COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council establishing a European Maritime Single Window environment and repealing directive 2010/65/EU
Date: 2018-05-17
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: EU Member State, administrative cooperation, administrative formalities, common ports policy, exchange of information, harbour installation, harmonisation of standards, maritime safety, maritime transport, simplification of formalities

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.5.2018  SWD(2018) 181 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council establishing a European Maritime Single Window environment and repealing directive 2010/65/EU {COM(2018) 278 final} - {SEC(2018) 230 final} - {SWD(2018) 182 final}  
 
 
Contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 5 

1.1.  Background: the Reporting Formalities Directive ....................................................................... 5 

1.2.  Legal context ................................................................................................................................ 7 

1.3.  Policy context .............................................................................................................................. 7 

1.4.  Economic and trade context ......................................................................................................... 9 

2. 

PROBLEM DEFINITION ................................................................................................................... 10 

2.1.  What is the problem? ................................................................................................................. 10 

2.2.  What are the problem drivers? ................................................................................................... 13 

2.3.  How will the problem evolve? ................................................................................................... 20 

3.  WHY SHOULD THE EU ACT? ......................................................................................................... 21 

3.1.  Legal basis ................................................................................................................................. 21 

3.2.  Subsidiarity: necessity of EU action .......................................................................................... 21 

3.3.  Subsidiarity: added value of EU action ...................................................................................... 22 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................ 23 

4.1.  General objectives ...................................................................................................................... 23 

4.2.  Specific objectives ..................................................................................................................... 23 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ..................................................................... 25 

5.1.  What is the baseline from which options are assessed (option 0)? ............................................ 25 

5.2.  Design of policy options ............................................................................................................ 28 

5.3.  Description of policy measures and options .............................................................................. 30 

5.4.  Overview of main differences between the harmonisation solutions ......................................... 44 

5.5.  Discarded policy options ............................................................................................................ 46 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 47 

6.1.  Economic impacts ...................................................................................................................... 47 

6.2.  SME impacts .............................................................................................................................. 54 

6.3.  Social impacts ............................................................................................................................ 55 

6.4.  Environmental impacts .............................................................................................................. 56 

6.5.  Other impacts ............................................................................................................................. 57 

7.  HOW DO THE OPTIONS COMPARE? ............................................................................................ 58 

7.1.  Stakeholder preferences ............................................................................................................. 58 

7.2.  Effectiveness .............................................................................................................................. 59 

7.3.  Cost-efficiency ........................................................................................................................... 60 

7.4.  Coherence .................................................................................................................................. 61 

7.5.  Proportionality ........................................................................................................................... 62 

7.6.  Summary: comparison of options .............................................................................................. 62 

8. 

PREFERRED OPTION ....................................................................................................................... 64 

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9. 

REFIT (SIMPLIFICATION AND IMPROVED EFFICIENCY) ....................................................... 64 

10.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 65 

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List of Annexes 

Annex 1: Procedural information                                                               

Annex 2: Stakeholder consultation                                                          

Annex 3: Who is affected and how?                                                         

Annex 4: Analytical methods                                                                       

Annex 5: Reporting Formalities Directive                                          

Annex 6: Policy options                                                                          

Annex 7: Connected policy areas                                                          

Annex 8: Trade and economic patterns                                                 

61 

68 

79 

81 

101 

104 

112 

118 

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Glossary 

Term or acronym 

Back-end entities 

DEM 

ECSA 

EMSA 

EMSWe 

ESPO 

ENS 

EU 

FAL 

Front end users 

ICT 

IMO 

IPCSA 

ISC 

MOVE 

NSW  
PCS 

RFD 

Shipping operator 

SSN 

SSS 

VTMIS 

WCO 

Meaning or definition 

The  authorities  and  IT  systems  receiving  data  via  the  National 
Single Windows 

Data Exchange Mechanism 

European Community Shipowners’ Association 

European Maritime Safety Agency 

European Maritime Single Window Environment 

European Sea Ports Organisation 

Entry Summary Declaration 

European Union 

Convention on Facilitation of International Maritime Traffic 

The  shipping  operators  providing  data  into  the  National  Single 
Window in connection to a port call 

Information and Communication Technologies 

International Maritime Organisation 

International Port Community Systems Association 

Inter-Service Consultation 

Directorate General for Mobility and Transport 

National Single Window 
Port  Community  System  -  an  electronic  platform  connecting  the 
systems  operated  by  the  organisations  and  entities  making  up  a 
seaport  community.  The  Port  Community  System  facilitates 
exchange  of  operational  or  administrative  information  between 
different  actors  in  the  port;  it  can  also  include  systems  for 
optimisation of processes (e.g. “smart port” systems). The PCS can 
be  operated  and  maintained  either  by  a  public,  private  or 
public/private organisation. 

Directive 2010/65/EU on Reporting Formalities for ships 

Subject to specific reporting requirements set in the EU legal acts 
and  international  agreements,  the  operator  may  be  a  shipping 
company,  a  ship  master  or  the  representative  of  the  shipping 
company/ship master 

SafeSeaNet 

Short Sea Shipping 

Vessel Traffic and Monitoring Information System 

World Customs Organisation 

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1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

Maritime transport operators face a wide range of reporting obligations every time a ship calls 
a port. Since the adoption of the Reporting Formalities Directive (RFD)1 in 2010 within the 
context of the European maritime transport space without barriers2, some of this reporting is 
channelled  via  National  Single  Windows.  The  purpose  of  the  RFD  was  to  harmonise  and 
simplify the administrative procedures for shipping operators, thus  improving the efficiency 
and  competitiveness  of  intra-EU  maritime  transport.  The  National  Single  Windows  should 
give  shipping  operators  the  benefit  of  simplified  reporting,  more  efficient  clearance  and 
thereby shorter release times for faster turnaround in ports.  

An evaluation of the RFD performed as part of the fitness check of the EU maritime transport 
policy in 2016-20173, found that these objectives have not been reached, although they remain 
highly relevant. Ultimately, the current RFD has been found ineffective: it does not provide 
the  tools,  incentives  or  requirements  to  achieve  EU-wide  harmonisation  of  reporting.  The 
voluntary  nature of the measures has  also proven insufficient. Further, the provisions of the 
RFD  are  too  vague  to  be  supportive  of  improvements,  as  it  does  not  have  mechanisms  for 
updating  the  framework  to  address  these  shortcomings  in  either  delegated  or  implementing 
procedures.  The  problem  analysis  has  been  confirmed  in  consultations  with  the  shipping 
industry  and  Member  States.  This  impact  assessment  therefore  assesses  several  options  for 
improving the situation and for creating a more effective and efficient reporting environment 
to facilitate maritime transport and trade. 

1.1.  Background: the Reporting Formalities Directive 

The RFD was intended as a tool to establish a simplified reporting environment for ships by 
asking  Member  States  to  provide  a  single  reporting  entry  point  for  a  number  of  reporting 
formalities for ships. 

The RFD did not introduce any new reporting obligations for shipping but aimed at reducing 
administrative burden deriving from EU legal acts or from international legislation:  

  by simplifying and rationalising information requirements set in different legal acts;  

1 Directive 2010/65/EU on reporting formalities for ships arriving in and/or departing from ports of the Member 
States (RFD), 20 October 2010, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32010L0065; 
Replacing at that time Directive 2002/6/EC 

2 European Commission, Communication and action plan with a view to establishing a European maritime 
transport space without barriers, 21 January 2009, COM(2009)10 final, http://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=COM:2009:0010:FIN  

3 European Commission Staff Working Document: Evaluation of Directive 2010/65/EU on reporting formalities 
for ships arriving in and/or departing from ports of the Member States, 2018 (referred to hereafter as 
Evaluation of the RFD) 

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  by replacing paper submissions with harmonised digital submissions; and  
  by  harmonising  reporting  on  national  level  and  establishing  a  single  entry  point  for 

multiple formalities, the National Single Windows. 

The  RFD  is  not  concerned  with  the  processing  or  content  of  the  reported  data;  only  with 
streamlined  reporting  procedures  and  formats  for  the  data  requested  from  ships  by  the 
underlying  legal  acts4.  The  data  sets  under  the  RFD  scope  are  defined  by  the  basic  acts 
referred to in the RFD annex. 

The  National  Single  Windows  could  be  organised  in  different  ways:  e.g.  centrally  in  the 
Member  State  or  in  a  distributed  system  of  National  Single  Window  entry  points.  The 
National  Single  Windows  channel  the  data  submitted  by  the  data  providers  (shipping 
operators) to the back-end data recipients (connected authorities and systems requiring these 
formalities). The National Single Windows thus perform two bundles of functionality: a) data 
collection from data providers, i.e. the functionality associated with receiving and validating 
the  reported  data  set  and  sending  back  responses  (reporting  gateway);  and  b)  data 
distribution  to  the  authorities,  i.e.  the  functionality  associated  with  rearranging  the 
information into specific data sets, sending them to the relevant authorities, and taking care of 
any related message exchanges.  

The RFD states that the same information (static data or data already reported and unchanged) 
should  have  to  be  reported  by  the  shipping  operator  only  once.  The  RFD  also  calls  for 
coordinated and harmonised reporting at EU-level5. The deadline for Member States to apply 
the new reporting regime was 1 June 20156. Among the main achievements of the RFD are 
the  largely  completed  digitalisation  of  reporting  and  the  connection  of  a  number  of  data 
recipient  authorities  to  the  National  Single  Windows,  creating  a  shared  national  entry  point 
for certain ship reporting.  

However, the current RFD does not provide any binding specifications for the interfaces, data 
formats  or  reporting  procedures  for  the  National  Single  Windows.  The  consequence  is  that 
each  Member  State  has  developed  a  unique  technical  interface  for  reporting.  There  is  no 
harmonised  front-end  (reporting  interface/entry  point)  towards  the  shipping  operators.  In 
addition, much reporting is still requested via other channels. This is further discussed in the 
Problem description below. 

More information about the current ship reporting environment is found in Annex 5. 

4 EU and international legislation referred to in RFD Annex 
5 RFD, Article 3.2 
6 RFD, Article 5.1 

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1.2.  Legal context 

Maritime transport is  subject to  complex administrative procedures even if vessels sail  only 
between EU ports (intra-EU maritime transport) and the cargo consists only of goods in free 
circulation  ("Union  goods").  These  procedures  involve  a  wide  set  of  international  and  EU 
legislation on transport safety and security, environment protection, customs, veterinary and 
plant-protection,  and  national  and  local  formalities  for  vessels  arriving  in  or  departing  from 
ports.  

The  RFD  complements  other  EU  legislation  by  providing  a  tool  for  streamlined  reporting 
from  shipping  operators  to  data  recipients  (authorities).  The  directive  covers  a  set  of  14 
digitalised reporting formalities resulting from international agreements and EU legal acts on 
vessel  traffic  and  monitoring  information  and  on  transport  of  dangerous  goods7,  on 
registration of persons sailing on board passenger ships8, on the Schengen Border Code9, on 
management  of  waste  and  cargo  residues10,  on  ship  and  port  security11,  and  on  the  Union 
Customs Code12. 

The  RFD  also  builds  on  the  international  level  legislation  and  notably  the  International 
Maritime  Organisation  (IMO)  framework  for  international  ship  reporting  formalities.  The 
IMO FAL Convention13 sets out some internationally agreed reporting formalities for ships. 
The  RFD  provides  the  European  framework  for  electronic  reporting  according  to  these 
standards.  The  IMO  however  does  not  establish  standards  for  all  ship  reporting  formalities, 
nor  does  the  international  framework  provide  any  guidance  for  simplified,  digital  reporting 
procedures and interfaces.  

1.3. 

Policy context 

The RFD is part of the EU maritime transport policy, contributing to the overall Commission 
transport policy goal of completing the internal market for transport by removing remaining 

7 Directive 2002/59/EC of the European Parliament and of the Council of 27 June 2002 establishing a 

Community vessel traffic monitoring and information system (OJ L 208, 5.8.2002, p. 10) 

8 Council Directive 98/41/EC of 18 June 1998 on the registration of persons sailing on board passenger ships 

operating to or from ports of the Member States of the Community 

9 Regulation (EC) No 562/2006 of the European Parliament and of the Council of 15 March 2006 establishing a 
Community Code on the rules governing the movement of persons across borders (Schengen Borders Code) 
(OJ L 105, 13.4.2006, p. 1) 

10 Directive 2000/59/EC of the European Parliament and of the Council of 27 November 2000 on port reception 

facilities for ship-generated waste and cargo residues (OJ L 332, 28.12.2000, p. 81) 

11 Regulation (EC) No 725/2004 of the European Parliament and of the Council of 31 March 2004 on enhancing 

ship and port facility security (OJ L 129, 29.4.2004, p. 6) 

12 Regulation (EU) No 952/2013 of 9 October 2013 laying down the Union Customs Code (OJ L 269, 10. 10. 

2013) (only part of customs formalities currently covered by the RFD scope) 

13 International Maritime Organisation, Convention on Facilitation of International Maritime Traffic (FAL), 

adopted 9 April 1965  

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bottlenecks, barriers and administrative burden14. It supports the Commission priorities of  a 
deeper and fairer internal market and the digital single market and indirectly contributes to 
the priority of jobs, growth and investments. 
The  objectives  of  the  European  maritime  transport  space  without  barrier15,  of  harmonising 
and  simplifying  administrative  procedures  remain  highly  relevant  for  EU  policy.  This  was 
confirmed by the European Council in its Valletta declaration on the EU's maritime policy16 
and its conclusions on 8 June 201717 on the priorities for the EU's maritime transport policy 
until 2020, both underlining the need to reduce administrative burden for maritime transport 
by  ensuring  simplified  and  digitalised  reporting  procedures  for  ships  and  inviting  the 
Commission to introduce measures for EU-level harmonisation of the reporting environment. 
The Council repeated this request again in its conclusions on digitalisation of transport on 8 
December, 201718.  

The  industry  and  maritime  transport  stakeholders  also  support  the  need  to  reduce  the 
administrative burden through harmonisation. In a joint statement on 1 March 201719, ten EU 
industry associations called for a "a true European single window environment for maritime 
carriers that fully ensures the ‘reporting once’ principle and which shares all necessary cargo 
and  conveyance  data  between  governments  and  all  relevant  authorities".  More  recent 
statements e.g. by the European Community Shipowners’ Association have echoed this same 
position20.  A  submission  to  the  REFIT  platform  was  done  by  Finland,  as  a  survey  amongst 
Finnish public administration, business and stakeholders identified the RFD as an example of 
EU  legislation  raising  particular  concerns.21The  proposal  for  a  revised  legal  framework  for 
reporting  formalities  is  part  of  the  Commission’s  third  mobility  package,  together  with, 
among  others,  a  proposal  for  a  regulation  on  electronic  freight  transport  information.  These 

14 European Commission, White paper: Roadmap to a Single European Transport Area, COM(2011) 144 final, 

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0144&from=EN  

15 Communication and action plan with a view to establishing a European maritime transport space without 

barriers, COM(2009)10 final  

16 Valletta Declaration: Priorities for the EU's Maritime Transport Policy until 2020: Competitiveness, 

Decarbonisation, Digitalisation to ensure global connectivity, and efficient internal market and a world-
class maritime cluster, Valletta, 29 March 2017, 
https://www.eu2017.mt/en/Documents/Valletta_Declaration_on_the_EU_maritime_transport_policy.pdf 

17 Council conclusions on Priorities for the EU's maritime transport policy until 2020: Competitiveness, 

Decarbonisation, Digitalisation to ensure global connectivity, an efficient internal market and a world-class 
maritime cluster, adopted by the Council at its 3545th meeting held on 8 June 2017, 
http://data.consilium.europa.eu/doc/document/ST-9976-2017-INIT/en/pdf 

18 Council conclusions on the digitalisation of transport, adopted by the Council at its 3581st meeting held on 5 

December 2017 http://data.consilium.europa.eu/doc/document/ST-15431-2017-INIT/en/pdf 

19 Joint industry statement, 1 March 2017, https://www.europeanshippingweek.com/joint-industry-statement-

clia-europe-eba-ecasba-ecsa-empa-eta-etf-euda-interferry-wsc/ 

20 European Community Shipowners’ Association, Newsletter 22 December 2017: A single market for shipping 

– time to make it happen, http://www.ecsa.eu/news/single-market-shipping-time-make-it-happen  

21 https://ec.europa.eu/info/sites/info/files/mobility_and_transport_1.pdf 

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two  initiatives  share  the  same  main  objective,  which  is  to  facilitate  the  communication  of 
regulatory information to authorities in electronic format, but differ in various respects. Such 
differences and similarities are further outlined below. 

The information concerned by the two initiatives has its source in different international, EU 
and Member States legal acts. These legal acts do not overlap between the two initiatives and 
the  information  sets  are  different.  For  example,  the  information  required  for  fulfilling 
maritime  reporting  formalities  includes  cargo  description,  alongside  a  wide  range  of  other 
information  elements  on  the  ship,  its  crew  and  passengers.  The  information  requirements 
under  the  scope  of  the  initiative  on  electronic  freight  transport  information,  while  also 
containing  elements  of  cargo  description,  are  focused  primarily  on  the  transport  operation 
itself – on the identity of the consignor, carrier and consignee, places of pick-up and delivery, 
route and  several  others.  However,  the  two  initiatives  will  ensure the interoperability  of  the 
electronic data concerned, concretely, by prescribing the same data model and syntax for the 
common data elements. 

Geographically,  the  scope  of  the  electronic  transport  document  initiative  begins  where  the 
maritime  reporting  environment  initiative  ends.  The  initiative  on  electronic  freight transport 
information concerns the transport of goods within the EU once these have been cleared for 
entry in the Union, following the process of maritime and customs reporting formalities. The 
proposal on freight transport information will allow the use of electronic documentation not 
just at the point of entry and exit of the EU – where it is already mandatory – but also in the 
following  (or  preceding,  in  case  of  export)  phase  of  inland  transport.  Together,  they  will 
ensure  appropriate  coverage  of  information,  for  the  entire  travelling  span  of  whatever  the 
freight concerned. 

In  terms  of  technical  solutions  envisaged,  the  two  initiatives  require  however  a  different 
approach.  This  is  because  in  the  case  of  reporting  formalities  in  ports,  information  must  be 
submitted  at  a  specific  point  in  time  to  a  pre-defined  set  of  authorities;  in  the  other  case 
(electronic freight  transport documents), information  only  needs to  be available in case  it is 
required  for  inspection.  The  two  initiatives  are  therefore  complementary  and  mutually 
reinforcing. 

The  proposal  for  a  revised  legal  framework  for  reporting  formalities  follows  on  the  Fitness 
check  of  the  Maritime  Transport  Policy  initiated  in  2016  under  the  Commission  REFIT 
programme, which found  the RFD  framework inefficient  and ineffective. The new proposal 
will be aligned with and supportive of the implementation of the Union Customs Code and its 
connected customs IT systems. 

More details on connected policy areas is found in Annex 7 

1.4.  Economic and trade context 

Maritime transport is a backbone of trade and communications within and beyond the single 
market. Almost one third of all intra-EU and three quarters of the internationally traded goods 
(in  tonnes)  are  seaborne.  In  terms  of  value,  about  half  of  EU  international  trade  in  goods  is 
transported by sea.  

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The  number  of  port  calls  by  passenger  or  freight  vessels  in  main  EU-28  ports  in  2016  was 
estimated  at  almost  2.1  million.  Each  year,  around  400  million  passengers  embark  and 
disembark  at  EU  ports.  Sea  transport  turnover  was  EUR  106  billion  in  total  for  EU28  in 
2014.22  

There  are  around  11  000  maritime  transport  enterprises  in  the  EU28  and  around  178  000 
people directly employed in the maritime transport sector23, with another 1.5 million jobs in 
EU ports24, indirectly linked to the sea-borne trade and transport. 

Furthermore, the smooth functioning of port calls is one link in a longer transport chain. Ports 
are not the final destination of goods. The efficiency of the ship port calls, as affected e.g. by 
the efficiency of the reporting environment, will impact on the entire logistics chain and the 
hinterland  transports  of  goods  and  passengers  to  and  from  the  ports,  notably  by  rail,  road, 
inland waterways or pipelines. 

More details on the economic context can be found in Annex 8. 

2.  PROBLEM DEFINITION 

2.1.  What is the problem? 

This initiative addresses the problem of the current inefficient port call reporting environment 
for maritime transport operators (legal reporting requirements for when a ship is to arrive in or 
depart from a port – a port call). 

Vessels  in  international  traffic  (generally  larger  vessels,  shipping  around  63%  of  all 
transported  goods  and  6%  of  the  passengers  going  into  or  out  of  EU  ports25)  are  subject  to 
both customs and maritime transport formalities. They need to submit a series of declarations 
and  notifications  at  different  points  in  time,  starting  with  the  Entry  Summary  Declaration 
(ENS)  with  cargo-related  information,  normally  submitted  even  before  departure  from  the 
third  country  port.  Approaching  the  port  call,  they  must  also  submit  information  and  data 
relating  to  border  controls,  environmental  controls,  safety/security  and  traffic  management. 
Some of these data elements are requested following legal requirements in EU or international 
law, other reporting is requested based on national legislation. Via the port reporting the ships 
may also arrange various port services such as pilotage and logistics for goods management 
(reporting not based on legislative requirements).  

22 European Commission, Statistical pocketbook 2017: EU transport in figures, 
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en  

23 Statistical pocketbook 2017: EU transport in figures 
24 https://ec.europa.eu/transport/modes/maritime/ports/ports_en  
25 Eurostat, Maritime ports freight and passenger statistics, January 2017 

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Vessels in intra-EU traffic ship around 25% of all goods and 33% of the passengers to or from 
EU ports. They too may have to complete customs formalities: if they have left EU territorial 
waters (twelve nautical miles from the coast), if they carry non-EU goods or if they sail under 
a non-EU flag. They must also complete most of the maritime transport reporting formalities 
required  for  the  international  traffic  vessels  as  described  above,  with  possible  exemptions 
from e.g. border controls within the Schengen zone. 

For  vessels  in  national  traffic  (shipping  9%  of  the  transported  goods  and  57%  of  all 
passengers to or from EU ports) there are normally less customs formalities applying, unless 
the  vessel  meets  one  of  the  criteria  mentioned  above  (non-EU  flag,  departing  from  EU 
territorial waters or carrying non-EU goods). The border control reporting normally does not 
information 
apply.  Other  maritime 
submissions must usually be completed. 

transport  reporting  formalities  and  port  service 

Some of the underlying legal acts to the RFD also have exemptions for vessels depending on 
their size, e.g. the Vessel Traffic Monitoring and Information System which does not apply to 
ships of less than 300 gross tonnage. There are also exemptions and simplifications for some 
vessels  in  regular  services  calling  exclusively  in  intra-EU  and/or  national  ports (e.g.  ferries, 
cargo or cruise ships operating on a fixed route). 

The  current  RFD  makes  it  mandatory  for  Member  States  to  request  the  maritime  reporting 
based  on  certain  EU  and  international  legislation  via  the  National  Single  Windows.  The 
national reporting requirements may also be channelled via the National Single Window while 
the large majority of customs formalities are done via separate IT systems. 

Some  shipping  companies  prefer  to  do  their  port  call  reporting  via  automated  machine-to-
machine  reporting  if  available  in  the  port  they  call.  This  is  especially  common  among  the 
large  shipping  operators.  Other  shipping  companies  prefer  reporting  via  graphic  user 
interfaces and uploading information using spreadsheet files, if available in the port they call. 
Many  companies  also  use  ship  agents  to  deal  with  the  reporting  formalities  and/or  cargo 
agents to deal with the customs formalities.  

The  use  of  ship  and/or  cargo  agents  is  often  needed  because  of  the  diverging  reporting 
systems in each Member State and in some cases in each port. 
The current legislative framework was evaluated in 201726. The evaluation concluded that the 
RFD  is  inadequately  effective  and  efficient,  in  spite  of  the  objectives  remaining  highly 
relevant and valid. The evaluation concluded that there is potential for further simplification 
and  burden  reduction  in  this  area.  This  is  also  the  strong  messages  repeatedly  sent  by 
stakeholders, calling for measures to urgently address the situation.  

26 Part of the Fitness check of the Maritime Transport Policy (initiative under the Commission Work Programme 

(REFIT) for 2016) 

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The main barrier emphasised by the shipping operators and stressed in the evaluation, is the 
lack of harmonisation of the maritime National Single Windows and the overall lack of EU-
level harmonisation of all reporting required by a carrier calling a port27. Today, each National 
Single Window looks different. Data formats are different, reporting procedures are different 
and  the  scope  of  reporting  through  each  National  Single  Window  differs.  Some  Member 
States accept machine-to-machine reporting, others provide graphic user interface and accepts 
uploading of spreadsheets  (or receives  spreadsheets per  e-mail). Some  Member States  allow 
reporting  via  port  community  systems  into  the  National  Single  Windows  or  have  delegated 
National Single Window functions to each port (decentralised system). The shipping operators 
thus have to adjust their reporting and their IT software and data sets for each Member State – 
or even for every individual port they call. 

The  non-harmonised  reporting  environment  makes  reporting  a  very  burdensome  and  time-
consuming task for shipping operators. Indeed, the current legal act provides no guidance or 
binding  specifications  to  guarantee  the  development  of  common  data  models,  front-end 
interface or reporting procedures for shipping operators. 

The  consequence  is  an  unnecessary  high  administrative  burden  on  shipping  operators.  The 
majority of the shipping companies replying to the open public consultation on the evaluation 
considered  that  administrative  burden  was  reduced  either  not  at  all  (61%  of  all  shipping 
companies and ship-owners’ associations) or only to a limited extent by the adoption of the 
RFD. According to more than half of all responding shipping operators, the burden has in fact 
increased rather than decreased28, as an effect of the old reporting requests via separate entry 
points often remaining in place in parallel to the new National Single Windows.  

For the national authorities and port operators, this is not a major problem. From the view of 
an  individual  port,  the  information  exchange  with  ships  is  normally  perceived  as  smoothly 
functioning. From the side of shipping companies and maritime transport operators however, 
as 
sometimes 
duplicating/overlapping reporting requests becomes a burden. This is the message repeatedly 
sent from shipping companies and their EU-level associations. 

the  multitude  of  different  and 

to  different  ports, 

they  call 

Every  year,  more  than  2  million  port  calls  are  made  in  the  EU.  For  these  port  calls,  the 
maritime transport operators are obliged to submit a large set of information. The evaluation 
found that on average, the time spent on reporting for one single port call ranges between one 
and three hours. This translates into around 4.6 million staff hours spent on reporting per year 
for all EU port calls. The large majority (90%) of all stakeholders consulted for the evaluation 

27 There is however EU-level harmonisation of data requirements within respective sectors, e.g. the harmonised 
customs  data  requirements  following  the  implementation  of  the  Union  Customs  Code  legislative  package, 
Regulation (EU) No 952/2013 of 9 October 2013 laying down the Union Customs Code (OJ L 269, 10. 10. 
2013). 

28 55% of shipping company respondents: Evaluation of the RFD 

12 

 
 
                                                            
 
and  the  impact  assessment  consider  that  this  time  spent  on  reporting  could  be  substantially 
further reduced by harmonisation and simplification of the reporting environment.  

is 

transport 

than  other 

less  competitive 

transport  modes.  Moreover, 

As  a  consequence  of  the  unnecessary  administrative  burden  facing  the  shipping  operators, 
maritime 
the 
attractiveness  of  the  profession  is  reduced  and  has  been  reported  as  an  important  cause  for 
employee  dissatisfaction  in  the  sector29.  The  lack  of  harmonisation  of  maritime  transport 
reporting creates an obstacle to an efficient and optimised movement of ships and cargo and 
thereby hampers the smooth functioning of the internal market. In the wider perspective, this 
mismatch of administrative proceedings and their low efficiency affects the whole EU logistic 
chain, beyond maritime transport (multimodal transport links; rail, road and inland waterway), 
since  the  overly  burdensome  administration  of  reporting  results  in  less  efficient  logistic 
planning and increased lag time in ports.  
The  issue  is  of  relevance  primarily  for  the  maritime  Member  States30  and  their  authorities 
linked to the maritime National Single Windows; for the maritime transport operators; and for 
all stakeholders involved in and around port operations and port management. The problems 
impact  in  first  hand  on  the  maritime  transport  sector  and  the  shipping  operators.  See  also 
detailed table in Annex 6. 

2.2.  What are the problem drivers? 

The evaluation identified the following drivers:  

Figure 1: Problem tree 

P1.  Diverse  ship  reporting  formats,  interfaces  and  procedures  used  throughout 
the EU 

29 Targeted consultations for the Impact Assessment 
30 Austria, Czech Republic, Hungary, Luxembourg and Slovakia as non-maritime states are not directly affected 

by the directive. 

13 

 
 
 
                                                            
 
the  Commission  should  develop  mechanisms  for 

The RFD did not introduce binding technical specifications for electronic interfaces, but left 
the  implementation  of  the  National  Single  Windows  to  Member  States.  According  to  the 
Directive, 
the  harmonisation  and 
coordination  of  reporting  formalities  within  the  Union,  together  with  the  Member  States31. 
This  was  done:  an  expert  group  on  maritime  administrative  simplification  and  electronic 
information  services  (the  eMS  group32)  developed  some  definitions,  business  rules  and 
guidelines33  and  a  standard  data  set34  in  2015.  The  European  Maritime  Safety  Agency 
(EMSA)  also  developed  a  prototype  of  a  National  Single  Window  and  the  results  are 
transparently  shared  and  made  available,  including  user  manuals  and  templates.  These 
guidelines  and  support  activities  have  however  not  proved  very  effective.  They  are  not 
binding,  nor  very  detailed;  the  guidelines  have  not  hindered  fragmented  implementation  of 
different National Single Window set-ups at Member State level.  Furthermore, the RFD has 
no  mechanisms  to  continuously  develop  and  improve  provisions  for  harmonisation  and  no 
tools for update of the legal framework in step with technical or political developments (e.g. a 
governance system, delegated/implementing acts35). 

industry  association  ECSA  concludes  on 

The absence of binding common standards has led to the introduction of reporting interfaces 
which are technically different for practically each port call36. Data sets and reporting formats 
differ,  sometimes  even  within  a  Member  State.  Data  models  and  interfaces  are  not  aligned 
even between Member States who participated in coordination projects such as AnNa37. The 
European  shipping 
the  reporting  formats 
encountered by their members: “These are not only complex and repetitive, but even worse, 
they are completely unharmonised throughout the EU”.38 The non-harmonisation is especially 
burdensome  for  vessels  calling  into  several  EU  ports  (as  compared  to  vessels  in  national 
traffic or going in liner traffic between the same two ports  – although those vessels are also 
affected by inefficiencies and duplication  of reporting beyond the non-harmonisation issue). 
The non-harmonisation is in particular an issue for vessels in tramp/non-fixed routes traffic, 
calling always into different ports. Tramp traffic vessels make up around 60% of all port calls, 
with around 40% of all port calls being by vessels in liner traffic. 

31 RFD, Article 3:2 
32 http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=2593  
33 National Single Window Guidelines, 17 April 2015, 

https://ec.europa.eu/transport/sites/transport/files/modes/maritime/doc/2015-06-11-nswguidelines-final.pdf  

34 eMS Data Mapping Report, 25 February 2015, 

https://ec.europa.eu/transport/sites/transport/files/data_mapping_report_2010_65_eu_0.pdf  

35 RFD, Article 10: possibility only to adopt delegated acts for the update of the Annex related to the FAL forms 

under IMO. 

36 Evaluation of the RFD, p.16 
37 http://www.annamsw.eu/about.html 
38 European Community Shipowners’ Association: A single market for shipping – time to make it happen 

14 

 
 
                                                            
 
Furthermore,  there  are  many  different  channels  or  interfaces  with  which  the  maritime 
operators need  to  adapt their systems in  order to provide all information  required for a port 
call.  For  one  port  call,  they  might  have  to  send  data  through  National  Single  Windows  in 
XML, through a port community system in EDIFACT and use a third format or data model 
for  national  customs  system.  This  creates  an  expensive  technical  environment  to  maintain. 
This is not a matter of harmonisation of data formats; with the introduction of the new Union 
Customs  Code  legislative  package,  customs  reporting  formalities  have  already  undergone  a 
process of harmonisation at EU level. However, since the harmonised customs formalities are 
requested  in  a  separate  reporting  channel  from  the  maritime  reporting  formalities,  shipping 
operators  state  that  the  total  time  spent  on  reporting  for  them  is  affected  negatively  (see 
further information below in chapter on impacts of options).  

The  existence  of  several  additional  reporting  entry  points  in  parallel  to  the  National  Single 
Window  limits  the  actual  harmonisation  of  reporting.  It  reduces  the  added  value  of  the 
National  Single  Window  for  the  industry,  who  is  faced  with  multiple  reporting  channels 
simultaneously. 

The  situation  of  non-harmonisation  is  highly  unlikely  to  be  solved  only  by  full 
implementation  of  the  current  Directive.  The  RFD  lacks  the  instruments  for  achieving 
harmonisation:  crucially,  it  lacks  the  possibility  of  adopting  binding  specifications.  When 
asked in the consultations, no single Member State replied that they intend to change current 
systems towards harmonisation on the basis of the voluntary guidelines. 

In  such  context,  full  compliance  of  Member  States  with  the  requirements  of  the  existing 
Directive  might  consolidate  a  situation  of  nationally  harmonised  but  EU  differentiated 
reporting systems, which might render even more difficult a further evolution towards a single 
EU approach, as demanded by the industry.   

P2. Diverse ship reporting requirements throughout the EU 

Currently,  the  RFD  reporting  rules  only  concern  some  of  the  formalities  envisaged  by  EU 
legislation and international maritime agreements. National requirements are only reported via 
the  National  Single  Window  on  voluntary  basis  while  some  EU  formalities,  e.g.  related  to 
customs aspects, are only partially included. Currently, some 230 data elements fall under the 
14  formalities  for  mandatory  RFD  reporting  (RFD  Annex  1,  part  A:  EU  legislation  and  B: 
international  obligations).  This  includes  the  core  maritime  transport  reporting  elements  for 
e.g.  safety,  security,  traffic  management,  border  controls  and  waste  control  (environmental 
objectives), as well as the seven standardised IMO forms39 relating to e.g. dangerous goods, 
crew  and  passenger  lists  and  the  general  and  cargo  declarations.  The  data  reported  via  the 

39 The so called “FAL forms”, 

http://www.imo.org/en/OurWork/Facilitation/FormsCertificates/Pages/Default.aspx 

15 

 
 
                                                            
 
National Single Windows thus serve several purposes and covers a broad spectrum of policy 
areas. 

However, in addition to these EU and international reporting obligations, ships are obliged to 
send many additional information elements when calling a port. A large part of the reporting 
burden  comes  from  the  non-harmonised  national  reporting  requirements  that  are  not 
mandatorily  channelled  via  the  National  Single  Windows.  These  requirements  also  differ 
from  Member  State  to  Member  State.  A  Member  State  sub-group40,  together  with  the 
Commission services, is currently mapping the additional data elements derived from national 
legislation (RFD Annex 1, part C), estimated to make up at least 200 additional data elements. 
Moreover,  maritime  operators  must  provide  transport-related  information  required  for 
statistical purposes41.  

In addition, data related to the ships’ cargo are required, primarily by customs authorities but 
also  by  maritime  transport  authorities.  This  data  has  recently  been  mapped  by  the  so  called 
eManifest  pilot  project.  The  project  has  identified  a  cargo  data  set  of  another  150  data 
elements  possibly  required  for  the  fulfilment  of  customs  formalities42  related  to  the 
arrival/departure of a ship from/to an EU port43. The list of customs formalities/functionalities 
requiring  this  information  includes:  Entry  Summary  Declaration,  Arrival  Notification, 
Presentation  Notification,  Declaration  for  Temporary  Storage,  Customs  Goods  Manifest, 
Electronic  Transport  Document  for  simplified  transit,  Re-Export  Notification,  Export 
Summary  Declaration,  and  Exit  Notification  for  Export.  These  customs  formalities  are 
currently  not  channelled  via  the  National  Single  Windows  but  mainly  through  customs  IT 
systems  (national  or  upcoming  EU-level  systems).  Customs  authorities  are  currently 
establishing  a  harmonised  data  set  under  the  implementation  of  the  Union  Customs  Code44 
and an EU-level single access point (the ICS2 shared trader interface for the Entry Summary 
Declaration) is being developed.  

All  data  elements  listed  above  have  already  been  mapped  out  by  the  Commission  in 
cooperation with EMSA and Member States in a single data set, providing an overview of all 
data that may be requested from ships in EU port under the current RFD scope and beyond.  

40 “Correspondence group on Part C data” under the Single Window subgroup to the High-level Steering Group 

for Governance of the Digital Maritime System and Services 

41 Directive 2009/42/EC  
42 The exact number of data elements required will depend on the formalities the ship has to fulfil which in turn 

depends on the previous port and on the nature of goods (union or non-union).  

43 Reported by the carrier or other persons identified by the Union Customs Code as responsible for completion 
of  customs  formalities  It  should  be  noted  that  the  cargo-related  data  elements  must  be  reported  for  each 
consignment/item and could thus amount to a huge reporting load, especially for container ships and general 
cargo ships with a multitude of different consignments on-board. 

44 Customs formalities are harmonised via the implementation of the Union Customs Code legislative package. 

16 

 
 
                                                            
 
Finally,  another  aspect which  presents  a  smaller  problem:  today,  paper  copies  of  a  set  of  at 
least 100 ship certificates such as Certificate of Registry and Certificate of Class are kept on-
board  ships  to  provide  proof  that  the  vessels  are  compliant  with  various  regulations  and 
conventions.  The  management  and  keeping  of  paper  certificates  is  often  seen  as  an 
administrative  burden  and  an  area  where  digitalisation  could  bring  further  benefits.  Paper 
certificates are also exposed to forgery and fraud which could be avoided with digitalisation, 
provided that relevant cyber-security measures are introduced. 

Bringing  in  a  more  comprehensive  data  set  into  the  coordinated  and  harmonised  reporting 
environment would require changes to the RFD. The current legal framework does not have 
the update mechanisms to allow a broadening of the data set. 

More detailed information on the data elements within and beyond the current scope of RFD 
can be found in Annex 5. 

P3. Unclear legal framework for sharing and using reporting information  

Today, data flows are suboptimal and duplicate reporting takes place because of lack of data 
sharing between authorities. 

The  data  provider  –  e.g.  the  carrier  or  the  agent  appointed  as  their  representative  for  these 
purposes – today submits through the National Single Windows a set of data including both 
static  and  dynamic  data.  The  static  data  can  be  broken  down  into  two  subcategories: 
permanent static and temporarily static data elements. Information which does not commonly 
change  (identification  and  particulars  such  as  tonnage)  is  considered  permanent  static.  The 
information  which does not usually change between the departure and arrival ports, such as 
crew  and  passenger  lists,  or  hazardous  cargo  information,  is  considered  temporarily  static 
information.  The  dynamic  information,  such  as  waste  on  board,  cargo  or  estimated  arrival 
time, is the one that changes regularly.  

There are two main aspects of reporting the same data only once. First, there is the issue of 
the same data often being requested several times within the same port call. Respondents in 
the  consultations  (in  particular  shipping  companies  and  ship  agents)  stressed  that  multiple 
reporting is a fact.  In  some ports (28% of respondents even claim:  in  most ports), maritime 
operators  are  required  to  report  the  same  information  (static  and  dynamic)  separately  to 
different  authorities  when  calling  a  port.45  Sometimes  the  reason  is  vertical  silos:  the 
authorities  act  independently  without  coordination.  Sometimes  there  is  a  horizontal  issue 
where  central  authorities  fail  to  share  data  with  local  ones.  This  means  that  many  Member 
States and ports still have an inefficient data sharing environment where reported data is not 
sufficiently  channelled  to  all  relevant  data  recipients.  Reporting  only  once  within  the  same 
port supports efficiency of reporting but also to some extent contributes to burden reduction 

45 Evaluation of the RFD, p.36 

17 

 
 
                                                            
 
for the shipping operator by minimising duplication of work, as described in the Commission 
Study  on  eGovernment  and  the  Reduction  of  Administrative  Burden  by  EY  and  DTI  from 
201446. The reporting-only-once was an objective mentioned already in the current RFD but 
not  achieved;  the poor implementation  of the current provisions is at least  partly a result of 
unclear Directive provisions providing insufficient instructions.  

The second aspect is the “reporting only once” enabling the re-use of static data from one port 
call to another (also not sufficiently addressed in the current RFD). This is not taking place at 
all  today,  except  in  a  few  pilot  project  cases  of  exchange  services  between  ports  with 
connected  systems.  These  pilot  projects  show  that  the  re-use  of  unchanged  data  would  in 
principle  be  possible,  assuming  that  data  protection  and  data  quality  rules  are  respected 
throughout  the  data  exchange  chain4748.  Lack  of  re-use  of  data  between  ports  is  a  missed 
opportunity for simplified reporting for shipping operators (e.g. enabling pre-filled forms or 
transforming  the  departure  form  from  one  port  into  the  arrival  form  for  next  port).  This 
especially  makes  some  difference  for  smaller  shipping  operators  reporting  manually  (via 
graphic user interface) where any duplication in reporting obligations means some time lost. It 
also  increases  the  complexity  of  port  calls  for  ships  with  small  crews.  In  the  consultations, 
81%  of all respondents expect to  have some or  high  benefits from data re-use, with highest 
focus on the need for data re-use among shipping operators and ship agents. 

However,  the  reporting  only  once  between  ports  is  also  about  missed  opportunities  for  the 
wider chain of transport logistics. The current lack of data sharing between ports (within and 
beyond a Member State) means that business potential for more efficient procedures for ports 
and for authorities is untapped. Access to this information would in many cases be quicker for 
these stakeholders by way of interconnecting the existing reporting systems rather than only 
requiring all updates directly from the vessels. 

It should also be noted that some information reported to the National Single Windows today 
is  already  exchanged  between  the  Member  States  through  SafeSeaNet49.  However,  the 
Member  States  have  reported  that  they  do  not  use  this  data  for  reduction  of  reporting 
duplications by ships, in spite of the possibility offered in the RFD50. 

46 https://ec.europa.eu/digital-single-market/en/news/final-report-study-egovernment-and-reduction-

administrative-burden-smart-20120061 

47 See for example the IPCSA Network of Trusted Networks project with web service for exchange of port to port 

exchange of data. 

48 See also “The Once Only Principle” (TOOP) project within the EU eGovernment Action Plan 2016-2020. The 
aim of TOOP is to ensure that information can be supplied to public administrations only once regardless of 
the company's country of origin. This principle is promoted to eliminate unnecessary burdens for European 
businesses by avoiding that they are asked to present the same data and documents repeatedly. 

49 RFD: Article 6 
50 RFD: Article 9 

18 

 
 
                                                            
 
Re-use  and  efficient  sharing  of  data  within  the  context  of  the  RFD  is  today  hampered 
primarily by unclear or missing specifications on data definitions and use/re-use. Authorities’ 
obligation  to  share  data,  even  for  the  same  port  call,  is  not  clearly  enough  specified.  The 
vague  provisions  of the  RFD  have  therefore  not  supported the  objective  of  moving  towards 
the “reporting only once”; this is a clear shortcoming of the current Directive. 

Furthermore, recipients of cargo or ship information are reluctant to share data since the legal 
framework – as regards aspects of data control, confidentiality, liability and access rights – is 
perceived as unclear. The current RFD does not provide sufficient specifications and support 
on  this.  For  example,  concerns  regarding  the  interpretation  of  the  General  Data  Protection 
Regulation  have  been  voiced  in  several  of  the  consultation  events51,  with  data  recipients 
uncertain  about  how  to  deal  with  potentially  sensitive  personal  data  elements  such  as 
passenger  lists  or  crew  personal  data.  Clear  rules  for  accessing  data  are  also  missing, 
according to consulted stakeholders52.  

This has an impact also on the information which is commonly considered as open data, such 
as  departure  and  arrival  times  which  could  be  of  value  for  efficiency  gains  throughout  the 
multimodal transport chain. There is today no uniform application on how this data should be 
treated. Some Member States make it public but only locally through port information boards, 
other share it via Internet. The inconsistent approaches reduce the possibility of using this data 
for multimodal transport management. 

These  issues  would  not  be  solved by  full  implementation  of  the  current  Directive;  the  RFD 
does not provide sufficiently clear provisions to achieve these objectives on its own and in its 
current form. 

P4. Inadequate implementation of current legislation 

The  unspecific  definitions  and  provisions  of  the  Directive  have  in  turn  also  hampered 
implementation and enforcement of the directive. The slow implementation of the RFD is not 
the  core  problem  for  shipping  operators  (and  full  implementation  would  not  solve  problem 
drivers 1-3, as described above), although it does contribute to the complexity of the reporting 
environment. 

It is telling that operational National Single Windows are still under implementation in eight 
of  the  23  maritime  Member  States.  In  addition,  even  where  there  are  National  Single 
Windows implemented, there are not always national procedures, national technical standards, 
or an actual single entry point for reporting. A likely reason for the diverse interpretations of 

51  E.g.  Report  from  consultation  event  with  the  HLSG  expert  sub-group  meeting  on  Single  Window,  Brussels, 

26th October 2017; Consultation synopsis report, Annex 2 

52  Consultation  workshop:  Moving  towards  a  European  Maritime  Single  Window  environment  –  what  road  to 

take? Digital Transport Days, Tallinn, 8 November 2017; Consultation synopsis report, Annex 2 

19 

 
 
                                                            
 
the  current  RFD  is  that  the  provisions  are  extremely  vague,  giving  very  little  guidance  or 
direction to Member States, who could reasonably claim they are not in principle failing their 
obligations. 

Ultimately, Member States have not had sufficiently hard incentives to establish their national 
single  windows  in  a  harmonised  way.  Considering  that  technical  assistance  and  voluntary 
guidelines have been offered but not widely applied, lack of resources, know-how or time are 
not  assessed  to  have  been  the  main  barriers  to  implementation.  It  seems  rather  to  be  the 
absence of binding specifications and clear instructions causing the uncertainties.  

Furthermore,  the  provisions  have  been  too  vague  to  support  the  Commission  in  pursuing 
infringements or other follow-up procedures.  

The  effect  of  the  slow  and  uneven  implementation  of  the  RFD  was  to  create  additional 
differences  between  the  reporting  environments  from  one  Member  State  to  the  next, 
aggravating the core problems as described above under drivers 1-3. 

2.3.  How will the problem evolve? 

The  RFD  does  not  provide  binding  technical  specifications  for  harmonised  reporting 
interfaces  or  to  include  new  or  missing  EU  or  national  reporting  obligations.  The  current 
situation with diversity of reporting procedures, formats and interfaces is unlikely to change 
in the future without EU level interventions53.  

The existing structures for exchange of best practices between the Member States54 have not 
so  far  been  effective  for  delivering  harmonised  implementation  of  the  National  Single 
Windows.  Guidelines  have  been  developed  in  close  cooperation  with  Member  States  and 
technical assistance for implementation has been offered via EMSA. Quantitative estimates of 
the impact of these initiatives, in particular the uptake effect of the EMSA prototype, are not 
available  but  the  Member  States  indicated  in  the  consultations  that  no  further  changes  to 
current systems are planned as a result of these activities. For the shipping operators, the 
administrative  burden  linked  to  lack  of  harmonised  single  entry  point(s)  and  lack  of 
harmonisation of data requirements will therefore remain high: in total 50 million staff hours 

53 At international level, the IMO application of Standard 1.3 bis to the FAL Convention should be in place by 8 
April 2019, requiring all IMO member countries to establish systems for electronic exchange of information 
by that date (Source: 
http://www.imo.org/en/OurWork/Facilitation/Electronic%20Business/Pages/default.aspx). This will 
however not affect EU Member States since this electronic reporting is already mandatory under the RFD 
and the IMO Standard does not introduce any common technical requirements. The Commission has offered 
to assist the IMO in developing a harmonised reference system by donating the National Single Window 
prototype specifications and documentation to the IMO. However, no decision has been taken on their side 
to pursue that development.  

54 The High Level Steering Group on Governance of the Digital Maritime System and the eMS group 

20 

 
 
                                                            
 
are  estimated  to  be  spent  on  reporting  during  the  baseline  period  (EU28).  In  addition,  new 
challenges and issues will emerge, risking render the current legal framework out of date. 

More information on how the situation is likely to evolve until 2030 can be found in section 
5.1. 

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

Article 100 (2) of the Treaty stipulates that "The European Parliament and the Council, acting 
in  accordance  with  the ordinary  legislative  procedure,  may  lay  down  appropriate  provisions 
for sea and air transport." 

3.2. 

Subsidiarity: Necessity of EU action 

The  legitimate  rights  of  Member  States  to  manage  and  develop their  port reporting  systems 
must  not  unduly  restrict  the  proper  functioning  of  the  internal  transport  market.  Maritime 
transport is to a large extent a single market concern; only 9% of the seaborne trade in the EU 
is  national,  compared  to  25%  and  66%  for  respectively  intra-EU  trade  and  extra-EU  trade. 
Moreover,  the  ports  are  not  the  final  destination  of  the  goods  and  via  the  hinterland 
connections a large part of the goods going through ports either comes from or continues to 
another  Member  State.  It  is  therefore  in  the  interest  of  the  Union  to  ensure  the  smooth 
functioning of ship port calls, for the sake of the wider internal transport market and for the 
considerable economic investments and cross-border business interests linked to the sector.  

The  problems  addressed  by  this  initiative  –  inefficient  reporting  environment  for  shipping 
operators  in  connection  to  a  port  call,  resulting  in  cumbersome  administration  for  transport 
operators – are unlikely to be solved sufficiently by Member States in the framework of their 
national  constitutional  systems  (necessity  test)  as  the  maritime  transport  is  a  highly 
international sector. Policies developed and implemented on a national or sub-national level 
are  unlikely  to  produce  solutions  harmonised  at  the  EU  level  (compare  with  successfully 
harmonised customs formalities thanks to Union Customs Code EU-level legislative package) 
and cannot efficiently address the  cross-border information exchanges. Fragmented national 
legislation  and  transport  systems,  often  incompatible  with  each  other,  lead  to  a  sub-optimal 
situation as far as the Internal Market in maritime transport is concerned. 

The inadequacy of voluntary harmonisation measures has also been clearly shown in the past. 
The existing non-binding guidelines and the regular interaction between Member States have 
not improved the situation and have not resulted in less fragmentation.  

21 

 
 
Stakeholders  widely  agree  with  this  assessment,  as  expressed  in  the  consultations  where  a 
majority of respondents (74%) in the open public consultation stated that these issues should 
be  addressed  on  the  EU  level  (87%  of  the  shipping  companies  and  ship  masters;  69%  of 
responding  Member  States).  82.5%  of  the  respondents  believed  that  the  actions  should  be 
mandatory  (97%  of  shipping  companies  and  shipmasters;  67%  of  Member  States).  Most 
respondents  believed  that  only  soft  measures  will  have  low  effectiveness,  and  hence  bring 
very limited benefits.55  

It could in principle also be considered to act on the matter primarily on the international level 
and  via  the  IMO.  However,  the  IMO  only  works  by  voluntary  implementation  and  non-
detailed specifications and has no mechanism for enforcement. While the IMO does address 
some of the ship reporting aspects such as the reporting formalities specified under the FAL 
Convention, the IMO does not address other of the policy areas covered by EU law56. Action 
only at international level will not bring added value for EU maritime transport operators with 
regard  to  the  reporting  environment.  On  the  contrary,  it  is  usually  the  EU  that  pushes  the 
development  of  the  IMO  framework  by  being  a  forerunner  in  adopting  more  effective, 
efficient  and  harmonised  rules;  going  further  than  the  lowest  common  denominator 
agreements  in  the  international  forum.  The  harmonised  reporting  environment  was  not 
achieved by voluntary action at EU-level and it is highly unlikely that better results could be 
achieved by similar non-binding action via the international organisations. 

3.3. 

Subsidiarity: Added value of EU action 

The proposed action can be better achieved at Union level than at national level as substantial 
results can only be achieved by a coherent framework addressing pan-European needs. 

The  development  and  implementation  of  common  standards  and  facilities  need  to  be 
coordinated  and  aligned  along  with  the  other  relevant  EU  and  international  initiatives  and 
technological  developments  as  well  as  socioeconomic  developments.  This  work  would 
normally primarily be done in the context of the underlying legal acts and the resulting data 
requirement agreements subsequently taken up in the RFD framework for the coordination of 
reporting.  Such  a  framework  permitting  and  ensuring  the  required  connections  and 
complementarity with the various existing reporting systems as well as development towards 
common data definitions can only be created at EU level. No international body provides an 
alternative  forum  for  creating  the  coordination  mechanism  for  the  comprehensive  body  of 
ship reporting requirements under international, EU and national legislation. 

55 Consultation synopsis report, Annex 2 
56 The IMO reporting standards do not cover all specified requirements set in the EU law. For example, FAL 5 
and 6: crew and passenger lists do not include the Schengen Border Code visa requirements and FAL 2: 
Cargo declaration is missing the information required by the Union Customs Code on the Union status of 
the goods. 

22 

 
 
                                                            
 
The European Union is in a privileged position to offer leverage and propagate best practices 
and  common  standards  for  harmonisation,  to  promote  cross-border  cooperation,  and  to 
facilitate the establishment of a wide market for digitalised transport services. 

The  competition  between  ports  is  strong  and  the  port  community  often  protective  of  its 
independence and individual competitive advantages. Only by acting at the EU level can the 
level playing field and the European Maritime Transport Space without Barriers be ensured.  

As is shown in the analysis of impacts below, action at EU level to achieve full harmonisation 
could result in an administrative burden reduction of 50-75%57 of the staff hours currently lost 
on  overly  cumbersome  reporting  procedures,  with  additional  indirect  benefits  in  terms  of 
possible  faster  turn-around  time  in  ports,  better  logistics  chain  predictability,  higher  job 
satisfaction  among  staff  and  gains  in  terms  of  more  staff  hours  released  for  e.g.  safety  and 
business related processes on-board. 

In addition, the initiative offers potential for further contributing to the efficiency of the entire 
Single  Market  multimodal  transport  chain  by  enhancing  information  flows  and  reducing 
potential  bottle-necks  in  connection  to  port  calls.  There  are,  in  particular,  opportunities  for 
added value in exploiting the data sharing aspects of the proposal to enable future cross-modal 
information  exchanges  and  by  ensuring  that  the  harmonised  data  formats  support 
interoperability across the transport modes. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The general objective of the initiative is to contribute to the smooth functioning of the single 
market and facilitate trade and transport by addressing the currently cumbersome and diverse 
reporting procedures for ships calling EU ports.  

This  means  a  well-functioning,  harmonised  and  future-proof  digital  reporting  environment 
enabling  interconnectivity  and  coordination  of  transport  and  customs  related  reporting,  to 
improve the efficiency, attractiveness and environmental sustainability of maritime transport 
while  contributing  also  to  the  integration  of  the  sector  to  the  digital  multimodal  logistics 
chain. 

4.2. 

Specific objectives 

The  initiative  will  contribute  to  the  general  objective  by  pursuing  the  following  specific 
objectives: 

57 Depending mainly on traffic type: fixed route or non-fixed route transports, affecting average reporting times 

and expected benefit of harmonisation. For more information on methodology, see Annex 4 

23 

 
 
                                                            
 
  To  harmonise  reporting  procedures,  interfaces  and  data  formats  in  order  to 
support  the  European  Maritime  Transport  Space  without  Barriers.  This  objective 
addresses  the  problem  driver  of  diverse  ship  reporting  procedures,  interfaces  and 
formats. 

  To reduce administrative burden in ship reporting by providing a single entry point, 
thereby  boosting  efficiency,  competitiveness,  jobs  and  growth  in  maritime  transport, 
ports and in connected sectors along the entire logistics chain. This objective addresses 
the problem driver of diverse ship reporting.  

  To  contribute  to  increased  efficiency  of  digital  reporting  for  maritime  operators  by 
facilitating  data  sharing/reuse  for  the  application  of  the  “reporting  only  once” 
principle.  This  will  in  turn  contribute  to  the  establishment  of  the  Digital  Single 
Market by removing legal uncertainties in the digital maritime transport environment, 
such  as  access  to  and  transfer  of  open  data,  data  liability,  interoperability  and 
standards, while taking in account relevant legal frameworks such as the General Data 
Protection  Regulation  (GDPR)58  and  the  Regulation  on  electronic  identification  and 
trust services (eIDAS)59. This objective addresses the problem driver of unclear legal 
framework for data sharing. 

  By adopting a clearer legal framework in line with the objectives above, with detailed 
provisions and binding technical specifications, the main barriers to implementation of 
the current RFD will be removed and the success rate of the new proposal is expected 
to be substantially higher than for the RFD. 

58 Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data 

and on the free movement of such data (General Data Protection Regulation) 

59 Regulation (EU) No 910/2014 on electronic identification and trust services for electronic transactions in the 

internal market 

24 

 
 
                                                            
 
Figure 2: Objectives 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed (Option 0)? 

Under this option the Commission would continue to rely on the existing framework, without 
undertaking  further  action  to  address  the  weaknesses  identified.  Without  EU  level 
harmonisation,  the  reporting  burden  from  a  non-harmonised  reporting  environment  is 
expected to  remain  unchanged.  The  baseline  period  has  been  set  to  2020-2030,  in  line  with 
that of other initiatives of the 3rd Mobility Package. There is no possibility of implementation 
earlier than 2020; beyond 2030 technical developments are expected to substantially change 
the overall reporting environment in unforeseeable ways. 

The soft measures assumed to be continued in the baseline scenario (e.g. technical assistance, 
voluntary  guidelines)  would  not  be  effective  on  their  own,  as  already  proven  by  past 
experience.  In  the  consultations,  Member  States  were  asked  whether  they  plan  to  develop 
their existing systems towards a more harmonised format on the basis of the existing support 
mechanisms from the EU.  

In this respect, it is noteworthy that no single Member State replied that they planned any 
such  changes.  Harmonisation  is  therefore  not  expected  to  take  place  in  the  baseline  period 
without additional EU action  and the current  problem are therefore unlikely  to  be solved in 
this  scenario.  This  includes  exchanging  and  using  data  and  information  for  reduction  of 
administrative burden and improving efficiency. Data re-use is expected to remain low due to 
the  continued  legal  uncertainties  on  rights  to  use  and  share  the  information  and  the  lack  of 
clear mandatory obligation on Member States to enable such data re-use.  

25 

 
 
 
In the baseline scenario60, the significant growth of the overall activity of the transport sector 
including  shipping  is  projected  to  continue,  driven  by  global  economic  and  trade  growth. 
These  developments  concern  both  passenger  and  freight  transport  with  maritime  freight 
transport  projected  to  grow  at  higher  rates  than  passenger  transport,  following  more  closely 
the  GDP  developments  and  the  increasing  demand  for  traded  goods.  International  maritime 
activity (including both intra-EU and extra-EU) would grow by more than 70% between 2010 
and 2050 (1.4% per year). For the cruise sector, a steady growth has been reported during the 
last decade and is expected to continue based on data from CLIA61. In addition, a 50% growth 
of  cargo  handled  in  EU  ports  is  projected  by  2030  according  to  a  study  of  the  European 
Parliament62. The modal share of maritime transport has remained fairly steady over time and 
is not projected to change significantly by 2050. 

The  expected  growth  of  trade  and,  subsequently,  in  volumes,  is  however  not  expected  to 
increase  the  number  of  port  calls.  The  trend  towards  growing  average  ship  size  is  likely  to 
continue, with large-capacity and large-scale ships being increasingly in demand, notably for 
sake of economics of scale. This development will affect the total number of future port calls: 
larger ships will be able to carry the increased volume of cargo; therefore, the number of port 
calls will slightly decrease over time: by about 2% from 2020 to 2025 and by 1.3% from 2025 
to  the  projected  2.02  million  port  calls  in  2030.  Growth  of  ship  size  is  most  visible  in  the 
container  segment,  with  an  average  ship  size  increase  of  about  5%63,  and  in  the  cruise 
segment, with an annual increase of about 4%.64 For other ship types, the size is projected to 
remain  relatively  stable  over  time,  in  line  with  the  historical  developments.  For  authorities, 
continued digitalisation of government services and systems, as monitored via the EU Digital 
Economy and Society Index65, is expected to continue, generating some benefits in terms of 
efficiency and simplification for ship reporting. The adoption rate however commonly varies 
with some Member States significantly more prone to quickly apply digital frameworks and 
others lagging behind. EU level digitalisation initiatives such as on eDelivery66 for secure and 

60 The baseline scenario used for this impact assessment draws on an update of the EU Reference scenario 2016 

and has been developed with the PRIMES-TREMOVE model by the ICCS-E3MLab. 

61 CLIA, 2017 State of the Cruise Industry outlook and Cruise Travel Trends Outlook, 

https://www.cliaeurope.eu/index.php?option=com_content&view=article&id=102:clia-releases-2017-state-
of-the-cruise-industry-outlook-and-cruise-travel-trends-forecast&catid=8&Itemid=111  

62 European Parliament; Directorate General for Internal Policies, Modal share of freight transports to and from 

EU ports, 2015, p.38, 
http://www.europarl.europa.eu/RegData/etudes/STUD/2015/540350/IPOL_STU(2015)540350_EN.pdf 

63 Eurostat; UNCTAD shipping statistics; https://www.statista.com 
64 ISL (2016), Shipping statistics and market review 2016, volume 60 - No. 8; 

http://www.cruiseindustrynews.com/cruise-industry-analysis/orderbook-data.html 

65 Digital Economy and Society Index 2017, https://ec.europa.eu/digital-single-market/en/desi  
66 https://ec.europa.eu/cefdigital/wiki/display/CEFDIGITAL/eDelivery  

26 

 
 
                                                            
 
reliable  exchange  of  data  and  documents  as  well  as  Horizon  2020  Information  and 
Communication Technologies67, may help push a more even implementation rate. 

The  average  time  estimated  by  shipping  stakeholders  in  the current  system  is  1-3  hours  per 
port  call.68  The  wide  range  is  explained  by  the  very  different  reporting  burden  notably  for 
vessels in tramp traffic69 (60% of all port calls; mainly general cargo and bulk vessels of less 
than 10 000GT) compared to fixed route traffic (40% of all port calls; mainly other types of 
vessels and larger bulk vessels). These tramp /non-fixed route operators typically make port 
calls in multiple ports and multiple Member States, facing a higher burden of non-harmonised 
reporting  (estimated  average  3  hours  per  port  call).  Fixed  route  transport  (e.g.  ferries)  and 
large liner vessels typically call in same and few ports and have lower average reporting times 
(estimated average 1 hour per port call). The non-fixed route operators typically run smaller 
vessels but make up 60% of all the port calls and a very high share of the total time spent on 
reporting in the EU. 

When applying the more specific reporting time estimates for these different vessel and traffic 
types,  the  resulting  estimate  is  a  total  of  4.6  million  hours  spent  currently  on  reporting  per 
year for all EU port calls. Despite the slight reduction in the total number of port calls over 
time (see section 2.4), the number of hours spent for reporting is projected to remain high, at 
4.4  million  hours  by  2030.  For  the  entire  baseline  period  2020-2030  and  for  EU2870,  50 
million  hours  are  estimated  to  be  spent  on  reporting,  equivalent  to  around  EUR  1.5  billion 
expressed as present value in 202071. 

The current National Single Windows cost on average 265 000 per Member State and year in 
operational  and  maintenance  costs.  Taking  into  account  the  above  presentation  of  projected 
problem  evolution,  development  of  number  of  port  calls  and  the  time  spent  on  reporting  in 
each port call, the baseline cost for the National Single Windows for EU28 over the entire 
baseline  period  is  estimated  at  EUR  108  million  (for  the  detailed  cost  calculations,  see 
Annex 4). 

The option of remaining at status quo also received very low support (7%) by all respondents 
in the consultations. 

67 Horizon 2020: Information and Communication Technologies, 

https://ec.europa.eu/programmes/horizon2020/en/h2020-section/information-and-communication-
technologies 

68 Depending primarily on type of traffic and vessel: fixed route/liner or non-fixed route/tramp traffic. 
69 Non-fixed route traffic 
70 Only actually impacting the maritime Member States in a EU28 scenario; all costs have also been calculated 

for an alternative non-UK EU27 scenario, see chapter 6 and Annex 4. 

71 Calculation based on a value of staff hour estimated at 38.35 € according to ECSA. 

27 

 
 
                                                            
 
5.2.  Design of policy options 

A number of decisions were made as point of departure for identifying viable policy options. 
These choices have been made as a result of the consultations and following discussions with 
Commission and external experts. The purpose was to define at an early stage what solutions 
would  solve  the  problems  identified,  be  realistic  and  sufficiently  acceptable  to  the  main 
stakeholders. 

1.  In order to address the problem of inefficient reporting environment for ships, the main 
options  considered  here  are  building  on  the  already  existing  framework  (National 
Single Windows structure). This was a demand from Member States in the consultation 
event  in  October  201772.  Options  that  would  require  an  entirely  different  set-up  have 
therefore been discarded from consideration as it would be inefficient – and unacceptable 
to  a  main  stakeholder  group  –  not  to  make  use  of  the  investments  and  efforts  already 
made. As mentioned in chapter 1, the National Single Windows perform two bundles of 
functionality:  data  collection  from  the  front-end  users  (shipping  operators)  and  data 
distribution  to  the  back-end  authorities  (data  recipients).  The  present  initiative  is 
concerned  with  the  harmonisation  of  the  reporting  gateways,  but  does  not  change  the 
connections to the back-end authorities beyond enabling more efficient data distribution 
and data sharing. 

2.  The  new  and  harmonised  reporting  gateway  should  be  offered  as  a  reporting  path 
always available for shipping operators and accepted by authorities, in line with the 
strong request from the shipping industry and as a trade facilitation measure. This does 
not mean that other reporting entry points must be banned, but only that if data providers 
choose  to  use  the  EU-level  harmonised  maritime  transport  gateway  to  submit  their 
reporting  formalities,  data  recipients  must  accept  those  submitted  reports  and  refrain 
from requesting additional and separate reporting.  

There are two main reasons for not forcing the closure of all other reporting entry points 
beyond  the  digital  harmonised  maritime  reporting  gateway.  First,  it  would  be  highly 
difficult  to  determine  e.g.  who  should  be  included  in  the  scope  for  reporting  via  this 
harmonised reporting gateway for maritime transport and who may use e.g. the customs 
IT systems directly. The maritime transport sector is highly heterogeneous and reporting 
requirements  differ:  some  report  all  of  the  data  elements,  some  (e.g.  small  vessels  or 
operators  on  regular  lines)  have  exemptions.  Some  split  their  data  sets  by  having  the 
cargo data reported via cargo agents, other report everything together. There is no sharp 
line between economic operators primarily affected by the maritime transport reporting, 
those  primarily  managing  the  customs  formalities,  and  those  concerned  with  both.  For 

72 Consultation with the High Level Steering Group: Single Window Subgroup, 26 October 2018 

28 

 
 
                                                            
 
those actors mostly working with the cargo issues, it will be easier to continue reporting 
straight  into  the  customs  IT  systems;  this  possibility  must  therefore  remain  for  them. 
Second,  Member  States  may  want  to  offer  a  national  entry  point  for  the  vessels  only 
active in national traffic (9% of maritime freight transport). If they find this convenient 
there is no reason for the Union to forbid such duplication. It may serve a purpose to give 
SMEs  in  national  traffic  a  more  local  reporting  path,  especially  in  the  case  of  an  EU-
level  central  gateway  option.  It  is  assumed  that  such  national  alternatives  would 
primarily be interesting in the short-term and as a transition period since, following the 
consultations,  it  is  clear  that  the  great  majority  of  shipping  operators  will  prefer  the 
offered  EU-harmonised  option.  For  the  possibility  to  report  directly  to  the  individual 
back-end  authorities  and  IT  systems,  this  would  not  entail  duplication  of  systems.  A 
decision to maintain alternative reporting systems in the National Single Windows will 
rest entirely with the Member States. 

3.  The  National  Single  Windows  should  remain  a  coordination  mechanism,  serving 
primarily  as  a  router  (with  technical  converter  between  data  formats  where  needed)  to 
pass  two-way  information  between  the  maritime  transport  operators  and  the  data 
recipients  (e.g.  port  authorities,  customs  interfaces  and  IT  systems,  border  control 
authorities, the SafeSeaNet, statistics authorities) with the aim to facilitate reporting for 
the maritime industry. The  harmonised reporting gateway will not process data beyond 
data  format  translations/transformation,  first  data  quality  checking,  certain  (temporary) 
data  storage  for  technical  purposes  or  other  procedures  necessary  to  smoothly  link  the 
data  from  providers  to  recipients.  All  final  processing  will  continue  to  be  done  by  the 
specialised  systems  of  the  connected  data  recipients.  The  reason  for  this  assumption  is 
first, to avoid building new systems on top of the already functioning ones for the sake of 
costs  and  proportionality,  and  second  to  avoid  incoherence  and  interference  with  the 
back-end  systems  where  the  data  processing  normally  takes  place.  The  objective  of 
adding  the  harmonised  reporting  gateway  is  not  to  change  the  functionalities  that 
National  Single  Windows  and  specialised  systems  already  perform  satisfactorily,  but 
only  to  ensure  a  simplified  and  harmonised  front-end  of  reporting  to  reduce  shipping 
operators’ burden. 

4.  The  initiative  will  not  create  new  reporting  requirements  but  will  coordinate  the 
reporting  between  the  data  providers  in  the  maritime  transport  sector  and  the  data 
recipients  as  specified  in  the  underlying  legal  acts  referred  to  in  the  revised  legal  act. 
This  may require translation  of data formats in  order  to  ensure a harmonised front end 
reporting (from the maritime transport operators) as well as reporting output at the back-
end (to the connected entities and authorities receiving the data). Any reporting requests 
via  the  harmonised  reporting  gateway  shall  fully  respect  the  applicable  technical 
specifications  of  the  underlying  legal  acts  and  IT  systems  supporting  these  underlying 
legal  acts  (e.g.  customs  legislation,  SafeSeaNet  requirements  specified  in  the  VTMIS 
Directive,  etc.).  This  design  principle  follows  on  clear  demands  from  both  shipping 
operators and Member States. 

5.  The new reporting  environment  must  ensure  clear and fair division  of  responsibility 
and  accountability  for  all  connected  entities,  including  guarantee  of  the  National 

29 

 
 
Competent  Authorities’73  full  responsibility  and  liability  for  the  intermediary 
services  of  the  National  Single  Windows  vis-à-vis  both  the  data  providers  and  the 
connected  data  recipients  (e.g.  functional  and  legal  responsibility,  high  availability, 
ensuring  two-way  flows  of  information,  etc.).  This  is  a  logical  point  of  departure  for 
enabling  a  comprehensive  scope  and  the  well-functioning  interconnection  of  maritime 
and customs reporting environments. 

5.3.  Description of policy measures and options 

Taking  into  account  the  principles  mentioned  above  and  following  the  results  of  the 
consultations with the relevant stakeholders, a number of possible measures were identified. 
To address the first and the second driver, several possible mutually exclusive solutions have 
been  identified.  In  addition,  some  measures  are  necessary  to  ensure  a  proper  and  well-
functioning  framework.  These  measures  are  common  for  all  the  options  (complementary 
measures).  

Mutually exclusive measures (alternative) 

Problem Driver 1: Diverse ship reporting formats, interfaces and procedures used throughout 
the EU 
No. 

Policy measures A-D 

Alt. A  Harmonised reporting gateways as front-end to the National Single Windows (NSWs): 

based on binding technical specifications  
Introduce  binding  harmonised  requirements  and  technical  specifications  for  the  front-end 
reporting  gateway  in  the  existing  NSWs  in  the  Member  States.  The  specifications  would 
cover  e.g.  data  content,  message  structure  format,  exchange  protocols,  user  interface 
requirements and other rules as necessary for ensuring the necessary information exchanges 
business  rules.  They  would  be  set  at  EU  level  but  responsibility  for  implementation  and 
operation would be fully on the Member States. The result would be a decentralised system 
of NSWs with identical reporting gateway functionalities for ship reporting. 

Alt. B  Harmonised reporting gateways as front-end to the National Single Windows (NSWs): 

based on common IT solution  
Develop  a  mandatory  common  harmonised  reporting  gateway/  front-end  interface 
component  (IT  solution)  at  EU  level,  for  installation  in  every  NSW.  Regular  updates  as 
required would be supplied via the EU. The operational responsibility would be on Member 
States but with helpdesk functions for the software installation at EU level. The result would 
be a decentralised system of identical reporting gateways in every Member State. 
Alt. C  Central  European  level  reporting  gateway:  introduction  of  a  centralised  European 

Maritime Single Window 
Introduce  a  centralised,  EU-level  reporting  gateway  /  front-end  interface  (European 
Maritime  Single  Window).  The  centralised  reporting  gateway  would  offer  one  single 
reporting entry point for all port calls throughout the EU including the necessary two-way 

73 The Member State authority charged with hosting and operating the National Single Window 

30 

 
 
                                                            
 
information exchanges between the data providers and the back-end connected entities and 
systems. The NSWs would remain in place as the router  between the centralised reporting 
gateway  and  the  national  level  data  recipients.  Member  States  would  be  responsible  for 
ensuring connection of their National Single Windows to the centralised gateway. 
Alt. D  Mandatory  Port  Community  Systems  (PCS)  as  basis  for  harmonised  reporting 

gateways in Member States (technical specifications) 
Build  the  EU  level  harmonisation  requirements  and  binding  technical  specifications  on 
mandatory  PCS  reporting  gateways  in  the  Member  States  (all  other  details  same  as  in 
alternative A above). 

Problem  Driver  2:  Diverse  ship  reporting  information  requirements  throughout  the  EU  – 
several parallel reporting entry points 
Policy measure 
No. 
Alt. 1  Comprehensive  single  entry  point  solution 
comprehensive Maritime Single Window data set) 
Set a wide scope for the reporting by ships in connection to a port call to be accepted via 
the  harmonised  reporting  environment:  covering  the  current  scope  of  RFD,  the  national 
reporting  requirements  and  channelling  of  customs  formalities  for  ships  into  (and  return 
messages from) the customs IT systems at national and EU level. 
Separate  entry  points  customs  /  maritime  (introduction  of  a  mandatory  limited 
Maritime Single Window data set) 
Set a limited scope for the reporting by ships in connection to a port call to be accepted via 
the harmonised reporting environment: covering the current scope of RFD and the national 
reporting requirements. Customs formalities to be reported via the parallel and harmonised 
customs IT systems. 

(introduction  of  a  mandatory 

Alt. 2 

Common/complementary set of measures (enabling framework) 

Problem  Driver  2:  Diverse  ship  reporting  information  requirements  throughout  the  EU  – 
several parallel reporting entry points 
No. 
I 

Policy measure 
Introduction of specifications for acceptance of e-certificates 
Enable  development  of  e-certificates  acceptance  by  initiating  processes  for  specifications 
and technical solutions (e.g. common registries). 

No. 
II 

Problem Driver 3: Unclear legal framework for sharing and using reporting information – no 
“reporting only once”  
Policy measure 
Establishment of data re-use principles for “reporting only once”  
A  set  of  clear  principles,  rules  and  rights  for  data  sharing  and  reuse  will  be  developed  to 
ensure  correct  and  smooth  data  management  and  “reporting  only  once”  for  carriers,  as  a 
minimum first step within the same port. Clear definitions for different requirements will be 
provided.  Definitions  and  specifications  concerning  the  processing  and  management  of 
personal or commercially sensitive data will be addressed.  
Development of common databases to support the system  
This includes a common exemption database, a common (federated) user database(s) and a 
common ship repository for improved data flows and data exchanges. 

III 

31 

 
 
 
Problem Driver 4: Inadequate implementation  

No. 
IV 

V 

VI 

Policy measure  
Introduction of a governance mechanism  
A  governance  mechanism  will  be  created  to  ensure  timely  and  appropriate  legal  and 
technical  updates.  Implementing  and/or  delegated  powers  for  maintenance  of  e.g.  the 
technical specifications are proposed. This will be accompanied by the set-up of the required 
expert  groups  for  coordination  and  consultation  with  Member  States  and  with  industry 
stakeholders as needed. 
Development of a complaint/feedback mechanism  
A complaint/feedback mechanism will be offered to maritime transport operators as a tool to 
alert  authorities if the harmonised reporting  and the reporting  only once principles are not 
respected or if any technical fault is found in the reporting systems. 
Development of helpdesk function  
To  facilitate  implementation,  technical  support  to  Member  States  on  the  reporting 
environment specifications and possible IT solution in the form of e.g. helpdesk functions, 
technical advice or development of application guidelines will be developed. 

The  measures  have  been  packaged  in  policy  options  along  the  two  main  dimensions:  to 
address the harmonisation requirements (mutually exclusive measures A-D) and to define the 
scope  of  what  shipping  operators  can  report  via  the  harmonised  reporting  environment 
(mutually exclusive measures 1-2). Six measures (I – VI) are common for all policy options.  

As a result, eight policy options have been considered and six of them have been retained for 
in-depth analysis, in addition to the baseline (see section 5.1): 

Harmonised 
gateways: 

A: 
NSW 
technical 
specifications 

Option A1: 
Measures A, 1 and 
I-VI 
Option A2: 
Measures A, 2 and 
I-VI 

B:  Harmonised  NSW 
gateways: 
common 
IT solution  

Option B1: 
Measures B, 1 and I-
VI 
Option B2: Measures 
B, 2 and I-VI 

C: 
Central 
reporting gateway  

D:  Mandatory  PCS 
(discarded) 

Option C1: 
Measures C, 1 
and I-VI 
Option C2: 
Measures C, 2 
and I-VI 

Option D1: 
Measures D, 1 and I-
VI 
Option D2: Measures 
D, 2 and I-VI 

1.  Comprehensive 
single  entry  point 
solution 
2.  Separate  entry 
points  customs  / 
maritime  

Table 1: Policy options 

The  main  difference  between  the  options  is  in  terms  of  roles  and  responsibilities  and  the 
division of tasks between Commission and the Member States, as is further described below.  

5.3.1.  Policy  option  A1:  Harmonised  reporting  gateways  as  front-ends  to  the 
requirements 

NSWs: 
specifications 
(decentralised/distributed) - comprehensive scope 

technical 

binding 

and 

Harmonisation 
Policy  option  A1  is  to  introduce  binding  requirements  and  technical  specifications  for 
harmonising  the  reporting  gateways  (front-end  interfaces)  of  existing  National  Single 
Windows  in  the  Member  States.  The  specifications  would  cover  data  content,  message 
structure format, exchange protocols, user interface requirements and other rules as necessary 

32 

 
 
 
 
 
 
 
 
for  ensuring  the  necessary  information  exchanges.  They  would  be  set  at  EU  level  but 
responsibility  for  implementation  and  operation  would  be  fully  on  the  Member  States.  It 
would  also  be  the  responsibility  of  Member  States  to  prepare  and  perform  updates, 
maintenance  and  support  services  as  required.  Coordination  and  overview  of  updates  for 
permanent  alignment  with  relevant  legal  and  technical  developments  should  be  led  by  the 
Commission  with  support  of  relevant  experts.  The  technical  specifications  will  be  designed 
with  a  view  to  enable  full  interoperability  between  the  National  Single  Windows,  future-
proofing  for  next  phases  of  more  access  and  exchange  of  relevant  data  (see  also  section  on 
data re-use below). 

The  result  would  be  a  decentralised  system  of  very  similar  (subject  to  possible  nuance 
interpretations  of  the  specifications  at  Member  State  level)  National  Single  Window  front 
ends,  allowing  the  shipping  operators  to  adjust  their  reporting  systems  only  once  for  being 
able to report in any EU port in the same way. 

The technical specifications for data and interfaces will be designed to enable both machine-
to-machine reporting and reporting via graphic user interface to meet the needs of all kinds of 
shipping  operators.  In  the  longer  term,  specifications  for  reporting  from  autonomous  ships 
could also be introduced74.  

The  option  requires  a  connection  between  the  National  Single  Window  and  all  entities  and 
systems assigned by the underlying legal acts to connect as back-end data recipients; e.g. by 
connecting  the  National  Single  Window  as  a  user  to  the  relevant  customs  trader  interfaces. 
The  back-end  technical  specifications,  from  a  National  Single  Window  to  a  relevant  local, 
national  or  EU  level  system,  would  be  derived  from  the  requirements  in  the  underlying 
reference  legal  acts  to  ensure  all  relevant  entities  continue  to  receive  the  data,  reports  and 
notifications  in  a  useful  and  timely  manner  and  in  compliance  with  the  functional 
requirements  and  technical  specifications  of  the  recipient  systems  (i.e.  customs  systems). 
Coordination  or  data  format  translation  efforts  will  be  needed  if  several  connected  entities 
require  the same  information  in  different  formats.  The  National  Single  Window  would  thus 
have a routing and, where/if needed, a technical data format translation function.  

The  data  and  notifications/declarations  received  from  shipping  operators  would  be  split  so 
that  each  data  recipient  only  receives  specific  data  elements  ("need  to  know"  basis). 
Information  flows  shall  follow  the  timelines  for  fulfilment  of  respective  reporting  needs; 
notably  the  timelines  for  customs  formalities  as  prescribed  in  the  customs  legislation. 
Declarants (shipping operators) will remain liable and responsible for the correct and timely 
submission  of  their  reports  and  notifications.  For  any  potentially  personal  data,  the  data 
recipient will be responsible and accountable for managing the data in line with all applicable 

74 Likely not needed as the reporting is location agnostic from a technical point of view. 

33 

 
 
                                                            
 
data  protection  rules  (e.g.  GDPR,  national  requirements)  to  ensure  proper  data  privacy 
including no storage of sensitive data beyond prescribed timelines.  

Any feedback provided by relevant authority, port operator or port service provider should be 
send to the declarant via the same channel as received. To facilitate reporting from maritime 
carriers, where internet connection is sometimes lacking, offline options for reporting will be 
considered, where appropriate and possible. 

Figure 3: Data flows in option A175 

Scope of reporting 
The  body  of  data  elements  which  are,  on  basis  of  EU,  international  or  national  law,  asked 
from a ship at a port call, must be clearly defined for the European Maritime Single Window 
environment.  The  data  elements  agreed  for  this  scope  must  then  be  coordinated  and 
harmonised  into  an  agreed  format  for  the  shipping  operators  at  front-end,  to  avoid 
duplications and to ensure harmonised reporting. 

The  new  legal  proposal  should  therefore  include  references  to  this  wider  set  of  underlying 
legal acts for the scope. In addition, a more detailed data set would be needed as a technical 
tool  to  aid  the  front-end  interface  set-up  and  as  a  service  and  business  guidance  to  the 
maritime  transport  operators.  This  technical  tool  data  list  would  be  a  living  document  to 
reflect – not prescribe – the data requirements following any legislative updates or updates of 
technical  specifications  of  the  underlying  back-end  systems.  Authorities  must  not  request 
these  data set elements in  non-harmonised format nor  ask  for  additional  data outside of the 

75 The figures illustrating the data flows via National Single Windows in chapter 5.3 are simplified illustrations 
of the policy options; more detailed diagrams showing connections, interlinkages between IT systems and 
other potential reporting paths can be found in Annex 6 

34 

 
 
 
                                                            
 
single window reporting environment. The aim is to protect shipping operators from excessive 
administrative burden.  

In  option  A1,  the  scope  of  the  European  Maritime  Single  Window  environment  covers  the 
comprehensive set of all reporting for a vessel to perform a port call. This would include e.g. 
all  entry/exit  formalities  and  notifications  required  from  the  carrier  by  customs76  (under  the 
Union Customs Code; reference to UCC to be included into the new RFD legislation) and all 
national level data elements (Part C of the current RFD, Annex 1).  

This  is  in  line  with  stakeholders'  opinions  reported  in  the  consultations.  82.5%  of  all 
responders to the public consultation (93.5% of all shipping companies and ship masters; 50% 
of  all  Member  States77)  stated  that  national  requirements  should  be  included  in  the  new 
framework  in  order  to  harmonise  all  information  required  for  a  port  call.  6.5%  of  all  open 
public  consultation  respondents  did  not  agree  the  national  requirements  should  be  included 
(0%  of  shipping  companies  and  ship  masters;  19%  of  Member  States)  and  11%  had  no 
opinion or felt neutral to the proposal. 
These results are also in line with those obtained during the evaluation78 when a large part of 
the  shipping  stakeholders  specifically  ask  also  for  a  more  comprehensive  approach  to 
transport  and  customs  reporting.  The  European  Community  Shipowners’ 
maritime 
Association  stressed  that:  “It  goes  without  saying  that  we  want  the  customs  reporting  to  be 
part  of  it  as  well.  Only  in  this  way  shipping  can  finally  enjoy  the  single  market.”79For 
rationalisation and simplification, the scope of the fully harmonised Maritime Single Window 
data set – notably the national data elements from current RFD, Part C – will be scrutinised in 
a process together with Member States and connected authorities to ensure that unnecessary 
(e.g. traditionally requested but now redundant) data elements are over time cleared from the 
reporting requests.  

In  order  to  enable  this  comprehensive  data  set,  timelines  and  data  requirements  must  be 
aligned  in  detail  with  the  current  developments  of  the  customs  IT  systems.  The  IT  systems 
related to the customs formalities proposed to be included in the scope of the RFD successor 
(e.g. ICS2) are scheduled to be ready by 2024-25. The implementation of the comprehensive 
European  Maritime  Single  Window  environment  should  be  prepared  with  technical  set-ups 
and test runs to align with this time frame. All customs reporting via the European Maritime 
Single  Window  environment  should  then  be  in  direct  correspondence  with  the  rules, 
specifications  and  requirements  derived  from  the  Customs  legislation  and  technical 

76  Currently:  Entry  Summary  Declaration,  Arrival  Notification,  Presentation  Notification,  Declaration  for 
Temporary  Storage,  Customs  Goods  Manifest,  Electronic  Transport  Document  for  simplified  transit,  Re-
Export Notification, Exit Summary declaration and Exit Notification 

77 For further detailed breakdowns of all these statistics, see Consultation synopsis report in Annex 2 
78 Evaluation of the RFD, p.47-48 
79 ECSA, A single market for shipping – time to make it happen 

35 

 
 
                                                            
 
specifications of the underlying customs IT systems, and reflect any amendments and updates 
in these underlying legal acts and specifications.  

Initiate development towards e-certificate acceptance 
Just  above  80%  of  respondents  to  the  open  public  consultation  also  stated  that  the  new 
framework  should  include  provisions  on  certain  e-certificates  (notably  ship  certificates)  to 
allow  for  future  fully  paperless  ships.  This  issue  will  be  addressed  in  the  revised  reporting 
formalities  framework  with  appropriate  references  and  links  to  the  parallel  initiative  on 
electronic  transport  documents.  IMO  has  also  issued  Guidelines  for  the  Use  of  Electronic 
Certificates80 promoting the use of secure e-certificates for maritime transport. 

The common databases and registries anyways established in the European harmonised digital 
reporting  s  environment  could  in  later  steps  be  exploited  to  also  allow  and  enable  future 
secure use of e-certificates and reference numbers for EU port calls.  

Development  of  clear  data  re-use  principles  for  step-wise  process  towards  “reporting 
only once” of same data 

In its Council conclusions on Digitalisation of transport on 5 December 2017, the European 
Council  specifically  called  on  the  Commission  to  apply  the  'once  only’  principle  when 
developing new or revising existing legislation, in order to keep it fit for the digital age. The 
“once  only”  principle  aims  to  reduce  administrative  burden  by  avoiding  that  the  same 
business actor is required to supply the same information more than once to the authorities, as 
first  priority  within  the  same  port.  The  goal  is  to  “get  the  data  to  circulate,  not  the  user”81: 
authorities  may  not  request  that  an  operator  submits  again  the  same,  unchanged  data  as 
already sent, unless for corrections or updates. This does not imply that the transport operators 
will  not  be  obliged  to  report  at  several  different  points  in  time  (e.g.  customs  formalities 
required  by  law  at  several  phases:  e.g.  early  stage  before  a  planned  port  call,  formalities 
required  closely  before  calling  a  port  and  formalities  upon  departure  from  port).  New  or 
changed data must always be reported again. 

There  has  been  a  strong  message  from  consulted  stakeholders  that  the  reported  information 
should be more efficiently shared and reused, both to reduce the burden of reporting and for 
the sake of maximising multimodal transport facilitation.82 Better access to data contributes to 
facilitating digital solutions for “smart ports”, significantly speeding up ports procedures with 
indirect  cost-savings  and  business  opportunity  improvements  for  the  entire  multimodal 

80 FAL.5/Circ.39/Rev.2, April 2016 
81 EY and DTI for the European Commission, Study on eGovernment and the Reduction of Administrative 
Burden, 2014, p.29, https://ec.europa.eu/digital-single-market/en/news/final-report-study-egovernment-and-
reduction-administrative-burden-smart-20120061  
82 Consultation workshop: Moving towards a European Maritime Single Window environment – what road to 

take? (80% of those who voted in the session poll) 

36 

 
 
                                                            
 
transport  chain.83  80.5%  of  all  respondents  stated  in  the  open  public  consultation  that  they 
would  have  some  or  high  benefits  from  more  data  sharing  and  data  re-use  (75%  of  the 
Member States, 83.5% of the shipping companies and ship masters, 100% of the ship agents). 
11% of the consulted stakeholders expected related benefits to be low (12.5% of the Member 
States, 10% of shipping companies and ship masters) and 7.5% expressed no opinion on this 
question. According to the respondents, the benefits would be increased productivity and time 
savings from avoiding duplicate reporting. 

A  set  of  clear  principles,  rules  and  rights  for  data  sharing  and  reuse  will  therefore  be 
developed  to  ensure  correct  and  smooth  data  management  and  “reporting  only  once”  for 
carriers.  As  a  minimum  first  step,  the  data  re-use  within  the  same  port  must  be  addressed. 
Clear  definitions  for  different  requirements  will  be  provided,  filling  the  gaps  of  the  current 
legal framework. Clear roles, responsibilities and accountability for all entities connected to 
the  system  will  be  defined,  together  with  legal  obligations/enablements  set  out  in  the 
legislative  framework  together  with  the  necessary  business  rules,  common  standards  and 
procedures. Coordination and technical support should be offered to the connecting entities if 
needed.  

The  protection  of  personal  data  must  be  well  covered  in  the  system,  e.g.  by  ensuring  that 
personal data is erased without delays once not needed, in compliance with the General Data 
Protection  Regulation.  A  distinction  will  be  made  between  non-personal  and  personal  data 
including with clarity in definitions of e.g. data reports including the name of the responsible 
data  provider  (e.g.  ship  master).  Definitions  and  guidelines  concerning  the  processing  and 
management of commercially sensitive data will be addressed. 

For supporting and enabling real, efficient and secure application of the “reporting only once” 
principle,  common  eGovernment  building  blocks84  e.g.  for  eID  and  eSignature  should  be 
exploited.  

The  aim  is  to  enable  the  application  of  "reporting  only  once".  To  achieve  this,  a  step-wise 
approach  will  be  taken,  with  the  requirements  for  sharing  of  static  information  and  sharing 
within  the  same  port  as  a  first  priority.  In  subsequent  steps,  data  re-use  and  data  sharing  in 
support of multimodal transport services and more efficient functioning of the logistics chains 
will be addressed including increased data sharing for "reporting-only-once" at Member State 
and EU level. Reuse of declarants’ own historical data submitted earlier to another node in the 
reporting environment should be facilitated where possible. 

Boston 

Consulting, 

83 
https://www.bcg.com/publications/2018/digital-imperative-container-shipping.aspx  
84 EU eGovernment Action Plan 2016-2020 Accelerating the digital transformation of government, 
COM/2016/0179  

Imperative 

Container 

Digital 

The 

in 

Shipping, 

2018, 

37 

 
 
 
                                                            
 
Development of common databases 
For  a  new  legislative  framework  under  policy  option  A1  to  work  smoothly,  it  would  be 
necessary to introduce certain common databases to support the interconnected system. This 
will  include  a  common  exemption  database,  a  common  (federated)  user  database(s)85  and  a 
common  ship  repository.  These  common  tools  would  ensure  efficient  flows  and  exchanges 
within  the  European  Maritime  Single  Window  environment  (decentralised  or  centralised). 
eGovernment  building  blocks  and  existing  tools  for  e.g.  digital  signature  and  eID  would  be 
applied; Horizon 2020 Information and Communication Technologies86 and relevant industry 
guidelines87 will be taken into account. 

Introduction of a governance mechanism  
To ensure flexibility and to keep the legislation relevant for the long-term in view of technical 
and  legal  developments  over  time,  a  governance  mechanism  must  be  created.  This  is 
especially the case to ensure the system remains maximum efficient also with a view to ICT 
innovations  and  new  technical  possibilities  developing.  Implementing  and/or  delegated 
powers for maintenance of the technical specifications and control of related updates, for the 
harmonised technical data set and for the data reuse rules and rights will therefore be needed. 
This  will  be  accompanied  by  the  set-up  of  the  required  expert  groups  for  coordination  and 
consultation with Member States and with industry stakeholders as needed. The governance 
mechanisms  should  be  coordinated  by  the  Commission  transport  sector  but  would  closely 
involve relevant Commission services/agencies from all involved policy areas. 

Development of a complaint/feedback mechanism  
The  Commission  is  responsible  for  appropriate  follow-up  and  possible  infringement 
procedures in case of Member States non-compliance, in order to ensure business continuity 
and equal access to harmonised services for the maritime transport operators. With more clear 
and  specific  legal  provisions  of  the  new  legal  proposal  (in  particular:  detailed  binding 
specifications),  the  Commission  will  have  the  possibility  of  pursuing  effective  infringement 
procedures, unlike under the current RFD. 

Member  States  and  their  National  Competent  Authorities  in  charge  of  the  National  Single 
Windows  will  in  turn  be  responsible  and  accountable  for  the  implementation  of  the 
harmonised reporting gateway/front-end. They will also be responsible for the connection to 
the back-end entities at EU and national level. 

85 Cf for example the common user database for the customs IT systems: EORI  
86 https://ec.europa.eu/programmes/horizon2020/en/h2020-section/information-and-communication-technologies  
87 The Guidelines on Cyber Security Onboard Ships (http://www.ics-shipping.org/docs/default-

source/resources/safety-security-and-operations/guidelines-on-cyber-security-onboard-ships.pdf?sfvrsn=16)  

38 

 
 
                                                            
 
A  complaint/feedback  mechanism  will  also  be  developed,  offering  the  maritime  transport 
operators  a  tool  to  alert  authorities  if  the  harmonised  reporting  and  the  reporting  only  once 
principles are not respected or if any technical fault is found in the reporting systems. 

Introduction of helpdesk function 
To facilitate implementation, technical support on the functioning of the European Maritime 
Single  Window  environment  specifications  in  the  form  of  helpdesk  functions,  technical 
advice and development of application guidelines or other tools to support the Member States 
will be developed. The helpdesk is for the Member States and will in options A1-A2 focus on 
providing  support  on  the  interpretation  of  the  technical  specifications  and  the  data  set.  This 
support  may  also  be  provided  in  forms  of  offered  trainings.  Support  functions  towards  the 
front-end  and  back-end  users  (data  providers  and  data  recipients)  will  continue  to  be  the 
responsibility  of  the  National  Single  Window  competent  authority.  Clear  information  to 
business operators about access to the specific content-related helpdesks for various parts of 
the reporting formalities will be available. 

5.3.2.  Policy  option  A2:  Harmonised  reporting  gateways  as  front-ends  to  the 
requirements 

specifications 

and 

NSWs: 
(decentralised/distributed) – limited scope 

technical 

binding 

Policy Option A2 is exactly the same as policy option A1 with the difference that the scope is 
limited to cover only the current mandatory RFD reporting formalities and the national legal 
requirements  (current  RFD  Part  C  data).  The  customs  IT  systems  will  remain  as  a  parallel 
interface for completion of customs formalities.  

This option would, according to the consulted shipping operators, not fully solve the issue of 
shipping operators being required to report to several reporting entry points (the harmonised 
reporting  gateway(s)  for  maritime  transport  and  to  the  various  harmonised  customs  trader 
interfaces and portals). The harmonisation of information requirements at customs level will 
still  be  achieved,  as  it  stems  from  the  already  adopted  UCC  legislation.  Without  the 
interconnection  with  the  customs  IT  systems,  the  timeline  could  be  shortened  and 
implementation of the European Maritime Single Window environment will be more flexible. 
With  this  option,  complex  interlinkage  between  the  European  Maritime  Single  Window 
environment  and  the  customs  IT  systems  will  not  be  implemented,  avoiding  risks  of  non-
synchronisation  between back-end entity technical specifications and the maritime  reporting 
gateway.  The  risk  of  technical  failures  will  therefore  be  reduced,  same  as  the  development 
and maintenance costs related to the project implementation. 

39 

 
 
Figure 4: Data flows in option A2 

5.3.3.  Policy  option  B1:  Harmonised  reporting  gateways  as  front-ends  to  the 
NSWs:  common  IT  solution  for  harmonised  interface  and  formats 
(decentralised/distributed; EU-level development responsibility, Member 
State operational responsibility) - comprehensive scope 

Option B1 is to develop a mandatory common reporting gateway IT solution88 at EU level and 
deliver  it  to  all  Member  States  for  installation  in  every  National  Single  Window  as  a 
harmonised front-end interface towards the shipping operators. The front-end component will 
enable submission of data in a common EU format to different National Single Windows by 
converting  the  harmonised  data  to  a  specific  national  format  used  by  the  National  Single 
Window,  and  vice  versa.  The  front-end  component  could  also  provide  data  validation  and 
authentication functionalities. The National Single Windows will plug in this new harmonised 
front-end  reporting  gateway  into  their  existing  system,  simply  replacing  the  old  user 
interfaces.  The  front-end  IT  solution  will  be  developed  as  open-source  software,  therefore 
allowing  the  national  competent  authorities  to  easily  modify  the  back-end  of  the  reporting 
gateway for the plug-in to their National Single Window, if necessary.  

For all other functionalities, the National Single Windows will remain the same, performing 
the same role towards the back-end entities and requiring minimum adaptations. 

The  reporting  gateway  IT  solution  will  be  developed  as  in  option  A,  at  EU-level.  The 
common  data  format  translation  keys  for  any  transformations  done  by  the  front-end 
component from EU formats to national formats would also be developed at EU level, based 
on  the  data mapping  already  completed.  Regular  updates  as  required  would  be  supplied  via 

88 For the machine-to-machine reporting, this would be built in the form of a “middleware” software component 
enabling  communication  between  the  two  different  system  environments  (on  the  one  hand  the  shipping 
operators and on the other hand the data distribution functionality of the National Single Window). 

40 

 
 
 
 
                                                            
 
the EU (task may be delegated to a technical support function) following update plans agreed 
together with the Member States (governance mechanism). The technical implementation for 
this  option  will  take  into  account  the  approach  and  progress  made  with  the  ICS2  Trader 
Interface  as  a  dedicated  channel  to  receive  the  Entry  Summary  Declaration  (ENS).  The 
development cost for this common IT solution would be carried at EU level including for all 
updates required to remain aligned to the technical specifications of the underlying legal acts. 
Responsibility for the functioning of the front-end component would be on the EU-level entity 
in charge of the task. Member States would be responsible for adopting/installing the front-
end  component  package  within  given  timelines  and  to  follow  instructions  for  regular  and 
timely  updates  and  maintenance  of  the  system.  The  operational  responsibility  would  be  on 
Member States, providing helpdesk functions for their connected national entities and for the 
front-end  data  providers.  Some  helpdesk  functions  towards  the  National  Single  Windows 
regarding the front-end component and specifications will be provided at EU level. 

The  result  would  be  a  decentralised  (distributed)  reporting  system  of  identical  reporting 
gateways in every Member State. As in option A1, the Member States would still be free to 
organise  the  back-end  connections  including  to  Port  Community  Systems  however  they 
prefer, as long as the set-up respects the common rules and specifications and the quality of 
services  and  information  flows  between  the  maritime  transport  operators  and  the  connected 
entities and authorities remain sufficiently high. 

Main principles concerning all sub-measures including scope, liability and responsibility for 
all  involved  entities,  EU  level  coordination  and  governance  mechanisms,  e-certificates 
initiative, helpdesk functions etc. would be arranged as in option A1 above. Governance and 
helpdesk  functions  will  be  required  regardless  of  the  policy  option,  as  technical  enablers  to 
ensure  the  reporting  environment  works  smoothly  and  can  remain  aligned  with  legal  and 
technical  developments.  In  options  B1-B2,  the  helpdesk  will  provide  support  on  the 
installation of the front-end gateway solution to the National Single Windows. 

Figure 5: Data flows in option B1 

5.3.4.  Policy  option  B2:  Harmonised  reporting  gateways  as  front-ends  to  the 
NSWs:  common  IT  solution  for  harmonised  interface  and  formats 

41 

 
 
 
 
(decentralised/distributed; EU-level development responsibility, Member 
State operational responsibility) – limited scope 

Option B2 is exactly the same as policy option B1 with the difference that the scope will be 
limited.  In  option  B2,  the  same  limited  scope  /  technical  data  set  is  considered as  in  option 
A2. 

Figure 6: Data flows in option B2 

5.3.5.  Policy  option  C1:  Harmonised  reporting  via  a  central  gateway 

(centralised solution) – comprehensive scope 

Option C1 is to introduce a centralised European reporting gateway hosted and operated by an 
EU-level entity or technical support function. The centralised window would offer one single 
reporting  entry  point  for  all  port  calls  throughout  the  EU  including  the  necessary  two-way 
information exchanges between data providers and connected entities and systems. Shipping 
operators  would  also  still  have  the  choice  to  report  directly  to  the  various  customs  trader 
interfaces. Member States may also in this case want to continue maintaining the old reporting 
gateway (front-end interface) of the National Single Windows as an option for SME operators 
in  domestic  traffic.  However,  if  a  shipping  operator  chooses  to  report  via  the  centralised 
European reporting gateway, authorities would not be allowed to request additional reporting 
also via other entry points (reporting only once).  

The  centralised  European  reporting  gateway  would  channel  incoming  reporting  and 
notifications directly to other EU-level systems, such as the Harmonised Trader Interface89 for 
customs  entry  summary  declarations.  It  would  channel  other  data  via  the  National  Single 

89 For more detailed information and overview of all connections between the European Maritime Single 

Window environment and customs IT systems, see Annexes 6-7 

42 

 
 
 
 
                                                            
 
Windows  for  transmissions  to  national  level  data  recipients.  Help  desk  and  other  support 
related to the functioning of the European reporting gateway will be provided at EU level. 

The National Single Windows would remain in place but with adaptations. They would serve 
mainly  as  a  router  between  the  centralised  European  gateway  and  the  national  level  data 
recipients (receiving data from the central front-end gateway and continuing the functionality 
of  distributing  that  data  to  national  level  back-end  entities).  Member  States  would  be 
responsible  for  ensuring  connection  of  their  National  Single  Windows  to  the  centralised 
gateway.  In  principle,  National  Single  Windows  could  also  continue  to  offer  an  alternative 
reporting channel through their former front-end gateways. If Member States wish to maintain 
this possibility as a voluntary alternative for the maritime operators it would be allowed – in 
addition to, not a replacement of the centralised European reporting gateway. 

Strong  back-up  and  cyber  security  solutions  would  be  required  to  ensure  resilience  and 
availability of the system.  

Main principles concerning all sub-measures including scope, liability and responsibility for 
all  involved  entities,  EU  level  coordination  and  governance  mechanisms,  e-certificates 
initiative,  helpdesk  functions  etc.  would  be  arranged  as  in  options  A1  and  B1  above.  The 
helpdesk in option C1-C2 will provide support to Member States on all issues regarding their 
connection into the centralised reporting gateway, as well as on the common data set and data 
formats.  Support  towards  national  back-end  entities  continues  to  be  provided  via  National 
Single Window competent authorities. 

Figure 7: Data flows in option C1 

5.3.6.  Policy  option  C2:  Harmonised  reporting  via  a  central  gateway 

(centralised solution) – limited scope 

Option C2 is exactly the same as policy option C1 with the difference that the scope will be 
limited. In option C2, the same limited scope / technical data set is considered as in options 
A2 and B2. 

43 

 
 
 
 
Figure 8: Data flows in option C2 

5.4.  Overview of main differences between the harmonisation solutions 

Harmonisation tool 

Options A1-A2 
Harmonisation 
legally 
achieved  via 
binding 
common 
technical  specifications 
for  Member  States  to 
a 
implement 
reporting 
harmonised 
front-end  gateway 
to 
their  National  Single 
Windows. 

Options B1-B2 
Harmonisation 
achieved  via  identical 
front-end  components 
the  harmonised 
for 
reporting 
gateway, 
developed at EU level 
and  installed  at  each 
National 
Single 
Window  

of  Member 

Role 
States 

Role of the EU 

the  new 
To  develop 
front-end solution based 
on 
EU 
the 
specifications, adapt the 
Single 
National 
accordingly 
Window 
and 
to 
to  continue 
operate  and  maintain 
the  National  Single 
Window. 
To deliver the technical 
to 
specifications; 
the 
coordinate 
governance and updates 

plug 

To 
provided 
component 
National 
Windows 
continue 
and  maintain 
National 
Window. 

the 
in 
front-end 
their 
to 
Single 
to 
to  operate 
the 
Single 

and 

To 
and 
develop 
deliver  the  common 
IT  solution  that  can 
be  plugged  in  at  all 
National 
Single 
Windows  as  the  new 

44 

Options C1-C2 
Harmonisation  achieved 
via  a  centralised  gateway 
at  EU-level.  The  gateway 
will  provide  single  EU-
level  entry  point  for  the 
reporting.  It  will  forward 
the  received  information 
to 
the  National  Single 
Windows  and  provide 
authentication, 
users 
validate  data  and  provide 
logging  and  monitoring 
functionalities. 
the  National 
To  adapt 
to  be 
Single  Window 
connected 
the 
centralised  gateway  layer 
including  shifting  some 
functionalities from front-
end  to  routing  roles;  to 
operate  and  maintain  the 
National  Single  Window 
as routing structure. 
To  develop,  establish  and 
central 
operate 
the 
to 
reporting  gateway; 
coordinate 
the 
governance and updates 

with 

 
 
 
 
 
National 
Windows 

Single 

(GUI) 

Remain as the reporting 
entry  points,  adapted  to 
the  harmonised  format; 
the 
will 
provide 
User 
Graphical 
for 
Interface 
shipping  operators;  will 
to  provide 
continue 
back-end 
national 
and 
connections 
services 
relevant 
for 
authorities; will provide 
independently 
all 
functionalities. 

EU-level 
function 

helpdesk 

Training/support 
offered 
States 

to  Member 

as 

reporting  gateway;  to 
the 
coordinate 
governance 
and 
updates. 
Remain 
the 
reporting entry points, 
compatible  with  the 
harmonised  front-end 
IT 
solution;  will 
provide  the  Graphical 
User  Interface  (GUI) 
shipping 
for 
operators; 
will 
to  provide 
continue 
back-end 
national 
connections 
and 
services  for  relevant 
will 
authorities; 
provide 
independently 
functionalities, 
possibly 
the 
validation. 
Will  provide  support 
to  Member  States  on 
and 
instalment 
functioning  of 
the 
front-end IT solution 

excluding 
data-type 

all 

Governance 

services 
Commission 
and  relevant  agencies 
together  with  Member 
and 
States 
experts 
to 
industry  observers 
of 
keep 
and 
updates 
coordination 
of 
specifications  and  data 
set. 

overview 

Commission  services 
and  relevant  agencies 
with 
together 
Member 
States 
experts  and  industry 
observers 
to  keep 
overview  of  updates 
and  coordination  of 
and 
specifications 
data set. 

include 

Will 
a  new 
routing  function  between 
the 
local  and  national 
authorities and the central 
data  entry  point  but  may 
also  remain  capable  to 
receive  reporting  directly 
from  shipping  operators; 
will  continue  to  provide 
back-end 
national 
connections  and  services 
for  relevant  authorities; 
will depend on centralised 
many 
gateway 
services  such  as  GUI, 
logging,  monitoring  and 
identity management. 

for 

support 

Will  provide  support  to 
the 
Member  States  on 
connections 
between 
National  Single  Windows 
and  the  central  gateway; 
for 
provide 
shipping  operators  on 
connecting  with 
the 
gateway. 
Commission  services  and 
relevant agencies together 
States 
with  Member 
experts 
industry 
keep 
observers 
overview  of  updates  and 
coordination  of  the  data 
set. 

and 

to 

Table 2: Core differences between options 

The outcome vis-à-vis the shipping operators is in all cases more or less the same (identical 
reporting gateways regardless of the port in options B and C; harmonised functionalities and 
more  or  less  the  same  gateway  towards  shipping  operators in  options A).  These  differences 
have impact on the cost estimates presented in a section below. In all options, the likelihood 
of  achieving  harmonised  reporting  is  far  higher  than  for  the  current  legal  framework 
(baseline)  as  a  result  of  either  binding  specifications,  a  delivered  identical  gateway  solution 
for all National Single Windows or the establishment of a central reporting gateway. 

45 

 
 
In all the options, a mix of expertise will be needed for the implementation and development 
of IT systems. The bulk of the work and the main responsibility for the project management 
will  be  for  the  Commission,  contracting  specific  IT  development  services  from  external 
service  providers  where  needed.  Technical  expertise  from  specialised  Commission  services 
and  decentralised  agencies  will  be  involved  as  appropriate.  The  exact  division  of  detailed 
tasks  (e.g.  service  contracting)  can  only  be  decided  at  a  later  stage  in  connection  with  the 
implementation  phase  and 
in 
the 
delegated/implementing acts. 

set-up  of  detailed  work  plans 

following 

5.5.  Discarded policy options 

5.5.1.  Policy  options  D1  –  D2:  Harmonised  reporting  via  mandatory  PCS: 
requirements 

binding 
(decentralised/distributed) – comprehensive and limited scope 

specifications 

technical 

and 

Options  D1  and  D2  build  the  EU  level  harmonisation  requirements  and  binding  technical 
specifications  on  mandatory  Port  Community  System  reporting  gateways  in  the  Member 
States. A Port Community System is defined as an electronic platform connecting the systems 
operated  by  the  organisations  and  entities  making  up  a  seaport  community.  The  Port 
Community System facilitates exchange of operational or administrative information between 
different  actors  in  the  port90;  it  can  also  include  systems  for  optimisation  of  processes  (e.g. 
“smart ports” systems). The PCS can be operated and maintained either by a public, private or 
public/private organisation. 

By linking the technical specifications to mandatory Port Community Systems, the reporting 
environment  would  build  on  the  systems  already  in  place  in  many  Member  States;  other 
Member States/ports would need to adapt by establishing (purchasing) such systems. 

In  the  consultations,  shipping  companies  noted  that  this  option  is  not  viable,  notably  since 
Port Community Systems normally are fee-based and the costs for shipping operators would 
therefore  increase.  The  option  was  supported  by  no  shipping  companies  in  the  targeted 
consultations  and  overall  seen  as  potentially  effective  by  only  by  11%  of  all  consultation 
participants;  somewhat  higher  share  among  ports  and  port  community  system  providers 
(31%).  

It was also highlighted in the consultations that this might be an option for large ports but was 
impractical as general solution since small ports today do not usually apply Port Community 
Systems. At the present time, less than half of all EU ports have Port Community Systems in 

90 J. Rodon, and J. Ramis-Pujol, “Exploring the Intricacies of Integrating with a Port Community System”, 19th 

Bled eConference eValues, Bled, Slovenia, 2006 

46 

 
 
 
                                                            
 
place,  usually  big  ports  with  high  volumes  of  traffic91.  According  to  IPCSA,  among  the  20 
major European ports, 75% deploy Port Community Systems.  

It  is  therefore  found  to  be  unrealistic  and  disproportionate  to  oblige  all  small  and  medium-
sized  ports  to  invest  in  Port  Community  Systems  and  to  prescribe  a  legal  obligation  for 
Member States to apply such commercial systems; this should instead remain a free choice.  

It should be noted however that the remaining policy options do not exclude the possibility for 
Member States who choose, voluntarily, to build their National Single Windows on existing 
Port Community Systems. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

In this section the quantifiable and qualitative economic, social and environmental impacts for 
the different options  are presented. They draw on the  excel-based tool developed by COWI 
and  Gartner  in  the  context  of  the  Impact  Assessment  support  study  and  on  the  modelling 
performed  by  ICCS-E3MLab  and  TRT  with  the  PRIMES-TREMOVE  and  TRUST  models. 
The 2020-2030 time horizon has been selected for assessing the impacts, in line with that of 
other initiatives that are part of the 3rd Mobility package. A discount rate of 4% has been used 
for calculating the present value, in line with the Better Regulation guidelines. 

6.1.  Economic impacts 

6.1.1.  Benefits: reduced administrative burden92 

The  harmonisation  of  the  reporting  formalities  is  going  to  bring  benefits  to  the  shipping 
operators and the industry, as the staff – generally the shipmaster – is expected to spend less 
time (as expressed in terms of staff hours) on reporting tasks. Ports, Member States and other 
connected  authorities  are  not  expected  to  incur  direct  cost  savings  in  terms  of  reduced 
administrative burden from harmonisation. 

While  the  magnitude  of  the  benefits  is  expected  to  be  similar  regardless  of  which 
harmonisation  mechanism  is  applied  (option  A,  B  or  C),  the  range  of  reporting  formalities 
considered (options 1 or 2) is likely to have an impact on the benefits. Therefore, the benefits 

91 Compared to the situation in 2010 when an impact assessment on e-maritime initiative found that about 60 out 
of 1200 European ports had a Port Community System in place: e.g. SKEMA e-Maritime Initiative Periodic 
Study, Task 2 - Annex 4: Inventory of Port Single Windows and Port Community Systems, 2010. A recent 
IPCSA estimate is that 75% of the 20 main European ports have PCS; for small and medium-sized ports 
PCS connections are less frequently in place. 

92 For the estimates of reduced administrative burden, a similar methodology as in the support study by  COWI 
has  been  used,  but  applying  a  more  cautious  sensitivity  analysis  therefore  arriving  at  more  conservative 
benefit estimates than in the support study. 

47 

 
 
                                                            
 
of options A1, B1 and C1 are assessed together in a first section; followed by an assessment 
of options A2, B2 and C2 together. 

Options A1, B1, C1   
The time savings for shipping operators in a harmonised reporting environment as compared 
to the baseline scenario are estimated to around 25 million staff hours for the entire baseline 
period  (2020-2030,  EU28),  based  on  input  from  ECSA  in  consultation  with  a  group  of 
shipping experts93. In a harmonised system with a single reporting entry point, less time will 
have  to  be  spent  on  the  reporting  tasks  and  there  will  be  no  need  to  adapt  the  data  set  into 
different formats for each new port call.  

The assumption for the benefit estimate is that gradually up to 90% of the shipping operators 
will  choose  to  use  the  harmonised  gateway  (possibility  that  SMEs  and  national  traffic 
operators opt to report in split data sets directly to national authorities – the 90% is already a 
cautious assumption). These staff hours saved – mainly by the qualified professional category 
of ship masters94 – are equivalent to around EUR 720 million95 expressed as present value in 
202096. Sensitivity analysis has been performed to take into account the uncertainty regarding 
the uptake of the voluntary new harmonised reporting format by also running the model with 
a  lower  uptake  among  shipping  operators:  gradually  increasing  up  to  only  80%  of  shipping 
operators  using  the  harmonised  reporting  gateway.  Assuming  the  more  pessimistic  uptake97 
over 2020-2030 is projected to lead to around 22 million staff hours saved, equivalent to EUR 
625 million, expressed as present value in 2020. Therefore, the total time saved is estimated 
at 22 to 25 million staff hours, equivalent to a value of EUR 625-720 million98. 

93  Calculation  based  on  assumptions  developed  in  consultations  with  ECSA  and  their  associated  members: 
average reporting time / average time savings for different types of vessels in different types of traffic (50% 
expected time savings for fixed route traffic; 75% for tramp traffic). For details on methodology, see Annex 
4 

94 A value of staff hour is estimated at 38.35 € according to ECSA. 
95  The  impact  assessment  support  study,  based  on  20  replies  received  through  the  consultations  (survey  and 
interviews),  showed  somewhat  lower  savings  estimated  at  EUR  67-79  million  per  year.  However,  this  is 
based  on  very  few  data  points  and  not  on  a  representative  selection  of  respondents;  however,  it  indicates 
some  uncertainty  around  the  numbers.  Interviewees  were  selected  with  a  view  to  represent  different 
geographic  areas  and  shipping  company  sizes  and  types;  the  respondents  to  the  survey  are  however  not 
selected  at  all,  the  invitation  to  the  survey  was  circulated  broadly.  20  respondents  of  the  total  11  000 
shipping operators in the EU are considered a statistically weak sample. 

96 Assuming a slow and gradual uptake from 25-90% over the baseline period with harmonisation benefits only 
available  as  from  2021  (>90%  of  shipping  companies  replied  in  consultations  that  they  urgently  want  a 
harmonised reporting environment but it is still considered unlikely that 90% will adapt to the new formats 
from day one). 

97 For the pessimistic uptake, the rate considered is 10 percentage points lower relative to the central rate for each 

year.  

98 With UK excluded, the expected estimated time savings for the total period would be 21-24 million staff hours 

equivalent to a value of EUR 600-690 million. 

48 

 
 
                                                            
 
The value of the time saved does not represent a direct cost saving for the shipping operators. 
It is unlikely that the reduced administrative burden can lead to actual cuts in staff costs; but it 
is an opportunity cost as a significant share of qualified labour staff hours will be released for 
other tasks. 

Implementing  efficient  data  sharing  and  application  of  the  “reporting  only  once”  principle 
(primarily:  within  same  port;  in  longer  term,  sharing  of  static  data  between  ports)  would 
additionally  benefit  the  maritime  transport  operators  by  reducing  the  number  of  data 
transactions and report submissions. This benefits especially SMEs and companies reporting 
manually via Graphic User Interface99. There is no quantifiable data accessible on the number 
of data elements currently asked more than once; this add-on benefit in burden reduction and 
time  savings  has  therefore  not  been  possible  to  monetise.  The  indirect  efficiency  gains  of 
improved information flows are also non-quantifiable. 

Options  B1-C1  have  an  added  benefit  over  option  A1  in  terms  of  accessibility:  with  the 
commonly  developed  front-end  component/portal,  language  translation  of  e.g.  the  graphic 
user interface text and of helpdesk information will be available for all EU languages in all 
reporting  gateways  at  the  National  Single  Windows  /  the  European  reporting  gateway  to  a 
more cost-efficient price (central once-only language translation for all).  

Options A2, B2, C2 
The total cost savings above are calculated on the assumption that the harmonised reporting 
gateway is indeed the single entry point for reporting. In a scenario where still a significant 
share of reporting is done separately and in parallel (options A2, B2, C2), the cost savings will 
be  lower  as  the  maritime  transport  operators  will  still  require  double  reporting  systems  and 
more  staff  hours  spent  on  reporting.  This  is  not  only  an  effect  of  two  separate  reporting 
systems with one clean-cut share of the data set each; the lower expected time saving is also 
an  effect  of  the  resulting  double-reporting  in  a  reporting  environment  without  the  inter-
connection  between  customs  and  maritime  reporting.  Part  of  the  data  set  is  over-lapping 
between  the  two  entities  and  data  will  continue  to  be  sent  in  duplicate  and  in  possibly 
different formats into the two reporting environments. 

The  assumption  used,  based  on  input  from  ECSA  in  consultation  with  a  group  of  shipping 
experts, sets the expected time reduction per port call to only 20-25% in policy options A2-
C2. This is substantially lower compared to expected reduction of 50-75% in the options with 
the  possibility  of  customs  and  maritime  reporting  done  together.  For  options  A2-C2,  the 
expected total time saved would therefore be around 7-8 million staff hours over 2020-

99  EY  and  DTI  for  the  European  Commission,  Study  on  eGovernment  and  the  Reduction  of  Administrative 

Burden, 2014 

49 

 
 
                                                            
 
2030  (EU28),  equivalent  to  EUR  215-245  million,  expressed  as  present  value  in  2020100. 
The same uptake rates are assumed as for options A1-C1. 

A1 

EU28 

A2 

B1 

B2 

C1 

C2 

Savings compared to baseline in million staff hours  
(baseline 50 million hours) 
Savings  compared  to  baseline,  €  million  (present  value) 
(baseline € 1,520 million) 

22-25 

7-8 

22-25 

7-8 

22-25 

7-8 

625-720 

215-245 

625-720 

215-245 

625-720 

215-245 

Excluding UK 

Savings compared to baseline in million staff hours 
(baseline 48 million hours) 
Savings  compared  to  baseline,  €  million  (present  value) 
(baseline € 1,455 million) 
Table 3: Reduced administrative burden for shipping operators relative to the baseline over 2020-2030 

600-690 

600-690 

205-235 

21-24 

21-24 

7-8 

7-8 

205-235 

21-24 

7-8 

600-690 

205-235 

6.1.2.  Costs: IT system investments and operational costs101 

The  main  investment  costs  of  evolving  the  current  RFD  system  into  a  comprehensive  and 
harmonised  port  call  reporting  environment  is  in  the  development  and  adaptation  of  IT 
solutions and IT infrastructure, including training of staff for the new gateway solution. With 
a  fully  interconnected  and  harmonised  set-up  there  will  also  be  a  need  for  certain  common 
features  such  as  common/connected  databases  and  registries  for  the  reporting  gateway(s). 
These  costs  will  be  primarily  for  the  Member  States  and  for  the  European  Commission.  In 
addition, there will be some adaptation costs for the back-end entities to enable connections to 
the updated and harmonised reporting environment. 

The  calculation  of  these  costs  is  based  on  the  average  cost  for  additional  adaptation  of  a 
currently  implemented  National  Single  Window  to  implement  the  new  common  gateway. 
Costs for finalising implementation of a National Single Window under the current RFD are 
not  factored  in  for  any  of  the  policy  options  (as  these  costs  are  due  regardless  of  any  new 
proposal as part of the implementation of the current Directive; the vast majority of Member 
States already have a National Single Window in place). The costs for national authorities are 
therefore  assumed  to  be  largely  similar  across  all  Member  States,  with  some  individual 
differences  based  on  e.g.  salary  levels  and  number  of  back-end  authorities  linked  to  their 
National Single Windows today. 

In all options A-C, some adaptation of the current National Single Window systems will be 
required.  In  options  A-B,  the  National  Single  Windows  will  need  to  be  upgraded  to  a 
harmonised  interface  specification  or  updated  to  plug  in  a  new  front-end  reporting  gateway 

100 With UK excluded, the expected estimated time savings for the total period would be equivalent to EUR 205-

235 million. 

101  For  the  cost  estimates,  data  from  the  support  study  by  COWI/Gartner  has  been  used.  More  details  on  the 

methodology for cost estimates is in Annex 4. 

50 

 
 
  
                                                            
 
solution; in option C, the National Single Window may also continue the current functions to 
be able to receive reporting directly from vessels in national traffic, but must also in any case 
be  adapted  to  be  able  to  connect  to  a  central  European  reporting  gateway.  This  implies 
changing some functionalities following the shift of responsibilities from national to EU level. 
The costs for developing the IT solutions is primarily on Member States in options A; on the 
EU in options B-C. 

To minimise the shipping operators’  adaptation costs, especially for ships in national traffic 
and  for  SMEs,  Member  States  may  decide  to  allow  for  shipping  operators  to  continue 
reporting  their  maritime  transport  formalities  either  to  the  former  National  Single  Window 
front-end interface (primarily relevant for option C) or directly to the back-end entities where 
it is so possible (to customs IT systems, port community systems, national authorities). The 
former case would entail duplication costs, e.g. on interface maintenance, that Member States 
may  wish  to  avoid  after  a  transition  period.  The  latter  case  would  not  necessarily  cause 
additional  costs  to  the  Member  States.  Note  that  the  possibility  to  maintain  the  former 
National Single Window front-end does not imply that a Member State could “opt out” of the 
obligation to offer the new harmonised front-end interface.  

As  for  shipping  operators,  there  are  no  additional  costs  beyond  the  normal  update  and 
maintenance costs under current  RFD. The adaptation costs for enabling plug-in  to the  new 
harmonised reporting system are not yet estimated; 68% of shipping operators replying in the 
consultations  expect  “low  or  some  costs”  and  13%  expect  “high  costs”  but  no  shipping 
company  has  been  able  to  provide  an  estimate  figure  of  these  expected  costs.  Costs  for 
shipping  operators  are  also  expected  to  differ  depending  on  e.g.  their  current  reporting 
systems  (graphical  user  interface,  machine-to-machine,  non-digital,  etc.).  For  the  smaller 
companies  applying  graphic  user  interface,  the  cost  can  be  zero  as  the  harmonised 
spreadsheets  will  be  provided  as  free  templates  for  the  new  data  formats.  For  machine-to-
machine reporting there will be a smaller adaptation cost, depending on the current formats. 
In the consultations, the uniform view of shipping industry stakeholders was that any required 
investments will be outweighed by the benefits. The harmonisation also means there will only 
be one update for all EU reporting instead of the need to adapt and update reporting to match 
different and non-synchronised systems for each port. 

The following IT system assumptions have been applied for the cost assessment by the Impact 
Assessment support study. The cost calculations have been done using a Fast Function Point 
Analysis; the full methodology and underlying assumptions are presented in Annex 4. For all 
policy  options,  the  cost  model  includes  the  costs  for  back-end  entity  connections  to  the 
adapted National Single Windows. 

  For  policy  option  A1,  most  major  costs  for  development,  implementation  and 
adaptation  will  be  covered  by  the  Member  States.  The  Member  State  must  translate 
the  specifications  of  the  EU  legislation  into  a  software,  guaranteeing  that  all 
functionalities, interface aspects and data models follow the common set-up and that 
all rules and requirements are fulfilled to ensure quality information flows between the 
back-end entities (e.g. customs trader interfaces and reporting systems) and the front-
end  users  (shipping  operators).  Annual  maintenance  and  operational  costs  will 

51 

 
 
increase  compared  to  the  baseline  cost  (approximate  average  EUR  265  000  per 
Member State and year), due to the expansion of the system.  

For  the  Commission  or  the  entity  assigned  this  task,  there  will  also  be  costs  for 
developing  and  maintaining  the  common  infrastructure,  e.g.  common  databases  and 
registries;  and  to  develop  the  technical  specifications.  EU-level  costs  will  also  be 
incurred for the connections with some central back-end systems. The annual update 
and management costs will cover e.g. helpdesk function towards the Member States, 
stakeholder  management  (governance  mechanism);  specifications  updates  (reflecting 
and following any developments in the underlying legal acts) and the maintenance of 
the common databases and registries.  

  For  policy  option  A2,  the  same  functions  and  related  costs  as  in  option  A1  apply. 
However, there are fewer connected entities (customs IT systems not interconnected), 
lower complexity of requirements/specifications and lower volume of messages to be 
transmitted  without  the  direct  connections  with  customs  IT  systems.  The  costs  for 
option A2 are therefore lower than in option A1. 

  For  policy  option  B1,  the  cost  for  Member  States’  one-off  investments  will  be 
substantially lower than in option A1 since the IT development cost is covered by the 
EU with economy of scale gains. The Member States will have some investment costs 
for  ensuring  the  first  plug-in  of  the  common  front-end  interface  solution  as  new 
reporting  gateway  to  the  National  Single  Windows,  but  the  functionalities  of  the 
National  Single  Windows  beyond  the  front-end  can  remain  more  or  less  unchanged. 
As  in  option  A1,  Member  States  will  face  some  additional  annual  maintenance  and 
operational  costs  caused  by  the  expansion  of  the  system,  in  addition  to  the  baseline 
cost of running the National Single Windows.  

The entity assigned by the Commission (delegation of the task highly likely; the work 
must be done by an entity with sufficient know-how of IT system development with 
EU  eGovernment  principles  in  mind  and  with  sufficient  expertise  of  the  specific 
reporting  requirements  and  linked  procedures)  will  manage  development  and 
production  of  the  front-end  component  IT  solution  and  the  common  specifications. 
This  will  relieve  some  of  the  cost  burden  from  Member  States  as  the  main  IT 
development  task  is  centralised.  The  front-end  solution  must  be  developed  with  the 
current National Single Windows in mind, creating a plug-in solution possible to adopt 
in  all  National  Single  Windows  with  minimum  extra  cost  for  Member  States.  In 
addition, the EU responsible entity would have costs for the common services such as 
databases,  central  helpdesk  function  (towards  Member  States)  and  stakeholder 
management (governance mechanism); these costs will be substantially higher for the 
EU in option B1 than in option A1 as more services are provided to the Member State.  

  For  policy  option  B2, 

lower  complexity  of 
requirements/specifications and lower volume of messages results in lower costs than 
in option B1. 

the  fewer  connected  entities, 

52 

 
 
  For policy option C1, Member States will need to perform updates of their receiving 
end systems; these costs are estimated to be slightly higher than the baseline costs of 
annual  maintenance  of  the  current  system  due  to  the  new  higher  pressure  for 
synchronised updates to legal and technical developments. In addition to maintaining 
the  current  front-end  to  be  able  to  process  data  received  directly  from  vessels  in 
national traffic (if the Member State decides to do so), the National Single Windows 
also  need  to  be  adapted  to  be  compatible  with  the  central  level  gateway.  They  will 
need to be slightly transformed as some functionalities are moved from national to EU 
level  and  a  routing  function  is  instead  added  in  the  National  Single  Window.  These 
more  complex  functionality  adaptations  imply  a  higher  investment  cost  for  Member 
States in adapting the National Single Windows, as compared with option B1. Some 
additional  annual  maintenance  and  operational  costs  are  expected  on  top  of  the 
baseline  cost  for  National  Single  Window  operation  due  to  the  expanded  volume  of 
messages  passing  via  the  window  and  the  stronger  demand  for  timely  updates 
whenever the centralised gateway is updated.  

The  cost  of  development  and  operation  of  the  centralised  solution  and  the  new  EU-
level  reporting  gateway  and  routing  system  will  be  for  the  EU  Commission  budget; 
including  helpdesk  functions  towards  Member  States,  regular  software  updates  and 
risk  mitigation  measures  to  ensure  high  availability  and  high  security  of  the  system. 
The  development  costs  for  the  Commission  for  the  full  IT  system  at  central  level 
(building  from  zero)  is  still  slightly  lower  than  the  cost  of  developing  a  front-end 
solution fit to plug into all existing National Single Windows as is required in options 
B1-B2 while the annual maintenance cost in option C is higher. 

lower  complexity  of 
For  policy  option  C2, 
requirements/specifications and lower volume of messages results in lower costs than 
in option C1. 

the  fewer  connected  entities, 

Regarding the costs for data re-use, there will be no need to establish additional systems for 
this  since  there  are  already  working  solutions  (like  SafeSeaNet)  or  planned  developments 
(like ICS2 for customs) for ‘administration to administration’ exchanges. The added value of 
data re-use can therefore be achieved at little or no cost. There may in any case be a need for 
existing authority IT systems to be updated to be in line with the new General Data Protection 
Regulation coming into force in May 2018. The data sharing within the European Maritime 
Single  Window  environment  will  need  to  respect  these  rules,  just  like  all  other  information 
flows  will.  Any  IT  solutions  or  business  rules  being  prepared  under  the  new  initiative  will 
also ensure data protection by design and by default. 

53 

 
 
 
Costs for the Member States  
(€ million, present value) 

Costs for the EU (European Commission 
or other entity assigned with the task)  
(€ million, present value) 

Total costs (€ million, present value) 

Costs for the Member States  
(€ million, present value) 

Baseline   A1 

A2 

B1 

B2 

C1 

C2 

CapEx 
OpEx104 
Total MS 

CapEx 

OpEx 

Total EU 

CapEx 
OpEx107 
Total MS 

CapEx 

EU28 

- 
108 

108 

- 

- 

- 

13,5 
14,3 

27,8 

1,7 

9,6 

11,3 

108 

39,1 

Excluding UK 

- 

12,9 

104 

104 

13,7 

26,6 

- 

1,7 

10,7 
11,0 

21,7 

1,7 

9,6 

11,3 

33,0 

10,2 

10,5 

20,7 

1,7 

7,8 
8,1 

7,1  10,7102  10,7103 
8,1 
8,1 
6,8 

15,8 

13,9 

2,5 

11,0 

13,5 

29,4 

2,5 

10,9 

13,3 

27,2 

18,8 

2,4 

13,0 

15,4 

34,2 

18,8 

2,4 

12,0 

14,4 

33,2 

7,5 

7,8 

6,8  10,2105  10,2106 
7,8 
7,8 
6,6 

15,2 

13,4 

2,5 

2,5 

18,0 

2,4 

18,0 

2,4 

Costs for the EU (European Commission 
 or other entity assigned with the task)  
(€ million, present value) 
Total costs (€ million, present value) 
Table 4: Investment/adaptation and operational costs (total period 2020-2030, EUR million, present value); 4% Better 
Regulation discount rate applies.  

11,3 
32,0 

11,3 
37.9 

13,5 
28,7 

13,3 
26,7 

15,4 
33,4 

Total EU 

- 
104 

OpEx 

11,0 

10,9 

13,0 

9,6 

9,6 

- 

12,0 

14,4 
32,4 

6.2. 

SME impacts 

6.2.1.  Benefits 

SMEs will benefit to a high degree especially from reduced administrative burden and more 
efficient  interactions  with  authorities  (data  re-use,  single  entry  point,  rationalisation  of 
duplicate or redundant reporting): SMEs generally have limited resources and are less likely 
to have the IT systems for machine-to-machine reporting. They are therefore more likely to be 
in  the  higher  end  of  average  reporting  burden  per  port  call  today.  Furthermore,  in  small 
companies  every  staff  hour  saved  makes  a  proportionally  bigger  difference  than  for  large 
companies with bigger on-board crew.  

102 This cost includes a cautious assumption of all Member States maintaining the current front-end gateway as 
an option for vessels in domestic traffic; in a scenario with no Member State providing this offer the total 
cost would be EUR 3 million lower (7.7) 

103 Idem 
104 In addition to the Member States' baseline cost for annual operation of the current National Single Windows; 

those costs also remain in all options. 
105 As in the C1 scenario for EU28 (7.2 million) 
106 As in the C2 scenario for EU28 (7.2 million) 
107 In addition to the Member States' baseline cost for annual operation of the current National Single Windows; 

those costs also remain in all options. 

54 

 
 
  
 
                                                            
 
In the targeted interviews, SMEs especially pointed to their expected benefits from clarified 
data re-use principles and data rules including regarding the use of potentially personal data. 
The consulted SMEs stressed that they struggle to integrate the requirements of the complex 
GDPR  in  their  business  models.  Especially  SME  shipping  companies  and  ship  agents 
mentioned this in the interviews, stressing that they have limited resources to put in place the 
right IT infrastructure to ensure GDPR compliance. 

Data is not sufficiently available to calculate a separate benefit quota for SMEs. 

6.2.2.  Costs 

Adaptation costs for SMEs and other shipping companies would be negligible or in size of the 
normal  regular  updates  under  the  current  RFD,  notably  since  the  harmonised  new  reporting 
entry point is offered and not a mandatory system. No additional costs are therefore forced on 
SMEs. 

6.3. 

Social impacts 

6.3.1.  Benefits 

The  direct  effect  is  notably  the  decrease  in  cumbersome  and  repetitive  work  tasks  for  the 
shipping operators, notably the ship masters. In the consultations, such tasks were pointed out 
by social partners as a very negative side-effect of the inefficient reporting environment. 70% 
of  all  respondents  expect  positive  or  strongly  positive  impact  on  overall  job  quality  from 
harmonisation  options  A  and  B;  90%  expect  positive  or  strongly  positive  impact  from 
harmonisation  option  C.  No  single  respondent  expect  negative  impacts  on  job  quality  from 
either  option.  Ship  masters  are  highly  qualified  professionals  with  long  education  for 
navigation; it is considered a particular waste of skills to spend their high-cost staff hours on 
burdensome  bureaucracy.  In  a  situation  where  the  maritime  transport  sector  finds  it 
increasingly difficult to recruit competent and qualified staff108, actions to make the maritime 
profession  more  attractive  by  reduced  administrative  burden  would  therefore  be  highly 
welcome.  Harmonisation  of  reporting  will  ease  this  burden;  single  reporting  entry  point  for 
customs  and  maritime  reporting;  reporting-only-once  and  continued  improvement  of  data 
flows  and  possibilities  of  more  machine-to-machine  reporting  offer  further  benefits  in  this 
regard. The value of this social benefit cannot be easily monetised and quantified. 

Apart from job satisfaction and quality of work, several stakeholders in the consultations have 
stressed  the  indirect  expected  benefit  on  safety  levels.  It  is  commonly  expected  that  the 
released staff hours will to a large extent be shifted to safety related tasks, especially when the 
ship  master  can  spend  his  time  at  the  bridge  instead  of  with  the  excel  sheets.  This  is 
particularly  important  since  much  of  the  reporting  requirements  are  due  at  the  time  a  ship 

108 https://ec.europa.eu/transport/modes/maritime/seafarers_en 

55 

 
 
                                                            
 
enters the port; so at the peak activity of a ship journey when the attention of the ship master 
would be most needed at the bridge. 

6.3.2.  Costs 

Any indirect negative social impact is primarily expected for shipping agents. With simplified 
reporting procedures, some shipping operators may no longer need shipping agent services in 
their  current  format.  For  this  group  of  stakeholders,  tasks  and  business  opportunities  will 
transform and jobs may disappear. It is impossible to make a credible estimate of this impact; 
since ship agents themselves primarily expect their services may be transformed rather than 
made  redundant109  and  since  the  over-all  shipping  volumes  may  at  the  same  time  increase, 
balancing out some of the potential negative impacts. 

6.4.  Environmental impacts 

6.4.1.  Benefits 

The  modelling  performed  with  the  PRIMES-TREMOVE  and  TRUST  models110  show  that 
policy options  A1-C1 would shift 3,395 million tonne-kilometres to waterborne transport in 
2030, mostly away from road, because of improved competitiveness of the sector (i.e. lower 
administrative  burden  relative  to  the  baseline).  This  represents  about  0.3%  increase  in  the 
transport  activity  of  the  waterborne  transport  in  2030  relative  to  the  baseline.  The  shift  in 
traffic  towards  waterborne  transport  would  also  have  an  environmental  impact  in  terms  of 
reduced  greenhouse  gas  emissions.  Over  the  2020-2030  horizon,  freight  transport  emissions 
are  estimated  to  decrease  by  1,880  thousand  tonnes  of  CO2  (0.1%  decrease)  relative  to  the 
baseline. This translates into around €145 million of external costs savings over 2020-2030, 
expressed as present value. The impacts of policy options A2-C2 would be more limited, due 
to the lower reduction in administrative burden relative to the baseline: 1,185 million tonne-
kilometres  shifted  to  waterborne  transport  in  2030  (mostly  away  from  road);  630  thousand 

109  Expected  impact  according  to  the  European  association  for  ship  agents,  ECASBA:  job  transformation  and 
higher  efficiency  primarily;  low  employment  impact.  From  the  case  study  interviews:  “Ship  agents  are 
confident about the demand for their services independently of the status of the NSW in which they work in. 
They believe they will benefit from harmonisation and digitalisation independently of how large a share of 
their business currently relies on handling reporting formalities”. 

110 The modelling has been performed by ICCS-E3MLab and TRT. The PRIMES-TREMOVE transport model 
and the TRUST model have been used to assess the impacts on modal shift and environmental impacts. The time 
savings for the shipping operators in the policy options relative to the Baseline have been used to calculate the 
impacts on the generalised transport costs by origin-destination with the TRUST model. The changes in the 
generalised transport costs have been subsequently used in PRIMES-TREMOVE to derive the impacts on modal 
shares for all freight transport modes together with their impacts on CO2 emissions. The time savings assumed 
for quantifying the impacts on modal shift and CO2 emissions are the same as those used for assessing the 
reduced administrative burden. More details about the inputs used and the modelling setup is provided in Annex 
4. 

56 

 
 
                                                            
 
tonnes  of  CO2  saved  relative  to  the  baseline  over  2020-2030,  equivalent  to  external  costs 
savings of around €48 million (expressed as present value). 

In the case studies, it was mentioned that in some Mediterranean and Black Sea ports, ships 
may  wait  even  days  outside  a  port  with  engines  running,  due  to  congestion  which  could  at 
least partly be relieved by better data handling and data flows to and from authorities. In the 
consultations, deep sea shipping operators mentioned that with less time spent in port or more 
accurate  port  availability  information,  they  could  adjust  speed  to  go  slower,  thereby  saving 
fuel and emissions. These impacts are non-quantifiable because of lack of detailed data. 

6.4.2.  Costs 

No negative environmental impacts have been suggested or identified. 

6.5.  Other impacts 

More  efficient  procedures  will  also  have  indirect  unquantifiable  benefits  for  maritime 
transport operators. The consequence of the more harmonised and simplified reporting would 
be  improved  competitiveness  for  the  maritime  transport  sector,  as  shipping  operators  can 
spend more time and effort on business related matters instead of on reporting; also costs for 
ship agents may to some extent be saved. This could indirectly benefit business results, GDP 
growth and prices for consumers.  

In  addition,  the  potential  benefits  of  National  Single  Windows  will  increase  if  the  digital 
information  received  is  efficiently  re-used  for  improving  maritime  transport  and  related 
multimodal  and  logistic  services.  For  example,  a  harmonised  provision  and  efficient  and 
appropriate  re-use  of  arrival  or  departure  times  could  enable  transport  and  logistics  service 
providers  to  optimise  the  flow  of  cargo  in  and  out  of  ports  in  real-time.  This  would  in  turn 
facilitate  the  establishment  of  more  efficient  and  environmentally-friendly  transport  and 
logistics services for all users. These indirect effects have not been possible to quantify.  

Member  States,  ports  and  other  authorities  are  expected  to  experience  less  tangible  benefits 
from improved data sharing and re-use; although in the long run the investments in such data 
flow systems may  have  beneficial  indirect effects on over-all efficiency gains and  enabling 
new  quality  services;  Member  States  are  also expected to  benefit  qualitatively  from  better 
information  exchanges  and  information  flows  between  authorities  nationally  and  cross-
border. 

Digital reporting offers a large potential to improve the efficiency and reliability of reporting 
process but also requires close attention from the point of view of concerns and risks related 
to  the  security  of  the  digital  reporting  and  wireless  communication  systems.  Cybersecurity 
and privacy technologies should become complementary enablers of the EU digital economy, 
ensuring a trusted networked ICT environment for governments, businesses and individuals. 
The EU ambition is to become a world leader in a secure digital economy.  

The  prevention  of  and  the  protection  against  attacks  that  target  modern  ICT  components, 
complex  ICT  infrastructures,  and  emerging  technologies  as  well  as  ensuring  continued 
operation  or  redundancy  remains  a  difficult  task.  This  concern  applies  to  all  considered 
options.  Whichever  option  is  chosen,  it  should  be  guaranteed  that  the  adopted  system  will 

57 

 
 
remain  open  to  the  continued  evolution  of  innovative  solutions  that  will  help  to  achieve  a 
well-functioning, harmonised, secure and future-proof digital reporting environment enabling 
interconnectivity and coordination of transport and customs related reporting, to improve the 
efficiency  attractiveness  and  environmental  sustainability  of  maritime  transport  while  also 
contributing to the more efficient integration of the sector within digital multimodal logistic 
chains. It should aim for  technology neutrality, and seek to avoid lock-in to one particular 
technology solution or technique that may change in future. Also the automation and technical 
developments in ships are expected to have a significant impact (see above, chapter 2.4). 

7.  HOW DO THE OPTIONS COMPARE? 

7.1. 

Stakeholder preferences 

Views among stakeholder groups differ substantially when it comes to the policy options for 
harmonisation.  Among  shipping  companies  and  ship  agents,  the  strong  preference  is  for 
greatest  possible  harmonisation;  the  largest  share  (43%)  supported  option  C.  They  have  not 
shared  strong  objections  against  any  option  except  status  quo.  Member  States  on  the  other 
hand  have,  in  interviews  and  consultation  events,  voiced  strong  objections  against  a 
centralised  approach.  Among  Member  States,  the  preferred  options  are  instead  option  A 
(40%) and option B (30%). Ports and port community system providers have been mostly in 
favour of discarded option D (31%) followed by option A (25%); however, these stakeholders 
are  neither  primarily  affected  by  the  problem  or  by  the  solution  (no  high  cost  of  new  legal 
obligations).  

It should be noted that in the consultations, no estimates on costs and benefits were yet ready 
and provided to stakeholders; the choices were made on the basis of other considerations. To 
be  able  to  take  the  differing  views  properly  into  account,  the  underlying  reasons  for  the 
stakeholder group choices were considered. 

The different preferences reflect the main interests of these groups. Shipping operators want 
to remove the administrative burden. Member States have stressed their interest in protecting 
their  previous  investments  in  National  Single  Windows.  Ports  and  port  community  systems 
have no specific disadvantages in the current non-harmonised situation and are less concerned 
about change.  

For Member States in particular it seems to be a political choice more than a preference based 
on  cost  calculations.  There  is  reluctance  to  accept  a  new  layer  of  structures  between  the 
National  Single  Window  and  the  shipping  operators  and  a  desire  to  maintain  a  degree  of 
control  over  the  operation  of  the  reporting  gateways.  There  is  also  a  high  awareness  of  the 
potential  risk  of  a  single  point  of  failure  with  high  impact  on  port  operations  in  case  the 
central reporting gateway fails.  

Shipping operators’ interest in a centralised system seems to be based on distrust in Member 
States’  capacity  to  achieve  harmonisation  when  in  charge  of  building  their  own  systems. 
Therefore,  options  B1-B2  represent  a  compromise  option  whereby  Members  States  would 
retain control on the operation of the reporting gateway, while stakeholders’ distrust could be 

58 

 
 
appeased  by  guaranteeing  a  harmonised  front-end  gateway/interface  developed  at  EU  level 
and delivered to all Member States. 

Regarding the scope of the requirements, shipping operators and ship agents strongly prefer a 
comprehensive scope including all national requirements (96% of shipping companies, 82% 
of ship agents) and all cargo reporting (93% of shipping companies, 85% of ship agents) via 
the  European  Maritime  Single  Window  environment;  this  is  less  of  a  priority  for  Member 
States (52% supporting national requirement inclusion; 79% supporting inclusion of customs 
formalities) and port operators (91% support inclusion of national requirement; 71% inclusion 
of customs formalities). 

For  back-end  entities,  options  A1-A2  are  expected  to  be  more  attractive,  giving  better 
possibility  of  synchronisation  of  national  level  requirements.  This  would  however  be  a 
potential  trade-off  at  the  expense  of  harmonisation  towards  the  shipping  operators  (lower 
benefits achieved). 

7.2.  Effectiveness 

For  policy  option  A1-A2,  the  responsibility  for  interpretation  and  implementation  of  the 
common specifications lies fully on Member States. The likelihood of reaching the objective 
of a fully harmonised reporting environment is therefore lower – differences in interpretation 
are likely to result in some fragmentation still of the systems, even if the main functionalities 
work  in  the  same  way  everywhere.  The  high  risk  of  non-synchronisation  (Member  States 
likely  to  have  different  cycles  for  updates  and  different  speed  of  implementation  and 
maintenance)  also  reduces  the  expected  effectiveness  of  the  option.  The  expected 
effectiveness  towards  the  objective  of  harmonisation  is  therefore  lower  with  option  A  than 
with options B-C.  

For  policy  option  B1-B2,  responsibility  for  interpretation  of  the  specifications  is  with  the 
EU-level  entity  in  charge  of  the  common  reporting  gateway  IT  solution,  ensuring  that  the 
harmonisation objective can be effectively reached. The timely installation and running of this 
IT component is then the responsibility of the Member States. Effectiveness may decrease if 
Member  States  fail  to  update  timely  and  in  accordance  with  instruction  by  the  responsible 
EU-level  entity.  Overall,  however  the  options  B1-B2  are  expected  to  deliver  reliable  and 
sufficient achievement of the harmonisation goals. 

For policy option C1-C2, the expected effectiveness of harmonisation is high: a single entry 
point will by nature provide the fully harmonised reporting environment.  

Policy  options  A1,  B1  and  C1  are  all  expected  to  deliver  high  effectiveness  towards  the 
single  entry  point  objective;  slightly  lower  however  for  option  A1  due  to  the  likelihood  of 
national  level  differences  in  the  interpretation  of  technical  specifications.  The  objective  of 
efficient  data  sharing  and  data  re-use  will  also  be  more  effectively  achieved  in  a  fully 
integrated reporting environment. In policy options A2, B2 and C2 however the single entry 
point objective will not be completely achieved as maritime and customs reporting will not be 
fully  integrated;  this  also  affects  the  effectiveness  towards  data  re-use  and  “reporting  only 
once”. 

59 

 
 
Beyond the direct effects and objectives, all options will contribute to the general objective of 
the  smooth  functioning  of  the  Single  Market;  the  simplification,  digitalisation  and  reduced 
burden on economic operators is expected to benefit the overall EU objectives by supporting 
more efficient trade and transport and thereby growth, competitiveness and employment. 

A1 

+ 

++ 

A2 

+ 

+ 

B1 

++ 

B2 

++ 

C1 

C2 

+++ 

+++ 

+++ 

+ 

+++ 

++ 

+++ 

++ 

+++ 

++ 

+++ 

++ 

++ 

+ 

+++ 

++ 

+++ 

++ 

Compared to Baseline  

Specific  objective:  To  harmonise  reporting 
procedures, interfaces and data formats  

Specific objective: To reduce administrative 
through  single  entry  point  for 
burden 
reporting  

Specific  objective:  To  increase  efficiency 
by enabling reporting only once 

General  objective:  To  contribute  to  the 
smooth functioning of the Single Market by 
facilitating trade and transport 

7.3.  Cost-efficiency 

The Impact assessment support study found that for the costs calculated, even an average time 
saving of five minutes per port call would lead to benefits matching the costs111. The expected 
time  savings  are  substantially  higher  than  this  figure  for  all  options  even  with  the  cautious 
estimate  ranges  and  the  assumption  of  a  slow  and  gradual  uptake;  the  cost-benefit  ratio  is 
clearly positive for all analysed options. 

(EU28) 

A1 

A2 

B1 

B2 

C1 

C2 

Benefit:  estimated  value  of  staff 
hours saved compared to baseline 

Costs:  total  estimated  additional 
costs for MS and COM (on top of 
baseline costs EUR 108 million for 
the time period) 

Cost-benefit ratio  

625-720 

215-245 

625-720 

215-245 

625-720 

215-245 

39.1 

33.0 

29.4 

27.2 

34.2 

33.2 

16.0-
18.5 

6.5-7.5 

21.3-24.6 

7.9-9.1 

18.3-21.1 

6.4-7.4 

111 COWI, Support study for the impact assessment of a European Maritime Single Window environment, 2018 

60 

 
 
 
 
                                                            
 
The costs are higher in options A1, B1 and C1 but the benefits for shipping operators are also 
considerably  higher.  Options  A2,  B2  and  C2  are  less  costly  and  easier  to  implement  and 
maintain but less ambitious in terms of achieving benefits and with subsequently lower cost-
benefit ratio.  

The ranking of options cost-wise remains the same even if we make the assumption that no 
Member  State  decides  to  offer  the  current  reporting  gateway  as  an  option  for  vessels  in 
national  traffic  (up  to  3  million  lower  costs  for  Member  States  in  total).  The  difference 
between options B and options C will be marginal. 

Options  A1-A2  have  less  certainty  of  achieving  the  benefits  (interpretation  of  the  technical 
specifications  is  done  by  the  Member  States;  unlikely  to  result  in  permanently  identical 
reporting  interfaces  although  main  functionalities  should  be  similar)  and  incur  the  highest 
costs  for  the  Member  States.  Options  B1-B2  is  the  least  costly,  in  particular  for  Member 
States, and yields high certainty of benefits for the shipping operators due to a better control 
on EU level harmonisation than with options A1-A2. Options C1-C2 have higher costs, but, 
as  options  B1-B2,  provides  high  certainty  of  benefits.  It  should  however  be  noted  that  the 
differences in total costs for the period of 2020-2030 are very low (EUR 11.9 million between 
the  most  expensive  and  the  cheapest  options)  and  the  cost-benefit  ratio  high  for  all  options 
and in particular for all comprehensive scope options. 

The option with highest cost-benefit ratio is option B1 (second cheapest option). 

7.4.  Coherence 

All options are in coherence with other EU policy objectives.  

The  objectives  of  the  proposal  are  in  coherence  with  EU  transport  policy  in  general  and 
maritime  transport  policy  in  particular.  The  initiative  supports  EU  policy  on  reducing 
emissions from the transport sector and contributes to the objectives of the EU transport social 
agenda. It remains well coherent with the Vessel Traffic Monitoring and Information Systems 
Directive  and  brings  added  value  by  enabling  coordination  of  the  reporting  requirements 
under the reference legal acts. The governance mechanism established in all options provides 
a guarantee that changes in underlying legislation will be appropriately and timely mirrored in 
the technical data set and with required updates for specifications and IT component.  

All  assessed  options  are  in  line  with  the  Commission  REFIT  programme  objectives  of 
administrative  burden  reduction  and  simplification  and  with  the  overall  Commission 
objectives of competitiveness, smoothly functioning internal market and digitalisation. 

The  proposal  is  in  coherence  and  closely  aligned  with  the  implementation  of  the  Union 
Customs  Code.  Options  A1-C1  create  a  closer  interconnection  between  the  maritime  and 
customs  policy  areas  requiring  more  efforts  for  cooperation  and  harmonisation  between  the 
services.  This  creates  a  higher  level  of  complexity  but  also  opportunities  for  increased 
coherence with benefits for external stakeholders. 

The  proposal  complements  also  the  initiative  on  electronic  freight  transport  information 
concerning  acceptance  in  digital  format  of  freight  transport  related  information  and 
certificates by authorities performing transport-related inspections in the EU hinterland. Just 

61 

 
 
like  the  e-Documents  initiative,  the  European  Maritime  Single  Window  environment  will 
support  digitalisation  and  simplification  for  transport  operators;  although  the  two  initiatives 
address  different  aspects  of  information  reporting  requirements  at  different  stages  in  the 
course of a freight transport operation. The two proposals have been developed with particular 
care to exploit synergies with regards to data interoperability aspects. 

None of the options will create contradictions with existing EU acquis. 

7.5. 

 Proportionality 

The  options  are  designed  not  to  impose  any  disproportionate  burden  on  the  shipping 
operators,  notably  by  offering  the  harmonised  European  Maritime  Single  Window 
environment as non-mandatory for shipping operators. By building on the existing structure of 
National  Single  Windows,  costs  to  Member  States  are  limited  and  clearly  exceeded  by  the 
potential direct and indirect benefits.  

Options C1 and C2 creates an additional EU-level layer between the shipping operators and 
Member  State  authorities,  creating  a  new  structure  for  reporting.  However,  even  these 
centralised option would be justifiable with respect to the benefits it would bring in terms of 
reduced administrative burden. 

None  of  the  options  therefore  go  beyond  what  is  necessary  to  achieve  the  objectives.  The 
expected  high  efficiency  gains  cannot  be  achieved  by  action  only  on  Member  State  or 
international level nor by other, non-legislative means. The proposed expansion of the scope 
is  well  defended  by  the  benefits  expected.  New  reporting  requirements  are  not  created  but 
existing requirements are brought into a coordination mechanism. 

To achieve the objectives, a Regulation replacing the current RFD is proposed as the adequate 
instrument. 

7.6. 

Summary: comparison of options 

The  preferences  for  different  options  differ  widely  between  the  stakeholder  groups.  While 
options  B1-B2  are  not  the  first  choice  of  any  stakeholder  group,  it  could  present  a  suitable 
compromise  option  for  all  main  stakeholder  categories,  considering  especially  that  the 
acceptance  for  option  C1-C2  is  low  among  Member  States.  The  compromise  option  should 
provide sufficient guarantees of harmonised front-ends to be supported also by the shipping 
operators  when  adopted.  None  of  the  other  options  present  a  realistic  compromise  with 
possibility of being supported by all main groups. 

The  options  B1-C1  have  highest  expected  effectiveness,  addressing  all  problem  drivers  and 
most likely to produce complete harmonisation of the front-end interfaces/gateways and data 
formats. These options are more likely to facilitate also the data re-use/data sharing issue, as 
compared to the limited scope options. 

While  option  B2  would  be  cheaper  to  implement,  it  would  also  yield  substantially  lower 
benefits for the shipping operators (trade-off). All options will result in unbalanced outcomes 

62 

 
 
for  the  different  stakeholder  groups:  the  costs  incurred  will  be  primarily  for  Member  States 
and  the  Commission  whereas  the  direct  benefits  will  be  reaped  by  the  maritime  transport 
industry.  Indirectly,  this  will  however  benefit  the  entire  Union  objectives  in  terms  of  more 
efficient trade and transport, beneficial for overall growth, competitiveness and employment.  

In terms of cost-benefit ratio, the options A1-C1 score higher than options A2-C2 with best 
ratio  for  option  B1.  The  cost-benefit  results  remain  clearly  positive  also  when  testing  the 
options for the assessed uncertainty of cost and benefit estimates (e.g. calculating benefits in a 
more pessimistic uptake scenario). The costs are however very similar across all options and 
the  cost  aspect  alone  is  not  sufficiently  decisive  to  argue  strongly  for  one  option  over  the 
others. 

The risk of system failure is lower in a distributed system, as in options A1-A2 and B1-B2. 
These options have higher resilience against e.g. cyber-attacks or technical break-down. The 
likelihood of all National Single Windows breaking down at the same time is considered low. 
Options C1-C2 on the other hand have a higher vulnerability because of the “single point of 
failure”  (low  resilience  to  cyber  security,  technical  failures;  high  impact  in  case  of  failure) 
which  would  require  solid  back-up  measures  to  mitigate  the  risk,  e.g.  by  transfer  of  risk 
(managed  hosting)  or  measures  to  lower  potential  impacts  (business  continuity  facility).  On 
the other hand, implementation related risk is higher in options A1-A2 and B1-B2 if not all 
MS have the capacity to properly apply the specifications and/or common software. The main 
risk  in  this  regard  is  the  non-synchronisation  and  failure  by  Member  States  to  update  their 
National  Single  Windows  timely  to  new  specifications,  notably  in  options  A1-A2  where  all 
developments  must  be  completed  at  Member  State  level.  This  risk  remains  even  with  a 
Regulation  as  legal  instrument  as  specifications  will  be  updated  by  delegated/implementing 
act. There is also a higher risk in A1-A2 and B1-B2 that there is no or an insufficient common 
knowledge base for the help-desk, resulting in heterogeneous quality of help-desk towards the 
data providers and back-end connected entities. 

Effectiveness 

Efficiency 

Coherence 

Proportionality 

Baseline 

Option A1 

Option A2 

Option B1 

Option B2 

Option C1 

Option C2 

0 

++ 

+ 

+++ 

++ 

+++ 

++ 

0 

+++ 

+++ 

+++ 

+++ 

+++ 

+++ 

0 

+++ 

+++ 

+++ 

+++ 

++ 

++ 

0 

++ 

+ 

+++ 

+ 

+++ 

+ 

63 

 
 
 
8.  PREFERRED OPTION 

The  preferred  option,  based  on  a  combined  analysis  of  cost-benefit  ratio,  acceptance  by 
stakeholders  and  expected  effectiveness,  proportionality  and  risk  rating,  is  therefore  option 
B1 with a total expected additional cost of EUR 29.4 million for 2020-2030 and expected new 
benefits of 22-25 million saved staff hours for the same time period (equivalent to a value of 
EUR  625-720  million).  This  option  yields  the  highest  benefit  to  an  acceptable  cost.  It  will 
ensure  a  harmonised  reporting  environment  while  respecting  the  current  set-up  of  National 
Single  Windows,  therefore  exploiting  the  already  made  investments.  It  can  realistically 
receive  the  support  of  all  main  stakeholder  groups.  The  burden  on  Member  States  is 
minimised  by  offering  a  common  software  developed  at  EU  level  and  it  avoids  the  risks 
attached to creating an additional layer of architecture (including by ensuring proportionality 
of the proposal) and reduces the risks deriving form single point of failure. 

The option will have budget implications for the European Commission, with expected costs 
for IT services and IT system development up to  EUR 13.5 million in the period of eleven 
years 2020-2030. The Commission costs are proposed to be covered via Support activities to 
the  European  transport  policy  and  passenger  rights  including  communication  activities 
(budget reference 06.02.05). 

In this, as in the other options, delegation of the IT development tasks is likely to be needed. 
The  main  project  management  will  remain  with  the  Commission  services  but  it  is  probable 
that  some  IT  development  services  will  need  to  be  provided  by  external  contractors  or 
specialised entities.  Commission  specialised  services and decentralised agencies with  expert 
know-how of IT system development (including EU eGovernment principles) and the specific 
maritime transport reporting requirements and linked procedures will need to be involved as 
appropriate.  Expertise  from  several  services  may  need  to  be  involved  in  the  project 
management  and  governance  mechanism,  e.g.  to  ensure  coordination  with  all  connected 
policy  areas  (underlying  legal  acts).  The  detailed  task  division  including  contracting  of  IT 
development  services  should  be  defined  in  connection  to  the  development  of  work  plans  in 
line with delegated/implementing acts. 

The  governance  mechanism  required  is  a  set  of  implementing/delegated  powers  to  enable 
necessary  updates  in  line  with  legal  and  technical  updates;  and  a  dedicated  expert  group  in 
coordination with all relevant Commission services. 

9.  REFIT (SIMPLIFICATION AND IMPROVED EFFICIENCY) 

The preferred option offers significant simplification and improved efficiency by reducing the 
administrative burden for shipping operators fulfilling legal requirements in  connection  to  a 
port call. 

The reduced administrative burden is expected to be achieved as the result of 1) harmonised 
front-end  reporting  gateways,  procedures  and  data  formats;  2)  the  provision  of  a  single 
reporting  entry  point;  3)  more  efficient  re-use  of  data  enabling  reporting  only  once  and 
removal  of  duplicate  reporting.  With  a  comprehensive  coordination  mechanism  for  all  port-
call  related  reporting  for  a  shipping  operator,  in  combination  with  fully  harmonised  data 

64 

 
 
formats,  reporting  procedures  and  front-end  interfaces,  a  high  number  of  staff  hours  can  be 
spent on other tasks, notably related to core business, to safety and security. 

REFIT Cost Savings – Preferred Option: B1 
Amount 
Description 

Comments 

Time saved on port call reporting: total 
for  all  EU  port  calls  over  the  baseline 
period 2020-2030.  

22-25  million  staff  hours 
in  the  time  period  2020-
2030;  equivalent 
to  a 
value  of  EUR  625-720 
million 

Major benefit for maritime transport 
operators 
operators); 
(shipping 
indirect  benefits  for  competitiveness 
and modal shift. 

Costs  primarily  for  the  Commission 
and for Member States authorities. 

10.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission will follow the progress, the impacts and results of this initiative by a set of 
monitoring  /  evaluation  mechanisms.  Progress  will  be  measured  towards  achieving  the 
specific  objectives  of  the  new  proposal.  With  more  clear  and  detailed  specifications  in  the 
new legal framework and with more support to Member States for implementation (notably: 
by  providing  the  common  front-end  plug-on  solution),  the  expected  implementation  rate  is 
substantially higher than for the current RFD. 

The  basis  for  monitoring  progress  will  by  necessity  be  the assessments  and  reports  by  the 
affected stakeholders (Member States, shipping operators). Static data on baseline issues such 
as  number  of  port  calls  and  number  of  reported  data  elements  per  port  call  can  be 
automatically extracted from the IT systems; this will however only give context information 
and not proof of achievement of the proposal objectives. The stakeholders’ assessments and 
replies  will  be  carefully  analysed  and  may  be  followed-up  if  needed  with  additional 
questionnaires or fact-finding activities.  

Requests  for  information  (reports,  survey  replies)  must  be  carefully  balanced  not  to  cause 
additional burden on the stakeholders by creating disproportionate new reporting requests. It 
could  be  considered  to  develop  a  survey  for  regular  consultation  of  stakeholders  e.g.  every 
two years following implementation. Specific monitoring of Member States’ implementation 
will also be done within the normal procedures for follow-up of legislation implementation, 
including the launch of infringement procedures in case needed. 

The  progress  indicators  will  show  development  over  time,  with  the  aim  of  reaching  100% 
success rate for each indicator. However, the main usefulness of the progress indicators is to 
identify areas or Member States where developments are slower, in order to set in appropriate 
countermeasures and support measures (e.g. training, guidance, technical assistance). 

Five years after the end of the implementation date of the legal proposal, the Commission will 
also  initiate  an  evaluation  to  verify  whether  the  objectives  of  the  initiative  have  been 
reached,  based  on  the  first  Member  States  reports  and  on  the  first  surveys  and  other  inputs 
(e.g. complaints submitted) from shipping operators. The aim is to determine whether the new 
measures  in  place  have  improved  the  situation.  Subsequently,  the  evaluation  will  inform 

65 

 
 
 
future  decision-making  processes  to  ensure  necessary  adjustments  for  reaching  the  set 
objectives.  

Data sources 

Member 
States 
to 
reports;  surveys 
shipping  operators; 
of 
number 
complaints 
by 
operators 
shipping 
regarding  access  to 
harmonised 
reporting 
gateway; 
number  of  on-going 
infringement 
procedures 
against 
Member  States  for 
non-implementation 

Success 
criteria 
  Data 

Specific objective  Operational 

Progress indicator 

harmonise 

To 
reporting 
procedures, 
interfaces  and  data 
formats 

objectives 
  Establish 
set 
data 
harmonised 
formats 
  Develop 

technical 
with 
data 

and 
implement  common 
harmonised 
software 
Nation 
Windows 

the 
Single 

for 

  Data 

set 

established  
  %  of  Member 
having 
the 

States 
installed 
harmonised 
reporting gateway 
software 
(synchronised, 
updated  version) 
over 
total  (Ref: 
Total  number  of 
MSs)  

  % 

in 
reduction 
time  required  for 
reporting  per  port 
total 
call  over 
(Ref: 
Average 
time per port call) 

 

 

set 
agreed  by 
the  expert 
group 
90-100% 
of Member 
States 
installed 
the 
reporting 
gateway 
by 
implement
ation 
deadline 
50% 
reduction 
in 
reporting 
per 
time 
port 
call 
for  vessels 
fixed 
in 
route 
traffic; 
75% 
reduction 
in 
reporting 
time 
port 
for 
traffic 
vessels  by 
5 
years 
after 
implement
ation 
deadline 

per 
call 
tramp 

Member 
reports;  survey 
shipping operators 

States 
to 

of 

  0-5% 
data 
elements 
are 
requested 
separately. 

reduce 

To 
administrative 
burden 
through 
single  entry  point 
for reporting 

  Reduce 

data 
elements  requested 
outside 
the 
harmonised 
European  Maritime 
Window 
Single 
environment 
for 
maritime transport 

  % 

data 

of 
elements 
requested  outside 
the 
harmonised 
European 
Maritime  Single 
Window 
environment  over 
total.  (Ref:  Total 
number  of  data 
elements 
as 
mapped by Part C 

66 

 
 
 
Member 
reports;  Survey 
shipping operators  

States 
to 

  0-10% 

of 
static  data 
elements 
are 
requested 
more 
than 
once  in  the 
same  port 
call 
  0-20% 

of 
static  data 
elements 
are 
requested 
more 
once 
beyond  the 
same  port, 
within 
the 
EU 

than 

increase 
To 
efficiency 
by 
enabling  reporting 
only once 

  Reduce  static  data 
reported 

elements 
more than once 

group 
and 
eManifest  group 
today) 

  %  of  static  data 

elements 
requested  more 
than  once  for  a 
port 
call  over 
total  (Ref:  Total 
number  of  data 
elements 
requested 
port) 

in  a 

  %  of  static  data 

elements 
requested  more 
than  once  within 
the  EU 
(Ref: 
Total  number  of 
elements 
data 
requested  in  the 
EU) 

67 

 
 
 
 
Annex 1: Procedural information 

Lead DG, Decide Planning/CWP references 

The lead DG is DG MOVE, Unit D1: Maritime Transport and Logistics 

DECIDE reference number: PLAN/2017/1050 

Item  5  in  Annex  II  to  Commission  Work  Programme  2018:  An  agenda  for  a  more  united, 
stronger and more democratic Europe112. 

Organisation and timing 

The impact assessment follows the ex-post evaluation on the Reporting Formalities Directive 
performed as part of the overall maritime transport policy fitness check in 2016-2017. 

The  impact  assessment  started  in  2017,  with  the  first  meeting  of  the  Inter-Service  Steering 
Group on 27 July 2017 and an inception impact assessment subsequently published on 28 July 
2017113.  Eleven  respondents  submitted  public  feedback  on  the  inception  impact  assessment 
(see Annex: consultation synopsis report). 

The  Commission  launched  a  call  for  tenders  for  a  support  study  on  “External  Impact 
Assessment support study on establishing European Maritime Single Window environment”. 
A  contract  was  signed  with  a  consortium  of  Ecorys/COWI  under  contract  reference 
MOVE/DDG2.D1/FV-2017-271  implementing  Framework  contract  No  MOVE/A3/119-
2013/LOT4. The support study was performed 2017-2018. 

The Inter-Service Steering Group met four times and was consulted throughout the different 
steps of the impact assessment process: notably on the Inception Impact Assessment, on the 
ToRs and call for tender for support study, on the consultation documents and on the draft IA 
report. 

The  Commission  Services  participating  in  the  ISG  are:  Secretariat-General,  DG  Maritime 
Affairs and Fisheries, DG Taxation and Customs Union, DG for Communications Networks, 
Content and Technology, DG Budget, DG Climate Action, DG Research & Innovation, DG 
European  Commission  Humanitarian  Aid  &  Civil  Protection  (ECHO),  DG  Migration  and 
Home  Affairs,  DG  for  Employment,  Social  Affairs  and  Inclusion,  DG  Industry, 

112 COM(2017) 650 final 
113 https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3807523_en  

68 

 
 
                                                            
 
Entrepreneurship and SMEs, DG Environment, DG Health and Food Safety and the European 
Maritime Safety Agency (EMSA). 

Consultation of the RSB 

The  draft  report  was  submitted  to  the  RSB  on  14  February  2017  and  was  discussed  by  the 
Board on 7 March 2018. The Board issued a negative opinion on 9 March 2018.  The Board 
made several recommendations. These have been addressed in the revised Impact Assessment 
report as detailed in the table below. This revised impact assessment report was re-submitted 
to the Regulatory Scrutiny Board on 13 March 2018. 

RSB recommendations 

Modification of the IA report 

Main considerations 

The  report  does  not  sufficiently  explain  the 
including  key  design  aspects, 
options, 
implementation  modalities 
and  material 
differences.  As  a  result,  the  presented  cost 
to 
differences  between  options  are  hard 
understand. 

information 

The  text  has  been  significantly  revised  to 
provide more information on the description 
and  design  of  options;  on  the  assumptions 
made  for  these  design  choices;  on  the 
technical  functionalities  of  each  option  and 
how  they  impact  on  the  current  National 
Single  Windows,  and  therefore  also  how 
they  impact  the  cost  calculations  for  each 
option.  More 
cost 
assumptions  has  been  submitted  by  the 
support study team and included into Annex 
4.  Clearer  language  has  been  adopted  to 
make  it  easier  for  readers  to  distinguish 
between 
the  new/changed  functionalities 
proposed  (front-end  reporting  gateway)  and 
remaining  untouched 
the 
in  data 
(National  Single  Windows  role 
back-end 
distribution 
connections). 

functionalities 

towards 

the 

on 

See  in  particular  extensive  redrafting  in 
chapters  5,  6,  7  and  8  and  new  information 
added in Annex 4. 

The  report  does  not  adequately  present 
stakeholders'  views.  These  views  appear 
central to selecting the preferred option, as the 

The text has been updated notably in sections 
7.1  and  7.6  to  more  clearly  explain  the 
concern  not  only  with  the  preferences  of 

69 

 
 
 
report’s evidence of costs and benefits do not 
clearly favour this option. 

stakeholders  but  also  with  the  resistance  of 
stakeholders  against  certain  options  and  the 
analysis  of  underlying 
reasoning  by 
stakeholders,  leading  to  conclusions  about 
possibility  of  a  compromise  option.  The 
missing  information  has  also  been  added  in 
Annex  2:  consultation  synopsis  report  (this 
to 
annex  has  also  been  shortened  due 
translation requirements). 

Further considerations 

report  needs 

The 
to  provide  a  more 
comprehensive overview of existing reporting 
systems,  including  a  description  of  how  they 
serve  different  vessel  types  and  different 
purposes. The report should explain why it is 
necessary  to  maintain  alternative  reporting 
systems 
the  European 
Maritime Single Window (EMSW). 

in  parallel  with 

The report has been revised to provide more 
information on the current and new reporting 
scopes  and  their  purposes.  Clarifications 
have  been  made 
the 
rationale  for  not  making  the  harmonised 
reporting  gateway  mandatory  for  operators 
and  what  this  means  in  practice  under  the 
different options. 

to  better  explain 

See  in  particular  sections  2.2,  5.2,  6.1.2  and 
Annex 5. 

legal 

deficits 

framework, 

The  report  should  more  clearly  define  the 
problem  and 
the  problem  drivers.  The 
evaluation  concludes  that  the  NSWs  do  not 
deliver  on  the  current  directive’s  objectives. 
On  the  basis  of  the  evaluation  results,  the 
report  should  clarify  whether  the  issue  is  the 
in 
current 
implementation  or  the  poor  workings  of  the 
NSWs.  The  report  should  reconsider  to  what 
extent  the  need  for  data  re-use  between  port 
calls can be justified by the (limited) reporting 
costs 
is 
harmonised. It seems that the need for data re-
use is more driven by efficiency gains for the 
authorities  and  the  possibilities  for  more 
effective  controls.  The  report  should  give  the 
reasons  why  the  baseline  expects  that  current 
problems will persist.  

for  operators,  once 

reporting 

the  role  of 

The description of problem drivers has been 
expanded  and 
the  current 
legislation and its implementation is clarified 
(implementation of the current Directive will 
not  solve  any  of  the  main  problem  drivers 
and is therefore not a sufficient solution; the 
key  conclusion  of  the  evaluation  was  the 
shortcoming  of  the  RFD  in  terms  of  lack  of 
clear provisions which can only be addressed 
by 
legal  amendment).  The  data  re-use 
aspects  have  been  specified  and  presented 
more  clearly  and 
lack  of 
harmonisation  has  been  more  directly 
explained. The reason why the problems are 
highly  unlikely  to  disappear  in  the  baseline 
scenario is described in more clear words. 

the  baseline 

See  chapters  1,  2.1,  4.2,  5.2,  5.3,  6.1.1  and 

70 

 
 
6.1.2. 

The options are now described in much more 
detail.  A  new  section  including  comparison 
table  has  been  added  (new  5.4)  to  help  the 
reader.  Detailed  information  on  governance 
and  helpdesk  functions  is  added.  Aspects 
relevant  for  deciding  implementation  mode 
(e.g. delegation of IT development tasks) are 
mentioned. 

See  in  particular  chapters  5.2,  5.3,  new  5.4, 
6.1.2 and 7.6. 

The  link  to  the  electronic  freight  transport 
documents has been presented in more detail. 
See chapter 1.3. 

The report is unclear about key design aspects 
of the options. As a result, it is not clear how 
they would work. The report needs a stronger 
presentation  of  the  differences  between  the 
options,  especially  with  regard  to  how  they 
would co-exist with existing NSWs and other 
reporting  channels.  It  should  detail 
the 
functional  differences  between  a  harmonized 
interface  for  the  NSWs  and  a  European 
Maritime Single Window. It should give a full 
account  of  what  is  required  for  NSWs  to 
interact through a harmonized interface or the 
EMSW.  It  should  also  give  more  details  on 
governance  and  helpdesk  functions  and  how 
these  would  differ  across  options.  The  report 
should  also  be  explicit  about  when  and  on 
what  basis  decisions  on 
implementation 
issues, such as who will develop and manage 
the IT systems, will be taken. 

 The  report  should  better  explain  how  this 
initiative  interacts  with  the  parallel  initiative 
on  paperless  transport  documents.  It  should 
clarify  to  what  extent  the  two  initiatives 
complement each other and how co-dependent 
they  are  in  reaching  the  set  objectives  and 
realising the benefits. In particular, the  report 
should  analyse  to  what  extent  the  different 
approaches of the two initiatives (harmonised 
reporting  system  vs  certification  of  systems) 
could hamper the development of inter-modal 
transport.  

The  report  should  expand  its  discussion  of 
their  preferences 
stakeholders'  views  and 
across  the  options.  The  current  discussion 
raises important questions that the report does 
stakeholder 
not 
groups’  support  for  different  options  appears 
to  vary  considerably,  with  little  common 

fully  answer.  Different 

The  key  aspects  of  stakeholder  opinions 
regarding the options have been clarified and 
more  detail  added.  The  selection  of  the 
preferred  option  is  explained  in  more  detail. 
The  differences  in  costs  (notably:  Member 
States’ costs) are explained more thoroughly 
technical 
the  more  detailed 
following 

71 

 
 
of 

the 

the 

results 

ground besides the call for simplification. The 
report  therefore  needs  to  be  more  specific  on 
how 
stakeholder 
consultations  and  evidence  of  benefits  and 
costs  have  influenced  the  selection  of  the 
preferred option. It could elaborate on various 
concerns  expressed  by  different  stakeholder 
the 
groups,  and  how 
alternative  options.  The  report  should  better 
explain  the  reasons  for  differences  between 
cost estimates for the different options, based 
on a clearer and more complete description of 
the options. 

these  factor 

into 

reporting 

formalities 

The  overall  objective  of  the  proposal  is  to 
simplify 
though 
harmonisation  of  the  data  requirements  and 
reporting  systems.  The  report  should  show 
how the preferred option will provide stronger 
incentives  for  harmonisation  compared  to  the 
current  framework  of  existing  legal  data 
requirements.  Also, 
the  preferred  option 
should  specify  the  choice  of  governance 
model. 

descriptions of all options. 

See especially chapters 5.3, 6.1.2, 7.1, 7.6, 8 
and Annex 4. 

The difference between the proposed options 
and the baseline situation with regards to the 
harmonisation  outcomes  is  more  clearly 
is 
presented.  The  governance  model 
specified for the preferred option. 

See chapters 5.3, 5.4 and 8. 

The  Board  issued  a  second,  positive  opinion  on  20  March  2018  including  some  additional 
recommendations. These have been addressed in the second revised Impact Assessment report 
as detailed in the table below. 

RSB recommendations 

Modification of the IA report 

Main considerations 

The  problem  description  does  not  provide  a 
clear  enough  explanation  of  how  the  existing 
systems  for  reporting  formalities  function 
today.  Relevant 
is  scattered 
across  the  evaluation,  the  annexes  and  other 
parts of the report. 

information 

situation  and  especially 

More  detailed  information  about  current 
reporting 
the 
different  requirements  for  different  vessel 
categories,  is  added  in  sections  2.1  and  2.2 
(P1). 

The report does not specify when and on what 
basis  implementation  issues  will  be  decided, 

Clarification and more detailed description is 
added in section 5.4 and in chapter 8. 

72 

 
 
 
e.g.  who  will  develop  and  manage  the  IT 
systems. 

Further considerations 

The  problem  description  should  present  a 
more  complete  overview  of  the  existing 
reporting systems and their shortcomings. The 
additions  in  annex  5  are  welcome,  and  the 
problem definition section would benefit from 
incorporating  more 
the 
evaluation and annexes. A clearer description 
of how the current system builds on different 
reporting needs for different vessel types with 
different  purposes  would  better  underpin  the 
argument  for  maintaining  alternative  systems 
under the new Single Maritime Window. 

information  from 

The report has revised the arguments in favour 
of  data  re-use.  In  particular,  it  presents  the 
potential  for  more  efficient  procedures  for 
ports  and  authorities  and  for  cross-modal 
information  exchanges.  The  relevant  specific 
objective  should 
this  modified 
argumentation instead of continuing to refer to 
reduced reporting costs for operators. It could 
also  clarify  the  importance  of  re-use  in 
selecting the preferred option. 

integrate 

The revised version of the report clarifies the 
differences  between  the  options.  Renamed 
options  and  a  new  comparison  table  are 
helpful.  Nevertheless,  the  illustrations  of  the 
different  policy  options  in  Annex  6  are  not 
intuitive.  Simpler  illustrations,  accompanying 
explanations  or  both  would  be  helpful  and 
would  add  to  clarity.  A  simple  illustration 
showing  the  different  options  could  be  added 
to the options section. 

The  report  indicates  that  the  Commission 
would  probably  assign  IT  development  to  a 
specialised entity, but it does not specify when 
and  on  what  basis  this  would  happen.  The 
report  should  at  least  be  explicit  about  the 

situation  and  especially 

More  detailed  information  about  current 
reporting 
the 
different  requirements  for  different  vessel 
categories,  is  added  in  sections  2.1  and  2.2 
(P1). 

in  section  2.2  (P3).  Where 

Some  clarification  on  the  main  benefit  is 
added 
the 
reference  to  reduced  reporting  burden  is 
retained  it  is  explained  with  sources  (the 
study  on 
reduction  of 
administration  burden  and  the  consultation 
outcomes). 

eGovernment 

Illustrations  of  the  options  are  added  in 
sections 5.3.1 – 5.3.6. 

illustrations 

in  Annex 
The 
complemented by explanatory text. 

6 

are 

timing  and  decision  on  detailed 
The 
(e.g. 
implementation 
outsourcing contracts and division of specific 
tasks  between  Commission  services  and 
in 
decentralised  agencies) 

is  clarified 

mechanisms 

73 

 
 
sections 5.4 and in chapter 8. 

The  information  in  the  quantification  tables 
has  been  double-checked  and 
remains 
correct. 

the  decision 

process.  If 
the 
legislative  proposal,  the  impact  assessment 
needs to include the underlying analysis. 

is  part  of 

The  Board  takes  note  of  the  quantification  of 
the various costs and benefits associated to the 
preferred  option  of  this  initiative,  as  assessed 
in  the  report  considered  by  the  Board  and 
summarised  in  the  attached  quantification 
tables. The attached quantification tables may 
need  to  be  adjusted  to  reflect  any  changes  in 
the  choice  or  the  design  of  the  preferred 
option in the final version of the report. 

Evidence, sources and quality 

The impact assessment is based on a several sources, using both quantitative and qualitative 
data. This includes: 

• 
• 

• 
• 

• 

• 
• 

• 

Ex-post evaluation of the Reporting Formalities Directive 
In-depth  case  studies  of  five  selected  ports  (Malmö/Copenhagen,  Hamburg, 
Constantza, Bari and Helsinki) 
Public on-line consultation (91 respondents) 
Targeted  consultations  via  surveys  (111  respondents)  and  consultation  events  (5 
workshops and meetings with a total of 167 participants) 
74 interviews (face-to-face or per phone) with stakeholders representing different 
interests 
External support study by Ecorys/COWI including IT cost assessments 
Reporting  time  estimate  model  developed  in  consultation  with  ECSA  and  their 
associated members 
Baseline scenario based on updated EU Reference scenario 2016, developed with 
the  PRIMES-TREMOVE  model  by  the  ICCS-E3MLabLiterature  review  on 
relevant material relating to the directive 

74 

 
 
 
 
Annex 2: Stakeholder consultation  

Synopsis report on the consultations for impact assessment of Directives 2010/65/EU on 
Reporting Formalities for ships arriving in and/or departing from ports of the Member 
States (RFD) 

1.  Introduction 

In June 2017, the European Council invited the Commission to propose follow-up to the revision of 
Directive  2010/65/EU  on Reporting  Formalities  for  Ships  (hereafter  the  RFD).  In  the  preparation  of 
the initiative, extensive consultations were carried out to inform the impact assessment process.  

2.  Methodology and Consultation Activities 

The  consultations  comprise  an  Open  Public  Consultation  (OPC)  and  targeted  consultations  (TC) 
including  consultation  events  and  workshops,  interviews,  case  studies  and  an  e-survey.  Written 
contributions submitted by the stakeholders have also been received. 

Open Public Consultation (OPC) 

The  OPC  online  survey  was  open  from  25  October  2017  to  18  January  2018  and  available  in  all 
official  EU  languages.  In  total,  91  replies  were  received.  13  of  these  stakeholders  also  uploaded 
position papers with their responses114.  

Targeted Consultations (TC) 

Survey 

The survey was sent by email to over 250 stakeholders with a diverse geographic spread. Additionally, 
20 relevant EU-wide industry associations were asked to share the survey with their members. In total, 
111 responses were received. The survey was open from 21 December 2017 to 12 January 2018.  

Interviews 

Targeted  in-depth  interviews  have  been  completed  with  74  representatives  of  the  key  stakeholder 
groups.  Each  interview  lasted  approximately  1-1.5  hours.  The  interviews  were  conducted  from  4 
December 2017 to 5 January 2018.  

Case study field visit interviews 

114 

https://ec.europa.eu/info/consultations/public-consultation-reporting-formalities-ships-european-maritime-

single-window-environment_en 

75 

 
 
                                                            
 
Some  interviews  were  completed  as  part  of  five  in-depth  case  studies  with  field  visits  to  ports: 
Hamburg (DE), Bari (IT), Constantza (RO), Helsinki (FI), Copenhagen/Malmo (DK/SE). These ports 
are from different sea basins, with different size, traffic and level of implementation of National Single 
Windows.  Each  visit  lasted  at  least  one  day  and  included  several  interviews,  mainly  with  port 
authorities, shipping companies and ship agents. 

Consultation events/workshops  

Five  workshops  were  organised  for  focused  discussions  with  the  main  stakeholder  groups.  One 
broader  workshop  took  place  at  the  Digital  Transport  Days.  In  total,  167  persons  participated  in  the 
events.  Participants  were  also  offered 
in  writing.  Written 
contributions115  were  submitted  by  eight  Member  States,  one  industry  stakeholder  and  one  port 
association. 

to  contribute  additional 

inputs 

Workshop 

Date 

ESPO consultation 
meeting 

24 October 2017 

Participants 

13 ports and port 
associations 

Additional 
Contributions 

n/a 

Consultation with the 
High Level Steering 
Group: Single Window 
Subgroup  

Digital Transport Days 
in Tallinn: consultation 
workshop 

26 October 2017 

8 November 2017 

16 Member States and 
Norway, 2 port 
associations, 2 shipping 
associations, 1 ship agent 
association 

65 mixed participants from 
different stakeholder 
groups 

6 contributions by Spain, 
France, Italy, Germany, 
Poland and ESPO 

1 contribution by Spain 

ECSA consultation 
meeting 

15 November 2017 

18 representatives of ship-
owners’ associations and 
shipping companies / 
shipping company 
associations 

n/a 

CUSTOMS 2020 Project 
Group meeting 

15 December 2017 

Customs experts from 18 
different Member States + 
observers (industry, 
stakeholder associations) 

2 contributions by custom 
authorities from Poland 
and Italy, one from 
CEFIC 

Table 5 - Overview of the workshops conducted by DG MOVE 

Outreach  was  done  via  the  DG  GROW  SME  network,  informing  SMEs  about  the  consultation 
opportunities and inviting them to the OPC.  

115 Published on the Commission consultation website 

76 

 
 
 
 
 
 
                                                            
 
Similarly,  the  European  social  partners116  were  approached  to  ensure  the  dissemination  of  the 
consultation  invitations  to  the  maritime  transport  professionals  and  the  trade  unions  in  the  maritime 
sector. 

Open Public Consultation 

Targeted consultation 

92 replies received 

Publicly accessible 

Online platform 

Targeted Survey 

>250 stakeholders approached 

111 responses received 

Online survey 

Targeted Interviews 

Target exceeded: 74 interviews, including 5 
field visits 

In person/phone interivews 

Consultation events /workshops 

Feedback submitted on IIA 

HLSG expert sub-group event 

Digital Transport Days in Tallinn 

CUSTOMS 2020 Project Group 

ECSA consultation meeting 

ESPO consultation meeting 

Other position papers & meetings 

Around 167 stakeholders reached 

Identification of Stakeholders 

Stakeholders  from  29  countries  (26  EU  Member  States)  and  16  EU-wide  representatives  have  been 
consulted. 

116 http://ec.europa.eu/social/main.jsp?catId=480&langId=en&intPageId=1844 

77 

 
 
 
                                                            
 
 
 
Figure 1 - Overview of the respondents per type of stakeholders 

Replies  were  received  from  all  maritime  Member  States,  with  higher  participation  in  the  e-surveys 
from  Germany,  Sweden,  Belgium,  Denmark,  Finland  and  the  Netherlands.  Fewer  respondents 
participated from Ireland, Lithuania, Cyprus, Greece and Croatia. No views at all were received from 
two of the landlocked Member States: Austria and Hungary. 

30

25

20

15

10

5

0

8 

4 

15 

2 
1 

10 

7 

7 

2 

4 

1 

1 
1 

1 
1 

8 

12 

5 

8 

2 

5 

2 
1 

2 

3 

4 

2 

3 

4 

2 
1 

9 

5 

5 

8 

12 

7 

9 

2 

2 
1 

2 
1 

1 

4 

4 

1 
2 

2 

5 

1 

1 

3 

4 

2 

1 

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
E

S
E

I
F

R
F

R
H

T
I

T
L

U
L

V
L

T
M

L
N

L
P

T
P

O
R

I

E S
S

K
S

Interview

OPC

Survey

7 

3 

5 

2 

K
U

1 

E
I

U
E

2 

2 

3 

…
E
E
/
A
E
E

2 

U
E
-
n
o
N

Figure 2 - Geographical overview of the respondents by consultation activities (excluding double responses, n=250) 

The possible bias from the uneven participation has been managed by weighting the inputs from the 
European  associations  representing  the  entire  geographic  range.  Respondents  for  the  TC  interviews 
were  also  selected  to  achieve  a  broad  geographic  spread  and  a  wide  representation  of  different 

78 

 
 
 
 
 
  
 
stakeholders  (size  and  type  of  companies,  interests  represented,  etc.).  The  limitation  of  the  lower 
participation  from  the  Mediterranean  sea  basin  was  discussed  with  the  European  Community 
Shipowners' Association (ECSA) who consider the overall results still to be solid and valid as there is 
no  major  difference  in  reporting  burden  between  the  different  sea  basins;  the  main  factor  impacting 
reporting burden is rather by type of traffic and vessel. 

3.  Results of the Consultation Activities on RFD 2010/65/EU 

Feedback on the Inception Impact Assessment 

Feedback  on  the  Inception  Impact  Assessment  (IIA)  was  received  from  eleven  stakeholders:  six 
international associations, one Member State, one Port Community System and three others (shipping 
related company, citizens).  

All these contributors agreed with the Commission problem analysis, although the Member State and 
the port organisation stressed that the RFD had also achieved some of its objectives (notably: higher 
level  digitalisation).  Harmonisation  was  stressed  by  all  as  the  main  priority  to  be  addressed.  One 
respondent mentioned the need to broaden the scope of the RFD. The Member State and the two port 
associations voiced concerns regarding the possibility of solving the “reporting only once” problem; 
the two major shipping associations on the other hand emphasised this as a crucial priority to address. 
Several  stakeholders  raised  the  importance  of  building  on  existing  standards  and  systems.  The  port 
community  systems  association  supported  EDIFACT  as  standard  protocol.  From  the  shipping 
operators, concerns were raised on the option of reporting via port community systems rather than via 
public national single windows as this would be a disproportionate and unrealistic option. 

Problem definitions 

The  problem  of  the  current  RFD  affects  in  particular  the  shipping  companies  and  ship  agents;  these 
groups also voiced the strongest critique against the lack of harmonisation, lack of a single reporting 
entry point and inefficient re-use of reported data (in particular static information). 

Also  other  stakeholders  in  the  OPC  and  TC  agree  with  the  identified  shortcomings  of  the  RFD  and 
notably the significant administrative burden on shipping companies. It is stressed in particular that the 
excessive administrative burden undermines the attractiveness of the maritime transport and places it 
in a disadvantageous position. 

The  stakeholders  with  least  agreement  on  the  problem  description  are  found  primarily  among  ports 
and port community systems providers. This is not surprising as the ports are generally not negatively 
affected by the lack of harmonisation. 

Subsidiarity 

The  majority  of  the  stakeholders  consulted  in  the  OPC  (82%)  confirm  that  the  RFD  issues  will  be 
more efficiently addressed at the EU level (91% of shipping companies; 92% of ship agents; 70% of 
Member State authorities; 59% of port operators and 60% of the port community service providers). 

When asked about whether the EU action should be mandatory, 83% of OPC respondents agree with 
the  statement.  The  European  associations  for  shipping  operators  and  agents,  such  as  ECSA  and  the 
European  Community  Association  of  Ship  Brokers  and  Agents  (ECASBA),  strongly  agree  that  the 

79 

 
 
action should be mandatory. This is also supported by all shipping companies in the survey and by the 
European port associations (Federation of European Private Port Companies and Terminals, FEPORT; 
European  Sea  Ports  Organisation,  ESPO).  Only  two  stakeholders  (2%)  strongly  disagree  with  the 
statement that actions should be mandatory: one ship agent and one port operator. 

Options 

Increased EU level harmonisation: addressing problem driver 1 

While there was strong agreement among all OPC respondents that harmonisation will bring some or 
even high benefits, there was strong fragmentation among the stakeholder groups regarding choice of 
policy option.  

In the OPC, respondents were asked to consider the options of no legal action, harmonisation based on 
current  National  Single  Windows  and  harmonisation  based  on  a  centralised  solution.  Overall,  a 
significant majority considered the “no legal action” option (option 0) to be either not (37%) or only 
slightly (35) effective. The different stakeholder categories replied rather similarly on this. 

Options  based  on  the  National  Single  Windows  (options  A  and  B)  were  seen  as  mostly  moderately 
effective  (33%)  or  very  effective  (23%).  71%  of  shipping  companies  and  74%  of  ship  agents 
considered  this  to  be  moderately,  very  or  extremely  effective,  with  12%  of  shipping  companies 
replying  it  would  be  extremely  effective.  Port  operators  were  more  sceptical  with  only  42% 
considering it to be at least moderately effective. Among Member States, 17% considered the option 
extremely effective and in total 58% thought it moderately or more effective. 

The  centralised  solution  (option  C)  received  high  overall  support  in  the  OPC  with  a  large  share  of 
respondents considering it very effective (33%) or extremely effective (29%). On this option however 
the views differed highly among stakeholder categories. 92% of shipping companies and 83% of ship 
agents  considered  this  option  to  be  very  or  extremely  effective.  Port  operators  on  the  other  hand 
mainly  considered  it  not  effective  at  all  (34%)  and  among  Member  State  authorities  13%  thought  it 
would be not effective and 35% only slightly effective. 

80 

 
 
 
OPC: Benefits from harmonisation 

OPC: No legal action 

0,0%

20,0%

40,0%

60,0%

80,0% 100,0%

No opinion

Low benefits

Some benefits High benefits

0,0%

20,0% 40,0% 60,0% 80,0% 100,0%

No opinion

Not at all effective

Slightly effective

Moderately effective

Very effective

Extremely effective

OPC: NSW-based solution 

OPC: Centralised solution 

0,0%

20,0%

40,0%

60,0%

80,0% 100,0%

0,0%

20,0% 40,0% 60,0% 80,0% 100,0%

No opinion

Not at all effective

No opinion

Not at all effective

Slightly effective

Moderately effective

Slightly effective

Moderately effective

Very effective

Extremely effective

Very effective

Extremely effective

Figure 9: Overall assessment of harmonisation options (OPC) 

These differences among stakeholder groups were mirrored in the TC where respondents could choose 
between  five  more  detailed  options117.  The  most  preferred  option  in  total  numbers  was  option  C 
(chosen  by  30%  of  all  respondents),  followed  by  option  A  (26%  of  all  respondents).  Option  B  was 
preferred option by 18% of all respondents. It should be noted that in the interviews, participants could 
select more than one option as preference. 

Option C (centralised solution) is the most preferred by shipping companies and ship / cargo agents 
(43%) in the TC. 

Figure 10: Preferred option per stakeholder category 

117 A: National Single Window solution based on technical specification; B: National Single Window solution 
based on common interface software; C: centralised European Maritime Single Window; D: mandatory Port 
Community System solution (discarded) and 0: no legal action / baseline 

81 

 
 
 
                                                            
 
Member State authorities expressed strongest preference for a solution based on the current National 
Single  Windows  (40%  for  A:  technical  specifications;  30%  for  common  software).  The  support  for 
status  quo  and  no  legal  action  (option  0)  is  the  lowest  among  Member  State  authority  respondents 
(only  2%).  The  preference  for  options  A  or  B  also  came  out  very  strongly  from  the  consultation 
events, where Member States voiced strong opposition to a centralised solution. 

Port operators and port community systems express the lowest support for a centralised option (15%) 
and slightly higher preference for no legal action (10%). The largest support from this group was for 
the discarded option D: mandatory port community systems (31%). 

Establishing a single reporting entry point: addressing problem driver 2 

83% of all OPC respondents support the proposal to include national requirements (current  part C of 
the RFD) into the mandatory scope of the new reporting environment.  

The inclusion of national reporting requirements is supported by both shipping operators (96%), ship 
agents  (82%),  port  operators  (91%)  and  port  community  system  providers  (100%  of  OPC 
respondents).  

Member State authorities were predictably less interested in such inclusion with only 52% agreeing or 
strongly agreeing to the statement (5% neutral, 23% didn’t know and 18% in disagreement). 

Figure 4 – OPC results: “National reporting requirements should be included in the new framework” 

The majority of the shipping companies, port operatorship agents and others perceive that the benefits 
from including the national requirements will be higher for them than the overall costs.  

In regard to a harmonised reporting environment data set, shipping companies and ship agents request 
rationalisation of data, limiting the reporting to the extent possible by clearing out non-essential data 
requests. The World Shipping Council (WSC) stated that 'maritime carriers need a single harmonised 
list of data elements that are genuinely necessary for EU wide port clearance.'  

82 

 
 
 
The question of the scope was further addressed in the targeted consultations, where stakeholders were 
asked also about inclusion of customs formalities. 

The majority (73%) of the respondents to the targeted survey believe that it is both technically feasible 
and  beneficial  to  integrate  customs  and  maritime  reporting  in  one  window.  Especially  shipping 
companies  (93%)  and  ship  or  cargo  agents  (85%)  request  inclusion  of  customs  formalities,  as  they 
consider that this would simplify their reporting procedures. Around 79% of Member State authority 
respondents  consider  it  both  technically  feasible  and  beneficial  to  integrate  customs  and  maritime 
reporting. The two contributions received as part of the consultations with the customs expert group 
are also generally positive to such developments. On the other hand, only 57% of the port community 
system  providers  (25%  don’t  know)  and  71%  of  the  ports  (12%  don’t  know)  consider  this  measure 
beneficial.  

Shipping Company (including Ship Masters)
and their Associations

Port Operators and their Associations

Port Community Systems and other ICT
System Providers

Other (NGO, Trade Union, Citizen, etc.)

Member State Authority

Ship or Cargo Agent

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%100%

I do not know

No

Yes

Figure  5  –  TC  result:  “Would  it  be  beneficial  if  customs  reporting  went  via  the  same  single  window  as  maritime 
transport reporting” 

Benefits from more data sharing and data re-using: addressing problem driver 3 

81% of respondents to the OPC expect to have some or high benefits from more data sharing and data 
re-use. In the targeted interviews, shipping companies show strong support of legislative measures that 
encourage  data  sharing  and  data  reuse  and  that  provide  clear  definitions  for  the  different  reporting 
requirements.  The  importance  of  the  “reporting  only  once”  principle  was  stressed  in  interviews  and 
survey comments by several stakeholders including e.g. ECSA and WSC. 

Technical elements of the revised RFD 

83 

 
 
 
 
Regarding governance of the new reporting environment, OPC respondents highlighted the importance 
of  consultation  with  and  involvement  of  the  industry  in  connection  to  technical  updates  of  the 
reporting environment (important or very important priority to 67% of all respondents).  

Stakeholders have also been asked about various technical elements in the OPC that could be included 
or further developed in the revised RFD such as e-certificates and private data.  

Provisions  for  acceptance  of  e-certificates  to  allow  for  future  fully  paperless  ships  are  supported  by 
76%  of  all  respondents  to  the  OPC.  Especially  ship  agents  (83%)  and  shipping  companies  (68%) 
expect higher benefits from provisions to accept e-certificates. 

In  the  specific  targeted  consultations,  issues  regarding  personal  data  reporting  were  also  brought  in, 
following requests in the consultation events during autumn. Across all categories, stakeholders in the 
targeted consultations agree that it will be highly relevant to clarify inclusion of personal data into the 
harmonised reporting environment in a manner that is in full compliance with the new General Data 
Protection Regulation (GDPR). This will provide added value especially for the SME segment of the 
private  maritime  sector  (shipping  companies,  agents,  port  operators,  PCS  and  ICT  providers).  The 
consulted  SMEs  report  to  struggle  to  integrate  the  requirements  of  the  complex  GDPR  in  their 
business models and would benefit especially from clarified provisions.  

Impacts 

When it comes to benefits of increased EU level harmonisation, according to the OPC results, 87% of 
respondents  stated  that  increased  EU-level  harmonisation  of  reporting  standards,  procedures  and 
interfaces  is  expected  to  bring  benefits  to  them.  52%  of  all  respondents  expect  these  benefits  to  be 
high,  mainly  expected  by  the  shipping  companies  (79%).  When  talking  about  the  cost  of 
harmonisation, 39% expect to have some cost of adaption - 17% expect these costs to be high (mainly 
port operators, PCS providers and Member State authorities).  

Option 0

Option D

Option C

Option B

Option A

I do not know

No impact

Low impact

Medium impact

High impact

0%

20%

40%

60%

80%

100%

Figure 6 - OPC results: Shipping companies' expected impact in terms of reduction of administrative burden 

During the TC survey and the interviews, respondents were also asked to assess economic, social and 
environmental impacts of the different policy options. Shipping companies expect the largest impact 
on the administrative burden from option C (centralised solution) as a first step towards a level playing 
field with road transports. This would therefore support a modal shift towards the more cost effective 
maritime  transport,  with  environmental  benefits  as  a  result.  Shipping  companies  also  find  that 

84 

 
 
 
harmonised reporting will improve working conditions for ship masters and the attractiveness of the 
sector.  

Option 0

Option D

Option C

Option B

Option A

I do not know

Strongly negative

Negative

Neutral

Positive

Strongly positive

0%

20%

40%

60%

80%

100%

Figure 7 – TC results: Overall job quality, Stakeholders’ expected impact 

Notably  ship  agents  also  stressed  in  the  TC  that  they  see  some  business  opportunities  arising  from 
harmonised  reporting,  especially  in  combination  with  better  re-use  and  sharing  of  data.  This  would 
allow them to focus on more value adding work than reporting.  

85 

 
 
  
 
 
 
Annex 3: Who is affected and how? 

Practical implications of the initiative  

  For  Member  States,  national  competent  authority  in  charge  of  the  National  Single 
Window:  by  implementation  deadline,  to  make  necessary  preparations  to  install  the 
common EU reporting gateway IT solution and to adapt the National Single Window 
to be in line with the new technical specifications. To ensure proper connections from 
the National Single Window to the relevant back-end entities (data recipients).  

  For connecting back-end authorities (data recipients), by implementation deadline, to 
ensure  systems  are  ready  to  be  interoperable  with  the  updated  National  Single 
Windows. 

  For  port  operators  and  other  connected  private  entities:  by  implementation  deadline, 
adapt  as/if  needed  the  systems  and  connections  to  the  National  Single  Window  to 
enable reception of data in harmonised format.  

  For  shipping  operators:  if  choosing  to  report  via  the  harmonised  maritime  reporting 

environment, to adapt systems and data to the harmonised EU format. 

Summary of costs and benefits 

I. Overview of Benefits (total for all provisions) – Preferred Option B1 
Amount 
Description 

Comments 

Direct benefits 

Reduced 
reporting 
operators (ship masters) 

time 
for 

spent  on 
shipping 

Indirect benefits 

Increased competitiveness of 
the maritime transport sector 
as  administrative  burden  is 
is 
reduced, 
simplified  and  data  more 
efficiently used and shared 

reporting 

e.g. 

Efficiency  gains  for  entire 
multimodal  /  logistics  chain 
from  better  use  of  data  in 
harmonised 
ports: 
provision  and  efficient  and 
appropriate  re-use  of  arrival 
times  will 
or  departure 
and 
enable 
logistics service providers to 
optimise the flow of cargo in 
and out of ports in real-time. 

transport 

22-25  million  staff  hours  in  the 
2020-2030; 
time 
equivalent  to  a  value  of  EUR 
625-720 million 

period 

A  possible  shift  of  3,395  million 
tonne-kilometres  to  waterborne 
transport  in  2030,  mostly  away 
from  road.  This  represents  about 
0.3%  increase  in  the  transport 
activity 
the  waterborne 
transport  in  2030  relative  to  the 
baseline. 

of 

Non-quantifiable. 

86 

Main beneficiary: Maritime transport operators 
High  priority  for  European  shipping  companies 
these 
and  ship  agents;  high  pressure  from 
stakeholder  groups 
the  current 
situation. 

remedy 

to 

Modelling  performed  with 
TREMOVE and TRUST models. 

the  PRIMES-

In  line  with  the  overall  Commission  Transport 
Policy (see: Transport White Paper, 2011) modal 
shift objectives. 

The  efficiency  of  the  ship  port  calls  will  impact 
on  the  entire  logistics  chain  and  the  hinterland 
transports  of  goods  and  passengers  to  and  from 
the  ports  (per  road,  rail,  pipeline  or  inland 
waterways). 

Stressed  by 
consultations. 

several 

stakeholders 

in 

the 

 
 
 
 
 
Non-quantifiable.  

Increased job satisfaction for 
higher 
masters; 
ship 
attractiveness  of  profession 
leading 
improved 
to 
possibilities for recruitment 

lack  of  European  seafarers, 

The  European  maritime  industry  suffers  from  an 
in 
increasing 
particular  officers.  Such  a  shortage  is  likely  to 
increase  in  the  coming  years  to  the  detriment  of 
the  maritime  industry,  which  needs  maritime 
expertise and experience. A main objective of the 
European maritime policy is therefore to improve 
employment and working conditions for seafarers 
on board EU-flagged ships, to make the maritime 
profession more attractive and ensure compliance 
with established training standards. 

The  most  commonly  mentioned  indirect  benefit 
from harmonisation, voiced by a high number of 
shipping companies and ship agents in the various 
consultations. 

Safety  and  security  gains  as 
ship  master  can  spend  more 
time on the bridge 

Better  information  flows  to 
inform  better  governance 
and public services 

Non-quantifiable. 

Non-quantifiable. 

Reduction 
emissions: 
impact 

of 

CO2 
environmental 

Freight  transport  emissions  are 
estimated  to  decrease  by  1,880 
thousand  tonnes  of  CO2  relative 
to  the  baseline  due  to  the  modal 
shift  (see  above).  This  translates 
into  around  €145  million  of 
indirect benefits over 2020-2030, 
expressed as present value. 

Commonly stressed by shipping companies in the 
targeted 
indirect, 
unquantifiable benefit. 

consultations 

likely 

as 

likely 

Member  State  authorities 
to  benefit 
indirectly  from  the  improved  data  flows  and 
access  to  harmonised  data;  notably  in  the  long-
term  with  future  developments  of  cross-border 
data exchanges. 

In  line  with  the  overall  Commission  Policy 
environmental objectives 

II. Overview of costs – Preferred option B1 

Citizens/Consumers  

Businesses (shipping operators)  Administrations (MS) 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

n/a 

n/a 

Direct costs 

Adaptation 
costs 
; 
quantified 

not 

Adaptation 
to 
regular  updates 
of  formats;  not 
quantified 

Average 
340  000  per 
Member 
State 

Average  350 
000 
per 
Member  State 
(2020-2030) 

Indirect costs 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

87 

 
 
 
 
 
 
 
 
 
Annex 4: Analytical methods 

The analytical work for this impact assessment is based on the PRIMES-TREMOVE transport 
model and TRUST model. The model suite covers the entire transport system (e.g. transport 
activity  represented  at  Member  State  level,  by  origin-destination  and  at  link  level, 
technologies  and  fuels  at  Member  State  level,  air  pollution  emissions  at  Member  State  and 
link level and CO2 emissions at Member State level): 

  Geographical coverage: EU level, all Member States separately.  

  Time horizon: 2005 to 2050 (5-year time steps).  

  Transport modes covered for freight transport: road freight (heavy goods vehicles, 
light  commercial  vehicles),  freight  rail,  freight  inland  navigation,  international 
shipping.  Numerous  classes  of  vehicles  and  transport  means  with  tracking  of 
technology vintages.  

  Regions/road types: traffic represented at country level in PRIMES-TREMOVE; by 

NUTS 3 region in TRUST model.  

In  addition,  an  excel  based  tool  has  been  developed  by  COWI/Gartner  for  calculating  the 
costs related to the IT systems.  

1.  Description of analytical models used 

1.1  PRIMES-TREMOVE transport model 

The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  transport  demand  by 
transport mode and transport mean. It is essentially a dynamic system of multi-agent choices 
under several constraints, which are not necessarily binding simultaneously. The projections 
include  details  for  a  large  number  of  transport  means,  technologies  and  fuels,  including 
conventional and alternative types, and their penetration in various transport market segments 
for each EU Member State. They also include details about greenhouse gas and air pollution 
emissions (e.g. NOx, PM, SOx, CO), as well as impacts on external costs of congestion, noise 
and accidents. 

In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. eco-
driving,  deployment  of  Intelligent  Transport  Systems,  labelling),  economic  measures  (e.g. 
subsidies  and  taxes  on  fuels,  vehicles,  emissions;  ETS  for  transport  when  linked  with 
PRIMES;  pricing  of  congestion  and  other  externalities  such  as  air  pollution,  accidents  and 
noise;  measures  supporting  R&D),  regulatory  measures  (e.g.  CO2  emission  performance 
standards  for  new  passenger  cars  and  new  light  commercial  vehicles;  EURO  standards  on 
road 
technologies), 
technology  standards  for  non-road 
infrastructure  policies  for  alternative  fuels  (e.g.  deployment  of  refuelling/recharging 
infrastructure for electricity, hydrogen, LNG, CNG). Used as a module which contributes to a 
broader  PRIMES  scenario,  it  can  show  how  policies  and  trends  in  the  field  of  transport 

transport  vehicles; 

transport 

88 

 
 
contribute to economy wide trends in energy use and emissions. Using data disaggregated per 
Member State, it can show differentiated trends across Member States.  

PRIMES-TREMOVE transport model has been used for the 2011 White Paper on Transport, 
Low Carbon Economy and Energy 2050 Roadmaps,  the 2030 policy framework for climate 
and  energy  and  more  recently  for  the  Effort  Sharing  Regulation,  the  review  of  the  Energy 
Efficiency  Directive,  the  recast  of  the  Renewables  Energy  Directive,  the  2016  European 
strategy on low-emission mobility, the revision of the Eurovignette Directive and the recast of 
the Regulations on CO2 standards for light duty vehicles.  

The  PRIMES-TREMOVE  is  a  private  model  that  has  been  developed  and  is  maintained  by 
E3MLab/ICCS  of  National  Technical  University  of  Athens118,  based  on,  but  extending 
features  of  the  open  source  TREMOVE  model  developed  by  the  TREMOVE119  modelling 
community. Part of the model (e.g. the utility nested tree) was built following the TREMOVE 
model120.  Other  parts,  like  the  component  on  fuel  consumption  and  emissions,  follow  the 
COPERT model.  

As  module  of  the  PRIMES  energy  system  model,  PRIMES-TREMOVE121  has  been 
successfully peer reviewed122, most recently in 2011123. 

1.2  TRUST transport network model 

TRUST (TRansport eUropean Simulation Tool) is a European scale transport network model 
covering  road,  rail  and  maritime  transport124.  TRUST  covers  the  whole  Europe  and  its 

118  Source: http://www.e3mlab.ntua.gr/e3mlab/ 
119  Source: http://www.tmleuven.be/methode/tremove/home.htm  
120  Several  model  enhancements  were  made  compared  to  the standard  TREMOVE  model,  as  for  example:  for 
the  number  of  vintages  (allowing  representation  of  the  choice  of  second-hand  cars);  for  the  technology 
categories  which  include  vehicle  types  using  electricity  from  the  grid  and  fuel  cells.  The  model  also 
incorporates additional fuel types, such as biofuels (when they differ from standard fossil fuel technologies), 
LPG  and  LNG.  In  addition,  representation  of  infrastructure  for  refuelling  and  recharging  are  among  the 
model  refinements,  influencing  fuel  choices.  A  major  model  enhancement  concerns  the  inclusion  of 
heterogeneity in the distance of stylised trips; the model considers that the trip distances follow a distribution 
function  with  different  distances  and  frequencies.  The  inclusion  of  heterogeneity  was  found  to  be  of 
significant influence in the choice of vehicle-fuels especially for vehicles-fuels with range limitations. 

121  The model can be run either as a stand-alone tool (e.g. for the 2011 White Paper on Transport and for the 
2016 Strategy on low-emission mobility) or fully integrated in the rest of the PRIMES energy systems model 
(e.g. for the Low Carbon Economy and Energy 2050 Roadmaps, for the 2030 policy framework for climate 
and energy, for the Effort Sharing Regulation, for the review of the Energy Efficiency Directive and for the 
recast of the Renewables Energy Directive). When coupled with PRIMES, interaction with the energy sector 
is taken into account in an iterative way. 

122  Source: http://ec.europa.eu/clima/policies/strategies/analysis/models/docs/primes_model_2013-2014_en.pdf.  
123  https://ec.europa.eu/energy/sites/ener/files/documents/sec_2011_1569_2.pdf  

89 

 
 
                                                            
 
neighbouring countries and allows for the assignment of origin-destination matrices at NUTS 
3 level (about 1600 zones) for passenger and freight demand. 

TRUST  projects  the  average  daily  loads  on  road  links  split  by  demand  segment  and  by 
country  of  origin,  road  traffic  activity  (passenger-km,  tonnes-km,  vehicle-km)  per  year  by 
country  (based  on  territoriality  principle),  origin-destination  journey  time,  road  accessibility 
measures by NUTS 3 region, energy consumption and emissions of NOx, PM, VOC, CO and 
CO2  by  link.  TRUST  rail  network  includes  different  link  types  according  to  technical 
elements (number of tracks, electrification, maximum speed allowed, etc.). 

TRUST  models  maritime  connections  between  the  main  ports  in  Europe  through  links 
simulating sea routes and allows the computation of distances and cost of maritime transport. 
TRUST  also  simulates  feeder  modes  accessing  ports  (e.g.  truck,  rail  or  inland  waterways 
according to existing infrastructures) allowing the definition of full path between true origin 
and final destination of freight. Ports are classified into three categories: bulk ports, container 
ports and general cargo ports. Most of the ports belong to more than one category but some 
ports  have  only  one  or  two  specialisation.  Maritime  demand  consists  of  origin-destination 
matrices  segmented  according  to  the  three  freight  categories  of  bulk,  container  and  general 
cargo. 

TRUST is suitable for modelling policies in the field of infrastructure (e.g. completion of the 
core  and  comprehensive  TEN-T  network)  and  road  charging  schemes  for  cars  and  heavy 
goods vehicles.  

TRUST  is  a  private  model,  developed  and  maintained  by  TRT125.  It  has  been  used  for  the 
impact assessment accompanying the revision of the Eurovignette Directive, the 2013 ex-post 
evaluation  of  transport  infrastructure  charging  policy,  for  the  TRACC  -  TRansport 
ACCessibility at regional/local scale and patterns in Europe126 and for other TEN-T projects 
focusing  on  e.g.  improving  the  ports  and  multimodal  transport  links  of  the  northern 
Adriatic127.  

1.3  COWI/Gartner model for IT system costs 

An  excel  based  tool  has  been  developed  by  Gartner  (COWI  sub-contracting  partner  for  the 
support  study)  for  calculating  the  costs  related  to  the  IT  system.  The  cost  model  was 

124  See Annex A of Ricardo et al. (2017) Support Study for the Impact Assessment Accompanying the Revision 

of Directive 1999/62/EC. 

125  Source : http://www.trt.it/en/tools/trust/  
126 http://www.espon.eu/main/Menu_Projects/Menu_ESPON2013Projects/Menu_AppliedResearch/tracc.html  
127  https://ec.europa.eu/inea/en/ten-t/ten-t-project-implementation-successes/improving-ports-and-multimodal-

transport-links-northern  

90 

 
 
                                                                                                                                                                                          
 
developed to estimate the investments and ongoing costs for implementing the policy options. 
The model estimates this both for EU and for the Member States (MS). 

In order to estimate the MS cost of the three retained policy options, the assumption is that 
the complexity of the NSW and therefore the complexity of implementing the policy options 
is functionally the same across the MS. In reality, most MSs should experience lower actual 
investments than estimated in this study. 

The following two factors are driving the differences in costs between Member States, among 
systems  of  similar  functional  scope:  Cost  of  developers  and  Number  of  national  authorities 
(i.e. authority interfaces) using the NSW. 

The Gartner labour rate database for IT staff has been used to assess the differences in cost of 
developers across the Member States. The rates used in the cost model are average seniority 
rates.  The  estimates  for  each  of  the  MSs  have  been  adjusted  with  a  factor  relative  to  the 
European  average.  The  European  average  day  rate  is  EUR  906,-.  For  instance,  the  average 
rate in Germany is EUR 1102,-, while in Poland it is EUR 506,-. 

It  is  also  assumed  that  all  MSs  either  have  an  existing  NSW  or  an  ongoing  NSW 
implementation  (legal  requirement  of  current  RFD).  This  means  that  reuse  of  the  authority 
interfaces  in  the  existing  NSW  is  assumed  in  all  retained  policy  options.  A  reservation  for 
resources  needed  to  adapt  these  interfaces  is  estimated,  however  not  development  from 
scratch. 

The  costs  modelled  for  the  EU  in  the  three  retained  policy  options  build  on  a  detailed 
breakdown for the functionality and for the required IT infrastructure.  

The following data sources have been used to populate the cost model for the EU costs: 

  EU  pan-European  systems  Peers:  Through  a  number  of  engagements  for  the 
Commission,  Gartner  has  collected  data  on  estimate  levels  of  budget  for  different 
activities, such as communication, training and stakeholder management that consider 
the special governance and working conditions for EU-wide systems. 

  Gartner Cost Benchmark data: Anonymised data pointers from peers engaged in cost 
benchmarks with Gartner and supplied using Gartner’s standard IT accounting model. 
This ensures a very high degree of comparability and possibility to normalise across 
collected  data.  These  data  mainly  exist  for  very  mature  environments,  such  as 
infrastructure areas. 

  Gartner  IT  Key  Metrics:  On  a  yearly  basis,  Gartner  conducts  a  survey  covering 
companies using IT in order to data on spending within all the IT domains. These data 
are available by geography and industry, and are used to capture trends in spending, as 
well as typical division of costs among areas. The Gartner IT Key Metrics also include 
average costs for key cost elements, such as Windows server costs. 

  Case  data:  These  are  anonymised  data  pointers  collected  in  Gartner’s  engagements 
with  clients  that  cover  e.g.,  project  costs  that  can  be  used  for  sanity  checks  of 
developed  cost  models  or  to  provide  high-level  cost  indications.  Such  case  data  is 
currently available for 20 pan-European information systems. 

91 

 
 
The model of the EU costs is a 10 year TCO model, estimating the total costs (investments 
and  ongoing  costs).  Where  relevant  (e.g.,  for  IT  hardware),  a  TCO  figure  has  been  used, 
which  includes  depreciations.  This  means  that  the  model  is  stable  and  can  be  projected 
beyond the 10 years, unless changes in the assumptions occur. 

The model assumes that the efforts for the EU can be undertaken within existing organisations 
of the EU, therefore it does not include costs for e.g., establishing a new European agency. 

The  cost  model  for  the  EU  uses  the  comprehensive  Maritime  Single  Window  data  set  as  a 
starting  point  for  estimating  the  complexity  of  the  MSW.  The  functional  complexity  of  the 
EMSW  is  independent  of  whether  it  is  operated  by  the  MSs  (Policy  Option  B  and  C)  or 
operated centrally (Policy Option D). 

The  functional  breakdown  is  done  with  the  Fast  Function  Point  Analysis  (FFPA) 
methodology.  FFPA  is  a  Gartner  adaption  of  the  FPA  methodology,  which  is  a  method  for 
assessing  the  complexity  of  a  system,  independent  of  the  programming  language  it  will  be 
built  and  maintained.  FFPA  has  proven  useful  in  estimating  both  development  and 
maintenance efforts for applications across different types of projects and systems.  

Gartner has systematically collected data points regarding functional complexity (number of 
function points) and the required effort to develop and maintain a piece of software. We can 
therefore use FFPA to provide a sensible estimate of the cost of developing a system like the 
EMSW.  The  number  and  type  of  resources  for  building  the  EMSW  was  determined  in  line 
with the following steps: 

  Counted  the  expected  Functional  Size  (in  FP)  per  building  block  for  each  policy 

option, 

  Determined the expected unit development effort (person days per developed FP) per 
building block. This is selected from the Gartner benchmarking database based on the 
following  criteria:  size  in  FP,  technology  mix,  requirements  stability,  and  non-
functional requirements, 

  Calculated  the  total  development  effort  (per  building  block  or  per  policy  option)  by 
multiplying the expected number of FPs (derived from step 1) with the expected unit 
effort (person days/FP derived from step 2). 

1.4    PRIMES-TREMOVE,  TRUST  and  COWI/Gartner  tool  role  in  the  impact 
assessment 

The  PRIMES-TREMOVE  transport  model  is  a  building  block  of  the  modelling  framework 
used for developing the EU Reference scenario 2016, and has a successful record of use in the 
Commission's transport, climate and energy policy analytical work – it is the same model as 
used for the 2011 White Paper on Transport and the 2016 European strategy on low-emission 
mobility. In this impact assessment, it has been used to define the Baseline scenario, having as 
a  starting  point  the  EU  Reference  scenario  2016  but  additionally  including  few  policy 
measures that have been adopted after its cut-off date (end of 2014).  

92 

 
 
 
TRUST model is a European scale transport network model that allows for the assignment of 
origin-destination matrices at NUTS 3 level for passenger and freight demand. In addition, it 
provides the maritime connections between the main ports in Europe through links simulating 
sea routes and allows the computation of distances and cost of maritime transport. At Member 
State  level,  the  Baseline  trend  of  transport  activity  in  TRUST  has  been  calibrated  on 
PRIMES-TREMOVE projections.  

PRIMES-TREMOVE  transport  model  together  with  the  TRUST  model  have  been  used  to 
assess the  impacts  of  the  policy  options  on  modal  shift.  More  specifically,  the time  savings 
achived by the ship operators in the policy options relative to the Baseline have been used to 
calculate the impacts on the generalised transport costs by origin-destination with the TRUST 
model.  The  changes  in  the  generalised  transport  costs  have  been  subsequently  used  in 
PRIMES-TREMOVE  to  derive  the  impacts  on  modal  shares  for  all  freight  transport  modes 
together with their impacts on CO2 and air pollutant emissions.  

The  excel  based  tool  developed  by  COWI/Gartner  has  been  used  for  calculating  the  costs 
related to the IT system: costs for EU and Member States respectively and taking into account 
bothe  the  one-off  investments  required  and  the  operational  costs  during  the  baseline  period 
until 2030. 

2.  Baseline scenario 

The  Baseline  scenario  used  in  this  impact  assessment  builds  on  the  EU  Reference  scenario 
2016  but  additionally  includes  few  policy  measures  adopted  after  its  cut-off  date  (end  of 
2014).  Building  an  EU  Reference  scenario  is  a  regular  exercise  by  the  Commission.  It  is 
coordinated  by  DGs  ENER,  CLIMA  and  MOVE  in  association  with  the  JRC,  and  the 
involvement of other services via a specific inter-service group.  

For  the  EU  Reference  scenario  2016,  Member  States  were  consulted  throughout  the 
development  process  through  a  specific  Reference  scenario  expert  group  which  met  three 
times  during  its  development.  Member  States  provided  information  about  adopted  national 
policies  via  a  specific  questionnaire,  key  assumptions  have  been  discussed  and  in  each 
modelling step, draft Member State specific results were sent for consultation. Comments of 
Member  States  were  addressed  to  the  extent  possible,  keeping  in  mind  the  need  for  overall 
comparability  and  consistency  of  the  results.  Quality  of  modelling  results  was  assured  by 
using  state  of  the  art  modelling  tools,  detailed  checks  of  assumptions  and  results  by  the 
coordinating Commission  services as well as  by the country specific  comments by Member 
States. 

93 

 
 
The EU Reference scenario 2016 projects EU and Member States energy, transport and GHG 
emission-related  developments  up  to  2050,  given  current  global  and  EU  market  trends  and 
adopted  EU  and  Member  States'  energy,  transport,  climate  and  related  relevant  policies. 
"Adopted policies" refer to those that have been cast in legislation in the EU or in MS (with a 
cut-off date end of 2014128). Therefore, the binding 2020 targets are assumed to be reached in 
the projection. This concerns greenhouse gas emission reduction targets as well as renewables 
targets, including renewables energy in transport. The EU Reference scenario 2016 provides 
projections,  not  forecasts.  Unlike  forecasts,  projections  do  not  make  predictions  about  what 
the future will be. They rather indicate what would happen if the assumptions which underpin 
the  projection  actually  occur.  Still,  the  scenario  allows  for  a  consistent  approach  in  the 
assessment of energy and climate trends across the EU and its Member States.  

The  report  "EU  Reference  Scenario  2016:  Energy,  transport  and  GHG  emissions-Trends  to 
2050"129  describe  the  inputs  and  results  in  detail.  In  addition,  its  main  messages  are 
summarised in the impact assessments accompanying the Effort Sharing Regulation130 and the 
revision  of  the  Energy  Efficiency  Directive131,  and  the  analytical  work  accompanying  the 
European strategy on low-emission mobility132.  

PRIMES-TREMOVE  is  one  of  the  core  models  of  the  modelling  framework  used  for 
developing  the  EU  Reference  scenario  2016  and  has  also  been  used  for  developing  the 
Baseline  scenario  of  this  impact  assessment.  The  model  was  calibrated  on  transport  and 
energy data up to year 2013 from Eurostat and other sources 

128  In addition, amendments to two Directives only adopted in the beginning of 2015 were also considered. This 
concerns  notably  the  ILUC  amendment  to  the  Renewables  Directive  and  the  Market  Stability  Reserve 
Decision amending the ETS Directive 

129  ICCS-E3MLab et al. (2016), EU Reference Scenario 2016: Energy, transport and GHG emissions - Trends to 

2050 

130  SWD(2016) 247 
131  SWD(2016) 405 
132  SWD(2016) 244 

94 

 
 
                                                            
 
2.1  Main assumptions of the Baseline scenario 

The  projections  are  based  on  a  set  of  assumptions,  including  on  population  growth, 
macroeconomic and oil price developments, technology improvements, and policies.  

Macroeconomic assumptions 

The  Baseline  scenario  uses  the  same  macroeconomic  assumptions  as  the  EU  Reference 
scenario  2016.  The  population  projections  draw  on  the  European  Population  Projections 
(EUROPOP  2013)  by  Eurostat.  The  key  drivers  for  demographic  change  are:  higher  life 
expectancy,  convergence  in  the  fertility  rates  across  Member  States  in  the  long  term,  and 
inward migration. The EU28 population is expected to grow by 0.2% per year during 2010-
2030  (0.1%  for  2010-2050),  to  516  million  in  2030  (522  million  by  2050).  Elderly  people, 
aged 65 or more, would account for 24% of the total population by 2030 (28% by 2050) as 
opposed to 18% today.  

GDP projections  mirror the joint  work of DG  ECFIN and  the Economic Policy Committee, 
presented  in  the  2015  Ageing  Report133.  The  average  EU  GDP  growth  rate  is  projected  to 
remain relatively low at 1.2% per year for 2010-2020, down from 1.9% per year during 1995-
2010. In the medium to long term, higher expected growth rates (1.4% per year for 2020-2030 
and 1.5% per year for 2030-2050) are taking account of the catching up potential of countries 
with  relatively  low  GDP  per  capita,  assuming  convergence  to  a  total  factor  productivity 
growth rate of 1% in the long run.  

Fossil fuel price assumptions 

Oil prices used in the Baseline scenario are the same with those of the EU Reference scenario 
2016.  Following  a  gradual  adjustment  process  with  reduced  investments  in  upstream 
productive capacities by non-OPEC134 countries, the quota discipline is assumed to gradually 
improve  among  OPEC  members  and  thus  the  oil  price  is  projected  to  reach  87  $/barrel  in 
2020  (in  year  2013-prices).  Beyond  2020,  as  a  result  of  persistent  demand  growth  in  non-
OECD countries driven by economic growth and the increasing number of passenger cars, oil 
price would rise to 113 $/barrel by 2030 and 130 $/barrel by 2050.  

No specific sensitivities were prepared with respect to oil price developments. Still, it can be 
recalled  that  lower  oil  price  assumptions  tend  to  increase  energy  consumption  and  CO2 
emissions not covered by the ETS. The magnitude of the change would depend on the price 
elasticities and on the share of taxation, like excise duties, in consumer prices. For transport, 

133  European  Commission/DG  ECFIN  (2014),  The  2015  Ageing  Report:  Underlying  Assumptions  and 

Projection Methodologies, European Economy 8/2014. 

134  OPEC stands for Organization of Petroleum Exporting Countries. 

95 

 
 
                                                            
 
the high share of excise duties in the consumer prices act as a limiting factor for the increase 
in energy consumption and CO2 emissions.  

Techno-economic assumptions 

For most transport means, the Baseline scenario uses the same technology costs assumptions 
as the EU Reference scenario 2016.  

For light duty vehicles, the data for technology costs and emissions savings has been updated 
based on a recent study commissioned by DG CLIMA135. Battery costs for electric vehicles 
are  assumed  to  go  down  to  205  euro/kWh  by  2030  and  160  euro/kWh  by  2050;  further 
reductions  in  the  cost  of  both  spark  ignition  gasoline  and  compression  ignition  diesel  are 
assumed to take place. Technology cost assumptions are based on extensive literature review, 
modelling and simulation, consultation with relevant stakeholders, and further assessment by 
the Joint Research Centre (JRC) of the European Commission. 

Specific policy assumptions 

The  key  policies  included  in  the  Baseline  scenario,  similarly  to  the  EU  Reference  scenario 
2016, are136:  

  CO2 standards for cars and vans regulations (Regulation (EC) No 443/2009, amended by 
Regulation (EU) No 333/2014 and Regulation (EU) No 510/2011, amended by Regulation 
(EU) No 253/2014); CO2 standards for cars are assumed to be 95gCO2/km as of 2021 and 
for  vans  147gCO2/km  as  of  2020,  based  on  the  NEDC  test  cycle,  in  line  with  current 
legislation.  No  policy  action  to  strengthen  the  stringency  of  the  target  is  assumed  after 
2020/2021. 

including 

  The  Renewable  Energy  Directive  (Directive  2009/28/EC)  and  Fuel  Quality  Directive 
(Directive  2009/30/EC) 
(Directive  2015/1513/EU): 
achievement of the legally binding RES target for 2020 (10% RES in transport target) for 
each Member State, taking into account the use of flexibility mechanisms when relevant as 
well  as  of  the  cap  on  the  amount  of  food  or  feed  based  biofuels  (7%).  Member  States' 
specific  renewable  energy  policies  for  the  heating  and  cooling  sector  are  also  reflected 
where relevant. 

ILUC  amendment 

  Directive on the deployment of alternative fuels infrastructure (Directive 2014/94/EU). 

135  Source: https://ec.europa.eu/clima/sites/clima/files/transport/vehicles/docs/technology_results_web.xlsx  
136  For  a  comprehensive discussion see  the  Reference scenario  report:  “EU Reference  Scenario  2016: Energy, 

transport and GHG emissions - Trends to 2050”  

96 

 
 
                                                            
 
  Directive  on  the  charging  of  heavy  goods  vehicles  for  the  use  of  certain  infrastructures 

(Directive 2011/76/EU amending Directive 1999/62/EC).  

  Relevant national policies, for instance on the promotion of renewable energy, on fuel and 

vehicle taxation, are taken into account.  

In addition, a few policy measures adopted after the cut-off date of the EU Reference scenario 
2016 at both EU and Member State level, have been included in the Baseline scenario: 

  Directive on weights & dimensions (Directive 2015/719/EU). 

  Directive as regards the opening of the market for domestic passenger transport services by 

rail and the governance of the railway infrastructure (Directive 2016/2370/EU). 

  Directive  on 

for 
2016/1629/EU), part of the Naiades II package. 

requirements 

technical 

inland  waterway  vessels 

(Directive 

  Regulation  establishing  a  framework  on  market  access  to  port  services  and  financial 

transparency of ports137. 

  The  replacement  of  the  New  European  Driving  Cycle  (NEDC)  test  cycle  by  the  new 
Worldwide  harmonised  Light-vehicles  Test  Procedure  (WLTP)  has  been  implemented  in 
the  Baseline  scenario,  drawing  on  work  by  JRC.  Estimates  by  JRC  show  a  WLTP  to 
NEDC  CO2  emissions  ratio  of  approximately  1.21  when  comparing  the  sales-weighted 
fleet-wide average CO2 emissions. WLTP to NEDC conversion factors are considered by 
individual vehicle segments, representing different vehicle and technology categories138.  

  Changes in road charges in Germany, Austria, Belgium and Latvia. 

  Reflecting the plateauing in the number of fatalities and injuries in the recent years, in the 
Baseline  scenario  it  has  been  assumed  that  post-2016  vehicle  technologies  would  be  the 
main source of reduction in fatalities, serious and slight injuries while measures addressing 
infrastructure  safety  (such  as  the  existing  RISM  and  Tunnel  Directives),  and  driver 
behaviour  (such  as  legislation  improving  enforcement  across  borders,  namely  Directive 

137  Awaiting signature of act (Source : 

http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?reference=2013/0157(COD)&l=en)  

138  Simulation  at  individual  vehicle  level  is  combined  with  fleet  composition  data,  retrieved  from  the  official 
European  CO2  emissions  monitoring  database,  and  publicly  available  data  regarding  individual  vehicle 
characteristics, in order to calculate vehicle CO2 emissions and fuel consumption over different conditions. 
Vehicle CO2 emissions are initially simulated over the present test protocol (NEDC) for the 2015 passenger 
car fleet; the accuracy of the method is validated against officially monitored CO2 values and experimental 
data. 

97 

 
 
                                                            
 
2015/413/EU  facilitating  cross-border  exchange  of  information  on  road  safety  related 
traffic offences) would compensate for the increase in traffic over time.  

2.2  Summary of main results of the Baseline scenario 

EU  transport  activity  is  expected  to  continue  growing  under  current  trends  and  adopted 
policies  beyond  2015,  albeit  at  a  slower  pace  than  in  the  past.  Freight  transport  activity  for 
inland  modes  is  projected  to  increase  by  36%  between  2010  and  2030  (1.5%  per  year)  and 
60% for 2010-2050 (1.2% per year). The annual growth rates by mode, for freight transport, 
are provided in Figure 1 below139. 

Road transport would maintain its dominant role within the EU. The share of road transport in 
inland freight is expected to slightly decrease at 70% by 2030 and 69% by 2050. The activity 
of heavy goods vehicles expressed in tonnes kilometres is projected to grow by 35% between 
2010  and  2030  (56%  for  2010-2050)  in  the  Baseline  scenario,  while  light  goods  vehicles 
activity would go up by 27% during 2010-2030 (50% for 2010-2050).  

Figure 11: Freight transport projections (average growth rate per year)140 

Rail freight transport activity is projected to grow significantly faster than for road, driven in 
particular  by  the  effective  implementation  of  the  TEN-T  guidelines,  supported  by  the  CEF 
funding,  leading  to  the  completion  of  the  TEN-T  core  network  by  2030  and  of  the 
comprehensive network by 2050. Rail freight activity grows by 51% by 2030 and 90% during 
2010-2050, resulting in 2 percentage points increase in modal share by 2030 and an additional 
percentage point by 2050. 

139  Projections for international maritime are presented separately and not included in the total freight transport 

activity to preserve comparability with statistics for the historical period. 

140 Source: Baseline scenario, PRIMES-TREMOVE transport model (ICCS-E3MLab) 

98 

-1.0%-0.5%0.0%0.5%1.0%1.5%2.0%2.5%3.0%RoadRailInland navigationFreight transport'95-'10'10-'30'30-'50 
 
 
 
 
                                                            
 
Transport  activity  of  freight  inland  navigation141  also  benefits  from  the  completion  of  the 
TEN-T core and comprehensive network, the promotion of inland waterway transport and the 
recovery in the economic activity and would grow by 26% by 2030 (1.2% per year) and by 
46% during 2010-2050 (0.9% per year).  

International maritime transport activity is projected to continue growing strongly with rising 
demand  for  oil,  coal,  steel  and  other  primary  resources  –  which  would  be  more  distantly 
sourced – increasing by 37% by 2030 and by 71% during 2010-2050.  

Transport accounts today for about one third of final energy consumption. In the context of 
growing  activity,  energy  use  in  transport  is  projected  to  decrease  by  5%  between  2010  and 
2030 and to stabilise post-2030. These developments are mainly driven by the implementation 
of the Regulations setting emission performance standards for new light duty vehicles. At the 
same time, heavy goods vehicles are projected to increase their share in final energy demand 
from 2010 onwards, continuing the historic trend from 1995. Energy demand by heavy goods 
vehicles would grow by 14% between 2010 and 2030 (23% for 2010-2050).  

Bunker fuels for maritime transport are projected to increase significantly: by 24% by 2030 
(42% for 2010-2050). 

LNG becomes a candidate energy carrier for road freight and waterborne transport, especially 
in the medium to long term, driven by the implementation of the Directive on the deployment 
of alternative fuels infrastructure and the revised TEN-T guidelines which represent important 
drivers  for  the  higher  penetration  of  alternative  fuels  in  the  transport  mix.  In  the  Baseline 
scenario, the share of LNG is projected to go up to 3% by 2030 (8% by 2050) for road freight 
and  4%  by  2030  (7%  by  2050)  for  inland  navigation.  LNG  would  provide  about  4%  of 
maritime  bunker  fuels  by  2030  and  10%  by  2050  –  especially  in  the  segment  of  short  sea 
shipping.  

Biofuels uptake is driven by the legally binding target of 10% renewable energy in transport 
(Renewables Directive), as amended by the ILUC Directive, and by the requirement for fuel 
suppliers to reduce the GHG intensity of road transport fuel by 6% (Fuel Quality Directive). 
Beyond  2020,  biofuel  levels  would  remain  relatively  stable  at  around  6%  in  the  Baseline 
scenario.  The  Baseline  scenario  does  not  take  into  account  the  recent  proposal  by  the 
Commission for a recast of the Renewables Energy Directive.  

In the Baseline scenario, oil products would still represent about 90% of the EU transport 
sector needs in 2030 and 85% in 2050, despite the renewables policies and the deployment of 

141  Inland navigation covers inland waterways and national maritime.  

99 

 
 
                                                            
 
alternative  fuels  infrastructure  which  support  some  substitution  effects  towards  biofuels, 
electricity, hydrogen and natural gas. 

The declining trend in transport emissions is expected to continue, leading to 13% lower 
emissions by 2030 compared to 2005, and 15% by 2050.142 However, relative to 1990 levels, 
emissions would still be 13% higher by 2030 and 10% by 2050, owing to the fast rise in the 
transport  emissions  during  the  1990s.  The  share  of  transport  in  total  GHG  emissions  would 
continue increasing, going up from 23% currently (excluding international maritime) to 25% 
in  2030  and  31%  in  2050,  following  a  relatively  lower  decline  of  emissions  from  transport 
compared  to  power  generation  and  other  sectors.  Maritime  bunker  fuel  emissions  are  also 
projected to grow strongly, increasing by 22% during 2010-2030 (38% for 2010-2050). 

CO2  emissions  from  road  freight  transport  (heavy  goods  and  light  goods  vehicles)  are 
projected  to  increase  by  6%  between  2010  and  2030  (11%  for  2010-2050)  in  the  Baseline 
scenario. For heavy goods vehicles, the increase would be somewhat higher (10% for 2010-
2030  and  17%  for  2010-2050),  in  lack  of  specific  measures  in  place.  At  the  same  time, 
emissions from passenger cars and passenger vans are projected to decrease by 22% between 
2010 and 2030 (32% for 2010-2050) thanks to the CO2 standards in place and the uptake of 
electromobility.  

NOx  emissions  would  drop  by  about  56%  by  2030  (64%  by  2050)  with  respect  to  2010 
levels. The decline in particulate matter (PM2.5) would be less pronounced by 2030 at 51% 
(65% by 2050). Overall, external costs related to air pollutants would decrease by about 56% 
by 2030 (65% by 2050).143  

High  congestion  levels  are  expected  to  seriously  affect  road  transport  in  several  Member 
States  by  2030  in  the  absence  of  effective  countervailing  measures  such  as  road  pricing. 
While  urban  congestion  will  mainly  depend  on  car  ownership  levels,  urban  sprawl  and  the 
availability of public  transport  alternatives, congestion on the  inter-urban network would be 
the  result  of  growing  freight  transport  activity  along  specific  corridors,  in  particular  where 
these corridors cross urban areas with heavy local traffic. Estimating the costs of congestion is 
not straightforward, because it occurs mostly during certain times of the day, often caused by 
specific bottlenecks in the network. In the Baseline scenario, total congestion costs for urban 
and  inter-urban  network  are  projected  to  increase  by  about  24%  by  2030  and  43%  by 
2050, relative to 2010. Noise related external costs of transport would continue to increase, 
by about 17% during 2010-2030 (24% for 2010-2050), driven by the rise in traffic.  

142  Including international aviation but excluding international maritime and other transportation.  
143  External costs are expressed in 2013 prices. They cover NOx, PM2.5 and SOx emissions. 

100 

 
 
                                                            
 
Further details on the Baseline scenario are available in the Impact Assessment accompanying 
the review of the Eurovignette Directive.144 

3.  Time savings assumptions  

In the Baseline scenario, the time per port call spent on reporting formalities is estimated at 60 
minutes  for  ships  on  fixed  routes  and  180  minutes  for  ships  on  non-fixed  routes145;  this 
assumption  has  been  developed  in  consultations  with  shipping  industry  representatives 
(ECSA, Interferry, CLIA) and their associated members. The rationale is that ships in fixed 
route (liner) traffic always call at the same ports, normally only at one or few EU ports. They 
are therefore  less  affected  by  the  lack  of  harmonisation  of  reporting.  The  fixed  route  traffic 
also includes most of the larger vessels normally applying machine-to-machine reporting. The 
average  reporting  time  per  port  call  is  thus  at  the  lower  end  for  the  fixed  route  traffic.  The 
non-fixed route (tramp)  traffic on the other  hand by nature calls at multiple  ports, requiring 
more  adaptations  to  the  non-harmonised  reporting  systems.  Time  spent  on  reporting  is 
therefore  higher.  This  traffic  category  also  covers  mostly  smaller  size  vessels,  less  likely  to 
apply machine-to-machine reporting. There are exceptions to the general rule in both groups; 
but  the  average  is  considered  a  correct  assumption  by  the  consulted  shipping  operator 
representatives. 

There  is  no  available  data  on  port  calls  per  traffic  type.  However,  ECSA  applies  an 
assumption  model  built  on  combining  two  main  factors:  vessel  size  and  cargo  type.  The 
majority  of  vessels  smaller  than  10  000GT  carrying  bulk  (dry  or  liquid)  goods  or  general 
cargo are assumed to go in tramp traffic. Larger vessels or vessels carrying other goods (e.g. 
passengers, containers) are more likely to be in fixed route traffic. There are some exceptions 
in  both  categories,  balancing  out  to  make  the  overall  assumption  hold.  Applying  these 
assumptions, it is estimated that about 40% of the total number of port calls in the EU can be 
attributed to fixed routes and 60% to non-fixed routes146.  

In the policy options A1-C1, on average 30 minutes per call (50%) are assumed to be saved 
relative to the Baseline scenario for the ships on fixed routes and 135 minutes (75%) relative 
to  the  Baseline  for  ships  on  non-fixed  routes.  The  higher  saving  potential  for  the  non-fixed 
route is based on the higher impact of harmonisation on these ships. The fixed-route ships will 
primarily  benefit  from  the  single  entry  point,  the  reduction  of  duplicate  data  requests 
(reporting only once). All traffic types will also benefit from the simplified and harmonised 
data set. 

144 Source: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52017SC0180 
145 Evaluation of the RFD, p.19-20 
146  Source: own estimates based on Eurostat statistics. 

101 

 
 
                                                            
 
For policy options A2-C2 lower time savings are assumed to be achieved: 12 minutes per call 
relative to the Baseline scenario (20%) for the ships on fixed routes and 45 minutes relative to 
the Baseline (25%) for ships on non-fixed routes. The separate entry points for reporting are 
not  only  expected  to  create  an  additional  administrative  burden  in  themselves;  there  will  be 
little harmonisation of data sets between the two separate reporting entry points with high risk 
of  duplication  of  data  elements  in  different  requested  formats.  The  consulted  shipping 
operators therefore expect only the low end benefits for these options. 

The new harmonised entry point will not be mandatory for shipping operators; they will still 
have the options to report via the non-harmonised and non-simplified old system with several 
reporting gateways in parallel. It is therefore assumed that not all shipping operators will in 
fact  make  use  of  this  option.  E.g.  some  SMEs  and  some  vessels  in  domestic  traffic  may 
choose not to make use of the new reporting system. In the consultations, more than 90% of 
all  shipping operators did  ask  for a harmonised reporting environment. For a  more cautious 
approach, a gradual uptake from 25-90% over the baseline period has been assumed. This was 
then  also  compared  against  a  pessimistic  scenario  with  an  estimated  lower  gradual  uptake 
from 15-80% over the same period. 

 Time spent on reporting – reduction of administrative burden 
MAIN ASSUMPTIONS 

Fixed route (share of total port calls) 
Non-fixed route (share of total port calls) 

Labour cost EUR/h 
Discount rate 

Hours spent for reporting, average (baseline) 

Fixed route  
Non-fixed route 

Time / average time savings (options A1-C1) – ECSA model 

Fixed route  
Non-fixed route 

Time / average time savings (options A2-C2) – ECSA model 

Fixed route  
Non-fixed route 

40% 
60% 

38,35 
4% 

1 
3 

50% 
75% 

20% 
25% 

102 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
GRADUAL UPTAKE 
ASSUMPTION 
Expected uptake 
Low uptake 

2020147 
0% 
0% 

2021 
25% 
15% 

2022 
50% 
40% 

2023 
75% 
65% 

2024 
90% 
80% 

2025 
90% 
80% 

2026 
90% 
80% 

2027 
90% 
80% 

2028 
90% 
80% 

2029  2030 
90% 
90% 
80% 
80% 

Baseline   A1 

Staff hours (million hours) 

50 

Savings compared to baseline 

0 

25-28 

22-25 

A2 

EU28 

42-43 

7-8 

B1 

B2 

C1 

C2 

25-28 

22-25 

42-43 

7-8 

25-28 

22-25 

42-43 

7-8 

€ million (present value) 

1,520 

800-895 

1275-1305 

800-895 

1275-1305 

800-895 

1275-1305 

Savings compared to baseline 

0 

625-720 

215-245 

625-720 

215-245 

625-720 

215-245 

Excluding UK 

Staff hours (million hours) 

48 

Savings compared to baseline 

0 

24-27 

21-24 

40-41 

7-8 

24-27 

21-24 

40-41 

7-8 

24-27 

21-24 

40-41 

7-8 

€ million (present value) 

1,455 

765-855 

1220-1250 

765-855 

1220-1250 

765-855 

1220-1250 

Savings compared to baseline 

0 

600-690 

205-235 

600-690 

205-235 

600-690 

205-235 

Table 6: Reduced administrative burden for shipping operators relative to the baseline over 2020-2030 

4.  Assumptions used to estimate costs related to IT systems 

The following TCO model has been elaborated, consisting of three levels of aggregation. The 
data  source(s)  used  to  populate/  estimate/  extrapolate  the  cost  of  the  category  and  sub-
category, as well as the manner in which it was computed, are detailed in the following tables.  

147 No expected benefits during first year of implementation 

103 

 
 
 
 
 
 
  
 
 
 
                                                            
 
Central Costs  
Level 1. Level 2. Level 3 
Software 
  Development 
     ERG 

Continuous 
infrastructure 

availability  DBMS 

functionalities 

     Additional 
reservation 
  Maintenance  
     ERG 
     Continuous 
infrastructure 
     Additional maintenance reservation 
  Other software costs 

availability  DBMS 

Operation Services 
  Managed services 
     A central directory  
     High-availability  ERG  (Level  2/3 
support) 
  Testing Services 
     A  certification  process  for  Data 
Providers  
     A sandbox environment for national 
authorities  
  Supporting services 
     Deployment services 
       Support the national authorities  
       Support the NSWs integrating 
  Service desk for National Authorities 
  Training services 
  Other supporting services 

Description 

  Cost category covering the EMSW 

development, maintenance support and other 
software costs 

  The development and maintenance ERG costs 

originate from the FFPA analysis 
  The continuous availability DBMS 

infrastructure and other software costs are 
derived from Gartner’s peer Benchmark data 
cumulated with Gartner Consulting experience 
and Gartner Case data 

  Comprehensive set of operation services that 
should be offered to cover all three retained 
policy options: managed services, testing, 
supporting services, service desk for National 
Authorities, training and other supporting 
services 

  Gartner Benchmark peer data fed into testing 
services, as well as into deployment services 

  Managed Services. A central directory: 

Calculated considering ½ FTE based on 24/7 
availability  

  Managed Services. High-availability ERG 

(Level 2/3 support): Calculated considering 1 
FTE based on 24/7 availability using synergies 
with EMSW’s maintenance and that of other 
systems 

  Testing Services have been costed in line with 
the Gartner Benchmark peer data points, 
considering the costs of setting up and 
supporting the certification process for the Data 
Providers 

  Gartner IT Key Metrics data has been leveraged 
to estimate the costs for the service desk for 
National Authorities, while Gartner 
benchmarking data fed into costing training and 
other supporting services. For the training 
services, across the three retained policy 
options 12 monthly training sessions have been 
envisaged 

104 

 
 
Central Costs  
Level 1. Level 2. Level 3 

Description 

Stakeholder Managed Services 
  Stakeholder on boarding services 
     Awareness raising activities  
  Community management services 
     Share best practice and experience 

Technical Specification 
   Maintenance 
     Maintain 
exchange standards 

eManifest 

and  other 

Programme Management 
   Vendor management 
   Programme coordination 

Infrastructure 
  Server & Storage 

Contingency 
  Contingency (20%) 

  Stakeholder on-boarding services and 

community management services have been 
envisioned as part of the EMSW Stakeholder 
Management Services, both costed in line with 
Gartner Benchmark peer data points, as well as 
other data points provided by EMSA 

  Maintenance. Maintain the technical data sets 
(eManifest and Maritime Single Window data 
set) and other exchange standards: The cost is 
associated with that of 1 FTE 

  Cost category covering both vendor 

management activities and programme 
management coordination activities, necessary 
for EU retention of resources  

  All cost elements included under Programme 

Management are in line with Gartner 
Consulting professional expertise  

  The Server & Storage costs were computed 

multiplying the number of environments across 
both data centres with the cost per Linux server 
adding up the cost of 1/ 5/ 10 raw terabytes of 
storage in line with Gartner Benchmark peer 
data and Gartner Case data  

  Across the three retained policy options, 20% 
out of the total costs per year are added up to 
account for the Contingency, defined as 
unforeseen costs to be spent by EU, not covered 
by any of the other cost categories 

Costs for the Member States148  
(€ million, present value) 

CapEx 
OpEx 

Total MS 

- 
108 

108 

13,5 
14,3 

27,8 

10,7 
11,0 

21,7 

7,8 
8,1 

7,1 
6,8 

10,7 
8,1 

10,7 
8,1 

15,8 

13,9 

18,8 

18,8 

Baseline   A1 

A2 

B1 

B2 

C1 

C2 

EU28 

148  Member  States'  baseline  cost  for  annual  operation  of  the  current  National  Single  Windows  remains  in  all 

options: the additional costs come on top of the annual costs of a NSW. 

105 

 
 
   
 
  
                                                            
 
Costs for the EU (European Commission 
or other entity assigned with the task)  
(€ million, present value) 

Total costs (€ million, present value) 

Costs for the Member States 149 
(€ million, present value) 

CapEx 

OpEx 

Total EU 

CapEx 

OpEx 

Total MS 

CapEx 

- 

- 

- 

108 

Excluding UK 
- 

104 

104 

- 

1,7 

9,6 

11,3 

39,1 

12,9 

13,7 

26,6 

1,7 

1,7 

9,6 

11,3 

33,0 

10,2 

10,5 

20,7 

1,7 

2,5 

11,0 

13,5 

29,4 

7,5 

7,8 

15,2 

2,5 

2,5 

2,4 

2,4 

10,9 

13,0 

12,0 

13,3 

15,4 

14,4 

27,2 

34,2 

33,2 

6,8 

6,6 

10,2 

10,2 

7,8 

7,8 

13,4 

18,0 

18,0 

2,5 

2,4 

2,4 

Costs for the EU (European Commission 
 or other entity assigned with the task)  
(€ million, present value) 
Total costs (€ million, present value) 
Table 7: Investment/adaptation and operational costs (total period 2020-2030, EUR million, present value); 4% Better 
Regulation discount rate applies.  

11,3 
32,0 

13,5 
28,7 

15,4 
33,4 

11,3 
37.9 

13,3 
26,7 

- 
104 

Total EU 

OpEx 

11,0 

13,0 

10,9 

9,6 

9,6 

- 

12,0 

14,4 
32,4 

Member State Costs 
Level 1. Level 2. Level 3 

Description 

CAPEX 
  Adaption of NSW 
  Adaption of national authority systems  

  The estimation of the development effort is 
based on FFPA, a Gartner adaption of the 
IFPUG FPA methodology for assessing 
functional complexity of software. The ERG 
development costs were plugged into the cost 
analysis 

  Adaptation of NSW and adaptation of national 
authority systems are dependent on Cost of IT 
developers across Member States. Gartner’s 
rate card statistics and IT Key Metrics have 
been used to factor in the differences in IT 
manpower across the Member States. The 
factor between the least and most expensive is a 
factor of 3 

  Adaptation of national authority systems is 

dependent on the number of local authorities 
involved in the NSW. The number of 
authorities in each Member State drives the 
number of integrations that require adaptations  

149  Member  States'  baseline  cost  for  annual  operation  of  the  current  National  Single  Windows  remains  in  all 

options: the additional costs come on top of the annual costs of a NSW. 

106 

 
 
   
                                                            
 
Member State Costs 
Level 1. Level 2. Level 3 

Description 

OPEX 
   Annual Adaption of NSW 
   Annual Adaption of authority systems 

  The estimation of the maintenance effort is 
based on FFPA, a Gartner adaption of the 
IFPUG FPA methodology for assessing 
functional complexity of software. The ERG 
maintenance costs were plugged into the cost 
analysis 

  Adaptation of NSW and adaptation of national 
authority systems are dependent on Cost of IT 
developers across Member States. Gartner’s 
rate card statistics and IT Key Metrics have 
been used to factor in the differences in IT 
manpower across the Member States. The 
factor between the least and most expensive is a 
factor of 3 

  Adaptation of national authority systems is 

dependent on the number of local authorities 
involved in the NSW. The number of 
authorities in each Member State drives the 
number of integrations that require adaptations 
and maintenance 

The  costs  for  Member  States  differ  between  the  options  mainly  depending  on  the  level  of 
adaptations required for the NSWs: 

The  support  study  has  analysed  the  additional  costs  for  MS  in  the  scenarios  with  the  three 
policy  options.  This  means  the  costs  for  adapting  or  updating  the  existing  NSWs  (CAPEX) 
and the increase in annual maintenance of the NSW due to expanded scope and functionalities 
in  the  updated  system  (OPEX).  These  costs  therefore  come  on  top  of  the  baseline  cost  of 
annual  operation  and  maintenance of  each  NSW  already  today.  The  NSW’s  are  assumed  to 
remain in the picture across options B, C and D. 

The NSW’s today consists of two bundles of functionality: 

1.  The front-end reporting interface(s) to the data providers, i.e. the functionality 

associated with receiving and validating the reporting data set and sending back 
responses. 

2.  The back-end connections to the authorities, i.e. the functionality associated with 
sending authority-specific data sets, and with sending, and receiving messages.  

In Option B, each MS will need to take on the costs for developing the necessary solutions to 
implement  the  technical  specifications  and  subsequently  adapt  the  existing  NSW’s  to  the 

107 

 
 
 
 
technical specifications. This requires them to update both functionality bundles 1 and 2. The 
estimate of this is based on function-point counting. 

In  Option  C,  the  front-end  reporting  interface  in  the  existing  NSW’s  is  replaced  by  the 
centrally developed and fully harmonised reporting gateway component. Member States have 
to plug in this software to the National Single Windows and ensure that the translation from 
the  common  software  to  the  back-end  connections  works.  This  means  that  they  replace  the 
original  functionality  bundle  1  with  the  centrally  developed  software.  Therefore,  the  MS 
CAPEX  of  option  C  is  lower  than  in  option  D  (and  B),  as  all  NSW  systems  are  recent 
implementations  and  it  is  therefore  a  relatively  simple  process  to  integrate  the  centrally 
developed  interface  and  switch  off  redundant  functionality.  The  associated  estimate  for 
Option C is 100 man-days. For Option C, the functionality bundle 2 also needs to be adapted 
and maintained (same as in option B and D). 

The  MS  OPEX  of  option  C  is  also  lower  than  in  option  D.  Instead  of  managing  the  full 
software  development  cycle  of  functionality  bundle  1,  they  only  need  to  care  about  initial 
adaptions  and  then  recurring  installation  and  testing  of  the  front-end  reporting  gateway 
solution they receive from EU-level.  

In  Option  D,  the  central  European  Maritime  Single  Window  is  implementing  functionality 
bundle  1  (providing  the  harmonised  front-end  interface  towards  the  users).  Each  Member 
State need to adapt their current functionality bundle 1 in the existing NSW’s and transform 
the  NSWs  into  playing  instead  a  routing  function  between  the  central  gateway  and  the 
“functionality  bundle  2”  connections.  Also,  they  need  to  adapt  the  functionality  bundle  2, 
facing the individual national authorities. This corresponds to the lines: “Adaption of NSW”, 
and “Adaption of authority interfaces” in Table 11 of Appendix G of the support study. 

Since  in  Option  D,  the  NSW’s  can  still  receive  reporting  directly  from  data  providers 
(national  traffic),  they  also  need  to  update  functionality  bundle  1  in  the  same  manner  as  is 
required  in  option  B.  In  total,  the  CAPEX  costs  for  option  D  are  therefore  higher  than  in 
option C for Member States. 

As  is  explained  in  Appendix  G  of  the  support  study,  Table  12  –  14,  the  MS  costs  vary 
significantly between the MS for the following reasons: 

  The estimates are taking a starting point in a generic estimation of the complexity of 
providing the functionality provided in a NSW, which drive the complexity of the 
adaptions and maintenance. 

  As the development and maintenance efforts in MS are typically done by specialized 

IT staff or specialized IT service providers, the massive differences in cost of 
developer staff between MS should be reflected. They vary from €392 in Bulgaria to € 
1263 in the Nordic countries using market data gathered by Gartner. 

108 

 
 
 
  As the complexity of the NSW varies with the number of authorities connected to the 
NSW, a complexity adjustment has been calculated based on data gathered from the 
national authorities. 

Regarding EU costs for the options. 

  Development costs for the ERG: 

o  In all options B, C, and D the EU is required to contribute to the functionality 
bundle 1 (see above). In option B, the technical specifications are developed at 
EU level. In Option C, a complete solution for the functionality bundle is 
developed and distributed to MS. In option D this functionality is installed on 
EU servers to provide the central service. 

  Stakeholder Management Services consists of two sub-categories: “Awareness-raising 
activities” and “Share best-practice and experience”. “Awareness raising activities” 
are estimated at equal levels based on data gathered by Gartner on other EU policy 
initiatives. “Share best-practice and experience” vary between the options for the 
following reasons: 

o  Options B are estimated to drive a slightly lower but still significant cost as the 
value of exchanging experience with implementing the technical specification 
can save costs and time in the MS implementation. 

o  Options C are estimated to drive the largest cost, as sharing best practice and 

experience will be crucial for the success of effectively deploying and 
integrating a centrally developed interface. 

o  Options D are estimated to have the lowest cost, as the need to share best 

practice will be lower with a central service. 

  Support services: 

o  The cost model estimates costs for support services towards national 

authorities, e.g. service desk and training offered. These costs are estimated to 
be higher for Option C than for the other options as the installation of central 
software will generate additional requests compared to the other options 

  Costs are also calculated for operation services such as the central directories, for 

programme management and for infrastructure (e.g. servers, storage, network). These 
costs are expected to be more or less similar regardless of the option. 

  Development costs are initiated in year two of the cost model in order to leave time for 

finding and contracting service providers for the development work. 

109 

 
 
 
 
 
Annex 5: the Reporting Formalities Directive 

In  2010,  the  Reporting  Formalities  Directive  (RFD)  was  adopted  with  the  aim  to  simplify, 
digitalise  and  harmonise  administrative  procedures  for  maritime  transport.  The  Directive 
introduced National Single Windows (one single reporting entry point for each Member State) 
for  reporting,  in  digital  format,  on  a  set  of  14  agreed  procedures  stemming  from  EU  or 
international law.  

The RFD covers three types of reporting formalities (as listed in Parts A-C of Annex 1): 

• 

• 

• 

Part A: information required by EU legislative acts. This includes notification for 
ships arriving in and departing from ports of the EU, information on border checks 
on  persons,  notification  of  dangerous  or  polluting  goods  carried  on  board, 
notification  of  waste  and  residues,  notification  of  security  information  and  entry 
summary declaration for customs. The data is collected for a set of purposes, e.g. 
to facilitate traffic management, for safety and security, for border controls and for 
environmental objectives.  

Part  B:  information  provided  in  accordance  with  the  IMO  ‘FAL  Convention’ 
(general and cargo declaration, ship’s store declaration, crew’s effect declaration, 
crew  and  passenger  list  and  dangerous  goods  information)  and  with  the 
International  Health  Regulations  (maritime  declaration  of  health).  This  data  is 
submitted in line with international standardised forms (IMO). 

o  Part  A  and  Part  B  together  require  the  submission  of  around  230  data 
elements.  Some  of  the  data  elements  collected in  Part  A  and  B  serve  double 
purposes and feed several of the back-end entities. 

Part C: information required by national legislation of the Member State of the 
port  of  call.  Part  C  data  is  not  mandatory  for  Member  States  to  request  via  the 
National Single Windows. These data sets differ for each Member State and there 
has until yet been no harmonisation of formats. This information is mostly linked 
to  ship/port  operations  (bunkering,  piloting,  tug  requests,  etc.).  The  on-going 
mapping of national reporting has found that shipping operators may be required 
to provide to local authorities up to 200 different data elements in addition to part 
A and B. 

This  covers  the  maritime  transport  related  reporting  a  shipping  operator  must  perform  in 
connection  to  a  port  call  but  not  the  bulk  of  cargo-related  reporting  (primarily  to  customs 
authorities). 

The  Reporting  Formalities  Directive  is  a  coordination  mechanism  to  facilitate  for  maritime 
transport operators when calling an EU port. It established a mechanism (the National Single 
Windows) for streamlining the reporting requested in a set of EU and international legal acts. 
It doesn’t cover all reporting requested from a ship (notably: cargo reporting to customs; only 
non-mandatory  reporting  of  national  and  legal  requirements)  and  the  Directive  does  not 

110 

 
 
 
 
 
specify the data model or  data  format to  be used.  The Directive does not  add any  reporting 
formalities;  it  only  specifies  how  Member  States  need  to  coordinate  the  reporting  requests 
under a certain set of legal acts via a single reporting entry point. 

In  the  absence  of  binding  technical  specifications,  Member  States  have  interpreted  and 
implemented  the  Directive  in  different  ways:  e.g.  applying  centralised  or  decentralised 
National  Single  Window  set-ups,  using  different  data  formats  and  reporting  templates  and 
requesting different sets of additional national reporting requirements in national formats via 
the reporting entry point. Although most maritime Member States have established some kind 
of National Single Window, these Single Windows can be arranged in many different ways. 
Some  are  fully  centralised  at  national  level,  some  have  national  level  specifications  and 
procedures but are implemented at local/port level in a distributed system of entry points. In 
other case the reporting obligations are fulfilled via the commercial Port Community Systems 
which in turn send information to the national authorities. 

The Directive doesn’t cover all existing reporting obligation requested from a ship (notably: 
most of cargo reporting to customs; only non-mandatory reporting of national requirements, 
statistical requirements). 

While  cargo  reporting  to  maritime  authorities  is  fulfilled  submitting  the  general  and  cargo 
declaration (FAL forms 1 and 2, see Part B), the RFD only mandates the transmission of the 
Entry  Summary  Declaration  to  customs  via  the  National  Single  Windows.  The  Entry 
Summary  Declaration  covers  around  50  cargo  data  elements.  Around  another  100  data 
elements  are  required  by  the  Union  Customs  Code  (Reg.  952/2013/UE)  and  must  be  sent 
directly  to  the  customs  IT  systems.  These  data  have  been  mapped  by  the  Commission 
eManifest  pilot  project,  with  the  purpose  of  assessing  how  to  fulfil  all  cargo  reporting 
obligations  (both  maritime  and  customs)  with  the  use  of  an  electronic  harmonised  data  set 
encompassing all required cargo data elements.  

DG MOVE launched the eManifest pilot project in 2016 in collaboration with DG TAXUD 
and  with  the  support  of  EMSA.  14  Member  States  and  14  shipping  industry  associations 
participate  in  the  pilot  project.  The  pilot  aims  to  establish  a  harmonised  electronic  data  set 
encompassing  cargo  data  elements  required  for  maritime  and  customs  reporting.  It  assesses 
how  this  information  can  be  submitted  to  the  authorities.  EMSA  has  already  developed  a 
prototype  for  the  testing  of  submission  of  cargo  formalities  along  with  the  remaining  non 
cargo  reporting.  The  project  has  run  in  four  phases  where  cargo  reporting  formalities  have 
been  assessed  and  gradually  added  to  the  testing,  with  final  outcomes  during  2018.  The 
outcome of the pilot project will be business rules and a data mapping made up of all cargo 
data  elements,  supporting  the  future  harmonised  European  Maritime  Single  Window 
environment. 

When a vessel calls in an EU port carrying goods, depending on factors like the last port of 
call and the type of cargo on board, a set of formalities may have to be submitted to customs 
authorities,  notably  the  arrival  notification,  the  presentation  notification  of  goods  and  the 

111 

 
 
declaration  for  temporary  storage.  Other  formalities  are  envisaged  instead  at  the  departure 
from an EU port, like the exit summary declaration, re-export notification, or the notification 
of exit for goods under export procedure 

Reporting to customs is necessary most of the times even when goods are carried between two 
points  of  the  EU  territory  by  sea.  In  this  case,  maritime  operators  can  benefit  of  simplified 
reporting  through  the  submission  of  the  ‘customs  goods  manifest’  or  of  the  ‘electronic 
transport document for simplified transit’. None of these simplified procedures are mentioned 
in the RFD and are therefore out of the scope. 

This  limited  scope  of  the  RFD  means  that,  today  only  about  one  third  of  all  information 
requested from a ship in a port call is always requested via the NSWs. This has been pointed 
out  by  shipping  operators  as  one  of  the  main  problem  drivers.  The  separate  reporting  paths 
mean uncoordinated reporting with duplications and non-harmonised formats. 

This  graph  is  a  simplified  picture  illustrating  the  main  reporting  flows  from  ships,  not  taking  into 
account the detailed and more complex two-way flows of information to and from customs. 

112 

 
 
 
 
 
 
Annex 6: Policy options 

Harmonised 
technical 

A: 
NSWs: 
specifications 

B: 
NSWs: 
software  

Harmonised 
common 

C: Central EMSW   D:  Mandatory  PCS 

(discarded) 

1.  Comprehensive 
single  entry  point 
solution 
2.  Separate  entry 
points  customs  / 
maritime  

Option A1: 
Measures A, 1 and 
I-VI 
Option A2: 
Measures A, 2 and 
I-VI 

Option B1: 
Measures B, 1 and I-
VI 
Option B2: 
Measures B, 2 and I-
VI 

Option C1: 
Measures C, 1 
and I-VI 
Option C2: 
Measures C, 2 
and I-VI 

Option D1: 
Measures D, 1 and I-
VI 
Option D2: Measures 
D, 2 and I-VI 

Alternative measures 

Problem Driver 1: Diverse ship reporting formats, interfaces and procedures used throughout 
the EU 
No. 

Policy measures A-D 

Alt. A  Harmonised reporting gateways as front-end to the National Single Windows (NSWs): 

based on binding technical specifications  
Introduce  binding  harmonised  requirements  and  technical  specifications  for  the  front-end 
reporting  gateway  in  the  existing  NSWs  in  the  Member  States.  The  specifications  would 
cover  e.g.  data  content,  message  structure  format,  exchange  protocols,  user  interface 
requirements and other rules as necessary for ensuring the necessary information exchanges 
business  rules.  They  would  be  set  at  EU  level  but  responsibility  for  implementation  and 
operation would be fully on the Member States. The result would be a decentralised system 
of NSWs with identical reporting gateway functionalities for ship reporting. 

Alt. B  Harmonised reporting gateways as front-end to the National Single Windows (NSWs): 

based on common IT solution  
Develop  a  mandatory  common  harmonised  reporting  gateway/  front-end  interface 
component at EU level, for installation in every NSW. Regular updates as required would be 
supplied  via  the  EU.  The  operational  responsibility  would  be  on  Member  States  but  with 
helpdesk  functions  for  the  software  installation  at  EU  level.  The  result  would  be  a 
decentralised system of identical reporting gateways, providing exactly the same “look and 
feel” front-end in every Member State. 

Alt. C  Central  European  level  reporting  gateway:  introduction  of  a  centralised  EU-level 

reporting entry point 
Introduce  a  centralised,  EU-level  reporting  gateway  /  front-end  interface.  The  centralised 
reporting gateway would offer one single reporting entry point for all port calls throughout 
the EU including the necessary two-way information exchanges between the data providers 
and the back-end connected entities and systems. The NSWs would remain in place as the 
router  between  the  centralised  reporting  gateway  and  the  national  level  data  recipients. 
Member  States  would  be  responsible  for  ensuring  connection  of  their  National  Single 
Windows to the centralised gateway. 

Alt. D  Mandatory  Port  Community  Systems  (PCS)  as  basis  for  harmonised  reporting 

gateways in Member States (technical specifications) 
Build  the  EU  level  harmonisation  requirements  and  binding  technical  specifications  on 
mandatory  PCS  reporting  gateways  in  the  Member  States  (all  other  details  same  as  in 
alternative A above). 

113 

 
 
 
 
 
 
 
 
 
(introduction  of  a  mandatory 

Problem  Driver  2:  Diverse  ship  reporting  information  requirements  throughout  the  EU  – 
several parallel reporting entry points 
No. 
Policy measure 
Alt. 1  Comprehensive  single  entry  point  solution 
comprehensive Maritime Single Window data set) 
Set a wide scope for the reporting by ships in connection to a port call to be accepted via 
the  harmonised  European  Maritime  Single  Window  environment:  covering  the  current 
scope of RFD, the national reporting requirements and channelling of customs formalities 
for ships into (and return messages from) the customs IT systems at national and EU level. 
Separate  entry  points  customs  /  maritime  (introduction  of  a  mandatory  limited 
Maritime Single Window data set) 
Set a limited scope for the reporting by ships in connection to a port call to be accepted via 
the  harmonised  European  Maritime  Single  Window  environment:  covering  the  current 
scope of RFD and the national reporting requirements. Customs formalities to be reported 
via the parallel and harmonised customs IT systems. 
Common/complementary set of measures (enabling framework) 

Alt. 2 

Problem  Driver  2:  Diverse  ship  reporting  information  requirements  throughout  the  EU  – 
several parallel reporting entry points 
No. 
I 

Policy measure 
Introduction of specifications for acceptance of e-certificates 
Enable  development  of  e-certificates  acceptance  by  initiating  processes  for  specifications 
and technical solutions (e.g. common registries). 

No. 
II 

Problem Driver 3: Unclear legal framework for sharing and using reporting information – no 
“reporting only once”  
Policy measure 
Establishment of data re-use principles for “reporting only once”  
A  set  of  clear  principles,  rules  and  rights  for  data  sharing  and  reuse  will  be  developed  to 
ensure  correct  and  smooth  data  management  and  “reporting  only  once”  for  carriers,  as  a 
minimum first step within the same port. Clear definitions for different requirements will be 
provided.  Definitions  and  specifications  concerning  the  processing  and  management  of 
personal or commercially sensitive data will be addressed.  
Development of common databases to support the system  
This includes a common exemption database, a common (federated) user database(s) and a 
common ship repository. 

III 

Problem Driver 4: Inadequate implementation  

No. 
IV 

V 

Policy measure  
Introduction of a governance mechanism  
A  governance  mechanism  will  be  created  to  ensure  timely  and  appropriate  legal  and 
technical  updates.  Implementing  and/or  delegated  powers  for  maintenance  of  e.g.  the 
technical specifications are proposed. This will be accompanied by the set-up of the required 
expert  groups  for  coordination  and  consultation  with  Member  States  and  with  industry 
stakeholders as needed. 
Development of a complaint/feedback mechanism  
A complaint/feedback mechanism will be offered to maritime transport operators as a tool to 
alert  authorities if the harmonised reporting  and the reporting only once principles are not 
respected or if any technical fault is found in the reporting systems. 

114 

 
 
 
VI 

Development of helpdesk function  
To facilitate implementation, technical support to Member States on the European Maritime 
Single  Window  environment  specifications  and  software  in  the  form  of  e.g.  helpdesk 
functions, technical advice or development of application guidelines will be developed. 

The  figure  below  illustrates  the  reporting  environment  in  options  A1  and  B1.  Each  National  Single 
Window has a harmonised front-end interface (a reporting gateway), either harmonised via technical 
specifications  –  software  development  done  by  the  Member  State  –  or  by  plugging  in  a  front-end 
module developed at EU level. 

Regardless  of  what  port  or  Member  State  the  shipping  operator  calls  to,  the  reporting  interface  will 
thus be the same (with identical functions in option A1; identical interface in option B1). 

The National Single Windows then distributes the data to the back-end data recipients, in the formats 
they  require  (using  translation  functions  if  needed)  and  providing  subsets  of  data  on  need-to-know 
basis  only.  These  back-end  data  recipients  include  for  example  border  control  authorities,  health 
authorities,  customs  IT  systems,  the  SafeSeaNet  and  port  community  systems.  These  back-end 
interfaces  will  remain  as  in  the  current  National  Single  Window  set-ups,  with  reservation  for 
adjustments due to harmonisation of the data set. 

A  number  of  common  databases  and  user  registries  are  maintained  at  EU  level  for  facilitating  the 
functioning of the system. 

The initiative does not ban other reporting paths and a shipping operator may choose to report part of 
their  data  directly  to,  for  example,  port  community  systems  or  customs  IT  system  (see  example  of 
“optional connection” in the figure below). 

In options A2 and B2, the same set-up would be established but the reporting to customs IT system 
would be separate from the National Single Window reporting (shipping operators reporting directly 
to the customs IT systems for the cargo-related data). 

115 

 
 
 
Figure 12: Option A-B, distributed system with harmonised entry point (via technical specifications or common front-
end IT solution) 

116 

 
 
 
The following figure illustrates the centralised scenario in option  C1. The shipping operator 
can report directly to a centralised and harmonised reporting gateway (“EMSW”). The data is 
then  routed  via  this  gateway  to  the  National  Single  Windows  and  to  the  back-end  data 
recipients  (see  also  next  figure  below  for  the  detailed  illustration  of  customs  IT  system 
connections). The centralised gateway also connects  to  a number of  common databases  and 
user registries. 

The National Single Windows would need to be adapted their front-end to connect with the 
centralised  new  reporting  gateway.  The  back-end  interfaces  will  remain  as  in  the  current 
National Single Window set-ups, with reservation for adjustments due to harmonisation of the 
data set. 

The  initiative  will  not  forbid  the  continuation  of  alternative  reporting  paths.  A  shipping 
operator  may  therefore  have  the  option  to  report  part  of  their  data  directly  to,  for  example, 
National  Single  Windows,  port  community  systems  or  customs  IT  system  (see  examples  of 
“optional connection” in the figure below). 

In  option  C2,  the  same  set-up  would  be  established  but  the  reporting  to  customs  IT  system 
would be separate from the European Maritime Single Window reporting (shipping operators 
reporting directly to the customs IT systems for the cargo-related data). 

117 

 
 
 
Figure 13: Option C, centralised system 

118 

 
 
The  figure  below  illustrates  in  more  detail  the  connections  between  the  maritime  single 
window (national or centralised level) and the customs IT systems in options A1, B1 and C1. 
The initiative will not interrupt existing reporting paths and a shipping operator may choose to 
continue reporting their cargo-related data directly to the customs IT systems. 

The shipping operator may however also choose to report the entire maritime single window 
data  set  via  the  harmonised  maritime  reporting  gateway,  from  where  the  data  is  routed  and 
distributed as required to the back-end connected authorities. This may require translation of 
some  data  elements  to  ensure  the  back-end  authorities  receive  the  data  subsets  in  their 
required  formats,  following  the  specifications  in  the  underlying  legal  acts.  The  maritime 
single window would also need to transmit the two-way flow of messages between customs 
IT systems and the shipping operators. 

This  reporting  environment  set-up  thus  creates  inter-connection  between  the  maritime 
transport reporting and the customs formalities for ships. 

119 

 
 
 
Figure 14: Connection between the maritime single window and customs IT systems: reporting options for shipping 
(detailed technical implementation for these connections between the maritime national single windows and customs IT 
systems will be subject to further IT feasibility studies) 

120 

 
 
of 

repetitive 

Key interests 
Simplified  reporting  procedures  to 
minimise  administrative  burden 
and  maximise  efficiency  of  port 
calls for shorter turnaround times 
Minimise 
and 
cumbersome  procedures  to  release 
work time for core tasks; protecting 
the  quality  and  reputation  of  the 
profession 
Competitiveness 
sector; 
protection  of  the  role  and  position 
of the profession; efficiency of port 
reporting  procedures  to  maximise 
profitability 
Developing 
and  maintaining 
and 
profitability, 
independence 
competitiveness  of  the  port;  level 
playing field for port competition 
Level  playing  field  for  and  within 
sector 
the  maritime 
contributing  to  jobs,  growth  and 
trade;  efficient  information  flows 
from  ships 
to  enable  authority 
follow-up  in  line  with  applicable 
law;  ensuring  an  effective,  cost-
practicable 
efficient 
and 
management 
that 
framework 
balances stakeholder needs 
reliable 
Efficient, 
submissions  of  declarations  and 
notifications  from  the  economic 
two-way 
operators; 
smooth 
and 
exchange  of 
notifications  between  customs  and 
the economic operators 
Availability  and  cost  of  goods  and 
passenger services 

information 

transport 

timely 

and 

Affected stakeholders and their key interests 

Stakeholder 
Shipping operators 

On-board staff 

Shipping agents 

providing  EU 

Description 
Operators 
and 
international  seaborne  trade  and 
maritime  passenger  services;  data 
providers at port calls 
Ship  masters  and  other  crew 
involved in reporting procedures 

Agents  and 
organising  or 
exchanges 
reporting for ships 

logistic  companies 
trade 
including  port  call 

facilitating 

Port authorities 

Public  or  private  bodies  that  own 
and/or manage the ports 

Maritime authorities 

Customs authorities 

Consumers 

or 

National 
authorities 
regulating and controlling maritime 
transport 

local 

Authorities 
controlling customs procedures  

regulating 

and 

Industries  or 
individual  citizens 
benefitting  from  the  availability 
and  prices  of  goods  delivered  by 
seaborne 
travelling  as 
passengers by sea 

trade  or 

121 

 
 
 
 
 
 
Annex 7: Connected policy areas 

Digital single market policy 

This  initiative  contributes  to  the  Commission  priority  of  establishing  a  connected  Digital 
Single  Market150.  The  Council  conclusions  on  digitalisation  from  5  December  2017, 
emphasising  the  importance  of  interoperability  and  harmonisation  of  interfaces  for  data 
exchange as an enabler for seamless and efficient cross-border multimodal transport services 
and  stressing  that  digitalisation  helps  reduce  the  administrative  burden  and  simplify 
procedures, creating a level playing field for all transport operators.  

Digitalisation  of  government  services  and  business-to-administration  interactions  is  a  key 
element  to  the  success  of  the  single  market,  helping  to  remove  existing  digital  barriers  and 
delivering efficiency benefits. The Communication on a European Strategy for Low-Emission 
Mobility151  highlights  that  digital  technologies  offer  significant  potential  for  optimising  the 
transport  system  and  open  up  new  opportunities  for  manufacturing  and  services.  Digital 
technologies also support the integration of transport with other systems, such as the energy 
system, and make the mobility sector more efficient.  

But to reap the full benefits of digitisation in the field of transport, it is necessary to create the 
regulatory  frameworks  to  incentivise  the  development  and  market  uptake  of  such 
technologies,  and  to  set  standards  to  ensure  interoperability,  including  across  borders,  and 
enable  data  exchange  while  at  the  same  time  addressing  data  protection  and  cyber-security 
issues.  

Automation  and  technical  development  in  ships  is  expected  to  have  an  impact  over  time, 
including  with  higher  uptake  of  automated  reporting  systems,  sensors  and  machine-to-
machine communications. Development of autonomous/un-manned vessels152 may challenge 
legal frameworks and technical progress on secure data sharing and data exchange aspects via 
e.g. block chains, cloud solutions or electronic IDs and e-certificates, can open opportunities 
but also raise new questions for the legislators. Aspects of data protection, cyber security and 

150 European Commission Communication, A Digital Single Market Strategy for Europe, COM(2015) 192 final, 

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015DC0192&from=EN  

151  European  Commission  Communication,  A  European  Strategy  for  Low-Emission  Mobility,  COM(2016)  501 

final,  

https://ec.europa.eu/transport/sites/transport/files/themes/strategies/news/doc/2016-07-20-
decarbonisation/com%282016%29501_en.pdf  
152 Horizon 2020: Smart, green and integrated transport, 

https://ec.europa.eu/programmes/horizon2020/en/h2020-section/smart-green-and-integrated-transport 

122 

 
 
                                                            
 
data privacy (technical developments, legal frameworks) are expected to continuously evolve. 
Cyber-crime,  IT  failure  or  data  breaches  (“cyber  incidents”)  are  an  increasing  concern  and 
were  listed  as  third  among  the  “10  Global  Business  Risks  for  2017”  by  a  recent  insurance 
company report153. 

A  more  harmonised  and  digital  reporting  environment  for  ships  is  considered  an  important 
contribution  towards  these  objectives.  The  establishment  of  the  “European  Maritime  Single 
Window  environment”  is  therefore  one  of  the  25  actions  listed  in  the  eGovernment  Action 
Plan 2016-2020154. This action plan aims to modernise public administration, to achieve the 
digital  internal  market,  and  to  engage  more  with  citizens  and  businesses  to  deliver  high 
quality services.  

Any proposal to extend digitalisation and especially the development of digital services will 
also take into account existing EU policy frameworks notably on the General Data Protection 
Regulation  (GDPR)  and  the  Regulation  on  electronic  identification  and  trust  services 
(eIDAS). 

Single market policy: boosting jobs, growth and investments 

The  establishment  of  a  simplified  regulatory  environment  can  also  have  significant  positive 
financial impact.155 

Businesses  suffer  both  direct  border-related  costs,  such  as  expenses  related  to  supplying 
information and documents to the relevant authority, and indirect costs, such as those arising 
from  procedural  delays  and  lost  business  opportunities.  Based  to  estimates156  by  the 
Organisation  for  Economic  Cooperation  and  Development  (OECD),  these  costs  may  range 
from 2% to 15% of the value of traded goods. 

Customs policy 

The Customs Union is an essential element in the functioning of the single market: ensuring 
common application  of common rules  and a common tariff at the Union’s  external borders. 

153 Allianz risk barometer: business risks 2017, 

http://www.agcs.allianz.com/assets/PDFs/Reports/Allianz_Risk_Barometer_2017_EN.pdf 

of 

government, 

154  European  Commission  Communication,  EU  eGovernment  Action  Plan  2016-2020,  Accelerating  the  digital 
transformation 
https://ec.europa.eu/digital-single-
market/en/news/communication-eu-egovernment-action-plan-2016-2020-accelerating-digital-transformation  
155 According to the World Bank study, about 30% ($107 billion) of the total gain from trade facilitation in 75 
analysed countries comes from the improvement in port efficiency and about $33 billion emanates from the 
improvement 
environment 
http://documents.worldbank.org/curated/en/977511468764990679/pdf/wps3224TRADE.pdf  

COM(2016) 

customs 

final, 

179 

in 

156 http://www.oecd.org/trade/facilitation/35459690.pdf  

123 

 
 
                                                            
 
Customs procedures and control methods are specified in the Union Customs Code157 which 
entered into force on 1 May 2016. The Union Customs Code puts emphasis on fully electronic 
communication  between  the  customs  administrations  and  economic  operators  and  between 
customs authorities in different Member States, in a paperless environment. The need of the 
data  harmonisation  for  the  exchange  of  information  has  brought  at  the  establishment  of  a 
Customs  Data  Model,  containing  a  data  set  encompassing  data  elements  and  definitions 
required  by  customs  authorities  throughout  the  EU.  Moreover,  in  order  to  introduce  a  full 
digital  environment  and  high  level  of  harmonisation  in  the  whole  customs  domain,  the 
existing national customs IT systems are being enhanced and adapted to the new requirements 
set  out  by  the  new  legislation,  while  at  the  same  time  a  number  of  centralised  EU-wide  IT 
systems are being developed and deployed by DG TAXUD. Safety and Security information 
has been enhanced, mainly through the improvement of data quality, enlarging the reporting 
to multiple parties along the logistic chain. For this specific purpose, a new centralised system 
is being developed, gathering all safety and security information, including that coming from 
the maritime transport. 

The  transport  and  customs  policy  areas  are  inseparable  and  must  be  developed  in  close 
coordination. Carriers need to report cargo information  to  both  port authorities and customs 
authorities  when  calling  at  an  EU  port.  The  complexity  and  the  number  of  cargo  reporting 
formalities  have  brought  to  a  considerable  administrative  burden  for  the  shipping  industry. 
Therefore, in early 2016, the eManifest pilot project was launched. The overall objective of 
the  project  is  to  test  the  possibility/practicability  of  submission  of  customs  entry/exit 
formalities  along  with  other  (maritime)  reporting  formalities  by  electronic  means  in  a 
harmonised  manner  with  assistance  of  the  Maritime  SW,  with  the  aim  to  reduce 
administrative  burden  for  ship  data  providers.  The  harmonised  eManifest  data  set  produced 
for the purposes of the pilot contains the data requirements set in the UCC DA and IA and in 
the IMO FAL Convention and is in line with the WCO Data Model, ensuring coherence and 
interoperability  between  maritime  and  customs  reporting.  The  coherence  between  customs 
and  maritime  reporting  represents  a  necessary  pre-condition  for  a  future  interoperability 
between  maritime  and  customs  electronic  systems,  adopting  the  technical  and  functional 
specifications set out by customs legislation. 

Social and environmental policy 

Finally,  a  more  efficient  maritime  transport  sector  is  closely  linked  to  the  social  and 
environmental policy contexts. 

157  Regulation  (EU)  No 952/2013,  laying  down  the  Union  Customs  Code,  9 October  2013,  http://eur-

lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32013R0952 

124 

 
 
                                                            
 
Having competent staff is essential for supporting the growth and prosperity of the maritime 
industry in Europe. The European maritime industry today suffers from an increasing lack of 
European  seafarers,  in  particular  officers.  In  line  with  the  Social  Agenda  for  Maritime 
Transport158,  the  Commission  therefore  strives  to  promote  the  attractiveness  of  maritime 
professions.  Reducing  and  removing  cumbersome  reporting  tasks  is  one  step  towards  this 
goal. 

The European Commission is working towards a form of mobility that is sustainable, energy-
efficient and respectful of the environment. The Transport White Paper calls for a modal shift 
towards rail and waterborne transports, especially for long-distance shipments159. For this, the 
maritime  transport  mode  attractiveness  must  be  optimised  by  e.g.  reliability,  efficiency  and 
low  operating  and  administrative  costs.  Supporting  trade  and  transport  facilitation  through 
simplification of the ship reporting environment is therefore aligned also with environmental 
policy. 

Research and innovation policy 

With  support  from  the  Horizon2020,  European  transport  research  contributes  to  finding 
solutions to the increasing mobility of people, with low-carbon technologies, clean vehicles, 
smart mobility systems and integrated services for passengers and freight. European research 
aims  to  strengthen  the  competitiveness  of  our  transport  industries  and  to  develop  a  better 
European transport system for the benefit of all. 

In the transport sector, research160 is at the core of developing new technologies for greener, 
smarter,  more  efficient  transport  means  and  innovative  solutions  for  safer,  more  sustainable 
and inclusive mobility. 

Statistics 

Maritime  transport  statistics  (MTS)  are  collected  by  the  EU  and  EFTA  Member  States 
according  to  the  Directive  2009/42/EC  and  transmitted  to  Eurostat  for  calculation  of  EU 
aggregates and dissemination. In addition, some MTS data are collected on a voluntary basis 
from Member States. The objective of this data collection is to compile harmonised statistics 
of the maritime component of European transport activity and to provide information on the 
carriage of goods and passengers by seagoing vessels calling at EU/EFTA ports as a basis for 
analysis, monitoring/evaluation and planning of European maritime transport. 

158 https://ec.europa.eu/transport/modes/maritime/seafarers_en  
159 European Commission, White paper: Roadmap to a Single European Transport Area, COM(2011) 144 final, 

p. 7, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0144&from=EN 
160 https://ec.europa.eu/programmes/horizon2020/en/h2020-section/smart-green-and-integrated-transport 

125 

 
 
                                                            
 
In order to comply with the requirements of the EU legal framework for provision of maritime 
statistics,  the  Member  States  today  use  various  non-harmonised  sources  for  collection  of 
maritime  transport  data  on  national  level.  These  data  requests  therefore  fall  under  the  RFD 
Part C data (national and local requirements; not mandatory to request via the National Single 
Windows).  

Inland waterways transport 

In inland waterways, a recently published EC financed study161 on Digital Inland Waterway 
Area (DINA) also underlined the administrative burden for barge operators for filing ship 
reports with the authorities and other mandatory declarations. Barge operators need to comply 
with relevant legislation. This includes both safety related legislation and other legislation 
(e.g. statistics).  

Barge operators indicate that they need to file the same data multiple times to comply with 
different aspects of legislation and dealing with different jurisdictions in cross-border 
operations. From the perspective of the authorities there are also high costs to verify 
compliance with legislation. There is a potential to make this process more effective and cost-
efficient by re-using data that is already there. 

Many maritime ports also have an inland port section increasing the administrative burden by 
having to comply with provisions for both the maritime and inland mode.  

Therefore, harmonisation and rationalisation would be very welcome for both economic 
operators and the administrative side. Ideally authorities should re-use data: from each other 
(e.g. data already filed with another) and from existing registrations (e.g. readily available 
business data made accessible for authorities under certain conditions). 

Currently, in inland waterways there is no overall framework for electronic reporting covering 
different purposes. 

Combined transport 

The Combined Transport Directive (92/1063/EC) is a support instrument encouraging the use 
multimodal transport of goods where the major part of transport is carried out by rail, inland 
waterways or maritime transport and is served by a short road leg in the beginning or end of 

161 Digital Inland Waterway Area, ISBN 978-92-79-76485-1 

https://ec.europa.eu/transport/sites/transport/files/studies/2017-10-dina.pdf  

126 

 
 
                                                            
 
 
the  transport  chain.  It  foresees  regulatory  and  fiscal  incentives  for  combined  transport 
operations with an aim to foster modal shift of freight transport.  

The 2016 evaluation of the Directive under the REFIT programme concluded that while the 
Directive continues to be relevant for achieving EU transport policy's objective as regards the 
reduction of these negative externalities, the effectiveness and the efficiency could be further 
improved  by  a  review  as  the  measures  are  the  definitions  are  too  complicated  and  the 
measures  partly  outdated.  Thus  the  Commission  adopted  a  proposal  for  amendment  on 
November 8th, 2017 simplifying the definition, improving the enforcement by clarifying the 
conditions of proof of eligibility and updating the economic incentives. 

E-documents for freight transport 

Transport documents are central to the freight transport operations. They need to accompany 
the cargo as it moves, recording signatures and keeping a paper trail of the logistics transfer. 
Moving from paper to electronic documents offers a large potential to improve the efficiency, 
reliability  and  cost-effectiveness  of  the  freight  transport  operations.  Transport  documents  in 
electronic format are currently used to different degrees in all transport sectors. However, and 
in  spite  of  several  initiatives  in  the  past  years  to  digitalise  transport  documents  in  each 
transport  mode,  the  percentage  of  operations  employing  electronic  documents  remains  in 
general  low.  This  is  particularly  the  case  for  multimodal  and  cross-border  transport 
operations, where electronic documents are least employed.  

The need for EU level intervention to support wider uptake of electronic transport documents 
for  freight  transport  in  all  transport  modes  has  been  first  emphasised  by  participants  in  the 
Digital  Transport  and  Logistics  Forum  (DTLF),  an  expert  group  formed  by  more  than  one 
hundred private and public stakeholder representatives. 

In May 2017, the Commission launched an impact assessment process to identify the barriers 
to the wider use of electronic means in information exchange linked to the transport of goods 
within  the  EU.  The  objective  is  to  eventually  enable  all  market  players  to  fully  exploit  the 
potential of digitalisation in the field of logistics. A legislative proposal is expected to be part 
of the third Mobility Package, planned to be adopted in the beginning of May 2018, together 
with the proposal for the review of the Reporting Formalities Directive (RFD). 

Vessel Traffic Monitoring and Information System and SafeSeaNet 

SafeSeaNet  is  a  vessel  traffic  monitoring  and  information  system,  established  in  order  to 
enhance maritime safety, port and maritime security, marine environment protection and the 
efficiency of maritime traffic and transport. 

It  has  been  set  up  as  a  network  for  maritime  data  exchange,  linking  together  maritime 
authorities  from  across  Europe.  It  enables  European  Union  Member  States,  Norway,  and 
Iceland, to provide and receive information on ships, ship movements, and hazardous cargoes. 

127 

 
 
The  network  includes  for  example  the  Automatic  Identification  System  (AIS)  information 
from ships. 

Progressively, more and information from and on ships is being centralised in the SafeSeaNet 
system. This means that, now and in the future, a growing number of different types of users 
are  being  given  the  opportunity  to  access  the  information  they  need  from  a  single  source, 
instead of using many different sources. This means that their work is made easier, and that 
they can operate more efficiently. 

128 

 
 
 
 
Annex 8: Trade and economic patterns 

Ports vary substantially both in size and specialisation. The 83 main seaports included in the 
TEN-T core network handle approximately 70% of the cargo passing through all EU seaports. 

2350000

2300000

2250000

2200000

2150000

2100000

2050000

2000000

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

Figure 15: Number of vessels calling EU ports in one year 2005-2015 (EU28)162 

Figure 16: Projected number of port calls 2015-2030 (developed from EU reference scenario 2016 and EuroStat data) 

162 Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-

explained/index.php/Maritime_ports_freight_and_passenger_statistics 

129 

0500,0001,000,0001,500,0002,000,0002,500,0002016201820202021202220232024202520262027202820292030Port calls / yearFixed routesNon scheculed/tram routes 
 
 
 
                                                            
 
Passengers, Goods, GDP  
 1995-2015  

145

140

135

130

125

120

115

110

105

100

0
0
1
=
5
9
9
1

199519961997199819992000200120022003200420052006200720082009201020112012201320142015

Passengers (1) (pkm)

Goods (2) (tkm)

GDP (at constant year 2005 prices)

Figure 17: Transport growth in EU28: passengers, goods and GDP163 

Of  the  goods  transported  via  the  main  EU  maritime  ports,  liquid  bulk  goods  accounted  for 
38%  of  the  total  cargo;  dry  bulk  goods  for  23%,  containerised  goods  for  21%  and  goods 
transported on roll-on, roll-off (Ro-Ro) mobile units made up 12 %.164 

Technical developments constantly change the capacity and composition of the EU fleet. One 
of  the  main  trends  today  is  the  move  towards  larger  vessels.  The  average  size  of  vessels 
calling  in  the  main  EU-28  ports  is  slowly  increasing  and  amounted  to  about  7  400  GT  in 
2015.165  Gigaliners,  autonomous  vessels  and  vessels  with  alternative  propulsion 
systems/alternative fuels are being developed. 

While  the  road  transport  share  of  goods  traffic  in  the  EU  steadily  increases,  the  maritime 
transport  modal  share  has  slightly  decreased  over  time,  although  now  somewhat  recovering 
since the dip in 2007-2009. 166 

163 European Commission, Statistical pocketbook 2017: EU transport in figures, 
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en 

164 Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-

explained/index.php/Maritime_ports_freight_and_passenger_statistics 

165 Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-

explained/index.php/Maritime_ports_freight_and_passenger_statistics 
166 European Commission, Statistical pocketbook 2017: EU transport in figures,  
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en  

130 

 
 
 
 
                                                            
 
 
60

50

40

30

20

10

0

Road

Rail

IWW

Pipelines

Maritime

Air

1995

2000

2005

2010

2015

Figure 18: Modal split over time in EU28 (goods transports, single market)167 

70

60

50

40

30

20

10

0

Passengers, excluding
cruise passengers (%)

Goods (% of tonnes)

International trade 

In  2015,  3.1  billion  tonnes  of  goods  were  shipped  by  sea  to  or  from  EU  ports.  This  was  an 
increase  by  1.6 %  from  2014.  63%  of  these  goods  were  international  transports.  Maritime 

167 European Commission, Statistical pocketbook 2017: EU transport in figures,  
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en  

131 

 
 
 
 
 
                                                            
 
transport is the most important mode for long distance transport of goods to or from the EU, in 
tonnage terms. 168 

EU  trade  exports  to  a  value  of  860  billion  EUR  were  transported  by  sea  in  2015.  Seaborne 
imports amounted to a value of 920 billion EUR in the same year. 169  

(% of trade based on value) 
EU28 

Imports 
53.0 

Exports 
48.1 

Total trade 
50.5 

Table 8: EU Member States trade in goods with non-EU countries carried by sea, 2015170 

Intra-EU traffic and short-sea shipping 

The transport operators in intra-EU traffic and short-sea shipping are the ones most affected 
by  the  lack  of  harmonisation  at  EU  level,  together  with  ships  in  international  traffic  calling 
several different ports in the EU.  

Maritime  transport  accounted  for  31.6%  of  all  single  market  goods  transports  in  2015.  For 
passenger transports within the single market, maritime mode accounted for 9.8%.  

According to Eurostat, 25% of the approximately 3.8 billion yearly tonnes of seaborne goods 
and  33%  of the 395  million passengers going  in or  out of EU ports are shipped in  intra-EU 
traffic.171 Estonia, Ireland, Latvia, Malta, Finland and Sweden have especially high shares of 
international  intra-EU  transport  (above  60  %  of  all  transported  goods  in  tonnes).  172  Larger 
ports tend to have a larger deep sea and transhipment function compared to smaller ports who 
tend to have a larger share in short sea transport.173 

Short-sea shipping is the transport of goods between main ports in the EU-28 member states 
and ports situated in geographical Europe or in non-European countries on the Mediterranean 
and  the  Black  Sea.  1.8  billion  tonnes  of  goods  were  transported  as  part  of  EU  short  sea 
shipping  in  2015,  an  increase  of  0.9  %  from  the  previous year.  Short  sea  shipping  made  up 

168 Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-

169 

explained/index.php/Maritime_ports_freight_and_passenger_statistics 
2017: 

Statistical 
https://ec.europa.eu/transport/facts-fundings/statistics/pocketbook-2017_en  

Commission, 

pocketbook 

European 

EU 

transport 

in 

figures, 

170 Eurostat Newsrelease 184/2016: World Maritime Day, 
http://ec.europa.eu/eurostat/documents/2995521/7667714/6-28092016-AP-EN.pdf, 28 September 2016 
171 Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-

explained/index.php/Maritime_ports_freight_and_passenger_statistics  

172 Eurostat, Maritime ports freight and passenger statistics, January 2017, http://ec.europa.eu/eurostat/statistics-

explained/index.php/Maritime_ports_freight_and_passenger_statistics 

173 DRAFT: Study on support measures for the implementation of the TEN-T core network related to sea ports, 
inland ports and inland waterway transport: Analysis of major geopolitical and technological developments 
affecting the future development of the EU seaport system, p. 34 of the draft study; update reference with 
D3 for final text 

132 

 
 
                                                            
 
close to 59 % of the total maritime transport of goods to and from the main EU ports in 2015, 
about the same as in 2014.  

Hinterland connections: cross-modal links 

The smooth functioning of port calls is one link in a longer transport chain. Ports are not the 
final  destination  of  goods.  The  efficiency  of  the  ship  port  calls  will  impact  on  the  entire 
logistics  chain  and  the  hinterland  transports  of  goods  and  passengers  to  and  from  the  ports. 
Depending  on  the  nature  and  volume  of  the  goods  and  on  the  distance  the  cargo  should  be 
transported,  transports  per  road,  rail,  pipeline  or  inland  waterways  connect  to  the  maritime 
transports. The shares of each transport mode vary significantly from port to port depending 
on geographical and other specificities. 

Road transport provides, overall, the largest share of throughput transport to and from ports. 
Road is the preferred mode for smaller volumes of cargo or shorter distances. It provides high 
flexibility and door-to-door transport possibility. 

Rail is a preferred mode for goods on regular/frequent services and for long-distance transport 
of e.g. dry bulk or containers. 

A  large  share  of  ports  have  inland  waterway  connectivity,  especially  in  the  North  Sea  and 
Black  Sea  basins.  All  ports  in  Belgium  and  the  Netherlands  are  connected  to  the  Rhine-
Scheldt delta. In the Black Sea area, the Romanian ports are connected by the Danube. The 
low  cost  and  high  capacity  makes  inland  waterways,  where  available,  a  preferred  mode 
especially for container transports. European container traffic on inland waterways is highly 
driven by the three largest European ports: Rotterdam, Antwerp and Hamburg. 

For oil and gas, pipelines are mostly used, especially for short distances. 4.8% of all tonne-
kilometres of transport go by pipeline. 

133 

 
 
Figure 10-19: 

Modal Split share in selected Seaports (Overall Throughput in 2013)174 

174 European Parliament; Directorate General for Internal Policies, Modal share of freight transports to and from 
p.38, 

EU 
http://www.europarl.europa.eu/RegData/etudes/STUD/2015/540350/IPOL_STU(2015)540350_EN.pdf 

ports, 

2015, 

134