EN    EN EN 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 21.1.2009 
SEC(2009) 46 
  
COMMISSION STAFF WORKING DOCUMENT 
 
accompanying the 
Proposal for a  
 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
on reporting formalities for ships arriving in or departing from  ports of the Member 
States of the Community a nd repealing directive 2002/6/EC 
  
Report on impact assessment of differen t options to simplify/reduce/eliminate 
administrative procedures for Short Sea Shipping 
and implementing a European Mariti me Transport Space without Barriers 
{COM(2009) 11 final} 
{SEC(2009) 47} 
EN 2   EN TABLE OF CONTENTS 
1. Procedural issues and consulta tion of interested parties ..............................................8 
1.1. Organisation and timing ...............................................................................................8 1.2. Expertise and consultation............................................................................................8 1.2.1. External expertise ...................................................................................................... ...8 
1.2.2. Public consultation ..................................................................................................... ..8 
1.2.3. Workshops with stakeholders.......................................................................................9 1.2.4. Main results ............................................................................................................ ......9 
1.3. Consultation of the Impact Assessment Board.............................................................9 1.3.1. Opinion of the Board .................................................................................................... 9 
1.3.2. How the opinion has been taken into account ............................................................10 2. Problem definition ......................................................................................................10 2.1. Underlying drivers of the problem .............................................................................11 2.1.1. Internal market in maritime transport is incompletely achieved ................................11 2.1.2. Further problem drivers..............................................................................................11 2.1.3. Magnitude of the problem ..........................................................................................11 2.1.4. Main bottlenecks generated by exis ting administrative procedures...........................13 
2.1.5. Comparison with other transport modes.....................................................................17 2.1.6. Qualitative considerations ..........................................................................................17 2.2. Who is affected? .........................................................................................................1 7 
2.3. Foreseen evolution of the problem .............................................................................18 2.4. Right of the EU to act.................................................................................................18 3. Objectives .................................................................................................................. .18 
3.1. General policy objectives ...........................................................................................18 3.2. Specific objectives......................................................................................................1 9 
3.3. Consistency with other policy objectives ...................................................................21 
4. Policy options .............................................................................................................2 1 
4.1. Policy option A: The do-nothing option.....................................................................21 4.2. Policy option B: The case-by-case approach..............................................................22 4.2.1. “Authorised Regular Shipping Servic es” Licence linked to companies ....................22 
EN 3   EN 4.2.2. Veterinary and phytosanitary controls........................................................................23 
4.2.3. Simplification of requirements fo r the carriage of dangerous goods .........................23 
4.2.4. Enhanced electronic data transmission.......................................................................25 4.2.5. Co-ordinated inspections by administrative services .................................................25 4.2.6. IMO/FAL forms .........................................................................................................26  
4.2.7. Pilot exemption Certificates .......................................................................................26 4.2.8. Alternative language for administrative procedures...................................................27 4.2.9. Separation of areas in ports ........................................................................................27 4.3. Policy option C: Act on the basis of a co-ordin ated set of measures simplifying, reducing, and, 
wherever possible, eliminating fo rmalities for vessels sailing betw een EU-ports in line with the 
model of the Internal Market  offered by land transport .............................................28 
5. Analysis of impacts ....................................................................................................28 5.1. Policy option A: The do-nothing option.....................................................................28 5.2. Policy option B: The case-by-case approach..............................................................29 5.2.1. Economic impacts.......................................................................................................2 9 
5.2.1.1. Cost decrease for reduction of time spent for administrative procedures for goods ..30 5.2.1.2. Cost decrease for reduction of time spent during ship calls.......................................31 5.2.1.3. Impacts on the level of fraud ......................................................................................31 5.2.2. Environmental impacts...............................................................................................32 5.2.3. Social impacts.......................................................................................................... ...33 
5.2.3.1. Impacts on safety and security....................................................................................33 5.2.3.2. Impacts on employment..............................................................................................33 5.2.4. Administrative costs ...................................................................................................3 4 
5.3. Policy option C: Act on the basis of a co-ordin ated set of measures simplifying, reducing, and, 
wherever possible, eliminating fo rmalities for vessels sailing betw een EU-ports in line with the 
model of the Internal Market  offered by land transport .............................................35 
5.3.1. Economic impacts.......................................................................................................3 6 
5.3.1.1. Cost decrease for reduction of time spent for administrative procedures for goods ..36 5.3.1.2. Cost decrease for reduction of time spent during ship calls.......................................36 5.3.1.3. Impacts on the level of fraud ......................................................................................36 5.3.2. Environmental impacts...............................................................................................36 5.3.3. Social impacts.......................................................................................................... ...38 
EN 4   EN 5.3.4. Administrative costs ...................................................................................................3 8 
6. Comparing the options................................................................................................40 6.1. Cost and benefits of measures ....................................................................................40 6.2. The main economic, environmental and so cial impacts of the preferred option........43 
6.3. Preferred approach......................................................................................................44  
6.4. Impact of the preferred approach on stakeholders......................................................46 6.5. Uncertainties and sensitivity analysis.........................................................................47 7. Monitoring and evaluation..........................................................................................50 
Annex A: Administrative procedures applic able to intra-EU maritime transport....................51 
Checks on ship safety certificates............................................................................................. 54 
Customs procedures............................................................................................................. .....54 
Annex B: Comparison of administrative proc edures for road and maritime transports...........57 
Administrative procedures in road transport ............................................................................57 Comparison between maritime and road administrative costs .................................................58 
Annex C: Evolution of Short Sea Shi pping market (Baseline scenario) ..................................61 
Possible evolution of the maritime tran sport in the baseline scenario......................................61 
Annex D: Main assumptions for the Impact Assessment.........................................................65 Annex E: List of abbreviations................................................................................................. 68 
EN 5   EN Lead DG : DG TREN 
Other involved services : DG AGRI,  DG EMPL,  DG ENTR,  DG ENV,  DG ESTAT,  DG INFSO,  DG JLS,  
DG JRC,  DG MARE,  DG MARKT,  OLAF,  DG REGIO,  DG RTD,  DG SANCO,  DG TAXUD,  SG,  DG 
TRADE,  DG TREN 
Agenda planning or WP reference : 2008/TREN/017 - CLWP 
Executive summary 
Fast growth of heavy road transport and rela ted congestion, accidents an d pollution are the main 
economic, social and environmental pr oblems that the policy to promote S hort Sea Shipping is expected to 
address. Europe needs an efficient co-modal transpor t system combining the benefits of all modes to 
maintain and increase its competitiveness and prosperity  in line with the Lisbon agenda and the mid-term 
review of the White Paper on European Transport Policy. 
Complex administrative procedures hi nder Short Sea Shipping from deve loping faster. The administrative 
procedures involved have negative economic consequen ces, in particular costs th at are associated with 
administrative delays, frequent or  regular controls and the time spent preparing documentation and 
procedures. This complexity also decreases the attr activeness of the mode a nd entails that Short Sea 
Shipping cannot fully contribute the efficiency and sustainability of  the European transport system. 
While the removal of obstacles to land transport has finally  become a reality, the Internal Market across 
the European Union is so far incomplete for Short Sea Shipping. 
Under the concept of European Mari time Transport Space without Barr iers, the Commission services have 
assessed the main administrative and documentary procedures in S hort Sea Shipping w ith a view to 
simplifying, reducing or, when possible, eliminating th em for transport operati ons between two EU ports. 
In particular, the following procedures were examined: 
• Customs procedures (includi ng simplified procedures); 
• Ship reporting procedures. 
• Veterinary and phytosanitary procedures; 
• Carriage of dangerous goods; 
Further enablers were also considered: 
• Electronic transmission of  administrative data; 
• Single window for all administrative formalities; 
• One-stop shop for controls; 
• Pilot Exemption Certificates; 
• Alternative administrative language; 
• Dedicated areas for Short Sea Shipping in ports. 
EN 6   EN The policy options that were considered were: 
– Status quo as baseline scenario; 
– Case-by-case simplification of individual administrative formalities; 
– Act on the basis of a co-ordinated set of meas ures simplifying, reducing, and, wherever possible, 
eliminating formalities for vessels sailing between EU -ports in line with the model of the Internal 
Market offered by land transport. 
The impact assessment of these options was based on many assumptions made under careful consideration 
of the contributions of all stak eholders. It showed with suffici ent confidence that administrative 
simplification brings clear benefits and that the maritime transport sector should not be excluded from the 
general free-circulation regime in place for land transport. 
The initiative has receiv ed full support from the stakeholders invol ved, and it is one of  the cornerstones of 
the recent Communication on an integrated mar itime policy, the "Blue Book". The stakeholders 
considered that not only the actual delays, but the risk  of delays are important disincentives to use Short 
Sea Shipping. Reliability and punctuality are the mo st important factors and will be improved by the 
proposed measures at a rather moderate cost for the society. The alignment of administrative formalities 
applied to intra-EU maritime transport with the other modes will attract more shippers to maritime 
transport. 
It is thus suggested that the Commission adopts an action plan to simplify existing administrative 
procedures and eliminate some of them. The action plan comprises short term measures: 
– Rationalisation of vessel-related and goods-relate d reporting and forms required by Directives 
2002/6/EC (formalities for vessels at the arriva l/departure of ports), 2000/59/EC (waste and 
residue reception), 2002/59/EC (vessel monito ring) and Regulation (EC) N° 725/2004 (maritime 
security). 
– Elimination of systematic c ontrols and documentary request s by Customs for goods carried by 
sea between EU ports in line with inland transpor t. The measure will require a modification of the 
implementing provision of the Community customs code1 and should be in force by 2010. 
– Concerning the legislation on veterinary an d phytosanitary products, guidelines should be 
adopted in 2009 in order to speed up the do cumentary checks in Directives 89/662/EEC2, 
90/425/EEC3 and 2000/29/EC4. 
                                                 
1 Council Regulation (EEC) N° 2913/92 of 12 October 1992 and Council Regulation of the European Parliament and the 
Regulation (EC) N° 450/2008 of 23 April 2008 laying down the Community Customs Code; OJ L 145 of 4.6.2008, p. 
1 
2 Council Directive of 11 December 1989 concerning veteri nary checks in intra-Community trade with a view to the 
completion of the Internal Market; OJ L 395 of 30.12.1989, p. 13 
3 Council Directive 90/425/EEC of 26 June 1990 concerni ng veterinary and zootechnical  checks applicable in intra-
Community trade in certain live animals and products with a view to the completion of the internal market; OJ L 224, 
18.8.1990, p. 29 
4 Council Directive 2000/29/EC of 8 May 2000 on protective measures against the introduction into the Community of 
organisms harmful to plants or plant products and against their spread within the Community; OJ L 169, 10.7.2000, p. 1 
EN 7   EN Further enabling measures would also  need to be implemented, namely: 
– Enhancing the electronic transm ission of administrative data; 
– Setting-up an administrative single window; 
– Simplification of the sea trans port of dangerous goods by implemen ting in the EU Member States 
the equivalence between some IM DG (carriage of dangerous goods  by sea) rules and those of 
ADR/RID (carriage of dangerous goods by road/rail). 
The two first measures could be implemented and co-o rdinated under wider proposal s, in particular those 
to be included in the action plan for the deployment of e-maritime systems in 2009. 
In addition, recommendations should be given that Member States im plement further enabling measures, 
each time the local conditions permit to do it in an efficient manner, namely: 
– Coordinate the inspections carried out in the por ts by the various admini strative services (“one-
stop administrative shop”); 
– Extend the scope of Pilot Exemption Certificates; 
– Introduce the use of the language most commonly used at sea as an alternative to the national 
language(s) in administrative communication; 
– Create areas in ports dedi cated to Short Sea Shipping where that can facilitate the operations for 
this mode. 
This combination and co-ordinated implementation of the measures will allow cost savings and 
productivity benefits while maintaining th e availability of e ssential information. 
Information on goods under Customs and other types of  supervision (animal pr oduct, veterinary and 
phytosanitary) would still be available and have to be presented at spot checks. 
The package will allow a reduction of administrative burden estimated at € 2.4 billion and environmental 
benefits estimated at € 182-365 millions during the period 2009-2040. The costs for designing, developing 
and operating the measures are estimated at € 617 millions. They would be shared by the economic 
operators, essentially port author ities and shipping companies. The costs for national administrations 
would be negligible. 
The approach would not risk lowering standards an d thus preserves the fundamental objectives of 
Customs and safety related regulations. 
It would help lowering the costs to businesses in several Member States  and, subsequently, to consumers. 
EN 8   EN 1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Organisation and timing 
The creation of the Europ ean Maritime Transport Space without barr iers is part of the Commission’s 
Legislative Work Programme 2008 and corresponds to  action 2008/TREN/017 of the Work Programme of 
the Directorate-General of  Energy and Transport. 
An interservice Working Group on internal market  and maritime transport, which included DG  AGRI,  DG 
EMPL,  DG ENTR,  DG ENV,  DG ESTAT,  DG INFSO,  DG JLS,  DG JRC,  DG MARE,  DG MARKT,  
OLAF,  DG REGIO,  DG RTD,  DG SANCO,  DG TAXUD,  SG,  DG TRADE  and DG TREN  was set up in 
October 2006. The Group met seven times until May 2008. 
The group provided a first inventory of  administrative measures applying to intra-EU maritime transport 
measures, identify the objective to achieve for its inse rtion in the action plan for an integrated maritime 
policy, prepared terms of reference for the quantificati on of the impacts of potential options by an external 
consultant, prepared the questionna ire for a public consultation and followed up the impact assessment 
study. 
1.2. Expertise and consultation 
1.2.1.  External expertise 
An impact assessment study was carried out by PriceWaterhouse Coopers (PwC) between September 
2007 and June 2008. The consultant pr ovided assistance in order to: 
– Identify the main stakeholders involved and set up contacts in order to di scuss potential solutions; 
– Develop a first set of draft solutions; 
– Analyse the decision processes and possible bottlenecks for impl ementing potential solutions in 
order to come up with pract ical, well defined results; 
– Substantiate the discussion with the stakeholde rs by analysing and re porting on the relevant 
issues (market issues, legal issues, specific Customs procedures); 
– Provide the Commission with elements of impact assessments for possible solutions. 
1.2.2.  Public consultation 
As part of the European's freight transport agenda5 of 18 October 2007, the Commission services launched 
an open consultation on a "Europe an maritime transport space wit hout barriers" unt il 20 January 2008. A 
questionnaire was put online on the European Commi ssion website in view to gathering stakeholders' 
views. 
The number of stakeholders that participated in th e consultation was 52. 45 stakeholders were from EU 
countries, 4 from non-EU European countries and 3 from outside Eur ope. 7 contributions came from 
                                                 
5 Communication from the Commission: The EU's freight tr ansport agenda: Boosting the efficiency, integration and 
sustainability of freight transport in Europe, COM(2007)606 of 18 October 2007 
EN 9   EN national administrations (of which 3 were national gove rnments, 16 came from ports and port services, 9 
from ship owners and 5 from shipping agents. 
1.2.3.  Workshops with stakeholders 
In addition to the online consultation, two dedicated workshops with participants from the industry were 
organised in Brussels on 26 March 2007 and in Antwerp on 15 April 2008. 
The Consultant sent specific ques tionnaires to selected  port authorities and port operators. These 
questionnaires collected information on issu es partially covered in the consultation. 
A reference stakeholder group comprising twelve persons from industry a nd the administration was 
established in October 2007 and had the opportunity to make comments during the impact assessment 
process. 
1.2.4.  Main results 
The consultation confirmed that most procedur es require around one physical control per 
arrival/departure: according to several stakeholders , dangerous goods procedures require more than one 
control per arrival/departure. Danger ous goods procedures generate a cons istent delay to arrival/departure 
due to controls and require the highest number of controls (document request , documentary control, 
inspections). 
Several stakeholders complained about the poor compe titiveness of sea transport against road transport, 
inter alia , due to much more complex administrative procedures. 
They warmly welcomed the principle of the abolis hment of administrative procedures in intra-EU 
maritime transport to the same extent that th ey have been abolished for road transport. 
Some stakeholders, notably thos e from administrations, pointed to possible negative impacts of 
eliminating or reducing administrative procedures. Fo r instance, the ones for Da ngerous Goods) should be 
reduced at no risk for human health  and the reduction of border controls  should not give ri se to increased 
security risks, trafficking or smuggling. 
Many respondents, however, call for a simplification of administ rative procedures. For customs 
procedures however, a share of stak eholders, notably shipowners, propos ed their elimination. It was also 
highlighted that the elimination of barriers woul d enhance the development of trade and intermodal 
maritime transport. 
The outcomes of the consultation have  been used to identify the measur es to be assessed and have been 
complemented during the impact assessment. 
1.3. Consultation of the Impact Assessment Board 
1.3.1.  Opinion of the Board 
The Impact Assessment Board of the European Commission gave an opinion of the draft impact 
assessment report on 18 July 2008. The Board expressed a number of remarks, which can be summarised 
as follows. 
The problem definition shall present more thoroughly all the relevant administrative 
bottlenecks/regulatory failures genera ted by existing administrative pr ocedures, clearly differentiating 
EN 10   EN whether these flow from EU or na tional legislation. The general and sp ecific objectives shall relate to 
them and to the concrete measures envisaged in the various policy options. The report shall define on 
subsidiarity grounds which instruments and at which leve l would be used to implem ent the elements of the 
options. 
The overall utility of the initiative (in terms of net benefits/cost) is largely determined by the correct 
assessment of 'time cost savings' and the IA report shall present more clearly how and on the basis of 
which assumptions the corresponding es timates have been calcu lated, and to what extent stakeholders 
considered these time cost savings to be the most im portant benefit of this initiative. The report shall 
clarify how the Standard Cost Model SCM methodology has been us ed when assessing changes in 
administrative burden. 
The IA report assumes (on the basis of two scenario s) significant environmental benefits resulting from 
the reduction of external costs (mainl y air pollution) due to an expect ed modal shift from road/rail to 
maritime transport. The report shall clearly set out  how Short Sea Shipping competes with road/rail 
transport, specify which Member States will be most affected and present more clearly the calculations 
and the data used to develop the s cenarios, consistent with the IA on  external costs of  transport (e.g. 
impact of the up-coming Euro VI measures for road transport). 
1.3.2.  How the opinion has been taken into account 
Modifications have been brought to the Report in order to integrate the remarks of the Board. In particular, 
a table based on the description of the policy measures  has been added under the "Problem definition" in 
order to describe more precisely the list of administrative bottlenecks and the information whether they flow from EU or national legislati on. The specific administrative failur es have been added in the table 
"specific objective" (paragraph 3.2.). The description of each m easure which is part of Option B 
(paragraphs 4.2.1. to 4.2.9.) indicates now clearly what the avai lable instruments are. An extended 
description of the methodology used  has been added as Annex D. 
2. P
ROBLEM DEFINITION  
The administrative procedures involv ed in Short Sea Shipping have negative economic consequences, in 
particular costs that are associated with administra tive delays, frequent or regular controls and the time 
spent preparing documentation and procedures. This comp lexity also decreases the attractiveness of the 
mode and entails negative environmental and social c onsequences such as road congestion, road accidents, 
lower efficiency and sustainability of the European transport system. 
With the complexities, Short Sea Shipping is not able to  play its full role in co-modality that is aimed at 
combining the benefits of all modes to maintain a nd increase European competitiveness and prosperity. 
The complexity of administrative procedures has b een generally identified as an obstacle to faster 
development of Short Sea Shipping not only by the Commission (cf. the 2003 Programme for the 
Promotion of Short Sea Shipping6, the mid-term review of that programme7 and earlier Commission 
Communications on the mode8) but also by national administra tions and other stakeholders. 
                                                 
6 Communication from the Commission: Mid-Term Review of the Programme for the Promotion of Short Sea Shipping, 
COM(2006) 380 final of 13.7.2006 
7 Communication from the Commission: Programme for the promotion of Short Sea Shipping, COM(2003) 155 final of 
07.04.2003 
8 Communication from the Commission: The Development of Short Sea Shipping in Europe, A Dynamic Alternative in 
a Sustainable Transport Chain, COM(1999) 317 final of 29.06.1999 
EN 11   EN 2.1. Underlying drivers of the problem 
2.1.1.  Internal market in maritime transport is incompletely achieved 
The achievement of an Inte rnal Market for goods across the European  Union is so far incomplete with 
regards to sea transport. Indeed, wh ile the removal of obstacles to la nd transport has finally become a 
reality, for sea transport there are st ill major barriers to overcome. Among these, there are administrative 
barriers, which are often complex and heterogeneous across Member States. 
With a few exceptions in the Customs, veterina ry and phytosanitary domai ns, the administrative 
procedures applicable to intra-EU maritime trans port of goods are comparable to those in force for 
international sea transport. 
Maritime voyages from one port of an EU Member St ate to another, even without calling at any 
intermediate non-EU port or free- port or meeting another ship en -route, are normally considered 
international. This is the case ir respective of the types of goods that  the vessel carries. For Customs 
purposes, a ship is indeed considered  to leave the Customs territory wh en it leaves a Community port for 
another Member State port, sailing through inte rnational waters. For th is reason, a number of 
administrative procedures are set up when vessels arrive or depart  from ports. These administrative 
procedures involve a wide set of EU  and international legislations. Th ey range from Customs and taxation 
rules to immigration, trade, statistics, environment, waste, phytosanitary veteri nary and health protection, 
security and safety regulations. These regulations ar e not coordinated with each other, thus sometimes 
leading to redundancies and heavy time consumption. 
2.1.2.  Further problem drivers 
– Procedures associated with sea transport of dangerous goods are different from those in land 
transport, thereby adding complexity to intermodal shipments; 
– Veterinary and phytosanitary controls in intra-EU  sea transport, with th e exception of regular 
direct links between ports, are considered im port/export with all the formalities involved. 
– EU common regulations are subject  to individual interpretations by Member States or even ports; 
– Member States often require administrative procedur es to be carried out in  their local languages; 
– Information technologies are not universally widespread across ports and there are different 
information systems in place. Electronic notificati ons or declarations are not commonly accepted 
across the EU. 
Most of the procedures  concentrate in ports. 
2.1.3.  Magnitude of the problem 
Administrative procedures are, admittedly, heavy in Short Sea Shipping. The mode cannot offer the same 
flexibility as road. Transit time is often somewhat  longer. Short Sea Shipping is the best option in 
transport over a certain distance that  is longer than in other modes. 
The existing procedures can be classified in a number of  ways. First of all, it needs to be pointed out that 
there are three main authorities that can collect  the information from vessels and can carry out 
inspections/controls on ve ssel, crew and goods: Port Authorities (that is, Harbourmasters in ports), 
EN 12   EN Customs authorities, and Maritime Rescue Coordina tion Centres (MRCCs), controlling vessels’ traffic 
along the coasts and border guards/control Authorities. 
On the side of the ships, three main representatives of the ships are involved in the procedures, reporting 
activities and possible checks on crew  and passengers: shipmasters, sh ip agents and ship operators 
(owners or carriers). 
All the procedures could be divided into three main  areas: ship reporting documents (usually related to 
port authority), declaration and clea rance of cargo (usually related to  customs) and routine checks or 
inspection. 
Costs for administrative formalities depend on the time spent preparing and carrying out specific 
procedures in port: document related and full-time-equi valent related procedures  (“vessel side” and “port 
side”) and the possible delays of  vessels or goods due to specific  inspections and/or procedures. 
The following table summarises the total man-hours (cons idering an average, best-case and worst-case 
scenario) required to carry out the various procedures9 for all entities/counterparts. 
Time involved for procedures on standard goods (man-hours per call) Source PwC Enquiry 2007 
 Proc. related to 
goods Proc. related to 
vessels Total 
Average time for the document 
preparation 2.5-3.0 3-3.5 6-6.5 
Average time carrying out the procedures 
in port  2.0-2.5 4.5-5.0 6.5-7.0 
Average time for carrying out the 
procedures  5.0-5.5 7.5-8.0 13.0-13.5 
Man-hours in relation to procedures on non-standard goods Source: PwC 2007 
 Dangerous 
Goods Phytosanitary Animal 
Average time for carrying out the 
procedures 2.0-2.5 1.5-2.0 2.5-3.0 
According to the assumption on personnel costs, the average pers onnel cost related to all the 
administrative procedures could be fixed at around € 288 per port call. 
The total costs related to personnel co sts of carrying out procedures and the effect that these procedures 
and related controls (of vessel and goods) can go up to 3 – 3.5% of total transportation costs. 
Dwelling time of goods depend on the impact of customs and other administrative procedures and also on 
the shortcomings in storage management and cargo handling, and on commercial practices. The average 
dwelling time does not exceed 5 to 7 days for contai ners, 7 to 10 days for general cargo, and two weeks 
                                                 
9 All figure have been carried out according to consulta tion outcome, data gathered from specific quantitative 
questionnaires and bottom up analysis. 
EN 13   EN for bulk products. In intra-EU SSS, wh ere journeys last on average less than a week (often less than a 
day), a delay longer than the journey time has a trem endous weight on the overa ll attractiveness of the 
maritime alternative to road transport. 
2.1.4.  Main bottlenecks generated by ex isting administrative procedures 
The main failures derive from customs, as well as veterinary, zootechnical, phyt osanitary administrative 
requirements, which are imposed on goods if they are moved by vessels when the same procedures are not 
be applicable if goods are carried with other transport modes. Admini strative procedures should be 
transport mode neutral. These failures clearly result from EU legislations. 
In addition, consultations have highlighted other failure s resulting either fully from  EU legislation or lack 
of legislation (transport of dangerous goods, authorised regular shi pping services, single windows, use of a 
second language) or partially (lack of  interoperability of electronic da ta transmission, pilotage exemption 
certificates, joined inspections) or fu lly from national or local conditions  (separation of areas in ports). 
The specific administrative failures have been added in the table "specific obj ective" (paragraph 3.2.). 
For four measures suggested by stakeholders dur ing the consultation, a recommendation is the only 
instrument which was envisaged, because they relie s on local condition and a general measure would only 
be envisaged after a more detailed analysis of th ese local conditions, which was not the purpose of our 
study. It is the case for the se paration of areas in ports. 
The following table indicates what the available instruments are. 
 
EN 14   EN List of the main measures  for the reduction of admini strative bottlenecks in SSS 
Bottleneck Measure Instruments Expected benefits 
Customs procedures, even when simplified is fairly cumbersome and 
induce a distortion with road transport Elimination of Customs formalities  for 
intra-EU sea transport of EU, EU cleared 
and goods in transit goods  The objective can only be achieved 
through EU legislation as the bottleneck 
results from existing EU legislation. The 
legislation should not  affect maritime 
transport of imported/exported goods. Free circulation within the EU ports 
Levelling with road transport 
Veterinary, phytosanitary procedur es and controls on animal foods 
products are systematic for non-regular  intra-EU sea transport, which 
induce a distortion with e quivalent land transport Elimination of 
veterinary/phytosanitary/sanitary 
systematic formalities  for intra-EU 
maritime transport. Extension of the exemptions granted to regular services 
by the relevant Directives 2000/29/EC, 
90/425/EEC, 89/662/EEC to all intra-EU 
services. The objective can only be achieved 
through EU legislation as the bottleneck 
results from existing EU legislation. The 
legislation should not  affect maritime 
transport of imported/exported goods. Free circulation within the EU ports 
Levelling with road transport 
Vessels are often changed by operators. Problems arising when 
operators take slots on vessels from  other short-sea operators can be 
solved in this way. High time consumption for carrying out 
procedures (customs); Low degree of competitiveness against road 
transport (customs) License  “Regular liner service” to be 
connected with operators (not with 
vessels) and to be granted to non regular 
liner services intra EU cargoes. The License should not  be connected to 
one or more vessels/r outes, but it should 
be given to the operator for intra EU 
cargoes. The objective can only be 
achieved through EU legislation as the 
bottleneck results from existing EU 
legislation. Less administrative burden, lower costs. 
More fleet manageme nt flexibility for 
shipping companies.  
(only for customs formalities) 
Sea transport of dangerous goods re quires compliance with different 
and more complicated regulations  and documentation than road 
transport.  Simplification of regulations on carriage 
of dangerous goods  in the case of 
“Authorised Regular Shipping Services”  Authorities must agree on regulations 
regarding dangerous goods that are harmonised between transport modes. 
Even if a regional agreement between 
Member States exists , the measure should 
be achieved through EU legislation, as it 
necessitates an adaptation of existing EU 
legislation. Intra and extra EU trade 
should benefit from this simplification SSS would become a more attractive 
transport mode; lower costs. 
High time consumption for carrying out procedures; Low degree of One single document  for administrative Introduction of a single document, which Faster turnaround times for vessels in ports 
 
EN 15   EN competitiveness against road transport pr ocedures applicable to intra-EU SSS  would be used for all the procedures. 
Several administrative forms are 
mandated by EU legislation and the 
introduction of a single document needs a 
change to existing legislation. Intra and 
extra EU trade should benefit from this 
simplification. (less counterparts in ports) 
Administrative procedures often require going to several offices, with 
different opening hours. Administrative single window in ports Setting up administrative desks in ports, 
where to go through all administrative 
procedures. Faster and more rational administrative 
operations. Lower administrative costs for 
Shipmaster. 
Not all MS recognize electronic mani fest; the use of IT for custom 
purpose is not considered in all ports Enhanced  electronic data transmission  Integration of the existing networks for 
monitoring sea traffic and for customs 
clearance. Integration of the SafeSeaNet 
system. Faster turnaround times for vessels in ports; 
enhanced maritime safety; lower waiting 
times; less costs 
Inspections are carried out by different services, which don't 
necessarily coordinated, and it follows that delays caused by 
inspections may be much longer than necessary. Coordinated inspections in ports Coordinated inspections can be organised 
either at EU level or at national level. As 
the inspection regime depends on factors, 
as the risk assessment methodology, 
which takes account of criteria varying 
with the inspection purposes, it is 
difficult to mandate fully coordinated 
inspections. Thus a recommendation is 
the only instrument contemplated in the 
report. Faster and more rational administrative 
operations. Lower administrative costs for 
Shipmaster. 
 Separation of areas in ports To dedicate and physically separate areas 
exclusively for vessels performing SSS. 
The feasibility and the efficiency of this 
measure depend on the port configuration 
and the traffic volume. The cost and 
benefits of this measure could only be 
assessed on a case-by-case basis, which 
can not be done in the framework of this 
study. The only instrument contemplated 
is a recommendation to the Member 
States.  To speed up loading/unloading and waiting 
times of vessels in ports. 
 
EN 16   EN Not all MS recognize electronic mani fest; the use of IT for custom 
purpose is not considered in all ports Enhanced  electronic data transmission  Integration of the existing networks for 
monitoring sea traffic and for customs 
clearance. Integration of the SafeSeaNet 
system. 
The measure can be applied at the 
initiative of a port, of a Member Sates or 
at EU level. The more realistic instrument 
mixes all level, ma king benefits of 
systems which have already been put in 
place locally, but enhancing the 
advantages of the electronic data 
transmission systems by providing an international framework for 
interoperability and standardisation of 
equipment. Faster turnaround times for vessels in ports; 
enhanced maritime safety; lower waiting 
times; less costs 
Not all countries grant PECs to s ea-going vessels. Even those which 
do issue PECs, there are often national barriers (e.g. language)  Issuing of Pilot Exemption Certificates 
(PECs)  to SSS vessels  Simplification of regulations, allowing 
operators to apply for PECs in an easier 
way. 
The granting of PECs depends on the 
specific difficulties of the ports. Thus, for 
the purpose of the report, only a 
recommendation is considered. The 
nature of the carried goods, intra-EU or 
non-EU should not be a criterion for the 
granting of PECs. Lower costs for SSS operators, speeding up 
port operations 
The use of national languages slows down compliance with administrative formalities. Use of English as o fficial administrative 
language  Use of the English language as the 
(second) official language for all 
administrative documents. 
For the purpose of the report, only a 
recommendation is considered. Intra and 
extra EU trade should benefit from this 
simplification.  Speed up administrative formalities. Avoid 
misunderstandings. 
 
EN 17   EN 2.1.5.  Comparison with other transport modes 
Short Sea Shipping competes with road and rail  transport on certain door-to-door co rridors (a 
maritime leg shall exist) and for certain goods (more easily on high volume, preferably not expensive goods). As a load rupture occurs , which incur handling, storage and insurance 
costs, maritime transport has to be cheap. It is  commonly said that sh ippers will not choose a 
door-to-door solution including a Short Sea Shipping leg if it is not 20% cheaper than the full 
road solution. If the port costs and delays can be reduced Short Sea Shipping will attract more 
traffic. 
It is generally acknowledged that  administrative procedures are more intricate for Short Sea 
Shipping than those applicable to road transport. 
The costs of carrying out admi nistrative procedures in S hort Sea Shipping represent a 
considerably higher share of the total transport costs than in road transport (roughly 3.3 % of 
total transport costs as compared to 0.2 % for ro ad transport). Furthermore, the fact that the 
procedures are different from or additional to those of road transport, create complexity. A 
truck carrying a container or trailer to a port n eeds a set of road transport documents that are 
then duplicated in another format for the maritime leg.  
A sample comparison between administrative pro cedures for short sea an d road transport has 
been done in Annex B. 
2.1.6.  Qualitative considerations 
Some stakeholders consider that the risk  of unforeseen lengthy time inherent with 
administrative procedures in maritime transport gives maritime transport a bad image. This is partly inherent to the fact that a vessel carri es hundreds of loading units while a normal road-
train only two. However, streamlining and simp lification of administ rative and documentary 
procedures in multimodal transport operations should have a positive effect on the reputation 
of Short Sea Shipping and lower transport cost s in logistics chains involving a sea leg. 
2.2. Who is affected? 
Everyone is affected by these issues. Road tr ansport results in cong estion, accidents, noise 
and environmental pollution that affect th e citizens and industry. Building land-based 
infrastructure also needs caref ul land-use planning. The short-sea cluster is an important 
source of employment. These concerns ar e also evident at political level. 
Europe at large is affected because its transport system is not used in a balanced way but 
emphasises the road component even over longer distances. European competitiveness and prosperity can suffer when the transport system  is not used optimally. Road transport will 
always be needed because shipping can not reach everyone’s doorstep but better 
complementarity of modes in co-modality  should produce more efficient results. 
The main sectors likely to be directly affected are: – European Union 
– Member States 
 
EN 18   EN – Port Authorities 
– Customs 
– Maritime lines 
– Ship Agents 
– Maritime Authorities 
– Forwarders 
– Citizens. 
2.3. Foreseen evolution of the problem 
Things remaining equal, without further measur es, Short Sea Shipping w ould not be able to 
fully respond to the challenges of the mid-te rm review of the White Paper on European 
Transport Policy and the Lisbon agenda. 
2.4. Right of the EU to act 
The policy to promote Short Sea Shipping is based on Article 80(2) of the Treaty. 
The achievement of the Internal Market is a co re objective of the EC Treaty. The fact that 
maritime transport is not fully incorporate in the Internal Market impairs the functioning of the whole co-modal transport system. 
National policies might not alwa ys produce interoperable transpor t solutions that are needed 
for Europe to optimally work together in an area without borders. Substantial results can only 
be achieved by the European Commission work ing with the Member States and industry 
towards a coherent framework covering the whole of Europe. 
Most of the measures impeding the smooth func tioning of the Internal Market in maritime 
transport are the consequences of existing EU legislations and the necessary amendments to these legislations rely on EU responsibility.  
Subsidiarity, proportionality and fundame ntal rights are fully respected. 
3. O
BJECTIVES  
3.1. General policy objectives 
The general policy objectives are: 
– To promote actions and measures aimed at increasing attractiveness of maritime 
transport against road and other transp ort modes in order to diminish the 
unsustainable trends indicated above. European competitiveness and prosperity need to be maintained and increased, and Short S ea Shipping is an essential part of this 
process. Furthermore, Short Sea Shipping e nhances cohesion and links to peripheral 
areas and islands 
 
EN 19   EN – To ensure that duplicated or obsolete reporting requirements are removed and to 
facilitate the free circulation of ma ritime transport between EU ports by 
simplifying/reducing/eliminating administ rative procedures connected to intra-
European market in order to reinforce efficiency and competitiveness. 
– To ensure that useful information continues to be available to users. This includes 
information concerning the involved parties and the goods that is normally found on 
documents such as ships' manifests. 
3.2. Specific objectives 
The following table presents specific and operational objectives in relation to the general 
policy objectives. 
 
EN 20   EN Specific and operational objectives 
Specific / operational objectives Co rresponding measures and instruments Consistency with EU policies 
To facilitate Intra-EU mar itime transport by providing 
for simplification or elimination of administrative 
procedure and Customs formalities on Community goods and between EU ports. 
To facilitate and simplify administrative procedures, 
reducing controls and inspection in a “European Maritime Transport Space without barriers” to a 
minimum feasible number. Elimination of Customs formalities for intra-EU sea 
transport of EU, EU cleared and goods in transit goods 
Elimination of veterinary, phytosanitary, sanitary 
systematic formalities for intra-EU maritime transport Mid Term review of the European Commission’s 
2001 Transport White Paper
10 
Commission Communication of 10 October 2007 
on “An Integrated Maritime Policy for the European Union” (“Blue Paper)” 
Commission Communication of 18 October 2007 
on port policy 
To facilitate the free circulation of Community goods between EU ports eliminating Customs formalities on 
goods; to speed up Customs and all administrative 
formalities in order to reduce time, delay on goods and delays on vessel due to administrative procedure and 
Customs formalities. License “Regular liner serv ice” to be connected with 
operators (not with vessels) and to be granted to non 
regular liner services intra EU cargoes Simplified Customs Proc edures in Short Sea 
Shipping: “Authorised Regul ar Shipping Service”, 
SEC(2004) 333 
To define a group of measures that could facilitate the 
free circulation of EU goods between EU ports and allow the reduction of transport costs in order to 
increase competitiveness of maritime sector and 
stimulate modal shift from road. Simplification of regulations on carriage of dangerous 
goods; use of a second official administrative language; separation of areas in ports; coordinated inspections in 
ports; issuing of Pilot Exemption Certificates (PECs) Programme for the Promotion of Short Sea 
Shipping, COM(2003) 155 final 
Mid-Term Review of the Programme for the 
Promotion of Short Sea Shipping, COM (2006) 
380 final. 
To integrate the information flow between different parties of different countries and elimination of 
physical presence of authorities (data and information 
network) Enhanced electronic data transmission and administrative 
single window in ports Council Conclusions concerning the Lisbon 
Strategy of 12 February 2007 
To facilitate maritime transport by providing for standardisation of reporting formalities and 
computerisation of monitoring system Rationalisation of documents requested for vessels 
arriving/departing from ports Directive 2002/6/EC on Reporting formalities for 
ships arriving in and/or departing from ports of the 
Member States of the Community 
                                                 
10 Commission Communication: “Keep Europe moving – Sustainable mobility for our continent – Mid-term review of the European Commi ssion’s 2001 Transport 
White paper” (COM (2006)314 final of 22 June 2006). 
 
EN 21   EN 3.3. Consistency with other policy objectives 
As the objectives are about reducing the administrative burden on business and the 
improvement of EU competitiveness, while pres erving levels of protection, they are fully 
consistent with the Lisbon strategy for growth and jobs, in particular by putting in place a 
more conducive environment for business. 
It is also fully in line with the objectives  of the mid-term review of the White Paper on 
European Transport Policy (co-modality, co mpetitiveness, sustainability, safety, bypassing 
land bottlenecks). 
The establishment of a European  Maritime Transport Space without Barriers is an important 
element in "An Integrated Maritime Policy fo r the European Union" ("The Blue Book")11. 
It will contribute to transport related objectives  as the promotion of quality shipping and the 
modernisation of national administrations. It wi ll bring the benefit from  the deployment of 
electronic surveillance systems implemented along the European coastline as a consequence of legislations already adopted by EU or at international level. 
Maritime transport has higher energy-efficiency than other modes of transport and is, in 
general, less harmful to the environment. Increased use of Shor t Sea Shipping would 
generally be in line with the Community  transport and environmental policies. 
4. P
OLICY OPTIONS  
Three main policy options were analysed: 
– Status quo as baseline scenario ("do nothing"); 
– Case-by-case simplification of individual administrative formalities; 
– Act on the basis of a co-ordinated set of measures simplifying, reducing, and, 
wherever possible, eliminating formalities for vessels sailing between EU-ports in line with the model of the Internal Market offered by land transport. 
4.1. Policy option A: The do-nothing option 
In this baseline scenario, the forecast of the volume of the Short Sea Shipping market is based 
on a growth rates equal to 3.0% until 2010 a nd 2.7% further on from 2006, where intra-EU 
Short Sea Shipping market accounted for 1.5 bi llion ton.km. The evolu tion of the Short Sea 
Shipping and transport markets are shown in Annex C. 
                                                
 
11 COM(2007) 575 final of 10 October 2007 which states: "nevertheless, shipping remains at a 
disadvantage compared to other means of transport. Other transport modes benefit from more public investment. Furthermore, a vessel travelling betwee n two EU ports is subject to more complex and 
time-consuming procedures than a truck would be, because a real internal market for maritime transport 
in Europe does not yet exist. In order to unlock the full potential of Europe's shipping industry this disadvantage of maritime transpor t compared with the other modes must be eliminated through the 
simplification of administrative and customs fo rmalities for intra-EU maritime services." 
 
EN 22   EN European competitiveness could suffer in light of the limited infrastructure resources 
available, if all the modes would not play th eir full role in co-modality. Competitiveness of 
Short Sea Shipping would decrease, because pr omotion would not advance and simplification 
would not take place. Administ rative and documentary obstac les to developing the mode 
would lead to higher operating costs and, ultim ately, to higher transport prices for the 
customer. Delays could increase owing to growi ng traffic volumes. European shipyards could 
suffer because the growth of Short Sea Shippi ng would not be optimal. New technological or 
logistics solutions might not be created for th e mode thereby decreasing its competitiveness 
and worsening its macroeconomic environment. 
Low competitiveness in Short Sea Shipping could lead to less maritime-related employment. 
Young people might be less attracted  to the profession. The external  social effects of transport 
would not be relieved (conge stion, accidents and noise). 
Short Sea Shipping is energy-e fficient, and produces less CO 2 per tonne-kilometre and has 
lower effect on global warming than other mode s. A less prominent role of the mode in 
Europe could decrease these positive trends. Research in new environmentally friendly 
technologies for Short Sea Shipping might decr ease. Sea is an open infrastructure which 
requires much less land use planning  than inland transport modes. 
4.2. Policy option B: The case-by-case approach 
A series of measures proposed by stakeholders during the preliminary co nsultation have been 
contemplated, which have a potential for re ducing the administrative burdens on intra-EU 
maritime transport. These measures are considered in detail in the subparagraphs below. 
The initiative of some of the measures falls clearly under EU responsibility while others can 
be implemented either at local or national leve ls, or within an EU framework. As the main 
objective of the European Maritime Transport Space without Barriers is to simplify, reduce 
or, when possible, eliminate formalities related to EU legislation, the main focus has been 
given to those measures. 
For actions going beyond the above,  recommendations have been c onsidered at this point in 
time. 
4.2.1.  “Authorised Regular Shipping Servic es” Licence linked to companies 
The Community Customs Code allows the simplification of certain customs procedures, in 
the case of those vessels perfor ming regularly scheduled routes between two EU ports. In this 
case it is necessary to have  a Certificate of “Authorised  Regular Shipping Service”12 (ARSS). 
This authorisation is given to named vessels on a specific route. 
A survey conducted by the Finnish Customs found that 62% of liner services have authorised 
regular service permits. 
The stakeholders have consistently request ed linking the licence of “Authorised Regular 
Shipping Service” to the operator or routes of  regular Short Sea Shipping service and not to 
                                                 
12 Simplified Customs Procedures in Short Sea Shipping: "Authorised Regular Shipping Service", 
SEC(2004) 333 
 
EN 23   EN individual vessels as is now required in th e existing regulations. Operators need more 
flexibility in managing their flee t. The licence certifies the qualit y of the operator;  therefore it 
should be secondary which vessels they employ.  Currently, when an application is lodged, it 
needs to indicate the names of the ports concerned and the name  of the vessels assigned to 
regular service. If a vessel is changed and replaced by another vessel , or if a vessel  is added to 
the service, the shipping company has to notify the authorising authoritie s, with the name of 
the new vessel. The authorisation certificate ha s to be physically amended. On the contrary, 
when the port of call is changed, a new certificate needs to be applied for. 
4.2.2.  Veterinary and phyto sanitary controls 
Directives 90/425/EEC, 89/662/EEC and 2000/29 a llow certain veterinary and phytosanitary 
controls in ports to be exempted from import / export procedures. Thes e concern the transport 
of products on direct an d regular shipping links. 
However, products transported via a third EU  port or on non-regular shipping links are 
subject to import and export proc edures even though their origin  is in another EU Member 
State and the products have not vi sited a third country on the way. 
In order to streamline the procedures, all tran sport of veterinary and phytosanitary products 
should be on the same footing provided they are cleared in one Member State and transported 
from one Member States to another by sea. 
4.2.3.  Simplification of requirements fo r the carriage of dangerous goods 
Transport of dangerous goods by road is governed by the European Agreement on the 
International Carriage of Dangerous Goods by Road (ADR)13. Similar agreements apply to 
rail (RID14) and inland waterways (ADN). The tran sport of dangerous goods by sea is 
governed by Directive 2002/59/EC15 and by the IMDG Code16. International transports of 
dangerous goods which comply with the provi sions set out in the ADR are exempt from 
domestic requirements. 
Regulations on dangerous/hazar dous/polluting goods are different  in sea transport and land 
road transport, representing a clear bottlen eck. The IMDG Code and Directive 2002/59/EC 
contain specific provisions for the carriage of dangerous/polluti ng goods at sea entailing early 
advance notifications and declarations. 
                                                 
13 Agreement concerning the Interna tional Carriage of Dangerous Goods by Road (ADR) of 30 September 
1957. This Agreement has been introduced in EU legislation by Council Directive 96/55/EC on the 
approximation of the laws of the Me mber States with regard to the transport of dangerous goods by 
road. 
14 Regulations concerning the international carriage of dangerous goods by rail (RID) stipulated in 
Appendix B, Annex 1of the Convention concerning international carriage by rail (COTIF), which defines uniform rules concerning the contract for in ternational carriage of goods by rail (CIM). These 
regulations have been introduced in EU legislation by Council Directive 96/49/EC on the 
approximation of the laws of the Member States with regard to the transport of dangerous goods by rail. 
15 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 and repealing Council OJ L 208 of 
5.8.2002, p. 10 
16 International Maritime Dangerous Goods (IMDG) Co de adopted in 1960 by the International Maritime 
Organisation. 
 
EN 24   EN Although declarations are similar for each mode of transport, there are differences between 
road and maritime sector, in particular: 
– Classification of substances can differ in some cases; 
– The two codes differ in terms of severity of application, with the IMDG Code being 
stricter (for instance quantity of da ngerous goods that can be carried); 
– In case of IMDG, any quantity of goods whic h are classified as dangerous must be 
declared: When goods are packed in limited quantity packaging, they do not have to comply with the ADR rules (with the excepti on of a transport document), if certain 
limits are not reached. On the contrary, fo r sea transport any quantity of dangerous 
goods must be declared according to the pr ovisions of the IMDG Code. Whatever the 
quantity of goods, a full declaration must  be made and the Dangerous Goods 
Manifest completed; 
– The ADR allows carrying some materials under a Limited Quantity Exemption rule, 
which states that UN tested and approved packaging is not re quired for dangerous 
goods in limited quantities. However, the pack aging used for the transport by road of 
dangerous substances must be: 
– Suitable for the purpose; 
– Designed and closed to prevent escape of the dangerous substance; 
– Compatible with the dangerous substance; 
– Capable of being re-closed repeat edly, without escape of contents; 
– Capable of meeting any special conditions  for a particular substance in the 
approved carriage list; 
– Of a design that has been UN approved. 
In case of a conflict between the two, the IM DG Code prevails. This can happen a truck 
carrying dangerous goods is then boarded onto a Ro/Ro ship. The following table shows all documentation required in the case of road tran sport and sea transpor t of dangerous goods. 
For the above reasons the transport of some da ngerous cargoes is restricted, complicated and 
costly at sea that goods are carried on land. 
A possible solution to this bottleneck would be  streamlining of the rules on dangerous goods. 
The rationale of this me asure would be that certain parts of the RID and ADR rules would be 
accepted for shipping services. This would e liminate the need for double documentation for 
the carriage of the same goods  in intermodal transport chains involving a sea leg. 
The general rules concerning transport, stow age and segregation of dangerous goods would 
continue to apply, in accordance  with the IMDG Code, but some extensions in the types and 
quantities of dangerous goods on board of the ve ssels would be permitted in line with the 
 
EN 25   EN ADR Agreement. In addition, the UN packagi ng is not required for dangerous goods in 
limited quantities as the ADR Agreement allows  it under a Limited Quantity Exemption rule. 
4.2.4.  Enhanced electronic data transmission 
The Commission announced in the action plan attached to its 2006 White paper on transport 
policy that it would propose in 2009 measures  for the deployment of e-maritime systems. 
Indeed several vessel traffic mon itoring systems are currently alr eady in place or about to be 
implemented in the European Union. Each  one fulfils a different objective. 
There are also several networks for sharing information on vessels’ traffic between Member 
States. It is hence necessary to carry out an EU-wide integration of these systems with the 
SafeSeaNet network within this framework. The integration of maritime surveillance systems 
will provide a much more enhanced tool for the monitoring of vessels  and traffic tracking. 
In addition, it will be necessary to set up a “s ingle window” for the electronic transmission of 
administrative documentation only once so that it can be automatically delivered to the administrations requiring it.
17 This can considerably speed up necessary administrative and 
documentary procedures. The “single window” will l ead to a single transmission of data from 
ship to shore and help avoiding several tran smissions of data with the same contents. 
This will ease administrative procedures for ships entering or leaving ports, as well as 
customs and other procedures. Indeed, the e-maritime system should be fully compatible with the eCustoms project. 
4.2.5.  Co-ordinated inspections by  administrative services 
Another simplification measure is that of or ganising a “one-stop shop" for inspections, by 
which all the authorities that need to board  the ship when in port (e.g. veterinary, 
phytosanitary, environmental, health, safety , customs etc.) for inspections do it in a 
coordinated way and at the same time. They ma y also empower other authorities to carry out 
their specific controls. In this way delays can be reduced and vess els’ turnaround times 
improved. Member States should encourage admi nistrations at port level to plan their 
                                                
 
17 Decision 70/2008/CE17 on a paperless environment for Customs and trade requires that Member States 
put in place no later than 15 February 2013 a Si ngle Window for all administrative procedures for 
imports and exports procedures. 
 The Single Window concept has been defined at UN level as a “system that allows traders to lodge 
information with a single body to fulfil all import or export-related regulatory requirements”17. 
 Currently, vessels need to interf ace with several parties in ports,  in order to carry out all the 
administrative procedures. This has an important influence on costs, the speed of goods handling process and the system’s overall reliability. Establishing a single desk, where all paperwork would be 
dealt with, would be highly beneficial. Indeed, all of the administrative formalities will be processed 
electronically or in coordination between entities. 
 In order to put in place an effici ent Single Window which will not be an addition layer, but will replace 
existing administrative interface, the general ob ligation of Decision N° 70/2008/EC shall be 
complemented by other provisions, both EU and national level. Member States should adopt a legal framework to regulate one-stop-shopping services, with coordination at European level. Many 
stakeholders have to be involved as the European Commission, individual port administrations, 
Customs, veterinary departments, maritime health, etc. 
 This Single Window will benefit to the long dist ance maritime trade as well as it will facilitate 
administrative formalities for maritime transport including both intra-EU goods and non-EU goods. 
 
EN 26   EN inspections jointly, in order to reduce the eco nomic negative impact on Short Sea Shipping 
without reducing the quality of the inspections. 
The advantage of this "one-stop shop" setting is  the speeding up of admi nistrative procedures 
and the time reduction in carrying out the fo rmalities for ships and cargoes. Moreover, a 
framework would be established, in which tran sport operators and agents responsible for 
processing documental formalities would be able to carry out all procedures at the same time with a single administrative counterpart. 
4.2.6.  IMO/FAL forms 
Directive 2002/6/EC on reporting formalities fo r ships arriving in and/or departing from 
ports
18 requires EU Member States to accept a unifor m set of ship arrival and departure forms 
based on IMO/FAL forms when those forms are applicable. 
The objective of Directive 2002/6/EC is to simp lify and streamline administrative formalities 
and documents by introducing uniformity in documentary formalities. 
The IMO/FAL Convention was revised in 2005. The Commission could amend this directive 
to align its Annexes with the Revised IMO/FAL Convention. As this alignment results from 
an international regulation, its impact is not assessed in this report. 
Apart from this alignment, several pieces of EU  legislation require ve ssel-related information 
to be submitted. This information is often repetitive but has to be submitted separately for each procedure. Rationalisation could be forese en in the context of Directive 2002/6/EC in 
order to streamline and clarify the application of the requirem ents of Directives 2000/59/EC
19 
and 2002/59/EC20 and Regulations (EC) N° 725/200421 and (EC) N° 562/200622 with regard 
to this directive. This alignment is a prerequisite for the rationalisation of administrative documents required by the various pieces of EU legislation. 
4.2.7.  Pilot exemption Certificates 
Nowadays the general rule is for a vessel to  have pilot in certain waters and when 
entering/leaving a port for safety reasons. Thes e services are not free, and their costs are 
charged upon ship operators. Pilot Exemption Cert ificates can, in certain cases, be delivered 
to the ship’s master or deck officers to carry out this pilotage themselves without using an 
external pilot. 
                                                
 
18 Directive 2002/6/EC of the European Parliament and the Council on reporting formalities for ships 
arriving in and/or departing from ports of the Member States of the Community, OJ L 67, 9.3.2002, p. 
31 
19 Directive 2000/59/EC of the European Parliament and of the Council of 27 November 2000 on port 
reception facilities for ship-generat ed waste and cargo residues OJ  L 332 of 28.1 2.2000, p. 81 
20 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 and repealing Council OJ L 208 of 5.8.2002, p. 10 
21 Regulation (EC) No 725/2004 of the European Parliament and of the Council of 31 March 2004 on 
enhancing ship and port facility secu rity OJ L 129 of 29.4.2004, p. 6 
22 Regulation (EC) N° 562/2006 establishing a Community Code on the rules governing the movement of 
persons across borders OJ L 105, 13.4.2006, p. 1 
 
EN 27   EN Shipping services frequently cal ling in some ports should, as a rule, have access to Pilot 
Exemption Certificates. The benefits this measure would entail would translate into lower costs for Short Sea Shipping opera tors and faster turnaround times of vessels in ports. The 
actions required for the implem entation of this proposal would need to be taken at national 
levels and coordinated among national authorities. 
Pilot Exemption Certificates or corresponding a rrangements should be available in English so 
that the master or deck officers would necessarily  not need to speak the official language(s) of 
the country delivering such certificates. This  would be without prejudice to safety 
circumstances in certain waters where knowledge of  the official language( s) of the country is 
considered necessary. 
4.2.8.  Alternative language for adm inistrative procedures 
National language requirements often represent a bottleneck to the development of Short Sea 
Shipping. Article 17 (e) of Directive 2001/25/ EC on the minimum level of training of 
seafarers
23 stipulates that, if there is no comm on languages, communi cation between ships 
and shore can be conducted in  a common language with refere nce to the Chapter V of the 
SOLAS Convention.  
Member States are encouraged to assess the feasibility of using a language commonly used 
for communications at sea as an alterna tive language for all administrative maritime 
documents and procedures, for sea-shore comm unications as well as administration-to-
administration communications. In practical term s, it would mean that  the personnel operating 
in ports and interacting with vessels' crews (Custom authorities, port authorities, health 
inspectors, immigration officers, etc.) would be  expected to understand and speak a second 
language. All procedures, including paperwork w ould be allowed to be carried out in this 
second language. 
4.2.9.  Separation of areas in ports 
Another measure for consideratio n could be the physical separati on in ports of areas reserved 
to Short Sea Shipping (in particular for containe r traffic and roro traffic). One or more piers 
could be exclusively dedicated  to vessels performing intra- EU Short Sea Shipping, with 
apposite administrative offices for the administra tive procedures. The bene fit of this measure, 
again, would be a more rational management of port traffic and a speeding up of vessels’ 
turn-around times in ports. 
There is a disadvantage of economies of scale a nd (in some cases) high infrastructure costs, 
but there are also several benefits that  could be consider ed, in particular: 
– Elimination of the problem of priority given to deep-sea vessels in some ports; 
– Optimized and faster round trips; 
– Shorter dwelling times and a higher frequency. 
                                                 
23 Directive 2001/25/EC of the European Parliament and of the Council of 4 April 2001 on the minimum 
level of training of seafarers, OJ L 136 of 18.5.2001, p. 17 
 
EN 28   EN – This option might not be suitable for all port s but could be consid ered when deciding 
on land use in ports where such a solution could be feasible. 
4.3. Policy option C: Act on the basis of a co -ordinated set of measures simplifying, 
reducing, and, wherever possible, eliminat ing formalities for vessels sailing 
between EU-ports in line with the model of the Internal Market offered by land 
transport 
This option builds upon the measures presented in option B and foresees their implementation 
as a consolidated package while adding furthe r simplification to them by considering the 
elimination of some procedures. 
The concept of European Maritime Transport Space without Barriers aims to simplify, 
facilitate or, when possible, exempt from the administrative formalities on arrival to the port 
ships operating between two EU ports. 
Documents related to Community goods carried between two EU ports are generally to be 
checked at the port of departure and the port of  arrival. However, documents of goods carried 
by a land transport between two points located in the EU, without transiting a third country, 
are not subject to systematic controls. Document s shall only be in the ve hicle for possible spot 
checks. 
The elimination of systematic administrativ e procedures would not lead to the full 
abolishment of transport documents. However, c ontrols should not be sy stematic but be based 
on random checks (risk analysis) as far as feasible. 
A further simplification could be for ships ope rating in triangular traffic between two EU 
ports while also calling a third- country or free port. The call in a third country should not be 
considered to "infect" the vesse l itself of the goods (products) carried onboard. This measure 
has been frequently called upon by the stakeholders. 
One could also think of eliminating all pro cedures on Community goods and products carried 
on any vessel between tw o EU ports. This would achieve a re al Internal Market for Short Sea 
Shipping and give a real boost to its development. 
5. ANALYSIS OF IMPACTS  
5.1. Policy option A: The do-nothing option 
Administrative burden are longstanding issue for maritime transport. Tentative to improve the 
situation has already been done either loca lly, as the development of electronic data 
transmission systems developed in some ports  or by EU measures in favour of intra-EU 
transport as the Customs facilitation for Author ised Regular Shipping Services. On the other 
hand, new requirements for instance, for food secu rity, security or environment have been 
added. They entailed specific formalities and inspection procedures. The situation has globally improved but at a too low pace, while th e amount of goods carried by sea is expected 
to increase and the port congestion is becoming a crucial problem. 
With the foreseen growth of traffic flows, the raising rate of feederi ng in Short Sea Shipping, 
as well as the mandatory introduc tion of tracing and tracking systems and the need to improve 
 
EN 29   EN shipping environment performances, the Eu ropean shipping sector in going through a 
transition phase. The time is appropriate to simplifying, reducing or, when possible, 
eliminating formalities, which will contribute to  creating a better business environment, and 
gives a positive signal for a modal shift and more investments in this sector. 
For further description of this  option, see section 4.1 above. 
5.2. Policy option B: The case-by-case approach 
As a general consideration, the achievement of the In ternal Market benefits in Short Sea 
Shipping is a political goal that has a consider able positive impact as such. This goal has been 
mentioned in the “Blue Book” on an integrated maritime policy and frequently referred to by 
politicians at the highest level (such as  by the President of the Commission or 
Commissioners). Consequentl y, the expectations are high. 
Apart from expectations, any simplification can, from the outset, be considered positive in 
decreasing administrative burden of businesse s in the EU. The positive impacts of such 
simplification can only be overturn, if nega tive economic, environmental or social 
consequences emerge to a degree that is not sust ainable. This does not se em to be the case for 
the European Maritime Transport Space without Barriers. 
For the purpose of the impact assessment st udy, the case-by-case measures were grouped in 
two clusters: 
– Cluster B1:  The extension of the Authorised  Regular Shipping Service Customs 
facilitation, the recognition of some non- maritime requirements for dangerous goods 
on vessels, and the avoidance of duplication in data requested for different vessel-
related legislation (see points 4.2.1, 4.2.2 and second part of 4.2.6 above); 
– Cluster B2:  Other measures mentioned in chapters 4.2.3 to 4.2.9 (excluding the first 
part of 4.2.6) with potentially hi gher start-up administrative costs. 
5.2.1.  Economic impacts 
The Consultation’s results have been used for quantifying the average delays in ports. They 
have been processed on the basis of the evidences  of some qualitative information gathered in 
the course of some interviews performed. There are many differences between ports and 
procedures, not only in terms of the magnitude of the delay but also in terms of probability of 
delays on arrival or departure.  
The following table shows the different values of  overall delay (probability), on arrivals and 
departures. The percentage only re fers to the total number of an swers received on the specific 
issue of delays. The percentage of answers within each time range has been associated to the 
probability of happening of the specific event. The overall delay is expressed as a probability 
value, weighted against different percentages for each time range. 
 
EN 30   EN General delay on arrival and on departure (hours) 
  Weight = 1 1-6 6-12 12-24 >24 Delay on goods Delay on vessel 
Average time chosen  1 3 9 18 48   
Formalities on GOODS 50% 41% 9% 5% 9% 0% 1.42 0.52 
Formalities on VESSELS 40% 48% 3% 0% 1% 1% 0.8 0.56 
Dangerous Goods 5% 55% 14% 0% 0% 0% 0.95 0.55 
Phytosanitary 2.5% 32% 5% 0% 5% 5% 3.45 0.32 
Animal origin 2.5% 18% 5% 0% 0% 5% 2.5 0.18 
Weighted average delay       1,48 0.47 
Source: PwC elaboration on Consultation data (2008) 
The Table above shows that delays on g oods are higher than delays on vessels. 
All Member States even transit or landlocked countries will benefit from the cost reduction 
and the social benefits of the modal shift. 
5.2.1.1.  Cost decrease for reduction of time spent for administrative procedures for goods 
The reduction of the time required for carrying out  the different administrative procedures 
would produce a proportional reduction in th e delays on goods caused by the formalities. 
The cost decrease has been calc ulated taking into account the time cost s arising from the 
application of intrinsic values of time to specific goods. Time co sts are an implicit factor of 
the generalised transport cost function, although not di rectly perceived as a monetary expense 
by the stakeholder demanding a tran sport service (e.g., the shipper),  or affected by a delay in 
the door-to-door transport ch ain (e.g. the consignee). 
For the purpose of the calculation, time saved is associated  only with the time reduction in 
ports for carrying out the different procedures  and not with the time spent by the operators 
preparing different documents (usually this  phase starts before vessels’ arrival). 
Freight transport’s value of time is  usually composed by three factors24: 
– Inventory costs corresponding to the traditional notion of immobilization of an asset, 
as typically used in any company’s account ing procedures when estimating the costs 
of storage and warehousing. While the goods  are being transported, they do not 
generate any added value, and therefore gene rate a financial cost to its owner, which 
is usually estimated on the basis of standard rates. 
– Loss of value related to the delay with whic h the consignment reaches its destination, 
as a deviation factor for the user in planning its activity; 
                                                 
24 See RECORDIT – Deliverable 1, (2001), and TRANSTOOLS Deliverable 2, (2005). 
 
EN 31   EN – Spoilage costs, defined as the loss of va lue resulting from a deterioration of the 
quality and usability of the goods as a consequence of the delay. 
The HEATCO25 deliverables incorporate those f actors when derivi ng standard EU-27 
reference figures. Thus those figures can be a pplied as “safer” reference values of time for 
measuring the benefits related to the decrease of delay probability. 
In terms of costs saved in relation to the re duction of delays on goods, the advantages of the 
implementation of the different measures correspond to an average ranging between 16.2 
million Euros (facilitation of Dangerous goods  and Customs procedures) to 102.4 million 
Euros per annum (reduction/elimination of  all formalities, including non-customs 
procedures). 
5.2.1.2.  Cost decrease for reduction of  time spent during ship calls 
The time spent by vessels in port is connected to operative activities and is not due to the 
carrying out of administrative pr ocedures (both customs and ad ministrative). It is very 
unlikely that a vessel is subjec t to delays because of activities connected with administrative 
procedures. When such delays do occur, they are normally not higher than 1 hour. 
Similarly to what has been done for delays on  goods, in order to calc ulate such potential 
delays, it has been evaluated the probability of reduction of delays. In this case too, it has 
been assessed the impact relative to the reduction of time for port operations. 
In order to calculate the time-rela ted costs of ships, an average hourly cost of rent of a ship 
has been considered. 
In terms of cost saved in relation to the reducti on of delays on vessels, the advantages (quite 
minimal) of the implementation of the different Policy Options correspond to an average ranging between 0.1 million Euros (facilitation of  Dangerous Goods and Customs procedures) 
to 1.38 million Euros per year (maximum elimination of formalities). 
5.2.1.3.  Impacts on the level of fraud 
Because of the lacking of statis tical data and information, potenti al impact of administrative 
facilitation on fraud pattern ca nnot be quantified. Main types of frauds would be a wrong 
declaration of the product origin (including sm uggling); whether to avoid paying the VAT or 
paying less Customs dues on imported products. As vessels which would benefit from the 
European Maritime Transport Space without barr iers would only carry EU, EU-cleared goods 
or goods under Customs supervision (under a "transit " regime), the risk of fraud would not be 
higher than in road transport where similar goods  are being carried. In addition, the loading of 
illegal products when the vessel is on high se as has been indicated as a potential risk. 
However modern port communication systems, in association with othe r surveillance methods 
(LRIT, AIS etc.) reduce to a large extend this risk. 
                                                
 
25 HEATCO: "Developing Harmonised European Approaches for Transport Costing and Project 
Assessment", Research Project from the sixth Framework Programme, European Commission DG 
TREN 
 
EN 32   EN 5.2.2.  Environmental impacts26 
The external costs of the diffe rent transport modes have been  taken from the 2004 ISIC study. 
They do not reflect the recent or pipeline decision s, as the proposal for Euro VI standards for 
heavy duty vehicles, which will reduce NOx an d particulate matters from 2012 or the IMO 
decision on low sulphur fuels for maritime trans port. The share of conventional pollution in 
the total external costs (comprising infrastruc ture costs, congestion costs, accidents and 
climate changes costs) is 30% for road and 50% for maritime transport. 
Figures presented in paragraph 5.3.2. concern the overall effects of reducing/eliminating 
administrative procedures. These effects can be  split among the measures contemplated in 
Policy Option B. In order to do th is, these measures have to be  assessed as concerns their 
capability or effectiveness in making Short Sea Shipping more competitive and therefore 
actually generate the modal shift forecast. In other words, a focus must be made to investigate 
the so-called “internal” benefits of the measures. 
Hence, some of the final results of the analysis are to be antic ipated here by stating that the 
implementation of the group of measures in cl uster B2 comprising ITS measures would have 
a higher internal benefits/costs  ratio than the simpler cluster B1 measures, by approximately 
4:1 On the basis of such indications the shares  of the modal shift (and  consequently of the 
environmental benefits) are assumed to be 20%  for cluster B1 measures and 80% for the 
cluster B2 measures. 
Application of such shares to the overall ex ternal benefits for each Option: the values 
obtained represent the environmental bene fits of the Option (per scenario). 
According to the 20%-80% shares attributed to Cluster B1 and B2, the environmental benefits 
in the reference year (2020) can be estimated at: 
– Cluster B1: 3.2 million Euros in the Low Scenario 
– Cluster B1: 6.4 million Euro s in the High Scenario 
– Cluster B2: 12.6 million Euros in the Low Scenario 
– Cluster B2: 25.2 million Euros in the High Scenario 
The cumulated environmental benefits over time  are equal respectively to 42-84 million Euro 
(Low-High scenario) and 163-326 million Euro (Low-High). 
Islands or quasi islands, which rely on Short S ea Shipping for most of  their supply will 
benefit from the cost reduction induced by the proposal but not from the reduction of 
environmental costs. 
                                                 
26 The modal shift to short sea shipping is calculated on the basis of the indications taken from the ISIC 
(Integrated Services in the Intermodal Chain) model which point out a percentage of modal shift to 
short sea shipping in presence of specific policies dedicated to such mode. 
 
EN 33   EN 5.2.3.  Social impacts 
5.2.3.1.  Impacts on safety and security 
Safety and security regulations have been si gnificantly developed in the past few years 
“aspects”. The main actions could be summarised as follows: 
– creation of EMSA (European Maritime Safe ty Agency) to ensure high, uniform and 
effective levels of maritime safety and prevention of pollution by ships in the Community. 
– the development of several secu rity provisions in particular: 
– Regulation (EC) N° 725/2004 on enhancing sh ip and port facility  security with 
the aim to introduce and impl ement security measures; 
– Regulation (EC) N° 884/2005 laying down a procedure for conducting 
Commission inspections in the field of maritime security; 
– Directive 2005/65/EC on enhancing the ex tension of security measures from 
the ship-port interface to  the whole port area. 
– Directive 2002/59/EC putting into place SafeSeaNet, a European electronic 
information system which deals with ship movements and cargoes. This monitoring 
and information system has been developed with the aim of enhancing the safety of 
efficiency of maritime traffic, improv ing the response of authorities at sea
27. 
Simplifications or relaxations of current legisl ative solutions already in place do not involve a 
radical change of procedures of interface betw een the various entities in port, but could 
increase dangerous or hazardous situations. Howeve r, the electronic data transmission of data 
will allow different authorities in ports (mainl y customs agencies) to set up and organise 
controls and inspections activities focused on the “higher risk situation” following a risk 
analysis process. While it is not possible to es timate a specific figure illustrating the impact of 
modern port communication systems and other su rveillance methods (LRID, AIS etc.), it is 
difficult to numerically quantify the extent to  which removing information flows would lead 
to higher security and safety costs. For the pur pose of the impact assessment, all the safety 
and security costs are co nsidered as non-variable. 
5.2.3.2.  Impacts on employment 
Available information does not allocate a cost  for a potential employment reduction in 
Customs or professions working on formalities like the ship or Customs agents. Those professions are being reorganise d, to cope with modernisation challenges (e-Customs), an 
extension of their missions a nd the growth in world trade induced by the globalisation. The 
European Maritime Transport Space without Ba rriers would have on effect on employment 
with a lower magnitude than those required to  meet these existing challenges. The reduction 
of Customs and other administrative burden on in tra-EU maritime transport could even help 
                                                
 
27 In October 2007, SafeSeaNet was implemented in Spain, Ireland, France, Italy, Belgium, Netherland, 
German, Poland, Denmark and was under test in UK,  Romania, Bulgaria, Greece, Slovenia, Lithuania, 
Latvia, Estonia, Sweden 
 
EN 34   EN the Customs to better deal with their core activity, which is the clearance of imported / 
exported goods. 
5.2.4.  Administrative costs 
The administrative costs born by Member States  comprise cost of design/development, 
training cost, monitoring cost  (start-up) and on-going co sts. The most impacted 
administrations are Customs and Port Authorities. 
Dangerous goods procedures  - The harmonisation of dangerous  goods procedures with other 
modes of transport (road and rail), while requi ring a strong commitment  in the design stage, 
leads to a substantial simplification of activities in port, without changing current 
organisational methods. Because of the need to activate transversa l agreements between 
different modes of transport, it is assumed that the effort in terms of administrative costs has an impact on many stakeholders in the maritime and road/rail sectors. Such financial effort 
translates into the launch of a working group with on average 9 FTE
28s for each MS and 5 
FTEs for the EU, supporting and coordinating the ac tivities. In this case , the work programme 
requires an average duration of 3 years. The consequent global financ ial effort amounts to 
about € 35.64 million. A cost due to a training progr amme for the different local structures in 
ports will have to be considered. The cost for each individual trai ning amounts to €1000. The 
financial effort for this training phase is a ssumed to amount to about €11 million. Finally, it is 
necessary to consider the creation or the strengt hening of structures linked to the control and 
monitoring of dangerous goods’ traffic in ports. It  is assumed that in each port, on average, 1 
FTE is dedicated to this, with a financial e ffort of about € 13.5 million at the EU level. 
Extending the ARSS Licence – This measure does not lead to changes in organisation and/or 
control systems of customs in port. However it requires efforts due to changes and/or 
simplifications in the way authorisations are issued ex-ante. Administrative costs connected with this measure are assumed to refer to the le gislative aspects, with an impact on the central 
administrations. A financial effort of about € 1.3 5 million at EU level has been considered. In 
addition, the cost of a training scheme for centr al customs and for local port operators needs 
to be taken into account. The financial effort in this training phase is as sumed to be less than € 
1 million. Finally, it is necessary to set up struct ures for the monitoring of the Licences issued 
corresponding to a financial commitment slightly higher than € 1 million. 
Electronic data transmission and single window  - Different projects currently ongoing 
within the EU have been considered and analys ed in order to calculate the cost of these 
measures. The average start-up cost (design and development cost) has been set at € 2 million 
per port; total development time has been assumed to be 4 years:  the average cost and time for 
the development of such an el ectronic data interc hange system has be en obtained via the 
elaboration of relevant information gathered  from various similar projects. Design and 
development costs have been differentiated betw een Member States. It has been considered, 
for each MS, a qualitative level of IT friendlin ess of countries, depending on the existence of 
e-information projects (planned or operati onal), current operating systems that allow 
paperless administrative procedur es. Countries with low degrees of IT friendliness would face 
higher costs than countries with medium or high degrees of IT friendliness. The final result is 
                                                
 
28 FTE: Full Time Equivalent job 
 
EN 35   EN that such system would present a total start- up cost at EU level of 58.3 million Euros. Annual 
development costs and running costs would amount to 1.31 million Euros. 
Use of an alternative language  – The only costs which emerge are the costs for the training 
of the staff in ports in a second language. It  has been assumed a heterogeneous financial 
effort, depending on the current level. Costs fo r language training also  depend on the total 
number of ports in countries and on the average num ber of staff (only front-office) per port 
that need to take these language classes. It has been assumed an average number of staff of 75 
(customs, port authority, etc) and a single cour se programme cost of 1000 €. On the basis of 
what has been assumed, it can be  inferred that this measure requi res a financial effort of about 
€ 5 million. 
Separation of areas in port  - A qualitative analysis has be en developed through interviews. 
The reaction to this measure raised controvers ial feedbacks from the contacted stakeholders. 
Answers ranged from "not feasible" to "alrea dy implemented", according to the layout and 
availability of free areas at terminals. Fu rthermore, major remarks concerned the cost-
opportunity of separating lanes for trailers  disembarked from Ro-Ro vessels: such a 
separation, together with the necessity to cope with Ro-Pax traffic, would imply the 
organisation of three lanes (non-EU goods, EU- goods, Schengen traffic) which would not fit 
with the actual space availability of most ports in EU. 
The availability of space in ports  and terminals resulted to be th e main constraint in separating 
areas for this purpose. A trade-off appears to exist between the surface utilisation rate of 
terminals and the cost of implementing the separation. 
However, the separation of areas in ports may lead to additional benefits in terms of FTE 
costs saved. The total amount of savings in perso nnel costs per year is estimated to amount to 
700-750,000 Euros per year, leading to a Net present Value of 11.7 million Euros on a 2009-2040 time horizon. The implementation of the Policy, even only at the major 25 ports 
throughout EU, would imply much higher costs. 
The separation of areas in port could have a stronger impact on Short Sea Shipping if the 
status of Authorised Regular Shi pping Service is extended also to  the vessels cal ling at one or 
more non-EU ports, namely “infect ed vessels”. With the extension of this status, in fact, it 
will be possible to separate EU goods from non-EU goods and tr ansit declarations. In this 
way, when a vessel calls at an EU port, EU  goods, maintaining thei r Community status, 
would not need any customs procedure and could be disembarked without any other 
administrative formality. Non-EU goods, instead, woul d have to be declared as for standard of 
import / export. 
5.3. Policy option C: Act on the basis of a co -ordinated set of measures simplifying, 
reducing, and, wherever possible, eliminat ing formalities for vessels sailing 
between EU-ports in line with the model of the Internal Market offered by land 
transport 
This option builds upon the measures presented in option B and foresees their implementation 
as a consolidated package while adding furthe r simplification to them by considering the 
elimination of some procedures. 
 
EN 36   EN 5.3.1.  Economic impacts 
5.3.1.1.  Cost decrease for reduction of time spent for administrative procedures for goods 
The reduction of the time required for carrying out  the different administrative procedures 
would lead to a reduction in the de lays on goods caused by the formalities. 
In terms of costs saved in relation to the reduc tion of time spent on procedures in relation to 
goods, the advantages of eliminating all admi nistrative procedures including Customs and 
other procedures could be estimated at the regi on of 2171 million Euros within the time frame 
2009-2040 or 678 million Euros within the time frame 2009-2020. 
It’s fundamental to clearly di stinguish the administrative proc edures due for trade purpose and 
the ones due for safety purpose. The latter  ones cannot be eliminated, because their 
elimination may cause hazards and dangers during the navigation and within port calls. 
Information on goods, service line, vessels and ope rators allow different authorities in ports 
(mainly customs agencies) to set and organise controls and inspections  activities focused on 
the “higher risk situation” follo wing a risk analysis process. 
5.3.1.2.  Cost decrease for reduction of  time spent during ship calls 
The time spent by vessels in port is connected to operative activities and is not due to the 
carrying out of administrative procedures (both customs and ad ministrative). Delays caused 
by activities connected with ad ministrative procedures are no t frequent. When occurring, the 
average value of such delays does not exceed 1 hour. 
Similarly to what has been done for delays on  goods, in order to calc ulate such potential 
delays, it has been evaluated the probability of reduction of delays. In this case too, it has 
been assessed the impact relative to the reduction of time for port operations. 
In order to calculate the time-rela ted costs of ships, an average hourly cost of rent of a ship 
has been considered. 
In terms of cost saved in relation to the reducti on of delays on vessels, the advantages (quite 
minimal) of the implementation of the different Policy Options correspond to an average ranging between 0.1 million Euros (facilitation of  Dangerous Goods and Customs procedures) 
to 1.38 million Euros per year (maximum reduction/elimination of formalities). 
5.3.1.3.  Impacts on the level of fraud 
The qualitative assessment in paragra ph 5.2.1.3. is applicable to Option C. 
5.3.2.  Environmental impacts
29 
By improving the internal efficiency of Short Sea Shipping, the elimin ation or reduction of 
administrative procedures determine a modal shift from road and rail to maritime transport, 
                                                 
29 The modal shift to short sea shipping is calculated on the basis of the indications taken from the ISIC 
(Integrated Services in the Intermodal Chain) model which point out a percentage of modal shift to 
short sea shipping in presence of specific policies dedicated to such mode. 
 
EN 37   EN which will induce a global reduction of the exte rnal costs. In order to assess the positive 
impact in terms of reduction of external cost s, a top-down approach has been adopted, based 
on the calculation of the overall modal shift (in terms of ton.km shifted from other modes to 
Short Sea Shipping in each year of the time horizon). 
The total number of ton.km in the short-sea transport of EU goods can be evaluated as 
amounting to 759,201 million ton.km, while in  the year 2020 it will amount to 1,115,906 
million ton.km, with an annual growth rate  of 3.0 % until 2010 and 2.7% afterwards. 
Two scenarios (Low and High) have been chosen to ensure the robustnes s of the analysis. In 
fact, the comparison between the “Low” and “H igh” scenarios will allow considering the 
sensitivity of such results to the extent of the gap between the two percentages used. 
The modal shift to Short Sea Shipping assumed in  the Low scenario is calculated on the basis 
of the indications taken from the ISIC model wh ich point out a percentage of modal shift to 
Short Sea Shipping in presence of specific polic ies dedicated to such mode. Such percentage 
is equal to 0.097%. This (0.097%) is assumed as the overall modal shift to  Short Sea Shipping 
deriving from the implementation of the Europ ean maritime transport space without barriers 
in the Low Scenario. 
The modal shift to Short Sea Shipping deriving from the implementation in the High Scenario 
is twice that of the Low Scenario, which is 0.194%. 
Since in the base-line scenario, in 2020 the Short Sea Ship ping of EU goods will account for 
1,115,906 million ton.km, considering the a dditional modal shift it results that: 
– In the Low Scenario the Short Sea Shippi ng of EU goods in  2020 is equal to 
1,116,986 million ton.km (+1,081 million ton.km shifted to Short Sea Shipping compared to the baseline); 
– In the High Scenario the Short Sea Shipping of EU goods in 2020 is equal to 
1,118,067 million ton.km (+2,161 million ton.km shifted to Short Sea Shipping compared to the baseline). 
The detour factor is the ratio that represents the share of a dditional transport (though it might 
be negative in certain cases) that is generated by the shift from a mode to another mode of the 
same door-to-door delivery. In other words, when shifting from road (or from rail) to Short Sea Shipping, a good has to travel through a higher  number of kilometres in order to reach its 
final destination; the detour factor quantifies mu ch higher such new route is. The detour factor 
assumed in this project is the deriving averag e of 19%. Moreover, from the same studies an 
average share of road vs. rail modal shift respec tively of 68% and 32% is derived out of total 
ton.km shifted from these two modes to Short Sea Shipping. 
As a consequence of such figures, i.e. deducing the detour factor: – In the Low Scenario, the amount of transpor t shifted from road and rail in 2020 is 
905 million ton.km (618 million ton.km fr om road, 287 million ton.km from rail); 
– In the High Scenario, the amount of trans port shifted from road to rail in 2020 is 
1,810 million ton.km (1,236 million ton.km from  road, 574 million ton.km from rail). 
 
EN 38   EN The savings results from the difference of exte rnals cost between the new situation (with a 
modal shift) and the baseline. It results from the differences of externalities between maritime 
transport and road and rail transport per ton.km . Externalities include impacts on air pollution, 
global warming, noise, accidents, transport conges tion and infrastructure costs. The benefits 
for the two low and high scenarios are broken dow n as shown in the following table in year 
2020. 
Environmental benefits per scenario in 2020 (million Euro) Source: PwC and Bocconi 
(2008) 
-2,04,06,08,010,012,014,016,0
Low EMS High EMSAir pollution
Global w arming
Noise
Accident costs
Congestion
Infrastructure
 
These figures give the range of external costs which can be allocated to the full elimination, 
where possible, of administrative procedures within the European Maritime Transport Space 
without barriers (EMS). For measures with  a more limited impact on elimination of 
administrative costs, the effect on environmen t is considered to be a proportion of these 
external costs. 
5.3.3.  Social impacts 
The qualitative assessment in paragra ph 5.2.3. is applicable to Option C. 
5.3.4.  Administrative costs 
The elimination of administrative formalities for vessels between EU-ports should reduce the 
present workload of administrations in ports. Member States will have to adapt their risk analysis methods, which will trigger new inspec tions schemes. A start-up phase for designing 
and training will be necessary. Change in pr ocedures follows the sa me logic in terms of 
development and implementation as the use of el ectric data transmission and the setting-up of 
a single window and similar administrative costs will be born. However there is an important 
overlap between these measures. It is possible to  assume that training, project, monitoring and 
on going costs (where evaluated) can be subs tantially reduced, if Policy Option B and C 
would be both proposed compared to the sum of  their respective costs.  There are synergies 
that can be exploited in or der to obtain consistent ec onomic savings. Policy Option C 
combined with Option B start-up costs are estimated at € 118.62 million) and ongoing costs 
 
EN 39   EN per year at € 34.94 millions. Design and developm ent costs (€ 100.3 milli on) account for most 
of the start-up costs. 
 
EN 40   EN 6. COMPARING THE OPTIONS  
6.1. Cost and benefits of measures 
Comparison of costs and benefits for all measures yields highly positive results. By means of 
relatively small costs of implementations, cons iderable benefits ca n be obtained at the 
community level. Though, if only internal benefits are considered (i.e. th e benefits related to 
the operation of Short Sea Shipping as such ), the comparison proves to be tighter. 
The measures concerning a single window and el ectronic data transmission affect the whole 
maritime transport of goods in Europe, whether it is intra-EU or not  and will bring even 
greater benefits. This remark is valid even in Member States a nd ports where the efficiency of 
electronic exchange of data is  already now at a high level. 
In the following table costs and benefits associated to the different scenarios and for the 
different Policy Options are computed on a 2009-2040 time span period. All values are 
expressed in their Net Present Value. 
 
EN 41   EN Cost Benefit Analysis: Monetised costs and benefits vs. baseline scenario (M € - Net Present Value - 2009-2040) - Source: PwC and CERTeT, 2008  
  Cluster of measures with low 
administrative costs Cluster of measures with higher 
administrative costs Elimination of administrative 
procedures 
Ref Impact on modal shift LOW HIGH LOW HIGH LOW HIGH 
A Investment + training costs 45.7 45.7 68.0 68.0 107.3 107.3 
B Operational costs 224.2 224.2 391.7 391.7 510.2 510.2 
C = A+B TOTAL COSTS 269.9 269.9 459.7 459.7 617.5 617.5 
D Personnel cost savings 11.7 11.7 232.7 234.7 244.4 244.4 
E Ship cost savings 0.17 0.17 25.9 25.9 26.0 26.0 
F Time cost savings 261.6 261.6 1917.9 1919.0 2171.6 2173.1 
G = D+E+F TOTAL INTERNAL BENEFITS 273.5 273.5 2176.5 2179.6 2442.1 2443.6 
H External benefits 37.4 74.8 145.3 290.5 182.7 365.3 
I = G+H-C TOTAL NET PRESENT VALUE 40.9 78.46 1862.0 2010.3 2007.2 2191.4 
 IRR 8.9% 12.0% 61.3% 62.5% 60.7% 61.9% 
(H+G) / C B/C RATIO 1.125 1.29  5.05 5.37 4.25 4.55 
 
EN 42   EN G / C INTERNAL BENEFIT / COST 
RATIO 1.01  1.01 4.73 4.73 3.95 3.95 
 
EN 43   EN The following comments arise from the analysis: 
– All policy options show a positive a Net Present Value (NPV) and Internal Rate of 
Return (IRR) in each scenario. The IRR ranges from 9% to 62%. The adoption of 
policies towards the implementation of a Maritime Space without Barriers appears to 
generate a higher amount of benefits than the burden of costs implied; 
– Investment costs are always lower in NPV than operational costs. It means that all 
policy options do not entail the necessity of  large scale investments (bearing in mind 
the EU-wide scope of the policies), but they imply a significant amount of direct effort from the stakeholders concerne d. In particular, the development and 
maintenance of Information and Communica tions Technologies features created for 
the policy implementation is higher compared  to the initial investment cost for the 
hardware/software development; 
– The relevance of time cost savings, i.e. of  the improvement of punctuality rate in 
door-to-door transport is outstanding comp ared to the remaining categories of 
benefits, and including “extern al” ones. It demonstrates that the largest share of 
benefits is widespread over a large panel of stakeholders (for warders, logistics 
operators, shippers/consignees, industries, etc.) that have their primary interest in 
receiving goods in a shorter time, and with a lower probabi lity of delay; 
– The costs will be shared between administrations and port authorities for the design, 
development and training phase (line A), but will be born by port authorities for the yearly costs (line B). The personal cost sa vings will beneficiate to the administration 
(around 20%) and the privat e sector (around 80%) ( line D). The cost for 
administrations of all the options should be counterweighted by the personal cost savings and are not significant. 
– Electronic data transmission and single window measures (in cluster B2) will induce 
the highest investment and operating costs.  The integration of these systems in a 
more integrated system capable to meet the industry needs and covering transport from door-to-door will further increa se the benefits of the measure. 
6.2. The main economic, environmental and so cial impacts of the preferred option 
The preferred action will implement administra tive simplification in view to induce a 
transport modal shift reducing congestion, infrastr ucture, safety and various pollution costs. It 
will bring the following benefits. 
Macro-
category Impact on: Detailed descri ption Indicators Effect 
Economic Higher efficiency 
and reduction of 
total transport 
costs Reduction of personnel costs: reduction or 
standardisation of proce dures could generate the 
savings in terms of FTE Full time equivalent 
involved in carrying 
out administrative 
procedures Benefit 
Economic Higher efficiency Reduction of personnel costs: reduction or 
standardisation of proce dures could generate the 
savings in terms of equivalent FTE Average delay 
(hours) in door-to-
door arrival of 
goods Benefit 
 
EN 44   EN Economic/ 
Environmental Competitiveness 
of shipping 
industry Cost decrease for time reduction of ship calls 
(minimal): Reduction of potential delay in port 
because of the elimination/simplification of 
administrative procedures. 
Other impacts (negligible):  
Reduction of waiting times in port and possible 
extension of the origin/destination time: lower 
waiting time in port. Sailing times can therefore be 
extended, thus realising energy and economic 
savings;  
Decrease of overall sailing time: shipping 
frequencies can be increased (qualitative) Benefit Benefit 
Economic Competitiveness 
of shipping 
industry and 
relative increase of 
total transport 
costs Administrative costs: short-term increase of 
administrative costs, due  to the harmonisation of 
procedures and to the management of the 
organisational stage of  the standardisation 
programme; Long-run decrease of administrative 
costs. All administrative 
costs (no personnel 
cost) Benefit 
Environmental Modal shift Reduction of ex ternal costs caused by modal shift: 
Modal shift (Environmental effect): modal shift 
determines lower emissions  of pollutants (shipping 
is environmentally friendlier than road/rail 
transport); 
Modal shift and additional costs of transport. 
Linked to the last part of the voyage by road/rail. 
Maritime transport cannot cover the overall 
transport of goods. The last part needs to be carried 
out with another mode of transport Emissions, Global 
warming, Noise, 
Congestion, 
Accident costs, 
Infrastructure, Vehicle costs 
 Benefit 
6.3. Preferred approach 
Individual measures present cl ear benefits and their combinat ion will permit to a certain 
extend to synergize their benefits. All of them merit to be implemented. However, as some of 
them are associated with almost no administra tive costs, while other imply investment in 
technology and training and shal l be encompassed in a wider c onsistent approach and other 
depends much on local and technical conditions , their modalities sha ll be differentiated. 
The preferred approach is Op tions C which builds upon the meas ures presented in option B 
and foresees their implementation as a consolidated package while adding further simplification to them by considering the elimination of certain procedures: 
– Elimination of systematic controls and doc umentary requests for Internal Market 
maritime transport and associated carriage of  goods or products in line with inland 
transport. Information on goods under Cust oms and other types of supervision 
(veterinary and phytosanitary) would still be available and have to  be presented at 
spot checks. 
The EU legislation, which requires the transmi ssion of data at the arrival or departure 
of vessels at ports relate to: 
 
EN 45   EN – Entry and departure notification (Directive 2002/59/EC  and Directive 
2002/6/EC) including the Maritime Declar ation of Health; 
– Waste management formalities (Directive 2000/59/EC); 
– Security notification prior to entry in to ports (Regulation (EC) N° 725/2004); 
– Port state control of ship ping (Directive 95/21/EC); 
– Dangerous goods procedure (Directive 2002/59/EC); 
– Customs Declaration (Re gulation (EEC) N° 2913/9230); 
– Veterinary checks on products of an imal origin (Directive 89/662/EEC); 
– Veterinary and zootechnical checks on live animals and products (Directive 
90/425/EEC); 
– Phytosanitary inspections  (Directive 2000/29/EC). 
– In this scenario, the extension of th e "Authorised Regular Shipping Service" 
facilitation to operators on authorised rout es would not be an option since all goods 
carried between EU ports would be subject to spot checks only. However, this option 
would have clear positive effects and c ould be recommended in today's situation. 
– Rationalisation of vessel-related and goods-re lated reporting and forms required by 
Directives 2002/6/EC, 2000/59/EC, 2002/59/ EC and Regulation (EC) N° 725/2004. 
Further enabling measures would also  need to be implemented, namely: 
– Electronic transmission of  administrative data; 
– Setting-up an administrative single window; 
– Simplification of the sea transport of dangerous goods with the recognition of 
equivalence for some IMDG and ADR rules. As this measure will require further 
consultations of the stakeholders of the va rious transport modes, it is envisaged at a 
later stage. 
These proposals would be implemented under wide r proposals, which will be included in the 
action plan for the deployment of e-maritime systems in 2009. 
In addition, the recommendations should be gi ven that Member States implement further 
enabling measures, each time the local conditions permit to do it in an efficient manner, namely: 
– Coordinate the inspections carried out in the ports by  the various administrative 
services (“one-stop administrative shop”); 
                                                
 
30 Council Regulation (EEC) N° 2913 of 12 October 1992 establishing the Community Customs Code 
 
EN 46   EN – Extend the scope of Pilot Exemption Certificates; 
– Introduce the use of the language most commonl y used at sea as an alternative to the 
national language(s) in administrative communication; 
– Create areas in ports dedicated  to Short Sea Shipping where that can facilitate the 
operations for this mode. 
These recommendations or enablers , in particular that of a “one-stop administrative shop” 
might be later converted into stronger instrume nts based on an evaluation to be undertaken 
within three years. 
This combination and co-ordinated implementati on of the measures will  allow costs savings 
and productivity benefits to be utilised while the same level of  essential information continues 
to be available. 
While allowing considerable reduc tion of administrative burde n, the approach does not risk 
fundamental objective of lowering standards. It would give legal certain ty regarding guidance 
and help lowering the costs to businesses in several Member a nd, subsequently, to consumers. 
It should be stressed that the available eviden ce indicates that standa rds would not be lowered 
and that therefore these estimated cost savi ngs are not offset by ot her, negative impacts 
elsewhere. 
6.4. Impact of the preferred approach on stakeholders 
The preferred option leading to the eliminati on of some of the systematic administrative 
formalities and the simplification of administrative procedures for all stakeholders: 
European 
Union 
 Costs: Administrative costs, such as management of the legislative process 
and monitoring feedbacks will be negligible; 
Benefits: increase of modal shift from road to maritime, achievement of the 
internal market and reduction of external costs. 
Member States and maritime 
Authorities Costs: Start-up administrative costs at national level will be compensated by 
benefits; 
Benefits: increase of modal shift from road to maritime, increased 
efficiency and better allocation of administrative services. Possible 
reduction of frauds. 
Port Authorities Costs: Administrative costs (mainly de velopment of the project at port level 
and on going costs related to upda ting running and controlling of 
programmes activated); increase of ad ministrative costs resulting from the 
development of the new programme; 
Benefits: increase in lab our productivity and reduc tion of time for each call 
(controls of physical docum ents no longer performed). 
Customs Costs: Administrative costs (mainly fo r developing the project at port level 
and on going costs related to upda ting running and controlling of 
 
EN 47   EN programmes activated) should be compensated by benefits;  
Benefits: increase in la bour productivity and consequent reduction of time 
for each call (controls of physical documents no longer performed). 
Maritime lines Costs: increase of technology costs for the alignment of harbour 
communication and single window tools. Increase in costs for 
computerisation of procedures; 
Benefits: net reduction of total transport costs due to the decrease of 
administrative costs; potential reduction of  internal costs due to the decrease 
of delays on vessels; increase of  utilisation rates of vessels. 
Ship Agents Benefits: increase in la bour productivity, as a consequence of reduction of 
time spent preparing different documents and carrying out administrative procedures). 
Forwarder Benefits: reduction of costs in re lation to a proportional decrease of 
administrative procedures and customs formalities (free circulation of EU 
goods within EU ports); reduction of  costs related to a decrease of 
probability of delays mainly of the goods (door-to-door transport); potential 
decrease in the price of transport services. Potential increase in the service level, due to the increase of punctuality rate on goods. 
Citizens Benefits: reduction of costs for the tran sport of goods and po tential increase 
in the price of transport services: reduction of emissions, noise, pollution, 
road congestions, accidents, caused by the modal shift from road to 
maritime. 
6.5. Uncertainties and sensitivity analysis 
A difficulty encountered was the lack of statistical data on th e 'EU or non-EU' origin of goods 
carried by maritime transport. Best assumptions on goods volume were thus made in co-operation with EUROSTAT. The “percentage of EU goods in regular se rvices”, has been 
chosen for a sensitivity analysis. 
The goal was to find the switching va lue of the parameter, i.e. the value for which the internal 
return of the simplification of Customs procedure turns to zero and to verify “how far” the 
switching value from the value used in the analysis is. 
The reference value used in the analysis is 90%, meaning that regular intra-EU shipping 
services authorised by the Customs to have si mplified procedures are assumed to carry a 90% 
average of EU goods. The sensitiv ity analysis showed that the switching value is reached at 
68%. According to the sources scanned and th e redemption of the stakeholders’ survey, it 
appears that a 68% ratio of EU goods in regular services is a low value, thus validating the 
assumption made. 
The figures also probably underestimate the effect of a reduction of procedures on the 
attractiveness of Short Sea Shipping. Shippers seem to be more sensitive to the risk of 
unexpected long delays than the actual average time lost in doi ng procedures. The modal shift 
induced by the reduction of administrative procedures may thus be underestimated. 
 
EN 48   EN Two scenarios of modal shift (low  and high) have been used to  ensure the robustness of the 
analysis. The expected effect that a signifi cant reduction of admi nistrative burdens can 
probably induce as the actual modal shift will not  only be related to costs as calculated, but 
will be largely amplified with a better regularity and reputation of the transport mode. Simplification measures will convince more shi ppers to use maritime transport if they are 
more visible. The efficiency of the preferred measure will be augmented if it has an intrinsic promotional virtue, not assessable by the modelling tools used for the study. 
As show in the following table, in a shorter te rm the cluster B1 shows negative result in both 
scenarios: the NPV and IRR are lower than zero and the Benefit/Cost ratio is lower than 1. In 
fact its benefits would apply on a limited range of the market and would not prove to make up 
for the corresponding costs in just 11 years. This is due to the fact that the highest costs arise 
in the start-up period and in the years afterw ards they are lower and constant, whereas 
benefits are only registered after the implemen tation and would grow in time – so that the 
shorter the time horizon, the lower the possi bility that they compensate for the 
implementation costs. 
 
EN 49   EN Cost Benefit Analysis: Monetised costs a nd benefits vs. baseline scenario (M € - Net Present Value - time horizon 2009-2020)  
  POLICY OPTION B1 POLICY OP TION B2 POLICY OPTION C 
Rif Impact  LOW HIGH LOW HIGH LOW HIGH 
A Investment + training cost s 45.7 45.7 68.0 68.0 107.3 107.3 
B Operational costs 98.2 98.2 158.3 158.3 213.7 213.7 
C = A+B TOTAL COSTS 143. 8 143.8 226.3 226.3 321.0 321.0 
D Personnel cost savings 5.0 5.0 82.0 82.4 87.0 87.0 
E Ship cost savings 0.07 0.07 9.2 9.2 9.2 9.2 
F Time cost savings 111. 1 111.1 678.9 679.2 813.5 813.9 
G = 
D+E+F TOTAL INTERNAL BENEFITS 116. 2 116.2 770.1 770.7 909.7 910.1 
H EXTERNAL BENEFITS (external 
costs saved by modal shift) 9.8 19.5 34.7 69.4 44.5 88.9 
I = G+H-C TOTAL NET PRESENT VALUE 
(NPV) -17.9 -8.1 578.5 613.8 633.2 678.0 
 IRR -3.6% 1.0% 60.3% 61.5% 59.8% 61.1% 
(H+G) / C B/C RATIO 0. 88 0.94 3.56 3.71 2.97 3.11 
G / C INTERNAL BENEFIT / COST 
RATIO 0.81 0.81 3.40 3.41 2.83 2.84 
Source: PwC and CERTeT elaboration (2008) 
 
EN 50   EN  
7. MONITORING AND EVALUATION  
The measures should provide the first tangible  effects on modal shift in the year following 
their implementation. 
The core indicators to assess the progress are the time and delays spend in administrative 
procedures in Short Sea Shipping as well as the evolution of the share of the different 
segments of Short Sea Shipping in the tota l transport volume in the Internal Market. 
The Commission will monitor th e progress in the establishment of the European maritime 
transport space without barriers a nd pay attention to any problem in the implementation phase 
and envisage further actions to address them if needed. 
It will monitor the implementation of the Inte rnal Market in maritime transport collect 
information by stakeholders and disseminate c oncrete data on best pr actices. A staff report 
should be issued three years after the adoptio n of the action plan, at the occasion of the 
forthcoming Commission Communication on the promotion of Short Sea Shipping. 
 
EN 51   EN Annex A: Administrative procedures app licable to intra-EU maritime transport  
Summary of the main procedures 
 Specific procedure/paper Specific References 
Safety and Navigation Entry and departure notification Directive 2002/59/EC 
Environment Loading/unloading of bulk carriers; 
Waste management procedure. 
 Directive 2001/96/EC 
Directive 2000/59/EC 
Port and ship security Security notification prior to entry; 
Procedures on Port state control of shipping (Paris 
Moue); 
Dangerous goods procedure “Dangerous Goods Declaration”; 
“Dangerous Goods Manifest”.  Regulation (EC) N° 
725/2004 
Directive 95/21/EC 
  
Directive 2002/59/EC 
IMO/FAL FORM (N°7) 
Custom procedures IMO/FAL forms (1, 3, 4, 5, 6); 
Cargo Manifest. Directive 2002/6/EC 
 
Control Immigration Immigration procedure: “Border Control”. Regulation (EC) N° 
562/2006 
Phytosanitary measures 
and agriculture Phytosanitary inspections.  
Veterinary Veterinary checks on products of animal origin; 
Veterinary and zootechnical  checks on live animals. Directive 89/662/EEC 
Directive 90/425/EEC 
 
Health Maritime Decl aration of Health; 
 IMO/FAL forms31 
Payment of dues Dues on cargo form; 
Declaration of vessel dues. French code and port 
regulations … 
 
                                                 
31 Attached to IMO/FAL Form No.1 (Gen eral Declaration), only on arrival 
 
EN 52   EN List and description of the main procedures 
Id  Description of Procedures 
1 All vessels 
(second part only 
some ships) Entry and departure notification (related to Directiv e 2002/59/EC), establishing a Community vessel traffic 
monitoring and information system (VTS) : 
Notification prior to entry into  ports to the port authority: (a) at least 24 hrs in advance; (b) at the latest, at the 
time the ship leaves the prev ious port, if the voyage is less than 24 hrs; (c) if the port of call is not known or it 
is changed during the voyage, as soon as this info rmation is available”. Ge neral information: ship 
identification, port of destination, estimated  time of arrival, no. of persons on board. 
Automatic Identification System (AIS) obligatory for ships > 300 GT. AIS can be picked up by other vessels or 
coastal stations within 40 miles; Ships must be  fitted with a Voyage Data Recorder (VDR); 
Ships entering the area of applicability of a VTS (Vessel Traffic Service) ope rated by one or more States must 
comply with the rules of that VTS. 
2 All vessels Waste management (Directive 2000/59/EC). 
A form is filled in by the shipmaster and sent to the ha rbourmaster via the ship agen t. The ship agent can enter 
electronically the information in the VTM system of the Port authority if  any, or send it directly to the 
harbourmaster by fax or e-mail. 
Deadline is 24 hours prior to arrival, if  the port of call is known, or as soon as the port of call is known, if this 
information is available less than 24 hours prior to arriva l, or at the latest upon departure from the previous 
port, if the duration of the voyage is less than 24 hours.  
Possibility of exemptions for scheduled services, on cond ition that they have an arrangement for disposal of 
waste 
3 Bulk carriers Loading / Unloading of bulk carri ers: Procedures related to Directive 2001/96/EC 
Notification by the master to the terminal before arriva l: estimated time of arrival, general information about 
the ship 
After receipt of Notification of  estimated time of arrival, the terminal must provide the master with information 
about the terminal 
Before loading/unloading, the master shall agree with  the terminal representative on the (un)loading Plan, 
prepared according to the BLU Code. Si gnature of the terminal representativ e. Ship Checklist to be completed 
and signed jointly by the master and terminal represen tative. At the end of (un) loading, written agreement by 
the master and terminal representative th at it has been done according to the Plan. 
4 All vessels Security notif ication prior to entry: 
No compulsory model from the ship to the port. Content of the form is a list  of items of information, detailed in 
Regulation (EC) N° 725/2004: identification of the ship , ETA, confirmation that the ship has a valid ISSC 
(International Ship Security  Certificate), security level of the ship, etc. 
Form is filled by the shipmaster and sent to the harbou rmaster. Harbourmaster transm its the form if necessary 
to the Port Facility Security Officer concerned with the ship. Deadline is at  least 24 hours before ship’s arrival 
to the port. Means of  transfer: fax, telex, e-mail, etc. 
Possibility of exemptions for scheduled se rvices, also for international services 
5 All vessels 
(random checks) Procedures related to Directive 95/21/EC on port state control of shipping 
Member States to carry out inspections on at least 25 % of the annual no. of ships entering ports. Inspection = 
check on compulsory documents (list in Annex II) + check on overall condition of the ship 
Some categories of ships have prior ity in inspections, and some other ones must have expanded inspections. 
Detailed rules on the inspections 
Paris Memorandum of Understanding on Port State Controls . A harmonized system of Port State Control. The 
MOU consists of a the main body in which the Authorities agree on: 
 
EN 53   EN their commitments and the releva nt international conventions 
the inspection procedures and the inve stigation of operational procedures 
the exchange of information 
the structure of the organization and amendment procedures 
6  Dangerous goods procedure (Directive 2002/59/EC) 
Before taking on board, a Declaration must be delivered to the master (Cargo information), with the list of all 
dangerous goods on board. At the latest at the moment of departure, shipmaster to  Notify competent authority 
(General information + Cargo information) in the port of  arrival. Information to be exchanged electronically. 
Possibility of exemption for scheduled services 
7 Vessels 
(dangerous goods) IMO Dangerous goods manife st (IMO/FAL form 7) 
It is notified in advance to the harbourmast er by the shipmaster, by fax, email, telex. 
8 All vessels Reporting formalities: IM O/FAL Declarations. Procedures related to Directive 2002/6/EC on reporting 
formalities for ships arriving in and/or departing from ports of EU Member States: IMO/FAL form 1 “General 
Declaration”, IMO/FAL form 3 “Ship’s stores Declarat ion”, IMO/FAL form 4 “Crew’s effects Declaration”, 
IMO/FAL form 5 “Crew List”, IMO/FAL form 6 “Passenger List”. 
Deadline: day of arrival or departure 
9 All vessels Cargo Manifest: Contains id entification of vessel, carrier, code no., master’s name, voyage, port of loading, 
port of discharge, list of goods carried on board, ….  
Signed by the shipmaster and given/sent to Customs no later than 24 hours after ship arrival and before ship’s 
departure. Means of tran sfer: paper, electronic. 
A cargo manifest is not developed only for customs purposes, it has in the first place a commercial function. 
10 All vessels Border controls on persons: Regulation (EC) N° 562/2006 
Ship’s captain to draw a list, in dup licate, of the crew and of any passeng ers. At the latest upon arriving in the 
port, the list must be given to the border guards. If th e list cannot be sent to the border guards, a copy will be 
sent to the appropriate border post or shipping authority , which shall forward it to the border guards. One copy 
of the two lists duly signed by the border guard shall be  returned to the ship’s cap tain, who shall produce it on 
request when in port. 
Ship’s captain to notify the border guards of the ship’s departure in due time. The second copy of the 
previously completed and signed list must be retu rned to the border guards or shipping authorities 
Cross-border movement at external borders shall be subj ect to checks by border guard s. Checks shall be carried 
out in accordance with  this chapter. 
All persons shall undergo a minimum check in order to establish their identities on the basis of the production 
or presentation of their travel documents.  
“The minimum check shall be the rule for persons enjoying the Community right of free movement…Member 
States may authorise seamen holdi ng a seafarer’s identity document32 (SID) to enter into the territory of the 
Member States by going ashore to stay “in the area of the port where their ship s call or in the adjacent 
municipalities without presenting themselves at a borde r crossing point, on condition that they appear on the 
crew list, which has previously been submitted for checki ng by the competent authoritie s, of the ship to which 
they belong”.33 
No specific forms for the lists of crew and passengers  are imposed by the Regulation (EC) N° 562/2006. The 
lists must be drawn up in duplicate 
                                                 
32 Seafarer’s identity document has to be issued in  accordance with the Geneva Convention of 19 June 
2003 (No 185), the London Convention of 9 April 1965 and the relevant national law 
33 Cf. Regulation (EC) N° 562/2006 (point 3.1 of Annex VII) 
 
EN 54   EN 11 Some vessels 
(random) Phytosanitary inspections: Member States shall organise  at random occasional checks, at any time and at any 
place where plants, plant products or other objects are moved. Systematic import inspection of regulated 
material moving between two places within the Communi ty over non-Community territory is not needed if 
there are no specific risks identifie d, but the possibility for occasional checks should always remain. 
12 Some vessels 
(random checks) Veterinary checks on products of animal origin: Proced ures related to Directive 89/662/EEC on Products to be 
accompanied by a health certificate 
Checks at origin. If products were im ported from outside the EC, then the Me mber State of origin must perform 
documentary checks. 
Checks at destination: local author ities can perform veterinary checks. 
13 Some vessels 
(random checks) Veterinary and zootechnical checks on live animals and products. Procedures related to Directive 90/425/EEC. 
Animals to be accompanied by health certificates and/other documents 
Checks at origin: If products were im ported from outside the EC, then the Member State of origin must perform 
documentary checks. 
Checks at destination: local authorities ma y perform vet. and zootechn. checks.  
14 All vessels Maritime Declaration of Health: Attached to IM O/FAL Form No.1 (General Declaration), only on arrival. The 
document includes the identification of the vessel, master’s name, deratting certificate or exemption, number of 
passengers, number of crew, the list of former ports of ca ll (for the last 4 weeks), a set of questions about cases 
of illness on board, to be answered by yes or no and pa rticulars of every case of illness or death occurring on 
board must be mentioned in a schedule  annexed to the declaration. The Decl aration is certified true and correct 
by the ship master. One copy is attached to the IMO/FA L Declaration No. 1. Another copy is sent to the port’s 
health services. 
Deadline: prior to entr ances, no fixed deadline 
15  Collection of port dues on Cargo (French code and port regulations): the dues on cargo forms includes the 
shipper and consignee names and addresses, ship name and flag, port of departure and destination, kind of 
goods, number of packages; NST number, references and le vel of dues, total amount to pay, mode of payment, 
(cash or guarantee) and is certified by consignee or his local agent. 
The form is used by Customs to collect the money fo r the benefit of Port Authority only for bulk cargo (for 
general cargo and containers, port dues are directly incl uded in Custom duties – in this case a copy of the 
manifest is sent to the Port Authority) 
16 All vessels Collection of port dues on vesse ls or passengers (French code and port regulations): The “declaration of vessel 
dues” (DN) form includes the ship name and flag, numb er of the voyage, names and addresses of the operator 
of the ship and his local ship agent, port of departur e and destination, characteristics of the ship, number of 
passengers and level of dues, total amount to pay, and is certified by the ship agent. 
Checks on ship safety certificates 
The certificates that ar e routinely checked by the authori ties on arrival or departure are: 
Certificate of Registry, Intern ational Tonnage Certificate, Ca rgo Ship Safety Construction 
Certificate, Cargo Ship Safety Equipment Certif icate, Cargo Ship Safety Radio Certificate, 
International Loadline Certificate, International Oil Pollution Prevention Certificate, Certificate of Fitness of Ca rgo Gear, Safe Manning Docume nt, Deratting Certificate, 
Certificate of Insurance for Oil Pollution Damages, Certificate of Class, Safety Management Certificate, Docume nt of Compliance. 
Customs procedures 
– The Community Customs Code
34 allows the simplification of certain customs 
procedures, in the case of those vessels  performing regularly scheduled routes 
                                                 
34 Council Regulation (EEC) N° 2913 of 12 October 1992 establishing the Community Customs Code; OJ 
L 302, 19.10.1992, p.1 and Regulation (EC) N° 450/2008 of the European Parliament and of the 
 
EN 55   EN between two EU ports. In th is case it is necessary to have a Certificate of 
“Authorised Regular Shipping Service” (AR SS). This authorisation is given to 
named vessels on a specific route. 
In relation to “non regular shipping service” operator, if goods are in free circulation, the 
proof of Community status is alwa ys required on arrival in a port. 
The following table shows the customs proce dures in the EC for Community and Non- 
Community goods35. 
Selected Customs Procedures in the EC 
 Non-regular shipping services Authorised regular shipping services 
Community goods All ‘other’ (no ARSS) shipping services 
carrying Community goods are obliged upon 
arrival at an EC port to present information to the Customs authorities. 
Proof of Community status always required on 
arrival in a port. 
Custom procedures: 
Presentation of goods - made by (either) the 
person who has brought the goods into the Customs territory of the Community or the 
person who assumes responsibility for their 
onward carriage 
Summary Declaration - made by (either) the 
person who conveyed the goods into the 
Community, the person who assumes responsibility for their onward carriage, the 
shipping company, or th e representative of any 
of the above 
The Customs office at the place of unloading 
should be contacted to agree which commercial 
documents are acceptable. The acceptable 
documents are: bills of lading, container 
manifests, loading lists, shipping company’s, consignment records (on computerised 
inventory systems) 
Unloading and storage of goods: goods may 
only be unloaded from a ship after presentation, 
lodging of a summary declaration and with 
Customs permission at places approved by 
Customs. No need to prove the status of Community goods 
(free circulation). 
                                                                                                                                                         
Council of 23 April 2008 laying down the Community Customs Code (Modernised Customs Code); OJ 
L 145 of 4.6.2008, p. 1 
35 Cf. commission staff working paper: “Guide to Customs Procedures for Short Sea Shipping” (Revised 
Working Version 3 updated on 14 January 2004). 
 
EN 56   EN Non Comm. goods (transit)Non-Community goods Presentation and summary declaration are the 
same as in the case of Community goods.  
Restrictions on the movement of goods after 
unloading Transit procedure: 
Presentation to the Customs office of departure 
and destination of Transit Declaration, Guarantee. 
There is a standard procedures and two types of 
simplified transit procedures (level 136 and level 
237): 
system based on Shipping Service’s own 
manifest; 
no requirement for a transit guarantee for goods 
carried under T138 or T2F39. 
Less paperwork, because the manifest replaces 
various transit documents. 
The simplified customs procedure of an "Authorised Regular Shipping Service"40 has been 
made available to operators but most of th em would like a further improvement of this 
facilitation, e.g. to have it linked to companies or  routes instead of sh ips. A survey conducted 
by the Finnish Customs found that 62% of liner services have authorised regular service 
permits. 
                                                 
36 Level 1, simplified procedure (i ndividual manifest for goods): recei ve authorization from competent 
authorities, load vessel, manifest, complete 2 c opies (one to Office of Departure and one to 
Accompanies Cargo) of separate manifests as trans it declaration endorsed by Office of Departure, 
goods unloaded and Manifest as transit declaration presented to office of destination. 
37 Level 2, simplified procedure (s ingle manifest for all goods): recei ve authorization from competent 
authorities, load vessel, single manifest to Port of unloading.  
38 T1 = declaration made on the Community transit do cument that the goods ar e placed under external 
Community transit. 
39 T2F = Declaration made on the Community trans it document that Community goods are travelling to, 
from, or between a part of the Customs territory of the Community where the provisions of Directive 77/388/EEC (VAT) do not apply (‘non-fiscal territories’) under internal Community transit. 
40 Simplified Customs Procedures in Short Sea Shipping: "Authorised Regular Shipping Service", 
SEC(2004) 333 
 
EN 57   EN Annex B: Comparison of administrative pr ocedures for road and maritime transports  
It is generally acknowledged that one of the ma in obstacles to the development of Short Sea 
Shipping is represented by the presence of cumb ersome administrative procedures, which are 
more intricate than those applicable to road transport. 
– This Annex presents a comparison between the administrative procedures applicable 
to maritime transport and those applicable to road transport. 
Administrative procedures in road transport 
In the following table an overview of transpor t documents required in international road 
transport across Europe is presented. 
Overview of road transport procedures 
Document Requirements 
International Consignment note Must be  carried on each vehicle at all times 
Community authorisation Must be car ried on each vehicle at all times 
Valid Insurance certificate Not mandatory 
Vehicle registration document Carried by the driver 
Letter of Authority If the vehicle does not belong the driver 
Vehicle tax disc The tax disc should be displayed: no vehicle 
taxation within EU 
Driver licence Carried by the driver 
Driver passport Carried by the driver 
Plating certificate Attached to the vehicles 
Tachograph record Tachograph record 
Good vehicle text certificate  
It is important to underline that  road vehicles carry only few certificates. There is no border 
crossing routine reportin g for European Road Transport (ERT), apart from the International 
Consignment Note. The control of these certifi cates is limited to checks at the external 
borders of the EU and to random roadside chec ks. Random roadside checks may occur at any 
time within the EU when the truck driver is required to produc e these documents. 
Moreover, the following table shows the difference between Short Sea Shipping and road 
Customs formalities in relation to the vehicles into the Customs territory. 
 
EN 58   EN Comparison of Customs formalities in Short Sea Shipping and road transport 
Subjects Short Sea Shipping Road transportation 
Community goods A) No “Authorised regular shipping 
services”  
Need to prove the status of Community 
goods because of re-entry of the Community at an 
- Presentation of goods 
- Proof of community status 
(T2L document or commercial 
documentation such as a ship manifest) 
B) “Authorised regular shipping services”  
No need to prove the status of Community 
goods because of authorisation of the vessel (free circulation). No proof of Community status when goods 
are transported within the EU (and do not 
cross external borders) 
 Proof of Community status when goods re-
enter the Community at an external border 
point: 
- Presentation of goods 
- Proof of Community status (T2L document or commercial 
documentation such as the CMR) 
Non-Community goods 
 Cargo Declaration or Manifests 
Transit (T1) Document41 
“Authorised Regular Liner Service”: 
Simplified transit declaration Transit (T1) Declaration 
Community goods carried by road, which remain w ithin the EU and do not  cross an external 
border point, do not need to provide evidence of  their status. By cont rast, a Community port 
constitutes an external border  point where proof of the Comm unity status of goods must be 
always provided except for goods carried by a vessel aut horised as a regular shipping service. 
Comparison between maritime a nd road administrative costs 
In order to evaluate the average costs of administrative procedures, as for maritime transport, 
the following assumptions have been set:  
– Time consumption and delays are considered only for “roadside checks/inspections” 
and a probability of contro l has to be considered: fo r the purpose of the Impact 
Assessment it has been set at 2.0%42; 
– Because of the presence of few documents, th e time for the preparation of documents 
has been assumed to be 1h; 
                                                 
41 There are 2 types of simplified transit procedures: system based on Shipping Service’s own manifest; 
no requirement for a transit guarantee for goods carried under T1 or T2F. 
42 Source PriceWaterhouse Coopers in relation to the Directives on “Better Road Safety Enforcement in 
the European Union” 2006/22/CE (15/03/2006). 
 
EN 59   EN – Time requirement for one inspection: 1 hour and 4 employees (2 drivers and 2 
inspectors); 
– Personnel cost: 20€/h; 
– Average tonnage for trucks 21 tons; 
– Average fee for renting a truc k: 70 €/h (18 hours per day). 
Consequently, the cost for one roadside inspection could be set at almost € 200. 
In order to better understand th e poor competitiveness of ma ritime transport against road 
transport, a comparison between different admi nistrative costs has been developed per vessel 
and truck. 
In line with the assumptions made above, the following table shows the costs of different 
administrative procedures. Different types of ma ritime transport and the all-road solution are 
considered. Data refe r to standard goods. 
Total cost per call for standard goods (€, €/tons) 
Prob.(Cost) Container Ro-Ro Bulk Avg MARITIME 
(weighted)  ROAD 
TOTAL internal Cost [€/call] 800.1 960.1 1632.5 € 1,336.6 195.2 
TOTAL Internal cost [€/tones] 0.27 0.38 0.20 0.22 0.18-0.89 
Average transport cost  5.36 
(€/tones) 5.36 
(€/tones) 7.64 
(€/tones) 9.15 
(€/tones) 90.0 
(€/tones) 
Market share 10.5% 12.8% 69.5% 100%  
ADM on total transport cost 5% 7% 2.67% 3.27% 0.20% 
 
 
EN 60   EN Total cost per call for standard goods (€, €/tons)43 
 960.11632.5
€ 1,336.6
€ 192.8800.1
€ 192.87.00%
5.00%
1.01% 0.20%3.27% 2.67%
0.0500.01000.01500.02000.02500.03000.0
Container Ro-Ro Bulk MARITIME ROAD ROAD Max0.00%2.00%4.00%6.00%8.00%10.00%
AD M  P R OC  C OST P E R  C ALL AVE R AGE  (BAU ) % of ADM COST on TOTAL TRAN. COST
 
 
As it can be inferred from the figure above, for maritime transport the average cost per call 
generated by the various administrative procedures could range between € 1.050 and € 
1.850.The administrative cost for a generi c truck is almost € 200 per inspection. 
It can be assumed an average cost of: – 0.22 €/tons for maritime transport (roughly 3.27% of total transport costs); 
– 0.18 €/tons for road transport (roughly 0.2% of total transpor t costs -- considering the 
probability of 2.0 % for the inspection on trucks). 
The cost per ton differs by 22%  but the relative impact on th e transport cost is more 
significant. The overall value can increase in relation to the per centage of annual percentage 
of truck inspections. 
                                                
 
43 Data related to general cargo have to be considered on average of the total. 
 
EN 61   EN Annex C: Evolution of Short Sea Shipping market (Baseline scenario)  
Possible evolution of the maritime transport in the baseline scenario 
In 2006 the market for Short Sea Shipping in the EU accounted for mo re than 1.5 billion 
ton.km. In the baseline scenario, the forecast of  the volume of Short Sea Shipping market can 
be based on the growth rates deri ved from available assessments. 
The annual growth rate of the la st ten-year period, when Shor t Sea Shipping trade grew from 
1,150 million ton.km in 1995 to 1,545 in 2006, reaches +2.7%.The recent ASSESS study44 
outlines for the Short Sea Shipping market a medium-run (2005-2010) growth path equivalent 
to +16%.Such growths correspond to an annual rate of 3.0% from 2005 onward. 
It is assumed that the Short Sea Shipping sector can benef it in the short run from an 
acceleration of its recent growth an d therefore grow in the base-l ine scenario at a higher rate 
than the historical one. In the medium-long run, though, the growth is assumed to get back to 
slightly lower rates. 
The assumed annual growth rates are therefore equal to 3.0% until 2010 and 2.7% until 2020 
and further on. 
As shown in the table below, the Short Sea Ship ping market in the EU would therefore reach, 
in the base-line scenario, some 1.4 bi llion ton.km in 2010 and 1.86 billion in 2020. 
Short Sea Shipping market in EU-27, projectio ns in the base-line scenario (million 
ton.km) 
1,2681,3071,3461,3861,4281,4671,5061,5471,5891,6321,6761,7211,7681,8151,864
2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
 
The projection of this growth to 2040 (which is the time-horiz on considered in the analysis) 
yields a Short Sea Shipping mark et of some 3.17 billion ton.km. 
The market of freight transport by other modes is also assessed in th e base-line scenario. 
For this reason, the trend-line growth accordi ng to the volumes of transport since 2002 is 
considered, which is equal, for road transpor t, to a slowing growth from +3.5% in 2007 to 
                                                 
44 DG TREN, ASSESS – Assessment of the contribution of the TEN and other transport policy measures 
to the midterm implementation of the White Paper on the European Transport Policy for 2010, Brussels 
2005. 
 
EN 62   EN +3.2% in 2020 (when the total road freight market would amount to 2.9 bill ion ton.km), and 
for rail transport to an accelerating growth from +2.3% in 2007 to 2.5% in  2020 (when the rail 
transport of goods would be equal to 612 million ton.km). 
Road and rail freight transp ort in EU-27, the base-line scenario (million ton.km) 
 2.916 
 2.842 
 2.768 
 2.694 
 2.620 
 2.546 
 2.472 
 2.398 
 2.324 
 2.251 
 2.177 
 2.103 
 2.029 
 1.955 
1888 
 612 
 599 
 586 
 573 
 560 
 535 
 522 
 509 
 496 
 484 
 471 
 458 
 445 
435  548 
2020 2019 2018 2017 2016 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006Road
Rail
 
 
The total amount of ton.km comprises some double counting and the counting of non EU 
goods, while in the modal shift assessment only the EU goods share has to be considered. By utilising jointly a bottom up and a top down approach it  has been possible to  assess the share 
of EU goods carried by intra EU lines an d connections. The EU goods share has been 
assessed in 59.9% of the total. 
In the table below the quantification of EU goods (tons) on which the modal shift assessment 
has been carried out is shown. 
EU goods carried in intra EU Short Sea Shippi ng, baseline scenario (000 million ton.km) 
 
-2004006008001.0001.200
2006 2008 2010 2012 2014 2016 2018 2020EU goods carried in intra EU SSS (000 mTkm)
 
 
EN 63   EN Therefore, the total number of ton.km can be assessed as equal to 759,201 million and in 2020 
it will be 1,115,906 million. After the year 2020, a slowdown of growth for all modes has 
been assumed. (1.5% yearly till 2040). 
Considering assumptions on vessels sizes and lo ad factors, the outpu t resulting from the 
database on the number of intra-EU lines and their frequency, it has also been possible to 
estimate the average number of tons transpor ted each year by intra-EU services. Regarding 
bulk traffics some other evidences have been collected, either on the overall number of tons-
kilometre and on the bulk share out of the total Short Sea Shipping traffic. 
Number of tons transported per year in intra EU Short Sea Shipping 
Vessel 
type Avg 
vessel's 
load % embarks/ 
disembark per call LU per 
line conv. factor 
LU / tons tons x 
line tons x 
call n. of line 
loops per 
year 
Ro-Ro 280 0,35 560 13  7.280   2.559  195,1 
Ro-Lo 220 0,24 300 13 /11,28  3.659  881 153,0 
Container 560 0,24 1120 11,28  12.634   2.985  67,2 
Ro-Pax 64 0,49 128 13  1.664   821  415,5 
Bulk  16.000  1 16000 1  16.000   8.000  - 
It is possible to extrapolate the number of  tons carried by Authorised Regular Shipping 
Services on the total and overall  volume of EU goods and non-EU  goods carried each year by 
intra-EU maritime transport. 
Number of tons, divided in ARSS and non ARSS, EU goods and non EU goods share 
Vessel type Tons transported by 
ARSS per year EU goods 
share (%) EU goods carried by 
ARSS per year Non EU goods carried 
by ARSS /year 
Ro-Ro 119.781.397 0,90 107.803.257 11.978.140 
Ro-Lo 13.537.357 0,90 12.183.621 1.353.736 
Container 162.210.774 0,90 145.989.696 16.221.077 
Ro-Pax 31.722.578 0,90 28.550.320 3.172.258 
Bulk - - - - 
Total 327.252.105,4  294.526.894,9 32.725.210,5 
 
 
EN 64   EN  
 Tons transp. by NON 
ARSS services/ year EU goods 
share (%) Non ARSS (EU goods) Non ARSS (non EU 
goods) 
Ro-Ro 73.414.404 0,5 36.707.202 36.707.202 
Ro-Lo 8.297.090 0,5 4.148.545 4.148.545 
Container 99.419.507 0,5 49.709.753 49.709.753 
Ro-Pax 19.442.870 0,5 9.721.435 9.721.435 
Bulk - - - - 
Total 200.573.871,1  100.286.935,5 100.286.935,5 
Finally, considering the overall number of t ons of EU goods and the ones of non-EU goods, 
without considering the service stat us, the following results were found: 
Number of tons per year divided in EU goods and non EU goods tons 
 Overall tons 
transported by intra-
EU services per year EU goods Overall tons Non EU goods Overall 
tons 
Ro-Ro  193.195.801   144.510.459   48.685.342  
Ro-Lo  21.834.446   16.332.166   5.502.280  
Container  261.630.280   195.699.450   65.930.831  
Ro-Pax  51.165.449   38.271.756   12.893.693  
Bulk  800.000.000   400.000.000   400.000.000  
Tot.  1.327.825.977   794.813.830   533.012.146 
 
EN 65   EN Annex D: Main assumptions for the Impact Assessment  
The impact assessment made assumption on the si ze of the vessels, number  of ship calls per 
line and vessels’ load factor, which affect the number of lines operated in the EU market, the 
number of Bills of Ladings (h ereafter B/L), which are fundamental variables in the cost 
benefit analysis, given the tota l traffic in terms of  ton.km. In fact, should the size of the 
vessels and/or the load factor increase/decrease, the number of lines and of B/Ls grows in a 
more/less than proportional way compared to the ton.km foreseen. Similarly, the share of 
Regular lines (Authorised Shipping Services) on the total number of lines is a variable that 
will affect the cost benefit analysis. 
The calculation (for the assessment of the time related cost of FTEs) are based on the number 
of B/Ls (on which controls will be effectiv ely performed), rather than on the number of 
loading units or ton.km. 
Different assumptions have been used for different  types of cargoes. In pa rticular, it has been 
studied the number of lines in the Short S ea Shipping container market and in the Ro-Ro 
market, while for the dry bulk market, because of its nature (tramp), an approach based on the 
number of ton.km (explained later in this doc ument) has been selected. Also the “mixed 
traffic” routes are examined, such as the Ro-Lo segment and the Ro-Pax one. 
A database45 has been set up, containing all the data available on Short Sea Shipping 
connections, in which all the intra-EU lin er maritime connections are shown, both for 
container traffic and for Ro-Ro traffic. 
Further elaborations on that da tabase allowed the assessment of the number of intra-EU lines, 
their average frequency, the aver age number of ports called per line and the overall number of 
line loops per year. Matching the containers co nnections’ data and the Ro-Ro ones it has been 
estimated the share of lines enti rely dedicated and the share of mixed traffic lines. At a later 
stage, with further elaborations  on the data on Ro-Ro lines, we analysed operators and fleets, 
as well as the number of lines used for the tran sport of passengers and private cars (Ro-Pax). 
In this way it is possible to define the differe nt typologies of intra-EU maritime cargo traffics, 
and to set the basis for further considerations on different cargo specif icities (average load 
factors, average number of ports called per line and average liner frequency, conversion 
factors from loading unit s to bill of ladings). 
The assumptions concerning the variables are shown in the table below: 
                                                 
45 Elaboration on European SSS Info data. 
 
EN 66   EN Avg. capacity of intra-EU vessels (per type of cargo) 
 Container Ro-Ro Ro-Lo Ro-pax Bulk 
Vessel size 800 TEU 350 LU 100 LU + 
200 TEU 80 LU 20,000 
tons 
Load Factor of vessels 70% 80% 80% (LU), 
70% (TEU) 80% 80% 
Number of lines in the EU Short Sea 
Shipping market 308 136 39 74 50,00046 
Avg number of port calls per line 4.23 2.84 4.15 2.03 2 
Avg number of B/L's per line per vessel 448 400 170 91 4 
Avg number of line loops per year 67.2 195.1 153.0 415.5 - 
Number of Bills of Lading 9,277,669.5 10, 615,153.9 1,016,094.9 2,811,288.4 200,000.0 
The assumptions made on average vessels’ cap acities and load factors were assessed 
(considered for each type of vessel), validated by the experts and stakeholders interviewed 
during the study47: 
– Average vessels’ capacities (consi dered per each type of vessel); 
– Average vessels’ loads (consider ed per each type of vessel); 
– The share of cargo embarked/disembarked in each port of call within the line 
(considered per each type of vessel); 
– Conversion factors48 from the number of LU49 to the number of B/L; 
– Conversion factors50 from the number of tons  to the number of B/L; 
Estimation of environment benefits  
The review of existing studies  (including the EC Handbook on exte rnal costs) show that the 
2006 ISIC analyses prove to be the most fitting ones to the present extern al cost assessment 
problem:  
– Figures are expressed in terms of Euro/tkm 
                                                 
46 The number of Bulk connections shown in the table (50,000) is not taken into consideration within the 
overall number of intra EU lines, because  it is not part of liner traffic. 
47 Based on our elaborations and data from previous study, interviews to experts and validation of the 
gathered data at the Antwerp meeting April 15th 2008 
48 1.4 LU per B/L in Ro-Ro traffic and 2,5 TEU per B/L in containerised one 
49 Containers and Loading Units 
50 1.4 LU per B/L in Ro-Ro traffic and 2,5 TEU per B/L in containerised one 
 
EN 67   EN – Figures are given also for SSS (recovering a usual lack of th e most part of external 
cost reviews, including the EC Handbook, in  which reference marginal or average 
external costs for seaborne  transport are not given). 
However, the ISIC figures do not reflect the rece nt or on-going decisions, as the proposal for 
Euro VI standards for heavy duty vehicles, which will reduce NOx and particulate matters from 2012 or the IMO decision on low sulphur fuels for maritime transport. The share of 
conventional pollution in the total external cost s (comprising infrastruc ture costs, congestion 
costs, accidents and climate changes costs) is  30% for road and 50% for maritime transport. 
The ISIC figures are shown in the table below. 
Key figures of external costs, Euros/ ton-km 
Key figures (in euro/tonkm) Road Rail SSS 
Air pollution 0,0089 0,0046 0,0056 
Global warming 0,0026 0,0046 0 
Noise 0,0028 0,0009 0 
Accident costs 0,0043 0,0014 0 
Congestion 0,0113 0 0 
Infrastructure 0,0043 0,0037 0,0034 
Source: EC ISIC project (2006) 
 
EN 68   EN Annex E: List of abbreviations  
Acronym Definition
ADN A greement on the carria ge of Dan gerous goods b y inland waterwa ys 
ADR Code A greement on the carria ge of Dan gerous goods b y Road
AIS Automatic Identification S ystem
ARSS Authorised Re gular Shi pping Service
B/L Bill of Ladin g 
CERTeT Centro di Economia Re gionale dei Tras porti e del Turismo (Universita Bocconi )
DG Dan gerous Goods
EDI Electronic Data Interchan ge
EMS Euro pean Maritime S pace
EMSA Euro pean Maritime Safet y Agency
ERT Euro pean Road Trans port
FTE Full Time E quivalen t
GT Gross Tonnes 
HEATCO Harmonised Euro pean A pproach fo rTrans port Costin g
ICT Information and Communications Technolo gy
IMDG Code International Maritime Dan gerous Goods Code
IMO International Maritime Or ganisation
IMO/FAL Convention on the Facilitation of  international maritime traffic 
IRR Internal Rate of Return
ISIC Inte grated Service in the Intermodal Chain
ISSC International Shi p Securit y Certificate
LRIT Lon g Range Identification and Trackin g of shi ps
MoU Memorandum of Understanding 
MRCC Maritime Rescue Coordination Centre
MTCP Maritime Trans port Co-ordination Platfor m
NPV Net Present Value
PDG Packa ged Dan gerous Goods
PEC Pilot Exem ption Certificate
PwC PricewaterhouseCoo pers
RID Re gulation on the carria ge of Dan gerous goods b y rail
Ro/Ro Roll-on Roll-off shi p
Ro-Pax Roll on/Roll off - Passen ger Vessel
SOLAS Convention International Convention for the Safet y of Life at Sea
SSS Short Sea Shi pping
SSN SafeSeaNe t 
VDR Vo yage Data Recorde r
VTS Vessel Traffic Service
 
 
EN 69   EN .