COMMISSION OF THE EUROPEAN COMMUNITIES 
Brussels, 21.12.1998 
COM(1998) 795 final 
COMMUNICATION FROM THE COMMISSION 
TO THE COUNCIL, THE EUROPEAN PARLIAMENT, 
THE ECONOMIC AND SOCIAL COMMITTEE 
AND THE COMMITTEE OF THE REGIONS 
on 
INTEROPERABLE ELECTRONIC FEE COLLECTION 
SYSTEMS IN EUROPE 

SUMMARY 
1. Electronic Fee Collection (EFC) systems offer the possibility of charging road 
vehicles in a highly flexible way. This enables the implementation of charging 
policies for the use of infrastructure to improve transport efficiency, allowing the 
recovery of costs and/or the management of traffic. It is important that such systems 
be interoperable across national borders to avoid creating new obstacles to traffic 
flows in Europe, in accordance with the Single Market provisions of the Treaty. 
2. Ultimately, interoperability should enable users to pay tolls without changing their on­
board equipment or reverting to manual payment when they cross the boundaries of 
different EFC areas. At the present time, however, EFC is at very different stages of 
implementation in various European countries and the Council1 has requested a 
strategy for convergence of EFC systems to an appropriate level of interoperability in 
the European Union (EU). 
3. In the intermediate convergence period, the degree of interoperability between EFC 
systems may be different between countries. Equally, the methods by which this 
intermediate degree of interoperability is achieved, and the corresponding costs may 
be different. However, the long term objective is that all European EFC systems will 
enable the use of interoperable on-board equipment by traffic moving from one system 
to another. 
4. In addition, the use of EFC for road pricing or access control to manage traffic is being 
considered by many as a possible contribution to a solution for the growing traffic 
congestion in urban agglomerations in Europe. Interoperability between urban and 
interurban applications therefore needs to be taken into account in the development 
and implementation of EFC systems. This will mean close co-operation between those 
responsible for achieving cross-border interoperability, and those dealing with urban 
schemes. 
5. This Communication examines the issues involved in developing a framework for the 
timely deployment of interoperable EFC systems in Europe able to support the 
implementation of current and future agreed charging policies while allowing national 
and regional variations. It proposes the best approach in resolving these issues, 
allowing in particular the implementation of the Commission proposals in the White 
Paper "Fair Payment for Infrastructure Use"2 on distance related charging with 
differentiation of rates according to vehicle and geographical characteristics. 
a) First major issue : Technical interoperability. Existing EFC systems for 
motorway tolling make use of Dedicated Short Range Communication (DSRC) 
Council Resolution 97/C 194/03 of 17.6.1997 on the development of telematics in road transport in particular 
with respect to electronic fee collection, OJ C 194 of 25.6.1997 
2 Commission White Paper COM(98) 466 final of 22.07.1998 on Fair Payment for Infrastructure Use: A phased 
approach to a common transport infrastructure charging framework in the EU. 
between the roadside and the vehicle. The feasibility of the DSRC technology 
has already been demonstrated, and European pre-standards have been agreed, 
which are not always compatible with the existing systems. 
An alternative system being considered makes use of satellite location 
(GNSS3) and mobile telephone technology (GSM). The individual basic 
technologies for satellite location and mobile telephone communication are 
well proven, but tolling applications based on the combination of these 
technologies are not advanced. The technology chosen will depend ultimately 
on the specific requirements, the timetable involved and the state of 
technological development. 
The first task should be the definition of a common minimum level of 
functionality for systems to enable drivers to use their onboard payment device 
on the networks of all the operators in the system. The scope for the 
development of equipment able to use both technologies needs to be examined. 
b) Second major issue : Contractual interoperability. The availability of 
technically interoperable equipment needs to be accompanied by contractual 
agreements between operators, and also between operators and other possible 
issuers of payment means. All relevant issues are being examined within EU-
sponsored projects with a view to the conclusion of a Memorandum of 
Understanding by the relevant actors. 
c) Non-equipped users : An issue of particular importance is the treatment of 
users who are not equipped with the necessary electronic on-board payment 
device. Within realistic expectations for non-discrimination, EFC systems 
need to be designed so that such users are not subjected to cumbersome and 
time consuming alternative payment procedures or to penalising prices. 
Within these constraints Member States introducing EFC systems may apply 
the options best suited to their circumstances for the treatment of non-equipped 
users. 
d) Classification : Vehicle classes used in each country do not themselves require 
harmonisation in order to achieve interoperability, although such class 
harmonisation would facilitate comparability and simplify users' understanding 
of charges. An acceptable set of vehicle attributes, which can be used for 
classification purposes, is essential and needs to be agreed. Work on this has 
already started within EU-sponsored projects under the 4th Framework 
Programme and the Trans-European Transport budget. Work is also well 
advanced in the European Standardisation bodies for drawing up a standard on 
classification parameters. To enable EFC systems to fulfil the likely 
requirements of future charging and pricing legislation, this set could include 
in addition to the usual vehicle characteristics, environmental attributes, such 
as emission and noise characteristics. As some of these attributes cannot be 
measured dynamically, they need to be stored in the vehicle on-board 
3 GNSS : Global Navigation Satellite System. 
equipment and interoperable EFC systems must be able to handle them. 
Member States may elect to charge vehicles using any combination of these 
declared attributes and / or the usual measured characteristics. 
e) Enforcement : Failure to enforce payment negates the policy objectives, and 
results in loss of credibility for the operators as well as loss of revenue. 
Enforcement must therefore form an integral part of any fee collection system. 
At present, the technical integration of system components to enable fully 
automatic enforcement in multi-lane systems presents a challenge in meeting 
operational reliability requirements. Effective cross-border information 
exchange and prosecution of offenders needs agreement on forms of evidence 
and on procedures. The. potential for successful enforcement through the 
establishment of close links and co-operation between tolling enforcement 
agencies and national registration data bases should be explored. 
f) Fraud : The incidence of fraud may increase as interoperable systems extend 
over wider geographical areas. Until an acceptable degree of system security is 
achieved, operators may wish not to enter into the contractual agreements 
which are necessary for systems interoperability. On the other hand, users 
need to be assured of an acceptable degree of data protection and privacy, 
which may vary according to different national approaches and traditions as 
well as according to requirements of individual users or user groups. 
6. The aim is to define a strategy and actions which give satisfactory answers to the 
issues above : the objective is that EFC systems in Europe should converge to "an 
appropriate level of interoperability". In determining what is to be considered as 
appropriate, it is necessary to take into account many factors. These include EU and 
national policy requirements, requirements of operators for system resistance to fraud, 
the desire of some users for anonymity, the extent of deployment of existing systems, 
the cost of changes to these systems, and the agreed timetables. 
7. This strategy will be developed respecting EU and national legislation and principles, 
like non-discrimination between users and data and privacy protection. In the medium 
term it seems most probable that each country according to its own national 
requirements will deploy its own EFC system but with sufficient common 
functionality to enable drivers to use their on-board equipment at least in several 
countries. 
8. Priorities for implementation need to tie in with policy priorities for 
introducing/developing charging systems. This means that immediate action should 
be undertaken to implement such systems for certain classes of vehicles, like Heavy 
Goods Vehicles (HGVs), to which EU charging rules already apply4, and also to long 
distance coaches. This is the category for which the single market arguments for both 
a common approach to charging, and international interoperability are strongest. A 
further advantage of starting with HGVs is that enforcement, privacy protection and 
4 Council Directive 93/89/EC of 25 October 1993 on taxes and charges on HGVs, OJ L279/32 of 12 November 
1993 
the question of non-equipped users could be easily solved. However, in giving 
priority to charging systems for HGVs and long distance coaches, no obstacle should 
be placed in the way of wider interoperability of systems. 
9. An EU strategy to achieve interoperability of EFC systems, allowing for convergence 
of existing and future systems will therefore require a phased approach. This is also 
in line with the phased approach for infrastructure charging put forward by the 
Commission in its White Paper. 
10. Main actions in the first phase (1998 to 2000) will be based on the following key 
assumptions: 
i. priority will be given to interoperability of EFC systems for HGVs and long-distance 
coaches used on the Trans-European Road Network (TERN). This will need to provide 
the means to implement decisions on EU wide charging policies. The Commission's 
White Paper proposed application to commercial operators of greater cost-related 
charging, differentiating by time, vehicle characteristics, route and so on', by 2004. 
ii. interoperability between urban and inter-urban applications also needs to be given 
priority in the development and implementation of EFC systems 
iii. an open-system architecture will be necessary, capable of responding to policies 
developed at EÙ pr national levels, of integrating further operational and technological 
developments, and enabling commercial opportunities. Such an architecture would 
require consideration of dual or multi-mode equipment which would permit the use not 
only of DSRC technology but also of GNSS-based systems or other technology, where 
appropriate, in response to policy need or operational convenience. The architecture 
should also allow the potential exploitation of EFC-based technologies for traffic 
management and value-added services. „ 
Achieving these objectives will require action by the Commission, the Member States, 
local and regional authorities, concessionaires, and by the standards bodies. 
These actions will be : 
a) to define and agree a common minimum level of functionality at the EU level 
(ie the'basic features needed in order to achieve interoperability, e.g. capacity to 
distinguish types of vehicle, methods and arrangements to effect payments etc), 
reflecting policy and operational requirements. This will be based on work done 
within EU-sponsored projects under the 4th Framework R&D Programme 
particularly on Transport Telematics Applications and of the Trans-European 
Network - Transport Programme. Any additional actions will be undertaken in 
the 5th Framework Programme. 
b) to enable these common functions to be performed, CEN (Comité Européen de 
Normalisation) should complete its work on EFC on the basis of Mandate 270 
from the European Commission, developing, validating and adopting standards 
on DSRC and other areas, where appropriate. These standards should enable 
multilane operation and the introduction of traffic management and other value-
added services, using the same technology. 
c) The Commission will help all interested parties to complete the wprk on 
contractual interoperability by promoting the signature of a Memorandum of 
Understanding between them, based on an EU framework agreement. 
d) The Commission will explore ways to facilitate cross-border enforcement and to 
adequately cover privacy and data-protection issues. 
e) The Commission will co-operate with cross-national groups of urban or regional 
authorities considering the introduction of road pricing, so as to offer a co­
ordinated approach between local systems and between them and inter-urban 
services. 
11. The Commission will put forward proposals for actions in subsequent phases on the 
basis of the results obtained in the first phase, and ongoing policy developments. The 
aim will be to achieve a convergence strategy for interoperability of EFC systems as 
requested by the Council. Failure to achieve interoperable EFC systems will cause 
disbenefits for the European citizens, especially long distance drivers who will be 
confronted with artificial borders between the different Member States, obliging them 
to use different cards or onboard units, or to stop and pay cash at toll booths. European 
industry will loose a competitive advantage on the world market, due to the 
proliferation of proprietary systems, and the resulting absence of economies of scales. 
Finally, road operators will also suffer because of increased equipment costs and 
restriction on their freedom of choice. 
12. In the meantime, the Commission recommends that decisions by national and local 
administrations or private concessionaires on EFC systems should be based on this 
Communication. 
The Commission therefore asks the Council and the Parliament to endorse this first stage in a 
convergence strategy for EFC systems in Europe and the assumptions on which it is based. 
TABLE OF CONTENTS 
1. INTRODUCTION ~ 1 
2. EVOLUTION OF SYSTEMS 3 
3. THE CHALLENGE OF INTEROPERABILITY 4 
3.1 GENERAL 4 
3.2 DEFINITION OF A COMMON MINIMUM FUNCTIONALITY FOR EQUIPMENT 6 
3.3 INTEROPERABILITY OF MOTORWAY TOLLING SYSTEMS WITH URBAN APPLICATIONS AND OTHER AREA 
TOLLING SCHEMES 7 
4. THE ISSUES 9 
4.1 NON-EQUIPPED USERS 9 
4.2 CLASSIFICATION ISSUES 10 
4.3 ENFORCEMENT ISSUES 11 
4.4 ISSUES CONCERNING DATA PROTECTION AND SYSTEM SECURITY 12 
4.5 PRIVACY ISSUES 13 
5. PREREQUISITES FOR CONVERGENCE .......14 
6. CONCLUSIONS 15 
\ti 
1. INTRODUCTION 
13. , Many road authorities now seek the recovery of construction, operation and 
maintenance costs of roads through tolls or other road use charges. In addition, many 
governments and city authorities are also considering some form of road pricing to 
manage traffic demand and to reduce the negative impacts of transport in terms of 
congestion, accidents and pollution, thereby improving the safe and efficient use of 
existing road infrastructure. 
14. These trends associated with substantial increases in road traffic lead to the 
consideration of charging systems which are able to levy road charges automatically 
and without the need for drivers to perform any additional actions beyond those related 
to normal driving activities. The systems should enable the collection of such charges 
at normal highway speeds and without creating obstacles to traffic flow as a result of 
lane segregation. 
15. In some countries with a long established tradition of motorway tolling, Electronic Fee 
Collection (EFC) systems have already been introduced, alongside manual payment 
methods using toll booths. This was a response to the wishes of motorists for a faster 
and more efficient service and of the operators for a more cost-effective operation. 
With the expansion of EFC systems, either newly introduced or as replacements of 
previous manually operated toll systems, the need for interoperability becomes 
increasingly pressing. 
16. Interoperability from the point of view of users is the ability to travel throughout the 
Union without having to adopt procedures different from those of their own countries 
and without having to install extra equipment when changing from one charging area 
to another. Interoperability is an important factor in serving Single Market and 
sustainable transport policy objectives, and contributing to the creation of the internal 
market for industry and the development of the Information Society. This justifies 
action at the EU level to achieve interoperability between EFC systems. 
17. In 1993, when the first harmonised Community approach on vehicle taxation and 
tolling for Heavy Goods Vehicles was established5, the Council requested Member 
States intending to introduce electronic toll systems to bear in mind the desirability of 
interoperability between systems. In order to address the issues raised by this 
requirement, CARDME6 was established to promote consensus on medium to long 
term strategies for convergence to full interoperability of EFC systems on European 
roads. 
18. Later, and in the light of ever increasing traffic congestion, environmental pollution 
and transport accidents, the Commission presented in 1995 its Green Paper on Fair and 
5 Council Directive 93/89/EEC of 25.10.1993 on the application by Member States of taxes on certain vehicles 
' used for the carriage of goods by road and tolls and charges for the use of certain infrastructures, OJ L 279 
of 12.11.1993 
6 Concerted Action for Research on Demand Management in Europe 
Efficient Pricing in Transport7. In it the Commission put forward the view that prices 
paid for individual journeys should be better aligned with the real costs of these 
journeys. As costs differ across time, space and transport modes, this implies a need 
for more differentiation and transparency, which can only be met by some form of 
electronic road pricing. However, the Green paper says that care should be taken to 
avoid the deployment of incompatible systems and to establish European-wide rules 
for interoperability. The Commission has now put forward more concrete proposals in 
a White Paper for transport infrastructure charging. This takes the form of a coherent 
framework on infrastructure charging in different modes. Its main relevance for EFC 
is that it sets out â timetable for implementation, and gives clear priority to action on 
HGVs, leading towards a differentiated kilometre charging system. 
19. Last year, the European Commission adopted a Communication8 to the Council and 
the European Parliament on a Community Strategy and Framework for the 
Deployment of Road Transport Telematics in Europe. In its proposals for initial 
actions the Commission has identified EFC as one of the priority areas in road 
transport telematics at EU level, where action is needed in order to devise and 
implement a strategy to achieve convergence between existing and new systems in 
order to ensure an appropriate level of interoperability Europe-wide. 
20. The Council of Ministers adopted a Resolution9 on the deployment of Road Transport 
Telematics, with particular emphasis on EFC systems. This again stresses the 
importance of developing a strategy for convergence of EFC systems in Europe taking 
into account already existing systems and the work of the European standardisation 
bodies in order to achieve an appropriate level of interoperability at a European level. 
This Communication examines the obstacles to interoperability of EFC systems and 
sets out a recommended approach to.achieve an appropriate level of interoperability at 
European level. It is not its aim to examine any aspect corresponding to the charging 
policies of the Member States or the EU for road transport, like for instance variation 
of charges by road type, or time. The assumption is that interoperable systems should 
enable all agreed policies to be implemented. 
The international dimension of road freight transport in the EU, the Single Market 
logic which precludes the creation of barriers to intra-Community transport and 
commerce by road, the plans for new inter-urban EFC systems, as well as the 
Commission proposals for road pricing, starting with commercial transport, all point to 
the need to give priority in our work at EU level to EFC systems intended for use on 
the TERN and applied to HGVs and long-distance coaches and buses. 
7 COM(95)691 final of 20.12.1995 Towards fair and efficient pricing in transport - Policy options for 
internalising the external costs of transport in the European Union 
8 COM(97) 223 final of 20.05.1997 on a Community strategy and framework for the deployment of road 
transport telematics in Europe and proposals for initial actions 
9 Council Resolution 97/C 194/03 of 17.6.1997 on the development of Telematics in road transport in particular 
with respect to Electronic Fee Collection, OJ C 194 of 25.6.1997 
21. In line with the principles of subsidiarity and proportionality, the approach is designed 
to ensure that necessary progress on EFC has been made to allow implementation of 
current and future agreed charging policies while allowing national and regional 
variations. 
2. EVOLUTION OF SYSTEMS 
22. The original road tolling systems involved vehicle drivers stopping at a barrier and 
paying the toll keeper who then opened the barrier. This simple procedure was most 
suitable for low traffic densities. It had the advantage of ensuring that all vehicles paid 
according to their classification while, at the same time, the privacy of the driver was 
maintained. 
23. Before the advent of suitable telematics technology, payment was invariably manual 
and large toll plazas were constructed to avoid queues as drivers stopped to pay. Toll 
systems may be "open", where a toll plaza is just a payment point at a defined 
location, or "closed", where the exact entry and exit of the motorway are monitored 
and payment is made at the exit. Both systems have advantages and disadvantages 
depending on general policy, traffic flows, land available and other possible items, and 
operators study carefully the type used for each section. With increasing traffic 
densities and technical progress, electronic road tolling systems, using a microwave 
communication between the vehicle and the roadside, have been introduced in one or 
more lanes of the toll plazas. Even if barriers are often retained to ensure payment, 
this allows the flow of the plazas to be increased and reduces the average queuing time 
for the drivers. Non-equipped drivers still have to pay manually. The plaza designers 
have usually dedicated some lanes to these electronic systems, to get full advantage of 
the technology, when the number of subscribers was large enough. These systems are 
referred to as "monolane systems". Due to the lack of any standard, they have been 
developed without any provision for interoperability across concession borders. 
24. Some EU Member States do not presently apply tolling on their motorways and do not 
wish, for a variety of reasons, to build toll plazas. Instead, they are considering 
introducing "multilane" free flow systems in which drivers passing toll collection 
points do not need to reduce speed and remain free to change lane. Multilane 
applications do not require toll plazas, but at most, only specific equipment mounted 
on gantries at the tolling points to ensure tolling functions : vehicle detection, 
classification, payment and enforcement. The infrastructure required is minimal. EFC 
systems to deal with these requirements have been demonstrated, but some questions 
about overall reliability remain to be tested, taking into account the need for vehicle 
classification and enforcement of payment. 
25. Two alternative technologies for electronic fee collection are being developed : one 
based on microwave technology (Dedicated Short Range Communications - DSRC) 
and the other based on satellite positioning (GNSS) and mobile telephone (GSM) 
technology. The feasibility of the DSRC technology in the 5.8 GHz frequency band 
has already been demonstrated and European pre-standards were adopted in 1997. 
Although this basic frequency band has been formally designated by ERC (European 
Radiocommunication Committee - Decision of 22 October 1992) for the co-ordinated 
introduction of Road Transport Telematic systems, it may be necessary to review the 
corresponding bandwidth requirements in the near future in order to allow for services 
other than EFC. Further work is currently in hand to ensure that new industrial 
equipment of different providers are compatible with each other. This should be 
completed by the year 2000. On the other hand, although the basic technology for 
satellite location and mobile telephone is well proven, and opens up further options, 
tolling applications based on a combination of these technologies are not advanced. 
Satellite location technology will be used to define whether or not the vehicle is on a 
charged road, and for payment related to kilometres travelled, to compute the travelled 
distance. The GSM technology will be used to collect payment. In case of application 
of these technologies to a payment principle based on distance travelled, interfacing 
the payment equipment to'the digital tachograph, if any, should be considered as this 
may be an option for HGVs. Further R&D work is required to prove the integrated 
concept. 
26. Some EU countries already have developed or are developing an internal policy using 
short range microwave technology, enabling drivers to use the same onboard 
equipment over the whole national network. But the drivers must revert to manual 
payment when driving outside their home countries, as there is no cross-border 
interoperability of EFC systems in Europe at present. 
3. THE CHALLENGE OF INTEROPERABILITY 
3.1 General 
27. Interoperability means that drivers, equipped to pay motorway tolls using the EFC 
system in one country or concession area, are able to pay tolls in any other country or 
concession area without having to use different on-board equipment. It does not mean 
that there would be one single supplier, but that there should be sufficient technical 
compatibility between different systems, backed up by contractual agreements between 
operators, so that to drivers, paying tolls on different stretches of road in the Union 
would be a seamless operation. A second objective is that the on-board equipment 
(OBE) installed for payment of motorway tolls should, if possible, be suitable for use 
in urban areas for traffic management and possibly for other payment applications. 
28. Member States have agreed that interoperability is desirable10 and have stated that "an 
appropriate level of interoperability between EFC systems in the Community must be 
achieved so as to provide an optimum service to the user in reasonable economic 
conditions and without creating any unnecessary bureaucracy".11 They have not 
defined these concepts in a way which would enable a comparison to be made between 
the net benefits and the additional costs which might have to be incurred. 
Users will benefit from interoperability in terms of convenience, reduction in travel 
time and operating costs as well as the opportunity for added value services. 
10 Council Directive 93/89/EEC of 25 October 1993 on taxes and charges on HGVs, OJ L279/32 of 12.11.1993 
11 Council Resolution on Road Transport Telematics and EFC : 97/C 194/03 of 17.06.1997 previously 
mentioned 
29. In general, operators are concerned with maximising revenue and will experience 
financial benefits from interoperability if it results in lower costs or in more vehicles 
using motorways than would otherwise be the case. If the achievement of pan-
European interoperability requires the involvement of issuers of payment means other 
than the operators themselves, this may be seen as a disadvantage with a possible 
adverse effect on the immediate cash flows of the motorway operators. The charges 
made by finance houses acting as issuers must be sufficiently low to ensure 
acceptability to users and operators. 
30. Manufacturers are likely to benefit from the use of standard interchangeable 
equipment, especially when convergence between new systems and established 
systems has been achieved. Their penetration on the market might be significantly 
increased if the equipment was providing other related services in addition to toll 
charging, such as parking payment, access control, plus added value services. 
31. Work done by CARDME has concluded that interoperability can only be possible if 
appropriate agreements are reached at the technical, procedural and contractual 
levels. Broadly speaking, these concern respectively : the physical characteristics of 
the communication between vehicle and roadside equipment, the organisation and 
processing of the data which are exchanged (including the steps and algorithms of the 
transaction process), and the relations between users and operators and with potential 
third parties such as financial institutions. 
32. At the most basic technical level, vehicle on-board equipment based on DSRC 
technology must be able to communicate with roadside or ground equipment in each 
country or concession area. The CEN pre-standard for Dedicated Short Range 
Communication links (DSRC), which has recently been adopted, enables, rather than 
guarantees, communication, as system elements based on different permitted choices 
of technical parameters will not necessarily be able to communicate. Therefore, 
further agreements on the communication parameters between national authorities and 
operators in co-operation with industry will be necessary to guarantee technical 
interoperability. Since this CEN pre-standard is not compatible with some existing 
operational EFC systems in Europe, a strategy for convergence to pan-European 
interoperability is needed. 
33. The fact that systems using satellite navigation and mobile telephone technologies are 
being considered by some countries adds to the complexity of interoperability. As 
mentioned earlier, vehicle location in these systems uses satellite location technology 
while payment is by means of cellular communication between vehicle and a central 
system. Interoperability is needed not only between different systems of this kind, but 
also between these systems and DSRC systems. However contractual and procedural 
rather than technical solutions may provide this interoperability. 
34. Such technologies, i.e. DSRC and GNSS/GSM might be used for other applications 
than Electronic Fee Collection, like Route Guidance, Traffic Management, Protection 
against Car Theft, Logistic Fleet Management... Systems and services are already 
under development and testing in some Member States as well as abroad. These 
services will increase the potential number of subscribing vehicles and the needs for 
technical interoperability. They may affect the technical design of the equipment, but 
not the work already done in the standardisation bodies, who considered applications 
wider than EFC. Equipment for these services should be backward compatible with 
EFC systems as they are developed. 
35. At the procedural level, the functionality of the on-board equipment must match that 
required by the tolling application. This means that the information passed between 
the on-board equipment and the roadside during the transaction must provide the 
necessary information to enable guaranteed payment to the operator". 
36. The draft pre-standard for the definition of the application interface between the on­
board equipment and the roadside appears to offer the required framework for 
procedural interoperability for DSRC systems and a similar interface definition for 
systems using satellite location is being developed. However, some on-board 
equipment may conform to the standard but still not have the required functionality for 
a particular application since choices can be made within the standards. Therefore, an 
agreement is required on a minimum common functionality for on-board equipment 
that is required to be interoperable. Agreement on a common minimum level of 
functionality would enable users with appropriate on-board equipment to make 
payments to all operators subscribing to the agreement. 
37. At the contractual level, agreements are required between operators and possible 
issuers to enable operators to receive guaranteed payment. Users must be able to use a 
payment means which is accepted by the operator for each concession area through 
which they travel12. At the present time, such interoperability depends on individual 
bi-lateral agreements between operators, which is a complex process. European 
interoperability is unlikely to be achieved solely by means of agreements of this kind. 
The elements of a framework for the development of interoperable European payment 
methods are now beginning to take shape. But they will require further work to take 
into account the difference between laws and regulations in the Member States, as well 
as to set up principles for clearing between operators and financial institutions! 
However, the introduction of the EURO should make electronic debiting of accounts 
easier and more transparent within its area. The needs of consumers must be fully 
taken into account in developing these agreements and consumer interest groups might 
be consulted. 
3.2 Definition of a common minimum functionality 
38. A requirement for all national systems to have the same level of functionality in order 
to achieve interoperability could mean some countries being forced to adopt a higher 
level than required for internal use, or others being required to lower their 
requirements. To achieve interoperability, a balance will need to be struck. In 
planning new systems operators will need to take into account the objectives, 
requirements and constraints of their systems ensuring that all potential users are 
offered acceptable choices for payment. These might include, for instance, opening a 
12 Users will therefore require a contract with an issuer who in turn will guarantee payment to the operator. 
Operators will also require a contract with the issuer to provide the guarantee of payment under agreed 
terms and conditions. The issuer of the payment means may be another operator, or a financial institution. 
credit account, declaration to a central data base or payment by cash, whichever is the 
most attractive to the users. Finally they should provide those users who wish to have 
interoperability with the opportunity to install on-board equipment designed to support 
common payment methods and common EFC transactions. Such interoperable 
equipment will need to have a minimum common functionality which may be higher 
or lower than that required for some national systems. Operators might charge if it 
involves them in extra costs, but economies of scale of a pan-European market might 
make such charging unnecessary. 
39. As a general definition, the common minimum level of functionality shall comprise all 
the technical and contractual elements enabling electronic toll payment by authorised 
subscribers, with the same payment means and equipment everywhere on the networks 
of the operators in the system. 
40. Recommended approach. 
EU projects should work closely with the operators on the definition of a common 
minimum functionality taking into account, as a first priority, cross border traffic of 
heavy goods vehicles and long distance coaches. CARD-ME will be the forum for co­
ordination between them on this issue. The definition of a common minimum 
functionality should form the basis for a Memorandum of Understanding (MoU) to be 
used for contractual agreements between operators wishing to achieve 
interoperability. 
CEN should take into account in its current tasks the work on a common minimum 
level of functionality for electronic fee collection systems. 
The strategy for achieving common minimum functionality should allow operators of 
existing non-interoperable systems to migrate to the interoperable system in a way 
allowing them to depreciate their investments in an acceptable way. 
European and National standardisation bodies should finalise and approve current 
work on electronic fee collection systems including the standardisation of a DSRC 
link, and other systems such as those using satellite position location with cellular 
communication, as soon as possible. 
All the actions proposed to CEN and other European standardisation bodies in this 
document shall be initiated through European Commission mandate M 270, the results 
of which will be evaluated to verify their adequacy with the recommendations of this 
Communication. Further actions may require a new mandate for achievement of these 
objectives. 
3.3 Interoperability of motorway tolling systems with urban applications and 
other area tolling schemes 
41. The concept of charging for the use of urban roads as a potential means of demand 
management is gaining in importance within Europe. While it is desirable to ensure 
that local urban EFC systems are interoperable with motorway EFC systems, there can 
be considerable difficulties in achieving this. The underlying objectives, requirements 
and constraints for the two systems may be different and give rise to different 
solutions: the emphasis of motorway tolling up to now has been on cost recovery 
compared with the focus on demand management in urban road pricing. However, 
Single Market principles require certain common functionality and interoperability of 
the equipment used in both systems. 
42. Area tolling systems using satellite location and mobile telephone technologies may 
seem attractive for urban applications due to the reduced roadside infrastructure 
required and the ability to operate without toll plazas. They are, however, relatively 
unproven, and interoperability with DSRC based motorway systems is still to be 
achieved. Dual mode equipment will almost certainly be needed if some Member 
States were deciding to use the satellite location and mobile telephone technologies. 
For systems intended for heavy goods vehicles and long distance coaches, with a 
distance based charging scheme, an interface with the digital tachograph should be 
'considered. 
43. In most countries little attention has so far been given to harmonisation of the 
requirements of different cities or of interoperability between urban and motorway 
tolling systems. 
As a minimum, the developers of urban charging systems will need to ensure that the 
emerging framework for designing EFC systems, based on work in CEN, is used. 
The Commission will, as set out in its White Paper on Infrastructure Charging, co­
operate with cross-national groups of urban or regional authorities that are seriously 
considering implementing road pricing, so as to offer a co-ordinated approach between 
local systems and between them and inter-urban systems, and also to ensure that these 
groups can take full advantage of the research and technical work on EFC which has 
been carried out at EU level. 
44. Recommended approach. 
The developers of urban charging systems will need to ensure that the emerging 
framework for designing EFC systems is used to facilitate interoperability. For 
example, the CEN Standard Application Interface Definition should be used. 
CEN should include in the standardisation of systems using satellite location 
technology, the requirement for retrieving data on distance travelled. 
CEN should also include in the standardisation of the DSRC Application Interface 
Definition the input of distance data from an odometer or satellite. 
CEN in co-operation with ETSI should also ensure and verify electromagnetic 
compatibility between the different systems implemented around the infrastructures. 
An interface for transmitting distance data between the travel data recording 
equipment for heavy vehicles and EFC systems should be specified. 
4. THE ISSUES 
4.1 Non-equipped users 
45. In this Communication non equipped users include those who have no equipment and 
those who have equipment which is not interoperable with the system in the 
concession area in which they are travelling. 
46. Existing toll operators provide EFC as an optional service for those who do not wish to 
pay manually. However, the market penetration of such systems is currently small. 
Typically 5% of all users of tolled motorways have EFC equipment although the 
figure is considerably higher in Norway and Portugal. 
47. Countries that have toll plazas offer a variety of payment methods. Drivers may use 
cash, credit or debit cards, various payment cards issued by the operator for regular 
travellers, and in some cases may be able to pay using an automatic machine rather 
than a toll booth. They may also use different payment methods on different 
occasions. 
48. One of the serious issues facing countries introducing tolling systems for the first time 
is how to provide for those users who do not have an acceptable EFC payment method. 
Most countries consider that users have a right to pay by cash, and experience suggests 
that users may sometimes choose to use this method even when equipped to pay 
electronically. 
49. Where tolling is being introduced for a specific market sector, such as heavy goods 
vehicles (HGVs), different issues arise. It is feasible and simple to make EFC 
equipment mandatory for HGVs, as they are subject to regulation and inspection. 
HGVs are already required to be equipped with a tachograph and EU legislation is 
being drafted for specifying future digital distance recording equipment. In this case, 
as the vehicles to be tolled represent a small proportion of the total traffic, it follows 
that most users of tolled motorways will remain out of the process, and will not be 
required to fit on-board equipment. . It may also determine the type of EFC system 
used. 
50. Finally, it is important, especially from the enforcement point of view that EFC 
systems should be able to distinguish between non-equipped users who are required to 
pay and those who are exempt (see below). A possibility is that a Member State could 
require all vehicles be fitted with on-board equipment. Exempt Users would fit on­
board equipment that communicated their exempt status. Non-equipped users would 
then be violators. 
51. Recommended approach. 
There should be no direct or indirect discrimination between users on the basis of 
their country of origin. Within the overall constraints emanating from EU legislation, 
each country should be free to implement its own choice of options for the treatment of 
non-equipped users, according to its particular circumstances, including the road 
network and traffic characteristics. 
The basis for fee charging should be the same for all users, although discounts can be 
given for options that reduce operators ' costs. 
Information on the payment options available to non equipped users must be readily 
available, e.g. via standardised signs before entering the tolling area, and also by way 
of telephone enquiry services. 
The time required for arranging the use of a non-equipped option for payment should 
not be excessive in comparison with the journey time. 
4.2 Classification issues 
52. EFC systems need to classify vehicles in order to apply the appropriate tariff for the 
use of the tolled road. Most current road tolling systems use automatic equipment for 
classifying vehicles. Current classification systems installed in mono-lane EFC 
systems are accurate and reliable. They measure the physical characteristics of 
vehicles, such as the number of axles and height and length of the vehicle, from which 
the operator determines the class and thus the tariff. Classification systems being 
developed for the measurement of characteristics for multi-lane operation perform 
poorly so far. 
53. Classification systems based on measured characteristics can provide only a limited 
range of parameters, such as length, height and width, which do not fully satisfy the 
emerging needs for defining classes. To resolve this issue, the use of declared 
characteristics, which would be stored within the on-board equipment, is being 
investigated. In addition to physical characteristics, it would be possible to store other 
parameters like emission, suspension or load characteristics which are much more 
difficult or even impossible to measure directly, but which may assume much greater 
importance in the future. 
54. At present, the classes to be used for tariffing are the sole concern of each operator and 
are not required to be interoperable. Agreements on interoperability will need to 
include a common set of declared characteristics to be stored in the on-board 
equipment. 
Agreement is currently being reached through the standardisation process on the set of 
characteristics that may be required for interoperable systems, as part of the CEN 
proposal for a standard Application Interface Definition. 
55. Recommended approach. 
Classification systems based purely on vehicle length, width and height might not 
adequately satisfy the requirements of all countries, nor the likely future requirements 
of an EU efficient charging policy. As a consequence, a common set of declared 
classification parameters needs to be agreed during the negotiation between 
operators. This should be included in the MoU between them. 
EFC systems for interoperable use in multi-lane environments need to be capable of 
storing and processing claimed characteristics without affecting the functionality of 
systems using measured characteristics. 
10 
CEN should draw up a standard on classification parameters able to fulfil the 
requirements of the operators. 
4.3 Enforcement issues 
56. Enforcement forms an integral part of any tolling system. Failure to enforce payment 
results in loss of credibility of the systems and non-attainment of the objectives of 
revenue collection or traffic management. There are two main issues here: 
57. Firstly, the technical performance of enforcement in DSRC systems that offer mono-
lane operation is generally acceptable whereas multi-lane operation is still not 
adequate. These systems are required to produce proof of passage and of the fee 
payable under all traffic and environmental conditions. The task of detecting, 
classifying and registering vehicles travelling in free traffic conditions present" a 
complex technical challenge. Enforcement may be separated from charging, 
depending on privacy requirements and overall system architecture. Possible 
enforcement procedures include the use of data bases. In the event of failure of the toll 
transaction, it must be possible to identify a vehicle as a result of photographing the 
physical number plate or electronically by reading an electronic number plate. 
58. A related issue is that roadside systems will register the passage of any vehicle that has 
been identified as not paying. Many users will not be obliged to pay and these users 
must not be enforced. EFC systems must therefore have the ability to distinguish 
between non-obliged users and obliged users who have not paid, in order' to avoid 
unjustified enforcement. Any of these users may be either equipped or non-equipped. 
59. The second major issue is that cross border prosecution of offenders will only be 
possible through international (general or bilateral) agreements that are not yet in 
place. An example for a bilateral agreement is arrangements between the Netherlands, 
Belgium and Germany on exchanges of data on drivers involved in traffic offences. 
Agreements are needed on mutual recognition of proof of payment and fee payable, on 
the exchange of information and on the administrative processes. The balance of costs 
incurred in carrying out these administrative processes in relation to the revenue that 
may be recovered is also likely to be an issue. If random checks are used, the 
probability of being checked must be the same for all users and must be high enough 
to act as a sufficient deterrent to non-payers. 
60. Systems that use satellite location and mobile telephone technology to collect tolls 
have special enforcement requirements. Whereas in DSRC systems the technical 
process of detection of non-payment occurs at the same time as the toll collection 
process and is an integral part of the transaction, this is not possible when the vehicle 
position is determined by its own on-board equipment and payment involves mobile 
telephone technology. In systems of this type a separate enforcement system is 
needed. 
11 
61. Recommended approach. 
A general framework at EU level for the facilitation of the prosecution of EFC 
violations across national borders should be explored by the Commission, 
complementary to or as a basis for bilateral agreements. 
National authorities should be encouraged to establish further links between tolling 
enforcement agencies and national registration data bases to facilitate enforcement 
across borders and of violators from other Member States. 
Toll operators and enforcement agencies should be encouraged to adopt common 
procedures for the exchange of evidence of violations and of data relating to 
enforcement. Evidence exchanged should comply with the regulations and the 
requirements on privacy (see §4.5). 
The electronic legibility of licence plates should be improved. Research on this could 
be part of the 5tn Framework RTD Programme. 
Toll system purchasers, and prospective purchasers, should be encouraged to promote 
further research, development and testing of tolling systems, with particular attention 
to the enforcement subsystems for multi-lane tolling. This should draw on relevant 
work within the EU RTD programmes. 
4.4 Issues concerning data protection and system security 
62. As users are offered the possibility of travelling across Europe using interoperable 
payment methods and on-board equipment, the risk of fraud inevitably increases. 
Users will enjoy the benefits of unhindered travel on longer journeys through various 
concession areas but this, in itself, provides greater opportunities for organised fraud. 
The security mechanisms designed to protect operators and regular car users in a local 
area may not be appropriate for Trans-European traffic. 
63. Fundamental work within MOVE-it13, CARDME and Working Group 1 of CEN 
Technical Committee 27814 has been developing the security framework required to 
support these interoperable systems. Issues such as the acceptability of arrangements 
on protection of data from other Member States, liability in case of failure, disputes 
and burden of proof, and the certification of equipment, need to be taken into account 
in framing contractual agreements. It is important that effort is focused on defining 
and reaching agreement on approaches to the common data protection domain and on 
migration paths. Those paths could lead to general agreement on the need to mimmise 
the risk of non interoperability from different security requirements of individual 
operators. Any decisions on the privacy and security aspects of interoperable EFC 
systems will need to be in line with general principles of IT (Information Technology) 
13 EU RTD project, acronym stands for Motorway Operators Validate EFC for interoperable transport 
14 Technical Committee on Road Transport and Traffic Telematics 
12 
data security and personal privacy as well as national legislation and the EU Directive 
on Data Protection15. 
64. Recommended approach. 
The presumption should be that the general rules on data security and protection will 
apply, and will be sufficient unless there is a convincing case otherwise. 
National authorities and toll operators should however be encouraged to consider if 
any additional measures are needed. Provisions for liability, insurance and risk 
acceptance resulting from failure in data protection should be integrated in the 
contracts between parties. 
In-depth studies must be encouraged about the legal and practical implications for the 
protection of privacy, and about data which may arise from the use of Telematics 
applications in EFC systems. 
4.5 Privacy issues 
65. There is a general presumption that the privacy of users will be preserved by toll 
systems. General privacy requirements are included in existing national and European 
legislation but the particular requirements of users in relation to ËFC systems are not 
yet subject to specific legislation and are still open to debate. It may be very costly, 
even if it is possible, to meet all the privacy requirements of all the Member States. 
66. For example, deferred payment has been suggested as a way of handling non-equipped 
users in multi-lane tolling systems. Users would be permitted to pay tolls within a 
limited time such as 24 hours before or after using the motorway. This would mean 
that the operator would need to store the identity of users who have not paid by the 
time of leaving the motorway for this period of time before either confirming payment 
or triggering the enforcement process. The legality of such a scheme has not yet been 
tested in the courts, but there is evidence from other applications and other locations 
that the principle of such a procedure is feasible. 
67. Some users may desire an anonymous method of payment. This means that, not only 
is the user identity not revealed to a third party, but also the operator is unable to 
identify the user except as part of the process of enforcement of non-paying users. 
Cash payment currently ensures anonymity. Electronic money will soon become 
available and could offer similar anonymity if accepted by operators as a payment 
means. The issuers of general purpose electronic money would have to be the 
financial institutions but many operators are reluctant to accept the involvement of 
financial institutions, as the issuer handles very large amounts of money which are 
critical to the business of the operator. A possible compromise acceptable to operators 
but less convenient for users would be the use of sector specific electronic money 
which could only be used to pay for services provided by toll operators and for which 
15 EU Directive on the protection of individuals in regard to the processing of personal data of 23.11.1995 OJ L 
281 
13 
they themselves could be the issuers. Participation of consumer interest groups could 
help in the search for an appropriate solution and ensure its general acceptance. 
68. Recommended approach. 
The Commission will examine the EC Directive16 on privacy to check whether it 
adequately covers the privacy aspects ofEFC systems or whether specific legislation 
is required. In depth studies of the legal and practical implications for the protection 
of privacy, which may arise from the use ofEFC, should also be encouraged. 
5. PREREQUISITES FOR CONVERGENCE 
69. Given the present differences in systems technologies, levels of deployment and pilot 
schemes throughout the EU, a strategy for convergence to pan-European 
interoperability must envisage several stages of migration from the present position : 
EFC systems are deployed on a large or a small scale in some countries, while no 
systems are deployed in other countries and several countries have experimental 
systems or actively plan systems. The existence of these different stages of 
development means that migration options must enable an appropriate level of 
interoperability. This level will be reached through successive changes to equipment 
and to procedural and contractual agreements leading to interoperability with 
increasing functionality and covering a widening geographical area at minimum cost 
to operators and users. A first step will be the completion of work within EU-funded 
projects, which should enable the existing CEN pre-standard on the DSRC link to be 
converted into a full standard.. 
70. From a theoretical point of view there is something to be said for defining a target 
system for the future and then converging as economically as possible to this target 
system. In the long term this may be possible, but, in the short term, the expectation is 
that each country will have its own national system with sufficient common 
functionality to enable drivers to pay tolls electronically in at least several countries 
without needing to change equipment. 
71. Countries that have existing tolled motorways, whether with manual or automatic 
payment, have built toll plazas with many lanes. Normally only one or two lanes at 
each plaza are equipped for automatic toll collection. Technical interoperability of a 
sort may be possible by installing another system in one of the existing lanes if the two 
systems are compatible and do not cause mutual interference. 
72. The situation in countries that do not have existing toll plazas is quite different. The 
absence of toll plazas means that in most cases multi-lane operation will be essential 
and the problem becomes one of ensuring interoperability with the single lane On-
Board Equipment in use in other countries. The technical problems may not be 
insuperable but the operational problems of providing anonymity when required and 
avoiding financial loss by fraud are at least as difficult as for the existing systems. 
16 EU Directive on the protection of individuals with regard to the processing of personal data OJ L 281 of 
23.11.1995 
14 
73. Anonymity is most easily achieved by cash payment as in existing systems and, if this 
solution is advocated for new multi-lane systems, a means of cash payment for 
motorways without toll plazas must be devised. The distinction between anonymity 
when the movements of a vehicle are not known to anyone but the driver, and privacy 
when the vehicle movements are known to the system operator but can be legally 
protected, is important. 
74. The avoidance of fraud presents escalating problems as the number of users and the 
number of interconnected operators offering interoperability increases. For this reason 
it could be efficient to set up a step by step interoperable operation starting with some 
groups of operators and issuers in a limited area. 
75. In developing strategies for convergence it will be necessary to adopt a phased 
approach. It is recommended that in the first phase, we concentrate on interoperability 
for heavy goods vehicles and long distance coaches, for which the equipment may be 
less price sensitive than for private users and for which issues of privacy and 
enforcement may be easier to solve. Another is concerned with the minimum 
functionality concept recognising that the majority of private vehicle owners will 
rarely travel outside their own country. The project CES ARE and the Euro-regional 
projects like VIKING and CENTRICO will help to define this strategy. CARD-ME 
will be the forum for co-ordination between them on this issue. 
6. CONCLUSIONS 
76. EFC systems provide a flexible tool to implement EU, national, regional and local 
policies for charging road vehicles for the use of infrastructure, either for recovery of 
costs, or for traffic management purposes. The Council has agreed that an appropriate 
level of interoperability between EFC systems must be achieved, and has called on the 
Commission and Member States to accelerate work to identify and remove obstacles 
to interoperability of EFC systems. It has also called on Member States when 
replacing, upgrading or introducing EFC systems, to do so in accordance with the 
strategy for convergence.17 This will require a phased approach. This Communication 
sets out the first phase of such a convergence strategy. 
77. Main actions in the first phase (1998 to 2000) will be based on the following key 
assumptions: 
i. priority will be given to interoperability of EFC systems for HGVs and long-distance 
coaches used on the Trans-European Road Network (TERN). This will need to provide 
the means to implement decisions on EU wide charging policies. The Commission's 
White Paper proposed application to commercial operators of greater cost-related 
charging, differentiating by time, vehicle characteristics, route and so on, by 2004. 
ii. interoperability between urban and inter-urban applications also needs to be given 
priority in the development and implementation of EFC systems 
17 Present plans in some Member States for replacing, upgrading or introducing EFC systems already go in this 
direction 
15 
iii. an open-system architecture will be necessary, capable of responding to policies 
developed at EU or national levels, of integrating further operational and technological 
developments, and enabling commercial opportunities. Such an architecture would 
require consideration of dual or multi-mode equipment which would permit the use not 
only of DSRC technology but also of GNSS-based systems or other technology, where 
appropriate, in response to policy need or operational convenience. The architecture 
should also allow the potential exploitation of EFC-based technologies for traffic 
management and value-added services. 
Achieving these objectives will require action by the Commission, the Member States, 
local and regional authorities, concessionaires and by the standards bodies. 
These actions will be : 
a) to define and agree a common minimum level of functionality at the EU level 
(ie the basic features needed in order to achieve interoperability, e.g. capacity to 
distinguish types of vehicle, methods and arrangements to effect payments etc) , 
reflecting policy and operational requirements. This will be based on work done 
within EU-sponsored projects under the 4th Framework R&D Programme 
particularly on Transport Telematics Applications and of the Trans-European 
Network - Transport Programme. Any additional actions will be undertaken in 
the 5th Framework Programme. 
b) to enable these common functions to be performed, CEN (Comité Européen de 
Normalisation) should complete its work on EFC on the basis of Mandate 270 
from the European Commission, developing, validating and adopting standards 
on DSRC and other areas, where appropriate. These standards should enable 
multilane operation and the introduction of traffic management arid other value-
added services, using the same technology. 
c) The Commission will help all interested parties to complete the work on 
contractual interoperability by promoting the signature of a Memorandum of 
Understanding between them, based on an EU framework agreement. 
d) The Commission will explore ways to facilitate cross-border enforcement and to 
adequately cover privacy and data-protection issues. 
e) The Commission will co-operate with cross-national groups of urban or regional 
authorities considering the introduction of road pricing, so as to offer a co­
ordinated approach between local systems and between them and inter-urban 
services. 
78. The Commission will produce detailed proposals based on this approach and the 
results of the work currently underway at EU, national and regional levels. It will then 
put forward proposals for actions in subsequent phases on the basis of the results 
obtained in the first phase. 
79, In the meantime it recommends that decisions by national or local administrations or 
private concessionaires on EFC systems should be based on this Communication. 
16 
80 Failure to achieve interoperable EFC systems will cause disbenefits for the European 
citizens, especially long distance drivers who will be confronted with artificial borders 
between the different Member States, obliging them to use different cards or onboard 
units, or to stop and pay cash at toll booths. European industry will loose a competitive 
advantage on the world market, due to the proliferation of proprietary systems, and the 
resulting absence of economies of scales. Finally, road operators will also suffer 
because of increased equipment costs and restriction on their freedom of choice. 
81 The Commission therefore,asks the Council and the Parliament to endorse this first 
stage in a convergence strategy for EFC systems in Europe and the assumptions on 
which it is based. 
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