85
Cf for example the common user database for the customs IT systems: EORI
86
https://ec.europa.eu/programmes/horizon2020/en/h2020-section/information-and-communication-technologies
87
The Guidelines on Cyber Security Onboard Ships (http://www.ics-shipping.org/docs/default-
source/resources/safety-security-and-operations/guidelines-on-cyber-security-onboard-ships.pdf?sfvrsn=16)
39
A complaint/feedback mechanism will also be developed, offering the maritime transport
operators a tool to alert authorities if the harmonised reporting and the reporting only once
principles are not respected or if any technical fault is found in the reporting systems.
Introduction of helpdesk function
To facilitate implementation, technical support on the functioning of the European Maritime
Single Window environment specifications in the form of helpdesk functions, technical
advice and development of application guidelines or other tools to support the Member States
will be developed. The helpdesk is for the Member States and will in options A1-A2 focus on
providing support on the interpretation of the technical specifications and the data set. This
support may also be provided in forms of offered trainings. Support functions towards the
front-end and back-end users (data providers and data recipients) will continue to be the
responsibility of the National Single Window competent authority. Clear information to
business operators about access to the specific content-related helpdesks for various parts of
the reporting formalities will be available.
5.3.2. Policy option A2: Harmonised reporting gateways as front-ends to the
NSWs: binding technical specifications and requirements
(decentralised/distributed) – limited scope
Policy Option A2 is exactly the same as policy option A1 with the difference that the scope is
limited to cover only the current mandatory RFD reporting formalities and the national legal
requirements (current RFD Part C data). The customs IT systems will remain as a parallel
interface for completion of customs formalities.
This option would, according to the consulted shipping operators, not fully solve the issue of
shipping operators being required to report to several reporting entry points (the harmonised
reporting gateway(s) for maritime transport and to the various harmonised customs trader
interfaces and portals). The harmonisation of information requirements at customs level will
still be achieved, as it stems from the already adopted UCC legislation. Without the
interconnection with the customs IT systems, the timeline could be shortened and
implementation of the European Maritime Single Window environment will be more flexible.
With this option, complex interlinkage between the European Maritime Single Window
environment and the customs IT systems will not be implemented, avoiding risks of non-
synchronisation between back-end entity technical specifications and the maritime reporting
gateway. The risk of technical failures will therefore be reduced, same as the development
and maintenance costs related to the project implementation.
40
Figure 4: Data flows in option A2
5.3.3. Policy option B1: Harmonised reporting gateways as front-ends to the
NSWs: common IT solution for harmonised interface and formats
(decentralised/distributed; EU-level development responsibility, Member
State operational responsibility) - comprehensive scope
Option B1 is to develop a mandatory common reporting gateway IT solution88
at EU level and
deliver it to all Member States for installation in every National Single Window as a
harmonised front-end interface towards the shipping operators. The front-end component will
enable submission of data in a common EU format to different National Single Windows by
converting the harmonised data to a specific national format used by the National Single
Window, and vice versa. The front-end component could also provide data validation and
authentication functionalities. The National Single Windows will plug in this new harmonised
front-end reporting gateway into their existing system, simply replacing the old user
interfaces. The front-end IT solution will be developed as open-source software, therefore
allowing the national competent authorities to easily modify the back-end of the reporting
gateway for the plug-in to their National Single Window, if necessary.
For all other functionalities, the National Single Windows will remain the same, performing
the same role towards the back-end entities and requiring minimum adaptations.
The reporting gateway IT solution will be developed as in option A, at EU-level. The
common data format translation keys for any transformations done by the front-end
component from EU formats to national formats would also be developed at EU level, based
on the data mapping already completed. Regular updates as required would be supplied via
88
For the machine-to-machine reporting, this would be built in the form of a “middleware” software component
enabling communication between the two different system environments (on the one hand the shipping
operators and on the other hand the data distribution functionality of the National Single Window).
41
the EU (task may be delegated to a technical support function) following update plans agreed
together with the Member States (governance mechanism). The technical implementation for
this option will take into account the approach and progress made with the ICS2 Trader
Interface as a dedicated channel to receive the Entry Summary Declaration (ENS). The
development cost for this common IT solution would be carried at EU level including for all
updates required to remain aligned to the technical specifications of the underlying legal acts.
Responsibility for the functioning of the front-end component would be on the EU-level entity
in charge of the task. Member States would be responsible for adopting/installing the front-
end component package within given timelines and to follow instructions for regular and
timely updates and maintenance of the system. The operational responsibility would be on
Member States, providing helpdesk functions for their connected national entities and for the
front-end data providers. Some helpdesk functions towards the National Single Windows
regarding the front-end component and specifications will be provided at EU level.
The result would be a decentralised (distributed) reporting system of identical reporting
gateways in every Member State. As in option A1, the Member States would still be free to
organise the back-end connections including to Port Community Systems however they
prefer, as long as the set-up respects the common rules and specifications and the quality of
services and information flows between the maritime transport operators and the connected
entities and authorities remain sufficiently high.
Main principles concerning all sub-measures including scope, liability and responsibility for
all involved entities, EU level coordination and governance mechanisms, e-certificates
initiative, helpdesk functions etc. would be arranged as in option A1 above. Governance and
helpdesk functions will be required regardless of the policy option, as technical enablers to
ensure the reporting environment works smoothly and can remain aligned with legal and
technical developments. In options B1-B2, the helpdesk will provide support on the
installation of the front-end gateway solution to the National Single Windows.
Figure 5: Data flows in option B1
5.3.4. Policy option B2: Harmonised reporting gateways as front-ends to the
NSWs: common IT solution for harmonised interface and formats
42
(decentralised/distributed; EU-level development responsibility, Member
State operational responsibility) – limited scope
Option B2 is exactly the same as policy option B1 with the difference that the scope will be
limited. In option B2, the same limited scope / technical data set is considered as in option
A2.
Figure 6: Data flows in option B2
5.3.5. Policy option C1: Harmonised reporting via a central gateway
(centralised solution) – comprehensive scope
Option C1 is to introduce a centralised European reporting gateway hosted and operated by an
EU-level entity or technical support function. The centralised window would offer one single
reporting entry point for all port calls throughout the EU including the necessary two-way
information exchanges between data providers and connected entities and systems. Shipping
operators would also still have the choice to report directly to the various customs trader
interfaces. Member States may also in this case want to continue maintaining the old reporting
gateway (front-end interface) of the National Single Windows as an option for SME operators
in domestic traffic. However, if a shipping operator chooses to report via the centralised
European reporting gateway, authorities would not be allowed to request additional reporting
also via other entry points (reporting only once).
The centralised European reporting gateway would channel incoming reporting and
notifications directly to other EU-level systems, such as the Harmonised Trader Interface89
for
customs entry summary declarations. It would channel other data via the National Single
89
For more detailed information and overview of all connections between the European Maritime Single
Window environment and customs IT systems, see Annexes 6-7
43
Windows for transmissions to national level data recipients. Help desk and other support
related to the functioning of the European reporting gateway will be provided at EU level.
The National Single Windows would remain in place but with adaptations. They would serve
mainly as a router between the centralised European gateway and the national level data
recipients (receiving data from the central front-end gateway and continuing the functionality
of distributing that data to national level back-end entities). Member States would be
responsible for ensuring connection of their National Single Windows to the centralised
gateway. In principle, National Single Windows could also continue to offer an alternative
reporting channel through their former front-end gateways. If Member States wish to maintain
this possibility as a voluntary alternative for the maritime operators it would be allowed – in
addition to, not a replacement of the centralised European reporting gateway.
Strong back-up and cyber security solutions would be required to ensure resilience and
availability of the system.
Main principles concerning all sub-measures including scope, liability and responsibility for
all involved entities, EU level coordination and governance mechanisms, e-certificates
initiative, helpdesk functions etc. would be arranged as in options A1 and B1 above. The
helpdesk in option C1-C2 will provide support to Member States on all issues regarding their
connection into the centralised reporting gateway, as well as on the common data set and data
formats. Support towards national back-end entities continues to be provided via National
Single Window competent authorities.
Figure 7: Data flows in option C1
5.3.6. Policy option C2: Harmonised reporting via a central gateway
(centralised solution) – limited scope
Option C2 is exactly the same as policy option C1 with the difference that the scope will be
limited. In option C2, the same limited scope / technical data set is considered as in options
A2 and B2.
44
Figure 8: Data flows in option C2
5.4. Overview of main differences between the harmonisation solutions
Options A1-A2 Options B1-B2 Options C1-C2
Harmonisation tool Harmonisation
achieved via legally
binding common
technical specifications
for Member States to
implement a
harmonised reporting
front-end gateway to
their National Single
Windows.
Harmonisation
achieved via identical
front-end components
for the harmonised
reporting gateway,
developed at EU level
and installed at each
National Single
Window
Harmonisation achieved
via a centralised gateway
at EU-level. The gateway
will provide single EU-
level entry point for the
reporting. It will forward
the received information
to the National Single
Windows and provide
users authentication,
validate data and provide
logging and monitoring
functionalities.
Role of Member
States
To develop the new
front-end solution based
on the EU
specifications, adapt the
National Single
Window accordingly
and to continue to
operate and maintain
the National Single
Window.
To plug in the
provided front-end
component to their
National Single
Windows and to
continue to operate
and maintain the
National Single
Window.
To adapt the National
Single Window to be
connected with the
centralised gateway layer
including shifting some
functionalities from front-
end to routing roles; to
operate and maintain the
National Single Window
as routing structure.
Role of the EU To deliver the technical
specifications; to
coordinate the
governance and updates
To develop and
deliver the common
IT solution that can
be plugged in at all
National Single
Windows as the new
To develop, establish and
operate the central
reporting gateway; to
coordinate the
governance and updates
45
reporting gateway; to
coordinate the
governance and
updates.
National Single
Windows
Remain as the reporting
entry points, adapted to
the harmonised format;
will provide the
Graphical User
Interface (GUI) for
shipping operators; will
continue to provide
national back-end
connections and
services for relevant
authorities; will provide
independently all
functionalities.
Remain as the
reporting entry points,
compatible with the
harmonised front-end
IT solution; will
provide the Graphical
User Interface (GUI)
for shipping
operators; will
continue to provide
national back-end
connections and
services for relevant
authorities; will
provide
independently all
functionalities,
possibly excluding
the data-type
validation.
Will include a new
routing function between
the local and national
authorities and the central
data entry point but may
also remain capable to
receive reporting directly
from shipping operators;
will continue to provide
national back-end
connections and services
for relevant authorities;
will depend on centralised
gateway for many
services such as GUI,
logging, monitoring and
identity management.
EU-level helpdesk
function
Training/support
offered to Member
States
Will provide support
to Member States on
instalment and
functioning of the
front-end IT solution
Will provide support to
Member States on the
connections between
National Single Windows
and the central gateway;
provide support for
shipping operators on
connecting with the
gateway.
Governance Commission services
and relevant agencies
together with Member
States experts and
industry observers to
keep overview of
updates and
coordination of
specifications and data
set.
Commission services
and relevant agencies
together with
Member States
experts and industry
observers to keep
overview of updates
and coordination of
specifications and
data set.
Commission services and
relevant agencies together
with Member States
experts and industry
observers to keep
overview of updates and
coordination of the data
set.
Table 2: Core differences between options
The outcome vis-à-vis the shipping operators is in all cases more or less the same (identical
reporting gateways regardless of the port in options B and C; harmonised functionalities and
more or less the same gateway towards shipping operators in options A). These differences
have impact on the cost estimates presented in a section below. In all options, the likelihood
of achieving harmonised reporting is far higher than for the current legal framework
(baseline) as a result of either binding specifications, a delivered identical gateway solution
for all National Single Windows or the establishment of a central reporting gateway.
46
In all the options, a mix of expertise will be needed for the implementation and development
of IT systems. The bulk of the work and the main responsibility for the project management
will be for the Commission, contracting specific IT development services from external
service providers where needed. Technical expertise from specialised Commission services
and decentralised agencies will be involved as appropriate. The exact division of detailed
tasks (e.g. service contracting) can only be decided at a later stage in connection with the
implementation phase and following the set-up of detailed work plans in
delegated/implementing acts.
5.5. Discarded policy options
5.5.1. Policy options D1 – D2: Harmonised reporting via mandatory PCS:
binding technical specifications and requirements
(decentralised/distributed) – comprehensive and limited scope
Options D1 and D2 build the EU level harmonisation requirements and binding technical
specifications on mandatory Port Community System reporting gateways in the Member
States. A Port Community System is defined as an electronic platform connecting the systems
operated by the organisations and entities making up a seaport community. The Port
Community System facilitates exchange of operational or administrative information between
different actors in the port90
; it can also include systems for optimisation of processes (e.g.
“smart ports” systems). The PCS can be operated and maintained either by a public, private or
public/private organisation.
By linking the technical specifications to mandatory Port Community Systems, the reporting
environment would build on the systems already in place in many Member States; other
Member States/ports would need to adapt by establishing (purchasing) such systems.
In the consultations, shipping companies noted that this option is not viable, notably since
Port Community Systems normally are fee-based and the costs for shipping operators would
therefore increase. The option was supported by no shipping companies in the targeted
consultations and overall seen as potentially effective by only by 11% of all consultation
participants; somewhat higher share among ports and port community system providers
(31%).
It was also highlighted in the consultations that this might be an option for large ports but was
impractical as general solution since small ports today do not usually apply Port Community
Systems. At the present time, less than half of all EU ports have Port Community Systems in
90
J. Rodon, and J. Ramis-Pujol, “Exploring the Intricacies of Integrating with a Port Community System”, 19th
Bled eConference eValues, Bled, Slovenia, 2006
47
place, usually big ports with high volumes of traffic91
. According to IPCSA, among the 20
major European ports, 75% deploy Port Community Systems.
It is therefore found to be unrealistic and disproportionate to oblige all small and medium-
sized ports to invest in Port Community Systems and to prescribe a legal obligation for
Member States to apply such commercial systems; this should instead remain a free choice.
It should be noted however that the remaining policy options do not exclude the possibility for
Member States who choose, voluntarily, to build their National Single Windows on existing
Port Community Systems.
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?
In this section the quantifiable and qualitative economic, social and environmental impacts for
the different options are presented. They draw on the excel-based tool developed by COWI
and Gartner in the context of the Impact Assessment support study and on the modelling
performed by ICCS-E3MLab and TRT with the PRIMES-TREMOVE and TRUST models.
The 2020-2030 time horizon has been selected for assessing the impacts, in line with that of
other initiatives that are part of the 3rd
Mobility package. A discount rate of 4% has been used
for calculating the present value, in line with the Better Regulation guidelines.
6.1. Economic impacts
6.1.1. Benefits: reduced administrative burden92
The harmonisation of the reporting formalities is going to bring benefits to the shipping
operators and the industry, as the staff – generally the shipmaster – is expected to spend less
time (as expressed in terms of staff hours) on reporting tasks. Ports, Member States and other
connected authorities are not expected to incur direct cost savings in terms of reduced
administrative burden from harmonisation.
While the magnitude of the benefits is expected to be similar regardless of which
harmonisation mechanism is applied (option A, B or C), the range of reporting formalities
considered (options 1 or 2) is likely to have an impact on the benefits. Therefore, the benefits
91
Compared to the situation in 2010 when an impact assessment on e-maritime initiative found that about 60 out
of 1200 European ports had a Port Community System in place: e.g. SKEMA e-Maritime Initiative Periodic
Study, Task 2 - Annex 4: Inventory of Port Single Windows and Port Community Systems, 2010. A recent
IPCSA estimate is that 75% of the 20 main European ports have PCS; for small and medium-sized ports
PCS connections are less frequently in place.
92
For the estimates of reduced administrative burden, a similar methodology as in the support study by COWI
has been used, but applying a more cautious sensitivity analysis therefore arriving at more conservative
benefit estimates than in the support study.
48
of options A1, B1 and C1 are assessed together in a first section; followed by an assessment
of options A2, B2 and C2 together.
Options A1, B1, C1
The time savings for shipping operators in a harmonised reporting environment as compared
to the baseline scenario are estimated to around 25 million staff hours for the entire baseline
period (2020-2030, EU28), based on input from ECSA in consultation with a group of
shipping experts93
. In a harmonised system with a single reporting entry point, less time will
have to be spent on the reporting tasks and there will be no need to adapt the data set into
different formats for each new port call.
The assumption for the benefit estimate is that gradually up to 90% of the shipping operators
will choose to use the harmonised gateway (possibility that SMEs and national traffic
operators opt to report in split data sets directly to national authorities – the 90% is already a
cautious assumption). These staff hours saved – mainly by the qualified professional category
of ship masters94
– are equivalent to around EUR 720 million95
expressed as present value in
202096
. Sensitivity analysis has been performed to take into account the uncertainty regarding
the uptake of the voluntary new harmonised reporting format by also running the model with
a lower uptake among shipping operators: gradually increasing up to only 80% of shipping
operators using the harmonised reporting gateway. Assuming the more pessimistic uptake97
over 2020-2030 is projected to lead to around 22 million staff hours saved, equivalent to EUR
625 million, expressed as present value in 2020. Therefore, the total time saved is estimated
at 22 to 25 million staff hours, equivalent to a value of EUR 625-720 million98
.
93
Calculation based on assumptions developed in consultations with ECSA and their associated members:
average reporting time / average time savings for different types of vessels in different types of traffic (50%
expected time savings for fixed route traffic; 75% for tramp traffic). For details on methodology, see Annex
4
94
A value of staff hour is estimated at 38.35 € according to ECSA.
95
The impact assessment support study, based on 20 replies received through the consultations (survey and
interviews), showed somewhat lower savings estimated at EUR 67-79 million per year. However, this is
based on very few data points and not on a representative selection of respondents; however, it indicates
some uncertainty around the numbers. Interviewees were selected with a view to represent different
geographic areas and shipping company sizes and types; the respondents to the survey are however not
selected at all, the invitation to the survey was circulated broadly. 20 respondents of the total 11 000
shipping operators in the EU are considered a statistically weak sample.
96
Assuming a slow and gradual uptake from 25-90% over the baseline period with harmonisation benefits only
available as from 2021 (>90% of shipping companies replied in consultations that they urgently want a
harmonised reporting environment but it is still considered unlikely that 90% will adapt to the new formats
from day one).
97
For the pessimistic uptake, the rate considered is 10 percentage points lower relative to the central rate for each
year.
98
With UK excluded, the expected estimated time savings for the total period would be 21-24 million staff hours
equivalent to a value of EUR 600-690 million.
49
The value of the time saved does not represent a direct cost saving for the shipping operators.
It is unlikely that the reduced administrative burden can lead to actual cuts in staff costs; but it
is an opportunity cost as a significant share of qualified labour staff hours will be released for
other tasks.
Implementing efficient data sharing and application of the “reporting only once” principle
(primarily: within same port; in longer term, sharing of static data between ports) would
additionally benefit the maritime transport operators by reducing the number of data
transactions and report submissions. This benefits especially SMEs and companies reporting
manually via Graphic User Interface99
. There is no quantifiable data accessible on the number
of data elements currently asked more than once; this add-on benefit in burden reduction and
time savings has therefore not been possible to monetise. The indirect efficiency gains of
improved information flows are also non-quantifiable.
Options B1-C1 have an added benefit over option A1 in terms of accessibility: with the
commonly developed front-end component/portal, language translation of e.g. the graphic
user interface text and of helpdesk information will be available for all EU languages in all
reporting gateways at the National Single Windows / the European reporting gateway to a
more cost-efficient price (central once-only language translation for all).
Options A2, B2, C2
The total cost savings above are calculated on the assumption that the harmonised reporting
gateway is indeed the single entry point for reporting. In a scenario where still a significant
share of reporting is done separately and in parallel (options A2, B2, C2), the cost savings will
be lower as the maritime transport operators will still require double reporting systems and
more staff hours spent on reporting. This is not only an effect of two separate reporting
systems with one clean-cut share of the data set each; the lower expected time saving is also
an effect of the resulting double-reporting in a reporting environment without the inter-
connection between customs and maritime reporting. Part of the data set is over-lapping
between the two entities and data will continue to be sent in duplicate and in possibly
different formats into the two reporting environments.
The assumption used, based on input from ECSA in consultation with a group of shipping
experts, sets the expected time reduction per port call to only 20-25% in policy options A2-
C2. This is substantially lower compared to expected reduction of 50-75% in the options with
the possibility of customs and maritime reporting done together. For options A2-C2, the
expected total time saved would therefore be around 7-8 million staff hours over 2020-
99
EY and DTI for the European Commission, Study on eGovernment and the Reduction of Administrative
Burden, 2014
50
2030 (EU28), equivalent to EUR 215-245 million, expressed as present value in 2020100
.
The same uptake rates are assumed as for options A1-C1.
A1 A2 B1 B2 C1 C2
EU28
Savings compared to baseline in million staff hours
(baseline 50 million hours)
22-25 7-8 22-25 7-8 22-25 7-8
Savings compared to baseline, € million (present value)
(baseline € 1,520 million)
625-720 215-245 625-720 215-245 625-720 215-245
Excluding UK
Savings compared to baseline in million staff hours
(baseline 48 million hours)
21-24 7-8 21-24 7-8 21-24 7-8
Savings compared to baseline, € million (present value)
(baseline € 1,455 million)
600-690 205-235 600-690 205-235 600-690 205-235
Table 3: Reduced administrative burden for shipping operators relative to the baseline over 2020-2030
6.1.2. Costs: IT system investments and operational costs101
The main investment costs of evolving the current RFD system into a comprehensive and
harmonised port call reporting environment is in the development and adaptation of IT
solutions and IT infrastructure, including training of staff for the new gateway solution. With
a fully interconnected and harmonised set-up there will also be a need for certain common
features such as common/connected databases and registries for the reporting gateway(s).
These costs will be primarily for the Member States and for the European Commission. In
addition, there will be some adaptation costs for the back-end entities to enable connections to
the updated and harmonised reporting environment.
The calculation of these costs is based on the average cost for additional adaptation of a
currently implemented National Single Window to implement the new common gateway.
Costs for finalising implementation of a National Single Window under the current RFD are
not factored in for any of the policy options (as these costs are due regardless of any new
proposal as part of the implementation of the current Directive; the vast majority of Member
States already have a National Single Window in place). The costs for national authorities are
therefore assumed to be largely similar across all Member States, with some individual
differences based on e.g. salary levels and number of back-end authorities linked to their
National Single Windows today.
In all options A-C, some adaptation of the current National Single Window systems will be
required. In options A-B, the National Single Windows will need to be upgraded to a
harmonised interface specification or updated to plug in a new front-end reporting gateway
100
With UK excluded, the expected estimated time savings for the total period would be equivalent to EUR 205-
235 million.
101
For the cost estimates, data from the support study by COWI/Gartner has been used. More details on the
methodology for cost estimates is in Annex 4.
51
solution; in option C, the National Single Window may also continue the current functions to
be able to receive reporting directly from vessels in national traffic, but must also in any case
be adapted to be able to connect to a central European reporting gateway. This implies
changing some functionalities following the shift of responsibilities from national to EU level.
The costs for developing the IT solutions is primarily on Member States in options A; on the
EU in options B-C.
To minimise the shipping operators’ adaptation costs, especially for ships in national traffic
and for SMEs, Member States may decide to allow for shipping operators to continue
reporting their maritime transport formalities either to the former National Single Window
front-end interface (primarily relevant for option C) or directly to the back-end entities where
it is so possible (to customs IT systems, port community systems, national authorities). The
former case would entail duplication costs, e.g. on interface maintenance, that Member States
may wish to avoid after a transition period. The latter case would not necessarily cause
additional costs to the Member States. Note that the possibility to maintain the former
National Single Window front-end does not imply that a Member State could “opt out” of the
obligation to offer the new harmonised front-end interface.
As for shipping operators, there are no additional costs beyond the normal update and
maintenance costs under current RFD. The adaptation costs for enabling plug-in to the new
harmonised reporting system are not yet estimated; 68% of shipping operators replying in the
consultations expect “low or some costs” and 13% expect “high costs” but no shipping
company has been able to provide an estimate figure of these expected costs. Costs for
shipping operators are also expected to differ depending on e.g. their current reporting
systems (graphical user interface, machine-to-machine, non-digital, etc.). For the smaller
companies applying graphic user interface, the cost can be zero as the harmonised
spreadsheets will be provided as free templates for the new data formats. For machine-to-
machine reporting there will be a smaller adaptation cost, depending on the current formats.
In the consultations, the uniform view of shipping industry stakeholders was that any required
investments will be outweighed by the benefits. The harmonisation also means there will only
be one update for all EU reporting instead of the need to adapt and update reporting to match
different and non-synchronised systems for each port.
The following IT system assumptions have been applied for the cost assessment by the Impact
Assessment support study. The cost calculations have been done using a Fast Function Point
Analysis; the full methodology and underlying assumptions are presented in Annex 4. For all
policy options, the cost model includes the costs for back-end entity connections to the
adapted National Single Windows.
 For policy option A1, most major costs for development, implementation and
adaptation will be covered by the Member States. The Member State must translate
the specifications of the EU legislation into a software, guaranteeing that all
functionalities, interface aspects and data models follow the common set-up and that
all rules and requirements are fulfilled to ensure quality information flows between the
back-end entities (e.g. customs trader interfaces and reporting systems) and the front-
end users (shipping operators). Annual maintenance and operational costs will
52
increase compared to the baseline cost (approximate average EUR 265 000 per
Member State and year), due to the expansion of the system.
For the Commission or the entity assigned this task, there will also be costs for
developing and maintaining the common infrastructure, e.g. common databases and
registries; and to develop the technical specifications. EU-level costs will also be
incurred for the connections with some central back-end systems. The annual update
and management costs will cover e.g. helpdesk function towards the Member States,
stakeholder management (governance mechanism); specifications updates (reflecting
and following any developments in the underlying legal acts) and the maintenance of
the common databases and registries.
 For policy option A2, the same functions and related costs as in option A1 apply.
However, there are fewer connected entities (customs IT systems not interconnected),
lower complexity of requirements/specifications and lower volume of messages to be
transmitted without the direct connections with customs IT systems. The costs for
option A2 are therefore lower than in option A1.
 For policy option B1, the cost for Member States’ one-off investments will be
substantially lower than in option A1 since the IT development cost is covered by the
EU with economy of scale gains. The Member States will have some investment costs
for ensuring the first plug-in of the common front-end interface solution as new
reporting gateway to the National Single Windows, but the functionalities of the
National Single Windows beyond the front-end can remain more or less unchanged.
As in option A1, Member States will face some additional annual maintenance and
operational costs caused by the expansion of the system, in addition to the baseline
cost of running the National Single Windows.
The entity assigned by the Commission (delegation of the task highly likely; the work
must be done by an entity with sufficient know-how of IT system development with
EU eGovernment principles in mind and with sufficient expertise of the specific
reporting requirements and linked procedures) will manage development and
production of the front-end component IT solution and the common specifications.
This will relieve some of the cost burden from Member States as the main IT
development task is centralised. The front-end solution must be developed with the
current National Single Windows in mind, creating a plug-in solution possible to adopt
in all National Single Windows with minimum extra cost for Member States. In
addition, the EU responsible entity would have costs for the common services such as
databases, central helpdesk function (towards Member States) and stakeholder
management (governance mechanism); these costs will be substantially higher for the
EU in option B1 than in option A1 as more services are provided to the Member State.
 For policy option B2, the fewer connected entities, lower complexity of
requirements/specifications and lower volume of messages results in lower costs than
in option B1.
53
 For policy option C1, Member States will need to perform updates of their receiving
end systems; these costs are estimated to be slightly higher than the baseline costs of
annual maintenance of the current system due to the new higher pressure for
synchronised updates to legal and technical developments. In addition to maintaining
the current front-end to be able to process data received directly from vessels in
national traffic (if the Member State decides to do so), the National Single Windows
also need to be adapted to be compatible with the central level gateway. They will
need to be slightly transformed as some functionalities are moved from national to EU
level and a routing function is instead added in the National Single Window. These
more complex functionality adaptations imply a higher investment cost for Member
States in adapting the National Single Windows, as compared with option B1. Some
additional annual maintenance and operational costs are expected on top of the
baseline cost for National Single Window operation due to the expanded volume of
messages passing via the window and the stronger demand for timely updates
whenever the centralised gateway is updated.
The cost of development and operation of the centralised solution and the new EU-
level reporting gateway and routing system will be for the EU Commission budget;
including helpdesk functions towards Member States, regular software updates and
risk mitigation measures to ensure high availability and high security of the system.
The development costs for the Commission for the full IT system at central level
(building from zero) is still slightly lower than the cost of developing a front-end
solution fit to plug into all existing National Single Windows as is required in options
B1-B2 while the annual maintenance cost in option C is higher.
For policy option C2, the fewer connected entities, lower complexity of
requirements/specifications and lower volume of messages results in lower costs than
in option C1.
Regarding the costs for data re-use, there will be no need to establish additional systems for
this since there are already working solutions (like SafeSeaNet) or planned developments
(like ICS2 for customs) for ‘administration to administration’ exchanges. The added value of
data re-use can therefore be achieved at little or no cost. There may in any case be a need for
existing authority IT systems to be updated to be in line with the new General Data Protection
Regulation coming into force in May 2018. The data sharing within the European Maritime
Single Window environment will need to respect these rules, just like all other information
flows will. Any IT solutions or business rules being prepared under the new initiative will
also ensure data protection by design and by default.
54
Baseline A1 A2 B1 B2 C1 C2
EU28
Costs for the Member States
(€ million, present value)
CapEx - 13,5 10,7 7,8 7,1 10,7102
10,7103
OpEx104
108 14,3 11,0 8,1 6,8 8,1 8,1
Total MS 108 27,8 21,7 15,8 13,9 18,8 18,8
Costs for the EU (European Commission
or other entity assigned with the task)
(€ million, present value)
CapEx - 1,7 1,7 2,5 2,5 2,4 2,4
OpEx - 9,6 9,6 11,0 10,9 13,0 12,0
Total EU - 11,3 11,3 13,5 13,3 15,4 14,4
Total costs (€ million, present value) 108 39,1 33,0 29,4 27,2 34,2 33,2
Excluding UK
Costs for the Member States
(€ million, present value)
CapEx - 12,9 10,2 7,5 6,8 10,2105
10,2106
OpEx107
104 13,7 10,5 7,8 6,6 7,8 7,8
Total MS 104 26,6 20,7 15,2 13,4 18,0 18,0
Costs for the EU (European Commission
or other entity assigned with the task)
(€ million, present value)
CapEx - 1,7 1,7 2,5 2,5 2,4 2,4
OpEx - 9,6 9,6 11,0 10,9 13,0 12,0
Total EU - 11,3 11,3 13,5 13,3 15,4 14,4
Total costs (€ million, present value) 104 37.9 32,0 28,7 26,7 33,4 32,4
Table 4: Investment/adaptation and operational costs (total period 2020-2030, EUR million, present value); 4% Better
Regulation discount rate applies.
6.2. SME impacts
6.2.1. Benefits
SMEs will benefit to a high degree especially from reduced administrative burden and more
efficient interactions with authorities (data re-use, single entry point, rationalisation of
duplicate or redundant reporting): SMEs generally have limited resources and are less likely
to have the IT systems for machine-to-machine reporting. They are therefore more likely to be
in the higher end of average reporting burden per port call today. Furthermore, in small
companies every staff hour saved makes a proportionally bigger difference than for large
companies with bigger on-board crew.
102
This cost includes a cautious assumption of all Member States maintaining the current front-end gateway as
an option for vessels in domestic traffic; in a scenario with no Member State providing this offer the total
cost would be EUR 3 million lower (7.7)
103
Idem
104
In addition to the Member States' baseline cost for annual operation of the current National Single Windows;
those costs also remain in all options.
105
As in the C1 scenario for EU28 (7.2 million)
106
As in the C2 scenario for EU28 (7.2 million)
107
In addition to the Member States' baseline cost for annual operation of the current National Single Windows;
those costs also remain in all options.
55
In the targeted interviews, SMEs especially pointed to their expected benefits from clarified
data re-use principles and data rules including regarding the use of potentially personal data.
The consulted SMEs stressed that they struggle to integrate the requirements of the complex
GDPR in their business models. Especially SME shipping companies and ship agents
mentioned this in the interviews, stressing that they have limited resources to put in place the
right IT infrastructure to ensure GDPR compliance.
Data is not sufficiently available to calculate a separate benefit quota for SMEs.
6.2.2. Costs
Adaptation costs for SMEs and other shipping companies would be negligible or in size of the
normal regular updates under the current RFD, notably since the harmonised new reporting
entry point is offered and not a mandatory system. No additional costs are therefore forced on
SMEs.
6.3. Social impacts
6.3.1. Benefits
The direct effect is notably the decrease in cumbersome and repetitive work tasks for the
shipping operators, notably the ship masters. In the consultations, such tasks were pointed out
by social partners as a very negative side-effect of the inefficient reporting environment. 70%
of all respondents expect positive or strongly positive impact on overall job quality from
harmonisation options A and B; 90% expect positive or strongly positive impact from
harmonisation option C. No single respondent expect negative impacts on job quality from
either option. Ship masters are highly qualified professionals with long education for
navigation; it is considered a particular waste of skills to spend their high-cost staff hours on
burdensome bureaucracy. In a situation where the maritime transport sector finds it
increasingly difficult to recruit competent and qualified staff108
, actions to make the maritime
profession more attractive by reduced administrative burden would therefore be highly
welcome. Harmonisation of reporting will ease this burden; single reporting entry point for
customs and maritime reporting; reporting-only-once and continued improvement of data
flows and possibilities of more machine-to-machine reporting offer further benefits in this
regard. The value of this social benefit cannot be easily monetised and quantified.
Apart from job satisfaction and quality of work, several stakeholders in the consultations have
stressed the indirect expected benefit on safety levels. It is commonly expected that the
released staff hours will to a large extent be shifted to safety related tasks, especially when the
ship master can spend his time at the bridge instead of with the excel sheets. This is
particularly important since much of the reporting requirements are due at the time a ship
108
https://ec.europa.eu/transport/modes/maritime/seafarers_en
56
enters the port; so at the peak activity of a ship journey when the attention of the ship master
would be most needed at the bridge.
6.3.2. Costs
Any indirect negative social impact is primarily expected for shipping agents. With simplified
reporting procedures, some shipping operators may no longer need shipping agent services in
their current format. For this group of stakeholders, tasks and business opportunities will
transform and jobs may disappear. It is impossible to make a credible estimate of this impact;
since ship agents themselves primarily expect their services may be transformed rather than
made redundant109
and since the over-all shipping volumes may at the same time increase,
balancing out some of the potential negative impacts.
6.4. Environmental impacts
6.4.1. Benefits
The modelling performed with the PRIMES-TREMOVE and TRUST models110
show that
policy options A1-C1 would shift 3,395 million tonne-kilometres to waterborne transport in
2030, mostly away from road, because of improved competitiveness of the sector (i.e. lower
administrative burden relative to the baseline). This represents about 0.3% increase in the
transport activity of the waterborne transport in 2030 relative to the baseline. The shift in
traffic towards waterborne transport would also have an environmental impact in terms of
reduced greenhouse gas emissions. Over the 2020-2030 horizon, freight transport emissions
are estimated to decrease by 1,880 thousand tonnes of CO2 (0.1% decrease) relative to the
baseline. This translates into around €145 million of external costs savings over 2020-2030,
expressed as present value. The impacts of policy options A2-C2 would be more limited, due
to the lower reduction in administrative burden relative to the baseline: 1,185 million tonne-
kilometres shifted to waterborne transport in 2030 (mostly away from road); 630 thousand
109
Expected impact according to the European association for ship agents, ECASBA: job transformation and
higher efficiency primarily; low employment impact. From the case study interviews: “Ship agents are
confident about the demand for their services independently of the status of the NSW in which they work in.
They believe they will benefit from harmonisation and digitalisation independently of how large a share of
their business currently relies on handling reporting formalities”.
110
The modelling has been performed by ICCS-E3MLab and TRT. The PRIMES-TREMOVE transport model
and the TRUST model have been used to assess the impacts on modal shift and environmental impacts. The time
savings for the shipping operators in the policy options relative to the Baseline have been used to calculate the
impacts on the generalised transport costs by origin-destination with the TRUST model. The changes in the
generalised transport costs have been subsequently used in PRIMES-TREMOVE to derive the impacts on modal
shares for all freight transport modes together with their impacts on CO2 emissions. The time savings assumed
for quantifying the impacts on modal shift and CO2 emissions are the same as those used for assessing the
reduced administrative burden. More details about the inputs used and the modelling setup is provided in Annex
4.
57
tonnes of CO2 saved relative to the baseline over 2020-2030, equivalent to external costs
savings of around €48 million (expressed as present value).
In the case studies, it was mentioned that in some Mediterranean and Black Sea ports, ships
may wait even days outside a port with engines running, due to congestion which could at
least partly be relieved by better data handling and data flows to and from authorities. In the
consultations, deep sea shipping operators mentioned that with less time spent in port or more
accurate port availability information, they could adjust speed to go slower, thereby saving
fuel and emissions. These impacts are non-quantifiable because of lack of detailed data.
6.4.2. Costs
No negative environmental impacts have been suggested or identified.
6.5. Other impacts
More efficient procedures will also have indirect unquantifiable benefits for maritime
transport operators. The consequence of the more harmonised and simplified reporting would
be improved competitiveness for the maritime transport sector, as shipping operators can
spend more time and effort on business related matters instead of on reporting; also costs for
ship agents may to some extent be saved. This could indirectly benefit business results, GDP
growth and prices for consumers.
In addition, the potential benefits of National Single Windows will increase if the digital
information received is efficiently re-used for improving maritime transport and related
multimodal and logistic services. For example, a harmonised provision and efficient and
appropriate re-use of arrival or departure times could enable transport and logistics service
providers to optimise the flow of cargo in and out of ports in real-time. This would in turn
facilitate the establishment of more efficient and environmentally-friendly transport and
logistics services for all users. These indirect effects have not been possible to quantify.
Member States, ports and other authorities are expected to experience less tangible benefits
from improved data sharing and re-use; although in the long run the investments in such data
flow systems may have beneficial indirect effects on over-all efficiency gains and enabling
new quality services; Member States are also expected to benefit qualitatively from better
information exchanges and information flows between authorities nationally and cross-
border.
Digital reporting offers a large potential to improve the efficiency and reliability of reporting
process but also requires close attention from the point of view of concerns and risks related
to the security of the digital reporting and wireless communication systems. Cybersecurity
and privacy technologies should become complementary enablers of the EU digital economy,
ensuring a trusted networked ICT environment for governments, businesses and individuals.
The EU ambition is to become a world leader in a secure digital economy.
The prevention of and the protection against attacks that target modern ICT components,
complex ICT infrastructures, and emerging technologies as well as ensuring continued
operation or redundancy remains a difficult task. This concern applies to all considered
options. Whichever option is chosen, it should be guaranteed that the adopted system will
58
remain open to the continued evolution of innovative solutions that will help to achieve a
well-functioning, harmonised, secure and future-proof digital reporting environment enabling
interconnectivity and coordination of transport and customs related reporting, to improve the
efficiency attractiveness and environmental sustainability of maritime transport while also
contributing to the more efficient integration of the sector within digital multimodal logistic
chains. It should aim for technology neutrality, and seek to avoid lock-in to one particular
technology solution or technique that may change in future. Also the automation and technical
developments in ships are expected to have a significant impact (see above, chapter 2.4).
7. HOW DO THE OPTIONS COMPARE?
7.1. Stakeholder preferences
Views among stakeholder groups differ substantially when it comes to the policy options for
harmonisation. Among shipping companies and ship agents, the strong preference is for
greatest possible harmonisation; the largest share (43%) supported option C. They have not
shared strong objections against any option except status quo. Member States on the other
hand have, in interviews and consultation events, voiced strong objections against a
centralised approach. Among Member States, the preferred options are instead option A
(40%) and option B (30%). Ports and port community system providers have been mostly in
favour of discarded option D (31%) followed by option A (25%); however, these stakeholders
are neither primarily affected by the problem or by the solution (no high cost of new legal
obligations).
It should be noted that in the consultations, no estimates on costs and benefits were yet ready
and provided to stakeholders; the choices were made on the basis of other considerations. To
be able to take the differing views properly into account, the underlying reasons for the
stakeholder group choices were considered.
The different preferences reflect the main interests of these groups. Shipping operators want
to remove the administrative burden. Member States have stressed their interest in protecting
their previous investments in National Single Windows. Ports and port community systems
have no specific disadvantages in the current non-harmonised situation and are less concerned
about change.
For Member States in particular it seems to be a political choice more than a preference based
on cost calculations. There is reluctance to accept a new layer of structures between the
National Single Window and the shipping operators and a desire to maintain a degree of
control over the operation of the reporting gateways. There is also a high awareness of the
potential risk of a single point of failure with high impact on port operations in case the
central reporting gateway fails.
Shipping operators’ interest in a centralised system seems to be based on distrust in Member
States’ capacity to achieve harmonisation when in charge of building their own systems.
Therefore, options B1-B2 represent a compromise option whereby Members States would
retain control on the operation of the reporting gateway, while stakeholders’ distrust could be
59
appeased by guaranteeing a harmonised front-end gateway/interface developed at EU level
and delivered to all Member States.
Regarding the scope of the requirements, shipping operators and ship agents strongly prefer a
comprehensive scope including all national requirements (96% of shipping companies, 82%
of ship agents) and all cargo reporting (93% of shipping companies, 85% of ship agents) via
the European Maritime Single Window environment; this is less of a priority for Member
States (52% supporting national requirement inclusion; 79% supporting inclusion of customs
formalities) and port operators (91% support inclusion of national requirement; 71% inclusion
of customs formalities).
For back-end entities, options A1-A2 are expected to be more attractive, giving better
possibility of synchronisation of national level requirements. This would however be a
potential trade-off at the expense of harmonisation towards the shipping operators (lower
benefits achieved).
7.2. Effectiveness
For policy option A1-A2, the responsibility for interpretation and implementation of the
common specifications lies fully on Member States. The likelihood of reaching the objective
of a fully harmonised reporting environment is therefore lower – differences in interpretation
are likely to result in some fragmentation still of the systems, even if the main functionalities
work in the same way everywhere. The high risk of non-synchronisation (Member States
likely to have different cycles for updates and different speed of implementation and
maintenance) also reduces the expected effectiveness of the option. The expected
effectiveness towards the objective of harmonisation is therefore lower with option A than
with options B-C.
For policy option B1-B2, responsibility for interpretation of the specifications is with the
EU-level entity in charge of the common reporting gateway IT solution, ensuring that the
harmonisation objective can be effectively reached. The timely installation and running of this
IT component is then the responsibility of the Member States. Effectiveness may decrease if
Member States fail to update timely and in accordance with instruction by the responsible
EU-level entity. Overall, however the options B1-B2 are expected to deliver reliable and
sufficient achievement of the harmonisation goals.
For policy option C1-C2, the expected effectiveness of harmonisation is high: a single entry
point will by nature provide the fully harmonised reporting environment.
Policy options A1, B1 and C1 are all expected to deliver high effectiveness towards the
single entry point objective; slightly lower however for option A1 due to the likelihood of
national level differences in the interpretation of technical specifications. The objective of
efficient data sharing and data re-use will also be more effectively achieved in a fully
integrated reporting environment. In policy options A2, B2 and C2 however the single entry
point objective will not be completely achieved as maritime and customs reporting will not be
fully integrated; this also affects the effectiveness towards data re-use and “reporting only
once”.
60
Beyond the direct effects and objectives, all options will contribute to the general objective of
the smooth functioning of the Single Market; the simplification, digitalisation and reduced
burden on economic operators is expected to benefit the overall EU objectives by supporting
more efficient trade and transport and thereby growth, competitiveness and employment.
Compared to Baseline A1 A2 B1 B2 C1 C2
Specific objective: To harmonise reporting
procedures, interfaces and data formats
+ + ++ ++ +++ +++
Specific objective: To reduce administrative
burden through single entry point for
reporting
++ + +++ + +++ ++
Specific objective: To increase efficiency
by enabling reporting only once
+++ ++ +++ ++ +++ ++
General objective: To contribute to the
smooth functioning of the Single Market by
facilitating trade and transport
++ + +++ ++ +++ ++
7.3. Cost-efficiency
The Impact assessment support study found that for the costs calculated, even an average time
saving of five minutes per port call would lead to benefits matching the costs111
. The expected
time savings are substantially higher than this figure for all options even with the cautious
estimate ranges and the assumption of a slow and gradual uptake; the cost-benefit ratio is
clearly positive for all analysed options.
(EU28) A1 A2 B1 B2 C1 C2
Benefit: estimated value of staff
hours saved compared to baseline
625-720 215-245 625-720 215-245 625-720 215-245
Costs: total estimated additional
costs for MS and COM (on top of
baseline costs EUR 108 million for
the time period)
39.1 33.0 29.4 27.2 34.2 33.2
Cost-benefit ratio 16.0-
18.5
6.5-7.5 21.3-24.6 7.9-9.1 18.3-21.1 6.4-7.4
111
COWI, Support study for the impact assessment of a European Maritime Single Window environment, 2018
61
The costs are higher in options A1, B1 and C1 but the benefits for shipping operators are also
considerably higher. Options A2, B2 and C2 are less costly and easier to implement and
maintain but less ambitious in terms of achieving benefits and with subsequently lower cost-
benefit ratio.
The ranking of options cost-wise remains the same even if we make the assumption that no
Member State decides to offer the current reporting gateway as an option for vessels in
national traffic (up to 3 million lower costs for Member States in total). The difference
between options B and options C will be marginal.
Options A1-A2 have less certainty of achieving the benefits (interpretation of the technical
specifications is done by the Member States; unlikely to result in permanently identical
reporting interfaces although main functionalities should be similar) and incur the highest
costs for the Member States. Options B1-B2 is the least costly, in particular for Member
States, and yields high certainty of benefits for the shipping operators due to a better control
on EU level harmonisation than with options A1-A2. Options C1-C2 have higher costs, but,
as options B1-B2, provides high certainty of benefits. It should however be noted that the
differences in total costs for the period of 2020-2030 are very low (EUR 11.9 million between
the most expensive and the cheapest options) and the cost-benefit ratio high for all options
and in particular for all comprehensive scope options.
The option with highest cost-benefit ratio is option B1 (second cheapest option).
7.4. Coherence
All options are in coherence with other EU policy objectives.
The objectives of the proposal are in coherence with EU transport policy in general and
maritime transport policy in particular. The initiative supports EU policy on reducing
emissions from the transport sector and contributes to the objectives of the EU transport social
agenda. It remains well coherent with the Vessel Traffic Monitoring and Information Systems
Directive and brings added value by enabling coordination of the reporting requirements
under the reference legal acts. The governance mechanism established in all options provides
a guarantee that changes in underlying legislation will be appropriately and timely mirrored in
the technical data set and with required updates for specifications and IT component.
All assessed options are in line with the Commission REFIT programme objectives of
administrative burden reduction and simplification and with the overall Commission
objectives of competitiveness, smoothly functioning internal market and digitalisation.
The proposal is in coherence and closely aligned with the implementation of the Union
Customs Code. Options A1-C1 create a closer interconnection between the maritime and
customs policy areas requiring more efforts for cooperation and harmonisation between the
services. This creates a higher level of complexity but also opportunities for increased
coherence with benefits for external stakeholders.
The proposal complements also the initiative on electronic freight transport information
concerning acceptance in digital format of freight transport related information and
certificates by authorities performing transport-related inspections in the EU hinterland. Just
62
like the e-Documents initiative, the European Maritime Single Window environment will
support digitalisation and simplification for transport operators; although the two initiatives
address different aspects of information reporting requirements at different stages in the
course of a freight transport operation. The two proposals have been developed with particular
care to exploit synergies with regards to data interoperability aspects.
None of the options will create contradictions with existing EU acquis.
7.5. Proportionality
The options are designed not to impose any disproportionate burden on the shipping
operators, notably by offering the harmonised European Maritime Single Window
environment as non-mandatory for shipping operators. By building on the existing structure of
National Single Windows, costs to Member States are limited and clearly exceeded by the
potential direct and indirect benefits.
Options C1 and C2 creates an additional EU-level layer between the shipping operators and
Member State authorities, creating a new structure for reporting. However, even these
centralised option would be justifiable with respect to the benefits it would bring in terms of
reduced administrative burden.
None of the options therefore go beyond what is necessary to achieve the objectives. The
expected high efficiency gains cannot be achieved by action only on Member State or
international level nor by other, non-legislative means. The proposed expansion of the scope
is well defended by the benefits expected. New reporting requirements are not created but
existing requirements are brought into a coordination mechanism.
To achieve the objectives, a Regulation replacing the current RFD is proposed as the adequate
instrument.
7.6. Summary: comparison of options
The preferences for different options differ widely between the stakeholder groups. While
options B1-B2 are not the first choice of any stakeholder group, it could present a suitable
compromise option for all main stakeholder categories, considering especially that the
acceptance for option C1-C2 is low among Member States. The compromise option should
provide sufficient guarantees of harmonised front-ends to be supported also by the shipping
operators when adopted. None of the other options present a realistic compromise with
possibility of being supported by all main groups.
The options B1-C1 have highest expected effectiveness, addressing all problem drivers and
most likely to produce complete harmonisation of the front-end interfaces/gateways and data
formats. These options are more likely to facilitate also the data re-use/data sharing issue, as
compared to the limited scope options.
While option B2 would be cheaper to implement, it would also yield substantially lower
benefits for the shipping operators (trade-off). All options will result in unbalanced outcomes
63
for the different stakeholder groups: the costs incurred will be primarily for Member States
and the Commission whereas the direct benefits will be reaped by the maritime transport
industry. Indirectly, this will however benefit the entire Union objectives in terms of more
efficient trade and transport, beneficial for overall growth, competitiveness and employment.
In terms of cost-benefit ratio, the options A1-C1 score higher than options A2-C2 with best
ratio for option B1. The cost-benefit results remain clearly positive also when testing the
options for the assessed uncertainty of cost and benefit estimates (e.g. calculating benefits in a
more pessimistic uptake scenario). The costs are however very similar across all options and
the cost aspect alone is not sufficiently decisive to argue strongly for one option over the
others.
The risk of system failure is lower in a distributed system, as in options A1-A2 and B1-B2.
These options have higher resilience against e.g. cyber-attacks or technical break-down. The
likelihood of all National Single Windows breaking down at the same time is considered low.
Options C1-C2 on the other hand have a higher vulnerability because of the “single point of
failure” (low resilience to cyber security, technical failures; high impact in case of failure)
which would require solid back-up measures to mitigate the risk, e.g. by transfer of risk
(managed hosting) or measures to lower potential impacts (business continuity facility). On
the other hand, implementation related risk is higher in options A1-A2 and B1-B2 if not all
MS have the capacity to properly apply the specifications and/or common software. The main
risk in this regard is the non-synchronisation and failure by Member States to update their
National Single Windows timely to new specifications, notably in options A1-A2 where all
developments must be completed at Member State level. This risk remains even with a
Regulation as legal instrument as specifications will be updated by delegated/implementing
act. There is also a higher risk in A1-A2 and B1-B2 that there is no or an insufficient common
knowledge base for the help-desk, resulting in heterogeneous quality of help-desk towards the
data providers and back-end connected entities.
Effectiveness Efficiency Coherence Proportionality
Baseline 0 0 0 0
Option A1 ++ ++ +++ +++
Option A2 + + +++ +++
Option B1 +++ +++ +++ +++
Option B2 ++ + +++ +++
Option C1 +++ +++ +++ ++
Option C2 ++ + +++ ++
64
8. PREFERRED OPTION
The preferred option, based on a combined analysis of cost-benefit ratio, acceptance by
stakeholders and expected effectiveness, proportionality and risk rating, is therefore option
B1 with a total expected additional cost of EUR 29.4 million for 2020-2030 and expected new
benefits of 22-25 million saved staff hours for the same time period (equivalent to a value of
EUR 625-720 million). This option yields the highest benefit to an acceptable cost. It will
ensure a harmonised reporting environment while respecting the current set-up of National
Single Windows, therefore exploiting the already made investments. It can realistically
receive the support of all main stakeholder groups. The burden on Member States is
minimised by offering a common software developed at EU level and it avoids the risks
attached to creating an additional layer of architecture (including by ensuring proportionality
of the proposal) and reduces the risks deriving form single point of failure.
The option will have budget implications for the European Commission, with expected costs
for IT services and IT system development up to EUR 13.5 million in the period of eleven
years 2020-2030. The Commission costs are proposed to be covered via Support activities to
the European transport policy and passenger rights including communication activities
(budget reference 06.02.05).
In this, as in the other options, delegation of the IT development tasks is likely to be needed.
The main project management will remain with the Commission services but it is probable
that some IT development services will need to be provided by external contractors or
specialised entities. Commission specialised services and decentralised agencies with expert
know-how of IT system development (including EU eGovernment principles) and the specific
maritime transport reporting requirements and linked procedures will need to be involved as
appropriate. Expertise from several services may need to be involved in the project
management and governance mechanism, e.g. to ensure coordination with all connected
policy areas (underlying legal acts). The detailed task division including contracting of IT
development services should be defined in connection to the development of work plans in
line with delegated/implementing acts.
The governance mechanism required is a set of implementing/delegated powers to enable
necessary updates in line with legal and technical updates; and a dedicated expert group in
coordination with all relevant Commission services.
9. REFIT (SIMPLIFICATION AND IMPROVED EFFICIENCY)
The preferred option offers significant simplification and improved efficiency by reducing the
administrative burden for shipping operators fulfilling legal requirements in connection to a
port call.
The reduced administrative burden is expected to be achieved as the result of 1) harmonised
front-end reporting gateways, procedures and data formats; 2) the provision of a single
reporting entry point; 3) more efficient re-use of data enabling reporting only once and
removal of duplicate reporting. With a comprehensive coordination mechanism for all port-
call related reporting for a shipping operator, in combination with fully harmonised data
65
formats, reporting procedures and front-end interfaces, a high number of staff hours can be
spent on other tasks, notably related to core business, to safety and security.
REFIT Cost Savings – Preferred Option: B1
Description Amount Comments
Time saved on port call reporting: total
for all EU port calls over the baseline
period 2020-2030.
22-25 million staff hours
in the time period 2020-
2030; equivalent to a
value of EUR 625-720
million
Major benefit for maritime transport
operators (shipping operators);
indirect benefits for competitiveness
and modal shift.
Costs primarily for the Commission
and for Member States authorities.
10. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
The Commission will follow the progress, the impacts and results of this initiative by a set of
monitoring / evaluation mechanisms. Progress will be measured towards achieving the
specific objectives of the new proposal. With more clear and detailed specifications in the
new legal framework and with more support to Member States for implementation (notably:
by providing the common front-end plug-on solution), the expected implementation rate is
substantially higher than for the current RFD.
The basis for monitoring progress will by necessity be the assessments and reports by the
affected stakeholders (Member States, shipping operators). Static data on baseline issues such
as number of port calls and number of reported data elements per port call can be
automatically extracted from the IT systems; this will however only give context information
and not proof of achievement of the proposal objectives. The stakeholders’ assessments and
replies will be carefully analysed and may be followed-up if needed with additional
questionnaires or fact-finding activities.
Requests for information (reports, survey replies) must be carefully balanced not to cause
additional burden on the stakeholders by creating disproportionate new reporting requests. It
could be considered to develop a survey for regular consultation of stakeholders e.g. every
two years following implementation. Specific monitoring of Member States’ implementation
will also be done within the normal procedures for follow-up of legislation implementation,
including the launch of infringement procedures in case needed.
The progress indicators will show development over time, with the aim of reaching 100%
success rate for each indicator. However, the main usefulness of the progress indicators is to
identify areas or Member States where developments are slower, in order to set in appropriate
countermeasures and support measures (e.g. training, guidance, technical assistance).
Five years after the end of the implementation date of the legal proposal, the Commission will
also initiate an evaluation to verify whether the objectives of the initiative have been
reached, based on the first Member States reports and on the first surveys and other inputs
(e.g. complaints submitted) from shipping operators. The aim is to determine whether the new
measures in place have improved the situation. Subsequently, the evaluation will inform
66
future decision-making processes to ensure necessary adjustments for reaching the set
objectives.
Specific objective Operational
objectives
Progress indicator Success
criteria
Data sources
To harmonise
reporting
procedures,
interfaces and data
formats
 Establish technical
data set with
harmonised data
formats
 Develop and
implement common
harmonised
software for the
Nation Single
Windows
 Data set
established
 % of Member
States having
installed the
harmonised
reporting gateway
software
(synchronised,
updated version)
over total (Ref:
Total number of
MSs)
 % reduction in
time required for
reporting per port
call over total
(Ref: Average
time per port call)
 Data set
agreed by
the expert
group
 90-100%
of Member
States
installed
the
reporting
gateway
by
implement
ation
deadline
 50%
reduction
in
reporting
time per
port call
for vessels
in fixed
route
traffic;
75%
reduction
in
reporting
time per
port call
for tramp
traffic
vessels by
5 years
after
implement
ation
deadline
Member States
reports; surveys to
shipping operators;
number of
complaints by
shipping operators
regarding access to
harmonised
reporting gateway;
number of on-going
infringement
procedures against
Member States for
non-implementation
To reduce
administrative
burden through
single entry point
for reporting
 Reduce data
elements requested
outside the
harmonised
European Maritime
Single Window
environment for
maritime transport
 % of data
elements
requested outside
the harmonised
European
Maritime Single
Window
environment over
total. (Ref: Total
number of data
elements as
mapped by Part C
 0-5% of
data
elements
are
requested
separately.
Member States
reports; survey to
shipping operators
67
group and
eManifest group
today)
To increase
efficiency by
enabling reporting
only once
 Reduce static data
elements reported
more than once
 % of static data
elements
requested more
than once for a
port call over
total (Ref: Total
number of data
elements
requested in a
port)
 % of static data
elements
requested more
than once within
the EU (Ref:
Total number of
data elements
requested in the
EU)
 0-10% of
static data
elements
are
requested
more than
once in the
same port
call
 0-20% of
static data
elements
are
requested
more than
once
beyond the
same port,
within the
EU
Member States
reports; Survey to
shipping operators
68
Annex 1: Procedural information
Lead DG, Decide Planning/CWP references
The lead DG is DG MOVE, Unit D1: Maritime Transport and Logistics
DECIDE reference number: PLAN/2017/1050
Item 5 in Annex II to Commission Work Programme 2018: An agenda for a more united,
stronger and more democratic Europe112
.
Organisation and timing
The impact assessment follows the ex-post evaluation on the Reporting Formalities Directive
performed as part of the overall maritime transport policy fitness check in 2016-2017.
The impact assessment started in 2017, with the first meeting of the Inter-Service Steering
Group on 27 July 2017 and an inception impact assessment subsequently published on 28 July
2017113
. Eleven respondents submitted public feedback on the inception impact assessment
(see Annex: consultation synopsis report).
The Commission launched a call for tenders for a support study on “External Impact
Assessment support study on establishing European Maritime Single Window environment”.
A contract was signed with a consortium of Ecorys/COWI under contract reference
MOVE/DDG2.D1/FV-2017-271 implementing Framework contract No MOVE/A3/119-
2013/LOT4. The support study was performed 2017-2018.
The Inter-Service Steering Group met four times and was consulted throughout the different
steps of the impact assessment process: notably on the Inception Impact Assessment, on the
ToRs and call for tender for support study, on the consultation documents and on the draft IA
report.
The Commission Services participating in the ISG are: Secretariat-General, DG Maritime
Affairs and Fisheries, DG Taxation and Customs Union, DG for Communications Networks,
Content and Technology, DG Budget, DG Climate Action, DG Research & Innovation, DG
European Commission Humanitarian Aid & Civil Protection (ECHO), DG Migration and
Home Affairs, DG for Employment, Social Affairs and Inclusion, DG Industry,
112
COM(2017) 650 final
113
https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3807523_en
69
Entrepreneurship and SMEs, DG Environment, DG Health and Food Safety and the European
Maritime Safety Agency (EMSA).
Consultation of the RSB
The draft report was submitted to the RSB on 14 February 2017 and was discussed by the
Board on 7 March 2018. The Board issued a negative opinion on 9 March 2018. The Board
made several recommendations. These have been addressed in the revised Impact Assessment
report as detailed in the table below. This revised impact assessment report was re-submitted
to the Regulatory Scrutiny Board on 13 March 2018.
RSB recommendations Modification of the IA report
Main considerations
The report does not sufficiently explain the
options, including key design aspects,
implementation modalities and material
differences. As a result, the presented cost
differences between options are hard to
understand.
The text has been significantly revised to
provide more information on the description
and design of options; on the assumptions
made for these design choices; on the
technical functionalities of each option and
how they impact on the current National
Single Windows, and therefore also how
they impact the cost calculations for each
option. More information on cost
assumptions has been submitted by the
support study team and included into Annex
4. Clearer language has been adopted to
make it easier for readers to distinguish
between the new/changed functionalities
proposed (front-end reporting gateway) and
the functionalities remaining untouched
(National Single Windows role in data
distribution towards the back-end
connections).
See in particular extensive redrafting in
chapters 5, 6, 7 and 8 and new information
added in Annex 4.
The report does not adequately present
stakeholders' views. These views appear
central to selecting the preferred option, as the
The text has been updated notably in sections
7.1 and 7.6 to more clearly explain the
concern not only with the preferences of
70
report’s evidence of costs and benefits do not
clearly favour this option.
stakeholders but also with the resistance of
stakeholders against certain options and the
analysis of underlying reasoning by
stakeholders, leading to conclusions about
possibility of a compromise option. The
missing information has also been added in
Annex 2: consultation synopsis report (this
annex has also been shortened due to
translation requirements).
Further considerations
The report needs to provide a more
comprehensive overview of existing reporting
systems, including a description of how they
serve different vessel types and different
purposes. The report should explain why it is
necessary to maintain alternative reporting
systems in parallel with the European
Maritime Single Window (EMSW).
The report has been revised to provide more
information on the current and new reporting
scopes and their purposes. Clarifications
have been made to better explain the
rationale for not making the harmonised
reporting gateway mandatory for operators
and what this means in practice under the
different options.
See in particular sections 2.2, 5.2, 6.1.2 and
Annex 5.
The report should more clearly define the
problem and the problem drivers. The
evaluation concludes that the NSWs do not
deliver on the current directive’s objectives.
On the basis of the evaluation results, the
report should clarify whether the issue is the
current legal framework, deficits in
implementation or the poor workings of the
NSWs. The report should reconsider to what
extent the need for data re-use between port
calls can be justified by the (limited) reporting
costs for operators, once reporting is
harmonised. It seems that the need for data re-
use is more driven by efficiency gains for the
authorities and the possibilities for more
effective controls. The report should give the
reasons why the baseline expects that current
problems will persist.
The description of problem drivers has been
expanded and the role of the current
legislation and its implementation is clarified
(implementation of the current Directive will
not solve any of the main problem drivers
and is therefore not a sufficient solution; the
key conclusion of the evaluation was the
shortcoming of the RFD in terms of lack of
clear provisions which can only be addressed
by legal amendment). The data re-use
aspects have been specified and presented
more clearly and the baseline lack of
harmonisation has been more directly
explained. The reason why the problems are
highly unlikely to disappear in the baseline
scenario is described in more clear words.
See chapters 1, 2.1, 4.2, 5.2, 5.3, 6.1.1 and
71
6.1.2.
The report is unclear about key design aspects
of the options. As a result, it is not clear how
they would work. The report needs a stronger
presentation of the differences between the
options, especially with regard to how they
would co-exist with existing NSWs and other
reporting channels. It should detail the
functional differences between a harmonized
interface for the NSWs and a European
Maritime Single Window. It should give a full
account of what is required for NSWs to
interact through a harmonized interface or the
EMSW. It should also give more details on
governance and helpdesk functions and how
these would differ across options. The report
should also be explicit about when and on
what basis decisions on implementation
issues, such as who will develop and manage
the IT systems, will be taken.
The options are now described in much more
detail. A new section including comparison
table has been added (new 5.4) to help the
reader. Detailed information on governance
and helpdesk functions is added. Aspects
relevant for deciding implementation mode
(e.g. delegation of IT development tasks) are
mentioned.
See in particular chapters 5.2, 5.3, new 5.4,
6.1.2 and 7.6.
The report should better explain how this
initiative interacts with the parallel initiative
on paperless transport documents. It should
clarify to what extent the two initiatives
complement each other and how co-dependent
they are in reaching the set objectives and
realising the benefits. In particular, the report
should analyse to what extent the different
approaches of the two initiatives (harmonised
reporting system vs certification of systems)
could hamper the development of inter-modal
transport.
The link to the electronic freight transport
documents has been presented in more detail.
See chapter 1.3.
The report should expand its discussion of
stakeholders' views and their preferences
across the options. The current discussion
raises important questions that the report does
not fully answer. Different stakeholder
groups’ support for different options appears
to vary considerably, with little common
The key aspects of stakeholder opinions
regarding the options have been clarified and
more detail added. The selection of the
preferred option is explained in more detail.
The differences in costs (notably: Member
States’ costs) are explained more thoroughly
following the more detailed technical
72
ground besides the call for simplification. The
report therefore needs to be more specific on
how the results of the stakeholder
consultations and evidence of benefits and
costs have influenced the selection of the
preferred option. It could elaborate on various
concerns expressed by different stakeholder
groups, and how these factor into the
alternative options. The report should better
explain the reasons for differences between
cost estimates for the different options, based
on a clearer and more complete description of
the options.
descriptions of all options.
See especially chapters 5.3, 6.1.2, 7.1, 7.6, 8
and Annex 4.
The overall objective of the proposal is to
simplify reporting formalities though
harmonisation of the data requirements and
reporting systems. The report should show
how the preferred option will provide stronger
incentives for harmonisation compared to the
current framework of existing legal data
requirements. Also, the preferred option
should specify the choice of governance
model.
The difference between the proposed options
and the baseline situation with regards to the
harmonisation outcomes is more clearly
presented. The governance model is
specified for the preferred option.
See chapters 5.3, 5.4 and 8.
The Board issued a second, positive opinion on 20 March 2018 including some additional
recommendations. These have been addressed in the second revised Impact Assessment report
as detailed in the table below.
RSB recommendations Modification of the IA report
Main considerations
The problem description does not provide a
clear enough explanation of how the existing
systems for reporting formalities function
today. Relevant information is scattered
across the evaluation, the annexes and other
parts of the report.
More detailed information about current
reporting situation and especially the
different requirements for different vessel
categories, is added in sections 2.1 and 2.2
(P1).
The report does not specify when and on what
basis implementation issues will be decided,
Clarification and more detailed description is
added in section 5.4 and in chapter 8.
73
e.g. who will develop and manage the IT
systems.
Further considerations
The problem description should present a
more complete overview of the existing
reporting systems and their shortcomings. The
additions in annex 5 are welcome, and the
problem definition section would benefit from
incorporating more information from the
evaluation and annexes. A clearer description
of how the current system builds on different
reporting needs for different vessel types with
different purposes would better underpin the
argument for maintaining alternative systems
under the new Single Maritime Window.
More detailed information about current
reporting situation and especially the
different requirements for different vessel
categories, is added in sections 2.1 and 2.2
(P1).
The report has revised the arguments in favour
of data re-use. In particular, it presents the
potential for more efficient procedures for
ports and authorities and for cross-modal
information exchanges. The relevant specific
objective should integrate this modified
argumentation instead of continuing to refer to
reduced reporting costs for operators. It could
also clarify the importance of re-use in
selecting the preferred option.
Some clarification on the main benefit is
added in section 2.2 (P3). Where the
reference to reduced reporting burden is
retained it is explained with sources (the
study on eGovernment reduction of
administration burden and the consultation
outcomes).
The revised version of the report clarifies the
differences between the options. Renamed
options and a new comparison table are
helpful. Nevertheless, the illustrations of the
different policy options in Annex 6 are not
intuitive. Simpler illustrations, accompanying
explanations or both would be helpful and
would add to clarity. A simple illustration
showing the different options could be added
to the options section.
Illustrations of the options are added in
sections 5.3.1 – 5.3.6.
The illustrations in Annex 6 are
complemented by explanatory text.
The report indicates that the Commission
would probably assign IT development to a
specialised entity, but it does not specify when
and on what basis this would happen. The
report should at least be explicit about the
The timing and decision on detailed
implementation mechanisms (e.g.
outsourcing contracts and division of specific
tasks between Commission services and
decentralised agencies) is clarified in
74
process. If the decision is part of the
legislative proposal, the impact assessment
needs to include the underlying analysis.
sections 5.4 and in chapter 8.
The Board takes note of the quantification of
the various costs and benefits associated to the
preferred option of this initiative, as assessed
in the report considered by the Board and
summarised in the attached quantification
tables. The attached quantification tables may
need to be adjusted to reflect any changes in
the choice or the design of the preferred
option in the final version of the report.
The information in the quantification tables
has been double-checked and remains
correct.
Evidence, sources and quality
The impact assessment is based on a several sources, using both quantitative and qualitative
data. This includes:
• Ex-post evaluation of the Reporting Formalities Directive
• In-depth case studies of five selected ports (Malmö/Copenhagen, Hamburg,
Constantza, Bari and Helsinki)
• Public on-line consultation (91 respondents)
• Targeted consultations via surveys (111 respondents) and consultation events (5
workshops and meetings with a total of 167 participants)
• 74 interviews (face-to-face or per phone) with stakeholders representing different
interests
• External support study by Ecorys/COWI including IT cost assessments
• Reporting time estimate model developed in consultation with ECSA and their
associated members
• Baseline scenario based on updated EU Reference scenario 2016, developed with
the PRIMES-TREMOVE model by the ICCS-E3MLabLiterature review on
relevant material relating to the directive
75
Annex 2: Stakeholder consultation
Synopsis report on the consultations for impact assessment of Directives 2010/65/EU on
Reporting Formalities for ships arriving in and/or departing from ports of the Member
States (RFD)
1. Introduction
In June 2017, the European Council invited the Commission to propose follow-up to the revision of
Directive 2010/65/EU on Reporting Formalities for Ships (hereafter the RFD). In the preparation of
the initiative, extensive consultations were carried out to inform the impact assessment process.
2. Methodology and Consultation Activities
The consultations comprise an Open Public Consultation (OPC) and targeted consultations (TC)
including consultation events and workshops, interviews, case studies and an e-survey. Written
contributions submitted by the stakeholders have also been received.
Open Public Consultation (OPC)
The OPC online survey was open from 25 October 2017 to 18 January 2018 and available in all
official EU languages. In total, 91 replies were received. 13 of these stakeholders also uploaded
position papers with their responses114
.
Targeted Consultations (TC)
Survey
The survey was sent by email to over 250 stakeholders with a diverse geographic spread. Additionally,
20 relevant EU-wide industry associations were asked to share the survey with their members. In total,
111 responses were received. The survey was open from 21 December 2017 to 12 January 2018.
Interviews
Targeted in-depth interviews have been completed with 74 representatives of the key stakeholder
groups. Each interview lasted approximately 1-1.5 hours. The interviews were conducted from 4
December 2017 to 5 January 2018.
Case study field visit interviews
114
https://ec.europa.eu/info/consultations/public-consultation-reporting-formalities-ships-european-maritime-
single-window-environment_en
76
Some interviews were completed as part of five in-depth case studies with field visits to ports:
Hamburg (DE), Bari (IT), Constantza (RO), Helsinki (FI), Copenhagen/Malmo (DK/SE). These ports
are from different sea basins, with different size, traffic and level of implementation of National Single
Windows. Each visit lasted at least one day and included several interviews, mainly with port
authorities, shipping companies and ship agents.
Consultation events/workshops
Five workshops were organised for focused discussions with the main stakeholder groups. One
broader workshop took place at the Digital Transport Days. In total, 167 persons participated in the
events. Participants were also offered to contribute additional inputs in writing. Written
contributions115
were submitted by eight Member States, one industry stakeholder and one port
association.
Workshop Date Participants
Additional
Contributions
ESPO consultation
meeting
24 October 2017
13 ports and port
associations
n/a
Consultation with the
High Level Steering
Group: Single Window
Subgroup
26 October 2017
16 Member States and
Norway, 2 port
associations, 2 shipping
associations, 1 ship agent
association
6 contributions by Spain,
France, Italy, Germany,
Poland and ESPO
Digital Transport Days
in Tallinn: consultation
workshop
8 November 2017
65 mixed participants from
different stakeholder
groups
1 contribution by Spain
ECSA consultation
meeting
15 November 2017
18 representatives of ship-
owners’ associations and
shipping companies /
shipping company
associations
n/a
CUSTOMS 2020 Project
Group meeting
15 December 2017
Customs experts from 18
different Member States +
observers (industry,
stakeholder associations)
2 contributions by custom
authorities from Poland
and Italy, one from
CEFIC
Table 5 - Overview of the workshops conducted by DG MOVE
Outreach was done via the DG GROW SME network, informing SMEs about the consultation
opportunities and inviting them to the OPC.
115
Published on the Commission consultation website
77
Similarly, the European social partners116
were approached to ensure the dissemination of the
consultation invitations to the maritime transport professionals and the trade unions in the maritime
sector.
Identification of Stakeholders
Stakeholders from 29 countries (26 EU Member States) and 16 EU-wide representatives have been
consulted.
116
http://ec.europa.eu/social/main.jsp?catId=480&langId=en&intPageId=1844
Open Public Consultation
92 replies received
Publicly accessible
Online platform
Targeted consultation
Targeted Survey
>250 stakeholders approached
111 responses received
Online survey
Targeted Interviews
Target exceeded: 74 interviews, including 5
field visits
In person/phone interivews
Consultation events /workshops
Feedback submitted on IIA
HLSG expert sub-group event
Digital Transport Days in Tallinn
CUSTOMS 2020 Project Group
ECSA consultation meeting
ESPO consultation meeting
Other position papers & meetings
Around 167 stakeholders reached
78
Figure 1 - Overview of the respondents per type of stakeholders
Replies were received from all maritime Member States, with higher participation in the e-surveys
from Germany, Sweden, Belgium, Denmark, Finland and the Netherlands. Fewer respondents
participated from Ireland, Lithuania, Cyprus, Greece and Croatia. No views at all were received from
two of the landlocked Member States: Austria and Hungary.
Figure 2 - Geographical overview of the respondents by consultation activities (excluding double responses, n=250)
The possible bias from the uneven participation has been managed by weighting the inputs from the
European associations representing the entire geographic range. Respondents for the TC interviews
were also selected to achieve a broad geographic spread and a wide representation of different
2 1
15
10
2 1 2
5 4
1
5
1 1 1
4
2 1
3 4
1
5
3
7
1 1
4
1
4
8 2 3
5
2
9
2
12
3
2
7
4
1 1
8
2
3
2
8
5
12
2
9
2
2
4
7
1
5 1
8
2 1 2
7
2
2
0
5
10
15
20
25
30
BE
BG
CY
CZ
DE
DK
EE
EL
ES
FI
FR
HR
IT
LT
LU
LV
MT
NL
PL
PT
RO
SE
SI
SK
UK
IE
EU
EEA/EE…
Non-EU
Interview OPC Survey
79
stakeholders (size and type of companies, interests represented, etc.). The limitation of the lower
participation from the Mediterranean sea basin was discussed with the European Community
Shipowners' Association (ECSA) who consider the overall results still to be solid and valid as there is
no major difference in reporting burden between the different sea basins; the main factor impacting
reporting burden is rather by type of traffic and vessel.
3. Results of the Consultation Activities on RFD 2010/65/EU
Feedback on the Inception Impact Assessment
Feedback on the Inception Impact Assessment (IIA) was received from eleven stakeholders: six
international associations, one Member State, one Port Community System and three others (shipping
related company, citizens).
All these contributors agreed with the Commission problem analysis, although the Member State and
the port organisation stressed that the RFD had also achieved some of its objectives (notably: higher
level digitalisation). Harmonisation was stressed by all as the main priority to be addressed. One
respondent mentioned the need to broaden the scope of the RFD. The Member State and the two port
associations voiced concerns regarding the possibility of solving the “reporting only once” problem;
the two major shipping associations on the other hand emphasised this as a crucial priority to address.
Several stakeholders raised the importance of building on existing standards and systems. The port
community systems association supported EDIFACT as standard protocol. From the shipping
operators, concerns were raised on the option of reporting via port community systems rather than via
public national single windows as this would be a disproportionate and unrealistic option.
Problem definitions
The problem of the current RFD affects in particular the shipping companies and ship agents; these
groups also voiced the strongest critique against the lack of harmonisation, lack of a single reporting
entry point and inefficient re-use of reported data (in particular static information).
Also other stakeholders in the OPC and TC agree with the identified shortcomings of the RFD and
notably the significant administrative burden on shipping companies. It is stressed in particular that the
excessive administrative burden undermines the attractiveness of the maritime transport and places it
in a disadvantageous position.
The stakeholders with least agreement on the problem description are found primarily among ports
and port community systems providers. This is not surprising as the ports are generally not negatively
affected by the lack of harmonisation.
Subsidiarity
The majority of the stakeholders consulted in the OPC (82%) confirm that the RFD issues will be
more efficiently addressed at the EU level (91% of shipping companies; 92% of ship agents; 70% of
Member State authorities; 59% of port operators and 60% of the port community service providers).
When asked about whether the EU action should be mandatory, 83% of OPC respondents agree with
the statement. The European associations for shipping operators and agents, such as ECSA and the
European Community Association of Ship Brokers and Agents (ECASBA), strongly agree that the
80
action should be mandatory. This is also supported by all shipping companies in the survey and by the
European port associations (Federation of European Private Port Companies and Terminals, FEPORT;
European Sea Ports Organisation, ESPO). Only two stakeholders (2%) strongly disagree with the
statement that actions should be mandatory: one ship agent and one port operator.
Options
Increased EU level harmonisation: addressing problem driver 1
While there was strong agreement among all OPC respondents that harmonisation will bring some or
even high benefits, there was strong fragmentation among the stakeholder groups regarding choice of
policy option.
In the OPC, respondents were asked to consider the options of no legal action, harmonisation based on
current National Single Windows and harmonisation based on a centralised solution. Overall, a
significant majority considered the “no legal action” option (option 0) to be either not (37%) or only
slightly (35) effective. The different stakeholder categories replied rather similarly on this.
Options based on the National Single Windows (options A and B) were seen as mostly moderately
effective (33%) or very effective (23%). 71% of shipping companies and 74% of ship agents
considered this to be moderately, very or extremely effective, with 12% of shipping companies
replying it would be extremely effective. Port operators were more sceptical with only 42%
considering it to be at least moderately effective. Among Member States, 17% considered the option
extremely effective and in total 58% thought it moderately or more effective.
The centralised solution (option C) received high overall support in the OPC with a large share of
respondents considering it very effective (33%) or extremely effective (29%). On this option however
the views differed highly among stakeholder categories. 92% of shipping companies and 83% of ship
agents considered this option to be very or extremely effective. Port operators on the other hand
mainly considered it not effective at all (34%) and among Member State authorities 13% thought it
would be not effective and 35% only slightly effective.
81
Figure 9: Overall assessment of harmonisation options (OPC)
These differences among stakeholder groups were mirrored in the TC where respondents could choose
between five more detailed options117
. The most preferred option in total numbers was option C
(chosen by 30% of all respondents), followed by option A (26% of all respondents). Option B was
preferred option by 18% of all respondents. It should be noted that in the interviews, participants could
select more than one option as preference.
Option C (centralised solution) is the most preferred by shipping companies and ship / cargo agents
(43%) in the TC.
117
A: National Single Window solution based on technical specification; B: National Single Window solution
based on common interface software; C: centralised European Maritime Single Window; D: mandatory Port
Community System solution (discarded) and 0: no legal action / baseline
0,0% 20,0% 40,0% 60,0% 80,0% 100,0%
OPC: Benefits from harmonisation
No opinion Low benefits Some benefits High benefits
0,0% 20,0% 40,0% 60,0% 80,0% 100,0%
OPC: No legal action
No opinion Not at all effective
Slightly effective Moderately effective
Very effective Extremely effective
0,0% 20,0% 40,0% 60,0% 80,0% 100,0%
OPC: NSW-based solution
No opinion Not at all effective
Slightly effective Moderately effective
Very effective Extremely effective
0,0% 20,0% 40,0% 60,0% 80,0% 100,0%
OPC: Centralised solution
No opinion Not at all effective
Slightly effective Moderately effective
Very effective Extremely effective
Figure 10: Preferred option per stakeholder category
82
Member State authorities expressed strongest preference for a solution based on the current National
Single Windows (40% for A: technical specifications; 30% for common software). The support for
status quo and no legal action (option 0) is the lowest among Member State authority respondents
(only 2%). The preference for options A or B also came out very strongly from the consultation
events, where Member States voiced strong opposition to a centralised solution.
Port operators and port community systems express the lowest support for a centralised option (15%)
and slightly higher preference for no legal action (10%). The largest support from this group was for
the discarded option D: mandatory port community systems (31%).
Establishing a single reporting entry point: addressing problem driver 2
83% of all OPC respondents support the proposal to include national requirements (current part C of
the RFD) into the mandatory scope of the new reporting environment.
The inclusion of national reporting requirements is supported by both shipping operators (96%), ship
agents (82%), port operators (91%) and port community system providers (100% of OPC
respondents).
Member State authorities were predictably less interested in such inclusion with only 52% agreeing or
strongly agreeing to the statement (5% neutral, 23% didn’t know and 18% in disagreement).
Figure 4 – OPC results: “National reporting requirements should be included in the new framework”
The majority of the shipping companies, port operatorship agents and others perceive that the benefits
from including the national requirements will be higher for them than the overall costs.
In regard to a harmonised reporting environment data set, shipping companies and ship agents request
rationalisation of data, limiting the reporting to the extent possible by clearing out non-essential data
requests. The World Shipping Council (WSC) stated that 'maritime carriers need a single harmonised
list of data elements that are genuinely necessary for EU wide port clearance.'
83
The question of the scope was further addressed in the targeted consultations, where stakeholders were
asked also about inclusion of customs formalities.
The majority (73%) of the respondents to the targeted survey believe that it is both technically feasible
and beneficial to integrate customs and maritime reporting in one window. Especially shipping
companies (93%) and ship or cargo agents (85%) request inclusion of customs formalities, as they
consider that this would simplify their reporting procedures. Around 79% of Member State authority
respondents consider it both technically feasible and beneficial to integrate customs and maritime
reporting. The two contributions received as part of the consultations with the customs expert group
are also generally positive to such developments. On the other hand, only 57% of the port community
system providers (25% don’t know) and 71% of the ports (12% don’t know) consider this measure
beneficial.
Figure 5 – TC result: “Would it be beneficial if customs reporting went via the same single window as maritime
transport reporting”
Benefits from more data sharing and data re-using: addressing problem driver 3
81% of respondents to the OPC expect to have some or high benefits from more data sharing and data
re-use. In the targeted interviews, shipping companies show strong support of legislative measures that
encourage data sharing and data reuse and that provide clear definitions for the different reporting
requirements. The importance of the “reporting only once” principle was stressed in interviews and
survey comments by several stakeholders including e.g. ECSA and WSC.
Technical elements of the revised RFD
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%100%
Ship or Cargo Agent
Member State Authority
Other (NGO, Trade Union, Citizen, etc.)
Port Community Systems and other ICT
System Providers
Port Operators and their Associations
Shipping Company (including Ship Masters)
and their Associations
I do not know No Yes
84
Regarding governance of the new reporting environment, OPC respondents highlighted the importance
of consultation with and involvement of the industry in connection to technical updates of the
reporting environment (important or very important priority to 67% of all respondents).
Stakeholders have also been asked about various technical elements in the OPC that could be included
or further developed in the revised RFD such as e-certificates and private data.
Provisions for acceptance of e-certificates to allow for future fully paperless ships are supported by
76% of all respondents to the OPC. Especially ship agents (83%) and shipping companies (68%)
expect higher benefits from provisions to accept e-certificates.
In the specific targeted consultations, issues regarding personal data reporting were also brought in,
following requests in the consultation events during autumn. Across all categories, stakeholders in the
targeted consultations agree that it will be highly relevant to clarify inclusion of personal data into the
harmonised reporting environment in a manner that is in full compliance with the new General Data
Protection Regulation (GDPR). This will provide added value especially for the SME segment of the
private maritime sector (shipping companies, agents, port operators, PCS and ICT providers). The
consulted SMEs report to struggle to integrate the requirements of the complex GDPR in their
business models and would benefit especially from clarified provisions.
Impacts
When it comes to benefits of increased EU level harmonisation, according to the OPC results, 87% of
respondents stated that increased EU-level harmonisation of reporting standards, procedures and
interfaces is expected to bring benefits to them. 52% of all respondents expect these benefits to be
high, mainly expected by the shipping companies (79%). When talking about the cost of
harmonisation, 39% expect to have some cost of adaption - 17% expect these costs to be high (mainly
port operators, PCS providers and Member State authorities).
Figure 6 - OPC results: Shipping companies' expected impact in terms of reduction of administrative burden
During the TC survey and the interviews, respondents were also asked to assess economic, social and
environmental impacts of the different policy options. Shipping companies expect the largest impact
on the administrative burden from option C (centralised solution) as a first step towards a level playing
field with road transports. This would therefore support a modal shift towards the more cost effective
maritime transport, with environmental benefits as a result. Shipping companies also find that
0% 20% 40% 60% 80% 100%
Option A
Option B
Option C
Option D
Option 0
I do not know
No impact
Low impact
Medium impact
High impact
85
harmonised reporting will improve working conditions for ship masters and the attractiveness of the
sector.
Figure 7 – TC results: Overall job quality, Stakeholders’ expected impact
Notably ship agents also stressed in the TC that they see some business opportunities arising from
harmonised reporting, especially in combination with better re-use and sharing of data. This would
allow them to focus on more value adding work than reporting.
0% 20% 40% 60% 80% 100%
Option A
Option B
Option C
Option D
Option 0
I do not know
Strongly negative
Negative
Neutral
Positive
Strongly positive
86
Annex 3: Who is affected and how?
Practical implications of the initiative
 For Member States, national competent authority in charge of the National Single
Window: by implementation deadline, to make necessary preparations to install the
common EU reporting gateway IT solution and to adapt the National Single Window
to be in line with the new technical specifications. To ensure proper connections from
the National Single Window to the relevant back-end entities (data recipients).
 For connecting back-end authorities (data recipients), by implementation deadline, to
ensure systems are ready to be interoperable with the updated National Single
Windows.
 For port operators and other connected private entities: by implementation deadline,
adapt as/if needed the systems and connections to the National Single Window to
enable reception of data in harmonised format.
 For shipping operators: if choosing to report via the harmonised maritime reporting
environment, to adapt systems and data to the harmonised EU format.
Summary of costs and benefits
I. Overview of Benefits (total for all provisions) – Preferred Option B1
Description Amount Comments
Direct benefits
Reduced time spent on
reporting for shipping
operators (ship masters)
22-25 million staff hours in the
time period 2020-2030;
equivalent to a value of EUR
625-720 million
Main beneficiary: Maritime transport operators
High priority for European shipping companies
and ship agents; high pressure from these
stakeholder groups to remedy the current
situation.
Indirect benefits
Increased competitiveness of
the maritime transport sector
as administrative burden is
reduced, reporting is
simplified and data more
efficiently used and shared
A possible shift of 3,395 million
tonne-kilometres to waterborne
transport in 2030, mostly away
from road. This represents about
0.3% increase in the transport
activity of the waterborne
transport in 2030 relative to the
baseline.
Modelling performed with the PRIMES-
TREMOVE and TRUST models.
In line with the overall Commission Transport
Policy (see: Transport White Paper, 2011) modal
shift objectives.
Efficiency gains for entire
multimodal / logistics chain
from better use of data in
ports: e.g. harmonised
provision and efficient and
appropriate re-use of arrival
or departure times will
enable transport and
logistics service providers to
optimise the flow of cargo in
and out of ports in real-time.
Non-quantifiable. The efficiency of the ship port calls will impact
on the entire logistics chain and the hinterland
transports of goods and passengers to and from
the ports (per road, rail, pipeline or inland
waterways).
Stressed by several stakeholders in the
consultations.
87
Increased job satisfaction for
ship masters; higher
attractiveness of profession
leading to improved
possibilities for recruitment
Non-quantifiable. The European maritime industry suffers from an
increasing lack of European seafarers, in
particular officers. Such a shortage is likely to
increase in the coming years to the detriment of
the maritime industry, which needs maritime
expertise and experience. A main objective of the
European maritime policy is therefore to improve
employment and working conditions for seafarers
on board EU-flagged ships, to make the maritime
profession more attractive and ensure compliance
with established training standards.
The most commonly mentioned indirect benefit
from harmonisation, voiced by a high number of
shipping companies and ship agents in the various
consultations.
Safety and security gains as
ship master can spend more
time on the bridge
Non-quantifiable. Commonly stressed by shipping companies in the
targeted consultations as likely indirect,
unquantifiable benefit.
Better information flows to
inform better governance
and public services
Non-quantifiable. Member State authorities likely to benefit
indirectly from the improved data flows and
access to harmonised data; notably in the long-
term with future developments of cross-border
data exchanges.
Reduction of CO2
emissions: environmental
impact
Freight transport emissions are
estimated to decrease by 1,880
thousand tonnes of CO2 relative
to the baseline due to the modal
shift (see above). This translates
into around €145 million of
indirect benefits over 2020-2030,
expressed as present value.
In line with the overall Commission Policy
environmental objectives
II. Overview of costs – Preferred option B1
Citizens/Consumers Businesses (shipping operators) Administrations (MS)
One-off Recurrent One-off Recurrent One-off Recurrent
Direct costs
n/a n/a Adaptation
costs ; not
quantified
Adaptation to
regular updates
of formats; not
quantified
Average
340 000 per
Member
State
Average 350
000 per
Member State
(2020-2030)
Indirect costs n/a n/a n/a n/a n/a n/a
88
Annex 4: Analytical methods
The analytical work for this impact assessment is based on the PRIMES-TREMOVE transport
model and TRUST model. The model suite covers the entire transport system (e.g. transport
activity represented at Member State level, by origin-destination and at link level,
technologies and fuels at Member State level, air pollution emissions at Member State and
link level and CO2 emissions at Member State level):
 Geographical coverage: EU level, all Member States separately.
 Time horizon: 2005 to 2050 (5-year time steps).
 Transport modes covered for freight transport: road freight (heavy goods vehicles,
light commercial vehicles), freight rail, freight inland navigation, international
shipping. Numerous classes of vehicles and transport means with tracking of
technology vintages.
 Regions/road types: traffic represented at country level in PRIMES-TREMOVE; by
NUTS 3 region in TRUST model.
In addition, an excel based tool has been developed by COWI/Gartner for calculating the
costs related to the IT systems.
1. Description of analytical models used
1.1 PRIMES-TREMOVE transport model
The PRIMES-TREMOVE transport model projects the evolution of transport demand by
transport mode and transport mean. It is essentially a dynamic system of multi-agent choices
under several constraints, which are not necessarily binding simultaneously. The projections
include details for a large number of transport means, technologies and fuels, including
conventional and alternative types, and their penetration in various transport market segments
for each EU Member State. They also include details about greenhouse gas and air pollution
emissions (e.g. NOx, PM, SOx, CO), as well as impacts on external costs of congestion, noise
and accidents.
In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. eco-
driving, deployment of Intelligent Transport Systems, labelling), economic measures (e.g.
subsidies and taxes on fuels, vehicles, emissions; ETS for transport when linked with
PRIMES; pricing of congestion and other externalities such as air pollution, accidents and
noise; measures supporting R&D), regulatory measures (e.g. CO2 emission performance
standards for new passenger cars and new light commercial vehicles; EURO standards on
road transport vehicles; technology standards for non-road transport technologies),
infrastructure policies for alternative fuels (e.g. deployment of refuelling/recharging
infrastructure for electricity, hydrogen, LNG, CNG). Used as a module which contributes to a
broader PRIMES scenario, it can show how policies and trends in the field of transport
89
contribute to economy wide trends in energy use and emissions. Using data disaggregated per
Member State, it can show differentiated trends across Member States.
PRIMES-TREMOVE transport model has been used for the 2011 White Paper on Transport,
Low Carbon Economy and Energy 2050 Roadmaps, the 2030 policy framework for climate
and energy and more recently for the Effort Sharing Regulation, the review of the Energy
Efficiency Directive, the recast of the Renewables Energy Directive, the 2016 European
strategy on low-emission mobility, the revision of the Eurovignette Directive and the recast of
the Regulations on CO2 standards for light duty vehicles.
The PRIMES-TREMOVE is a private model that has been developed and is maintained by
E3MLab/ICCS of National Technical University of Athens118
, based on, but extending
features of the open source TREMOVE model developed by the TREMOVE119
modelling
community. Part of the model (e.g. the utility nested tree) was built following the TREMOVE
model120
. Other parts, like the component on fuel consumption and emissions, follow the
COPERT model.
As module of the PRIMES energy system model, PRIMES-TREMOVE121
has been
successfully peer reviewed122
, most recently in 2011123
.
1.2 TRUST transport network model
TRUST (TRansport eUropean Simulation Tool) is a European scale transport network model
covering road, rail and maritime transport124
. TRUST covers the whole Europe and its
118
Source: http://www.e3mlab.ntua.gr/e3mlab/
119
Source: http://www.tmleuven.be/methode/tremove/home.htm
120
Several model enhancements were made compared to the standard TREMOVE model, as for example: for
the number of vintages (allowing representation of the choice of second-hand cars); for the technology
categories which include vehicle types using electricity from the grid and fuel cells. The model also
incorporates additional fuel types, such as biofuels (when they differ from standard fossil fuel technologies),
LPG and LNG. In addition, representation of infrastructure for refuelling and recharging are among the
model refinements, influencing fuel choices. A major model enhancement concerns the inclusion of
heterogeneity in the distance of stylised trips; the model considers that the trip distances follow a distribution
function with different distances and frequencies. The inclusion of heterogeneity was found to be of
significant influence in the choice of vehicle-fuels especially for vehicles-fuels with range limitations.
121
The model can be run either as a stand-alone tool (e.g. for the 2011 White Paper on Transport and for the
2016 Strategy on low-emission mobility) or fully integrated in the rest of the PRIMES energy systems model
(e.g. for the Low Carbon Economy and Energy 2050 Roadmaps, for the 2030 policy framework for climate
and energy, for the Effort Sharing Regulation, for the review of the Energy Efficiency Directive and for the
recast of the Renewables Energy Directive). When coupled with PRIMES, interaction with the energy sector
is taken into account in an iterative way.
122
Source: http://ec.europa.eu/clima/policies/strategies/analysis/models/docs/primes_model_2013-2014_en.pdf.
123
https://ec.europa.eu/energy/sites/ener/files/documents/sec_2011_1569_2.pdf
90
neighbouring countries and allows for the assignment of origin-destination matrices at NUTS
3 level (about 1600 zones) for passenger and freight demand.
TRUST projects the average daily loads on road links split by demand segment and by
country of origin, road traffic activity (passenger-km, tonnes-km, vehicle-km) per year by
country (based on territoriality principle), origin-destination journey time, road accessibility
measures by NUTS 3 region, energy consumption and emissions of NOx, PM, VOC, CO and
CO2 by link. TRUST rail network includes different link types according to technical
elements (number of tracks, electrification, maximum speed allowed, etc.).
TRUST models maritime connections between the main ports in Europe through links
simulating sea routes and allows the computation of distances and cost of maritime transport.
TRUST also simulates feeder modes accessing ports (e.g. truck, rail or inland waterways
according to existing infrastructures) allowing the definition of full path between true origin
and final destination of freight. Ports are classified into three categories: bulk ports, container
ports and general cargo ports. Most of the ports belong to more than one category but some
ports have only one or two specialisation. Maritime demand consists of origin-destination
matrices segmented according to the three freight categories of bulk, container and general
cargo.
TRUST is suitable for modelling policies in the field of infrastructure (e.g. completion of the
core and comprehensive TEN-T network) and road charging schemes for cars and heavy
goods vehicles.
TRUST is a private model, developed and maintained by TRT125
. It has been used for the
impact assessment accompanying the revision of the Eurovignette Directive, the 2013 ex-post
evaluation of transport infrastructure charging policy, for the TRACC - TRansport
ACCessibility at regional/local scale and patterns in Europe126
and for other TEN-T projects
focusing on e.g. improving the ports and multimodal transport links of the northern
Adriatic127
.
1.3 COWI/Gartner model for IT system costs
An excel based tool has been developed by Gartner (COWI sub-contracting partner for the
support study) for calculating the costs related to the IT system. The cost model was
124
See Annex A of Ricardo et al. (2017) Support Study for the Impact Assessment Accompanying the Revision
of Directive 1999/62/EC.
125
Source : http://www.trt.it/en/tools/trust/
126
http://www.espon.eu/main/Menu_Projects/Menu_ESPON2013Projects/Menu_AppliedResearch/tracc.html
127
https://ec.europa.eu/inea/en/ten-t/ten-t-project-implementation-successes/improving-ports-and-multimodal-
transport-links-northern
91
developed to estimate the investments and ongoing costs for implementing the policy options.
The model estimates this both for EU and for the Member States (MS).
In order to estimate the MS cost of the three retained policy options, the assumption is that
the complexity of the NSW and therefore the complexity of implementing the policy options
is functionally the same across the MS. In reality, most MSs should experience lower actual
investments than estimated in this study.
The following two factors are driving the differences in costs between Member States, among
systems of similar functional scope: Cost of developers and Number of national authorities
(i.e. authority interfaces) using the NSW.
The Gartner labour rate database for IT staff has been used to assess the differences in cost of
developers across the Member States. The rates used in the cost model are average seniority
rates. The estimates for each of the MSs have been adjusted with a factor relative to the
European average. The European average day rate is EUR 906,-. For instance, the average
rate in Germany is EUR 1102,-, while in Poland it is EUR 506,-.
It is also assumed that all MSs either have an existing NSW or an ongoing NSW
implementation (legal requirement of current RFD). This means that reuse of the authority
interfaces in the existing NSW is assumed in all retained policy options. A reservation for
resources needed to adapt these interfaces is estimated, however not development from
scratch.
The costs modelled for the EU in the three retained policy options build on a detailed
breakdown for the functionality and for the required IT infrastructure.
The following data sources have been used to populate the cost model for the EU costs:
 EU pan-European systems Peers: Through a number of engagements for the
Commission, Gartner has collected data on estimate levels of budget for different
activities, such as communication, training and stakeholder management that consider
the special governance and working conditions for EU-wide systems.
 Gartner Cost Benchmark data: Anonymised data pointers from peers engaged in cost
benchmarks with Gartner and supplied using Gartner’s standard IT accounting model.
This ensures a very high degree of comparability and possibility to normalise across
collected data. These data mainly exist for very mature environments, such as
infrastructure areas.
 Gartner IT Key Metrics: On a yearly basis, Gartner conducts a survey covering
companies using IT in order to data on spending within all the IT domains. These data
are available by geography and industry, and are used to capture trends in spending, as
well as typical division of costs among areas. The Gartner IT Key Metrics also include
average costs for key cost elements, such as Windows server costs.
 Case data: These are anonymised data pointers collected in Gartner’s engagements
with clients that cover e.g., project costs that can be used for sanity checks of
developed cost models or to provide high-level cost indications. Such case data is
currently available for 20 pan-European information systems.
92
The model of the EU costs is a 10 year TCO model, estimating the total costs (investments
and ongoing costs). Where relevant (e.g., for IT hardware), a TCO figure has been used,
which includes depreciations. This means that the model is stable and can be projected
beyond the 10 years, unless changes in the assumptions occur.
The model assumes that the efforts for the EU can be undertaken within existing organisations
of the EU, therefore it does not include costs for e.g., establishing a new European agency.
The cost model for the EU uses the comprehensive Maritime Single Window data set as a
starting point for estimating the complexity of the MSW. The functional complexity of the
EMSW is independent of whether it is operated by the MSs (Policy Option B and C) or
operated centrally (Policy Option D).
The functional breakdown is done with the Fast Function Point Analysis (FFPA)
methodology. FFPA is a Gartner adaption of the FPA methodology, which is a method for
assessing the complexity of a system, independent of the programming language it will be
built and maintained. FFPA has proven useful in estimating both development and
maintenance efforts for applications across different types of projects and systems.
Gartner has systematically collected data points regarding functional complexity (number of
function points) and the required effort to develop and maintain a piece of software. We can
therefore use FFPA to provide a sensible estimate of the cost of developing a system like the
EMSW. The number and type of resources for building the EMSW was determined in line
with the following steps:
 Counted the expected Functional Size (in FP) per building block for each policy
option,
 Determined the expected unit development effort (person days per developed FP) per
building block. This is selected from the Gartner benchmarking database based on the
following criteria: size in FP, technology mix, requirements stability, and non-
functional requirements,
 Calculated the total development effort (per building block or per policy option) by
multiplying the expected number of FPs (derived from step 1) with the expected unit
effort (person days/FP derived from step 2).
1.4 PRIMES-TREMOVE, TRUST and COWI/Gartner tool role in the impact
assessment
The PRIMES-TREMOVE transport model is a building block of the modelling framework
used for developing the EU Reference scenario 2016, and has a successful record of use in the
Commission's transport, climate and energy policy analytical work – it is the same model as
used for the 2011 White Paper on Transport and the 2016 European strategy on low-emission
mobility. In this impact assessment, it has been used to define the Baseline scenario, having as
a starting point the EU Reference scenario 2016 but additionally including few policy
measures that have been adopted after its cut-off date (end of 2014).
93
TRUST model is a European scale transport network model that allows for the assignment of
origin-destination matrices at NUTS 3 level for passenger and freight demand. In addition, it
provides the maritime connections between the main ports in Europe through links simulating
sea routes and allows the computation of distances and cost of maritime transport. At Member
State level, the Baseline trend of transport activity in TRUST has been calibrated on
PRIMES-TREMOVE projections.
PRIMES-TREMOVE transport model together with the TRUST model have been used to
assess the impacts of the policy options on modal shift. More specifically, the time savings
achived by the ship operators in the policy options relative to the Baseline have been used to
calculate the impacts on the generalised transport costs by origin-destination with the TRUST
model. The changes in the generalised transport costs have been subsequently used in
PRIMES-TREMOVE to derive the impacts on modal shares for all freight transport modes
together with their impacts on CO2 and air pollutant emissions.
The excel based tool developed by COWI/Gartner has been used for calculating the costs
related to the IT system: costs for EU and Member States respectively and taking into account
bothe the one-off investments required and the operational costs during the baseline period
until 2030.
2. Baseline scenario
The Baseline scenario used in this impact assessment builds on the EU Reference scenario
2016 but additionally includes few policy measures adopted after its cut-off date (end of
2014). Building an EU Reference scenario is a regular exercise by the Commission. It is
coordinated by DGs ENER, CLIMA and MOVE in association with the JRC, and the
involvement of other services via a specific inter-service group.
For the EU Reference scenario 2016, Member States were consulted throughout the
development process through a specific Reference scenario expert group which met three
times during its development. Member States provided information about adopted national
policies via a specific questionnaire, key assumptions have been discussed and in each
modelling step, draft Member State specific results were sent for consultation. Comments of
Member States were addressed to the extent possible, keeping in mind the need for overall
comparability and consistency of the results. Quality of modelling results was assured by
using state of the art modelling tools, detailed checks of assumptions and results by the
coordinating Commission services as well as by the country specific comments by Member
States.
94
The EU Reference scenario 2016 projects EU and Member States energy, transport and GHG
emission-related developments up to 2050, given current global and EU market trends and
adopted EU and Member States' energy, transport, climate and related relevant policies.
"Adopted policies" refer to those that have been cast in legislation in the EU or in MS (with a
cut-off date end of 2014128
). Therefore, the binding 2020 targets are assumed to be reached in
the projection. This concerns greenhouse gas emission reduction targets as well as renewables
targets, including renewables energy in transport. The EU Reference scenario 2016 provides
projections, not forecasts. Unlike forecasts, projections do not make predictions about what
the future will be. They rather indicate what would happen if the assumptions which underpin
the projection actually occur. Still, the scenario allows for a consistent approach in the
assessment of energy and climate trends across the EU and its Member States.
The report "EU Reference Scenario 2016: Energy, transport and GHG emissions-Trends to
2050"129
describe the inputs and results in detail. In addition, its main messages are
summarised in the impact assessments accompanying the Effort Sharing Regulation130
and the
revision of the Energy Efficiency Directive131
, and the analytical work accompanying the
European strategy on low-emission mobility132
.
PRIMES-TREMOVE is one of the core models of the modelling framework used for
developing the EU Reference scenario 2016 and has also been used for developing the
Baseline scenario of this impact assessment. The model was calibrated on transport and
energy data up to year 2013 from Eurostat and other sources
128
In addition, amendments to two Directives only adopted in the beginning of 2015 were also considered. This
concerns notably the ILUC amendment to the Renewables Directive and the Market Stability Reserve
Decision amending the ETS Directive
129
ICCS-E3MLab et al. (2016), EU Reference Scenario 2016: Energy, transport and GHG emissions - Trends to
2050
130
SWD(2016) 247
131
SWD(2016) 405
132
SWD(2016) 244
95
2.1 Main assumptions of the Baseline scenario
The projections are based on a set of assumptions, including on population growth,
macroeconomic and oil price developments, technology improvements, and policies.
Macroeconomic assumptions
The Baseline scenario uses the same macroeconomic assumptions as the EU Reference
scenario 2016. The population projections draw on the European Population Projections
(EUROPOP 2013) by Eurostat. The key drivers for demographic change are: higher life
expectancy, convergence in the fertility rates across Member States in the long term, and
inward migration. The EU28 population is expected to grow by 0.2% per year during 2010-
2030 (0.1% for 2010-2050), to 516 million in 2030 (522 million by 2050). Elderly people,
aged 65 or more, would account for 24% of the total population by 2030 (28% by 2050) as
opposed to 18% today.
GDP projections mirror the joint work of DG ECFIN and the Economic Policy Committee,
presented in the 2015 Ageing Report133
. The average EU GDP growth rate is projected to
remain relatively low at 1.2% per year for 2010-2020, down from 1.9% per year during 1995-
2010. In the medium to long term, higher expected growth rates (1.4% per year for 2020-2030
and 1.5% per year for 2030-2050) are taking account of the catching up potential of countries
with relatively low GDP per capita, assuming convergence to a total factor productivity
growth rate of 1% in the long run.
Fossil fuel price assumptions
Oil prices used in the Baseline scenario are the same with those of the EU Reference scenario
2016. Following a gradual adjustment process with reduced investments in upstream
productive capacities by non-OPEC134
countries, the quota discipline is assumed to gradually
improve among OPEC members and thus the oil price is projected to reach 87 $/barrel in
2020 (in year 2013-prices). Beyond 2020, as a result of persistent demand growth in non-
OECD countries driven by economic growth and the increasing number of passenger cars, oil
price would rise to 113 $/barrel by 2030 and 130 $/barrel by 2050.
No specific sensitivities were prepared with respect to oil price developments. Still, it can be
recalled that lower oil price assumptions tend to increase energy consumption and CO2
emissions not covered by the ETS. The magnitude of the change would depend on the price
elasticities and on the share of taxation, like excise duties, in consumer prices. For transport,
133
European Commission/DG ECFIN (2014), The 2015 Ageing Report: Underlying Assumptions and
Projection Methodologies, European Economy 8/2014.
134
OPEC stands for Organization of Petroleum Exporting Countries.
96
the high share of excise duties in the consumer prices act as a limiting factor for the increase
in energy consumption and CO2 emissions.
Techno-economic assumptions
For most transport means, the Baseline scenario uses the same technology costs assumptions
as the EU Reference scenario 2016.
For light duty vehicles, the data for technology costs and emissions savings has been updated
based on a recent study commissioned by DG CLIMA135
. Battery costs for electric vehicles
are assumed to go down to 205 euro/kWh by 2030 and 160 euro/kWh by 2050; further
reductions in the cost of both spark ignition gasoline and compression ignition diesel are
assumed to take place. Technology cost assumptions are based on extensive literature review,
modelling and simulation, consultation with relevant stakeholders, and further assessment by
the Joint Research Centre (JRC) of the European Commission.
Specific policy assumptions
The key policies included in the Baseline scenario, similarly to the EU Reference scenario
2016, are136
:
 CO2 standards for cars and vans regulations (Regulation (EC) No 443/2009, amended by
Regulation (EU) No 333/2014 and Regulation (EU) No 510/2011, amended by Regulation
(EU) No 253/2014); CO2 standards for cars are assumed to be 95gCO2/km as of 2021 and
for vans 147gCO2/km as of 2020, based on the NEDC test cycle, in line with current
legislation. No policy action to strengthen the stringency of the target is assumed after
2020/2021.
 The Renewable Energy Directive (Directive 2009/28/EC) and Fuel Quality Directive
(Directive 2009/30/EC) including ILUC amendment (Directive 2015/1513/EU):
achievement of the legally binding RES target for 2020 (10% RES in transport target) for
each Member State, taking into account the use of flexibility mechanisms when relevant as
well as of the cap on the amount of food or feed based biofuels (7%). Member States'
specific renewable energy policies for the heating and cooling sector are also reflected
where relevant.
 Directive on the deployment of alternative fuels infrastructure (Directive 2014/94/EU).
135
Source: https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/technology_results_web.xlsx
136
For a comprehensive discussion see the Reference scenario report: “EU Reference Scenario 2016: Energy,
transport and GHG emissions - Trends to 2050”
97
 Directive on the charging of heavy goods vehicles for the use of certain infrastructures
(Directive 2011/76/EU amending Directive 1999/62/EC).
 Relevant national policies, for instance on the promotion of renewable energy, on fuel and
vehicle taxation, are taken into account.
In addition, a few policy measures adopted after the cut-off date of the EU Reference scenario
2016 at both EU and Member State level, have been included in the Baseline scenario:
 Directive on weights & dimensions (Directive 2015/719/EU).
 Directive as regards the opening of the market for domestic passenger transport services by
rail and the governance of the railway infrastructure (Directive 2016/2370/EU).
 Directive on technical requirements for inland waterway vessels (Directive
2016/1629/EU), part of the Naiades II package.
 Regulation establishing a framework on market access to port services and financial
transparency of ports137
.
 The replacement of the New European Driving Cycle (NEDC) test cycle by the new
Worldwide harmonised Light-vehicles Test Procedure (WLTP) has been implemented in
the Baseline scenario, drawing on work by JRC. Estimates by JRC show a WLTP to
NEDC CO2 emissions ratio of approximately 1.21 when comparing the sales-weighted
fleet-wide average CO2 emissions. WLTP to NEDC conversion factors are considered by
individual vehicle segments, representing different vehicle and technology categories138
.
 Changes in road charges in Germany, Austria, Belgium and Latvia.
 Reflecting the plateauing in the number of fatalities and injuries in the recent years, in the
Baseline scenario it has been assumed that post-2016 vehicle technologies would be the
main source of reduction in fatalities, serious and slight injuries while measures addressing
infrastructure safety (such as the existing RISM and Tunnel Directives), and driver
behaviour (such as legislation improving enforcement across borders, namely Directive
137
Awaiting signature of act (Source :
http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2013/0157(COD)&l=en)
138
Simulation at individual vehicle level is combined with fleet composition data, retrieved from the official
European CO2 emissions monitoring database, and publicly available data regarding individual vehicle
characteristics, in order to calculate vehicle CO2 emissions and fuel consumption over different conditions.
Vehicle CO2 emissions are initially simulated over the present test protocol (NEDC) for the 2015 passenger
car fleet; the accuracy of the method is validated against officially monitored CO2 values and experimental
data.
98
2015/413/EU facilitating cross-border exchange of information on road safety related
traffic offences) would compensate for the increase in traffic over time.
2.2 Summary of main results of the Baseline scenario
EU transport activity is expected to continue growing under current trends and adopted
policies beyond 2015, albeit at a slower pace than in the past. Freight transport activity for
inland modes is projected to increase by 36% between 2010 and 2030 (1.5% per year) and
60% for 2010-2050 (1.2% per year). The annual growth rates by mode, for freight transport,
are provided in Figure 1 below139
.
Road transport would maintain its dominant role within the EU. The share of road transport in
inland freight is expected to slightly decrease at 70% by 2030 and 69% by 2050. The activity
of heavy goods vehicles expressed in tonnes kilometres is projected to grow by 35% between
2010 and 2030 (56% for 2010-2050) in the Baseline scenario, while light goods vehicles
activity would go up by 27% during 2010-2030 (50% for 2010-2050).
Figure 11: Freight transport projections (average growth rate per year)
140
Rail freight transport activity is projected to grow significantly faster than for road, driven in
particular by the effective implementation of the TEN-T guidelines, supported by the CEF
funding, leading to the completion of the TEN-T core network by 2030 and of the
comprehensive network by 2050. Rail freight activity grows by 51% by 2030 and 90% during
2010-2050, resulting in 2 percentage points increase in modal share by 2030 and an additional
percentage point by 2050.
139
Projections for international maritime are presented separately and not included in the total freight transport
activity to preserve comparability with statistics for the historical period.
140
Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab)
-1.0%
-0.5%
0.0%
0.5%
1.0%
1.5%
2.0%
2.5%
3.0%
Road Rail Inland navigation
Freight transport
'95-'10 '10-'30 '30-'50
99
Transport activity of freight inland navigation141
also benefits from the completion of the
TEN-T core and comprehensive network, the promotion of inland waterway transport and the
recovery in the economic activity and would grow by 26% by 2030 (1.2% per year) and by
46% during 2010-2050 (0.9% per year).
International maritime transport activity is projected to continue growing strongly with rising
demand for oil, coal, steel and other primary resources – which would be more distantly
sourced – increasing by 37% by 2030 and by 71% during 2010-2050.
Transport accounts today for about one third of final energy consumption. In the context of
growing activity, energy use in transport is projected to decrease by 5% between 2010 and
2030 and to stabilise post-2030. These developments are mainly driven by the implementation
of the Regulations setting emission performance standards for new light duty vehicles. At the
same time, heavy goods vehicles are projected to increase their share in final energy demand
from 2010 onwards, continuing the historic trend from 1995. Energy demand by heavy goods
vehicles would grow by 14% between 2010 and 2030 (23% for 2010-2050).
Bunker fuels for maritime transport are projected to increase significantly: by 24% by 2030
(42% for 2010-2050).
LNG becomes a candidate energy carrier for road freight and waterborne transport, especially
in the medium to long term, driven by the implementation of the Directive on the deployment
of alternative fuels infrastructure and the revised TEN-T guidelines which represent important
drivers for the higher penetration of alternative fuels in the transport mix. In the Baseline
scenario, the share of LNG is projected to go up to 3% by 2030 (8% by 2050) for road freight
and 4% by 2030 (7% by 2050) for inland navigation. LNG would provide about 4% of
maritime bunker fuels by 2030 and 10% by 2050 – especially in the segment of short sea
shipping.
Biofuels uptake is driven by the legally binding target of 10% renewable energy in transport
(Renewables Directive), as amended by the ILUC Directive, and by the requirement for fuel
suppliers to reduce the GHG intensity of road transport fuel by 6% (Fuel Quality Directive).
Beyond 2020, biofuel levels would remain relatively stable at around 6% in the Baseline
scenario. The Baseline scenario does not take into account the recent proposal by the
Commission for a recast of the Renewables Energy Directive.
In the Baseline scenario, oil products would still represent about 90% of the EU transport
sector needs in 2030 and 85% in 2050, despite the renewables policies and the deployment of
141
Inland navigation covers inland waterways and national maritime.
100
alternative fuels infrastructure which support some substitution effects towards biofuels,
electricity, hydrogen and natural gas.
The declining trend in transport emissions is expected to continue, leading to 13% lower
emissions by 2030 compared to 2005, and 15% by 2050.142
However, relative to 1990 levels,
emissions would still be 13% higher by 2030 and 10% by 2050, owing to the fast rise in the
transport emissions during the 1990s. The share of transport in total GHG emissions would
continue increasing, going up from 23% currently (excluding international maritime) to 25%
in 2030 and 31% in 2050, following a relatively lower decline of emissions from transport
compared to power generation and other sectors. Maritime bunker fuel emissions are also
projected to grow strongly, increasing by 22% during 2010-2030 (38% for 2010-2050).
CO2 emissions from road freight transport (heavy goods and light goods vehicles) are
projected to increase by 6% between 2010 and 2030 (11% for 2010-2050) in the Baseline
scenario. For heavy goods vehicles, the increase would be somewhat higher (10% for 2010-
2030 and 17% for 2010-2050), in lack of specific measures in place. At the same time,
emissions from passenger cars and passenger vans are projected to decrease by 22% between
2010 and 2030 (32% for 2010-2050) thanks to the CO2 standards in place and the uptake of
electromobility.
NOx emissions would drop by about 56% by 2030 (64% by 2050) with respect to 2010
levels. The decline in particulate matter (PM2.5) would be less pronounced by 2030 at 51%
(65% by 2050). Overall, external costs related to air pollutants would decrease by about 56%
by 2030 (65% by 2050).143
High congestion levels are expected to seriously affect road transport in several Member
States by 2030 in the absence of effective countervailing measures such as road pricing.
While urban congestion will mainly depend on car ownership levels, urban sprawl and the
availability of public transport alternatives, congestion on the inter-urban network would be
the result of growing freight transport activity along specific corridors, in particular where
these corridors cross urban areas with heavy local traffic. Estimating the costs of congestion is
not straightforward, because it occurs mostly during certain times of the day, often caused by
specific bottlenecks in the network. In the Baseline scenario, total congestion costs for urban
and inter-urban network are projected to increase by about 24% by 2030 and 43% by
2050, relative to 2010. Noise related external costs of transport would continue to increase,
by about 17% during 2010-2030 (24% for 2010-2050), driven by the rise in traffic.
142
Including international aviation but excluding international maritime and other transportation.
143
External costs are expressed in 2013 prices. They cover NOx, PM2.5 and SOx emissions.
101
Further details on the Baseline scenario are available in the Impact Assessment accompanying
the review of the Eurovignette Directive.144
3. Time savings assumptions
In the Baseline scenario, the time per port call spent on reporting formalities is estimated at 60
minutes for ships on fixed routes and 180 minutes for ships on non-fixed routes145
; this
assumption has been developed in consultations with shipping industry representatives
(ECSA, Interferry, CLIA) and their associated members. The rationale is that ships in fixed
route (liner) traffic always call at the same ports, normally only at one or few EU ports. They
are therefore less affected by the lack of harmonisation of reporting. The fixed route traffic
also includes most of the larger vessels normally applying machine-to-machine reporting. The
average reporting time per port call is thus at the lower end for the fixed route traffic. The
non-fixed route (tramp) traffic on the other hand by nature calls at multiple ports, requiring
more adaptations to the non-harmonised reporting systems. Time spent on reporting is
therefore higher. This traffic category also covers mostly smaller size vessels, less likely to
apply machine-to-machine reporting. There are exceptions to the general rule in both groups;
but the average is considered a correct assumption by the consulted shipping operator
representatives.
There is no available data on port calls per traffic type. However, ECSA applies an
assumption model built on combining two main factors: vessel size and cargo type. The
majority of vessels smaller than 10 000GT carrying bulk (dry or liquid) goods or general
cargo are assumed to go in tramp traffic. Larger vessels or vessels carrying other goods (e.g.
passengers, containers) are more likely to be in fixed route traffic. There are some exceptions
in both categories, balancing out to make the overall assumption hold. Applying these
assumptions, it is estimated that about 40% of the total number of port calls in the EU can be
attributed to fixed routes and 60% to non-fixed routes146
.
In the policy options A1-C1, on average 30 minutes per call (50%) are assumed to be saved
relative to the Baseline scenario for the ships on fixed routes and 135 minutes (75%) relative
to the Baseline for ships on non-fixed routes. The higher saving potential for the non-fixed
route is based on the higher impact of harmonisation on these ships. The fixed-route ships will
primarily benefit from the single entry point, the reduction of duplicate data requests
(reporting only once). All traffic types will also benefit from the simplified and harmonised
data set.
144
Source: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017SC0180
145
Evaluation of the RFD, p.19-20
146
Source: own estimates based on Eurostat statistics.
102
For policy options A2-C2 lower time savings are assumed to be achieved: 12 minutes per call
relative to the Baseline scenario (20%) for the ships on fixed routes and 45 minutes relative to
the Baseline (25%) for ships on non-fixed routes. The separate entry points for reporting are
not only expected to create an additional administrative burden in themselves; there will be
little harmonisation of data sets between the two separate reporting entry points with high risk
of duplication of data elements in different requested formats. The consulted shipping
operators therefore expect only the low end benefits for these options.
The new harmonised entry point will not be mandatory for shipping operators; they will still
have the options to report via the non-harmonised and non-simplified old system with several
reporting gateways in parallel. It is therefore assumed that not all shipping operators will in
fact make use of this option. E.g. some SMEs and some vessels in domestic traffic may
choose not to make use of the new reporting system. In the consultations, more than 90% of
all shipping operators did ask for a harmonised reporting environment. For a more cautious
approach, a gradual uptake from 25-90% over the baseline period has been assumed. This was
then also compared against a pessimistic scenario with an estimated lower gradual uptake
from 15-80% over the same period.
Time spent on reporting – reduction of administrative burden
MAIN ASSUMPTIONS
Fixed route (share of total port calls) 40%
Non-fixed route (share of total port calls) 60%
Labour cost EUR/h 38,35
Discount rate 4%
Hours spent for reporting, average (baseline)
Fixed route 1
Non-fixed route 3
Time / average time savings (options A1-C1) – ECSA model
Fixed route 50%
Non-fixed route 75%
Time / average time savings (options A2-C2) – ECSA model
Fixed route 20%
Non-fixed route 25%
103
GRADUAL UPTAKE
ASSUMPTION 2020
147
2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Expected uptake 0% 25% 50% 75% 90% 90% 90% 90% 90% 90% 90%
Low uptake 0% 15% 40% 65% 80% 80% 80% 80% 80% 80% 80%
Baseline A1 A2 B1 B2 C1 C2
EU28
Staff hours (million hours) 50 25-28 42-43 25-28 42-43 25-28 42-43
Savings compared to baseline 0 22-25 7-8 22-25 7-8 22-25 7-8
€ million (present value) 1,520 800-895 1275-1305 800-895 1275-1305 800-895 1275-1305
Savings compared to baseline 0 625-720 215-245 625-720 215-245 625-720 215-245
Excluding UK
Staff hours (million hours) 48 24-27 40-41 24-27 40-41 24-27 40-41
Savings compared to baseline 0 21-24 7-8 21-24 7-8 21-24 7-8
€ million (present value) 1,455 765-855 1220-1250 765-855 1220-1250 765-855 1220-1250
Savings compared to baseline 0 600-690 205-235 600-690 205-235 600-690 205-235
Table 6: Reduced administrative burden for shipping operators relative to the baseline over 2020-2030
4. Assumptions used to estimate costs related to IT systems
The following TCO model has been elaborated, consisting of three levels of aggregation. The
data source(s) used to populate/ estimate/ extrapolate the cost of the category and sub-
category, as well as the manner in which it was computed, are detailed in the following tables.
147
No expected benefits during first year of implementation
104
Central Costs
Level 1. Level 2. Level 3 Description
Software
Development
ERG
Continuous availability DBMS
infrastructure
Additional functionalities
reservation
Maintenance
ERG
Continuous availability DBMS
infrastructure
Additional maintenance reservation
Other software costs
 Cost category covering the EMSW
development, maintenance support and other
software costs
 The development and maintenance ERG costs
originate from the FFPA analysis
 The continuous availability DBMS
infrastructure and other software costs are
derived from Gartner’s peer Benchmark data
cumulated with Gartner Consulting experience
and Gartner Case data
Operation Services
Managed services
A central directory
High-availability ERG (Level 2/3
support)
Testing Services
A certification process for Data
Providers
A sandbox environment for national
authorities
Supporting services
Deployment services
Support the national authorities
Support the NSWs integrating
Service desk for National Authorities
Training services
Other supporting services
 Comprehensive set of operation services that
should be offered to cover all three retained
policy options: managed services, testing,
supporting services, service desk for National
Authorities, training and other supporting
services
 Gartner Benchmark peer data fed into testing
services, as well as into deployment services
 Managed Services. A central directory:
Calculated considering ½ FTE based on 24/7
availability
 Managed Services. High-availability ERG
(Level 2/3 support): Calculated considering 1
FTE based on 24/7 availability using synergies
with EMSW’s maintenance and that of other
systems
 Testing Services have been costed in line with
the Gartner Benchmark peer data points,
considering the costs of setting up and
supporting the certification process for the Data
Providers
 Gartner IT Key Metrics data has been leveraged
to estimate the costs for the service desk for
National Authorities, while Gartner
benchmarking data fed into costing training and
other supporting services. For the training
services, across the three retained policy
options 12 monthly training sessions have been
envisaged
105
Central Costs
Level 1. Level 2. Level 3 Description
Stakeholder Managed Services
Stakeholder on boarding services
Awareness raising activities
Community management services
Share best practice and experience
 Stakeholder on-boarding services and
community management services have been
envisioned as part of the EMSW Stakeholder
Management Services, both costed in line with
Gartner Benchmark peer data points, as well as
other data points provided by EMSA
Technical Specification
Maintenance
Maintain eManifest and other
exchange standards
 Maintenance. Maintain the technical data sets
(eManifest and Maritime Single Window data
set) and other exchange standards: The cost is
associated with that of 1 FTE
Programme Management
Vendor management
Programme coordination
 Cost category covering both vendor
management activities and programme
management coordination activities, necessary
for EU retention of resources
 All cost elements included under Programme
Management are in line with Gartner
Consulting professional expertise
Infrastructure
Server & Storage
 The Server & Storage costs were computed
multiplying the number of environments across
both data centres with the cost per Linux server
adding up the cost of 1/ 5/ 10 raw terabytes of
storage in line with Gartner Benchmark peer
data and Gartner Case data
Contingency
Contingency (20%)
 Across the three retained policy options, 20%
out of the total costs per year are added up to
account for the Contingency, defined as
unforeseen costs to be spent by EU, not covered
by any of the other cost categories
Baseline A1 A2 B1 B2 C1 C2
EU28
Costs for the Member States148
(€ million, present value)
CapEx - 13,5 10,7 7,8 7,1 10,7 10,7
OpEx 108 14,3 11,0 8,1 6,8 8,1 8,1
Total MS 108 27,8 21,7 15,8 13,9 18,8 18,8
148
Member States' baseline cost for annual operation of the current National Single Windows remains in all
options: the additional costs come on top of the annual costs of a NSW.
106
Costs for the EU (European Commission
or other entity assigned with the task)
(€ million, present value)
CapEx - 1,7 1,7 2,5 2,5 2,4 2,4
OpEx - 9,6 9,6 11,0 10,9 13,0 12,0
Total EU - 11,3 11,3 13,5 13,3 15,4 14,4
Total costs (€ million, present value) 108 39,1 33,0 29,4 27,2 34,2 33,2
Excluding UK
Costs for the Member States 149
(€ million, present value)
CapEx - 12,9 10,2 7,5 6,8 10,2 10,2
OpEx 104 13,7 10,5 7,8 6,6 7,8 7,8
Total MS 104 26,6 20,7 15,2 13,4 18,0 18,0
Costs for the EU (European Commission
or other entity assigned with the task)
(€ million, present value)
CapEx - 1,7 1,7 2,5 2,5 2,4 2,4
OpEx - 9,6 9,6 11,0 10,9 13,0 12,0
Total EU - 11,3 11,3 13,5 13,3 15,4 14,4
Total costs (€ million, present value) 104 37.9 32,0 28,7 26,7 33,4 32,4
Table 7: Investment/adaptation and operational costs (total period 2020-2030, EUR million, present value); 4% Better
Regulation discount rate applies.
Member State Costs
Level 1. Level 2. Level 3 Description
CAPEX
Adaption of NSW
Adaption of national authority systems
 The estimation of the development effort is
based on FFPA, a Gartner adaption of the
IFPUG FPA methodology for assessing
functional complexity of software. The ERG
development costs were plugged into the cost
analysis
 Adaptation of NSW and adaptation of national
authority systems are dependent on Cost of IT
developers across Member States. Gartner’s
rate card statistics and IT Key Metrics have
been used to factor in the differences in IT
manpower across the Member States. The
factor between the least and most expensive is a
factor of 3
 Adaptation of national authority systems is
dependent on the number of local authorities
involved in the NSW. The number of
authorities in each Member State drives the
number of integrations that require adaptations
149
Member States' baseline cost for annual operation of the current National Single Windows remains in all
options: the additional costs come on top of the annual costs of a NSW.
107
Member State Costs
Level 1. Level 2. Level 3 Description
OPEX
Annual Adaption of NSW
Annual Adaption of authority systems
 The estimation of the maintenance effort is
based on FFPA, a Gartner adaption of the
IFPUG FPA methodology for assessing
functional complexity of software. The ERG
maintenance costs were plugged into the cost
analysis
 Adaptation of NSW and adaptation of national
authority systems are dependent on Cost of IT
developers across Member States. Gartner’s
rate card statistics and IT Key Metrics have
been used to factor in the differences in IT
manpower across the Member States. The
factor between the least and most expensive is a
factor of 3
 Adaptation of national authority systems is
dependent on the number of local authorities
involved in the NSW. The number of
authorities in each Member State drives the
number of integrations that require adaptations
and maintenance
The costs for Member States differ between the options mainly depending on the level of
adaptations required for the NSWs:
The support study has analysed the additional costs for MS in the scenarios with the three
policy options. This means the costs for adapting or updating the existing NSWs (CAPEX)
and the increase in annual maintenance of the NSW due to expanded scope and functionalities
in the updated system (OPEX). These costs therefore come on top of the baseline cost of
annual operation and maintenance of each NSW already today. The NSW’s are assumed to
remain in the picture across options B, C and D.
The NSW’s today consists of two bundles of functionality:
1. The front-end reporting interface(s) to the data providers, i.e. the functionality
associated with receiving and validating the reporting data set and sending back
responses.
2. The back-end connections to the authorities, i.e. the functionality associated with
sending authority-specific data sets, and with sending, and receiving messages.
In Option B, each MS will need to take on the costs for developing the necessary solutions to
implement the technical specifications and subsequently adapt the existing NSW’s to the
108
technical specifications. This requires them to update both functionality bundles 1 and 2. The
estimate of this is based on function-point counting.
In Option C, the front-end reporting interface in the existing NSW’s is replaced by the
centrally developed and fully harmonised reporting gateway component. Member States have
to plug in this software to the National Single Windows and ensure that the translation from
the common software to the back-end connections works. This means that they replace the
original functionality bundle 1 with the centrally developed software. Therefore, the MS
CAPEX of option C is lower than in option D (and B), as all NSW systems are recent
implementations and it is therefore a relatively simple process to integrate the centrally
developed interface and switch off redundant functionality. The associated estimate for
Option C is 100 man-days. For Option C, the functionality bundle 2 also needs to be adapted
and maintained (same as in option B and D).
The MS OPEX of option C is also lower than in option D. Instead of managing the full
software development cycle of functionality bundle 1, they only need to care about initial
adaptions and then recurring installation and testing of the front-end reporting gateway
solution they receive from EU-level.
In Option D, the central European Maritime Single Window is implementing functionality
bundle 1 (providing the harmonised front-end interface towards the users). Each Member
State need to adapt their current functionality bundle 1 in the existing NSW’s and transform
the NSWs into playing instead a routing function between the central gateway and the
“functionality bundle 2” connections. Also, they need to adapt the functionality bundle 2,
facing the individual national authorities. This corresponds to the lines: “Adaption of NSW”,
and “Adaption of authority interfaces” in Table 11 of Appendix G of the support study.
Since in Option D, the NSW’s can still receive reporting directly from data providers
(national traffic), they also need to update functionality bundle 1 in the same manner as is
required in option B. In total, the CAPEX costs for option D are therefore higher than in
option C for Member States.
As is explained in Appendix G of the support study, Table 12 – 14, the MS costs vary
significantly between the MS for the following reasons:
 The estimates are taking a starting point in a generic estimation of the complexity of
providing the functionality provided in a NSW, which drive the complexity of the
adaptions and maintenance.
 As the development and maintenance efforts in MS are typically done by specialized
IT staff or specialized IT service providers, the massive differences in cost of
developer staff between MS should be reflected. They vary from €392 in Bulgaria to €
1263 in the Nordic countries using market data gathered by Gartner.
109
 As the complexity of the NSW varies with the number of authorities connected to the
NSW, a complexity adjustment has been calculated based on data gathered from the
national authorities.
Regarding EU costs for the options.
 Development costs for the ERG:
o In all options B, C, and D the EU is required to contribute to the functionality
bundle 1 (see above). In option B, the technical specifications are developed at
EU level. In Option C, a complete solution for the functionality bundle is
developed and distributed to MS. In option D this functionality is installed on
EU servers to provide the central service.
 Stakeholder Management Services consists of two sub-categories: “Awareness-raising
activities” and “Share best-practice and experience”. “Awareness raising activities”
are estimated at equal levels based on data gathered by Gartner on other EU policy
initiatives. “Share best-practice and experience” vary between the options for the
following reasons:
o Options B are estimated to drive a slightly lower but still significant cost as the
value of exchanging experience with implementing the technical specification
can save costs and time in the MS implementation.
o Options C are estimated to drive the largest cost, as sharing best practice and
experience will be crucial for the success of effectively deploying and
integrating a centrally developed interface.
o Options D are estimated to have the lowest cost, as the need to share best
practice will be lower with a central service.
 Support services:
o The cost model estimates costs for support services towards national
authorities, e.g. service desk and training offered. These costs are estimated to
be higher for Option C than for the other options as the installation of central
software will generate additional requests compared to the other options
 Costs are also calculated for operation services such as the central directories, for
programme management and for infrastructure (e.g. servers, storage, network). These
costs are expected to be more or less similar regardless of the option.
 Development costs are initiated in year two of the cost model in order to leave time for
finding and contracting service providers for the development work.
110
Annex 5: the Reporting Formalities Directive
In 2010, the Reporting Formalities Directive (RFD) was adopted with the aim to simplify,
digitalise and harmonise administrative procedures for maritime transport. The Directive
introduced National Single Windows (one single reporting entry point for each Member State)
for reporting, in digital format, on a set of 14 agreed procedures stemming from EU or
international law.
The RFD covers three types of reporting formalities (as listed in Parts A-C of Annex 1):
• Part A: information required by EU legislative acts. This includes notification for
ships arriving in and departing from ports of the EU, information on border checks
on persons, notification of dangerous or polluting goods carried on board,
notification of waste and residues, notification of security information and entry
summary declaration for customs. The data is collected for a set of purposes, e.g.
to facilitate traffic management, for safety and security, for border controls and for
environmental objectives.
• Part B: information provided in accordance with the IMO ‘FAL Convention’
(general and cargo declaration, ship’s store declaration, crew’s effect declaration,
crew and passenger list and dangerous goods information) and with the
International Health Regulations (maritime declaration of health). This data is
submitted in line with international standardised forms (IMO).
o Part A and Part B together require the submission of around 230 data
elements. Some of the data elements collected in Part A and B serve double
purposes and feed several of the back-end entities.
• Part C: information required by national legislation of the Member State of the
port of call. Part C data is not mandatory for Member States to request via the
National Single Windows. These data sets differ for each Member State and there
has until yet been no harmonisation of formats. This information is mostly linked
to ship/port operations (bunkering, piloting, tug requests, etc.). The on-going
mapping of national reporting has found that shipping operators may be required
to provide to local authorities up to 200 different data elements in addition to part
A and B.
This covers the maritime transport related reporting a shipping operator must perform in
connection to a port call but not the bulk of cargo-related reporting (primarily to customs
authorities).
The Reporting Formalities Directive is a coordination mechanism to facilitate for maritime
transport operators when calling an EU port. It established a mechanism (the National Single
Windows) for streamlining the reporting requested in a set of EU and international legal acts.
It doesn’t cover all reporting requested from a ship (notably: cargo reporting to customs; only
non-mandatory reporting of national and legal requirements) and the Directive does not
111
specify the data model or data format to be used. The Directive does not add any reporting
formalities; it only specifies how Member States need to coordinate the reporting requests
under a certain set of legal acts via a single reporting entry point.
In the absence of binding technical specifications, Member States have interpreted and
implemented the Directive in different ways: e.g. applying centralised or decentralised
National Single Window set-ups, using different data formats and reporting templates and
requesting different sets of additional national reporting requirements in national formats via
the reporting entry point. Although most maritime Member States have established some kind
of National Single Window, these Single Windows can be arranged in many different ways.
Some are fully centralised at national level, some have national level specifications and
procedures but are implemented at local/port level in a distributed system of entry points. In
other case the reporting obligations are fulfilled via the commercial Port Community Systems
which in turn send information to the national authorities.
The Directive doesn’t cover all existing reporting obligation requested from a ship (notably:
most of cargo reporting to customs; only non-mandatory reporting of national requirements,
statistical requirements).
While cargo reporting to maritime authorities is fulfilled submitting the general and cargo
declaration (FAL forms 1 and 2, see Part B), the RFD only mandates the transmission of the
Entry Summary Declaration to customs via the National Single Windows. The Entry
Summary Declaration covers around 50 cargo data elements. Around another 100 data
elements are required by the Union Customs Code (Reg. 952/2013/UE) and must be sent
directly to the customs IT systems. These data have been mapped by the Commission
eManifest pilot project, with the purpose of assessing how to fulfil all cargo reporting
obligations (both maritime and customs) with the use of an electronic harmonised data set
encompassing all required cargo data elements.
DG MOVE launched the eManifest pilot project in 2016 in collaboration with DG TAXUD
and with the support of EMSA. 14 Member States and 14 shipping industry associations
participate in the pilot project. The pilot aims to establish a harmonised electronic data set
encompassing cargo data elements required for maritime and customs reporting. It assesses
how this information can be submitted to the authorities. EMSA has already developed a
prototype for the testing of submission of cargo formalities along with the remaining non
cargo reporting. The project has run in four phases where cargo reporting formalities have
been assessed and gradually added to the testing, with final outcomes during 2018. The
outcome of the pilot project will be business rules and a data mapping made up of all cargo
data elements, supporting the future harmonised European Maritime Single Window
environment.
When a vessel calls in an EU port carrying goods, depending on factors like the last port of
call and the type of cargo on board, a set of formalities may have to be submitted to customs
authorities, notably the arrival notification, the presentation notification of goods and the
112
declaration for temporary storage. Other formalities are envisaged instead at the departure
from an EU port, like the exit summary declaration, re-export notification, or the notification
of exit for goods under export procedure
Reporting to customs is necessary most of the times even when goods are carried between two
points of the EU territory by sea. In this case, maritime operators can benefit of simplified
reporting through the submission of the ‘customs goods manifest’ or of the ‘electronic
transport document for simplified transit’. None of these simplified procedures are mentioned
in the RFD and are therefore out of the scope.
This limited scope of the RFD means that, today only about one third of all information
requested from a ship in a port call is always requested via the NSWs. This has been pointed
out by shipping operators as one of the main problem drivers. The separate reporting paths
mean uncoordinated reporting with duplications and non-harmonised formats.
This graph is a simplified picture illustrating the main reporting flows from ships, not taking into
account the detailed and more complex two-way flows of information to and from customs.
113
Annex 6: Policy options
A: Harmonised
NSWs: technical
specifications
B: Harmonised
NSWs: common
software
C: Central EMSW D: Mandatory PCS
(discarded)
1. Comprehensive
single entry point
solution
Option A1:
Measures A, 1 and
I-VI
Option B1:
Measures B, 1 and I-
VI
Option C1:
Measures C, 1
and I-VI
Option D1:
Measures D, 1 and I-
VI
2. Separate entry
points customs /
maritime
Option A2:
Measures A, 2 and
I-VI
Option B2:
Measures B, 2 and I-
VI
Option C2:
Measures C, 2
and I-VI
Option D2: Measures
D, 2 and I-VI
Alternative measures
Problem Driver 1: Diverse ship reporting formats, interfaces and procedures used throughout
the EU
No. Policy measures A-D
Alt. A Harmonised reporting gateways as front-end to the National Single Windows (NSWs):
based on binding technical specifications
Introduce binding harmonised requirements and technical specifications for the front-end
reporting gateway in the existing NSWs in the Member States. The specifications would
cover e.g. data content, message structure format, exchange protocols, user interface
requirements and other rules as necessary for ensuring the necessary information exchanges
business rules. They would be set at EU level but responsibility for implementation and
operation would be fully on the Member States. The result would be a decentralised system
of NSWs with identical reporting gateway functionalities for ship reporting.
Alt. B Harmonised reporting gateways as front-end to the National Single Windows (NSWs):
based on common IT solution
Develop a mandatory common harmonised reporting gateway/ front-end interface
component at EU level, for installation in every NSW. Regular updates as required would be
supplied via the EU. The operational responsibility would be on Member States but with
helpdesk functions for the software installation at EU level. The result would be a
decentralised system of identical reporting gateways, providing exactly the same “look and
feel” front-end in every Member State.
Alt. C Central European level reporting gateway: introduction of a centralised EU-level
reporting entry point
Introduce a centralised, EU-level reporting gateway / front-end interface. The centralised
reporting gateway would offer one single reporting entry point for all port calls throughout
the EU including the necessary two-way information exchanges between the data providers
and the back-end connected entities and systems. The NSWs would remain in place as the
router between the centralised reporting gateway and the national level data recipients.
Member States would be responsible for ensuring connection of their National Single
Windows to the centralised gateway.
Alt. D Mandatory Port Community Systems (PCS) as basis for harmonised reporting
gateways in Member States (technical specifications)
Build the EU level harmonisation requirements and binding technical specifications on
mandatory PCS reporting gateways in the Member States (all other details same as in
alternative A above).
114
Problem Driver 2: Diverse ship reporting information requirements throughout the EU –
several parallel reporting entry points
No. Policy measure
Alt. 1 Comprehensive single entry point solution (introduction of a mandatory
comprehensive Maritime Single Window data set)
Set a wide scope for the reporting by ships in connection to a port call to be accepted via
the harmonised European Maritime Single Window environment: covering the current
scope of RFD, the national reporting requirements and channelling of customs formalities
for ships into (and return messages from) the customs IT systems at national and EU level.
Alt. 2 Separate entry points customs / maritime (introduction of a mandatory limited
Maritime Single Window data set)
Set a limited scope for the reporting by ships in connection to a port call to be accepted via
the harmonised European Maritime Single Window environment: covering the current
scope of RFD and the national reporting requirements. Customs formalities to be reported
via the parallel and harmonised customs IT systems.
Common/complementary set of measures (enabling framework)
Problem Driver 2: Diverse ship reporting information requirements throughout the EU –
several parallel reporting entry points
No. Policy measure
I Introduction of specifications for acceptance of e-certificates
Enable development of e-certificates acceptance by initiating processes for specifications
and technical solutions (e.g. common registries).
Problem Driver 3: Unclear legal framework for sharing and using reporting information – no
“reporting only once”
No. Policy measure
II Establishment of data re-use principles for “reporting only once”
A set of clear principles, rules and rights for data sharing and reuse will be developed to
ensure correct and smooth data management and “reporting only once” for carriers, as a
minimum first step within the same port. Clear definitions for different requirements will be
provided. Definitions and specifications concerning the processing and management of
personal or commercially sensitive data will be addressed.
III Development of common databases to support the system
This includes a common exemption database, a common (federated) user database(s) and a
common ship repository.
Problem Driver 4: Inadequate implementation
No. Policy measure
IV Introduction of a governance mechanism
A governance mechanism will be created to ensure timely and appropriate legal and
technical updates. Implementing and/or delegated powers for maintenance of e.g. the
technical specifications are proposed. This will be accompanied by the set-up of the required
expert groups for coordination and consultation with Member States and with industry
stakeholders as needed.
V Development of a complaint/feedback mechanism
A complaint/feedback mechanism will be offered to maritime transport operators as a tool to
alert authorities if the harmonised reporting and the reporting only once principles are not
respected or if any technical fault is found in the reporting systems.
115
VI Development of helpdesk function
To facilitate implementation, technical support to Member States on the European Maritime
Single Window environment specifications and software in the form of e.g. helpdesk
functions, technical advice or development of application guidelines will be developed.
The figure below illustrates the reporting environment in options A1 and B1. Each National Single
Window has a harmonised front-end interface (a reporting gateway), either harmonised via technical
specifications – software development done by the Member State – or by plugging in a front-end
module developed at EU level.
Regardless of what port or Member State the shipping operator calls to, the reporting interface will
thus be the same (with identical functions in option A1; identical interface in option B1).
The National Single Windows then distributes the data to the back-end data recipients, in the formats
they require (using translation functions if needed) and providing subsets of data on need-to-know
basis only. These back-end data recipients include for example border control authorities, health
authorities, customs IT systems, the SafeSeaNet and port community systems. These back-end
interfaces will remain as in the current National Single Window set-ups, with reservation for
adjustments due to harmonisation of the data set.
A number of common databases and user registries are maintained at EU level for facilitating the
functioning of the system.
The initiative does not ban other reporting paths and a shipping operator may choose to report part of
their data directly to, for example, port community systems or customs IT system (see example of
“optional connection” in the figure below).
In options A2 and B2, the same set-up would be established but the reporting to customs IT system
would be separate from the National Single Window reporting (shipping operators reporting directly
to the customs IT systems for the cargo-related data).
116
Figure 12: Option A-B, distributed system with harmonised entry point (via technical specifications or common front-
end IT solution)
117
The following figure illustrates the centralised scenario in option C1. The shipping operator
can report directly to a centralised and harmonised reporting gateway (“EMSW”). The data is
then routed via this gateway to the National Single Windows and to the back-end data
recipients (see also next figure below for the detailed illustration of customs IT system
connections). The centralised gateway also connects to a number of common databases and
user registries.
The National Single Windows would need to be adapted their front-end to connect with the
centralised new reporting gateway. The back-end interfaces will remain as in the current
National Single Window set-ups, with reservation for adjustments due to harmonisation of the
data set.
The initiative will not forbid the continuation of alternative reporting paths. A shipping
operator may therefore have the option to report part of their data directly to, for example,
National Single Windows, port community systems or customs IT system (see examples of
“optional connection” in the figure below).
In option C2, the same set-up would be established but the reporting to customs IT system
would be separate from the European Maritime Single Window reporting (shipping operators
reporting directly to the customs IT systems for the cargo-related data).
118
Figure 13: Option C, centralised system
119
The figure below illustrates in more detail the connections between the maritime single
window (national or centralised level) and the customs IT systems in options A1, B1 and C1.
The initiative will not interrupt existing reporting paths and a shipping operator may choose to
continue reporting their cargo-related data directly to the customs IT systems.
The shipping operator may however also choose to report the entire maritime single window
data set via the harmonised maritime reporting gateway, from where the data is routed and
distributed as required to the back-end connected authorities. This may require translation of
some data elements to ensure the back-end authorities receive the data subsets in their
required formats, following the specifications in the underlying legal acts. The maritime
single window would also need to transmit the two-way flow of messages between customs
IT systems and the shipping operators.
This reporting environment set-up thus creates inter-connection between the maritime
transport reporting and the customs formalities for ships.
120
Figure 14: Connection between the maritime single window and customs IT systems: reporting options for shipping
(detailed technical implementation for these connections between the maritime national single windows and customs IT
systems will be subject to further IT feasibility studies)
121
Affected stakeholders and their key interests
Stakeholder Description Key interests
Shipping operators Operators providing EU and
international seaborne trade and
maritime passenger services; data
providers at port calls
Simplified reporting procedures to
minimise administrative burden
and maximise efficiency of port
calls for shorter turnaround times
On-board staff Ship masters and other crew
involved in reporting procedures
Minimise repetitive and
cumbersome procedures to release
work time for core tasks; protecting
the quality and reputation of the
profession
Shipping agents Agents and logistic companies
organising or facilitating trade
exchanges including port call
reporting for ships
Competitiveness of sector;
protection of the role and position
of the profession; efficiency of port
reporting procedures to maximise
profitability
Port authorities Public or private bodies that own
and/or manage the ports
Developing and maintaining
profitability, independence and
competitiveness of the port; level
playing field for port competition
Maritime authorities National or local authorities
regulating and controlling maritime
transport
Level playing field for and within
the maritime transport sector
contributing to jobs, growth and
trade; efficient information flows
from ships to enable authority
follow-up in line with applicable
law; ensuring an effective, cost-
efficient and practicable
management framework that
balances stakeholder needs
Customs authorities Authorities regulating and
controlling customs procedures
Efficient, timely and reliable
submissions of declarations and
notifications from the economic
operators; smooth two-way
exchange of information and
notifications between customs and
the economic operators
Consumers Industries or individual citizens
benefitting from the availability
and prices of goods delivered by
seaborne trade or travelling as
passengers by sea
Availability and cost of goods and
passenger services
122
Annex 7: Connected policy areas
Digital single market policy
This initiative contributes to the Commission priority of establishing a connected Digital
Single Market150
. The Council conclusions on digitalisation from 5 December 2017,
emphasising the importance of interoperability and harmonisation of interfaces for data
exchange as an enabler for seamless and efficient cross-border multimodal transport services
and stressing that digitalisation helps reduce the administrative burden and simplify
procedures, creating a level playing field for all transport operators.
Digitalisation of government services and business-to-administration interactions is a key
element to the success of the single market, helping to remove existing digital barriers and
delivering efficiency benefits. The Communication on a European Strategy for Low-Emission
Mobility151
highlights that digital technologies offer significant potential for optimising the
transport system and open up new opportunities for manufacturing and services. Digital
technologies also support the integration of transport with other systems, such as the energy
system, and make the mobility sector more efficient.
But to reap the full benefits of digitisation in the field of transport, it is necessary to create the
regulatory frameworks to incentivise the development and market uptake of such
technologies, and to set standards to ensure interoperability, including across borders, and
enable data exchange while at the same time addressing data protection and cyber-security
issues.
Automation and technical development in ships is expected to have an impact over time,
including with higher uptake of automated reporting systems, sensors and machine-to-
machine communications. Development of autonomous/un-manned vessels152
may challenge
legal frameworks and technical progress on secure data sharing and data exchange aspects via
e.g. block chains, cloud solutions or electronic IDs and e-certificates, can open opportunities
but also raise new questions for the legislators. Aspects of data protection, cyber security and
150
European Commission Communication, A Digital Single Market Strategy for Europe, COM(2015) 192 final,
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015DC0192&from=EN
151
European Commission Communication, A European Strategy for Low-Emission Mobility, COM(2016) 501
final,
https://ec.europa.eu/transport/sites/transport/files/themes/strategies/news/doc/2016-07-20-
decarbonisation/com%282016%29501_en.pdf
152
Horizon 2020: Smart, green and integrated transport,
https://ec.europa.eu/programmes/horizon2020/en/h2020-section/smart-green-and-integrated-transport
123
data privacy (technical developments, legal frameworks) are expected to continuously evolve.
Cyber-crime, IT failure or data breaches (“cyber incidents”) are an increasing concern and
were listed as third among the “10 Global Business Risks for 2017” by a recent insurance
company report153
.
A more harmonised and digital reporting environment for ships is considered an important
contribution towards these objectives. The establishment of the “European Maritime Single
Window environment” is therefore one of the 25 actions listed in the eGovernment Action
Plan 2016-2020154
. This action plan aims to modernise public administration, to achieve the
digital internal market, and to engage more with citizens and businesses to deliver high
quality services.
Any proposal to extend digitalisation and especially the development of digital services will
also take into account existing EU policy frameworks notably on the General Data Protection
Regulation (GDPR) and the Regulation on electronic identification and trust services
(eIDAS).
Single market policy: boosting jobs, growth and investments
The establishment of a simplified regulatory environment can also have significant positive
financial impact.155
Businesses suffer both direct border-related costs, such as expenses related to supplying
information and documents to the relevant authority, and indirect costs, such as those arising
from procedural delays and lost business opportunities. Based to estimates156
by the
Organisation for Economic Cooperation and Development (OECD), these costs may range
from 2% to 15% of the value of traded goods.
Customs policy
The Customs Union is an essential element in the functioning of the single market: ensuring
common application of common rules and a common tariff at the Union’s external borders.
153
Allianz risk barometer: business risks 2017,
http://www.agcs.allianz.com/assets/PDFs/Reports/Allianz_Risk_Barometer_2017_EN.pdf
154
European Commission Communication, EU eGovernment Action Plan 2016-2020, Accelerating the digital
transformation of government, COM(2016) 179 final, https://ec.europa.eu/digital-single-
market/en/news/communication-eu-egovernment-action-plan-2016-2020-accelerating-digital-transformation
155
According to the World Bank study, about 30% ($107 billion) of the total gain from trade facilitation in 75
analysed countries comes from the improvement in port efficiency and about $33 billion emanates from the
improvement in customs environment
http://documents.worldbank.org/curated/en/977511468764990679/pdf/wps3224TRADE.pdf
156
http://www.oecd.org/trade/facilitation/35459690.pdf
124
Customs procedures and control methods are specified in the Union Customs Code157
which
entered into force on 1 May 2016. The Union Customs Code puts emphasis on fully electronic
communication between the customs administrations and economic operators and between
customs authorities in different Member States, in a paperless environment. The need of the
data harmonisation for the exchange of information has brought at the establishment of a
Customs Data Model, containing a data set encompassing data elements and definitions
required by customs authorities throughout the EU. Moreover, in order to introduce a full
digital environment and high level of harmonisation in the whole customs domain, the
existing national customs IT systems are being enhanced and adapted to the new requirements
set out by the new legislation, while at the same time a number of centralised EU-wide IT
systems are being developed and deployed by DG TAXUD. Safety and Security information
has been enhanced, mainly through the improvement of data quality, enlarging the reporting
to multiple parties along the logistic chain. For this specific purpose, a new centralised system
is being developed, gathering all safety and security information, including that coming from
the maritime transport.
The transport and customs policy areas are inseparable and must be developed in close
coordination. Carriers need to report cargo information to both port authorities and customs
authorities when calling at an EU port. The complexity and the number of cargo reporting
formalities have brought to a considerable administrative burden for the shipping industry.
Therefore, in early 2016, the eManifest pilot project was launched. The overall objective of
the project is to test the possibility/practicability of submission of customs entry/exit
formalities along with other (maritime) reporting formalities by electronic means in a
harmonised manner with assistance of the Maritime SW, with the aim to reduce
administrative burden for ship data providers. The harmonised eManifest data set produced
for the purposes of the pilot contains the data requirements set in the UCC DA and IA and in
the IMO FAL Convention and is in line with the WCO Data Model, ensuring coherence and
interoperability between maritime and customs reporting. The coherence between customs
and maritime reporting represents a necessary pre-condition for a future interoperability
between maritime and customs electronic systems, adopting the technical and functional
specifications set out by customs legislation.
Social and environmental policy
Finally, a more efficient maritime transport sector is closely linked to the social and
environmental policy contexts.
157
Regulation (EU) No 952/2013, laying down the Union Customs Code, 9 October 2013, http://eur-
lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32013R0952
125
Having competent staff is essential for supporting the growth and prosperity of the maritime
industry in Europe. The European maritime industry today suffers from an increasing lack of
European seafarers, in particular officers. In line with the Social Agenda for Maritime
Transport158
, the Commission therefore strives to promote the attractiveness of maritime
professions. Reducing and removing cumbersome reporting tasks is one step towards this
goal.
The European Commission is working towards a form of mobility that is sustainable, energy-
efficient and respectful of the environment. The Transport White Paper calls for a modal shift
towards rail and waterborne transports, especially for long-distance shipments159
. For this, the
maritime transport mode attractiveness must be optimised by e.g. reliability, efficiency and
low operating and administrative costs. Supporting trade and transport facilitation through
simplification of the ship reporting environment is therefore aligned also with environmental
policy.
Research and innovation policy
With support from the Horizon2020, European transport research contributes to finding
solutions to the increasing mobility of people, with low-carbon technologies, clean vehicles,
smart mobility systems and integrated services for passengers and freight. European research
aims to strengthen the competitiveness of our transport industries and to develop a better
European transport system for the benefit of all.
In the transport sector, research160
is at the core of developing new technologies for greener,
smarter, more efficient transport means and innovative solutions for safer, more sustainable
and inclusive mobility.
Statistics
Maritime transport statistics (MTS) are collected by the EU and EFTA Member States
according to the Directive 2009/42/EC and transmitted to Eurostat for calculation of EU
aggregates and dissemination. In addition, some MTS data are collected on a voluntary basis
from Member States. The objective of this data collection is to compile harmonised statistics
of the maritime component of European transport activity and to provide information on the
carriage of goods and passengers by seagoing vessels calling at EU/EFTA ports as a basis for
analysis, monitoring/evaluation and planning of European maritime transport.
158
https://ec.europa.eu/transport/modes/maritime/seafarers_en
159
European Commission, White paper: Roadmap to a Single European Transport Area, COM(2011) 144 final,
p. 7, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0144&from=EN
160
https://ec.europa.eu/programmes/horizon2020/en/h2020-section/smart-green-and-integrated-transport
126
In order to comply with the requirements of the EU legal framework for provision of maritime
statistics, the Member States today use various non-harmonised sources for collection of
maritime transport data on national level. These data requests therefore fall under the RFD
Part C data (national and local requirements; not mandatory to request via the National Single
Windows).
Inland waterways transport
In inland waterways, a recently published EC financed study161
on Digital Inland Waterway
Area (DINA) also underlined the administrative burden for barge operators for filing ship
reports with the authorities and other mandatory declarations. Barge operators need to comply
with relevant legislation. This includes both safety related legislation and other legislation
(e.g. statistics).
Barge operators indicate that they need to file the same data multiple times to comply with
different aspects of legislation and dealing with different jurisdictions in cross-border
operations. From the perspective of the authorities there are also high costs to verify
compliance with legislation. There is a potential to make this process more effective and cost-
efficient by re-using data that is already there.
Many maritime ports also have an inland port section increasing the administrative burden by
having to comply with provisions for both the maritime and inland mode.
Therefore, harmonisation and rationalisation would be very welcome for both economic
operators and the administrative side. Ideally authorities should re-use data: from each other
(e.g. data already filed with another) and from existing registrations (e.g. readily available
business data made accessible for authorities under certain conditions).
Currently, in inland waterways there is no overall framework for electronic reporting covering
different purposes.
Combined transport
The Combined Transport Directive (92/1063/EC) is a support instrument encouraging the use
multimodal transport of goods where the major part of transport is carried out by rail, inland
waterways or maritime transport and is served by a short road leg in the beginning or end of
161
Digital Inland Waterway Area, ISBN 978-92-79-76485-1
https://ec.europa.eu/transport/sites/transport/files/studies/2017-10-dina.pdf
127
the transport chain. It foresees regulatory and fiscal incentives for combined transport
operations with an aim to foster modal shift of freight transport.
The 2016 evaluation of the Directive under the REFIT programme concluded that while the
Directive continues to be relevant for achieving EU transport policy's objective as regards the
reduction of these negative externalities, the effectiveness and the efficiency could be further
improved by a review as the measures are the definitions are too complicated and the
measures partly outdated. Thus the Commission adopted a proposal for amendment on
November 8th, 2017 simplifying the definition, improving the enforcement by clarifying the
conditions of proof of eligibility and updating the economic incentives.
E-documents for freight transport
Transport documents are central to the freight transport operations. They need to accompany
the cargo as it moves, recording signatures and keeping a paper trail of the logistics transfer.
Moving from paper to electronic documents offers a large potential to improve the efficiency,
reliability and cost-effectiveness of the freight transport operations. Transport documents in
electronic format are currently used to different degrees in all transport sectors. However, and
in spite of several initiatives in the past years to digitalise transport documents in each
transport mode, the percentage of operations employing electronic documents remains in
general low. This is particularly the case for multimodal and cross-border transport
operations, where electronic documents are least employed.
The need for EU level intervention to support wider uptake of electronic transport documents
for freight transport in all transport modes has been first emphasised by participants in the
Digital Transport and Logistics Forum (DTLF), an expert group formed by more than one
hundred private and public stakeholder representatives.
In May 2017, the Commission launched an impact assessment process to identify the barriers
to the wider use of electronic means in information exchange linked to the transport of goods
within the EU. The objective is to eventually enable all market players to fully exploit the
potential of digitalisation in the field of logistics. A legislative proposal is expected to be part
of the third Mobility Package, planned to be adopted in the beginning of May 2018, together
with the proposal for the review of the Reporting Formalities Directive (RFD).
Vessel Traffic Monitoring and Information System and SafeSeaNet
SafeSeaNet is a vessel traffic monitoring and information system, established in order to
enhance maritime safety, port and maritime security, marine environment protection and the
efficiency of maritime traffic and transport.
It has been set up as a network for maritime data exchange, linking together maritime
authorities from across Europe. It enables European Union Member States, Norway, and
Iceland, to provide and receive information on ships, ship movements, and hazardous cargoes.
128
The network includes for example the Automatic Identification System (AIS) information
from ships.
Progressively, more and information from and on ships is being centralised in the SafeSeaNet
system. This means that, now and in the future, a growing number of different types of users
are being given the opportunity to access the information they need from a single source,
instead of using many different sources. This means that their work is made easier, and that
they can operate more efficiently.
129
Annex 8: Trade and economic patterns
Ports vary substantially both in size and specialisation. The 83 main seaports included in the
TEN-T core network handle approximately 70% of the cargo passing through all EU seaports.
Figure 15: Number of vessels calling EU ports in one year 2005-2015 (EU28)162
Figure 16: Projected number of port calls 2015-2030 (developed from EU reference scenario 2016 and EuroStat data)
162
Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-
explained/index.php/Maritime_ports_freight_and_passenger_statistics
2000000
2050000
2100000
2150000
2200000
2250000
2300000
2350000
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
0
500,000
1,000,000
1,500,000
2,000,000
2,500,000
2016 2018 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Port
calls
/
year
Fixed routes Non scheculed/tram routes
130
Figure 17: Transport growth in EU28: passengers, goods and GDP163
Of the goods transported via the main EU maritime ports, liquid bulk goods accounted for
38% of the total cargo; dry bulk goods for 23%, containerised goods for 21% and goods
transported on roll-on, roll-off (Ro-Ro) mobile units made up 12 %.164
Technical developments constantly change the capacity and composition of the EU fleet. One
of the main trends today is the move towards larger vessels. The average size of vessels
calling in the main EU-28 ports is slowly increasing and amounted to about 7 400 GT in
2015.165
Gigaliners, autonomous vessels and vessels with alternative propulsion
systems/alternative fuels are being developed.
While the road transport share of goods traffic in the EU steadily increases, the maritime
transport modal share has slightly decreased over time, although now somewhat recovering
since the dip in 2007-2009.166
163
European Commission, Statistical pocketbook 2017: EU transport in figures,
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en
164
Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-
explained/index.php/Maritime_ports_freight_and_passenger_statistics
165
Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-
explained/index.php/Maritime_ports_freight_and_passenger_statistics
166
European Commission, Statistical pocketbook 2017: EU transport in figures,
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en
100
105
110
115
120
125
130
135
140
145
199519961997199819992000200120022003200420052006200720082009201020112012201320142015
1995=100
Passengers, Goods, GDP
1995-2015
Passengers (1) (pkm) Goods (2) (tkm) GDP (at constant year 2005 prices)
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Figure 18: Modal split over time in EU28 (goods transports, single market)167
International trade
In 2015, 3.1 billion tonnes of goods were shipped by sea to or from EU ports. This was an
increase by 1.6 % from 2014. 63% of these goods were international transports. Maritime
167
European Commission, Statistical pocketbook 2017: EU transport in figures,
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en
0
10
20
30
40
50
60
1995 2000 2005 2010 2015
Road
Rail
IWW
Pipelines
Maritime
Air
0
10
20
30
40
50
60
70
Passengers, excluding
cruise passengers (%)
Goods (% of tonnes)
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transport is the most important mode for long distance transport of goods to or from the EU, in
tonnage terms. 168
EU trade exports to a value of 860 billion EUR were transported by sea in 2015. Seaborne
imports amounted to a value of 920 billion EUR in the same year.169
(% of trade based on value) Imports Exports Total trade
EU28 53.0 48.1 50.5
Table 8: EU Member States trade in goods with non-EU countries carried by sea, 2015170
Intra-EU traffic and short-sea shipping
The transport operators in intra-EU traffic and short-sea shipping are the ones most affected
by the lack of harmonisation at EU level, together with ships in international traffic calling
several different ports in the EU.
Maritime transport accounted for 31.6% of all single market goods transports in 2015. For
passenger transports within the single market, maritime mode accounted for 9.8%.
According to Eurostat, 25% of the approximately 3.8 billion yearly tonnes of seaborne goods
and 33% of the 395 million passengers going in or out of EU ports are shipped in intra-EU
traffic.171
Estonia, Ireland, Latvia, Malta, Finland and Sweden have especially high shares of
international intra-EU transport (above 60 % of all transported goods in tonnes). 172
Larger
ports tend to have a larger deep sea and transhipment function compared to smaller ports who
tend to have a larger share in short sea transport.173
Short-sea shipping is the transport of goods between main ports in the EU-28 member states
and ports situated in geographical Europe or in non-European countries on the Mediterranean
and the Black Sea. 1.8 billion tonnes of goods were transported as part of EU short sea
shipping in 2015, an increase of 0.9 % from the previous year. Short sea shipping made up
168
Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-
explained/index.php/Maritime_ports_freight_and_passenger_statistics
169
European Commission, Statistical pocketbook 2017: EU transport in figures,
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en
170
Eurostat Newsrelease 184/2016: World Maritime Day,
http://ec.europa.eu/eurostat/documents/2995521/7667714/6-28092016-AP-EN.pdf, 28 September 2016
171
Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-
explained/index.php/Maritime_ports_freight_and_passenger_statistics
172
Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-
explained/index.php/Maritime_ports_freight_and_passenger_statistics
173
DRAFT: Study on support measures for the implementation of the TEN-T core network related to sea ports,
inland ports and inland waterway transport: Analysis of major geopolitical and technological developments
affecting the future development of the EU seaport system, p. 34 of the draft study; update reference with
D3 for final text
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close to 59 % of the total maritime transport of goods to and from the main EU ports in 2015,
about the same as in 2014.
Hinterland connections: cross-modal links
The smooth functioning of port calls is one link in a longer transport chain. Ports are not the
final destination of goods. The efficiency of the ship port calls will impact on the entire
logistics chain and the hinterland transports of goods and passengers to and from the ports.
Depending on the nature and volume of the goods and on the distance the cargo should be
transported, transports per road, rail, pipeline or inland waterways connect to the maritime
transports. The shares of each transport mode vary significantly from port to port depending
on geographical and other specificities.
Road transport provides, overall, the largest share of throughput transport to and from ports.
Road is the preferred mode for smaller volumes of cargo or shorter distances. It provides high
flexibility and door-to-door transport possibility.
Rail is a preferred mode for goods on regular/frequent services and for long-distance transport
of e.g. dry bulk or containers.
A large share of ports have inland waterway connectivity, especially in the North Sea and
Black Sea basins. All ports in Belgium and the Netherlands are connected to the Rhine-
Scheldt delta. In the Black Sea area, the Romanian ports are connected by the Danube. The
low cost and high capacity makes inland waterways, where available, a preferred mode
especially for container transports. European container traffic on inland waterways is highly
driven by the three largest European ports: Rotterdam, Antwerp and Hamburg.
For oil and gas, pipelines are mostly used, especially for short distances. 4.8% of all tonne-
kilometres of transport go by pipeline.
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Figure 10-19: Modal Split share in selected Seaports (Overall Throughput in 2013)174
174
European Parliament; Directorate General for Internal Policies, Modal share of freight transports to and from
EU ports, 2015, p.38,
http://www.europarl.europa.eu/RegData/etudes/STUD/2015/540350/IPOL_STU(2015)540350_EN.pdf