COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT   Accompanying document to the   Proposal for a Regulation (EU) of the European Parliament and of the Council No xx/yy on the professional cross border transportation of euro cash by road between euro-area Member States   and the   Proposal for a Council Regulation (EU) No zz/yy concerning the extension of the scope of Regulation (EU) of the European Parliament and of the Council No xx/yy on the professional cross border transportation of euro cash by road between euro-area Member States  {COM(2010)377 final} {SEC(2010) 878final}
Date: 2010-07-14
Institutions: European Commission
Subjects: EU Member State, EU action, European currency, common transport policy, cross-border transport, impact study, paper money

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EUROPEAN COMMISSION 

Brussels, 14.7.2010 
SEC(2010) 877 final 

COMMISSION STAFF WORKING DOCUMENT 

SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying document to the 

Proposal for a Regulation (EU) of the European Parliament and of the Council No xx/yy 
on the professional cross-border transportation of euro cash by road between euro-area 
Member States 

and the 

Proposal for a Council Regulation (EU) No zz/yy concerning the extension of the scope 
of Regulation (EU) of the European Parliament and of the Council No xx/yy on the 
professional cross-border transportation of euro cash by road between euro-area 
Member States 

{COM(2010)377 final} 
{SEC(2010) 878final} 

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COMMISSION STAFF WORKING DOCUMENT 

SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying document to the 

Proposal for a Regulation (EU) of the European Parliament and of the Council No xx/yy 
on the professional cross-border transportation of euro cash by road between euro-area 
Member States 

and the 

Proposal for a Council Regulation (EU) No zz/yy concerning the extension of the scope 
of Regulation (EU) of the European Parliament and of the Council No xx/yy on the 
professional cross-border transportation of euro cash by road between euro-area 
Member States 

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1. 

PROBLEM DEFINITION 

The  16  Member  States  that  have  so  far  adopted  the  euro  use  the  same  banknotes  and 
coins. However, due to strong differences between national legislations it is in practice 
very  difficult  to  transport  euro  cash  by  road  on  a  professional  basis  between  euro-area 
Member States and very little cross-border land transportation therefore takes place. It is 
a contradiction in terms that there are border barriers to the professional transport of the 
single currency within the euro area. 

Due to the nature of the goods transported, the cash-in-transit (CIT) sector is moreover 
exposed  to  serious  security  risks.  It  is  therefore  of  paramount  importance  that  cross-
border  cash  transports  take  place  under  conditions  that  provide  a  high  level  of  security 
for the CIT-staff and for the general public. Due to different national traditions and risk 
environments,  security  requirements  are  however  interpreted  very  differently  across 
euro-area  Member  States, leading to large  differences between  national rules in  a large 
number  of  areas,  such  as  authorised  transport  types,  armouring  and  equipment  of  the 
CIT-vehicles,  the  use  of  intelligent  banknote  neutralisation  systems  (IBNS),  number  of 
staff  in  the  CIT-vehicles,  the  possession  and  carrying  of  firearms  by  the  CIT-staff, 
training requirements, information towards the police, licence rules and penalties.  

Due  to  these  differences  between  national  regulations,  commercial  banks,  big  retailers 
and  other  professional  cash  handlers  are  in  practice  in  most  cases  prevented  from 
contracting with a CIT-company in another Member State, even though it might be able 
to provide for the most efficient (and shortest) cash pick-up and delivery circuits. They 
are  likewise  prevented  from  taking  advantage  of  the  cash  services  of  the  nearest  NCB 
branch  or  CIT  cash  center,  if  it  happens  to  be  located  across  the  border  in  another 
Member State. Finally, CIT-companies carrying out transportation in border regions are 
not  able  to  plan  their  transport  routes  and  other  cash  logistics  in  the  most  efficient 
manner,  if  potential  customers  are  located  on  both  sides  of  the  border.  This  situation 
implies a sub-optimal organisation of the cash cycle in such regions and thus also at euro-
area level. This, in turn, means a higher cost of cash and/or a lower service level for the 
customers  compared  to  a  situation  without  national  regulatory  barriers  to  cross-border 
cash transports. 

In order to allow stakeholders to take full advantage of the single currency, obstacles to 
the free circulation of euro cash within the euro area should be lifted, while ensuring a 
high level of security for the CIT-staff and the general public.  

At  the  same  time,  the  CIT-market  has  a  local  character  and  the  potential  cross-border 
market primarily concerns border regions. The potential geographical market can roughly 
speaking be estimated to some 100 km on each side of the border for the majority of the 
transports. Measures to lift the barriers to cross-border transport of cash should therefore 
be proportionate. 

2. 

ANALYSIS OF SUBSIDIARITY 

The  alternative  to  action  at  EU  level  would  be  voluntary  bilateral  agreements  between 
Member  States  or  even  multilateral  agreements.  However,  action  at  EU  level  brings 

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important economies of scale as compared to bilateral or multilateral action. Only action 
at EU level allows taking into account the future enlargement of the euro area as the EU 
rules  for  cross-border  transport  can  be  used  by  any  new  participating  Member  State, 
which is not the case for bilateral/multilateral agreements. 

Furthermore,  even  though  a  demand  exists  as  expressed  notably  by  the  banking  sector, 
more  than  eight  years  after  the  introduction  of  euro  cash  Member  States  have  not 
concluded any agreements to facilitate professional cross-border transport of cash. This 
suggests  that  EU  action  is  in  practice  the  only  possible  way  of  reconciling  diverging 
regulatory  regimes  (currently  16  in  number),  covering  a  wide  range  of  complex  issues 
where  security  issues  (e.g.  the  carrying  of  weapons)  and  labour  market  considerations 
interact. 

3. 

OBJECTIVES 

The  general  objective  of  the  present  Commission  initiative  is  to  facilitate  the  free 
circulation  of  euro  cash  within  the  euro  area  by  removing  obstacles  to  the  professional 
transport of euro cash by road between euro-area Member States, while ensuring that the 
transports take place under conditions that provide a high level of security for the CIT-
staff and for the general public. 

To facilitate professional cross-border transport of euro cash is, moreover, a natural and 
necessary  complement  to  the  European  Central  Bank's  Roadmap  for  more  convergence 
of National Central Bank (NCB) cash services and the creation of a single euro cash area 
for  professional  cash  handlers.  It  is  moreover  complementary  to  the  payment  services 
directive1 and SEPA  – the  single  euro  payments  area, which aims at making electronic 
cross-border payments in euro as easy as domestic payments. 

As  regards  the  free  circulation  of  the  euro,  and  due  to  the  local  character  of  the  CIT-
market,  the  specific  objective  should  therefore  be  to  facilitate  transport  in  such  border 
areas between euro-area Member States. 

As regards the security for the CIT-staff and for the general public, attacks should as far 
as  possible  be  deterred  and  if  an  attack  nevertheless  takes  place,  it  should  result  in  a 
minimum  of  human  damage.  The  specific  objective  should  be  that  cross-border 
transports are at least as secure as domestic transports.  

An  increase  in  cross-border  cash  transports  could,  however,  at  the  same  time  lead  to  a 
possible negative effect on wage levels and/or employment in the CIT-sector in a given 
host  country,  if  there  are  significant  wage  differences  compared  to  neighbouring 
countries.  While  Member  States  should  in  general  not  be  prevented  from  using  their 
comparative advantages, a social minimum protection to be observed in the host country 
should at the same time be ensured for the staff in the CIT-sector in line with the existing 
principles in EU legislation. 

1 

Directive  2007/64/EC  of  the  European  Parliament  and  of  the  Council  of  13 November  2007  on 
payment services in the internal market, 5.12.2007. 

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4. 

POLICY OPTIONS AND APPRAISAL OF BROAD POLICY OPTIONS 

The appraisal has been organised in two rounds starting with a general appraisal of the 
broad policy options and thereafter a more detailed assessment of the policy options that 
were considered to have the potential of reaching the objectives. 

The impact assessment (IA) has considered five broad options to achieve the objective: 
(1) a baseline no-change scenario; (2) Bilateral or multilateral agreement between those 
Member  States  potentially  most  concerned  by  cross-border  transports;  (3)  A  set  of 
common rules for cross-border transports only; (4) Full mutual recognition; and (5) Full 
harmonisation of the regulation of all CIT-transport. 

Three sub-options were furthermore considered: a) extending the scope of the rules to EU 
Member States that have not adopted the euro; b) extending the scope to other cash and 
possibly valuables; and c) restricting the scope to point-to-point transports only. 

The IA finds that options 1 (no-change) and 2 (bilateral/multilateral agreements) would 
not be effective in meeting the objective of facilitating the free circulation of euro cash, 
since it seems highly unlikely that such agreements would materialise spontaneously on a 
larger scale. This is confirmed by the fact that no agreement has so far been concluded 
during the more than eight years that have passed since euro banknotes and coins were 
introduced. Furthermore, even in the case of such an agreement, it would still only cover 
part of the euro area and it would not allow taking into account future enlargements of 
the  euro  area.  An  agreement  at  EU  level  therefore  seems  to  be  a  more  efficient  and  in 
practice the only  possible  approach to facilitate cross-border cash transport between all 
the concerned countries. 

Option 3 (a common set of rules applicable to cross-border CIT-transports only) would 
meet the objective of facilitating the free circulation of euro cash. Since it is limited to 
cross-border transports it would furthermore not go beyond what is necessary to achieve 
the objectives.  

Option  4  (full  mutual  recognition)  would  meet  the  overarching  objective  of  facilitating 
the  free  circulation  of  euro  cash,  but  it  would  mean  that  CIT-companies  would  be 
allowed  to  operate  across  borders  under  several  different  national  sets  of  rules.  This 
would  be  very  confusing  for  the  competent  national  supervisory  and  enforcement 
authorities. Such a situation would be unacceptable in a sector that is by the nature of its 
business exposed to serious security threats and would not meet the objective of ensuring 
that the transports take place under conditions that provide a high level of security for the 
CIT-staff and for the general public. This option could also be seen as disproportionate 
since it could affect the whole territory of the host Member States, unless the scope of the 
option is specifically restricted to cross-border operations. 

Option 5 (full harmonisation) would meet the objective of facilitating the free circulation 
of euro cash and would be consistent with a single euro cash area and the single market. 
However, since cross-border euro cash transport only concerns a limited part of all euro 
cash transport, it would not be proportionate relative to the stated objective to harmonise 
the rules for all CIT-transports, whether cross-border or not. A full harmonisation would 
furthermore  be  very  difficult  in  view  of  the  many  sensitive  and  security-related  issues 
involved  in  the  area  of  CIT,  not  the  least  concerning  the  possession  and  carrying  of 
weapons. 

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The three sub-options are considered as relevant. However, including such diverse items 
as  valuables  in  general  under  the  scope  of  common  rules  is  rejected  since  it  risks 
complicating the legislative effort and deflect it from the core objective of the initiative. 

The  detailed  analysis  of  impacts  therefore  concerns  a  set  of  common  rules  for  cross-
border transport together with sub-option a), part of sub-option b) and sub-option c).  

5. 

DETAILED ASSESSMENT OF IMPACTS 

The second-round assessment includes a detailed assessment of the economic, social and 
environmental impacts of the broad option 3 - common cross-border rules – and the three 
sub-options. It also assesses the possible impact on the security of the transports.  

The different impacts depend to a large degree on the size of the potential market and the 
extent  to  which  it  can  be  realised.  In  order  to  collect  information  on  the  current  CIT-
market and to estimate the size of the potential market for cross-border cash transport by 
road, if current regulatory obstacles to such transports are lifted, DG ECFIN launched an 
external study that was carried out by Ramböll Management2. According to this study, it 
is  estimated  that  the  potential  long-term  market,  assuming  that  all  obstacles  to 
professional cross-border euro cash transports by road are lifted, would amount to around 
2.6 % of the total market (expressed in terms of the value of all euro cash ordered to CIT-
companies), which would correspond to some 77 000 cross-border transports3 potentially 
being carried out each year in the 11 euro-area countries that have land borders to other 
euro-area  countries.  This  is  a  large  increase  compared  to  the  current  situation  and 
indicates  that  there  is  a  potential  for  a  significant  increase  in  cross-border  euro  cash 
transports if regulatory obstacles are lifted. 

The above estimation is based on current traffic flows. It is, however, difficult to predict 
what the effects of opening the cross-border market may be. Cross-border cash transports 
means not only potentially cheaper service, but also potentially better service for which 
customers may be willing to pay more. As an example, a big retailer may be better served 
from  a  cash  center  across  the  border  that  could  more  easily  deliver/pick-up  cash  on  a 
daily  instead  of  on  a  weekly  basis.  Lifting  obstacles  to  cross-border  transport  could  in 
this example have a positive impact on the costs/risks of the retailer (less storage/security 
costs  and  risks  involved)  which  could  have  a  positive  impact  on  the  CIT-business  as 
more frequent deliveries and additional turnover would be created.  

The  facilitation  of  cross-border  cash  transports  is  also  likely  to  produce  some 
environmental benefits, due to shorter transports overall.  

A significant increase in cross-border transports may, however, also have negative social 
effects  in  the  host  countries.  This  concerns  notably  a  possible  effect  on  wage  levels 
and/or  employment  in  the  CIT-sector  in  a  given  host  country,  if  there  are  significant 
differences in salaries compared to neighbouring countries. The impact assessment shows 

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the 

Available 
Commission 
http://ec.europa.eu/economy_finance/articles/euro/2010-02-26-cross-border-cash_en.htm  
A  transport  meaning  a  CIT-vehicle  that  crosses  the  border  twice;  once  on  its  outbound  journey 
and once on its homebound journey. 

European 

website 

the 

at: 

of 

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that  significant  differences  in  salaries  seem  to  exist  between  some  neighbouring  euro-
area countries. Salary differences are furthermore very substantial between some of the 
countries  that  have  not  yet  adopted  the  euro  and  their  neighbours  in  the  euro  area.  It 
therefore  seems  justified  to  mitigate  the  potential  social  impact  in  the  host  country  by 
ensuring a minimum protection of the workers in line with the principles of existing EU 
legislation.  

Directive  96/71/EC  on  the  posting  of  workers  is  intended  to  provide  for  a  minimum 
protection  to  be  observed  in  the  host  country  in  the  case  of  workers  who  are  posted  to 
perform temporary work there. However, considering the specific nature of CIT transport 
services, notably the frequent and short-term nature of the potential work periods abroad 
and  the  different  contractual  situations,  there  is  a  need  to  provide  for  the  analogous 
application of Directive 96/71/EC to all cross-border cash transport services in order to 
provide legal certainty for operators and ensure the practical applicability of the Directive 
in this sector. The proposal therefore includes some specific provisions in order to create 
legal  certainty  for  the  concerned  operators,  notably  by  ensuring  that  cross-border  CIT 
workers are guaranteed the relevant minimum rates of pay of the host country according 
to the Directive. 

The broad option 3 is furthermore developed into four specific options in order to take 
into account security-related or other sensitive issues: 

Option A. National rules on the carrying of weapons by CIT-staff remain fully in force. 

Option B. A number of CIT-transport types are established, with opt-out possibilities for 
the individual Member States. 

Option  C.  Restriction  of  the  scope  of  cross-border  transport  to  one  day  and  daytime, 
meaning that the CIT-vehicle shall depart from and return to its Member State of origin 
in the same day and the transport shall be carried out during daytime. 

Option D. The majority of the number of cash deliveries/pick-ups made by a CIT-vehicle 
during the day must be carried out on the territory of the host Member State(s). 

The  consultations  with  Member  States'  administrations  and  other  stakeholders  have 
shown  that  these  exceptions  are  seen  as  necessary  in  order  to  ensure  a  high  level  of 
security and that they are a necessary precondition for achieving a sufficient consensus 
on common cross-border rules for cash transports. 

The  analysis  has  shown  that  although  these  options  may  imply  a  reduction  of  the 
potential cross-border market, they are not expected to create major obstacles for cross-
border transports and the proposal foresees in all cases solutions that enable cross-border 
transports  (strong-box  for  weapons  in  the  vehicle  that  can  only  be  opened  by  remote 
control  by  the  control  room,  standardised  transport  options,  recognition  of  equivalent 
weapons training etc.).  

As  regards  the  security  of  the  transports,  the  proposal  foresees  high  standards  in  the 
relevant security-related fields, the preservation of national rules in sensitive areas such 
as  weapons  legislation  and  possibilities  for  Member  States  to  opt  out  from  specific 
transport types if they do not consider them compatible with the national environment. It 

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is therefore concluded that the envisaged common rules provide a high level of security 
for cross-border transports. 

The administrative burden, finally, is considered to be relatively limited and would in the 
case of CIT-companies only concern those companies that choose to apply for a cross-
border licence. 

6. 

COMPARISON OF OPTIONS 

The impact assessment concludes that the preferred option is a set of common rules that 
would  be  valid  in  all  euro-area  Member  States  but  limited  to  cross-border  transports 
(option  3),  together  with  the  specific  derogations  and  restrictions  to  the  scope  foreseen 
under  the  specific  options  A-D.  This  policy  option  would  fulfil  the  objective  of 
facilitating the free circulation of euro cash within the euro area, and would do so in the 
most  efficient  way  relative  to  the  other  broad  policy  options,  while  ensuring  that  the 
transports take place under conditions that provide a high level of security for the CIT-
staff and for the general public. It is furthermore recommended that Option 3 is extended 
to  the  territory  of  a  Member  State  that  is  about  to  introduce  the  euro,  since  there  will 
normally be an increased need for cross-border euro cash transportation in the run-up to 
the  changeover.  The  extension  should  apply  as  from  the  date  of  the  decision  of  the 
Council to abrogate its derogation from participating in the euro. 

7. 

MONITORING AND EVALUATION 

A  Committee  on  the  cross-border  transport  of  euro  cash,  with  representatives  from  the 
Commission, the Member States covered by the common rules and representatives of the 
European Central Bank, should be set up in order to monitor the implementation of the 
new rules and possibly propose measures to improve their functioning. The Committee 
should also consult the relevant stakeholders, including the social partners, and take their 
views into account as appropriate. 

A  formal  review  should  furthermore  be  foreseen  with  a  Commission  report  to  the 
European Parliament and the Council at the latest two years after the entry into force of 
the  common  rules.  The  review  should  also  include  consultations  of  the  stakeholders  in 
the  sector,  including  the  social  partners.  Based  on  the  result  of  the  review,  the 
Commission  could  make  a  proposal  to  revise  the  Regulation.  The  review  should 
thereafter be repeated every five years. 

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