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 and repealing directive 2002/6/EC - Report on impact assessment of different options to simplify/reduce/eliminate administrative procedures for Short Sea Shipping and implementing a European Maritime Transport Space without Barriers {COM(2009) 11 final} {SEC(2009) 47}
Date: 2009-01-21
Institutions: European Commission
Subjects: administrative formalities, customs regulations, harbour installation, report, simplification of formalities, vessel

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COMMISSION OF THE EUROPEAN 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 and repealing directive 2002/6/EC 

Report on impact assessment of different options to simplify/reduce/eliminate 
administrative procedures for Short Sea Shipping 
and implementing a European Maritime Transport Space without Barriers 

{COM(2009) 11 final} 
{SEC(2009) 47} 

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TABLE OF CONTENTS 

1. 

1.1. 

1.2. 

Procedural issues and consultation of interested parties ..............................................8 

Organisation and timing ...............................................................................................8 

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 existing administrative procedures...........................13 

2.1.5.  Comparison with other transport modes.....................................................................17 

2.1.6.  Qualitative considerations ..........................................................................................17 

2.2.  Who is affected? .........................................................................................................17 

2.3. 

2.4. 

3. 

3.1. 

3.2. 

3.3. 

4. 

4.1. 

4.2. 

Foreseen evolution of the problem .............................................................................18 

Right of the EU to act .................................................................................................18 

Objectives ...................................................................................................................18 

General policy objectives ...........................................................................................18 

Specific objectives......................................................................................................19 

Consistency with other policy objectives ...................................................................21 

Policy options .............................................................................................................21 

Policy option A: The do-nothing option.....................................................................21 

Policy option B: The case-by-case approach..............................................................22 

4.2.1. 

“Authorised Regular Shipping Services” Licence linked to companies ....................22 

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4.2.2.  Veterinary and phytosanitary controls........................................................................23 

4.2.3.  Simplification of requirements for 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. 

5. 

5.1. 

5.2. 

Policy option C: 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 .............................................28 

Analysis of impacts ....................................................................................................28 

Policy option A: The do-nothing option.....................................................................28 

Policy option B: The case-by-case approach..............................................................29 

5.2.1.  Economic impacts.......................................................................................................29 

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 ...................................................................................................34 

5.3. 

Policy option C: 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 .............................................35 

5.3.1.  Economic impacts.......................................................................................................36 

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 

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5.3.4.  Administrative costs ...................................................................................................38 

6. 

6.1. 

6.2. 

6.3. 

6.4. 

6.5. 

7. 

Comparing the options................................................................................................40 

Cost and benefits of measures ....................................................................................40 

The main economic, environmental and social impacts of the preferred option........43 

Preferred approach......................................................................................................44 

Impact of the preferred approach on stakeholders......................................................46 

Uncertainties and sensitivity analysis.........................................................................47 

Monitoring and evaluation..........................................................................................50 

Annex A: Administrative procedures applicable to intra-EU maritime transport....................51 

Checks on ship safety certificates.............................................................................................54 

Customs procedures..................................................................................................................54 

Annex B: Comparison of administrative procedures 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 Shipping market (Baseline scenario) ..................................61 

Possible evolution of the maritime transport in the baseline scenario......................................61 

Annex D: Main assumptions for the Impact Assessment .........................................................65 

Annex E: List of abbreviations .................................................................................................68 

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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  related  congestion,  accidents  and  pollution  are  the  main 
economic, social and environmental problems that the policy to promote Short Sea Shipping is expected to 
address.  Europe  needs  an  efficient  co-modal  transport  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 hinder Short Sea Shipping from developing faster. The administrative 
procedures  involved  have  negative  economic  consequences,  in  particular  costs  that  are  associated  with 
administrative  delays,  frequent  or  regular  controls  and  the  time  spent  preparing  documentation  and 
procedures.  This  complexity  also  decreases  the  attractiveness  of  the  mode  and  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 Maritime Transport Space without Barriers, the Commission services have 
assessed  the  main  administrative  and  documentary  procedures  in  Short  Sea  Shipping  with  a  view  to 
simplifying, reducing or, when possible, eliminating them for transport operations between two EU ports. 

In particular, the following procedures were examined: 

•  Customs procedures (including 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. 

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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 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. 

The impact assessment of these options was based on many assumptions made under careful consideration 
of  the  contributions  of  all  stakeholders.  It  showed  with  sufficient  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 received full support from the stakeholders involved, and it is one of the cornerstones of 
the  recent  Communication  on  an  integrated  maritime  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  most  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: 

– 

– 

– 

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Rationalisation  of  vessel-related  and  goods-related  reporting  and  forms  required  by  Directives 
2002/6/EC  (formalities  for  vessels  at  the  arrival/departure  of  ports),  2000/59/EC  (waste  and 
residue reception), 2002/59/EC (vessel monitoring) and Regulation (EC) N° 725/2004 (maritime 
security). 

Elimination  of  systematic  controls  and  documentary  requests  by  Customs  for  goods  carried  by 
sea between EU ports in line with inland transport. 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  and  phytosanitary  products,  guidelines  should  be 
adopted  in  2009  in  order  to  speed  up  the  documentary  checks  in  Directives  89/662/EEC2, 
90/425/EEC3 and 2000/29/EC4. 

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 
Council  Directive  of  11  December  1989  concerning  veterinary  checks  in  intra-Community  trade  with  a  view  to  the 
completion of the Internal Market; OJ L 395 of 30.12.1989, p. 13 
Council  Directive  90/425/EEC  of  26  June  1990  concerning  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 
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. 
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Further enabling measures would also need to be implemented, namely: 

– 

– 

– 

Enhancing the electronic transmission of administrative data; 

Setting-up an administrative single window; 

Simplification of the sea transport of dangerous goods by implementing in the EU Member States 
the  equivalence  between  some  IMDG  (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-ordinated under wider proposals, 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 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”); 

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 dedicated 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 the availability of essential information. 

Information  on  goods  under  Customs  and  other  types  of  supervision  (animal  product,  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  authorities  and  shipping  companies.  The  costs  for  national  administrations 
would be negligible. 

The  approach  would  not  risk  lowering  standards  and  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. 

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1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Organisation and timing 

The  creation  of  the  European  Maritime  Transport  Space  without  barriers  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 insertion in the action plan for an integrated maritime 
policy, prepared terms of reference for the quantification of the impacts of potential options by an external 
consultant,  prepared  the  questionnaire  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 provided assistance in order to: 

– 

– 

– 

– 

– 

Identify the main stakeholders involved and set up contacts in order to discuss potential solutions; 

Develop a first set of draft solutions; 

Analyse the decision processes and possible bottlenecks for implementing potential solutions in 
order to come up with practical, well defined results; 

Substantiate  the  discussion  with  the  stakeholders  by  analysing  and  reporting  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 "European maritime transport space without barriers" until 20 January 2008. A 
questionnaire  was  put  online  on  the  European  Commission  website  in  view  to  gathering  stakeholders' 
views. 

The number of stakeholders that participated in the consultation was 52. 45 stakeholders were from EU 
countries,  4  from  non-EU  European  countries  and  3  from  outside  Europe.  7  contributions  came  from 

5 

Communication  from  the  Commission:  The  EU's  freight  transport  agenda:  Boosting  the  efficiency,  integration  and 
sustainability of freight transport in Europe, COM(2007)606 of 18 October 2007 

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national administrations (of which 3 were national governments, 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  questionnaires  to  selected  port  authorities  and  port  operators.  These 
questionnaires collected information on issues partially covered in the consultation. 

A  reference  stakeholder  group  comprising  twelve  persons  from  industry  and  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  procedures  require  around  one  physical  control  per 
arrival/departure:  according  to  several  stakeholders,  dangerous  goods  procedures  require  more  than  one 
control per arrival/departure. Dangerous goods procedures generate a consistent 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  competitiveness  of  sea  transport  against  road  transport, 
inter alia, due to much more complex administrative procedures. 

They  warmly  welcomed  the  principle  of  the  abolishment  of  administrative  procedures  in  intra-EU 
maritime transport to the same extent that they have been abolished for road transport. 

Some  stakeholders,  notably  those  from  administrations,  pointed  to  possible  negative  impacts  of 
eliminating or reducing administrative procedures. For instance, the ones for Dangerous Goods) should be 
reduced at no risk for human health and the reduction of border controls should not give rise to increased 
security risks, trafficking or smuggling. 

Many  respondents,  however,  call  for  a  simplification  of  administrative  procedures.  For  customs 
procedures however, a share of stakeholders, notably shipowners, proposed their elimination. It was also 
highlighted  that  the  elimination  of  barriers  would  enhance  the  development  of  trade  and  intermodal 
maritime transport. 

The outcomes of the consultation have been used to identify the measures 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 
administrative 
bottlenecks/regulatory  failures  generated  by  existing  administrative  procedures,  clearly  differentiating 

shall  present  more 

thoroughly 

relevant 

the 

all 

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whether  these  flow  from  EU  or  national  legislation.  The  general  and  specific  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 level would be used to implement 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  estimates  have  been  calculated,  and  to  what  extent  stakeholders 
considered  these  time  cost  savings  to  be  the  most  important  benefit  of  this  initiative.  The  report  shall 
clarify  how  the  Standard  Cost  Model  SCM  methodology  has  been  used  when  assessing  changes  in 
administrative burden. 

The IA report assumes (on the basis of  two scenarios)  significant environmental  benefits resulting from 
the  reduction  of  external  costs  (mainly  air  pollution)  due  to  an  expected  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  scenarios,  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  legislation.  The  specific  administrative  failures  have  been  added  in  the  table 
"specific  objective"  (paragraph  3.2.).  The  description  of  each  measure  which  is  part  of  Option  B 
(paragraphs  4.2.1.  to  4.2.9.)  indicates  now  clearly  what  the  available  instruments  are.  An  extended 
description of the methodology used has been added as Annex D. 

2. 

PROBLEM DEFINITION 

The administrative procedures involved in Short Sea Shipping have negative economic consequences, in 
particular  costs  that  are  associated  with  administrative  delays,  frequent  or  regular  controls  and  the  time 
spent  preparing  documentation  and  procedures.  This  complexity  also  decreases  the  attractiveness  of  the 
mode and entails negative environmental and social consequences 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  and  increase  European  competitiveness  and  prosperity. 
The  complexity  of  administrative  procedures  has  been  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 administrations and other stakeholders. 

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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 
Communication from the Commission: Programme for the promotion of Short Sea Shipping, COM(2003) 155 final of 
07.04.2003 
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 

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2.1. 

Underlying drivers of the problem 

2.1.1. 

Internal market in maritime transport is incompletely achieved 

The  achievement  of  an  Internal  Market  for  goods  across  the  European  Union  is  so  far  incomplete  with 
regards  to  sea  transport.  Indeed,  while  the  removal  of  obstacles  to  land  transport  has  finally  become  a 
reality, for sea transport there are still 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,  veterinary  and  phytosanitary  domains,  the  administrative 
procedures  applicable  to  intra-EU  maritime  transport  of  goods  are  comparable  to  those  in  force  for 
international sea transport. 

Maritime  voyages  from  one  port  of  an  EU  Member  State  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  irrespective  of  the  types  of  goods  that  the  vessel  carries.  For  Customs 
purposes, a ship is indeed considered to leave the Customs territory when it leaves a Community port for 
another  Member  State  port,  sailing  through  international  waters.  For  this  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. They range from Customs and taxation 
rules to immigration, trade, statistics, environment, waste, phytosanitary veterinary and health protection, 
security  and  safety  regulations.  These  regulations  are  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  the  exception  of  regular 
direct links between ports, are considered import/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 procedures 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 notifications 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  vessel,  crew  and  goods:  Port  Authorities  (that  is,  Harbourmasters  in  ports), 

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Customs  authorities,  and  Maritime  Rescue  Coordination  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,  ship  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  clearance  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-equivalent 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  (considering  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 

related 

Proc. 
vessels 

to 

Total 

Average 
preparation 

time 

for 

the 

document 

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 
procedures  

time 

for  carrying  out 

the 

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 
procedures 

time 

for  carrying  out 

the 

2.0-2.5 

1.5-2.0 

2.5-3.0 

According  to  the  assumption  on  personnel  costs,  the  average  personnel  cost  related  to  all  the 
administrative procedures could be fixed at around € 288 per port call. 

The total costs related to personnel costs 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 containers, 7 to 10 days for general cargo, and two weeks 

9 

All  figure  have  been  carried  out  according  to  consultation  outcome,  data  gathered  from  specific  quantitative 
questionnaires and bottom up analysis. 

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12 

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for  bulk  products.  In  intra-EU  SSS,  where  journeys  last  on  average  less  than  a  week  (often  less  than  a 
day),  a  delay  longer  than  the  journey  time  has  a  tremendous  weight  on  the  overall  attractiveness  of  the 
maritime alternative to road transport. 

2.1.4.  Main bottlenecks generated by existing administrative procedures 

The main failures derive from customs, as well as veterinary, zootechnical, phytosanitary 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.  Administrative  procedures  should  be 
transport mode neutral. These failures clearly result from EU legislations. 

In addition, consultations have highlighted other failures resulting either fully from EU legislation or lack 
of legislation (transport of dangerous goods, authorised regular shipping services, single windows, use of a 
second language) or partially (lack of interoperability of electronic data transmission, pilotage exemption 
certificates, joined inspections) or fully from national or local conditions (separation of areas in ports). 

The specific administrative failures have been added in the table "specific objective" (paragraph 3.2.). 

For  four  measures  suggested  by  stakeholders  during  the  consultation,  a  recommendation  is  the  only 
instrument which was envisaged, because they relies on local condition and a general measure would only 
be  envisaged  after  a  more  detailed  analysis  of  these  local  conditions,  which  was  not  the  purpose  of  our 
study. It is the case for the separation of areas in ports. 

The following table indicates what the available instruments are. 

EN 

13 

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List of the main measures for the reduction of administrative 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  

Veterinary, phytosanitary procedures and controls on animal foods 
products are systematic for non-regular intra-EU sea transport, which 
induce a distortion with equivalent land 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) 

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. 

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 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. 

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 

Free circulation within the EU ports 

Levelling with road transport 

The License should not be connected to 
one or more vessels/routes, 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 management flexibility for 
shipping companies.  

(only for customs formalities) 

Sea transport of dangerous goods requires 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. 

SSS would become a more attractive 
transport mode; lower costs. 

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 

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 

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competitiveness against road transport 

procedures applicable to intra-EU SSS 

would be used for all the procedures. 

(less counterparts in ports) 

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. 

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 manifest; 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 

Faster and more rational administrative 
operations. Lower administrative costs for 
Shipmaster. 

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. 

Separation of areas in ports 

To dedicate and physically separate areas 
exclusively for vessels performing SSS. 

To speed up loading/unloading and waiting 
times of vessels in ports. 

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.  

EN 

15 

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Not all MS recognize electronic manifest; 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 

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, making 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. 

Not all countries grant PECs to sea-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. 

Lower costs for SSS operators, speeding up 
port operations 

The use of national languages slows down compliance with 
administrative formalities. 

Use of English as official administrative 
language 

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. 

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. 

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2.1.5.  Comparison with other transport modes 

Short Sea Shipping competes with road and rail transport on certain door-to-door corridors (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 shippers 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  administrative  procedures  in  Short  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 road 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 needs a set of road transport documents that are 
then duplicated in another format for the maritime leg.  

A sample comparison between administrative procedures for short sea and 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 carries hundreds of loading units while a normal road-
train only two. However, streamlining and simplification of administrative and documentary 
procedures in multimodal transport operations should have a positive effect on the reputation 
of Short Sea Shipping and lower transport costs in logistics chains involving a sea leg. 

2.2.  Who is affected? 

Everyone  is  affected  by  these  issues.  Road  transport  results  in  congestion,  accidents,  noise 
and  environmental  pollution  that  affect  the  citizens  and  industry.  Building  land-based 
infrastructure  also  needs  careful  land-use  planning.  The  short-sea  cluster  is  an  important 
source of employment. These concerns are 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  cannot  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 

17 

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– 

– 

– 

– 

– 

– 

– 

Port Authorities 

Customs 

Maritime lines 

Ship Agents 

Maritime Authorities 

Forwarders 

Citizens. 

2.3. 

Foreseen evolution of the problem 

Things remaining equal, without further measures, Short Sea Shipping would not be able to 
fully  respond  to  the  challenges  of  the  mid-term  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  core  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 always produce interoperable transport 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  working  with  the  Member  States  and  industry 
towards a coherent framework covering the whole of Europe. 

Most  of  the  measures  impeding  the  smooth  functioning  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 fundamental rights are fully respected. 

3. 

OBJECTIVES 

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  transport  modes  in  order  to  diminish  the 
unsustainable trends indicated above. European competitiveness and prosperity need 
to  be  maintained  and  increased,  and  Short  Sea  Shipping  is  an  essential  part  of  this 
process. Furthermore, Short Sea Shipping enhances cohesion and links to peripheral 
areas and islands 

EN 

18 

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– 

– 

To  ensure  that  duplicated  or  obsolete  reporting  requirements  are  removed  and  to 
facilitate  the  free  circulation  of  maritime  transport  between  EU  ports  by 
simplifying/reducing/eliminating  administrative  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 

19 

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Specific / operational objectives 

Corresponding measures and instruments 

Consistency with EU policies 

Specific and operational objectives 

To  facilitate  Intra-EU  maritime  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. 

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. 

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. 

To  integrate  the  information  flow  between  different 
parties  of  different  countries  and  elimination  of 
physical  presence  of  authorities  (data  and  information 
network) 

To  facilitate  maritime  transport  by  providing  for 
and 
of 
standardisation 
computerisation of monitoring system 

formalities 

reporting 

Elimination  of  Customs  formalities  for  intra-EU  sea 
transport of EU, EU cleared and goods in transit goods 

Mid  Term  review  of  the  European  Commission’s 
2001 Transport White Paper10 

Elimination  of  veterinary,  phytosanitary, 
systematic formalities for intra-EU maritime transport 

sanitary 

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 

License  “Regular  liner  service”  to  be  connected  with 
operators  (not  with  vessels)  and  to  be  granted  to  non 
regular liner services intra EU cargoes 

Simplified  Customs  Procedures  in  Short  Sea 
Shipping: “Authorised Regular Shipping Service”, 
SEC(2004) 333 

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. 

Enhanced electronic data transmission and administrative 
single window in ports 

Council  Conclusions  concerning 
Strategy of 12 February 2007 

the  Lisbon 

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 

EN 

Commission  Communication:  “Keep  Europe  moving  –  Sustainable  mobility  for  our  continent  –  Mid-term  review  of  the  European  Commission’s  2001  Transport 
White paper” (COM (2006)314 final of 22 June 2006). 

20 

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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  preserving  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,  competitiveness,  sustainability,  safety,  bypassing 
land bottlenecks). 

The establishment of a European Maritime Transport Space without Barriers is an important 
element in "An Integrated Maritime Policy for 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  will  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  Short  Sea  Shipping  would 
generally be in line with the Community transport and environmental policies. 

4. 

POLICY 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 and 2.7% further on from 2006, where intra-EU 
Short Sea Shipping market accounted for 1.5 billion ton.km. The evolution 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  between  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  transport  compared  with  the  other  modes  must  be  eliminated  through  the 
simplification of administrative and customs formalities for intra-EU maritime services." 

EN 

21 

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European  competitiveness  could  suffer  in  light  of  the  limited  infrastructure  resources 
available, if all the modes would not play their full role in co-modality. Competitiveness of 
Short Sea Shipping would decrease, because promotion would not advance and simplification 
would  not  take  place.  Administrative  and  documentary  obstacles  to  developing  the  mode 
would  lead  to  higher  operating  costs  and,  ultimately,  to  higher  transport  prices  for  the 
customer. Delays could increase owing to growing traffic volumes. European shipyards could 
suffer because the growth of Short Sea Shipping would not be optimal. New technological or 
logistics solutions might not be created for the 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 (congestion, accidents and noise). 

Short  Sea  Shipping  is  energy-efficient,  and  produces  less  CO2  per  tonne-kilometre  and  has 
lower  effect  on  global  warming  than  other  modes.  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  decrease.  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 consultation have been 
contemplated,  which  have  a  potential  for  reducing  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  levels,  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 considered at this point in 
time. 

4.2.1.  “Authorised Regular Shipping Services” Licence linked to companies 

The  Community  Customs  Code  allows  the  simplification  of  certain  customs  procedures,  in 
the case of those vessels performing 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  requested  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 

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individual  vessels  as  is  now  required  in  the  existing  regulations.  Operators  need  more 
flexibility in managing their fleet. The licence certifies the quality 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 authorities, with the name of 
the new vessel. The authorisation certificate has 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 phytosanitary controls 

Directives 90/425/EEC, 89/662/EEC and 2000/29 allow certain veterinary and phytosanitary 
controls in ports to be exempted from import / export procedures. These concern the transport 
of products on direct and regular shipping links. 

However,  products  transported  via  a  third  EU  port  or  on  non-regular  shipping  links  are 
subject  to  import  and  export  procedures  even  though  their  origin  is  in  another  EU  Member 
State and the products have not visited a third country on the way. 

In  order  to  streamline  the  procedures,  all  transport  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 for 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  transport  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  provisions  set  out  in  the  ADR  are  exempt  from 
domestic requirements. 

Regulations  on  dangerous/hazardous/polluting  goods  are  different  in  sea  transport  and  land 
road  transport,  representing  a  clear  bottleneck.  The  IMDG  Code  and  Directive  2002/59/EC 
contain specific provisions for the carriage of dangerous/polluting goods at sea entailing early 
advance notifications and declarations. 

13 

14 

15 

16 

Agreement concerning the International 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  Member  States  with  regard  to  the  transport  of  dangerous  goods  by 
road. 
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 international 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. 
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 
International Maritime Dangerous Goods (IMDG) Code adopted in 1960 by the International Maritime 
Organisation. 

EN 

23 

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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 dangerous goods that can be carried); 

In case of IMDG, any quantity of goods which 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 exception of a transport document), if certain 
limits are not reached. On the contrary, for sea transport any quantity of dangerous 
goods must be declared according to the provisions 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  required  for  dangerous 
goods in limited quantities. However, the packaging 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 repeatedly, 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  IMDG  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 transport and sea transport of dangerous goods. 

For the above reasons the transport of some dangerous 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 measure would be that certain parts of the RID and ADR rules would be 
accepted for shipping services. This would eliminate 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,  stowage  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  vessels  would  be  permitted  in  line  with  the 

EN 

24 

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ADR  Agreement.  In  addition,  the  UN  packaging  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 monitoring systems are currently already 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 “single 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 lead to a single transmission of data from 
ship to shore and help avoiding several transmissions 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  organising  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 may also empower other authorities to carry out 
their  specific  controls.  In  this  way  delays  can  be  reduced  and  vessels’  turnaround  times 
improved.  Member  States  should  encourage  administrations  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  Single  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  interface  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 efficient Single Window which will not be an addition layer, but will replace 
existing  administrative  interface,  the  general  obligation  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  distance  maritime  trade  as  well  as  it  will  facilitate 
administrative formalities for maritime transport including both intra-EU goods and non-EU goods. 

EN 

25 

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inspections  jointly,  in  order  to  reduce  the  economic  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 administrative procedures 
and  the  time  reduction  in  carrying  out  the  formalities  for  ships  and  cargoes.  Moreover,  a 
framework  would  be  established,  in  which  transport  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  for  ships  arriving  in  and/or  departing  from 
ports18 requires EU Member States to accept a uniform 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 simplify 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 vessel-related information 
to  be  submitted.  This  information  is  often  repetitive  but  has  to  be  submitted  separately  for 
each  procedure.  Rationalisation  could  be  foreseen  in  the  context  of  Directive  2002/6/EC  in 
order to streamline and clarify the application of the requirements of Directives 2000/59/EC19 
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.  These  services  are  not  free,  and  their  costs  are 
charged upon ship operators. Pilot Exemption Certificates 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 

19 

20 

21 

22 

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 
Directive  2000/59/EC  of  the  European  Parliament  and  of  the  Council  of  27  November  2000  on  port 
reception facilities for ship-generated waste and cargo residues OJ L 332 of 28.12.2000, p. 81 
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 
Regulation  (EC)  No  725/2004  of  the  European  Parliament  and  of  the  Council  of  31  March  2004  on 
enhancing ship and port facility security OJ L 129 of 29.4.2004, p. 6 
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 

26 

   EN 

 
                                                 
Shipping  services  frequently  calling  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  operators  and  faster  turnaround  times  of  vessels  in  ports.  The 
actions  required  for  the  implementation  of  this  proposal  would  need  to  be  taken  at  national 
levels and coordinated among national authorities. 

Pilot Exemption Certificates or corresponding arrangements 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 administrative 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 
seafarers23  stipulates  that,  if  there  is  no  common  languages,  communication  between  ships 
and  shore  can  be  conducted  in  a  common  language  with  reference  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  alternative  language  for  all  administrative  maritime 
documents  and  procedures,  for  sea-shore  communications  as  well  as  administration-to-
administration communications. In practical terms, 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  would  be  allowed  to  be  carried  out  in  this 
second language. 

4.2.9. 

Separation of areas in ports 

Another measure for consideration could be the physical separation in ports of areas reserved 
to Short Sea Shipping (in particular for container 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 administrative procedures. The benefit 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 and (in some cases) high infrastructure costs, 
but there are also several benefits that could be considered, in particular: 

– 

– 

– 

23 

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. 

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 

27 

   EN 

 
                                                 
– 

4.3. 

This option might not be suitable for all ports but could be considered when deciding 
on land use in ports where such a solution could be feasible. 

Policy option C: 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 

This option builds upon the measures presented in option B and foresees their implementation 
as  a  consolidated  package  while  adding  further  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. Documents shall only be in the vehicle for possible spot 
checks. 

The  elimination  of  systematic  administrative  procedures  would  not  lead  to  the  full 
abolishment of transport documents. However, controls should not be systematic but be based 
on random checks (risk analysis) as far as feasible. 

A  further  simplification  could  be  for  ships  operating  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 vessel itself of the goods (products) carried onboard. This measure 
has been frequently called upon by the stakeholders. 

One could also think of eliminating all procedures on Community goods and products carried 
on any vessel between two EU ports. This would achieve a real 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  locally,  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 Authorised Regular Shipping Services. On the other 
hand,  new  requirements  for  instance,  for  food  security,  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 the 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 feedering in Short Sea Shipping, 
as well as the mandatory introduction of tracing and tracking systems and the need to improve 

EN 

28 

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shipping  environment  performances,  the  European  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  Internal  Market  benefits  in  Short  Sea 
Shipping is a political goal that has a considerable 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). Consequently, the expectations are high. 

Apart  from  expectations,  any  simplification  can,  from  the  outset,  be  considered  positive  in 
decreasing  administrative  burden  of  businesses  in  the  EU.  The  positive  impacts  of  such 
simplification  can  only  be  overturn,  if  negative  economic,  environmental  or  social 
consequences emerge to a degree that is not sustainable. This does not seem to be the case for 
the European Maritime Transport Space without Barriers. 

For the purpose of the impact assessment study, 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 higher 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 refers to the total number of answers 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 

29 

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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% 

Formalities on VESSELS 

40% 

48% 

3% 

0% 

1% 

1% 

Dangerous Goods 

5% 

55%  14% 

0% 

0% 

0% 

Phytosanitary 

2.5% 

32% 

5% 

0% 

5% 

5% 

Animal origin 

2.5% 

18% 

5% 

0% 

0% 

5% 

Weighted average delay 

1.42 

0.8 

0.95 

3.45 

2.5 

1,48 

Source: PwC elaboration on Consultation data (2008) 

The Table above shows that delays on goods are higher than delays on vessels. 

0.52 

0.56 

0.55 

0.32 

0.18 

0.47 

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 the delays on goods caused by the formalities. 

The  cost  decrease  has  been  calculated  taking  into  account  the  time  costs  arising  from  the 
application of intrinsic values of time to specific goods. Time costs are an implicit factor of 
the generalised transport cost function, although not directly perceived as a monetary expense 
by the stakeholder demanding a transport service (e.g., the shipper), or affected by a delay in 
the door-to-door transport chain (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: 

– 

– 

24 

Inventory costs corresponding to the traditional notion of immobilization of an asset, 
as typically used in any company’s accounting procedures when estimating the costs 
of  storage  and  warehousing.  While  the  goods  are  being  transported,  they  do  not 
generate any added value, and therefore generate a financial cost to its owner, which 
is usually estimated on the basis of standard rates. 

Loss of value related to the delay with which the consignment reaches its destination, 
as a deviation factor for the user in planning its activity; 

See RECORDIT – Deliverable 1, (2001), and TRANSTOOLS Deliverable 2, (2005). 

EN 

30 

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– 

Spoilage  costs,  defined  as  the  loss  of  value  resulting  from  a  deterioration  of  the 
quality and usability of the goods as a consequence of the delay. 

The  HEATCO25  deliverables  incorporate  those  factors  when  deriving  standard  EU-27 
reference  figures.  Thus  those  figures  can  be  applied  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 reduction 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  procedures  (both  customs  and  administrative).  It  is  very 
unlikely that a vessel is subject 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  calculate  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-related costs of ships, an average hourly cost of rent of a ship 
has been considered. 

In terms of cost saved in relation to the reduction 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 statistical data and information, potential impact of administrative 
facilitation  on  fraud  pattern  cannot  be  quantified.  Main  types  of  frauds  would  be  a  wrong 
declaration of the product origin (including smuggling); 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 barriers 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  seas  has  been  indicated  as  a  potential  risk. 
However modern port communication systems, in association with other 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 

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31 

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5.2.2.  Environmental impacts26 

The external costs of the different transport modes have been taken from the 2004 ISIC study. 
They do not reflect the recent or pipeline 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  costs  (comprising  infrastructure  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  this,  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 anticipated here by stating that the 
implementation of the group of measures in cluster 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  external  benefits  for  each  Option:  the  values 
obtained represent the environmental benefits 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 Euros 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  Sea  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 

32 

   EN 

 
                                                 
5.2.3. 

Social impacts 

5.2.3.1.  Impacts on safety and security 

Safety  and  security  regulations  have  been  significantly  developed  in  the  past  few  years 
“aspects”. The main actions could be summarised as follows: 

– 

– 

– 

creation of EMSA (European Maritime Safety Agency) to ensure high, uniform and 
effective  levels  of  maritime  safety  and  prevention  of  pollution  by  ships  in  the 
Community. 

the development of several security provisions in particular: 

– 

– 

– 

Regulation (EC) N° 725/2004 on enhancing ship and port facility security with 
the aim to introduce and implement 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  extension  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, improving the response of authorities at sea27. 

Simplifications or relaxations of current legislative solutions already in place do not involve a 
radical  change  of  procedures  of  interface  between  the  various  entities  in  port,  but  could 
increase dangerous or hazardous situations. However, the electronic data transmission of data 
will  allow  different  authorities  in  ports  (mainly  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 estimate a specific figure illustrating the impact of 
modern  port  communication  systems  and  other  surveillance  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  purpose  of  the  impact  assessment,  all  the  safety 
and security costs are considered 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  reorganised,  to  cope  with  modernisation  challenges  (e-Customs),  an 
extension of their missions and the growth in world trade induced by the globalisation. The 
European  Maritime  Transport  Space  without  Barriers  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 intra-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 

33 

   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  costs.  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 requiring 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  transversal  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  FTE28s  for  each  MS  and  5 
FTEs for the EU, supporting and coordinating the activities. In this case, the work programme 
requires  an  average  duration  of  3  years.  The  consequent  global  financial  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 training amounts to €1000. The 
financial effort for this training phase is assumed to amount to about €11 million. Finally, it is 
necessary to consider the creation or the strengthening 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 effort 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 legislative 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 central customs and for local port operators needs 
to be taken into account. The financial effort in this training phase is assumed to be less than € 
1 million. Finally, it is necessary to set up structures 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  analysed  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  electronic  data  interchange  system  has  been  obtained  via  the 
elaboration  of  relevant  information  gathered  from  various  similar  projects.  Design  and 
development costs have been differentiated between Member States. It has been considered, 
for each MS, a qualitative level of IT friendliness of countries, depending on the existence of 
e-information  projects  (planned  or  operational),  current  operating  systems  that  allow 
paperless administrative procedures. 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 

34 

   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  for  language  training  also  depend  on  the  total 
number of ports in countries and on the average number 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 course programme cost of 1000 €. On the basis of 
what has been assumed, it can be inferred that this measure requires a financial effort of about 
€ 5 million. 

Separation of areas in port - A qualitative analysis has been developed through interviews. 
The reaction to this measure raised controversial feedbacks from the contacted stakeholders. 
Answers  ranged  from  "not  feasible"  to  "already  implemented",  according  to  the  layout  and 
availability  of  free  areas  at  terminals.  Furthermore,  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 the 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 personnel 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 Shipping Service is extended also to the vessels calling at one or 
more  non-EU  ports,  namely  “infected  vessels”.  With  the  extension  of  this  status,  in  fact,  it 
will  be  possible  to  separate  EU  goods  from  non-EU  goods  and  transit  declarations.  In  this 
way,  when  a  vessel  calls  at  an  EU  port,  EU  goods,  maintaining  their  Community  status, 
would  not  need  any  customs  procedure  and  could  be  disembarked  without  any  other 
administrative formality. Non-EU goods, instead, would 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,  eliminating  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  further  simplification  to  them  by  considering  the 
elimination of some procedures. 

EN 

35 

   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 delays on goods caused by the formalities. 

In terms of costs saved in relation to the reduction of time spent on procedures in relation to 
goods,  the  advantages  of  eliminating  all  administrative  procedures  including  Customs  and 
other procedures could be estimated at the region 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 distinguish the administrative procedures 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 operators allow different authorities in ports 
(mainly customs agencies) to set and organise controls and inspections activities focused on 
the “higher risk situation” following 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  administrative).  Delays  caused 
by activities connected with administrative procedures are not 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  calculate  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-related costs of ships, an average hourly cost of rent of a ship 
has been considered. 

In terms of cost saved in relation to the reduction 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 paragraph 5.2.1.3. is applicable to Option C. 

5.3.2.  Environmental impacts29 

By  improving  the  internal  efficiency  of  Short Sea  Shipping,  the  elimination  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 

36 

   EN 

 
                                                 
which  will  induce  a  global  reduction  of  the  external  costs.  In  order  to  assess  the  positive 
impact in terms of reduction of external costs, 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 robustness of the analysis. In 
fact,  the  comparison  between  the  “Low”  and  “High”  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 which point out a percentage of modal shift to 
Short Sea Shipping in presence of specific policies 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 European 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 Shipping of EU goods will account for 
1,115,906 million ton.km, considering the additional modal shift it results that: 

– 

– 

In  the  Low  Scenario  the  Short  Sea  Shipping  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 additional 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 much higher such new route is. The detour factor 
assumed in this project is the deriving average of 19%. Moreover, from the same studies an 
average share of road vs. rail modal shift respectively 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: 

– 

– 

EN 

In  the  Low  Scenario,  the  amount  of  transport  shifted  from  road  and  rail  in  2020  is 
905 million ton.km (618 million ton.km from road, 287 million ton.km from rail); 

In  the  High  Scenario,  the  amount  of  transport  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). 

37 

   EN 

 
The  savings  results  from  the  difference  of  externals  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 congestion and infrastructure costs. The benefits 
for the two low and high scenarios are broken down as shown in the following table in year 
2020. 

Environmental benefits per scenario in 2020 (million Euro) Source: PwC and Bocconi 
(2008) 

16,0

14,0

12,0

10,0

8,0

6,0

4,0

2,0

-

Air pollution

Global w arming

Noise

Accident costs

Congestion

Infrastructure

Low EMS

High EMS

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  environment  is  considered  to  be  a  proportion  of  these 
external costs. 

5.3.3. 

Social impacts 

The qualitative assessment in paragraph 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 inspections schemes. A start-up phase for designing 
and  training  will  be  necessary.  Change  in  procedures  follows  the  same  logic  in  terms  of 
development and implementation as the use of electric 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  substantially  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  order  to  obtain  consistent  economic  savings.  Policy  Option  C 
combined with Option B start-up costs are estimated at € 118.62 million) and ongoing costs 

EN 

38 

   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 

39 

   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,  considerable  benefits  can  be  obtained  at  the 
community level. Though, if only internal benefits are considered (i.e. the benefits related to 
the operation of Short Sea Shipping as such), the comparison proves to be tighter. 

The measures concerning a single window and electronic 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 and 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 

40 

   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 

B 

Investment + training costs 

Operational costs 

C = A+B 

TOTAL COSTS 

D 

E 

F 

Personnel cost savings 

Ship cost savings 

Time cost savings 

45.7 

224.2 

269.9 

11.7 

0.17 

261.6 

G = D+E+F  TOTAL INTERNAL BENEFITS 

273.5 

H 

External benefits 

37.4 

I = G+H-C  TOTAL NET PRESENT VALUE 

40.9 

IRR 

(H+G) / C 

B/C RATIO 

8.9% 

1.125 

45.7 

224.2 

269.9 

11.7 

0.17 

261.6 

273.5 

74.8 

78.46 

68.0 

391.7 

459.7 

232.7 

25.9 

68.0 

391.7 

459.7 

234.7 

25.9 

107.3 

510.2 

617.5 

244.4 

26.0 

107.3 

510.2 

617.5 

244.4 

26.0 

1917.9 

1919.0 

2171.6 

2173.1 

2176.5 

2179.6 

2442.1 

2443.6 

145.3 

290.5 

182.7 

365.3 

1862.0 

2010.3 

2007.2 

2191.4 

12.0% 

61.3% 

62.5% 

60.7% 

61.9% 

1.29  

5.05 

5.37 

4.25 

4.55 

EN 

41 

EN 

 
  
 
 
 
G / C 

INTERNAL BENEFIT / COST 
RATIO 

1.01  

1.01 

4.73 

4.73 

3.95 

3.95 

EN 

42 

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  concerned.  In  particular,  the  development  and 
maintenance of Information and Communications 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  compared  to  the  remaining  categories  of 
benefits,  and  including  “external”  ones.  It  demonstrates  that  the  largest  share  of 
benefits  is  widespread  over  a  large  panel  of  stakeholders  (forwarders,  logistics 
operators,  shippers/consignees,  industries,  etc.)  that  have  their  primary  interest  in 
receiving goods in a shorter time, and with a lower probability 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 savings will beneficiate to the administration 
(around  20%)  and  the  private  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 increase the benefits of the measure. 

6.2. 

The main economic, environmental and social impacts of the preferred option 

The  preferred  action  will  implement  administrative  simplification  in  view  to  induce  a 
transport modal shift reducing congestion, infrastructure, safety and various pollution costs. It 
will bring the following benefits. 

Impact on: 

Detailed description 

Indicators 

Effect 

Higher  efficiency 
and  reduction  of 
total 
transport 
costs 

Reduction  of  personnel  costs: 
reduction  or 
standardisation  of  procedures  could  generate  the 
savings in terms of FTE 

Economic 

Higher efficiency 

Reduction  of  personnel  costs: 
reduction  or 
standardisation  of  procedures  could  generate  the 
savings in terms of equivalent FTE 

Benefit 

Benefit 

Full  time  equivalent 
involved  in  carrying 
out 
administrative 
procedures 

Average 
delay 
(hours)  in  door-to-
of 
door 
goods 

arrival 

Macro-
category 

Economic 

EN 

43 

   EN 

 
Economic/ 

Environmental 

Competitiveness 
of 
industry 

shipping 

Cost  decrease  for  time  reduction  of  ship  calls 
(minimal):  Reduction  of  potential  delay  in  port 
because  of 
the  elimination/simplification  of 
administrative procedures. 

Benefit 

Benefit 

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 
time: 
frequencies can be increased (qualitative) 

sailing 

shipping 

Economic 

Competitiveness 
shipping 
of 
industry 
and 
relative increase of 
total 
transport 
costs 

Administrative  costs:  short-term 
increase  of 
administrative  costs,  due  to  the  harmonisation  of 
procedures  and 
the 
standardisation 
organisational 
programme;  Long-run  decrease  of  administrative 
costs. 

the  management  of 

stage  of 

the 

to 

Environmental  Modal shift 

Reduction of external costs caused by modal shift: 

Modal  shift  (Environmental  effect):  modal  shift 
determines lower emissions of pollutants (shipping 
is 
road/rail 
transport); 

environmentally 

friendlier 

than 

All 
administrative 
costs  (no  personnel 
cost) 

Benefit 

Benefit 

Emissions,  Global 
warming, 
Noise, 
Congestion, 
Accident 
Infrastructure, 
Vehicle costs 

costs, 

Modal  shift  and  additional  costs  of  transport. 
Linked  to  the  last  part  of  the  voyage  by  road/rail. 
Maritime 
the  overall 
transport of goods. The last part needs to be carried 
out with another mode of transport 

transport  cannot  cover 

6.3. 

Preferred approach 

Individual  measures  present  clear  benefits  and  their  combination  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  administrative  costs,  while  other  imply  investment  in 
technology and training and shall be encompassed in a wider consistent approach and other 
depends much on local and technical conditions, their modalities shall be differentiated. 

The preferred approach is Options C which builds upon the measures 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  documentary  requests  for  Internal  Market 
maritime  transport  and  associated  carriage  of  goods  or  products  in  line  with  inland 
transport.  Information  on  goods  under  Customs  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 transmission of data at the arrival or departure 
of vessels at ports relate to: 

EN 

44 

   EN 

 
 
– 

Entry  and  departure  notification  (Directive  2002/59/EC  and  Directive 
2002/6/EC) including the Maritime Declaration of Health; 

–  Waste management formalities (Directive 2000/59/EC); 

– 

– 

– 

– 

– 

– 

– 

Security notification prior to entry into ports (Regulation (EC) N° 725/2004); 

Port state control of shipping (Directive 95/21/EC); 

Dangerous goods procedure (Directive 2002/59/EC); 

Customs Declaration (Regulation (EEC) N° 2913/9230); 

Veterinary checks on products of animal 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  the  "Authorised  Regular  Shipping  Service" 
facilitation to operators on authorised routes 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 could be recommended in today's situation. 

Rationalisation  of  vessel-related  and  goods-related  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 various transport modes, it is envisaged at a 
later stage. 

These proposals would be implemented under wider proposals, which will be included in the 
action plan for the deployment of e-maritime systems in 2009. 

In  addition,  the  recommendations  should  be  given  that  Member  States  implement  further 
enabling  measures,  each  time  the  local  conditions  permit  to  do  it  in  an  efficient  manner, 
namely: 

– 

30 

EN 

Coordinate  the  inspections  carried  out  in  the  ports  by  the  various  administrative 
services (“one-stop administrative shop”); 

Council Regulation (EEC) N° 2913 of 12 October 1992 establishing the Community Customs Code 

45 

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– 

– 

– 

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  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  instruments  based  on  an  evaluation  to  be  undertaken 
within three years. 

This combination and co-ordinated implementation 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  reduction  of  administrative  burden,  the  approach  does  not  risk 
fundamental objective of lowering standards. It would give legal certainty regarding guidance 
and help lowering the costs to businesses in several Member and, subsequently, to consumers. 
It should be stressed that the available evidence indicates that standards would not be lowered 
and  that  therefore  these  estimated  cost  savings  are  not  offset  by  other,  negative  impacts 
elsewhere. 

6.4. 

Impact of the preferred approach on stakeholders 

The  preferred  option  leading  to  the  elimination  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 development of the project at port level 
and  on  going  costs  related  to  updating  running  and  controlling  of 
programmes  activated);  increase  of  administrative  costs  resulting  from  the 
development of the new programme; 

Benefits: increase in labour productivity and reduction of time for each call 
(controls of physical documents no longer performed). 

Customs 

Costs: Administrative costs (mainly for developing the project at port level 
and  on  going  costs  related  to  updating  running  and  controlling  of 

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46 

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programmes activated) should be compensated by benefits;  

Benefits: increase in labour productivity  and consequent reduction of time 
for each call (controls of physical documents no longer performed). 

Costs:  increase  of  technology  costs  for  the  alignment  of  harbour 
communication  and  single  window 
for 
computerisation of procedures; 

in  costs 

Increase 

tools. 

Maritime lines 

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 labour productivity, as a consequence of reduction of 
time  spent  preparing  different  documents  and  carrying  out  administrative 
procedures). 

Forwarder 

Citizens 

Benefits:  reduction  of  costs  in  relation  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. 

Benefits: reduction of costs for the transport of goods and potential 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 the '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  services”,  has  been 
chosen for a sensitivity analysis. 

The goal was to find the switching value 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 simplified procedures are assumed to carry a 90% 
average of EU goods. The sensitivity analysis showed that the switching value is reached at 
68%.  According  to  the  sources  scanned  and  the  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 doing procedures. The modal shift 
induced by the reduction of administrative procedures may thus be underestimated. 

EN 

47 

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Two scenarios of modal shift (low and high) have been used to ensure the robustness of the 
analysis.  The  expected  effect  that  a  significant  reduction  of  administrative  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  shippers  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 term 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  afterwards  they  are  lower  and  constant,  whereas 
benefits  are  only  registered  after  the  implementation  and  would  grow  in  time  –  so  that  the 
shorter  the  time  horizon,  the  lower  the  possibility  that  they  compensate  for  the 
implementation costs. 

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48 

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Cost Benefit Analysis: Monetised costs and benefits vs. baseline scenario (M € -  Net Present Value - time horizon 2009-2020) 

POLICY OPTION B1 

POLICY OPTION B2 

POLICY OPTION C 

Impact  

LOW 

HIGH 

Rif 

A 

B 

Investment + training costs 

Operational costs 

C = A+B 

TOTAL COSTS 

D 

E 

F 

G = 
D+E+F 

H 

Personnel cost savings 

Ship cost savings 

Time cost savings 

TOTAL INTERNAL BENEFITS 

EXTERNAL BENEFITS (external 
costs saved by modal shift) 

45.7 

98.2 

143.8 

5.0 

0.07 

111.1 

116.2 

9.8 

I = G+H-C  TOTAL NET PRESENT VALUE 

-17.9 

(NPV) 

IRR 

(H+G) / C  B/C RATIO 

G / C 

INTERNAL BENEFIT / COST 
RATIO 

-3.6% 

0.88 

0.81 

45.7 

98.2 

143.8 

5.0 

0.07 

111.1 

116.2 

19.5 

-8.1 

1.0% 

0.94 

0.81 

LOW 

68.0 

158.3 

226.3 

82.0 

9.2 

678.9 

770.1 

34.7 

578.5 

HIGH 

68.0 

158.3 

226.3 

82.4 

9.2 

679.2 

770.7 

69.4 

613.8 

LOW 

107.3 

213.7 

321.0 

87.0 

9.2 

813.5 

909.7 

44.5 

633.2 

HIGH 

107.3 

213.7 

321.0 

87.0 

9.2 

813.9 

910.1 

88.9 

678.0 

60.3% 

61.5% 

59.8% 

61.1% 

3.56 

3.40 

3.71 

3.41 

2.97 

2.83 

3.11 

2.84 

Source: PwC and CERTeT elaboration (2008) 

EN 

49 

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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 total transport volume in the Internal Market. 

The  Commission  will  monitor  the  progress  in  the  establishment  of  the  European  maritime 
transport space without barriers and 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  Internal  Market  in  maritime  transport  collect 
information  by  stakeholders  and  disseminate  concrete  data  on  best  practices.  A  staff  report 
should  be  issued  three  years  after  the  adoption  of  the  action  plan,  at  the  occasion  of  the 
forthcoming Commission Communication on the promotion of Short Sea Shipping. 

EN 

50 

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Annex A: Administrative procedures applicable 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; 

Directive 2001/96/EC 

Waste management procedure. 

Directive 2000/59/EC 

Port and ship security 

Security notification prior to entry; 

Regulation 
725/2004 

(EC) 

N° 

Procedures  on  Port  state  control  of  shipping  (Paris 
Moue); 

Directive 95/21/EC 

Dangerous goods procedure 

“Dangerous Goods Declaration”; 

“Dangerous Goods Manifest”.  

Directive 2002/59/EC 

IMO/FAL FORM (N°7) 

Custom procedures 

IMO/FAL forms (1, 3, 4, 5, 6); 

Directive 2002/6/EC 

Cargo Manifest. 

Control Immigration 

Immigration procedure: “Border Control”. 

Regulation 
562/2006 

(EC) 

N° 

Phytosanitary  measures 
and agriculture 

Phytosanitary inspections. 

Veterinary 

Veterinary checks on products of animal origin; 

Directive 89/662/EEC 

Veterinary and zootechnical checks on live animals. 

Directive 90/425/EEC 

Health 

Maritime Declaration of Health; 

IMO/FAL forms31 

Payment of dues 

Dues on cargo form; 

Declaration of vessel dues. 

code 
French 
regulations … 

and 

port 

31 

Attached to IMO/FAL Form No.1 (General Declaration), only on arrival 

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51 

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Id 

1 

List and description of the main procedures 

Description of Procedures 

All vessels 

Entry  and  departure  notification  (related  to  Directive  2002/59/EC),  establishing  a  Community  vessel  traffic 
monitoring and information system (VTS) : 

(second  part  only 
some ships) 

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 previous 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  information  is  available”.  General  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) operated 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 harbourmaster via the ship agent. 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  arrival,  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  condition  that  they  have  an  arrangement  for  disposal  of 
waste 

3 

Bulk carriers 

Loading / Unloading of bulk carriers: Procedures related to Directive 2001/96/EC 

Notification by the  master to the terminal before arrival: 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. Signature of the terminal representative. Ship Checklist to be completed 
and signed jointly by the master and terminal representative. At the end of (un)loading, written agreement by 
the master and terminal representative that it has been done according to the Plan. 

4 

All vessels 

Security notification 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 harbourmaster. Harbourmaster transmits 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 services, also for international services 

5 

All 
(random checks) 

vessels 

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 priority 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 

52 

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their commitments and the relevant international conventions 

the inspection procedures and the investigation of operational procedures 

the exchange of information 

the structure of the organization and amendment procedures 

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 

IMO Dangerous goods manifest (IMO/FAL form 7) 

It is notified in advance to the harbourmaster by the shipmaster, by fax, email, telex. 

6 

7 

Vessels 
(dangerous 
goods) 

8 

All vessels 

Reporting  formalities:  IMO/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  Declaration”,  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  identification  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 transfer: 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 duplicate, of the crew and of any passengers. At the latest upon arriving in the 
port, the list must be given to the border guards. If the 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 captain, 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 returned to the border guards or shipping authorities 

Cross-border movement at external borders shall be subject to checks by border guards. 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  holding  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  ships  call  or  in  the  adjacent 
municipalities without presenting themselves at a border crossing point, on condition that they appear on the 
crew list, which has previously been submitted for checking by the competent authorities, 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 

33 

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 
Cf. Regulation (EC) N° 562/2006 (point 3.1 of Annex VII) 

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11 

Some 
(random) 

vessels 

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  Community  over  non-Community  territory  is  not  needed  if 
there are no specific risks identified, but the possibility for occasional checks should always remain. 

12 

Some 
(random checks) 

vessels 

Veterinary checks on products of animal origin: Procedures related to Directive 89/662/EEC on Products to be 
accompanied by a health certificate 

Checks at origin. If products were imported from outside the EC, then the Member State of origin must perform 
documentary checks. 

Checks at destination: local authorities can perform veterinary checks. 

13 

Some 
(random checks) 

vessels 

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 imported from outside the EC, then the Member State of origin must perform 
documentary checks. 

Checks at destination: local authorities may perform vet. and zootechn. checks.  

14 

All vessels 

Maritime Declaration of Health: Attached to IMO/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 call (for the last 4 weeks), a set of questions about cases 
of illness on board, to be answered by yes or no and particulars of every case of illness or death occurring on 
board must be mentioned in a schedule annexed to the declaration. The Declaration is certified true and correct 
by the ship master. One copy is attached to the IMO/FAL Declaration No. 1. Another copy is sent to the port’s 
health services. 

Deadline: prior to entrances, 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 level 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 for the benefit of Port Authority only for bulk cargo (for 
general  cargo  and  containers,  port  dues  are  directly  included  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 vessels or passengers (French code and port regulations): The “declaration of vessel 
dues” (DN) form includes the ship name and flag, number of the voyage, names and addresses of the operator 
of  the  ship  and  his  local  ship  agent,  port  of  departure  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  are  routinely  checked  by  the  authorities  on  arrival  or  departure  are: 
Certificate  of  Registry,  International  Tonnage  Certificate,  Cargo  Ship  Safety  Construction 
Certificate,  Cargo  Ship  Safety  Equipment  Certificate,  Cargo  Ship  Safety  Radio  Certificate, 
International  Loadline  Certificate,  International  Oil  Pollution  Prevention  Certificate, 
Certificate  of  Fitness  of  Cargo  Gear,  Safe  Manning  Document,  Deratting  Certificate, 
Certificate of Insurance for Oil Pollution Damages, Certificate of Class, Safety Management 
Certificate, Document of Compliance. 

Customs procedures 

– 

34 

EN 

The  Community  Customs  Code34  allows  the  simplification  of  certain  customs 
procedures,  in  the  case  of  those  vessels  performing  regularly  scheduled  routes 

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 

54 

   EN 

 
 
                                                 
between  two  EU  ports.  In  this  case  it  is  necessary  to  have  a  Certificate  of 
“Authorised  Regular  Shipping  Service”  (ARSS).  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 always required on arrival in a port. 

The  following  table  shows  the  customs  procedures  in  the  EC  for  Community  and  Non- 
Community goods35. 

Selected Customs Procedures in the EC 

Non-regular shipping services 

Authorised regular shipping services 

No need to prove the status of Community goods 
(free circulation). 

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, 
assumes 
responsibility  for  their  onward  carriage,  the 
shipping company, or the representative of any 
of the above 

person  who 

the 

s
d
o
o
g
y
t
i
n
u
m
m
o
C

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 
computerised 
inventory systems) 

records 

(on 

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. 

35 

Council of 23 April 2008 laying down the Community Customs Code (Modernised Customs Code); OJ 
L 145 of 4.6.2008, p. 1 
Cf. commission staff working paper: “Guide to Customs Procedures for Short Sea Shipping” (Revised 
Working Version 3 updated on 14 January 2004). 

EN 

55 

   EN 

 
 
 
 
                                                                                                                                                         
s
d
o
o
g
y
t
i
n
u
m
m
o
C
-
n
o
N

)
t
i
s
n
a
r
t
(

s
d
o
o
g
.

m
m
o
C
n
o
N

Presentation  and  summary  declaration  are  the 
same as in the case of Community goods.  

Transit procedure: 

Restrictions  on  the  movement  of  goods  after 
unloading 

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  them  would  like  a  further  improvement  of  this 
facilitation, e.g. to have it linked to companies or routes instead of ships. A survey conducted 
by  the  Finnish  Customs  found  that  62%  of  liner  services  have  authorised  regular  service 
permits. 

36 

37 

38 

39 

40 

Level  1,  simplified  procedure  (individual  manifest  for  goods):  receive  authorization  from  competent 
authorities,  load  vessel,  manifest,  complete  2  copies  (one  to  Office  of  Departure  and  one  to 
Accompanies  Cargo)  of  separate  manifests  as  transit  declaration  endorsed  by  Office  of  Departure, 
goods unloaded and Manifest as transit declaration presented to office of destination. 
Level  2,  simplified  procedure  (single  manifest  for  all  goods):  receive  authorization  from  competent 
authorities, load vessel, single manifest to Port of unloading.  
T1  =  declaration  made  on  the  Community  transit  document  that  the  goods  are  placed  under  external 
Community transit. 
T2F = Declaration made on the Community transit 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. 
Simplified  Customs  Procedures  in  Short  Sea  Shipping:  "Authorised  Regular  Shipping  Service", 
SEC(2004) 333 

EN 

56 

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Annex B: Comparison of administrative procedures for road and maritime transports 

It is generally acknowledged that one of the main obstacles to the development of Short Sea 
Shipping is represented by the presence of cumbersome 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  transport  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 carried 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  reporting  for  European  Road  Transport  (ERT),  apart  from  the  International 
Consignment  Note.  The  control  of  these  certificates  is  limited  to  checks  at  the  external 
borders of the EU and to random roadside checks. Random roadside checks may occur at any 
time within the EU when the truck driver is required to produce 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 

57 

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Comparison of Customs formalities in Short Sea Shipping and road transport 

Subjects 

Short Sea Shipping 

Road transportation 

Community goods 

A)  No  “Authorised 
services”  

regular 

shipping 

No proof of Community status when goods 
are  transported  within  the  EU  (and  do  not 
cross external borders) 

Need  to  prove  the  status  of  Community 
goods  because  of 
the 
Community at an 

re-entry  of 

- Presentation of goods 

- Proof of community status 

(T2L 
documentation such as a ship manifest) 

document 

or 

commercial 

B) “Authorised regular shipping services”  

No need to prove the status of Community 
goods  because  of  authorisation  of  the 
vessel (free circulation). 

Proof of Community status when goods re-
enter the Community at an external border 
point: 

- Presentation of goods 

- Proof of Community status 

(T2L 
documentation such as the CMR) 

document 

or 

commercial 

Non-Community 
goods 

Cargo Declaration or Manifests 

Transit (T1) Declaration 

Transit (T1) Document41 

“Authorised Regular Liner Service”: 

Simplified transit declaration 

Community goods carried by road, which remain within the EU and do not cross an external 
border point, do not need to provide evidence of their status. By contrast, a Community port 
constitutes an  external border point where proof of the Community status of goods must be 
always provided except for goods carried by a vessel authorised as a regular shipping service. 

Comparison between maritime and road administrative costs 

In order to evaluate the average costs of administrative procedures, as for maritime transport, 
the following assumptions have been set:  

– 

– 

41 

42 

Time consumption and delays are considered only for “roadside checks/inspections” 
and  a  probability  of  control  has  to  be  considered:  for  the  purpose  of  the  Impact 
Assessment it has been set at 2.0%42; 

Because of the presence of few documents, the time for the preparation of documents 
has been assumed to be 1h; 

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. 
Source PriceWaterhouse Coopers in relation to the Directives on “Better Road Safety Enforcement in 
the European Union” 2006/22/CE (15/03/2006). 

EN 

58 

   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 truck: 70 €/h (18 hours per day). 

Consequently, the cost for one roadside inspection could be set at almost € 200. 

In  order  to  better  understand  the  poor  competitiveness  of  maritime  transport  against  road 
transport, a comparison between different administrative 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 maritime transport and the all-road solution are 
considered. Data refer to standard goods. 

Total cost per call for standard goods (€, €/tons) 

Prob.(Cost) 

Container  Ro-Ro 

Bulk 

Avg MARITIME 

ROAD 

(weighted)  

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 

5.36 

7.64 

9.15 

90.0 

(€/tones) 

(€/tones) 

(€/tones) 

(€/tones) 

(€/tones) 

Market share 

10.5% 

12.8% 

69.5% 

100% 

ADM on total transport cost 

5% 

7% 

2.67% 

3.27% 

0.20% 

EN 

59 

   EN 

 
 
 
Total cost per call for standard goods (€, €/tons)

43 

3000.0

2500.0

2000.0

1500.0

1000.0

500.0

0.0

7.00%

5.00%

800.1

1632.5

960.1

2.67%

€ 1,336.6

3.27%

0.20%

€ 192.8

€ 192.8

1.01%

10.00%

8.00%

6.00%

4.00%

2.00%

0.00%

Container

Ro-Ro

Bulk

MARITIME

ROAD

ROAD Max

ADM PROC COST PER CALL AVERAGE (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 generic 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 transport costs -- considering the 
probability of 2.0 % for the inspection on trucks). 

The  cost  per  ton  differs  by  22%  but  the  relative  impact  on  the  transport  cost  is  more 
significant. The overall value can increase in relation to the percentage of annual percentage 
of truck inspections. 

43 

Data related to general cargo have to be considered on average of the total. 

EN 

60 

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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  more  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 derived from available assessments. 

The annual growth rate of the last ten-year period, when Short 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  benefit  in  the  short  run  from  an 
acceleration of its recent growth and therefore grow in the base-line 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 Shipping market in the EU would therefore reach, 
in the base-line scenario, some 1.4 billion ton.km in 2010 and 1.86 billion in 2020. 

Short Sea Shipping market in EU-27, projections in the base-line scenario (million 
ton.km) 

1,547

1,589

1,506

1,632

1,676

1,721

1,768

1,815

1,864

1,346

1,386

1,428

1,467

1,268

1,307

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-horizon considered in the analysis) 
yields a Short Sea Shipping market of some 3.17 billion ton.km. 

The market of freight transport by other modes is also assessed in the base-line scenario. 

For  this  reason,  the  trend-line  growth  according  to  the  volumes  of  transport  since  2002  is 
considered,  which  is  equal,  for  road  transport,  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 

61 

   EN 

 
 
                                                 
+3.2% in 2020 (when the total road freight market would amount to 2.9 billion 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 transport in EU-27, the base-line scenario (million ton.km) 

Road

Rail

5 
 1.95

9 
 2.02

1888 

7 
 2.17

1 
 2.25

3 
 2.10

4 
 2.32

8 
 2.39

2 
 2.47

6 
 2.54

4 
 2.69

8 
 2.76

0 
 2.62

2 
 2.84

6 
 2.91

435 

 445 

 458 

 471 

 484 

 496 

 509 

 522 

 535 

 548 

 560 

 573 

 586 

 599 

 612 

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

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  and  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 Shipping, baseline scenario (000 million ton.km) 

EU goods carried in intra EU SSS (000 mTkm)

1.200

1.000

800

600

400

200

-

2006

2008

2010

2012

2014

2016

2018

2020

EN 

62 

   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  load  factors,  the  output  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  transported  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 

Ro-Ro 

280 

Ro-Lo 

220 

Container 

560 

Ro-Pax 

64 

embarks/ 
% 
disembark per call 

LU  per 
line 

conv.  factor 
LU / tons 

tons  x 
line 

tons  x 
call 

n.  of 
loops 
year 

line 
per 

0,35 

0,24 

0,24 

0,49 

560 

300 

13 

 7.280  

 2.559  

195,1 

13 /11,28 

 3.659 

 881 

153,0 

1120 

11,28 

 12.634  

 2.985  

67,2 

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 

transported  by 

Tons 
ARSS per year 

EU  goods 
share (%) 

EU  goods  carried  by 
ARSS per year 

Non EU goods carried 
by ARSS /year 

Ro-Ro 

Ro-Lo 

119.781.397 

13.537.357 

Container 

162.210.774 

Ro-Pax 

31.722.578 

Bulk 

Total 

- 

0,90 

0,90 

0,90 

0,90 

- 

107.803.257 

11.978.140 

12.183.621 

1.353.736 

145.989.696 

16.221.077 

28.550.320 

3.172.258 

- 

- 

327.252.105,4 

294.526.894,9 

32.725.210,5 

EN 

63 

   EN 

 
 
 
Tons  transp.  by  NON 
ARSS services/ year 

EU  goods 
share (%) 

Non ARSS (EU goods) 

Non  ARSS  (non  EU 
goods) 

Ro-Ro 

Ro-Lo 

73.414.404 

8.297.090 

Container 

99.419.507 

Ro-Pax 

19.442.870 

Bulk 

Total 

- 

0,5 

0,5 

0,5 

0,5 

- 

36.707.202 

36.707.202 

4.148.545 

4.148.545 

49.709.753 

49.709.753 

9.721.435 

9.721.435 

- 

- 

200.573.871,1 

100.286.935,5 

100.286.935,5 

Finally, considering the overall number of tons of EU goods and the ones of non-EU goods, 
without considering the service status, 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 

64 

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Annex D: Main assumptions for the Impact Assessment 

The impact assessment made assumption on the size 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  (hereafter  B/L),  which  are  fundamental  variables  in  the  cost 
benefit  analysis,  given  the  total  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  effectively  performed),  rather  than  on  the  number  of 
loading units or ton.km. 

Different assumptions have been used for different types of cargoes. In particular, it has been 
studied  the  number  of  lines  in  the  Short  Sea  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  document)  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  liner  maritime  connections  are  shown,  both  for 
container traffic and for Ro-Ro traffic. 

Further elaborations on that database allowed the assessment of the number of intra-EU lines, 
their average frequency, the average number of ports called per line and the overall number of 
line loops per year. Matching the containers connections’ data and the Ro-Ro ones it has been 
estimated the share of lines entirely 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 transport of passengers and private cars (Ro-Pax). 

In this way it is possible to define the different typologies of intra-EU maritime cargo traffics, 
and  to  set  the  basis  for  further  considerations  on  different  cargo  specificities  (average  load 
factors,  average  number  of  ports  called  per  line  and  average  liner  frequency,  conversion 
factors from loading units to bill of ladings). 

The assumptions concerning the variables are shown in the table below: 

45 

Elaboration on European SSS Info data. 

EN 

65 

   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 

Load Factor of vessels 

70% 

80% 

100  LU  + 
200 TEU 

80 LU 

20,000 
tons 

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 

Avg number of B/L's per line per vessel 

448 

2.84 

400 

4.15 

170 

2.03 

91 

Avg number of line loops per year 

67.2 

195.1 

153.0 

415.5 

2 

4 

- 

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’  capacities  and  load  factors  were  assessed 
(considered  for  each  type  of  vessel),  validated  by  the  experts  and  stakeholders  interviewed 
during the study47: 

– 

– 

– 

– 

– 

Average vessels’ capacities (considered per each type of vessel); 

Average vessels’ loads (considered 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 external costs) show that the 
2006 ISIC analyses prove to be the most fitting ones to the present external cost assessment 
problem:  

– 

Figures are expressed in terms of Euro/tkm 

46 

47 

48 
49 
50 

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. 
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 
1.4 LU per B/L in Ro-Ro traffic and 2,5 TEU per B/L in containerised one 
Containers and Loading Units 
1.4 LU per B/L in Ro-Ro traffic and 2,5 TEU per B/L in containerised one 

EN 

66 

   EN 

 
 
                                                 
– 

Figures are given also for SSS (recovering a usual lack of the 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 recent 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 costs (comprising infrastructure 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) 

Air pollution 

Global warming 

Noise 

Accident costs 

Congestion 

Infrastructure 

Source: EC ISIC project (2006) 

Road 

0,0089 

0,0026 

0,0028 

0,0043 

0,0113 

0,0043 

Rail 

0,0046 

0,0046 

0,0009 

0,0014 

0 

0,0037 

SSS 

0,0056 

0 

0 

0 

0 

0,0034 

EN 

67 

   EN 

 
Acronym
ADN 

ADR Code 

AIS 

ARSS 

B/L 

Annex E: List of abbreviations 

Definition
Agreement on the carriage of Dangerous goods by inland waterways 

Agreement on the carriage of Dangerous goods by Road

Automatic Identification System

Authorised Regular Shipping Service

Bill of Lading 

CERTeT 

Centro di Economia Regionale dei Trasporti e del Turismo (Universita Bocconi)

DG 

EDI 

EMS 

EMSA 

ERT 

FTE 

GT 

Dangerous Goods

Electronic Data Interchange

European Maritime Space

European Maritime Safety Agency

European Road Transport

Full Time Equivalent

Gross Tonnes 

HEATCO 

Harmonised European Approach for Transport Costing

ICT 

Information and Communications Technology

IMDG Code 

International Maritime Dangerous Goods Code

IMO 

International Maritime Organisation

IMO/FAL 

Convention on the Facilitation of international maritime traffic 

IRR 

ISIC 

ISSC 

LRIT 

MoU 

MRCC 

MTCP 

NPV 

PDG 

PEC 

PwC 

RID 

Ro/Ro 

Ro-Pax 

Internal Rate of Return

Integrated Service in the Intermodal Chain

International Ship Security Certificate

Long Range Identification and Tracking of ships

Memorandum of Understanding 

Maritime Rescue Coordination Centre

Maritime Transport Co-ordination Platform

Net Present Value

Packaged Dangerous Goods

Pilot Exemption Certificate

PricewaterhouseCoopers

Regulation on the carriage of Dangerous goods by rail

Roll-on Roll-off ship

Roll on/Roll off - Passenger Vessel

SOLAS Convention 

International Convention for the Safety of Life at Sea

SSS 

SSN 

VDR 

VTS 

Short Sea Shipping

SafeSeaNet 

Voyage Data Recorder

Vessel Traffic Service

EN 

68 

   EN 

 
 
. 

EN 

69 

   EN