Study supporting the evaluation of Directive 2005/44/EC on Harmonised River Information Services (RIS) : final report.
Date: 2020-04-14
Institutions: Directorate-General for Mobility and Transport
Subjects: cross-border cooperation, directive (EU), exchange of information, harmonisation of standards, inland waterway shipping, network of navigable waterways, pollution control, transport safety

Study supporting the 
evaluation of Directive 
2005/44/EC on Harmonised 
River Information Services 
(RIS) 

Final Report 

Vanessa Ludden, Dr. Karolina Wrona, Lara Jansen, Elisa Colaiacomo (Ramboll) 
Dr. Edwin Verberght, Prof. Thierry Vanelslander, Prof. Edwin van Hassel (University of Antwerp) 
Linus Hoet (DLA Piper) 

January – 2020 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Mobility and Transport 
Directorate D Waterborne  
Unit D3 — Ports and Inland Navigation 

Contact: Mario Sattler 

E-mail:  MOVE-D3-SECRETARIAT@ec.europa.eu 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Study supporting the 
evaluation of Directive 
2005/44/EC on Harmonised 
River Information Services 
(RIS)  

Final Report 

Directorate-General for Mobility and Transport  
Waterborne – Ports and Inland Navigation 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Europe Direct is a service to help you find answers  
to your questions about the European Union. 
Freephone number (*): 
00 800 6 7 8 9 10 11 

(*) 

The information given is free, as are most calls (though some operators, phone 

boxes or hotels may charge you). 

LEGAL NOTICE 

The information and views set out in this study are those of the authors and do not necessarily reflect the 

official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this 

study. Neither the Commission nor any person acting on the Commission’s behalf can be held responsible for 

the use which may be made of the information contained therein.  

More information on the European Union is available on the Internet (http://www.europa.eu). 

Luxembourg: Publications Office of the European Union, 2020 

ISBN 978-92-76-16283-4 
doi: 10.2832/541263 

© European Union, 2020 

Reproduction is authorised provided the source is acknowledged. 

iv 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Table of Contents 

ABSTRACT ...................................................................................................... X 

EXECUTIVE SUMMARY ..................................................................................... XI 

Objectives and scope of the study ............................................................... xi 
Overview of Methodology ........................................................................... xi 
Key findings, conclusions and recommendations .......................................... xii 
Effectiveness ................................................................................... xii 
Efficiency ....................................................................................... xiv 
Relevance ....................................................................................... xv 
Coherence ..................................................................................... xvi 
EU added value ............................................................................. xvii 

RÉSUMÉ .................................................................................................... XVIII 

NOTE DE SYNTHÈSE ..................................................................................... XIX 

Objectifs et portée de l’étude ................................................................... xix 
Aperçu de la méthodologie ....................................................................... xix 
Principales constatations, conclusions et recommandations ........................... xx 
Efficacité ........................................................................................ xx 
Efficience ...................................................................................... xxii 
Pertinence ....................................................................................xxiv 
Cohérence .................................................................................... xxv 
Valeur ajoutée européenne ............................................................. xxv 

KURZBESCHREIBUNG ................................................................................ XXVII 

ZUSAMMENFASSUNG ................................................................................ XXVIII 

Ziele und Umfang der Studie ................................................................. xxviii 
Überblick über die Methodik .................................................................. xxviii 
Die wichtigsten Ergebnisse, Schlussfolgerungen und Empfehlungen .............xxix 
Wirksamkeit ..................................................................................xxix 
Effizienz .......................................................................................xxxi 
Relevanz .................................................................................... xxxiii 
Kohärenz .................................................................................... xxxiv 
EU-Mehrwert ................................................................................ xxxv 

1.  CONTEXT ................................................................................................. 1 

1.1.  Objectives and scope of the study ...................................................... 1 
1.2.  The RIS Directive ............................................................................. 2 
1.2.1.  Implementing acts ................................................................. 2 
1.2.2.  The RIS waterway network ..................................................... 3 
1.2.3.  Institutional framework .......................................................... 4 
1.2.4.  Previous assessment of implementation .................................... 5 
1.2.5.  Evaluation baseline ................................................................ 6 

2.  METHODOLOGY ........................................................................................ 9 

2.1.  Stakeholder consultation activities ...................................................... 9 
2.1.1.  Targeted questionnaires ........................................................ 10 
2.1.2.  Interviews ............................................................................ 10 

v 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

2.1.3.  Study visit to a RIS Centre ..................................................... 11 
2.1.4.  Workshops and events........................................................... 11 
2.1.5.  Open Public Consultation ....................................................... 12 

3.  ANSWERS TO THE EVALUATION QUESTIONS .............................................. 13 

3.1.  Effectiveness ................................................................................... 13 
3.1.1.  Availability and benefits of RIS technologies ............................. 13 
Data for navigation and planning ............................................ 13 
A. 
Electronic Navigational Charts (ENC) ....................................... 20 
B. 
C. 
Notices to Skippers (NtS) ....................................................... 28 
3.1.2.  Electronic ship reporting ........................................................ 37 
3.1.3.  Type-approval of RIS equipment ............................................. 43 
3.1.4.  Establishment of a harmonised, interoperable RIS .................... 47 
3.1.5.  Unintended positive effects .................................................... 48 
3.1.6.  Achievement of general objectives .......................................... 50 
Increased competitiveness ..................................................... 52 
A. 
Optimised use of infrastructure ............................................... 53 
B. 
Improved safety and security ................................................. 54 
C. 
Increased environmental protection ........................................ 55 
D. 
3.2.  Efficiency ........................................................................................ 57 
3.2.1.  Preparation of the relevant Regulations ................................... 57 
Costs and negative impacts of RIS technologies .................................. 58 
Data for navigation and planning ............................................ 58 
A. 
B. 
Electronic Navigational Charts (ENC) ....................................... 61 
Notices to Skippers (NtS) ....................................................... 64 
C. 
3.2.2.  Electronic ship reporting ........................................................ 68 
3.2.3.  Type-approval of RIS equipment ............................................. 70 
3.2.4.  Establishment of a harmonised, interoperable RIS .................... 72 
3.2.5.  Unintended negative effects ................................................... 73 
3.2.6.  Simplification and reduction of regulatory burden ..................... 74 
3.2.7.  Costs and negative impacts at the level of general objectives ..... 77 
3.3.  Relevance ....................................................................................... 78 
3.3.1.  Continued relevance of RIS Directive objectives ........................ 78 
3.4.  Coherence ...................................................................................... 82 

3.4.1.  Internal coherence of the RIS Directive and its Implementing Acts

 .......................................................................................... 82 

3.4.2.  External  coherence  of  the  RIS  Directive  with  the  relevant 

international obligations of the Member States ......................... 83 
3.4.3.  External coherence of RIS Directive with other EU legislation ..... 85 
3.5.  EU added value ............................................................................... 88 
3.5.1.  Rationale of the RIS Directive ................................................. 88 
3.5.2.  EU added value of the RIS Directive ........................................ 89 

4.  CONCLUSIONS AND RECOMMENDATIONS ................................................... 92 

4.1.  Effectiveness ................................................................................... 92 
4.2.  Efficiency ........................................................................................ 94 
4.3.  Relevance ....................................................................................... 95 
4.4.  Coherence ...................................................................................... 96 
4.5.  EU added value ............................................................................... 96 

vi 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Please note that this report is accompanied by a separate document containing Technical 
Annexes, as follows: 

  Technical Annex 1: Evaluation Questions Matrix 

  Technical Annex 2: Assessment of Implementation  

  Technical Annex 3: List of Consulted Documentary Sources 

  Technical Annex 4: List of Consulted Stakeholders  

  Technical Annex 5: Econometric Modelling  

  Technical Annex 6: Ex-post Social Cost-Benefit Analysis   

  Technical Annex 7. References and literature sources  

The  report  is  also  accompanied  by  a  separate  Stakeholder  Consultation  Report 
containing the following sections: 

  1. Introduction 

  2. Consultation Coverage and Response Rate  

  3. Integration of Consultation Results into Answers to Evaluation Questions  

  4. Discussion on and Comparison of Consultations Results 

  Annex 1: Findings from the Survey Questionnaires  

  Annex 2: Findings from the Interviews  

  Annex 3: Findings from the Open Public Consultation  

  Annex 4: Findings from the Events Attended  

vii 

 
 
 
 
 
 
 
 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Abbreviations and Acronyms 

AIS 

BICS 

CBA 

CCNR 

CEMT 

CESNI 

Automatic Identification System 

Barge Information and Communication System 

Cost-benefit analysis 

Central Commission for the Navigation of the Rhine 

European Conference of Ministers of Transport 

European committee for drawing up standards in the field of inland 
navigation – Comité Européen pour l’Élaboration de Standards dans 
le Domaine de Navigation Intérieure 

DG MOVE 

Directorate General for Mobility and Transport 

DINA 

Digital Inland Waterway Area 

ECDIS 

Electronic chart display and information system for inland navigation 

ECM 

EG(s) 

ENC 

Error correction models 

Expert Group(s) 

Electronic Navigational Chart  

ERDMS 

European Reference Data Management System 

ERINOT 

ERI NOTification message 

ERIRSP 

ERI ReSPonse message 

ERI 

ETA 

EU 

FIS  

FTM 

GDP 

Electronic Reporting in inland navigation 

Estimated Time of Arrival  

European Union  

Fairway Information Services  

Fairway conditions and traffic messages (NtS) 

Gross Domestic Product  

GDPR 

General Data Protection Regulation 

GPS 

ICEM 

IEHG 

IWT 

NtS 

OPC 

Global Positioning System 

Ice messages (NtS)  

Inland ENC Harmonisation Group 

Inland Waterway Transport 

Notices to Skippers 

Open Public Consultation  

PAXLST 

Passenger List Message 

PIANC 

The World Association for Waterborne Transport Infrastructure 

RIS 

River Information Services 

RIS COMEX   RIS Corridor Management Execution 

SCBA 

Social cost-benefit analysis 

SWINg 

Single Window Inland Navigation 

UNECE 

United Nations Economic Commission for Europe 

viii 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

VHF 

VTS 

VTT 

Very High Frequency  

Vessel Traffic Services 

Vessel Tracking and Tracing 

WERM 

Weather-related messages (NtS) 

WRM 

WSDL 

XML  

Water level messages (NtS) 

Web Service Definition Language 

Extensible Mark-up Language  

ix 

 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

ABSTRACT 

The European Commission is undertaking an evaluation of the River Information Services 
(RIS)  Directive  2005/44/EC.  This  study,  by  Ramboll  Management  Consulting  and  the 
University of Antwerp, presents an analytically robust ex-post assessment of the Directive. 
It forms part of the evidence base of the Commission’s evaluation. The study has looked 
into  the  Directive’s  actual  effectiveness,  efficiency,  coherence,  relevance  and  EU  added 
value, covering the period of 2005 to 2018 and the countries to which it applied.  

Qualitative  and  some  quantitative  results  show  that  the  RIS  Directive  has  been  largely 
successful  in  introducing  common  technical  standards  and  encouraging  cross-border 
cooperation, although some key challenges around the quality of the provided services and 
the  speed  of  revision  and  provision  of  technical  specifications  and  their  regulation 
remain.  There are indications that the Directive has at least in part had a positive impact 
on  establishing  harmonised  and  interoperable  RIS  whilst  costs  associated  with  the  RIS 
Directive seem to be proportionate to the benefits achieved.  

Evidence  is  mixed  with  respect  to  the  Directive’s  contribution  to  the  achievement  of  its 
general  objectives  (increasing  the  competitiveness,  the  use  of  existing  infrastructure, 
safety and security and the environmental friendliness of the inland navigation sector). No 
statistically significant effect on sectoral growth could be found. A robust attribution of an 
observed decrease in fuel consumption to the Directive has not been possible. Despite the 
absence of reliable accident data, however, a clear positive effect on perceived safety could 
be established. 

x 

 
 
 
 
 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

EXECUTIVE SUMMARY 

OBJECTIVES AND SCOPE OF THE STUDY 

The European Commission is undertaking an ex-post evaluation of the River Information 
Services (RIS) Directive (Directive 2005/44/EC)1.  

This evaluation support study provides the Commission with an analytically robust ex-post 
evaluation  of  the  Directive  as  an  evidence  base;  it  follows  the  Commission's  Better 
Regulation Guidelines and Toolboxes. Accordingly, the analysis was structured around the 
evaluation criteria of effectiveness, efficiency, relevance, coherence and EU added value. 
In the next step the evidence provided by this study (and other sources) might be used 
to:  

  Evaluate progress in meeting the objectives of the Directive and assess whether the 

Directive has generated actual benefits;  

  Assess  the  costs  associated  with  the  Directive  and  whether  the  cost  has  been 

proportionate to the benefits achieved;  

  Establish  whether  the  objectives  of  the  Directive  remain  relevant  for  the  inland 

navigation sector given recent developments;  

  Assess whether the Directive is internally coherent and in line with other relevant 

legislation; and 

  Assess whether the EU level intervention in RIS has added value to EU society over 
and above what could have been achieved in its absence through Member State or 
river-specific initiatives. 

This study built upon previous work undertaken in the context of Directive 2005/44/EC, 
particularly the results of the 2018 fact-finding study, the evaluation carried out in 2014 
covering the years 2006-2011, and other relevant studies.  

The period of analysis of this study spanned the years 2005-2018. 

The geographical scope encompassed all EU Member States that are part of the European 
network  of  waterways  of  class  IV  or  above.  This  includes:  Austria,  Belgium,  Bulgaria, 
Croatia,  Czechia,  France,  Germany,  Hungary,  Luxembourg,  the  Netherlands,  Poland, 
Romania  and  Slovakia.  The  study  also  covered  other  countries  that  applied  the  RIS 
Directive in line with Article 2(2) of the Directive (namely: Serbia, Moldova, Ukraine, Italy, 
Spain, Switzerland and Portugal) where relevant and appropriate. 

OVERVIEW OF METHODOLOGY 

The used methodology was based on: 

  Desk research and analysis of information, which formed the basis of the study and 

informed the assessment of the current state of implementation;  

  Stakeholder  consultation  via  questionnaires,  interviews,  workshops  and  an  open 
public  consultation  across  all  relevant  Member  States  to  supplement  secondary 
evidence with views and opinions from stakeholders; and  

 

In-depth  analysis  of  the  primary  and  secondary  data  collected,  including  an 
assessment  of  the  state  of  implementation,  econometric  modelling,  and  a  social 
cost-benefit analysis.  

1 The five Implementing Acts did not form part of the scope of this assignment, in that they were not analysed 
one by one, but rather were taken into account in an assessment of how they have contributed as a whole to 
the overall achievement of the objectives of the RIS Directive. 

xi 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

KEY FINDINGS, CONCLUSIONS AND RECOMMENDATIONS 

Effectiveness  

As set out in Article 4(3) of the RIS Directive, in order to set up RIS, Member States shall: 

(a) supply to RIS users all relevant data concerning navigation and voyage planning 
on inland waterways;  

(b)  ensure  that  for  all  their  inland  waterways  of  class  V  and  above,  electronic 
navigational charts suitable for navigational purposes are available to RIS users; 

(c)  enable  the  competent  authorities  to  receive  electronic  ship  reports  of  the 
required data from ships;  

(d) ensure that  notices  to skippers, including water level (or maximum allowable 
draught) and ice reports of their inland waterways, are provided as standardised, 
encoded and downloadable messages.  

Furthermore, in order to support RIS and to ensure the interoperability of these services, 
the  Commission  defined  technical  guidelines  for  the  planning,  implementation  and 
operational  use  of  the  services  (RIS  guidelines),  as  well  as  technical  specifications  for 
vessel  tracking  and  tracing,  electronic  chart  display  and  information  systems  for  inland 
navigation,  electronic  ship  reporting,  and  notices  to  skippers.  These  RIS  guidelines  and 
technical specifications have been adopted as Implementing Acts. Although they did not 
fall within the scope of the present assignment in their own right, they were nevertheless 
taken into account in an assessment of how they have contributed as a whole to the overall 
achievement of the objectives of the RIS Directive.  

As far as could be established by this study, all relevant Member States complied fully with 
the  minimum  requirements  for  the  provision  of  data  for  navigation  and  voyage 
planning outlined in Annex I to the RIS Directive. However, the data provided is not fully 
harmonised across Member States due to the lack of harmonised, reinforced guidelines or 
legislation  on  detailed  data  requirements.  This  is,  at  least  partially,  explained  by  the 
voluntary  nature  and  complexity  of  some  provisions  included  in  the  RIS  Directive:  the 
minimum data to be provided as per Annex I of the Directive provides limited detail, and 
there is no additional EU legislation on this matter. As a result, the benefits brought about 
by the standardisation of data for navigation and planning have not fully materialised. The 
data  already  provided  are  nevertheless  considered  useful  for  waterway  users  to  make 
informed navigational decisions.  

Electronic navigational charts are made available in all relevant Member States at least 
to some extent. However, not all waterways of CEMT class V and above are fully covered, 
and there are differences between countries in the quality and accuracy of the charts. Not 
all charts are up-to-date as the RIS Directive and its Implementing Acts do not prescribe 
the frequency of revision and provision. Despite there being room for improvement in terms 
of quality and frequency, the availability of electronic navigational charts is considered by 
waterway  users  as  a  useful  and  beneficial  result  of  the  RIS  Directive,  supporting  the 
effective and safe navigation of inland waterways 

All  relevant  Member  States  provide  mandatory  standardised  notices  to  skippers 
(containing information on FTM, WRM, ICEM) on waterways of class IV and above, although 
coverage of relevant waterways is below 100% in three Member States. In addition, not 
all  Member  States  fully  comply  by  providing  notices  in  an  encoded  and  downloadable 
format – some use extensive free text that causes problems for interoperability between 
countries and for translation. The RIS Directive is nevertheless perceived by users of the 
waterways  to  have  improved  the  situation  through  the  standardisation  of  notices  to 
skippers,  which  are  considered  to  have  improved  voyage  planning  and  safety  in  inland 
navigation. 

xii 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Evidence  strongly  suggests  that  there  has  not  been  a  reduction  in  resubmissions  of 
electronic  ship  reports  when  crossing  a  border,  as  there  is  limited  data  exchange 
between authorities in different Member States. Hindering factors include concerns about 
data  privacy,  as  well  as  different  legal  requirements  in  the  Member  States.  The  RIS 
Directive  mandates  Member  States,  as  far  as  ship  reporting  is  required  by  national  or 
international  regulations,  to  enable  the  competent  authorities  to  receive  electronic  ship 
reports of the required data from ships. In cross-border transport, this information shall 
be  transmitted  to  the  competent  authorities  of  the  neighbouring  State  and  any  such 
transmission  shall  be  completed  before  arrival  of  the  vessels  at  the  border.  The  RIS 
Directive  does  not  specify  the  information  in  those  reports,  nor  does  it  mandate  ship 
reporting  as  such.  As  a  result,  not  all  the  information  in  the  electronic  ship  reports  is 
supported in all relevant Member States and reports are not automatically shared, requiring 
waterway  users  to  submit  information  more  than  once  on  an  international  voyage. 
Consequently, none of the expected associated cost savings for the users of the waterways 
and  RIS  authorities  have  materialised.  The  finding  suggests  future  policy  analysis  could 
look  into  concrete  ways  to  address  this  ineffectiveness.  A  further  harmonisation  of 
electronic reporting requirements should be considered as an option.  

All  type-approvals  of  Inland  ECDIS  viewers  in  navigation  mode  and  Inland  AIS 
transponders  in  the  European  Union  are  carried  out  by  one  German  authority2    and  are 
recognised in all other Member States. This concentration – as such not prescribed by the 
Directive - leads to a consistent quality and interoperability of equipment across Europe, 
and reportedly saves other authorities time and money that would otherwise have been 
spent on approving equipment in their own countries. It is unclear whether these efficiency 
savings are directly attributable to the RIS Directive per se: a few consulted stakeholders 
argued that Member States would accept the type-approvals carried out by other Member 
State authorities regardless of whether or not this was required by the Directive.  

Overall, the RIS Directive has been found to have contributed to the establishment of a 
harmonised, interoperable RIS in the EU, but not to a full extent. Although an increased 
degree of harmonisation is one of the main benefits brought about by the Directive, there 
are  still  discrepancies  between  countries  and  river  corridors.  RIS  technologies  are  not 
utilised to the same extent in all countries. A current lack of cooperation and collaboration 
between countries and river corridors would have to be overcome to level out the playing 
field between the traditionally more advanced riparian states in the Rhine region, and those 
that started at a lesser level of development in the Danube region.   

There is no strong, reliable evidence to conclude that the RIS Directive has brought about 
unintended positive effects, although there are indications that it led to the creation of 
new  opportunities  in  the  context  of  market  developments  (e.g.  autonomous  sailing),  as 
well as the creation of new work places, amongst others in informatics 

With regards to the achievement of its general objectives, evidence is mixed. There is 
no statistically significant evidence that the RIS Directive had an impact on the growth 
of  the  inland  navigation  sector  or  led  to  the  optimised  use  of  existing 
infrastructure.  There  are  indications  that  it  has  promoted  environmental  protection 
through  a  decrease  in  fuel  consumption,  although  the  degree  to  which  this  is  fully 
attributable  to  the  RIS  Directive  is  difficult  to  measure.  Despite  the  absence  of  reliable 
accident  data,  there  is  a  clear  perception  among  all  stakeholder  groups  that  the  RIS 
Directive has contributed to improved safety in inland navigation. 

Main conclusions and recommendations  

  All key RIS technologies (for which the Directive and its Implementing Acts include 
technical standards and guidelines) have been implemented in all relevant Member 
States. There are still some differences in the degree to which they conform to the 
standards prescribed, and clearer guidelines would be welcomed by the sector as a 
whole.  

2 Wasser- und Schifffahrtsverwaltung des Bundes Fachstelle der WSV für Verkehrstechniken (FVT 

xiii 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

 

It  is  recommended  that  the  Commission  consider  clarifying  guidelines  on  the 
relevant data for navigation and planning to be collected and reported upon, as this 
could  help  harmonise  approaches  and  further  level  out  the  playing  field  across 
Member States and river corridors.  

  The  RIS  Directive  has  been  largely  successful  in  achieving  its  overall  aim  of 
establishing a harmonised, interoperable RIS by introducing a mandatory provision 
of data in electronic format and shared technical standards and encouraging cross-
border  cooperation.  A  few  challenges,  notably  the  speed  of  revision  of  these 
technical standards and their regulation, as well as the abovementioned lack of clear 
guidance, hinder the full achievement of this goal.  

  Evidence is mixed with respect to the Directive’s contribution to the achievement of 
its  general  objectives  (increasing  the  competitiveness,  the  use  of  existing 
infrastructure, safety and security and the environmental friendliness of the inland 
navigation  sector).  No  statistically  significant  effect  on  sectoral  growth  could  be 
found.  A  robust  attribution  of  an  observed  decrease  in  fuel  consumption  to  the 
Directive  has  not  been  possible.  Despite  the  absence  of  reliable  accident  data, 
however, a clear positive effect on perceived safety could be established.  

Efficiency 

The  Commission  incurred  costs  associated  with  the  preparation  of  the  RIS  Directive 
and associated Implementing Acts, but there is no indication that the costs incurred 
were  disproportionate  to  the  achieved  outcome.  There  are,  however,  concerns  among 
national authorities that the speed with which technical standards are adopted across the 
EU creates a regulatory burden, as technology is constantly evolving, and the technical 
requirements need to keep up to remain relevant. 

Most costs to make RIS technologies available are borne by RIS authorities, whereas 
most  benefits  are  reaped  by  RIS  users.  Authorities  incur  significant  costs  for  making 
available  data  for  navigation  and  planning,  electronic  navigational  charts  and  notices  to 
skippers, though they do not consider these costs to be disproportionately high compared 
to the benefits they bring to the sector as a whole.  

Users of the waterways incur very limited costs in relation to the key RIS technologies. 
Data  for  navigation  and  planning  and  notices  to  skippers  are  provided  free  of  charge. 
Moreover,  the  hard-  and  software  investment  costs  needed  to  make  use  of  electronic 
navigational charts on board are marginal compared to the cost of the vessel, and in many 
cases  such  investment  costs  have  been  subsidised.  Overall,  RIS  technologies  are 
considered useful and therefore the costs associated with the RIS Directive in this regard 
are judged to be outweighed by the benefits.  

It is unclear whether the RIS Directive has led to any changes in costs associated with 
electronic  ship  reporting,  because  it  does  not  mandate  reporting  as  such  but  just 
mandates certain requirements related to the format of the reports. As there are limits to 
data  exchange  and  sharing  of  electronic  reports,  it  is  unlikely  that  costs  have  changed 
considerably,  either  for  authorities  or  users  of  the  waterways.  There  are  indications, 
however, that further harmonisation of electronic ship reporting could reduce the time and 
money  spent  by  users  that  is  currently  associated  with  re-submissions  of  reports  when 
crossing a border. Nevertheless, this may not be something the RIS Directive can solve, 
as the fragmentation is caused by variance in national police regulations.  

Despite  the  lack  of  concrete  cost  data,  the  fact  that  all  type  approvals  for  RIS 
equipment in the EU are carried out by one organisation and mutually recognised across 
all Member States, implies that all other Member States are saving time and money that 
would otherwise be spent on carrying out their own approvals.  It is, however, not clear 
whether this is directly attributable to the RIS Directive or whether this would have been 
the case regardless.  

xiv 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Overall,  although  the  costs  of  RIS  implementation  incurred  by  RIS  authorities  and 
inland  waterway  users  have  not  been  aggregated  to  the  level  of  the  RIS  Directive  as  a 
whole, we have found no indications that the overall costs outweigh the overall benefits.  

No strong evidence has been found that suggests the RIS Directive has brought about any 
unintended negative economic, social or environmental effects.  

There are no disproportionate administrative costs for RIS authorities nor for waterway 
users.  However,  in  both  instances  there  is  still  a  potential  to  further  reduce  the 
administrative  burden  associated  with  day-to-day  operations,  notably  through  further 
harmonisation of electronic ship reporting to maximise efficiency of data exchange between 
authorities and to avoid double reporting for users.  

It is difficult to draw conclusions on the costs incurred at the level of the achievement 
of the general objectives of the RIS Directive, because of a lack of reliable data at the 
level  of  outputs  (e.g.  accident  data  is  not  comparable  over  time  and  across  Member 
States), and because data cannot be granulated at the input level (i.e. costs of achieving 
these results). However, available quantitative data suggests that, since the adoption of 
the RIS Directive in 2005, the 13 relevant Member States have experienced an average 
annual  decrease  in  energy  consumption  of  inland  navigation  of  1.86%.  Based  on  the 
assumption that 40% of RIS users use their equipment for the purpose of fuel consumption 
reduction, it can be concluded that the RIS Directive has a positive return on investment 
in this regard. This conclusion holds as long as 12% or more vessels equipped with RIS 
technology use it for fuel consumption reduction.  

Main conclusions and recommendations 

  Although  a  lack  of  reliable  cost  data  does  not  allow  for  a  sufficiently  robust 
quantitative cost-benefit analysis, qualitative evidence suggests that the benefits of 
the RIS Directive likely outweigh the costs incurred. Costs are primarily borne by 
authorities, while the benefits are reaped by users of the waterways.  

  This is true for data for all key RIS technologies, except for electronic ship reporting, 
where an increase in harmonisation and data exchange could plausibly be expected 
to lead to further time and cost savings for users and authorities alike.  

  The  timeline  for  the  adoption  of  technical  standards  for  RIS  technologies  is 
considered by stakeholders to be too long to keep up with expected technological 
developments.  The  authors  of  this  study  note,  however,  that  the  recent 
establishment of the CESNI/TI working group in June 2019 may accelerate the rate 
of issuing new technical standards.  

 

It is recommended that the Commission continue its efforts to further harmonise 
RIS  in  Europe.  It  could  consider  ways  to  solve  the  different  interpretations  of 
technical standards and the lack of comparable data, e.g. the way in which water 
depth is measured and reported on throughout Europe.  

Relevance 

There  has  been  a  high  degree  of  alignment  between  the  objectives  laid  out  in  the 
Directive  and  the  needs  of  the  inland  waterway  transport  sector  throughout  the 
period  under  review.  However,  stakeholders  note  that  the  focus  has  shifted:  while  the 
Directive was established primarily with the issue of safety in mind, the sector now has a 
stronger need for improving efficiency in inland navigation and establishing stronger links 
with other modes of transport.  

New  needs  have  emerged  in  the  inland  navigation  sector  since  2005  that  are  not 
addressed by the current set of objectives and that would need to be considered to ensure 
that the RIS Directive remains relevant in the future. Most notable is the strong wave of 
digitalisation that introduced technological developments such as a move towards (semi)-
autonomous sailing. The increased awareness and utilisation of RIS has also prompted the 

xv 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

necessity to provide adequate training and education on the new tools and technologies 
used in the sector.  

Stakeholders agree that the RIS guidelines and technical standards imposed through the 
RIS  Implementing  Acts  are  relevant  and  necessary.  However,  they  perceive  the  slow 
process for updating them as a risk to their continued relevance in the future.   

Main conclusions and recommendations 

  The objectives set out in the RIS Directive were very much aligned with the needs 
of the sector at the time of the Directive’s publication, and continue to be relevant 
today.  In  recent  years,  a  strong  wave  of  digitalisation  has  brought  about 
technological developments that may need to be addressed to ensure the Directive 
remains relevant in the future.  

  The  slow  regulatory  process  required  for  the  development  and  adoption  of  new 
technical  specifications,  which  is  necessary  to  ensure  their  ongoing  relevance  in 
light of technological advancements, poses a risk to the future relevance of the RIS 
Directive.  

 

It 
is  recommended  that  the  Commission  considers  recent  technological 
developments if it decides to revisit and potentially adapt the RIS Directive. It could 
consider keeping the text ‘technology neutral’ to ensure it can adapt to technological 
developments quickly, and thereby avoid the Directive becoming redundant in the 
future.  

Coherence 

No internal inconsistencies have been found within the RIS Directive. The legal analysis 
and supporting stakeholder feedback suggest that the Directive and its Implementing Acts 
provide  a  coherent  framework  for  minimum  requirements  to  enable  cross-border 
compatibility of national systems.  

There is no evidence of incoherence between the RIS Directive and other pre-existing 
relevant international obligations of the Member States. All relevant related guidelines 
and recommendations (e.g. by PIANC, UNECE, River Commissions) have been drafted with 
the RIS Directive in mind and are thus fully coherent.   

The RIS Directive is coherent with other EU policy in inland waterway transport, such 
as the Professional Qualifications Directive and the Directive on technical requirements for 
inland waterway vessels.  

The Directive is also fully aligned with the goals laid out in the European White Paper on 
Transport and the Europe on the move initiative, underlining its coherence with wider EU 
transport legislation.  

No inconsistencies between the RIS Directive and other EU legislation in areas outside 
transport  policy  were  uncovered.  This  includes  the  Digital  Single  Market  and  e-
Government initiatives in relation to digitalisation and data protection rules.  

Main conclusions and recommendations 

  The RIS Directive is internally and externally coherent. There are no contradictions 
within  the  Directive,  nor  between  the  Directive  and  relevant  international 
obligations  of  the  Member  States;  EU  legislation  in  inland  waterway  transport 
policy; EU transport legislation; or other  EU legislation in areas outside transport 
policy.  

 

It  is  recommended  that,  in  case  of  any  possible  revisions  of  the  Directive,  the 
Commission  take  into  consideration  any  upcoming  legislation  in  and  beyond  the 
transport area. This will ensure that the Directive continues to be coherent with any 
policy developments after 2018, which is the cut-off point for the present study.  

xvi 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

EU added value 

The rationale for public intervention at the EU level is to be found in the cross-border, 
international  character  of  the  inland  waterway  transport  sector.  At  the  time  of  the 
Directive’s adoption, RIS was being developed at different rates throughout Europe, with 
different technologies and applications creating potential barriers to cross-border voyages. 
The  Directive  was  adopted  with  the  aim  to  harmonise  technologies  across  Europe  to 
enhance cross-border transport, and to minimise coordination costs.  

The RIS Directive is considered, by all different stakeholder groups, to be appropriate and 
justified, compared to what can reasonably be expected to have been achieved by 
interventions at national or regional level. Although similar benefits might have been 
achieved  by  River  Commissions,  they  would  likely  not  have  led  to  the  same  degree  of 
harmonisation and would likely have maintained fragmentation between different regions 
(i.e. Rhine and Danube countries).  

In terms of evidence on the Directive’s  actual EU added value, all stakeholder groups 
agree that the Directive has a strong EU added value. Most notable is the introduction of 
a  common  legal  base  as  a  basis  for  common  technical  standards,  which  led  to 
standardisation and harmonisation across Europe. Considering the different starting points 
of different countries, this supported the progress towards the creation of a level playing 
field and removed barriers to international voyages.  

EU-funded projects and resulting knowledge sharing has played a key role in this levelling 
out of the playing field, as RIS authorities and users in both regions believe they increased 
awareness  and  interest  in  the  inland  navigation  sector.  Although  difficult  to  prove,  they 
speculate that this would not have happened as quickly or efficiently without EU support.   

Main conclusions and recommendations 

  The  rationale  for  public  intervention  at  the  EU  level  is  based  on  the  cross-
border, international character of the inland waterway transport sector. An EU-level 
intervention for RIS is considered appropriate and justified by stakeholders given 
its  role  played  in  making  progress  towards  the  creation  of  a  level  playing  field 
between the traditionally more advanced countries and the less advanced countries.  

  One of the main driving forces behind actual progress towards a level playing field 
are EU funded projects. They helped to raise awareness about RIS and prompted 
countries to share knowledge and experiences, which in turn incentivised Member 
States to further invest in the inland navigation sector themselves (where they were 
not yet doing so before). 

xvii 

 
 
 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

RÉSUMÉ 

La Commission Européenne mène une évaluation de la Directive 2005/44/CE relative à des 
services d’information fluviale (SIF) harmonisés. La présente étude, dirigée par Ramboll 
Management Consulting et l’université d’Anvers, offre une évaluation ex post solide sur le 
plan  analytique  de  la  Directive.  Elle  constitue  une  partie  des  fondements  factuels  de 
l’évaluation de la Commission. L’étude porte  sur l’efficacité, l’efficience, la cohérence, la 
pertinence  et  la  valeur  ajoutée  européenne  réelles  de  la  Directive,  couvrant  la  période 
de 2005 à 2018 et les pays auxquels elle s’applique.  

Des  résultats  qualitatifs  et  certains  résultats  quantitatifs  indiquent  que  la  Directive  SIF 
s’avère  largement  efficace  en  ce  qui  concerne  l’introduction  de  normes  techniques 
communes  et  la  promotion  de  la  coopération  transfrontalière.  Toutefois,  certains  défis 
majeurs subsistent quant à la qualité des services fournis et à la vitesse de révision et de 
fourniture des spécifications techniques, ainsi qu’à leur réglementation. Il semblerait que 
la Directive ait eu un impact positif, au moins en partie, sur la création de SIF harmonisés 
et interopérables, tandis que les coûts liés à la Directive SIF apparaissent proportionnels 
aux avantages obtenus.  

Les  éléments  d’appréciation  sont  mitigés  quant  à  la  contribution  de  la  Directive  à  la 
réalisation de ses objectifs généraux (à savoir renforcer la compétitivité, l’utilisation des 
infrastructures existantes, la sûreté et la sécurité du secteur de la navigation intérieure, 
ainsi que le respect de l’environnement). Aucune incidence significative d'un point de vue 
statistique sur la croissance sectorielle n’a été constatée. En outre, il n’a pas été possible 
d’imputer  avec  certitude  à  la  Directive  la  baisse  de  la  consommation  de  carburant 
observée. Malgré l’absence de données fiables sur les accidents, un effet positif clair sur le 
sentiment de sécurité a pu être établi. 

xviii 

 
 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

NOTE DE SYNTHÈSE 

OBJECTIFS ET PORTÉE DE L’ÉTUDE 

La  Commission  Européenne  mène  une  évaluation  ex  post  de  la  Directive  relative  à  des 
services d’information fluviale (SIF) (Directive 2005/44/CE)3.  

La présente étude d'appui à l'évaluation fournit à la Commission une évaluation ex post, 
solide  sur  le  plan  analytique,  de  la  Directive  en  tant  que  base  factuelle.  Elle  suit   « les 
lignes directrices et la boîte à outils pour une meilleure réglementation » de la Commission. 
L’analyse  s'articule,  par  conséquent,  autour  des  critères  d’évaluation  de  l’efficacité, 
l’efficience,  la  pertinence,  la  cohérence  et  la  valeur  ajoutée  européenne.  Lors  de  la 
prochaine étape, les informations fournies par cette étude (et d’autres sources) pourraient 
servir à:  

  évaluer  les  progrès  enregistrés  en  vue  d’atteindre  les  objectifs  de  la  Directive  et 

déterminer si la Directive a entraîné de réels avantages;  

  estimer les coûts liés à la Directive et établir s’ils sont proportionnels aux avantages 

obtenus;  

  déterminer si les objectifs de la Directive demeurent pertinents pour le secteur de 

la navigation intérieure compte tenu des dernières évolutions;  

  évaluer si la Directive présente une cohérence interne et est conforme à d’autres 

lois pertinentes; et 

  définir si l’intervention de l’UE en matière de SIF offre à la société européenne une 
valeur  ajoutée  supérieure  à  ce  qui  aurait  été  réalisé  en  son  absence,  via  des 
initiatives des États membres ou des initiatives spécifiques à chaque cours d’eau. 

La  présente  étude  s’appuie  sur  des  travaux  antérieurs  entrepris  dans  le  cadre  de  la 
Directive 2005/44/CE,  notamment  les  résultats  de  l’étude  documentaire  de 2018, 
l’évaluation  réalisée  en 2014  couvrant  les  années 2006-2011,  ainsi  que  d’autres  études 
pertinentes.  

La période d’analyse de la présente étude porte sur les années 2005-2018. 

La  couverture  géographique  comprend  tous  les  États  membres  de  l’UE  faisant  partie  du 
réseau  Européen  de  voies  navigables  de  classe IV  ou  supérieure.  Elle  concerne: 
l’Allemagne,  l’Autriche,  la  Belgique,  la  Bulgarie,  la  Croatie,  la  France,  la  Hongrie,  le 
Luxembourg, les Pays-Bas, la Pologne, la Roumanie, la Slovaquie et la Tchéquie. L’étude 
couvre également d’autres pays qui appliquent la Directive SIF conformément à l’article 2, 
paragraphe 2 de la Directive (à savoir: la Serbie, la Moldavie, l’Ukraine, l’Italie, l’Espagne, 
la Suisse et le Portugal), lorsque cela s’est avéré pertinent et approprié. 

APERÇU DE LA MÉTHODOLOGIE 

La méthodologie utilisée reposait sur: 

  des recherches documentaires  et une analyse  d’informations, qui constituaient la 
base de l’étude et ont servi de référence à l’évaluation quant à l’état actuel de la 
mise en œuvre;  

  une consultation des parties prenantes par le biais de questionnaires, d'entretiens, 
d'ateliers  et  d'une  consultation  publique  ouverte  auprès  de  l’ensemble  des  États 

3 Les cinq actes d’exécution ne faisaient pas partie de cette mission, dans la mesure où ils n’ont pas été analysés 
un par un, mais ont plutôt été pris en compte dans une évaluation de la façon dont ils ont contribué dans leur 
ensemble à la réalisation globale des objectifs de la Directive SIF. 

xix 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

membres concernés, afin d'étayer les éléments probants secondaires à l’aide d’avis 
et d’opinions des parties prenantes; et  

  une analyse approfondie des données primaires et secondaires récoltées, dont une 
évaluation de l’état de la mise en œuvre, une modélisation économétrique et une 
analyse coûts/avantages sociaux.  

PRINCIPALES CONSTATATIONS, CONCLUSIONS ET RECOMMANDATIONS 

Efficacité  

Tel qu’énoncé à l’article 4, paragraphe 3 de la Directive SIF, afin de mettre en place les 
SIF, les États membres: 

a) fournissent aux utilisateurs des SIF toutes les données pertinentes concernant la 
navigation et les plans de voyage sur les voies navigables;  

b) veillent à ce que les utilisateurs des SIF disposent [...] de cartes électroniques 
adaptées  à  la  navigation  pour  toutes  leurs  voies  navigables  de  classe V  et 
supérieure; 

c)  habilitent  les  autorités  compétentes  [...]  à  recevoir  des  comptes  rendus 
électroniques des données que doivent fournir les navires;  

d) veillent à ce que les avis aux capitaines, en ce compris les informations relatives 
au  niveau  d’eau  (ou  tirant  d’eau  maximum  autorisé)  et  au  gel  sur  leurs  voies 
navigables,  soient  fournis  sous  la  forme  de  messages  normalisés,  encodés  et 
téléchargeables.  

En outre, pour soutenir les SIF et en assurer l’interopérabilité, la Commission a défini des 
orientations  techniques  concernant  la  planification,  la  mise  en  œuvre  et  l'exploitation 
opérationnelle des services (orientations SIF), ainsi que des spécifications techniques pour 
le repérage et le suivi des navires, des systèmes de visualisation des cartes électroniques 
et d’informations pour la navigation intérieure, un système de notification électronique des 
navires et des avis aux capitaines. Les orientations SIF et les spécifications techniques ont 
été adoptées en tant qu’actes d’exécution. Bien qu’elles n’entrent pas à part entière dans 
le champ d’application de la présente mission, elles ont néanmoins été prises en compte 
afin  d’évaluer  la  manière  dont  elles  ont  contribué,  dans  leur  ensemble,  à  la  réalisation 
globale des objectifs de la Directive SIF.  

D’après les conclusions de cette étude, tous les États membres concernés ont pleinement 
respecté les exigences minimales de fourniture de données concernant la navigation 
et les plans de voyage décrites à l’Annexe I de la Directive SIF. Cependant, les données 
fournies  ne  sont  pas  entièrement  harmonisées  entre  les  États  membres,  en  raison  de 
l’absence de lignes directrices ou de textes de loi harmonisés et renforcés sur les exigences 
en matière de données détaillées. Cette situation est, au moins en partie, liée à la nature 
volontaire et à la complexité de certaines dispositions prévues dans la Directive SIF: les 
données  minimales  à  fournir  conformément  à  l’annexe I  de  la  Directive  SIF  n’apportent 
que des détails limités et il n’existe aucune autre disposition législative européenne à ce 
sujet.  Par  conséquent,  les  avantages  de  la  normalisation  des  données  relatives  à  la 
navigation et aux plans de voyage ne se sont pas complètement concrétisés. Les données 
déjà  fournies  sont  néanmoins  considérées  comme  utiles  pour  permettre  aux  utilisateurs 
des voies navigables de prendre des décisions de navigation éclairées.  

Des cartes électroniques de navigation sont disponibles dans tous les États membres 
concernés,  du  moins  dans  une  certaine  mesure.  Toutes  les  voies  navigables  de  classe 
CEMT V et supérieure ne sont cependant pas entièrement reprises et les cartes présentent 
des différences de qualité et de précision entre les pays. Les cartes ne sont pas toutes à 

xx 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

jour, et la Directive SIF et ses actes d’exécution n’imposent aucune fréquence en matière 
de  révision  et  de  mise  à  disposition.  Bien  que  la  qualité  et  la  fréquence  peuvent  être 
améliorées,  les  utilisateurs  des  voies  navigables  considèrent  la  disponibilité  des  cartes 
électroniques  de  navigation  comme  un  résultat  utile  et  bénéfique  de  la  Directive  SIF, 
favorisant une navigation efficace et sûre sur les voies navigables intérieures. 

Tous les États membres concernés  remettent  des  avis standardisés obligatoires aux 
capitaines (contenant des informations relatives au FTM, au WRM et à l’ICEM) concernant 
les  voies  navigables  de  classe IV  et  supérieure.  La  couverture  des  voies  navigables  en 
question est cependant inférieure à 100 % dans trois États membres. En outre, tous les 
États membres ne respectent pas pleinement cette obligation et fournissent des avis dans 
un  format  codé  et  téléchargeable.  Certains  utilisent  du  texte  libre  à  foison,  causant  des 
problèmes  d’interopérabilité  entre  les  pays  et  de  traduction.  Les  utilisateurs  des  voies 
navigables estiment néanmoins que la Directive SIF a amélioré la situation en normalisant 
les avis aux capitaines, qui ont, selon eux, optimisé les plans de voyage et la sécurité de 
la navigation intérieure. 

Les  données  probantes  suggèrent  que  le  nombre  de  notifications  électroniques  des 
navires soumis à plusieurs reprises au moment de franchir une frontière n’a pas baissé, 
car les échanges de données entre les autorités des différents États membres sont limités. 
Les préoccupations quant à la confidentialité des données, ainsi que les diverses exigences 
légales dans les États membres comptent parmi les principaux obstacles. La Directive SIF 
charge les États membres, dans la mesure où la notification des navires est requise par la 
réglementation nationale ou internationale, d’habiliter les autorités compétentes à recevoir 
des comptes rendus électroniques de données que doivent fournir les navires. En cas de 
transport transfrontalier, ces informations sont transmises aux autorités compétentes de 
l’État voisin, et ce, avant l’arrivée des navires à la frontière. La Directive SIF ne précise 
pas quelles informations doivent figurer dans ces comptes rendus. En outre, elle n’impose 
pas,  en  soi,  la  transmission  de  comptes  rendus  de  navigation.  Par  conséquent,  les 
informations contenues dans les comptes rendus électroniques ne sont pas toutes prises 
en  charge  dans  tous  les  États  membres  concernés  et  les  comptes  rendus  ne  sont  pas 
automatiquement  partagés.  Les  utilisateurs  des  voies  navigables  sont  ainsi  obligés  de 
soumettre des informations à plusieurs reprises lors d’un voyage international. Dès lors, 
ces  derniers  et  les  autorités  SIF  n’ont  profité  d'aucune  des  économies  associées 
escomptées.  Cette  constatation  laisse  entendre  qu’une  future  analyse  des  politiques 
pourrait se pencher sur la recherche de moyens concrets pour remédier à cette inefficacité. 
Il conviendrait en effet d’envisager une harmonisation plus approfondie des exigences en 
matière de comptes rendus électroniques.  

reconnues  dans 

Toutes  les  certifications  des  visionneuses  ECDIS  intérieur  en  mode  navigation  et  des 
transpondeurs SAI intérieur au sein de l’Union européenne sont effectuées par une autorité 
Allemande4  et  sont 
les  autres  États  membres.  Cette 
concentration – bien qu’elle ne soit pas prévue  dans la Directive – assure une qualité et 
une  interopérabilité  constantes  des  équipements  à  travers  l’Europe.  Elle  permettrait 
également aux autres autorités de gagner du temps et de l’argent, qu’elles devraient sinon 
consacrer  à  l’approbation  d’équipements  dans  leur  propre  pays.  Il  n’est  toutefois  pas 
clairement  établi que  ces  gains  d’efficacité  découlent  directement  de  la  Directive  SIF  en 
soi:  quelques  parties  prenantes  consultées  soutiennent  que  les  États  membres 
accepteraient les certifications réalisées par les autorités d’autres États membres, qu’elles 
soient requises ou non par la Directive.  

tous 

Globalement,  il  apparaît  que  la  Directive  SIF  a  contribué  à  la  mise  en  place  de  SIF 
interopérables  et  harmonisés  dans  l’UE,  mais  ce,  dans  un  degré  limité.  Bien  que 
l’amélioration  de  l’harmonisation  constitue  l’un  des  principaux  avantages  amenés  par  la 
Directive,  certaines  divergences  demeurent  entre  les  pays  et  les  corridors  fluviaux.  Les 
technologies SIF ne sont pas exploitées dans la même mesure dans tous les pays. L’actuel 
manque de coopération et de collaboration entre les pays et les corridors fluviaux devrait 

4 Wasser- und Schifffahrtsverwaltung des Bundes Fachstelle der WSV für Verkehrstechniken (FVT 

xxi 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

être compensé afin de garantir des conditions de concurrence  équitables  entre les États 
riverains traditionnellement plus avancés, dans la région du Rhin, et les États dont le niveau 
de développement initial était plus faible, dans la région du Danube.   

Aucun élément probant fiable et sûr ne permet de conclure que la Directive SIF a eu des 
effets positifs imprévus, bien que certains signes indiquent qu’elle a offert de nouvelles 
possibilités en faisant évoluer le marché (pour exemple, navigation autonome) et qu’elle a 
permis de créer de nouveaux lieux de travail, notamment dans l’informatique. 

En ce qui concerne la réalisation de ses objectifs généraux, les résultats sont mitigés. 
Aucune donnée statistiquement significative n’indique que la Directive SIF a eu un impact 
sur  la  croissance  du  secteur  de  la  navigation  intérieure  ou  a  permis  d’optimiser 
l’utilisation  des  infrastructures  existantes.  Il  semblerait  qu’elle  ait  favorisé  la 
protection  de  l’environnement  en  réduisant  la  consommation  de  carburant,  bien  qu’il 
s’avère  difficile  d’évaluer  la  mesure  dans  laquelle  cette  baisse  lui  est  pleinement 
attribuable. Malgré l’absence de données fiables concernant les accidents, l’ensemble des 
groupes  de  parties  prenantes  estiment  que  la  Directive  SIF  a  contribué  à  améliorer  la 
sécurité de la navigation intérieure. 

Principales conclusions et recommandations  

  Toutes les technologies SIF clés (pour lesquelles la Directive et ses actes d’exécution 
comportent  des  normes  techniques  et  des  orientations)  ont  été  mises  en  œuvre 
dans tous les États membres concernés. Certaines différences demeurent quant à 
la  mesure  dans  laquelle  elles  correspondent  aux  normes  prévues.  Aussi,  des 
orientations  plus  claires  seraient  accueillies  favorablement  par  l’ensemble  du 
secteur.  

 

Il est recommandé que la Commission pense à clarifier les orientations concernant 
les données pertinentes relatives à la navigation et à la planification des voyages 
qui  doivent  être  récoltées  et  reprises  dans  les  comptes  rendus.  Cette  mesure 
pourrait  contribuer  à  harmoniser  les  approches  et  à  offrir  des  conditions  de 
concurrence plus équilibrées dans les différents États membres et corridors fluviaux.  

  La Directive SIF a largement réussi à atteindre son objectif global visant à établir 
des  SIF  harmonisés  et  interopérables,  en  instaurant  la  fourniture  obligatoire  de 
données au format électronique ainsi que des normes techniques communes, et en 
encourageant  la  coopération  transfrontalière.  Plusieurs  défis,  dont  la  vitesse  de 
révision de ces normes techniques et de leur réglementation, ainsi que le manque 
d’orientations  claires  mentionné  ci-avant,  entravent  le  plein  accomplissement  de 
cet objectif.  

  Les éléments d’appréciation sont mitigés quant à la contribution de la Directive à la 
réalisation de ses objectifs généraux (à savoir renforcer la compétitivité, l’utilisation 
des infrastructures existantes, la sûreté et la sécurité du secteur de la navigation 
intérieure, ainsi que le respect de l’environnement). Aucune incidence significative 
d'un point de vue statistique sur la croissance sectorielle n’a été constatée. Il n’a 
en  outre  pas  été  possible  d’imputer  avec  certitude  à  la  Directive  la  baisse  de  la 
consommation de carburant observée. Malgré l’absence de données fiables sur les 
accidents, un effet positif clair sur le sentiment de sécurité a pu être établi.  

Efficience 

La Commission s’est exposée à des frais liés à la préparation de la Directive SIF et des 
actes  d’exécution  connexes,  mais  il  ne  semble  pas  que  les  coûts  encourus  aient  été 
disproportionnés  par  rapport  au  résultat  obtenu.  Les  autorités  nationales  craignent 
toutefois  que  la  vitesse  à  laquelle  les  normes  techniques  sont  adoptées  au  sein  de  l’UE 
entraîne  une  charge  réglementaire,  car  la  technologie  évolue  en  permanence  et  les 
exigences techniques se doivent d’être à jour pour rester pertinentes. 

xxii 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

La plupart des coûts nécessaires pour assurer la disponibilité des technologies SIF 
incombent aux autorités SIF, alors que la plupart des avantages bénéficient aux utilisateurs 
des SIF. Les autorités supportent des frais conséquents pour que les données de navigation 
et  de  planification  des  voyages,  les  cartes  électroniques  de  navigation  et  les  avis  aux 
capitaines  soient  disponibles,  bien  qu’elles  ne  considèrent  pas  ces  coûts  comme 
disproportionnellement élevés par rapport aux avantages qu’ils offrent au secteur dans son 
ensemble.  

Les  utilisateurs  des  voies  navigables  s’exposent  à  des  coûts  très  limités  par  rapport 
aux technologies SIF clés. Les données de navigation et des plans de voyage ainsi que 
les avis aux capitaines sont fournis gratuitement. En outre, les coûts d’investissement en 
matériels et logiciels nécessaires pour utiliser les cartes électroniques de navigation à bord 
sont  minimes  en  comparaison  avec  le  coût  du  navire.  Par  ailleurs,  ces  dépenses  sont 
subventionnées.  En  général,  les  technologies  SIF  sont  perçues  comme  utiles  et,  par 
conséquent, les coûts associés à la Directive SIF à cet égard sont jugés compensés par les 
avantages.  

Il est difficile de savoir si la Directive SIF a entraîné des changements en ce qui concerne 
les coûts liés au système de notification électronique des navires, car elle n’impose 
pas  ce  système  en  soi,  mais  elle  prescrit  certaines  exigences  concernant  le  format  des 
comptes  rendus.  En  raison  des  limites  existantes  dans  les  échanges  de  données  et  le 
partage de comptes rendus électroniques, il est peu probable que les coûts aient fortement 
changé,  tant  pour  les  autorités  que  pour  les  utilisateurs  des  voies  navigables.  Certains 
signes  indiquent  toutefois  qu’une  meilleure  harmonisation  du  système  de  notification 
électronique des navires pourrait réduire le temps et l’argent que les utilisateurs consacrent 
actuellement  au  fait  de  soumettre  plusieurs  fois  des  comptes  rendus  au  passage  d'une 
frontière. Il se peut cependant que la Directive SIF ne puisse résoudre ce problème, car la 
fragmentation est due à des différences entre les règlements de police nationaux.  

En  dépit  du  manque  de  données  concrètes  concernant  les  coûts,  le  fait  que  toutes  les 
certifications  pour  les  équipements  SIF  dans  l’UE  soient  effectuées  par  une  seule 
organisation  et  mutuellement  reconnues  par  tous  les  États  membres  permet  à  tous  les 
autres  États  membres  de  gagner  du  temps  et  de  l’argent,  qu’ils  ne  doivent  pas  prévoir 
pour  réaliser  leurs  propres  approbations.  Il  n’est  toutefois  pas  clairement  établi  si  cette 
situation découle directement de la Directive SIF ou si elle se serait imposée dans tous les 
cas.  

De manière générale, bien que les coûts de la mise en œuvre des SIF que les autorités 
SIF et les utilisateurs des voies navigables intérieures doivent  supporter n’aient pas été 
agrégés  au  niveau  de  la  Directive  SIF  dans  leur  ensemble,  nous  n’avons  décelé  aucun 
élément permettant d’établir que les coûts globaux surpassent les avantages généraux.  

Il  n'existe  aucun  élément  probant  suggérant  que  la  Directive  SIF  a  entraîné  des  effets 
négatifs imprévus sur le plan économique, social ou environnemental.  

Les  coûts  administratifs  incombant  aux  autorités  SIF  et  aux  utilisateurs  des  voies 
navigables  ne  sont  pas  disproportionnés.  Cependant,  dans  les  deux  cas,  il  est  encore 
possible  de  réduire  davantage  la  charge  administrative  associée  aux  opérations 
quotidiennes,  notamment  en  renforçant  l’harmonisation  du  système  de  notification 
électronique des navires afin de maximiser l’efficience des échanges de données entre les 
autorités et d’épargner aux utilisateurs les doubles comptes rendus.  

Il  s’avère  difficile  de  tirer  des  conclusions  concernant  les  coûts  encourus  pour  la 
réalisation des objectifs généraux de la Directive SIF en raison de l’absence de données 
fiables  au  niveau  des  résultats  (p.  ex.,  les  données  relatives  aux  accidents  ne  sont  pas 
comparables dans le temps et entre les États membres) et parce qu'il est impossible d'avoir 
des données d'entrée granulaires (c.-à-d. les coûts pour obtenir ces résultats). Cependant, 
les données quantitatives disponibles suggèrent que, depuis l’adoption de la Directive SIF 
en 2005, les 13 États membres concernés ont enregistré une baisse moyenne annuelle de 
1,86 % de la consommation d’énergie de la navigation intérieure. En supposant que 40 % 

xxiii 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

des utilisateurs des SIF utilisent leurs équipements en vue de réduire la consommation de 
carburant, on peut affirmer que la Directive SIF a un retour sur investissement positif à 
cet égard. Cette conclusion reste valable tant qu’au moins 12 % des navires équipés de la 
technologie SIF l’utilisent pour réduire leur consommation de carburant.  

Principales conclusions et recommandations 

  Bien que l’absence de données fiables concernant les coûts empêche de mener une 
analyse quantitative coûts/avantages suffisamment solide, les données qualitatives 
démontrent que les avantages de la Directive SIF l’emportent vraisemblablement 
sur  les  frais  encourus.  Ces  coûts  sont  principalement  assumés  par  les  autorités, 
tandis que les avantages bénéficient aux utilisateurs des voies navigables.  

  Cette situation se vérifie pour les données relatives à toutes les technologies SIF 
clés, à l’exception du système de notification électronique des navires, pour lequel 
une harmonisation plus approfondie et de meilleurs échanges de données devraient 
permettre  aux  utilisateurs  et  aux  autorités  de  gagner  davantage  de  temps  et 
d’argent.  

  Les parties prenantes estiment que le délai d’adoption de normes techniques pour 
les  technologies  SIF  est  trop  long  pour  suivre  les  évolutions  technologiques 
attendues.  Les  auteurs  de  la  présente  étude  notent  toutefois  que  la  formation 
récente du groupe de travail CESNI/TI en juin 2019 est susceptible d'accélérer le 
rythme de publication de nouvelles normes techniques.  

 

Il  est  recommandé  à  la  Commission  de  poursuivre  ses  efforts  pour  harmoniser 
davantage les SIF en Europe. Elle pourrait réfléchir à des moyens de résoudre les 
différentes interprétations des normes techniques et pallier l’absence  de données 
comparables, comme la façon dont la profondeur de l’eau est mesurée et signalée 
dans toute l’Europe.  

Pertinence 

Les objectifs fixés dans la Directive et les besoins du secteur du transport par voies 
navigables  intérieures  ont  présenté  un  degré  élevé  d’alignement  pendant  la  période 
étudiée. Cependant, les parties prenantes notent un changement d’orientation: alors que 
la Directive a été rédigée en tenant compte essentiellement de la question de la sécurité, 
le secteur a aujourd’hui davantage besoin d’améliorer l’efficacité de la navigation intérieure 
et de nouer des liens plus étroits avec d’autres modes de transport.  

Depuis 2005, le secteur de la navigation intérieure a vu naître de nouveaux besoins que 
les  objectifs  actuels  ne  couvrent  pas  et  qui  devraient  être  pris  en  considération  pour 
s'assurer  que  la  Directive  SIF  reste  pertinente  à  l’avenir.  L’importante  vague  de 
numérisation ayant entraîné des évolutions technologies comme le passage à la navigation 
(semi-)autonome,  constitue  le  besoin  le  plus  remarquable.  En  raison  d’une  plus  grande 
sensibilisation  aux  SIF  et  d’une  meilleure  utilisation  de  ceux-ci,  il  s’est  avéré  nécessaire 
d’assurer  une  formation  et  une  éducation  adéquates  en  vue  de  maîtriser  les  nouveaux 
outils et technologies utilisés dans le secteur.  

Les  parties  prenantes  reconnaissent  que  les  orientations  SIF  et  les  normes  techniques 
imposées par les actes d’exécution SIF sont pertinentes et indispensables. Toutefois, elles 
considèrent que la lenteur de leur mise à jour pourrait nuire à leur pertinence à l’avenir.   

Principales conclusions et recommandations 

  Les objectifs établis dans la Directive SIF étaient fortement alignés sur les besoins 
du secteur au moment de la publication de la Directive et ils demeurent pertinents 
à l’heure actuelle. Ces dernières années, une importante vague de numérisation a 
entraîné  des  évolutions  technologiques  qui  doivent  être  prises  en  compte  pour 
veiller à ce que la Directive reste pertinente à l’avenir.  

xxiv 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  La lenteur du processus réglementaire requis pour élaborer et adopter de nouvelles 
spécifications  techniques – mesure  nécessaire  pour  continuer  de  garantir  leur 
pertinence à la lumière des avancées technologiques – fait peser un risque sur la 
pertinence future de la Directive SIF.  

 

Il  est  recommandé  à  la  Commission  de  tenir  compte  des  récentes  évolutions 
technologiques  si  elle  décide  de  réexaminer  et  d’éventuellement  modifier  la 
Directive  SIF.  Elle  pourrait  envisager  de  proposer  un  texte  «neutre  sur  le  plan 
technologique»,  afin  qu’il  s’adapte  rapidement  aux  évolutions  technologiques,  et 
ainsi éviter que la Directive ne devienne obsolète à l’avenir.  

Cohérence 

La Directive en tant que telle ne semble contenir aucune incohérence. L’analyse juridique 
et les commentaires des parties prenantes à l’appui suggèrent que la Directive et ses actes 
d’exécution  fournissent  un  cadre  cohérent  pour  les  exigences  minimales  permettant  la 
compatibilité transfrontalière des systèmes nationaux.  

Il  n’y  a  aucune  preuve  d’incohérence  entre  la  Directive  SIF  et  d’autres  obligations 
internationales pertinentes préexistantes des États membres. Toutes les orientations 
et  recommandations  connexes  pertinentes  (p.  ex.,  de  l’AIN,  de  la  CEE-ONU  et  des 
commissions fluviales) ont été rédigées en tenant compte de la Directive SIF et sont donc 
parfaitement cohérentes.   

La  Directive  SIF  est  cohérente  avec  les  autres  politiques  de  l’UE  en  matière  de 
transport  par  voie  navigable,  telles  que 
les  qualifications 
professionnelles et la Directive sur les prescriptions techniques applicables aux bateaux de 
navigation intérieure.  

la  Directive  sur 

La Directive est également parfaitement alignée sur les objectifs établis dans le livre blanc 
de  l'Union  sur  les  transports  et  l’initiative  «L’Europe  en  mouvement»,  soulignant  sa 
cohérence avec la législation plus large de l’UE en matière de transports.  

Aucune  incohérence  entre  la  Directive  SIF  et  d’autres  instruments  législatifs 
européens  dans  des  domaines  autres  que  la  politique  des  transports  n’a  été 
relevée.  Ces  domaines  comprennent  le  marché  unique  numérique  et  les  initiatives 
d’administration  en  ligne  en  lien  avec  la  numérisation  et  les  règles  de  protection  des 
données.  

Principales conclusions et recommandations 

  La  Directive  SIF  est  cohérente  sur  le  plan  interne  et  externe.  Elle  ne  présente 
aucune contradiction, ni en son sein ni par rapport aux obligations internationales 
pertinentes des États membres, à la législation européenne en matière de politique 
de transport par voie navigable, à la législation européenne sur les transports, ou 
à toute autre réglementation européenne dans des domaines autres que la politique 
des transports.  

 

Il est recommandé qu’en cas d’éventuelles révisions de la Directive, la Commission 
tienne compte de tout nouvel élément législatif dans le secteur des transports et 
au-delà. Ce point permettra à la Directive de rester cohérente avec toute nouvelle 
mesure prise après 2018 – date limite de la présente étude.  

Valeur ajoutée européenne 

L'argument en faveur de  l’intervention  publique  au niveau de  l’UE  réside dans le 
caractère  international  et  transfrontalier  du  secteur  du  transport  par  voies  navigables 

xxv 

 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

intérieures. Au moment de l’adoption de la Directive, les SIF étaient mis en place à des 
rythmes  différents  à  travers  l’Europe,  avec  plusieurs  technologies  et  applications  créant 
des obstacles potentiels aux voyages transfrontaliers. La Directive a été adoptée dans le 
but  d’harmoniser  les  technologies  dans  toute  l’Europe,  afin  d’améliorer  le  transport 
transfrontalier et de minimiser les coûts de coordination.  

La  Directive  SIF  est  considérée,  par  tous  les  différents  groupes  de  parties  prenantes, 
comme  appropriée  et  justifiée,  par  rapport  aux  résultats  que  des  interventions 
menées au niveau national ou régional auraient pu raisonnablement donner. Bien 
que des avantages  similaires auraient pu être  obtenus par les  commissions fluviales, ils 
n’auraient  probablement  pas  conduit  au  même  degré  d’harmonisation  et  auraient  sans 
doute  maintenu  la  fragmentation  entre  les  différentes  régions  (c’est-à-dire  les  pays  du 
Rhin et du Danube).  

En ce qui concerne les preuves de la valeur ajoutée européenne réelle de la Directive, 
tous  les  groupes  de  parties  prenantes  conviennent  que  la  Directive  présente  une  forte 
valeur ajoutée européenne. L’introduction d’une base juridique commune comme référence 
pour  des  normes  techniques  communes,  qui  a  conduit  à  la  normalisation  et  à 
l’harmonisation  à  travers  l’Europe,  en  constitue  l’élément  le  plus  remarquable.  Compte 
tenu des divers points de départ des différents pays, cette mesure a soutenu les progrès 
vers la création de conditions de concurrence équitables et a levé les obstacles aux voyages 
internationaux.  

Les projets financés par l’UE et le partage des connaissances qui en résulte  ont joué un 
rôle  clé  dans  ce  nivellement  des  conditions  de  concurrence,  car  les  autorités  SIF  et  les 
utilisateurs des deux régions estiment qu'ils ont renforcé la sensibilisation et l’intérêt pour 
le secteur de la navigation intérieure. Bien que ce point soit difficile à prouver, ils pensent 
que cela ne se serait pas produit aussi rapidement ou aussi efficacement sans le soutien 
de l’UE.   

Principales conclusions et recommandations 

  L'argument  en  faveur  de  l’intervention  publique  au  niveau  de  l’UE  repose 
sur  le  caractère  international  et  transfrontalier  du  secteur  du  transport  par  voies 
navigables  intérieures.  Une  intervention  européenne  pour  les  SIF  est  considérée 
comme appropriée et justifiée par les parties prenantes, compte tenu de son rôle 
dans  les  progrès  enregistrés  vers  la  création  de  conditions  de  concurrence 
équitables  entre  les  pays  traditionnellement  plus  avancés  et  les  pays  moins 
avancés.  

  Les projets financés par l’UE constituent l’un des principaux moteurs de progrès 
réels  vers  des  conditions  de  concurrence  équitables.  Ils  ont  permis  de  mobiliser 
l’attention autour des SIF et ont encouragé les pays à partager leurs connaissances 
et leurs expériences, ce qui a incité les États membres à investir davantage dans le 
secteur de la navigation intérieure (s’ils ne le faisaient pas encore).   

xxvi 

 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

KURZBESCHREIBUNG 

Die  Europäische  Kommission  führt  eine  Bewertung  der  Richtlinie 2005/44/EG  über 
Binnenschifffahrtsinformationsdienste  (RIS)  durch.  Diese  Studie,  die  von  Ramboll 
Management  Consulting  und  der  Universität  Antwerpen  durchgeführt  wurde,  stellt  eine 
analytisch solide Ex-post-Bewertung der Richtlinie dar. Sie ist Teil der Evidenzgrundlage 
für  die  Bewertung  der  Kommission.  Im  Rahmen  der  Studie  wurden  die  tatsächliche 
Wirksamkeit,  Effizienz,  Kohärenz,  Relevanz  und  der  EU-Mehrwert  der  Richtlinie  für  den 
Zeitraum von 2005 bis 2018 und für die Länder ihres Geltungsbereichs untersucht.  

gemeinsamer 

technischer  Standards 

Wie  qualitative  und  einige  quantitative  Ergebnisse  zeigen,  war  die  RIS-Richtlinie  bei  der 
Einführung 
der 
grenzüberschreitenden  Zusammenarbeit  weitgehend  erfolgreich,  wenngleich  einige 
zentrale  Herausforderungen  in  Bezug  auf  die  Qualität  der  angebotenen  Dienste  und  die 
Beschleunigung  der  Revision  und  Bereitstellung  technischer  Spezifikationen  sowie  deren 
Regulierung weiterhin bestehen. Es gibt Anzeichen dafür, dass sich die Richtlinie zumindest 
teilweise positiv auf die Einrichtung harmonisierter und interoperabler RIS ausgewirkt hat, 
während die mit der RIS-Richtlinie verbundenen Kosten in einem angemessenen Verhältnis 
zu den erzielten Vorteilen zu stehen scheinen.  

Förderung 

und 

der 

Hinsichtlich des Beitrags der Richtlinie zur Erreichung ihrer allgemeinen Ziele (Steigerung 
der  Wettbewerbsfähigkeit,  Nutzung  der  bestehenden  Infrastruktur,  Sicherheit  und 
Gefahrenabwehr sowie Umweltfreundlichkeit des Binnenschifffahrtssektors) ergibt sich ein 
uneinheitliches  Bild.  Es  konnte  keine  statistisch  signifikante  Wirkung  auf  das  sektorale 
Wachstum beobachtet werden. Der beobachtete Rückgang an Kraftstoffverbrauch ließ sich 
nicht  eindeutig  der  Richtlinie  zuschreiben.  Trotz  des  Fehlens  zuverlässiger  Unfalldaten 
konnte jedoch ein klarer positiver Effekt auf die gefühlte Sicherheit festgestellt werden. 

xxvii 

 
 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

ZUSAMMENFASSUNG 

ZIELE UND UMFANG DER STUDIE 

Die  Europäische  Kommission 
Binnenschifffahrtsinformationsdienste (RIS-Richtlinie 2005/44/EG) durch5.  

führt  eine  Ex-post-Bewertung  der  Richtlinie  über 

Diese Studie zur Unterstützung der Bewertung liefert der Kommission eine analytisch solide 
Ex-Post-Bewertung  der  Richtlinie  als  Evidenzgrundlage.  Sie  folgt  den  Leitlinien  und  dem 
Instrumentarium der Kommission zur besseren Rechtsetzung. Dementsprechend wurde die 
Analyse anhand der Bewertungskriterien Wirksamkeit, Effizienz, Relevanz, Kohärenz und 
EU-Mehrwert strukturiert. Im nächsten Schritt könnten die in dieser Studie (und in anderen 
Quellen) vorgelegten Beweise dazu verwendet werden:  

  die  Fortschritte  bei  der  Erfüllung  der  Ziele  der  Richtlinie  zu  bewerten  und  zu 

beurteilen, ob die Richtlinie tatsächlich Vorteile gebracht hat;  

  die mit der Richtlinie verbundenen Kosten zu  bewerten und zu beurteilen, ob die 

Kosten in einem angemessenen Verhältnis zu dem erzielten Nutzen stehen;  

 

festzustellen, ob die Ziele der Richtlinie angesichts der jüngsten Entwicklungen für 
den Binnenschifffahrtssektor weiterhin relevant sind;  

  zu beurteilen, ob die Richtlinie intern kohärent ist und mit anderen einschlägigen 

Rechtsvorschriften in Einklang steht; 

  zu beurteilen, ob die Intervention auf EU-Ebene in RIS einen Mehrwert für die EU-
Gesellschaft erbracht hat, der über das hinaus geht, was ohne diese Intervention 
durch mitgliedstaatliche oder auf die Binnenschifffahrt bezogene Initiativen erreicht 
hätte werden können. 

Diese  Studie  baut  auf  früheren  Arbeiten  auf,  die  im  Zusammenhang  mit  der 
Richtlinie 2005/44/EG durchgeführt wurden, insbesondere auf den Ergebnissen der Studie 
von  2018,  der  2014  durchgeführten  Bewertung  für  die  Jahre 2006-2011  und  anderen 
relevanten Studien.  

Der Analysezeitraum dieser Studie erstreckte sich über die Jahre 2005-2018. 

Der  geografische  Umfang  umfasste  alle  EU-Mitgliedstaaten,  die  Teil  des  europäischen 
Netzes von Wasserstraßen der Klasse IV oder höher sind. Dazu zählen: Österreich, Belgien, 
Bulgarien,  Kroatien,  Tschechien,  Frankreich,  Deutschland,  Ungarn,  Luxemburg,  die 
Niederlande, Polen, Rumänien und die Slowakei. Die Studie erstreckte sich auch auf andere 
Länder, die die RIS-Richtlinie in Übereinstimmung mit Artikel 2 Absatz 2 der Richtlinie in 
relevanten  und  angemessenen  Fällen  anwenden  (nämlich:  Serbien,  Moldawien,  Ukraine, 
Italien, Spanien, Schweiz und Portugal). 

ÜBERBLICK ÜBER DIE METHODIK 

Die verwendete Methodik basierte auf: 

  Fachliteraturrecherchen  und  Analyse  von  Informationen,  die  die  Grundlage  der 
Studie  bildeten  und  in  die  Bewertung  des  aktuellen  Stands  der  Umsetzung 
einflossen;  

  Konsultationen  der  Interessengruppen  über  Fragebögen,  Interviews,  Workshops 
und  eine  öffentliche  Konsultation  in  allen  relevanten  Mitgliedsstaaten,  um  die 

5 Die fünf Durchführungsrechtsakte gehörten nicht zum Umfang dieser Aufgabe, sodass sie nicht einzeln analysiert 
wurden,  sondern  vielmehr  bei  der  Bewertung  ihres  Beitrags  zur  Erreichung  der  Ziele  der  RIS-Richtlinie 
insgesamt berücksichtigt wurden. 

xxviii 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

sekundären  Beweise  durch  Ansichten  und  Meinungen  der  Interessengruppen  zu 
ergänzen;  

  eingehende  Analyse  der  gesammelten  Primär-  und  Sekundärdaten,  einschließlich 
einer Bewertung des Stands der Umsetzung, einer ökonometrischen Modellierung 
und einer sozialen Kosten-Nutzen-Analyse.  

DIE WICHTIGSTEN ERGEBNISSE, SCHLUSSFOLGERUNGEN UND EMPFEHLUNGEN 

Wirksamkeit  

Wie  in  Artikel 4  Absatz 3  der  RIS-Richtlinie  festgelegt,  müssen  die  Mitgliedstaaten  zur 
Einrichtung von RIS 

a)  den  RIS-Benutzern  alle  relevanten  Daten  für  die  Navigation  und  Reiseplanung 
auf den Binnenwasserstraßen übermitteln;  

b)  gewährleisten,  dass  auf  allen  ihren  Binnenwasserstraßen  der  Klasse V  und 
darüber  den  RIS-Benutzern  navigationstaugliche  elektronische  Schifffahrtskarten 
zur Verfügung stehen; 

c)  die  zuständigen  Behörden  in  die  Lage  versetzen,  elektronische  Meldungen  der 
erforderlichen Daten von Schiffen zu empfangen;  

d)  sicherstellen,  dass  Nachrichten 
für  die  Binnenschifffahrt,  einschließlich 
Wasserstandsberichten  (beziehungsweise  Berichten  über  den  maximal  zulässigen 
Tiefgang)  und  Eisberichten  für  ihre  Binnenwasserstraßen,  in  standardisierter, 
codierter und abrufbarer Form bereitgestellt werden.  

Darüber  hinaus  hat  die  Kommission  zu  Förderung  der  RIS  und  Gewährleistung  ihrer 
Interoperabilität technische Leitlinien für die Planung, die Einführung und den Betrieb der 
Dienste  (RIS-Leitlinien)  sowie  technische  Spezifikationen  für  die  Schiffsverfolgung  und  -
aufspürung, für die elektronische Darstellung von Binnenschifffahrtskarten und von damit 
verbundenen Informationen, für elektronische Meldungen in der Binnenschifffahrt und für 
Nachrichten  für  die  Binnenschifffahrt  festgelegt.  Diese  RIS-Leitlinien  und  technischen 
Spezifikationen  wurden  als  Durchführungsrechtsakte  verabschiedet.  Obwohl  sie  für  sich 
genommen  nicht  in  den  Geltungsbereich  der  vorliegenden  Aufgabe  fielen,  wurden  sie 
dennoch bei der Beurteilung des Beitrags berücksichtigt, den sie insgesamt zur Erreichung 
der Ziele der RIS-Richtlinie geleistet haben.  

Soweit  im  Rahmen  dieser  Studie  festgestellt  werden  konnte,  haben  alle  relevanten 
Mitgliedstaaten  die  Mindestanforderungen  für  die  Bereitstellung  von  Daten  für  die 
Navigation und Reiseplanung gemäß Anhang I der RIS-Richtlinie vollständig erfüllt. Die 
bereitgestellten Daten sind jedoch in den Mitgliedstaaten nicht vollständig harmonisiert, da 
es  keine  harmonisierten,  verstärkten  Leitlinien  oder  Rechtsvorschriften  über  detaillierte 
Datenanforderungen gibt. Das erklärt sich zumindest teilweise durch die freiwillige Natur 
und die Komplexität einiger Bestimmungen der RIS-Richtlinie: Durch die gemäß Anhang I 
der  Richtlinie  zu  liefernden  Mindestdaten  werden  nur  begrenzte  Angaben  bereitgestellt, 
und es gibt keine zusätzlichen EU-Rechtsvorschriften zu diesem Punkt. Infolgedessen sind 
die Vorteile, die die Standardisierung der Daten für die Navigation und Planung mit sich 
bringt, noch nicht voll zum Tragen gekommen. Die bereits zur Verfügung gestellten Daten 
werden von den Nutzern der Wasserstraßen dennoch als nützlich angesehen, um fundierte 
Navigationsentscheidungen treffen zu können.  

Elektronische Schifffahrtskarten werden in allen relevanten Mitgliedsstaaten zumindest 
in gewissem Umfang zur Verfügung gestellt. Allerdings sind nicht alle Wasserstraßen der 
CEMT-Klasse V und darüber vollständig abgedeckt, und es gibt Unterschiede zwischen den 
Ländern  hinsichtlich  der  Qualität  und  Genauigkeit  der  Karten.  Nicht  alle  Karten  sind  auf 

xxix 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

dem  neuesten  Stand,  da  die  RIS-Richtlinie  und  ihre  Durchführungsrechtsakte  keine 
Auflagen in Bezug auf die Häufigkeit der Überarbeitung und Bereitstellung vorschreiben. 
Obwohl es Raum für Verbesserungen in Bezug auf die Qualität und Häufigkeit gibt, wird 
die Verfügbarkeit elektronischer Schifffahrtskarten von den Wasserstraßennutzern als ein 
nützliches und vorteilhaftes Ergebnis der RIS-Richtlinie angesehen, das die effektive und 
sichere Navigation auf den Binnenwasserstraßen unterstützt. 

Alle relevanten Mitgliedstaaten stellen obligatorische standardisierte Nachrichten für 
die Binnenschifffahrt (mit Informationen zu  FTM,  WRM,  ICEM)  auf  Wasserstraßen der 
Klasse IV  und  darüber  zur  Verfügung,  wenngleich  die  Abdeckung  der  relevanten 
Wasserstraßen  in  drei  Mitgliedstaaten  unter  100 %  liegt.  Darüber  hinaus  kommen  nicht 
alle  Mitgliedstaaten  der  Anforderung  nach,  Mitteilungen  in  einem  verschlüsselten  und 
herunterladbaren  Format  zur  Verfügung  stellen.  Einige  verwenden  einen  umfangreichen 
freien  Text,  der  Probleme  bei  der  Interoperabilität  zwischen  den  Ländern  und  bei  der 
Übersetzung verursacht. Dennoch  sind die Nutzer der Wasserstraßen  der Meinung, dass 
die RIS-Richtlinie durch die Standardisierung der Nachrichten für die Binnenschifffahrt die 
Situation verbessert hat, da damit die Reiseplanung und Sicherheit in der Binnenschifffahrt 
verbessert werden konnten. 

Die  Beweise  deuten  stark  darauf  hin,  dass  die  Notwendigkeit  neuerlicher  Vorlagen  von 
elektronischen Meldungen in der Binnenschifffahrt beim Grenzübertritt aufgrund des 
begrenzten Datenaustauschs zwischen den Behörden verschiedener Mitgliedstaaten nicht 
reduziert werden konnte. Zu den hinderlichen Faktoren gehören Bedenken hinsichtlich des 
Datenschutzes  sowie  unterschiedliche  rechtliche  Anforderungen  in  den  Mitgliedstaaten. 
Durch die RIS-Richtlinie sind die Mitgliedstaaten beauftragt, die zuständigen Behörden – 
soweit Schiffsmeldungen durch nationale oder internationale Vorschriften vorgeschrieben 
sind – in die Lage zu versetzen, von den Schiffen elektronische Schiffsmeldungen über die 
erforderlichen  Daten  zu  erhalten.  Bei  grenzüberschreitenden  Transporten  werden  diese 
Informationen an die zuständigen Behörden des Nachbarstaates übermittelt, wobei diese 
Übermittlung  vor  Ankunft  der  Schiffe  an  der  Grenze  abgeschlossen  sein  muss.  Die  RIS-
Richtlinie  spezifiziert  weder,  welche  Informationen  diese  Berichte  enthalten  sollen,  noch 
schreibt  sie  Schiffsmeldungen  als  solche  vor.  Infolgedessen  werden  nicht  alle 
Informationen in den elektronischen Meldungen in der Binnenschifffahrt in allen relevanten 
Mitgliedstaaten  unterstützt,  und  die  Berichte  werden  nicht  automatisch  ausgetauscht, 
sodass  die  Wasserstraßennutzer  auf  einer  internationalen  Reise  die  Informationen  mehr 
als  einmal  vorlegen  müssen.  Folglich  hat  sich  keine  der  erwarteten  Kosteneinsparungen 
für die Nutzer der Wasserstraßen und die RIS-Behörden ergeben. Diesem Ergebnis zufolge 
ist es empfehlenswert,  dass eine künftige politische Analyse konkrete Wegen findet, um 
dieser  Ineffektivität  entgegenzuwirken.  Eine  weitere  Harmonisierung  der  Anforderungen 
für die elektronische Berichterstattung sollte als Option in Betracht gezogen werden.  

Alle  Typgenehmigungen  von  Inland  ECDIS-Viewern  im  Navigationsmodus  und  Inland-
AIS-Transpondern  in  der  Europäischen  Union  werden  von  einer  deutschen  Behörde6 
durchgeführt und sind in allen anderen Mitgliedstaaten anerkannt. Diese Konzentrierung – 
die  als  solche  von  der  Richtlinie  nicht  vorgeschrieben  ist –  führt  zu  einer  einheitlichen 
Qualität und Interoperabilität der Ausrüstung in ganz Europa und spart Berichten zufolge 
anderen  Behörden  Zeit  und  Geld,  die  sonst  in  die  Zulassung  der  Ausrüstung  in  ihren 
eigenen  Ländern  investiert  worden  wären.  Es  ist  unklar,  ob  diese  Effizienzeinsparungen 
direkt  auf  die  RIS-Richtlinie  an  sich  zurückzuführen  sind:  einige  wenige  konsultierte 
Interessenvertreter  argumentierten,  dass  die  Mitgliedstaaten  die  von  den  Behörden 
anderer  Mitgliedstaaten  durchgeführten  Typgenehmigungen  akzeptieren  würden, 
unabhängig davon, ob dies in der Richtlinie vorgeschrieben ist oder nicht.  

Insgesamt  wurde 
festgestellt,  dass  die  RIS-Richtlinie  zur  Einrichtung  eines 
harmonisierten, interoperablen RIS in der EU beigetragen hat, jedoch nicht in vollem 
Umfang.  Obwohl  ein  verbesserter  Harmonisierungsgrad  einer  der  Hauptvorteile  der 
Richtlinie  ist,  gibt  es  immer  noch  Diskrepanzen  zwischen  den  Ländern  und  den 

6 Wasser- und Schifffahrtsverwaltung des Bundes Fachstelle der WSV für Verkehrstechniken (FVT) 

xxx 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Flusskorridoren. RIS-Technologien werden nicht in allen Ländern in gleichem Maße genutzt. 
Ein  derzeitiger  Mangel  an  Kooperation  und  Zusammenarbeit  zwischen  den  Ländern  und 
Flusskorridoren müsste  überwunden werden, um die Rahmenbedingungen zwischen den 
traditionell  weiter  fortgeschrittenen  Anrainerstaaten  im  Rheingebiet  und  denjenigen,  die 
auf einem geringeren Entwicklungsniveau im Donauraum begonnen haben, auszugleichen.   

Es gibt keine stichhaltigen, verlässlichen Beweise für die Schlussfolgerung, dass die RIS-
Richtlinie  unbeabsichtigte  positive  Auswirkungen  hatte,  obwohl  es  Anzeichen  dafür 
im  Zusammenhang  mit 
gibt,  dass  sie  zur  Schaffung  neuer  Möglichkeiten 
Marktentwicklungen  (z. B.  autonomes  Segeln)  sowie  zur  Schaffung  neuer  Arbeitsplätze, 
u. a. in der Informatik, geführt hat. 

In Bezug auf die Erreichung ihrer allgemeinen Ziele ergibt sich ein uneinheitliches Bild. 
Es gibt keine statistisch signifikanten Beweise dafür, dass die RIS-Richtlinie einen Einfluss 
auf  das Wachstum  des  Binnenschifffahrtssektors  hatte  oder  zu  einer  optimierten 
Nutzung  der  bestehenden  Infrastruktur  führte.  Es  gibt  Hinweise  darauf,  dass  sie 
durch  einen  Rückgang  des  Kraftstoffverbrauchs  zum  Umweltschutz  beigetragen  hat, 
obwohl schwer zu messen ist, inwiefern dies gänzlich auf die RIS-Richtlinie zurückgeführt 
werden  kann.  Obwohl  keine  zuverlässigen  Unfalldaten  vorliegen,  besteht  bei  allen 
Interessengruppen  die  klare  Auffassung,  dass  die  RIS-Richtlinie  zur  Verbesserung  der 
Sicherheit in der Binnenschifffahrt beigetragen hat. 

Wichtigste Schlussfolgerungen und Empfehlungen  

  Alle  wichtigen  RIS-Technologien 

ihre 
(für 
Durchführungsrechtsakte  technische  Normen  und  Leitlinien  enthalten)  wurden  in 
allen relevanten Mitgliedstaaten umgesetzt. Es gibt aber noch einige Unterschiede 
in Bezug auf den Grad der Übereinstimmung mit den vorgeschriebenen Standards, 
und der gesamte Sektor würde klarere Leitlinien begrüßen.  

die  Richtlinie 

und 

die 

  Es  wird  empfohlen,  dass  die  Kommission  eine  Klärung  der  Leitlinien  zu  den 
relevanten  Daten,  die  für  die  Schifffahrt  und  die  Planung  zu  sammeln  und  zu 
übermitteln sind, in Betracht zieht, da dies dazu beitragen könnte, die Ansätze zu 
harmonisieren  und  die  Rahmenbedingungen  zwischen  den  Mitgliedstaaten  und 
Flusskorridoren weiter auszugleichen.  

  Die RIS-Richtlinie hat ihr übergeordnetes Ziel der Erschaffung eines harmonisierten, 
interoperablen  RIS  durch  die  Einführung  einer  obligatorischen  Bereitstellung  von 
Daten  in  elektronischem  Format  und  gemeinsamen  technischen  Standards  sowie 
durch  die  Förderung  der  grenzüberschreitenden  Zusammenarbeit  weitgehend 
erreicht. Einige Herausforderungen, insbesondere die Beschleunigung der Revision 
dieser technischen Normen und ihrer Regulierung sowie der oben erwähnte Mangel 
an  klaren  Leitlinien,  stehen  einer  vollständigen  Erreichung  dieses  Ziels  noch  im 
Wege.  

und 

Gefahrenabwehr 

  Hinsichtlich  des  Beitrags  der  Richtlinie  zur  Erreichung  ihrer  allgemeinen  Ziele 
(Steigerung  der  Wettbewerbsfähigkeit,  Nutzung  der  bestehenden  Infrastruktur, 
Sicherheit 
des 
Binnenschifffahrtssektors)  ergibt  sich  ein  uneinheitliches  Bild.  Es  konnte  keine 
statistisch  signifikante  Wirkung  auf  das  sektorale  Wachstum  beobachtet  werden. 
Der  beobachtete  Rückgang  an  Kraftstoffverbrauch  konnte  nicht  eindeutig  der 
Richtlinie  zugeschrieben  werden.  Trotz  des  Fehlens  zuverlässiger  Unfalldaten 
konnte  jedoch  ein  klarer  positiver  Effekt  auf  die  gefühlte  Sicherheit  festgestellt 
werden.  

Umweltfreundlichkeit 

und 

Effizienz 

Der  Kommission  sind  Kosten  im  Zusammenhang  mit  der  Vorbereitung  der  RIS-
Richtlinie und der zugehörigen Durchführungsrechtsakte entstanden, aber es gibt 
keinen Hinweis darauf, dass die entstandenen Kosten in keinem Verhältnis zu dem erzielten 

xxxi 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Ergebnis standen. Die nationalen Behörden sind jedoch besorgt, dass die zeitliche Dauer 
für  die  Annahme  von  technischen  Normen  in  der  EU  eine  regulatorische  Belastung 
darstellt,  da  sich  die  Technologie  ständig  weiterentwickelt,  und  die  technischen 
Anforderungen ständig aktualisiert werden müssen, um relevant zu bleiben. 

Die meisten Kosten für die Bereitstellung von RIS-Technologien werden von den RIS-
Behörden  getragen,  während  die  meisten  Vorteile  den  RIS-Benutzern  zugute  kommen. 
Den  Behörden  entstehen  erhebliche  Kosten  für  die  Bereitstellung  von  Daten  für  die 
Navigation  und  Planung,  elektronischen  Navigationskarten  und  Nachrichten  für  die 
Binnenschifffahrt, obwohl sie diese Kosten im Vergleich zu den Vorteilen, die sie für den 
Sektor insgesamt bringen, nicht für unverhältnismäßig hoch halten.  

Den  Nutzern  der  Wasserstraßen  entstehen  nur  sehr  geringe  Kosten  in  Bezug  auf  die 
wichtigsten RIS-Technologien. Daten für Navigation und Planung sowie Nachrichten für 
die  Binnenschifffahrt  werden  kostenlos  zur  Verfügung  gestellt.  Darüber  hinaus  sind  die 
Investitionskosten  für  Hard-  und  Software,  die  für  die  Nutzung  der  elektronischen 
Navigationskarten  an  Bord  erforderlich  sind,  im  Vergleich  zu  den  Kosten  des  Schiffes 
marginal, und in vielen Fällen wurden solche Investitionskosten subventioniert. Insgesamt 
werden  RIS-Technologien  als  nützlich  erachtet,  weshalb  die  mit  der  RIS-Richtlinie 
diesbezüglich verbundenen Kosten als durch den Nutzen aufgewogen betrachtet werden.  

Es ist unklar, ob die RIS-Richtlinie zu Änderungen bei den Kosten im Zusammenhang 
mit  elektronischen  Meldungen  in  der  Binnenschifffahrt  geführt  hat,  da  sie  die 
Meldungen  als  solche  nicht  vorschreibt,  sondern  nur  bestimmte  Anforderungen  an  das 
Format der Meldungen stellt. Da dem Datenaustausch und der gemeinsamen Nutzung von 
elektronischen  Berichten  Grenzen  gesetzt  sind,  ist  es  unwahrscheinlich,  dass  sich  die 
Kosten  erheblich  geändert  haben,  weder  für  die  Behörden  noch  für  die  Nutzer  der 
Wasserstraßen.  Es  gibt  jedoch  Anzeichen  dafür,  dass  eine  weitere  Harmonisierung  der 
elektronischen Meldungen in der Binnenschifffahrt den Zeit- und Geldaufwand der Nutzer 
reduzieren  könnte,  der  derzeit  mit  den  neuerlichen  Vorlagen  von  Meldungen  beim 
Grenzübertritt verbunden ist. Die RIS-Richtlinie kann jedoch möglicherweise keine Lösung 
für  dieses  Problem  bieten,  da  die  Fragmentierung  durch  unterschiedliche  nationale 
Polizeivorschriften verursacht wird.  

Obwohl  keine  konkreten  Daten  zu  den  Kosten  vorliegen,  ist  die  Tatsache,  dass  alle 
Typgenehmigungen  für  RIS-Ausrüstungen  in  der  EU  von  einer  Organisation 
durchgeführt  und  in  allen  Mitgliedstaaten  wechselseitig  anerkannt  werden,  ein  Hinweis 
darauf,  dass  die  jeweils  anderen  Mitgliedstaaten  Zeit  und  Geld  sparen,  die  sonst  in  die 
Durchführung ihrer eigenen Genehmigungen investiert würden. Es ist jedoch nicht klar, ob 
dies direkt auf die RIS-Richtlinie zurückzuführen ist oder ob dies auch unabhängig davon 
der Fall gewesen wäre.  

Obwohl  die  den  RIS-Behörden  und  Binnenschifffahrtsnutzern  entstehenden  Kosten  der 
RIS-Implementierung nicht gänzlich auf der Ebene der RIS-Richtlinie kumuliert wurden, 
gab es keine Hinweise darauf, dass die Gesamtkosten den Gesamtnutzen übersteigen.  

Es  wurden  keine  stichhaltigen  Beweise  dafür  gefunden,  dass  die  RIS-Richtlinie 
unbeabsichtigte negative wirtschaftliche, soziale oder ökologische Auswirkungen 
hatte.  

Es  gibt  keine  unverhältnismäßigen  Verwaltungskosten  für  die  RIS-Behörden  oder  die 
Wasserstraßenbenutzer. In beiden Fällen besteht jedoch noch ein Potenzial zur weiteren 
Verringerung  des  mit  dem  täglichen  Betrieb  verbundenen  Verwaltungsaufwands, 
insbesondere  durch  eine  weitere  Harmonisierung  der  elektronischen  Meldungen  in  der 
Binnenschifffahrt,  um  die  Effizienz  des  Datenaustauschs  zwischen  den  Behörden  zu 
maximieren und Doppelmeldungen für die Nutzer zu vermeiden.  

Es ist schwierig, Schlussfolgerungen über die Kosten zu ziehen, die auf der Ebene der 
Erreichung der allgemeinen Ziele der RIS-Richtlinie anfallen, weil es an zuverlässigen 
Daten auf der Output-Ebene fehlt (z. B. sind Unfalldaten im Zeitablauf und zwischen den 

xxxii 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Mitgliedstaaten nicht vergleichbar) und weil die Daten auf der Input-Ebene nicht granuliert 
werden können (d. h. die Kosten für die  Erreichung dieser  Ergebnisse). Die verfügbaren 
quantitativen  Daten  deuten  jedoch  darauf  hin,  dass  seit  der  Verabschiedung  der  RIS-
Richtlinie  im  Jahr 2005  in  den  13 betroffenen  Mitgliedstaaten  ein  durchschnittlicher 
jährlicher  Rückgang  des  Energieverbrauchs  der  Binnenschifffahrt  von  1,86 %  zu 
verzeichnen  ist.  Ausgehend  von  der  Annahme,  dass  40 %  der  RIS-Benutzer  ihre 
Ausrüstung zum Zwecke der Reduzierung des Kraftstoffverbrauchs nutzen, kann man den 
Schluss 
in  dieser  Hinsicht  eine  positive 
Investitionsrentabilität  aufweist.  Diese  Schlussfolgerung  gilt,  solange  12 %  oder  mehr 
Schiffe,  die  mit  RIS-Technologie  ausgestattet  sind,  diese  zur  Reduzierung  des 
Treibstoffverbrauchs einsetzen.  

ziehen,  dass  die  RIS-Richtlinie 

Wichtigste Schlussfolgerungen und Empfehlungen 

  Obwohl  das  Fehlen  von  zuverlässigen  Kostendaten  keine  ausreichend  robuste 
quantitative  Kosten-Nutzen-Analyse  ermöglicht,  deuten  qualitative  Belege  darauf 
hin,  dass  die  Vorteile  der  RIS-Richtlinie  wahrscheinlich  die  anfallenden  Kosten 
überwiegen. Die Kosten werden in erster Linie von den Behörden getragen, während 
der Nutzen den Wasserstraßennutzern zugute kommt.  

  Dies  gilt  für  Daten  für  alle  wichtigen  RIS-Technologien,  mit  Ausnahme  der 
elektronischen Meldungen in der Binnenschifffahrt, bei denen plausibel anzunehmen 
ist,  dass  eine  verstärkte  Harmonisierung  und  ein  verstärkter  Datenaustausch  zu 
weiteren Zeit- und Kosteneinsparungen für Nutzer und Behörden führen könnten.  

  Der Zeitrahmen für die Annahme von technischen Standards für RIS-Technologien 
wird  von  den  Interessengruppen  als  zu  lang  betrachtet,  um  mit  den  erwarteten 
technologischen Entwicklungen Schritt zu halten. Die Autoren dieser Studie weisen 
jedoch  darauf  hin,  dass  die  jüngste  Einrichtung  der  CESNI/TI-Arbeitsgruppe  im 
Juni 2019 das Tempo der Herausgabe neuer technischer Standards beschleunigen 
könnte.  

  Es  wird  empfohlen,  dass  die  Kommission  ihre  Bemühungen  um  eine  weitere 
Harmonisierung  der  RIS  in  Europa  fortsetzt.  Sie  könnte  Wege  zur  Lösung  der 
unterschiedlichen Interpretationen technischer Standards und der Bewältigung des 
Mangels  an  vergleichbaren  Daten  prüfen,  z. B.  die  Art  und  Weise,  in  der  die 
Wassertiefe in ganz Europa gemessen und übermittelt wird.  

Relevanz 

Während des gesamten Berichtszeitraums gab es ein hohes Maß an  Übereinstimmung 
zwischen  den  in  der  Richtlinie  festgelegten  Zielen  und  den  Bedürfnissen  des 
Binnenschifffahrtssektors.  Die  Interessengruppen  stellen  jedoch  fest,  dass  sich  der 
Schwerpunkt  verlagert  hat:  Während  die  Richtlinie  in  erster  Linie  mit  Blick  auf  die 
Sicherheit erstellt wurde, hat der Sektor nun einen stärkeren Bedarf, die Effizienz in der 
Binnenschifffahrt  zu  verbessern  und  stärkere  Verbindungen  zu  anderen  Verkehrsträgern 
herzustellen.  

Seit dem Jahr 2005 sind in der Binnenschifffahrt neue Bedürfnisse entstanden, die von 
den derzeitigen Zielen nicht abgedeckt werden und die berücksichtigt werden müssten, um 
sicherzustellen,  dass  die  RIS-Richtlinie  auch  in  Zukunft  von  Bedeutung  bleibt.  Am 
bemerkenswertesten  ist  die  starke  Welle  der  Digitalisierung,  durch  die  technologische 
Entwicklungen  wie  der  Übergang  zum  (halb-)autonomen  Segeln  eingeleitet  wurden.  Die 
zunehmende  Sensibilisierung  und  Nutzung  von  RIS  hat  auch  die  Notwendigkeit  einer 
angemessenen Schulung und Ausbildung über die neuen Werkzeuge und Technologien, die 
in diesem Sektor verwendet werden, mit sich gebracht.  

Die Interessengruppen  sind sich einig darüber, dass die RIS-Richtlinien und technischen 
Standards,  die  durch  die  RIS-Durchführungsrechtsakte  auferlegt  werden,  relevant  und 

xxxiii 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

notwendig sind. Sie sehen jedoch im langsamen Prozess ihrer Aktualisierung ein Risiko für 
ihre weitere Bedeutung in der Zukunft.   

Wichtigste Schlussfolgerungen und Empfehlungen 

  Die 

in  der  RIS-Richtlinie 

festgelegten  Ziele  waren  zum  Zeitpunkt  der 
Veröffentlichung  der  Richtlinie  sehr  stark  auf  die  Bedürfnisse  des  Sektors 
abgestimmt  und  sind  auch  heute  noch  relevant.  In  den  letzten  Jahren  hat  eine 
starke  Digitalisierungswelle  zu  technologischen  Entwicklungen  geführt,  die 
möglicherweise angegangen werden müssen, um sicherzustellen, dass die Richtlinie 
auch in Zukunft relevant bleibt.  

  Der langsame Regelungsprozess, der für die Entwicklung und Verabschiedung neuer 
technischer  Spezifikationen  erforderlich  ist,  um  deren  anhaltende  Relevanz 
angesichts des technologischen Fortschritts sicherzustellen, stellt ein Risiko für die 
zukünftige Relevanz der RIS-Richtlinie dar.  

  Es  wird  empfohlen,  dass  die  Kommission  die 

jüngsten  technologischen 
Entwicklungen  berücksichtigt,  wenn  sie  beschließt,  die  RIS-Richtlinie  zu 
überarbeiten  und  möglicherweise  anzupassen.  Sie  könnte  erwägen,  den  Text 
„technologieneutral“  zu  halten,  um  sicherzustellen,  dass  er  schnell  an 
technologische Entwicklungen angepasst werden kann, und so zu vermeiden, dass 
die Richtlinie in Zukunft redundant wird.  

Kohärenz 

Es wurden keine internen Inkonsistenzen innerhalb der RIS-Richtlinie gefunden. Die 
rechtliche Analyse und das unterstützende Feedback der Interessengruppen legen nahe, 
dass  die  Richtlinie  und  ihre  Durchführungsrechtsakte  einen  kohärenten  Rahmen  für 
Mindestanforderungen bieten, um die grenzüberschreitende Kompatibilität der nationalen 
Systeme zu ermöglichen.  

Es gibt keine Hinweise auf eine Inkohärenz zwischen der RIS-Richtlinie und anderen 
internationalen  Verpflichtungen  der 
bereits  bestehenden  einschlägigen 
Mitgliedstaaten.  Alle  relevanten  einschlägigen  Richtlinien  und  Empfehlungen  (z. B.  von 
PIANC,  UNECE  oder  den  Stromkommissionen)  wurden  mit  Blick  auf  die  RIS-Richtlinie 
entworfen und sind somit gänzlich kohärent.   

Die  RIS-Richtlinie  steht  im  Einklang  mit  anderen  EU-Politiken  im  Bereich  der 
Binnenschifffahrt,  wie  z. B.  der  Richtlinie  über  Berufsqualifikationen  und  der  Richtlinie 
über die technischen Vorschriften für Binnenschiffe.  

Die Richtlinie ist auch vollständig auf die im Europäischen Weißbuch zum Verkehr und die 
Initiative „Europa in Bewegung“ dargelegten Ziele abgestimmt, was ihre Kohärenz mit der 
umfassenderen EU-Verkehrsgesetzgebung unterstreicht.  

Es  wurden  keine  Unstimmigkeiten  zwischen  der  RIS-Richtlinie  und  anderen  EU-
Rechtsvorschriften  in  Bereichen  außerhalb  der  Verkehrspolitik  aufgedeckt.  Diese 
umfassen  Initiativen  zum  digitalen  Binnenmarkt  und  E-Government  in  Bezug  auf 
Digitalisierung und Datenschutzbestimmungen.  

Wichtigste Schlussfolgerungen und Empfehlungen 

  Die  RIS-Richtlinie  ist  intern  und  extern  kohärent.  Es  gibt  weder  Widersprüche 
innerhalb  der  Richtlinie  noch  zwischen  der  Richtlinie  und  den  einschlägigen 
internationalen  Verpflichtungen  der  Mitgliedstaaten,  der  EU-Gesetzgebung  in  der 
Binnenschifffahrtspolitik,  der  EU-Verkehrsgesetzgebung  oder  anderen  EU-
Rechtsvorschriften in Bereichen außerhalb der Verkehrspolitik.  

  Es  wird  empfohlen,  dass  die  Kommission  bei  eventuellen  Überarbeitungen  der 
Richtlinie  alle  bevorstehenden  Rechtsvorschriften  innerhalb  und  außerhalb  des 

xxxiv 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Verkehrsbereichs  berücksichtigt.  Auf  diese  Weise  wird  sichergestellt,  dass  die 
Richtlinie  auch  nach  dem  Jahr 2018,  dem  Endpunkt  der  vorliegenden  Studie,  mit 
allen politischen Entwicklungen kohärent bleibt.  

EU-Mehrwert 

im 
Die  Begründung  für  eine  öffentliche  Intervention  auf  EU-Ebene 
grenzüberschreitenden, 
internationalen  Charakter  des  Binnenschifffahrtssektors  zu 
suchen.  Zum  Zeitpunkt  der  Verabschiedung  der  Richtlinie  wurden  RIS  in  Europa  in 
unterschiedlichem  Tempo  entwickelt,  wobei  unterschiedliche  Technologien  und 
Anwendungen  potenzielle  Hindernisse  für  grenzüberschreitende  Fahrten  darstellen.  Die 
Richtlinie  wurde  mit  dem  Ziel  verabschiedet,  die  Technologien  in  ganz  Europa  zu 
harmonisieren,  um  den  grenzüberschreitenden  Verkehr  zu  verbessern  und  die 
Koordinierungskosten zu minimieren.  

ist 

Die  RIS-Richtlinie  wird  von  allen  verschiedenen  Interessengruppen  als  angemessen  und 
gerechtfertigt angesehen, verglichen damit, was nach vernünftigem Ermessen durch 
Interventionen  auf  nationaler  oder  regionaler  Ebene  erreicht  hätte  werden 
können.  Obwohl  Stromkommissionen  einen  ähnlichen  Nutzen  erzielt  hätten  können, 
hätten  sie  wahrscheinlich  nicht  zum  gleichen  Grad  an  Harmonisierung  geführt,  und  die 
Fragmentierung  zwischen  den  verschiedenen  Regionen  (d. h.  Rhein- und  Donauländern) 
wäre bestehen geblieben.  

Was Belege für den tatsächlichen EU-Mehrwert der Richtlinie betrifft, so sind sich alle 
Interessengruppen  einig,  dass  die  Richtlinie  einen  starken  EU-Mehrwert  hat.  Am 
bemerkenswertesten ist die Einführung einer gemeinsamen Rechtsgrundlage als Basis für 
gemeinsame  technische  Standards,  die  zu  einer  europaweiten  Standardisierung  und 
Harmonisierung  führte.  In  Anbetracht  der  unterschiedlichen  Ausgangspunkte  der 
verschiedenen  Länder  unterstützte  dies  den  Fortschritt  bei  der  Schaffung  gleicher 
Rahmenbedingungen und beseitigte Hindernisse für internationale Reisen.  

EU-finanzierte Projekte und der daraus resultierende Wissensaustausch haben bei dieser 
Angleichung eine Schlüsselrolle gespielt. Die RIS-Behörden und Nutzer in beiden Regionen 
sind  der  Ansicht,  dass  dadurch  das  Bewusstsein  und  das  Interesse 
für  den 
Binnenschifffahrtssektor verstärkt wurde. Obwohl es schwer zu beweisen ist, vertreten sie 
die  Annahme,  dass  dies  ohne  die  Unterstützung  der  EU  nicht  so  schnell  und  effizient 
geschehen wäre.   

Wichtigste Schlussfolgerungen und Empfehlungen 

grenzüberschreitenden, 

  Die  Begründung  für  eine  öffentliche  Intervention  auf  EU-Ebene  beruht  auf 
dem 
des 
Binnenschifffahrtssektors.  Eine  Intervention  auf  EU-Ebene  für  RIS  wird  von  den 
Interessengruppen  als  angemessen  und  gerechtfertigt  erachtet,  da  sie  dazu 
beiträgt, Fortschritte bei der Schaffung gleicher Rahmenbedingungen zwischen den 
traditionell weiter fortgeschrittenen und den weniger fortgeschrittenen Ländern zu 
erzielen.  

internationalen 

Charakter 

  Hauptantriebskräfte  für  tatsächliche  Fortschritte  auf  dem  Weg  zu  gleichen 
Rahmenbedingungen  sind  von  der  EU  finanzierte  Projekte.  Sie  trugen  zur 
Sensibilisierung für RIS bei und veranlassten die Länder zum Austausch von Wissen 
und  Erfahrungen,  was  wiederum  einen  Anreiz  für  die  Mitgliedstaaten  darstellte, 
selbst weiter in den Binnenschifffahrtssektor zu investieren (wo sie dies zuvor noch 
nicht taten).   

xxxv 

 
 
 
Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

1.  CONTEXT  

1.1.  OBJECTIVES AND SCOPE OF THE STUDY 

This study intends to support the European Commission in assessing the current situation 
regarding the implementation of the Directive 2005/44/EC – the River Information 
Services (RIS) Directive.  

The  study  therefore  assessed  the  current  EU  RIS  policy  framework  within  the  existing 
technological,  regulatory  and  political  context  and  taking  into  account  the  concerns  of 
different stakeholders, with the purpose of presenting a  comprehensive state-of-play 
of the situation by the end of 2018. 

The  general  objective  of  this  study  was  to  provide  the  Commission  with  an  analytically 
robust  (ex-post)  evaluation  of  the  RIS  Directive.  In  order  to  address  the  evaluation 
questions provided in the Terms of Reference, the study:  

1)  Conducted  an  analysis  of  gaps  in  knowledge  on  the  implementation  process  and 
impact  of  the  Directive  by  carrying  out  a  systematic  review  of  studies,  reports, 
research and other relevant material published to date on the topic. 

2)  Provided  a  comprehensive  update  on  the  state-of-play  of  implementation  of  the 
Directive, making recommendations where relevant for potential actions to be taken 
at EU as well as regional/national level.  

The  study  is  of  a  summative  nature  in  that  it  aimed  to  take  stock  of  the  present-day 
situation  and  how  implementation  has  evolved  since  2005  as  a  result  of  Directive 
2005/44/EC, considering the introduction of new technological processes of relevance to 
Inland Waterway  Transport (IWT).  It assessed how far the main results of the Directive 
link to the expectations surrounding the initiative in 2005, differentiating and explaining 
results by country, corridor and RIS technology, as appropriate.  

The  study  built  upon  previous  work  undertaken  in  the  context  of  Directive  2005/44/EC, 
particularly  the  review  carried  out  in  20147  covering  the  years  2006-2011,  as  well  as 
subsequent studies and the results of the 2018 fact-finding study.  

Ultimately, the study is intended to provide a firm basis for future policy-making given that 
it will allow for a judgement to be made on whether and how Directive 2005/44/EC may 
need  to  be  adapted  in  the  future,  in  light  of  legislative,  technological  and  market 
developments since it was first devised.  

As  the  analysis  carried  out  under  this  support  study  will  feed  into  an  evaluation  of  the 
European  Commission,  the  study  itself  followed  the  Commission's  Better  Regulation 
Guidelines and Toolboxes. Accordingly, the analysis was structured around the evaluation 
criteria of effectiveness, efficiency, relevance, coherence and EU added value. The 
full evaluation questions matrix is included in the Technical Annexes (a separate document 
accompanying this report).  

The period of analysis of the study spanned the years  2005-2018 and the geographical 
scope  encompassed  all  EU  Member  States  that  are  part  of  the  European  network  of 
waterways of class IV or above. This includes: Austria, Belgium, Bulgaria, Czechia, Croatia, 
France, Germany, Hungary, Luxembourg, The Netherlands, Poland, Romania and Slovakia. 

7 

Panteia 

(2014), 

Evaluation 

of  RIS 

Implementation 

for 

the 

period 

2006-2011, 

see 

https://ec.europa.eu/transport/sites/transport/files/modes/inland/studies/doc/2014-07-evaluation-of-ris-
implementation-main-report.pdf  

1 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

The study also covered other countries that applied the RIS Directive in line with Article 
2(2) of the Directive8 . 

1.2. THE RIS DIRECTIVE 

The goal of harmonising river traffic information services on inland waterways is part of a 
broader  European  Commission  aim  to  make  waterway  transportation  a  more  viable 
alternative to road or rail transport. The introduction of the RIS Directive intended to secure 
interoperability between existing information services in Europe as well as with those that 
will be developed in the future9.  

In  a  nutshell,  RIS  support  navigation  on  the  inland  waterway  network,  more  broadly 
looking to enhance safety in inland ports and rivers, as well as the efficiency of navigation 
and calamity abatement processes, the better utilisation of existing infrastructure, and the 
increased integration of inland waterway transport into multimodal supply chains via the 
timely provision of relevant information10.  

1.2.1.   Implementing acts 

Over the years a number of concrete legislative measures have been adopted to support 
the development and maintenance of IWT in Europe, of which the RIS Directive is just one 
component.  Foremost,  five  Implementing  Acts  have  been  adopted  in  response  to 
Commission’s obligation, which supplement the RIS Directive:  

  Commission  Regulation  (EC)  No  414/2007  of  13  March  2007  concerning  the 
technical guidelines for the planning, implementation and operational use of River 
Information Services (OJL L 105, 23/04/2007) - based upon the PIANC-guidelines.  

  Commission  Regulation  (EC)  No  415/2007  of  13  March  2007  concerning  the 
technical  specifications  for  vessel  tracking  and  tracing  systems  (OJ  L  105/35, 
23/02/2007),  as  amended  by  the  Commission  Implementing  Regulation  (EC)  No 
689/2012 of 27 July 2012 on Vessel Tracking and Tracing (OJ L202,28/07/2012) 
(Inland AIS).  

  Commission Implementing Regulation (EU) No 909/2013 of 10 September 2013 on 
the  technical  specifications  for  the  electronic  chart  display  and  information 
system for inland navigation (OJ L 258, 28/09/2013) (Inland ECDIS), amended 
by Commission Implementing Regulation (EU) 2018/1973 as of 7 December 2018, 
which takes into account resolution 48 concerning ECDIS from the UNECE and the 
regulations of the CCNR. 

  Commission  Regulation  (EU)  No  164/2010  of  25  January  2010  on  the  technical 
specifications  for  Electronic  Reporting  in  inland  navigation  (OJ  L057, 
06/03/2010) (ERI) 

  Commission  Regulation  (EC)  No  416/2007  of  22  March  2007  concerning  the 
technical specifications for Notices to Skippers (OJ L 105/35, 23/02/2007) (NtS), 
amended  by  Commission  Implementing  Regulation  (EU)  2018/2032  of  20 
November 2018. 

The  Implementing  Acts  themselves  were  not  in  scope  for  this  assignment,  in  that  they 
were  not  analysed  one  by  one,  but  rather  were  taken  into  account  in  an  assessment  of 

8 Namely: Serbia, Moldova, Ukraine, Italy, Spain, Switzerland and Portugal. Serbia and the Ukraine are the most 

important from this list, due to their part of the European interconnected waterway network. 

9 Panteia (2014), Evaluation of RIS Implementation for the period 2006-2011, see 

https://ec.europa.eu/transport/sites/transport/files/modes/inland/studies/doc/2014-07-evaluation-of-ris-
implementation-main-report.pdf 

10 See https://ris.cesni.eu/  

2 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

how they have contributed as a whole to the overall achievement of the objectives of the 
RIS Directive.  

1.2.2.  The RIS waterway network  

The  RIS  Directive  applies  to  13  EU  Member  States:  Austria,  Belgium,  Bulgaria,  Croatia, 
Czechia,  France,  Germany,  Hungary,  Luxembourg,  the  Netherlands,  Poland,  Romania, 
Slovakia; because they contain inland waterways of CEMT class IV and above11. In addition, 
there  are  a  number  of  countries,  namely  Spain,  Italy,  Portugal,  Switzerland,  Serbia, 
Moldova and Ukraine, that are implementing the Directive voluntarily.  

The  main  countries  of  relevance  to  the  Directive  can  be  grouped  along  four  main 
corridors12: 

  Rhine  corridor:  Rhine  stream  area,  Neckar,  Mosel  and  waterways  in  Northern 

Netherlands; 

  Danube  corridor:  Danube  including  Main  Danube  canal  and  parts  of  tributaries 
like Sava, Drava (higher or equal than CEMT class IV) until the Black-sea and White 
Gate-Midia canal; 

  North-South  corridor:  Southern  Netherlands  (Scheldt  and  Maas),  Belgium  and 

France (until the Mediterranean but excluding Mosel and Upper Rhine);  

  East-West Corridor: Oder- Wisła, Elbe and Mittellandkanal. 

Smaller  RIS  actions  can  be  observed  in  Portugal  (Douro),  Italy  (Po)  and  Spain 
(Guadalquivir)  within  the  Orient-East-Med  and  the  Mediterranean  corridor.  The  latter 
actions are on a voluntary basis and are not included in the scope of this study.  

11 The Directive applies to “all inland waterways of the Member States of class IV and above which are linked 
by a waterway of class IV or above to a waterway of class IV or above of another Member State, including the 
ports on such waterways as referred to in Decision No 1346/2001/EC of the European Parliament and of the 
Council of 22 May 2001 amending Decision No 1692/96/EC as regards seaports, inland ports and intermodal 
terminals as well as project No 8 in Annex III (3).” 

12 It should be noted that definitions differ between different sources and approaches. According to the TEN-T 
approach, for instance, the main corridors are the Rhine-Danube and the Alpine-Rhine corridors. For the purpose 
of  the  present  study,  the  RIS  COMEX  approach  is  followed.  In  RIS  COMEX,  the  corridors  are  defined  as 
“Information services among fairway authorities mutually and with waterway users and related logistic partners 
in order to optimize use of inland navigation corridors within the network of European waterways.” This definition 
comprises the next important step in the development of RIS where a corridor approach is being developed 
instead of focusing on regions or Member States. 

3 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Figure 1. The corridor approach 

Source: Consortium led by Ramboll 

1.2.3.  Institutional framework 

The RIS Directive does not operate in a vacuum. A range of other institutional actors, at 
international level (UNECE13, PIANC committee 12514),regional level (River Commissions – 
CCNR,  Danube  Commission,  Sava  Commission,  and  Mosel  Commission),  and  local  level 
(national competent authorities and RIS providers) all play a role in the development and 
implementation of RIS activities in Europe.  

In addition, the Member States are involved through different platforms and expert groups, 
including the four official RIS Expert Groups which are tasked with the development and 
updating  of  the  technical  specifications  for  the  different  RIS  technologies15.  These  are 
envisaged  to  be  integrated  through  the  recently  established  CESNI  working  group  on 
information technology (CESNI/TI)16.  

Besides the public institutions, there are also expert groups within branch organizations 
working on RIS such as the IWT platform, with member organizations such as ESO17 and 
EBU18.  Since  2018,  ESO  and  EBU  are  cooperating  in  a  more  structured  way  within  the 
Inland Waterway Transport Platform. Notably, different member organisations of the IWT 

13  The  UNECE  has resolutions  for  international  standards for  tracking  and  tracing,  ERI,  NtS  and  guidelines for 
VTS, RIS in general, electronic chart display and information system. RIS is an issue that is discussed in the 
SC.3/WP.3 and inland Transport Committee of the UNECE 

14 PIANC is known for the RIS guidelines which is currently subject for a 5th revision and also has been published 
by the European Commission (regulation no. 414/2017) as one of the technical annexes of the RIS Directive. 

15 The four RIS Expert Groups are as follows: Expert Group on Electronic Chart Display and Information Systems 
(ECDIS); Expert Group on Electronic Reporting International (ERI); Expert Group on Notices to Skippers (NtS); 
and Expert Group on Vessel Tracking and Tracing (VTT).  

16 CESNI/TI was established in June 2019 and its activities thus fall outside of the scope of the present study.  

17 European Skippers Organisation: branch organisation that represents the interest of independent vessel owner 

/ operators and national organisations 

18 European Barge Union: branch organisation that represents the interests of freight brokers and some larger 

IWT companies with multiple vessels 

4 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

platform share the same experts and several people ‘wear a number of hats.’, i.e. represent 
multiple organisations. 

The institutional framework has changed since the publication of the Directive, as Member 
States  seek  more  cooperation  with  neighbouring  countries  to  comply  with  the  RIS 
standards and to allow for cross-border data exchange. Also, between the supranational 
and  intergovernmental  institutions  such  as  the  River  Commissions,  much  more 
collaboration with the European Commission is becoming formalised with CESNI. 

The  following  institutional  schematic  can  be  drawn  within  the  current  RIS  policy 
environment: 

Figure 2. Institutional RIS environment 

Source: Consortium led by Ramboll 

The schematic shows the RIS Expert Groups that are divided according to the four RIS key 
technologies, each with their own terms of reference, and working rather independently of 
supranational organisations such as the EU or the CCNR to a certain extent. These expert 
groups  provide  standards,  technical  documents,  guidelines  and  other  documents,  in 
addition to providing the RIS Index to all institutions. It is expected that they will do this 
in the future for CESNI instead of for the CCNR and the EC separately as has been the case 
to  date.  CESNI  would  then  be  the  reference  for  the  legal  base  that  is  provided  by  the 
European Commission and the CCNR. 

1.2.4.  Previous assessment of implementation 

A  general  assessment  of  the  RIS  packages  implementation  was  made  in  2006  by  the 
network of the SPIN-TN (Strategies to Promote Inland Navigation) and in 2014 by Panteia. 
The first assessment deployed a cost-benefit analysis (CBA) as an ex ante-tool assuming 
RIS would be rolled out by 2005 in Europe. The latter study was based on the principles of 
critical, evidence-based judgment, as defined in the Commission Guidelines for Evaluation 
and looked ex-post at the roll-out and development for the Member States between 2006 
and 2011. 

In terms of the implementation process, the 2014 review of the RIS Directive (covering 
the years 2006-2011) described RIS as a significant development and concluded that there 
had been “major progress” in terms of the implementation of key technological aspects, 
including  fairway  information  and  traffic  information  services.  The  study  identified 
differences in the pace of implementation of the RIS Directive between Member States and 
certain corridors, which have led to an uneven deployment and implementation of key RIS 

5 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

technologies and RIS services respectively. Differences were attributed to divergences in 
timing and initiation of the implementation process, as well as differences in the size of 
industry and infrastructure management organisation, and divergent resource availability 
across Member States. Overall, the 2014 study also found that implementation had taken 
longer  than  expected  upon  publication  of  the  Directive  which  foresaw  near  complete 
implementation by 2010.19  

In 2018, a  consortium on behalf of DG MOVE  carried out a ‘fact-finding study  on the 
practical and operational measures in application of the RIS Directive’. The aim of the study 
was to collect and analyse practical information about RIS as actually implemented in the 
Member  States.  The  study  was  survey-based  and  the  survey  targeted  waterway 
administrations  and  RIS  providers  –  it  did  not  aim  to  collect  the  views  and  experiences 
from the users (barge operators, freight forwarders, etc.). The findings of the fact-finding 
study have been included in the current report, where relevant. It is important to note that 
verifying  or  checking  correctness  of  the  results  of  the  fact-finding  study  fell  outside  the 
scope of this evaluation support study.  

1.2.5.  Evaluation baseline  

When evaluating the results and impacts of the RIS Directive, it is important to consider a 
scenario in which the Directive did not exist, and what the likely state of the sector would 
be in that case. As such, an attempt can be made at isolating the effect of the RIS Directive, 
rather than external developments, on the inland navigation sector.  

This section briefly describes the situation before the RIS Directive was adopted in 2005, 
relevant developments that have shaped the sector since then, and the actual impact of 
the RIS Directive, based on findings from the present support study, as further detailed in 
chapter 3 and the Technical Annexes to this report.  

The situation prior to the adoption of the RIS Directive  

No formal Impact Assessment was carried out prior to the adoption of the RIS Directive 
that can be considered as the baseline or status quo for the present study.  

Nevertheless, the Commission’s proposal for the RIS Directive, as well as evaluations of 
the Directive and other studies that have been conducted since 2005  provide an insight 
into the state of play prior to the adoption of the Directive.  

The development  of RIS technologies was spearheaded by a small number  of countries, 
located primarily along the Rhine corridor (Germany and the Netherlands, but also Austria, 
Belgium and France). Examples of RIS developments prior to 2005 include20:  

  BICS (Barge Information and Communication System): a system for reporting on 
the transport of dangerous goods via EDI (Electronic Data Interchange) messages. 
Prior  to  BICS,  information  was  exchanged  orally  or  via  fax/phone.  BICS  is 
operational since 1996. 

  ARGO (Advanced River Navigation): German fairway information system providing 

waterway users with electronic navigational charts.  

  ELWIS:  the  German  Electronic  Waterway  Information  System,  which  provides  a 
series  of  (fairway)  information  services,  including  notices  to  skippers,  actual  and 
forecast  water  levels  and  draughts,  information  on  ice,  addresses  of  authorities, 
traffic statistics and legal regulations. It has been in use since 1999.  

19 Panteia (2014), Evaluation of RIS Implementation for the period 2006-2011  

20 This list is not exhaustive but aims to provide insight into the types of applications being developed in parallel 
in different European countries (notably in the Rhine region). The examples are based on COM(2004) 392 final 
– the Commission’s proposal for the RIS Directive.  

6 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  IVS90: a ship reporting system used by the Dutch waterway authorities supporting 
lock planning, vessel traffic services, calamity abatement and statistics. It became 
operational  in  1996  and  allowed  for  automatic  data  transmission  between  locks 
and/or regional VTS centres, after the data is entered once by the relevant skipper 
at the beginning of the voyage.  

As a result, the Commission identified the challenge facing the inland waterway transport 
sector  that  triggered  the  adoption  of  the  RIS  Directive:  integrating  the  various  services 
and systems being implemented in different EU Countries into a single common operational 
concept. 

Developments that have shaped the sector since 2005  

Since 2005, a lot has changed in the policy, economic and technological spheres that might 
have influenced developments in the use of RIS and in the inland navigation sector more 
generally. For instance: 

Policy developments 

  The institutional framework has been reformed. Since 2015, the EU and the CCNR 
started collaborating more closely on technical standards and requirements in inland 
navigation, through CESNI working groups and committees. As the CCNR manages 
inland  navigation  on  the  Rhine,  which  is  a  heavily  trafficked  river  corridor,  its 
influence in standard  setting is considerable.  One standard for all (e.g.  ES-TRIN) 
replaces the dual regime based on mutual recognition in this area between the EU 
and the CCNR through CESNI. A consolidation of standards through this means is 
likely to influence the interoperability of RIS across borders.  

 

Internationally,  organisations  such  as  PIANC  and  the  UNECE  also  have  their  own 
sets of guidelines and recommendations on RIS. They, however, do not exist in a 
vacuum and collaborate with other institutional actors and expert groups within the 
RIS environment. 

  At EU level, the general transport agenda has been focused on achieving a modal 
shift away from road to more sustainable transport means. Legislation and actions 
taken in other transport areas might influence the degree to which inland navigation 
is used for transport and logistics. This, in turn, might influence the degree to which 
the RIS Directive has led to the achievement of a modal shift.  

  On the contrary, policy developments  such as  the adoption of the GDPR, making 
data  protection  rules  more  stringent,  might  have  had  a  negative  effect  –  the 
growing concern about privacy and data protection, paired with stricter rules, makes 
it difficult to share vessel data freely across countries. This might hinder the degree 
to which RIS can be used to its full potential, e.g. for more efficient lock planning. 

Economic developments 

  The  global  economic  crisis  of  2008  negatively  affected  the  performance  of  all 
transport sectors, including inland navigation. The  overall economic situation can 
also  influence  the  use  of  RIS  positively,  for  instance  through  investing  in 
technological improvements to improve the efficiency of existing RIS equipment. 

  Fluctuations in fuel prices had a possible impact on the performance of the sector. 
When fuel prices are high, vessel owners are more likely to look for means to reduce 
fuel consumption, which in turn might have a positive environmental effect beyond 
the use of RIS technologies. Other fluctuations, such as the demand for coal and 
iron  ore  (for  dry  cargo  barges)  and  the  demand  for  chemical  products  (for  tank 
barges) affect the performance of the sector as well. 

  National  funding,  which  in  turn  is  based  on  the  GDP  of  a  Member  State  and  the 
degree  to  which  inland  navigation  is  considered  a  priority  investment  for  that 
country, influences the speed at which a country develops and implements its RIS 
technologies.  

7 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Technological developments 

 

Improvements in technology greatly influence the use of RIS. Digitalisation of data, 
the use of cloud storage to efficiently share data across countries, developments in 
cellular  data  capacity  (and  price),  all  play  a  role.  One  of  the  results  of  these 
technological  developments  is  a  shift  in  focus,  away  from  safety,  towards 
multimodal supply chains and more efficient voyage and lock planning.  

  Similarly, improvements in AIS technology and an upcoming shift towards (semi)-
autonomous  sailing  might  positively  impact  the  degree  of  safety  in  inland 
navigation.  

In short, a lot has changed in and beyond Europe since the adoption of the RIS Directive 
in 2005. Although most of the abovementioned developments are likely to have positively 
influenced  the  sector,  and  thus  contributed  to  the  expected  achievements  of  the  RIS 
Directive, some might have had the opposite effect.  

The results of the economic analysis of the RIS Directive  

Based on an econometric and a cost-benefit analyses conducted as part of this study, an 
attempt was made to isolate the above developments from the effect caused solely by the 
RIS Directive itself. The following conclusions can be drawn with regards to the impact of 
the RIS Directive compared to a hypothetical situation in which the RIS  Directive would 
not exist:  

  The implementation of the RIS Directive led to a 1% growth in tank barge market 
in terms of tonne.km. However, this effect is not statistically significant, meaning 
that it cannot be concluded nor refuted that it indeed had an effect, or whether this 
growth would have occurred in its absence.  

  There  is  no  statistically  significant  evidence  to  conclude  whether  or  not  the  RIS 
Directive  impacted  the  growth  of  the  dry  cargo  market  in  terms  of  tonne.km,  or 
whether the same growth pattern would have occurred in its absence.  

  There  is  no  statistically  significant  evidence  to  suggest  that  the  RIS  Directive 
impacted the modal share of the inland navigation sector in Europe  compared to 
other  modes  of  transport.  As  the  modal  share  of  inland  navigation  has  remained 
stable since 1995, it is unlikely that this would have changed in the absence of the 
Directive either. 

 

It  is  not  possible  to  identify  an  effect  of  the  RIS  Directive  on  the  safety  level  of 
inland navigation. Poor data quality and limited comparability over time and across 
countries make this difficult to assess. It is unlikely that safety would have improved 
in absence of the RIS Directive.  

  No  statistical  evidence  was  available  to  show  that  traffic  or  lock  management 
improved by implementing RIS technologies. In fact, no significant changes seem 
to have occurred at all in this regard, though this could change in the future through 
increased use of RIS technologies.  

  Fuel consumption in inland navigation in Europe has decreased since 1990, notably 
in the Danube riparian states. The use of RIS technology is shown to have an impact 
on  this  trend,  although  it  is  difficult  to  attribute  the  use  of  RIS  directly  to  the 
implementation  of  the  RIS  Directive.  Some  evidence  was  found  that  suggests  a 
decrease in fuel consumption with the use of RIS leading to more efficient sailing.  

It is difficult to assess the impact the RIS Directive had on the development of the inland 
waterway sector in Europe, to isolate its effect from the use of RIS technologies as such, 
and to estimate the likely state of affairs had the RIS Directive not been adopted. It can 
be plausibly assumed, however, that the Directive contributed to the levelling of the playing 
field  in  inland  navigation  between  the  traditionally  more  mature  riparian  states  (in  the 
Rhine region) and the less mature (Danube region). Chapter 3 provides further details on 
the progress made since 2005, and the degree to which this can or cannot be attributed 
to the RIS Directive. 

8 

 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

2.  METHODOLOGY 

In accordance with the Terms of Reference, the study was structured along six consecutive 
Tasks, as depicted in the figure below.  

Figure 3. Overview of study tasks and their inter-linkages 

Task 1 involved a series of preliminary activities, including a kick-off meeting, exploratory 
interviews, and preliminary desk research which allowed the study team to gather a good 
understanding of the objectives of the study and to refine the methodology and prepare 
the ground for the subsequent data collection tasks.  

Tasks 2 to 4 represented the study’s data collection tasks, ranging from desk-research 
(Tasks  2  and  3)  to  an  extensive  stakeholder  consultation  programme  (Task  4).  Tasks  2 
and 3 allowed the study team to take stock of existing data and identify gaps that needed 
to be filled as part of the stakeholder consultation activities in Task 4.  

As part of Task 5, the secondary and primary data collected as part of Tasks 2 to 4 were 
analysed in order to derive robust findings. This task comprised the use of qualitative and 
quantitative  data  analysis  methods,  as  well  as  the  development  of  a  counterfactual  / 
baseline scenario, conducting econometric modelling, and developing an ex-post social cost 
benefit analysis21. The findings were triangulated, comparing and contrasting the results 
of different data sources, in order to analyse how far the outputs and outcomes observed 
are in line with the Directive’s intended objectives. 

Finally,  Task  6  provided  an  assessment  of  the  effects  of  Directive  2005/44/EC,  and 
whether the framework introduced by the Directive is fit-for-purpose.  

2.1.STAKEHOLDER CONSULTATION ACTIVITIES 

Task  4  represented  one  of  the  core  tasks  of  the  study  in  that  it  built  on  the  outputs  of 
Tasks  1,  2  and  3  by  consulting  relevant  stakeholders  to  build-on  and  validate  findings 

21 The full econometric modelling exercise as well as the ex-post social cost benefit analysis are included in the 

Technical Annex to this report (a separate document). 

9 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

derived from, and fill gaps/inconsistencies identified during, the desk-based review.  The 
stakeholder consultation activities conducted as part of this study included: 

  Targeted questionnaires  

 

In-depth interviews  

  Study visit to a RIS centre 

  Workshops and events 

  Open Public Consultation 

Details  of  the  stakeholder  consultation  activities  are  presented  in  the  Stakeholder 
Consultation Report - a stand-alone document accompanying this report. The paragraphs 
below offer summaries of the approach to individual elements of stakeholder consultation.  

2.1.1.  Targeted questionnaires 

Targeted questionnaires aimed to fill factual gaps as identified in earlier stages of the study, 
and primarily gather quantitative data. Two types of questionnaires were developed: 

 

 

for national administrations / competent authorities 

for users of waterways 

To disseminate the questionnaires to  relevant  stakeholders, i.e. national authorities and 
private sector representative bodies/users, the study team relied on a combination of DG 
MOVE’s contacts in the area, the contacts of the experts at the University of Antwerp, and 
national authorities’ and national associations’ member contacts. For national authorities’ 
and national associations’ contacts, in light of GDPR, the study team needed to rely on the 
assistance of national associations in disseminating the questionnaire to their members.  

Table 1. Overview of questionnaires received 

Category of stakeholder  
Public body: national level  

Private body: national association, skippers  

Questionnaires received  

6 (Austria, Belgium (Flanders), Czechia, Romania, 
Serbia, Slovakia)22  
9 (7 representative organisations, 2 skippers)23 

Total 

15 

The goal of the study team was to  receive a filled-out questionnaire from  each  relevant 
Member State (13 in total), however this proved impossible despite repeated follow-ups 
and additional requests for cooperation sent by the European Commission. The study team 
aimed to fill the remaining gaps, for which the questionnaires could not provide evidence, 
through  interviews  with  associations  and  representative  organisations.  The  limited  cost 
data received was  complemented with qualitative evidence from the in-depth interviews 
where relevant. Specific limitations of the data stemming from the questionnaires are made 
explicit in the answers to the individual evaluation questions in Chapter 3.  

2.1.2.  Interviews 

The  interviews  aimed  to  gather  evidence  in  relation  to  evaluation  criteria/questions  for 
which qualitative data was judged to be an important source. 

22 Many RIS authorities and competent authorities in given Member States filled the questionnaire in jointly. Six 

questionnaires were returned, but in reality, they cover 9 authorities.  

23  This  covers  the  following  countries:  Austria  (2),  Romania  (2),  Netherlands  (2),  Germany,  France,  Slovakia. 
Seven of the respondents (all representative organisations) indicated primarily operating on the Danube, and 
two (both skippers) on the Rhine. 

10 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

The  study  team  carried  out  the  interviews  with  a  sample  of  key  stakeholders  per  main 
stakeholder type, as presented in the table below. 

Table 2. Overview of interview status  

Category of stakeholder 

Type of Stakeholder 

Public bodies: International level  Shipping Regulation / Technical Certification Authority  

Public bodies: European level 

River Commissions 
RIS expert groups 

d
e
n
n
a
l
P

2 

4 
2 

d
e
t
c
u
d
n
o
C

3 

3 
3 

Public bodies: National level 

Port authorities 
National RIS authorities (13 in scope of Directive) 

3 
13 

4 
1324 

Private sector companies / 
representative organisations 

Total 

National RIS authorities (voluntary implementors) 
Public authorities e.g. transport management 

Calamity abatement support / agencies 
Professional Associations: European level 

Professional Associations: National level 
Developers of RIS 

Users of the waterways (skippers)  

2 
2 

2 
5 

8 
7 

2 
2 

1 
5 

7 
6 

1 

0 
50  50 

It  proved  difficult  to  organise  the  planned  number  of  interviews  in  certain  categories 
despite numerous follow-up efforts and unforeseen delays. Yet, the study team managed 
to conduct the planned number of interviews, although the number of interviews conducted 
in certain categories was different to the number originally proposed, as evidenced in the 
table above. Overall, the study team judges the sample consulted to be representative of 
the breadth of stakeholders concerned by the RIS Directive. 

The  detailed  list  of  consulted  stakeholders  in  presented  in  the  Stakeholder  Consultation 
Report, which is annexed to this report. 

2.1.3.  Study visit to a RIS Centre 

On  23rd  August  2019  members  of  the  study  team  visited  the  RIS  Centre  in  Evergem, 
Belgium. They met with the Vlaamse Waterweg, who presented their work on VisuRIS25, 
and plans for the future development of RIS in Flanders. They underlined the importance 
of  cross-border  collaboration  through  projects  such  as  RIS  COMEX,  and  SWINg  (Single 
Window  Inland  Navigation).  The  study  team  was  shown  interesting  data  and  witnessed 
first-hand  how  e.g.  notices  to  skippers  are  inputted  digitally  to  be  made  available  to  all 
users  online  and  how  calamity  abatement  works  in  practice.  Additionally,  the  visit  shed 
light on the possibilities of RIS data use in the future, e.g. for lock planning.  

2.1.4. Workshops and events 

In addition to the questionnaires and the interviews, the study team attended a number of 
events and workshops relating to RIS across Europe.  

24  One  of  the  interviewees  in  this  category  formerly  worked  for  one  of  the  national  RIS  authorities.  Although 
recently  retired,  he  was  involved  in  the  earlier  stages  of  implementation  of  the  RIS  Directive  and  thus  had 
valuable insights to share. 

25 VisuRIS, see https://www.visuris.be/ 

11 

 
 
 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  Open Shipping Days (Antwerp, Belgium, March 2019) 

As the Open Shipping Days took place during the early stages of the Inception Phase of 
the project, members of the study team used this event as a networking opportunity to 
meet  several key stakeholders in an informal setting and increase the awareness of the 
study among (mostly Belgian) IWT community.  

   RIS Week (Galați, Romania, June 2019) 

Members of the study team attended the Common Issues Day for the RIS Week. Gathering 
many RIS-stakeholders in the same place allowed the study team not only to explain the 
evaluation process and interact with the stakeholders; but also undertake a group-polling 
exercise of the session attendees. The details of the session and the analysis of the polling 
exercise are included in the Stakeholder Consultation Report.  

   DINA Expert Group (Brussels, Belgium, October 2019)  

The DINA Expert Group meeting took place after the preliminary findings and conclusions 
of the study had been developed. The study team led a structured workshop during this 
expert group meeting, in which the emerging findings were discussed, and applicability of 
any conclusions to Member States / corridors was verified with the stakeholders present 
at the event. 

   RIS Week (Liège, Belgium, November 2019) 

Members  of  the  study  team  presented  the  results  of  the  current  study  as  part  of  the 
‘Opening Speeches: Strategic Developments’ session.  

  CESNI/TI (Strasbourg, France, December 2019) 

Members of the study team presented the final findings and conclusions of the study during 
the CESNI/TI meeting in December. The event took place after the submission of the Final 
Report  of  this  study.  For  that  reason,  this  event  served  a  purpose  of  disseminating  the 
finalised study findings.  

2.1.5.  Open Public Consultation 

The European Commission launched an online open public consultation (OPC) to gather the 
opinions  of  the  broader  stakeholder  community  on  Directive  2005/44/EC, 
its 
implementation and interaction with other legislation in the area. The OPC was open to all 
EU citizens from 8th August to 31st October 2019, in line with the European Commission’s 
Better Regulation Guidelines26.  

The  study  team  analysed  the  results27  and  incorporated  them  into  the  stakeholder 
consultation  report,  as  well  as  taking  into  account  its  results  in  drafting  findings, 
conclusions and recommendations. 

26 

European 

(2017), 
https://ec.europa.eu/info/sites/info/files/better-regulation-guidelines.pdf  

Commission 

Regulation 

Better 

Guidelines, 

SWD(2017) 

350, 

see 

27 It is worth noting that there was considerable overlap in the respondents to the open public consultation and 

the stakeholders interviewed. A total of 12 out of the 44 OPC respondents were also interviewed.  

12 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.  ANSWERS TO THE EVALUATION QUESTIONS 

This  section  presents  the  detailed  findings  structured  per  each  evaluation  criterion  and 
then per evaluation question within a given criterion. The full Evaluation Questions Matrix, 
which  operationalises  the  evaluation  questions  and  outlines  the  indicators,  data  sources 
and analytical approach of the study, is presented as Annex 1 in the Technical Annexes 
(separate document accompanying this Report). 

Answers to each of the questions commence with a short contextual information aiming to 
set the scene for a given question. Subsequently included are highlighted summary boxes, 
presenting  the  key  findings  at  the  level  of  each  question.  These  are  then  followed  by 
highlighted headings, which delineate individually each of the key findings, and the text 
below presents the detailed evidence supporting them.  

In the case of answers to questions under  effectiveness, on the level of each of the RIS 
key technologies (data for navigation and planning, electronic navigational charts, notices 
to skippers, electronic ship reporting, and type-approval), the sections additionally include 
the elaborated causal pathways. The causal pathways illustrate how the objectives are 
related to the input, activities, output, and results of the Directive. The causal pathways 
are  different  from  the  Intervention  Logic  in  that  they  detail  the  actual  achieved  outputs 
and results of the Directive based on the results of this study, while the Intervention Logic 
is an evaluation tool that describes what the Directive is expected to change.  

3.1. EFFECTIVENESS 

3.1.1.  Availability and benefits of RIS technologies  

EQ 1: Compared to what would have happened in the absence of the Directive, in quantitative and qualitative 
terms, to what extent have (a) data for navigation and planning, (b) electronic navigational charts, and (c) 
notices to skippers been made available by Member States, and benefitted the resource planning of users of 
the inland waterways? 

A. 

Data for navigation and planning  

Context  

Availability of data for navigation and planning  

The RIS Directive stipulates that Member States shall “supply to RIS users all relevant 
data concerning navigation and voyage planning on inland waterways”, which is to be made 
available “at least in an accessible electronic format”28. The minimum data to be provided 
is detailed as follows29: 

  waterway axis with kilometre indication; 

 

restrictions  for  vessels  or  convoys  in  terms  of  length,  width,  draught  and  air 
draught; 

  operation times of restricting structures, in particular locks and bridges; 

 

 

location of ports and transhipment sites; 

reference data for water level gauges relevant to navigation. 

Although  not  officially  mentioned  in  the  Directive,  the  RIS  Index  was  established  to 
eventually enable countries to fulfil their minimum data requirements in line with Article 
4(3a). The RIS Index is a register of standardised geo-related RIS reference data, which 

28 Article 4(3a), Directive 2005/44/EC 

29 Annex I, “Minimum Data Requirements”, Directive 2005/44/EC 

13 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

was developed with a view to harmonise all reference data across the relevant European 
inland  waterways.  Reference  data  of  objects  relevant  for  Inland  Navigation  (e.g.  gauge 
stations,  waterway  axes,  lock  chambers,  bridges,  harbours,  berths,  terminals)  is  to  be 
maintained by Member States within their area of competence. All national RIS Indices are 
stored in the European Reference Data Management System (ERDMS)30, and individually 
made  available  for  download.  The  ERDMS  is  maintained  by  the  European  Commission, 
though the data is provided by the Member States themselves.  

There is no official European legislation available for the RIS Index31, though the standards, 
as well as a template and encoding guide were approved by all RIS Expert Groups. All RIS 
standards make use of  the RIS  Index or are at least compatible with the RIS  Index. As 
such, the reference data can be integrated into all other RIS systems (i.e. AIS, VTT, ENCs 
and NtS), with the aim of achieving full interoperability of RIS.  

Benefits of data for navigation and planning  

No formal impact assessment was carried out prior to the adoption of the RIS Directive. 
Therefore, there are no official expectations of economic, social or environmental benefits 
against  which  to  measure  actual  benefits  brought  about  by  the  RIS  Directive  through 
changes in provision of data for navigation and voyage planning. Nevertheless, prior to the 
adoption  of  the  Directive,  it  was  envisaged  that32  the  provision  of  all  relevant  data  for 
navigation  and  voyage  planning  to  skippers  would  improve  the  basis  for  immediate 
navigational  decisions,  which  in  turn  enhances  safety  and  environmental  protection,  as 
well as reduced reaction times in emergencies33.  

As such, at the onset of this evaluation support study, it was expected that the provision 
of data for navigation and planning would lead to RIS users being better informed, allowing 
them to make better informed decisions. As a  result, there  should be  more harmonised 
data  exchange  and  communication,  as  well  as  cost  savings  from  optimised  use  of 
infrastructure and better resource planning. In the long run, these results are expected to 
reduce  the  negative  environmental  impact  of  the  inland  navigation  sector,  improve  its 
competitiveness,  and  eventually  contribute  to  a  modal  shift.  The  degree  to  which  these 
expected benefits have been achieved is outlined below, and presented in the elaborated 
causal pathway in Figure 4. 

Box 1. Summary of findings on EQ 1a - data for navigation and planning 

Availability of data for navigation and planning  

All relevant Member States seem to comply with the RIS Directive’s requirements 
for  making  available  data  concerning  navigation  and  voyage  planning  on  inland 
waterways.  

Although the Directive clearly states the minimum data to be made available, and that 
this data needs to be provided in an accessible electronic format, it does not mandate 
for this data to be standardised. All Member States nevertheless provide  most data in 
line with the commonly agreed RIS Index, although there are indications that it is not 
fully  harmonised.  Notably  fairway  depth  data  is  considered  as  lacking,  e.g.  in 
Germany.  

The reason for the lack of harmonisation is the voluntary nature and complexity of 
the RIS Index and associated Encoding Guide. The voluntary nature of providing data, 

30 Available at https://webgate.ec.europa.eu/RIS/EUERDMS_WEB 

31 RIS Index Encoding Guide version 2.0, December 2015, p. 10.  

32 These expectations are based on the 2006 “Assessment of the implementation of river information services in 
Europe”  prepared  by  ViaDonau  in  the  context  of  the  SPIN-TN  project,  combined  with  the  intervention  logic 
prepared at the onset of the present study. 

33 ViaDonau, Assessment of the Implementation of River Information Services in Europe. Working Paper, 2006.  

14 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

combined  with  tight  public  budgets leads  to  a  lack  of  prioritisation  of  the  provision  of 
relevant data. According to stakeholders, this might be solved by the provision of clearer 
guidance or the enforcement of minimum standards through the RIS Directive.  

Benefits of data for navigation and planning  

Data for navigation and planning informs users of the waterways, who in turn can make 
more informed navigational decisions and better plan their voyages, provided the 
data is correct and up to date.  

Considering the lack of available cost data, there is no reliable evidence that skippers 
being better informed has actually led to cost savings, though there are indications that 
it leads to more efficient sailing.  

There  is  no  evidence  of  social  or  environmental  benefits  of  data  for  navigation  and 
planning.  However,  there  are  strong  indications  that  the  data  indirectly  improves 
safety, through its pivotal role in other RIS technologies (notably AIS and ENCs).  

The  benefits  of  data  for  navigation  and  planning  are  hindered  by  the  lack  of  full 
harmonisation  of  data  provided  across  Member  States.  If  current  efforts  towards 
harmonisation  are  continued,  it  is  likely  that  the  benefits  of  data  for  navigation  and 
planning will materialise in the future. 

Findings  

  All relevant Member States comply with the RIS Directive’s requirements 

for the provision of data for navigation and planning 

The 2018 fact-finding study found (based on self-reported information) that all relevant 
Member States had provided their respective RIS Indices, though not all of them were in 
line  with  the  latest  version  (version  2.0).  It  found  that  Flanders,  Czechia,  France,  the 
Netherlands and Poland had not yet updated their RIS Indices to the most recent version, 
although it was planned in Flanders, France and the Netherlands. Consultations carried out 
within the context of this study reveal that France, for instance, had updated its RIS Index 
to conform to the new version in 2019.  

In terms of the coverage of objects (e.g. gauge stations, waterway axes, lock chambers, 
bridges, harbours, berths, terminals), the fact-finding study found that the majority of the 
relevant  Member  States  cover almost all objects on their  waterways.  It  reported  a 
few  remaining  gaps  in  Bulgaria  (a  missing  Ferry  terminal),  Czechia  (missing  mooring 
facilities and pontoons), and France34. All other relevant Member States reportedly cover 
(close to) 100% of the objects on their waterways. However, the data is self-reported and 
not all countries participated in the survey, so it may not be fully reliable. It is beyond the 
scope of the present evaluation support study to check the accuracy of this information, 
though some indications were collected through the stakeholder consultation process.   

As there is no official European legislation for the RIS Index, Member States are not legally 
obligated to update theirs in line with the agreed standards. Therefore, as long as all data 
specified in Annex I of the Directive (i.e. adequate information in terms of the coverage of 
objects) is provided in some easily accessible electronic format by the Member States, they 
legally comply with the RIS Directive. As there is no strong indication of major gaps in the 
RIS Index in terms of the information included, it can be assumed that all relevant Member 
States are fully compliant.  

34  France  was  identified  as  having  0  objects  in  its  RIS  Index  at  the  time  of  writing  of  the  fact-finding  study. 

However, it became apparent through our interviews that France made the data available in 2019.  

15 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  The  voluntary  nature  of  the  provision  of  data  leads  to  a  lack  of 

harmonisation in the data provided  

Although Member States seem to comply with their legal requirements regarding making 
data  for  navigation  and  planning  available,  there  are  discrepancies  in  the  data 
provided. A total of 15 respondents to the open public consultation35 highlighted this issue 
in  some  way,  noting  a  lack  of  harmonised  reference  data  as  a  result  of  the  different 
interpretations in Member States.  For  example, not all countries measure and report on 
water  levels  in  the  same  way.  Three  separate  interviewees  mentioned  Austria  as  an 
example of good practice in this context, and two mentioned Germany as an example of a 
country  that  does  not  provide  the  information.  Especially  RIS  developers  stressed  the 
importance of fairway depth information to be accurately measured and published, because 
it can impact voyage planning and efficient sailing.  

This lack of harmonisation is primarily a result of the voluntary nature of the use of the 
RIS Index encoding guide. According to seven RIS authorities, the provision of accurate 
and up-to-date information simply is not prioritised because of this. Paired with reportedly 
tight  public  budgets  and  the  complexity  of  the  data,  this  leads  to  a  lack  of  full 
implementation. Three authorities36 and a RIS developer specifically stressed that there is 
a  lot  of  data  to  be  measured,  which  makes  the  collection  of  accurate  and  up-to-date 
information  difficult,  while  a  total  of  seven  acknowledged  the  limitations  of  human  and 
financial resources37.  

This was further confirmed by seven different RIS authorities38, who believe there is a lack 
of precision in the Directive. It specifies the minimum required data to be provided, but 
does not elaborate on how, when or how often this data should be provided/updated. Three 
of them specifically suggested that a clearer legal basis and/or stronger enforcement would 
help harmonise the provision of data throughout Europe.  

  The voluntary nature of the provision of data for navigation and planning 

limits the benefits it brings about  

As detailed above, steps have been taken to harmonise the data provided in all relevant 
Member  States.  However,  due  to  the  voluntary  nature  of  the  data  to  be  provided  and 
limited public resources, this process has not yet been fully completed, and differences in 
the quality and timeliness of data provided persist. Therefore, permanent cross-border RIS 
operations  have  not  been  rolled  out  as  originally  envisaged  by  the  RIS  Directive.  Data 
exchange across borders, comparable data quality and harmonised service levels across 
European waterways have been particularly hampered by the sector’s fragmentation.  

This lack of harmonisation can reasonably be assumed to impact the degree to which the 
RIS Directive brought about benefits with regards to changes to data for navigation and 
planning. In fact, a total of six interviewees, equally divided between RIS authorities and 
user representative organisations, mentioned the lack of harmonisation and data exchange 
as a hindering factor in this regard.  

Nevertheless, there are indications that the changes to data for navigation and planning 
brought about by the RIS Directive have been beneficial to some extent, as further detailed 

35 See section 7.2.7, Annex 3 “Findings from the open public consultation” of the Stakeholder Consultation Report  

36 All three authorities are located in Western Europe, though it is expected that this issue also exists in other 

Member States.  

37 Seven RIS authorities from all parts of Europe mentioned the lack of resources as a hindering factor in making 
data for navigation and planning available. Although not all of them specifically stated this to be an issue, two 
of the three who did are among the traditionally wealthier countries in Western Europe.  

38 RIS authorities from different parts of Europe share this opinion – no pattern emerges in terms of geographical 

location.  

16 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

below.  It  can  be  reasonably  expected,  therefore,  that  if  efforts  are  made  to  improve 
harmonisation across countries, the magnitude of these benefits will increase.  

Economic benefits  

  The  increased  availability  of  data  led  to  more  informed  navigation 

decisions  

Although difficult to prove, there are indications accrued through stakeholder consultations 
that suggest that changes in data for navigation and planning have positively impacted the 
day-to-day operations of users of the waterways.  

Research  conducted  in  the  framework  of  this  study  suggests  that  despite  the  lack  of 
harmonisation,  the  change  in  the  data  provided  has  impacted  waterway  users 
positively. Five out of seven questionnaire respondents who indicated they make use of 
data for navigation and planning specified that the data had been useful to them39. The 
one respondent who claimed the data was not useful also indicated they did not use data 
as it was not relevant to them. Three of the respondents specifically pointed to improved 
trip  planning  as  a  benefit  brought  about  by  the  RIS  Directive  in  this  regard.  This  was 
confirmed through interviews40, where more than half of those who discussed the benefits 
of data for navigation and planning agreed that the data had been beneficial for resource 
planning41. Correct and up-to-date information was cited as making navigation easier and 
more efficient.  

  There are indications that improved trip planning leads to cost savings for 

skippers  

There is limited evidence on cost savings because no adequate data on costs associated 
with  data  for  navigation  and  planning  on  the  side  of  users  of  the  waterways  could  be 
obtained. Nevertheless, three private sector user representatives stated in interviews that 
the  improved  trip  planning  resulting  from  more  and  better  data,  saves  users  money 
through  more  efficient  sailing.  If  they  are  better  informed  about  the  fairway,  they  can 
optimise their loading capacity and potentially get to their destination faster. This result 
might  not  be  significant,  but  at  least  there  are  no  indications  of  the  opposite  (i.e.  cost 
increase) happening on the side of RIS users. More details on costs compared to benefits 
are included under EQ 8. 

  There  are  no  strong  indications  of  improved  competitiveness  or  industry 

development  

Although  three  interviewees,  including  a  RIS  Developer,  a  RIS  authority,  and  a 
representative  of  an  international  organisation,  highlighted  the  development  and 
professionalisation  of  the  inland  navigation  sector  as  benefits  stemming  from  data  for 
navigation and planning, there is no quantitative evidence to prove that this is indeed the 
case.  According  to  them,  providers  use  data  for  investments,  maintenance,  repair, 
accidents, density, etc., which professionalises the sector. However, our general findings 
suggest that RIS data has not been used optimally for these types of activities.  

39  See  Question  53  of  the  RIS  user  questionnaire,  in  section  5.3.5.,  Annex  1  “Findings  from  the  survey 

questionnaires” of the Stakeholder Consultation Report 

40 See section 6.1 on benefits (EQ 1.4), Annex 2, “Findings from the interviews” of the Stakeholder Consultation 

Report.  

41 This was mentioned by 15 interviewees, among whom nine private sector interviewees, four RIS authorities, 

and one RIS expert group chair. 

17 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Nevertheless, it is safe to assume that in the longer run, provided that all Member States 
continue  to  provide  correct  and  up-to-date  information  in  line  with  the  mutually  agreed 
format of the RIS Index, these benefits will materialise42.  

Social benefits  

  Data  for  navigation  and  planning  indirectly  improves  safety  in  inland 

navigation  

Although  four  interviewees  and  three  questionnaire  respondents  highlighted  improved 
safety  as  a  benefit  resulting  from  data  for  navigation  and  planning,  there  is  reason  to 
believe that the link is indirect – it is likely to have an impact because the data feeds in to 
other aspects of RIS but the availability of the data as such is unlikely to directly influence 
safety.  

Data for navigation and planning feeds into electronic navigational charts, AIS and notices 
to skippers, which are all believed to impact safety in inland navigation. When discussed 
in interviews, many people brought up notably AIS as having significantly reduced the rate 
of accidents and thereby improved safety. As AIS relies on the data discussed here, there 
is thus likely to be an indirect causal relationship. More details on the topic of improved 
safety are included under EQ 6c on improved safety. 

Environmental benefits  

  There  is  no  proof  of  environmental  benefits  resulting  from  data  for 

navigation and planning  

Although  it  was  mentioned  as  an  expected  benefit  of  data  for  navigation  and  planning 
through  its  positive  effect  on  efficient  sailing,  there  is  no  evidence  to  suggest  that  fuel 
reduction  and,  hence,  less  pollution  has  resulted  from  this.  More  details  on  the  topic  of 
reduced  negative  environmental  impact  are  included  under  EQ  6d  on  increased 
environmental protection. 

42 A total of five interviewees, including three RIS authorities, a RIS developer and a skipper see potential in this 
regard.  Two  of  them  mentioned  the  expected  progress  of  the  RIS  COMEX  project  in  this  regard:  further 
harmonisation and provision of e.g. traffic information will have benefits for the sector as a whole in the future.  

18 

                                                
Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Figure 4. Causal pathway – Data for navigation and planning43 

43 Throughout the causal pathways, the colours of different boxes are used for clarity and readability purposes only.  

19 

 
 
                                                
Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

B. 

Electronic Navigational Charts (ENC)  

Context 

Availability of electronic navigational charts  

The  RIS  Directive  stipulates  that  in  addition  to  the  data  concerning  navigation  and 
voyage planning, Member States are to ensure “electronic navigational charts suitable for 
navigational purposes are available to RIS users”44.  

In its Annex, the Directive further specifies that the technical requirements for electronic 
navigational  charts  are  to  include  all  kinds  of  geographical  objects  necessary  for  safe 
navigation45;  integrate  fairway  water  depth  information;  and  integrating  additional 
information from parties other than the competent authorities, provided it does not affect 
the minimum information required for safe navigation46. It also stipulates that the charts 
are  to  be  made  available  to  RIS  users,  as  well  as  to  all  relevant  manufacturers  of 
applications, against a reasonable cost-related charge. 

In 2013, the Commission published the technical specifications for Inland ECDIS47, which 
was  subsequently  updated  in  201848.  Although  the  specifications  address  primarily  the 
requirements for  Inland ECDIS49 hard- and software, they also detail that the electronic 
charts that feed into Inland ECDIS are to contain at least the following information50:  

  waterway axis with kilometres indication;  

 

 

 

links  to  the  external  xml-files  with  operation  times  of  restricting  structures,  in 
particular locks and bridges;  

location of ports and transhipment sites;  

reference data for water level gauges relevant to navigation;  

  bank of waterway (at mean water level); 

 

shoreline  construction  (e.g.  groin,  longitudinal  control  dam,  training  wall  –  any 
facility that is considered a hazard to navigation); 

 

contours of locks and dams; 

  boundaries of the fairway/navigation channel (if defined); 

 

 

isolated dangers in the fairway/navigation channel under water; 

isolated  dangers  in  the  fairway/navigation  channel  above  water  level,  such  as 
bridges, overhead cables etc.; 

44 Article 4 (3b), Directive 2005/44/EC  

45 E.g. boundaries of the fairway, shoreline constructions, beacons, … 

46 Annex II (2) “Inland ECDIS”, Directive 2005/44/EC  

47 Commission Regulation No 909/2013 of 10 September 2013 on the technical specifications for the electronic 
chart display and information system for inland navigation (Inland ECDIS) referred to in Directive 2005/44/EC 
of the European Parliament and of the Council. 

48  Commission  Implementing  Regulation  (EU)  2018/1973  of  7  December  2018  amending  Implementing 
Regulation  (EU)  No 909/2013  on  the  technical  specifications for  the  electronic  chart  display  and  information 
system for inland navigation (Inland ECDIS) referred to in Directive 2005/44/EC of the European Parliament 
and of the Council. 

49 Inland ECDIS is the electronic chart display and information system for inland navigation. It is composed of 
hardware, software for the operating system and application software. As such, these technical specifications 
detail primarily which minimum conditions need to be met by Inland ECDIS devices and software. As such, it 
also provides a basis for the type-approval of Inland ECDIS viewers (see EQ 3).  

50 The first four points are included in the minimum data requirements detailed in Annex I of the RIS Directive 

and are considered among the data for navigation and planning discussed under part 1 of EQ 1 above.  

20 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  official aids-to-navigation (e.g. buoys, beacons, lights, notice marks). 

The Implementing Regulation also details the data standard for electronic charts, i.e. the 
technical specifications to be used for the exchange of digital hydrographic data between 
national  inland  waterway  authorities,  as  well  as  for  its  distribution  to  manufacturers, 
skippers and other users51. It details that the data contained within electronic charts is to 
be encoded using (a) the Inland ENC Feature Catalogue, and (b) the rules described in the 
Inland ENC Encoding Guide.  

Benefits of electronic navigational charts  

No formal impact assessment was carried out prior to the adoption of the RIS Directive. 
Therefore, there are no official expectations of economic, social or environmental benefits 
against  which  to  measure  actual  benefits  brought  about  by  the  RIS  Directive  through 
changes regarding electronic navigational charts.  

Nevertheless, prior to its adoption, it was envisaged that52 electronic navigational charts 
could have a number of benefits for the sector. When skippers use up-to-date navigational 
charts, they are better informed about the fairway, and can therefore make better informed 
navigational decisions. More informed decision-making, in turn, is expected to lead to cost 
savings from better resource planning and optimised use of existing infrastructure, and to 
a  more  harmonised  approach  to  data  exchange  and  cross-border  coordination.  This,  in 
turn, is expected to increase the competitiveness of the sector as a whole and eventually 
lead to a modal shift. The degree to which these expected benefits have been achieved is 
outlined below, and presented in the elaborated causal pathway in Figure 5. 

Box 2. Summary of findings on EQ 1b - electronic navigational charts  

Availability of electronic navigational charts  

Electronic navigational charts are provided in all relevant Member States. However, 
the  coverage  of  electronic  charts  for  waterways  of  CEMT  class  Va  and  above  (as 
mandated by the RIS Directive) is not yet at 100%. Coverage is not yet at 100% in the 
Netherlands, Poland and Slovakia.  

All  relevant  Member  States,  along  with  non-EU  Member  States  that  voluntarily 
implement the RIS Directive, make their charts available for download free of charge on 
their respective websites. There is no indication of incompatibility between the charts 
and  the  technical  specifications  for  Inland  ECDIS  mandated  by  the  relevant 
Implementing Acts.  

Despite  the  fact  that  all  relevant  Member  States  make  electronic  navigational  charts 
available,  there  are  differences  in  their  quality  and  accuracy.  As  neither  the  RIS 
Directive  nor  its  Implementing  Acts  include  requirements  related  to  the  timeliness  of 
information  to  be  provided,  Member  States  themselves  decide  how  often  to  update 
charts. In most countries, this is done at least once a year, but in Bulgaria, for example, 
charts have not been updated since 2018. This can hinder the effectiveness of electronic 
navigational charts in achieving the expected benefits.  

Aside  from  the  fact  that  updates  are  not  mandated  by  the  RIS  Directive,  limited 
resources  are  a  hindering  factor  for  Member  States  in  making  electronic  charts 
available.  Measuring  and  providing  the  necessary  data  requires  significant  time  and 
money.  Although  limited  quantitative  details  on  the  costs  associated  with  this  are 
available, it was highlighted as an issue by seven of the thirteen relevant Member States. 

51 Commission Implementing Regulation (EU) 2018/1973, p. 15. The Inland ENC data standard is based on ‘IHO 
Transfer Standard for Digital Hydrographic Data’, Special Publication No 57, Edition 3.1 Supplement No 2 with 
all Appendices and Annexes, in brief ‘S-57’, as the RIS Directive mandates interoperability with maritime charts.  

52 These expectations are based on the 2006 “Assessment of the implementation of river information services in 
Europe”  prepared  by  ViaDonau  in  the  context  of  the  SPIN-TN  project,  combined  with  the  intervention  logic 
prepared at the onset of the present study.  

21 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Hence,  the  study  team  considers  this  to  be  a  strong  indication  of  reliability  of  the 
information.  

Benefits of electronic navigational charts  

Electronic  navigational  charts  are  highly  valued  by  users  of  the  waterways  and  RIS 
authorities alike as being a useful and beneficial tool for inland navigation.  

There  are  indications  that  the  availability  of  charts  has  benefitted  the  resource 
planning  of  waterway  users  as  their  availability  provides  users  with  the  fairway 
information necessary to efficiently and safely navigate the waterways. As such, it allows 
users to plan their voyages, especially if they are not familiar with a route. Nevertheless, 
there is no concrete evidence on time or money saved by users of the waterways 
as a result of this, due to a lack of data.  

Although there is no evidence to suggest a change in safety on inland waterways, there 
is a clear perception that safety has improved among RIS authorities and users alike. 
Although this relationship is likely influenced by the integration of AIS data on  ECDIS 
viewers, it is an important finding nevertheless.  

There  is  no  evidence  of  any  environmental  benefits  brought  about  by  electronic 
navigational charts as a result of the RIS Directive.  

Findings  

  All relevant Member  States make  electronic navigational charts available 

in line with the RIS Directive  

Research conducted suggests that electronic navigational charts are provided for all major 
European  Inland  Waterways.  In  June  2016,  a  total  of  13,042  km  of  waterways  had 
already been covered, with an additional 1,733 km planned. In most cases, the minimum 
content is provided. 

As  per  the  self-reported  data  contained  in  the  2018  fact-finding  study,  the  coverage  of 
electronic navigational charts on waterways of CEMT class Va and above is 100%53 in all 
relevant  Member  States,  except  the  Netherlands,  Poland  and  Slovakia.  The  study  listed 
Luxembourg as “not applicable” because they indicated that their charts are provided via 
the German ELWIS portal. As their stretch of the Mosel river which is applicable to the RIS 
Directive is shared with Germany, there is no need for both authorities to provide charts 
separately. As a result, coverage in Luxembourg is 100% as well.  

Slovakia is at 69% because charts are made available in full only for their stretch of the 
Vah river that falls under CEMT class Va and VIa. The Netherlands is a special case because 
it has the densest waterway network containing a variety of small and large waterways. 
Charts  are  fully  provided  for  the  majority  of  the  main  waterways,  while  some  shorter 
stretches are missing, though they are planned for production54. No details were provided 
for  Poland,  where  a  total  of  100.3  km  of  waterways  is  currently  covered  by  electronic 
charts55.  In  the  interview  with  the  Polish  RIS  authority,  it  was  stated  that  all  rivers 

53 Although not required by the RIS Directive, most Member States also provide electronic navigational charts 

for some smaller waterways, e.g. if they are considered relevant for traffic or if regional authorities in charge 
decide to make them available. This is done in all relevant Member States except for Poland and Slovakia 
according to the 2018 fact-finding study.  

54 The Dutch part of the Rhine Corridor still has approximately 104,5 km of waterway planned and of the North-

South corridor another 74km is planned to be charted. See 
http://ienc.openecdis.org/files/IENC_Prod_overview.pdf (Last accessed 16th October 2019).  

55 See http://ienc.openecdis.org/files/IENC_Prod_overview.pdf (Last accessed 16th October 2019). 

22 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

applicable to the Directive are currently covered, however, it is beyond the scope of this 
study to check whether this is indeed the case.  

Although  fact-checking  the  above  self-reported  findings  falls  outside  the  scope  of  the 
present study, none of the consulted RIS authorities mentioned any missing charts for the 
relevant waterways. As such, it is assumed that the above information is factually correct.  

All relevant Member States make the electronic charts  available for download free of 
charge  on  their  respective  websites56.  Links  to  all  of  these  websites  containing 
downloadable charts are also provided on the EU RIS Portal57. Luxembourg is not listed, 
again, because the electronic charts covering its stretch of the Mosel river are published 
on  the  German  ELWIS  website.  Switzerland,  Serbia  and  Ukraine  also  make  their  charts 
available for download via this portal. All of these downloadable charts are compatible with 
Free ECDIS Viewers (e.g. SevenCs) to be viewed for informational purposes. To be able to 
use the charts for navigational purposes, a professional ECDIS viewer58 is needed on board.  

  The  up-to-datedness  of  electronic  navigational  charts  varies  across 

corridors  

Although all Member States make electronic navigational charts available for waterways of 
CEMT class Va and above as required by the Directive, there are shortcomings in terms 
of their accuracy and up-to-datedness.  

As per the overview of inland electronic navigational charts maintained by the Inland ENC 
Harmonisation Group (IEHG), all Member States,  except for Croatia, provide updates to 
their charts. However, there are considerable differences between those who do. The latest 
update  to  electronic  navigational  charts  in  Bulgaria,  for  example,  dates  back  to  2018. 
Flanders, Hungary, Serbia and Ukraine (Danube part) reportedly update charts (at least) 
once per year59. Austria provides updates 3-4 times per year, and the Netherlands as often 
as once every 1-2 weeks, depending on the region60.  

This variance in rates of updates is considered by consulted stakeholders to be a hindering 
factor to the effectiveness of the RIS Directive with regards to electronic navigational 
charts. Four RIS authorities, two RIS developers, a user representative organisation and 
an  international  organisation  pointed  to  complaints  about  charts  not  being  sufficiently 
updated. According to that user representative organisation, there is a notable difference 
between regions in this respect, with Rhine countries updating their charts more frequently 
than those in the Danube. The interviewed Slovakian authority mentioned that their charts 
are  amongst  those  that  are  not  regularly  updated.  Paired  with  the  evidence  from 
documentary sources, it can be concluded that there indeed seems to be a trend in this 
respect61: updates in the Danube corridor tend to be less frequent compared to the Rhine, 
North-South and East-West corridors.  

Different rates of updates across countries hinder the accuracy of charts, which in turn has 
a negative impact on the usefulness of the charts, as elaborated in more detail below.  

56 See http://ienc.openecdis.org/files/IENC_Prod_overview.pdf (Last accessed 16th October 2019). 

57 See http://www.ris.eu/general/what_is_ris_/electronic_navig__charts__enc_ (Last accessed 19th October 

2019).  

58 Several companies such as Periskal and Tresco are specialized in putting user-friendly layers on the free 

available ENCs which are then sold in a full service package.  

59 Based on IEHG overview, supplemented with interview results. 

60 Based on IEHG overview, supplemented with interview results. 

61 See Table 2 “ENC implementation status on 22 February 2019 according to IEGH” in Annex 2 “Assessment of 

implementation at the level of individual Member States”.  

23 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  The RIS Directive provided the necessary legal basis for making electronic 
charts available but is not adequately clear on additional requirements  

A  total  of  eight  interviewed  stakeholders,  including  five  RIS  authorities62  and  two  RIS 
developers,  believe  the  RIS  Directive  provided  the  necessary  legal  basis  for  electronic 
navigational charts to be provided by Member State authorities. According to one authority, 
without the Directive this “would not [have been] done as fast or as well”, despite the fact 
that some of them reportedly waited until the technical specifications were published63.  

However, aside from specifying that electronic charts are to be provided by Member States, 
the Directive does not outline (beyond the minimum data for navigation and planning in 
Annex  I)  what  details  they  should  include  or  how  often  the  charts  need  to  be  updated. 
Further details on content were provided through the Implementing Acts, though there are 
still requirements on updates or minimum quality. A total of seven interviewees, among 
whom  four  RIS  authorities  and  two  RIS  developers,  stated  this  as  a  hindering  factor  in 
making electronic charts available. As previously outlined, added to this is the fact that not 
all countries measure and report on e.g. water levels in the same way. If the data is not 
measured in the same way, there is no comparability across countries, which may create 
barriers for cross-border traffic.  

  A lack of resources and political prioritisation seems to have slowed down 

the implementation of electronic navigational charts  

A  total  of  eight  different  RIS  authorities64,  as  well  as  one  representative  from  a  river 
commission, highlighted the lack of resources as a key factor that makes it difficult 
for  authorities  to  make  electronic  navigational  charts  available.  As  discussed  above, 
measuring and providing the necessary data for navigation and planning, which feeds into 
the  electronic  charts,  is  resource-intensive.  In  Czechia,  for  example,  national legislation 
requires charts to be updated twice a year. In reality, these deadlines are often not met 
because of a lack of staff65. In some cases, as specified by the Netherlands, the collection 
of the information necessary for the development of electronic navigational charts needs 
to be outsourced as a result of this pressure.  

Naturally, the more waterways of CEMT class Va or above a Member State has, the more 
resources  are  needed  to  provide  this  data.  That  explains  why,  in  the  Netherlands,  the 
coverage of electronic charts is not yet at 100%, compared to e.g. Luxembourg with only 
242km of relevant waterways.  

However, limited reliable quantitative evidence on costs associated with making electronic 
navigational charts available was provided by RIS authorities66, so it is difficult to assess 
exactly how much it cost them and how significant these costs were. The fact that more 
than half of the relevant Member States mentioned it to be an issue nevertheless indicates 
a high likelihood of this indeed being the case. More detail on the costs associated with 
making electronic charts available is included under EQ 8b. 

  Overall,  electronic  navigational  charts  are  considered  to  be  useful  and 

beneficial for skippers  

Stakeholder consultations carried out within the framework of the present study confirm 
that electronic navigational charts are highly valued across all different stakeholder 
groups  as  a  useful  and  beneficial  tool.  At  the  Common  Issues  meeting  at  RIS  Week  in 

62 Two of these five authorities are voluntary implementers of RIS.  

63 This was mentioned by an interviewed RIS authority.  

64 From Austria, Belgium, Czechia, Luxembourg, the Netherlands, Romania and Slovakia.  

65 This was explained by the RIS authority in Czechia.  

66 See Question 23 and 24 in section 5.2.4., Annex 1 “Findings from the survey questionnaires” to the Stakeholder 

Consultation Report. 

24 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Galați, for example, electronic navigational charts were ranked by as the RIS instrument 
with the most positive impact on the sector by 30% of all participants67. In the open public 
consultation, electronic navigational charts were listed as being “very  useful” or “mostly 
useful”  by  all  37  respondents  who  provided  input68.  All  nine  surveyed  skippers  believed 
electronic  charts  to  be  useful  for  their  day-to-day  activities,  and  all  interviewed 
stakeholders  who  had  an  opinion  on  the  matter  believe  they  have  been  useful  and 
beneficial to skippers. Considering the overwhelming positive views of stakeholders on this 
topic, this finding is considered robust.  

Economic benefits  

  There  are  indications  that  electronic  navigational  charts  have  benefitted 

the resource planning of waterway users  

Research  suggests  that  electronic  navigational  charts  have  benefitted  the  resource 
planning of waterways users by making journeys more efficient, both in terms of time and 
costs, though no robust conclusion on the magnitude of costs and time saved can 
be made on the basis of available evidence.  

A survey carried out by the CCNR in 2017 found that 663 out of the 933 surveyed skippers 
believe that the implementation of Inland AIS and Inland ECDIS have contributed to safer 
and quicker navigation. However, the results seem primarily focused on AIS technology, 
and its impact on safety, rather than providing insight on electronic charts and their impact 
on speed of navigation. Stakeholders interviewed in the context of the present study show 
a similar line of thinking, often focusing on the benefit of integrating electronic charts and 
AIS/VTT  technology.  For  example,  user  representative  organisations  highlighted  that 
electronic charts help voyage planning because they show bottlenecks and traffic, which 
help  plan  skippers’  time  of  arrival.  Traffic  figures,  however,  are  the  result  of  AIS,  not  a 
direct effect of the availability of electronic charts.  

Nevertheless, it is clear from consultations carried out that the charts themselves are still 
valued  for  their  positive  impact  on  voyage  planning.  Six  RIS  authorities,  along  with 
four  RIS  developers,  agree  -  they  explained  that  the  RIS  Directive  has  enhanced  the 
information on the fairway that is available to users of the waterways through  electronic 
navigational  charts.  For  example,  if  a  skipper  is  sailing  somewhere  they  have  not  been 
before, electronic charts provide all the necessary information on the fairway to make more 
informed navigation decisions. In this context, it is important for the charts to be accurate 
and updated, as many (younger) waterway users reportedly rely on the charts to navigate, 
so missing or inaccurate elements can create problems.  

  There is no concrete evidence suggesting time or cost savings as a result 

of improved resource planning 

Despite indications that resource planning has improved, there is no concrete evidence 
that this has resulted in cost or time savings. Of the six skippers who provided input 
to  the  questionnaire,  half  indicate  a  small  increase  in  costs  associated  with  electronic 
navigational  charts,  and  the  other  half  indicate  a  small  decrease69.  More  details  on  the 
costs associated with electronic navigational charts and how they compare to the benefits 
are provided under EQ 8b. 

67 See Question 7 in section 8.1., Annex 4 “Findings from the events attended” to the Stakeholder Consultation 

Report.  

68  See  Question  2  in  section  7.2.2.,  Annex  3  “Findings  from  the  open  public  consultation”  to  the  Stakeholder 

Consultation Report.  

69  See  Question  23  in  section  5.3.3.,  Annex  1  “Findings  from  the  survey  questionnaires”  to  the  Stakeholder 

Consultation Report  

25 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Social benefits  

  Stakeholders  believe  electronic  navigational  charts  improved  safety  in 

inland navigation  

Waterway users and RIS authorities agree that safety in inland navigation has improved 
thanks to electronic navigational charts, representing a social benefit.  

Eight of the nine skippers who provided input to the questionnaire noted improved safety 
as a benefit on electronic charts, and seven interviewed RIS authorities agreed. However, 
there  is  no  evidence  of  a  direct  correlation  between  the  availability  of  electronic 
navigational charts and a change in accident rates or safety in inland navigation due to a 
lack of reliable data.  

It should be noted that three of the seven interviewed authorities who were of this opinion 
made reference to AIS as being a key contributor to improved safety. This highlights the 
interconnectedness of RIS technologies, and their potential to improve the magnitude of 
benefits produced when they are fully interoperable. More details on the topic of improved 
safety are included under EQ 6c on improved safety. 

Environmental benefits  

  There is no evidence of environmental benefits brought about by electronic 

navigational charts  

Although  intended,  through  their  effect  on  more  informed  navigational  decisions  and 
voyage planning, there is no evidence that electronic navigational charts have reduced the 
negative  environmental  impact  of  the  inland  navigation  sector.  While  five  of  the  nine 
waterway  users  identified  less  fuel  consumption  as  a  benefit  of  the  charts  in  the 
questionnaire, there is little reason to believe that the availability of the charts themselves 
have  had  an  impact  in  this  regard.  Again,  paired  with  AIS  technology,  which  inter  alia 
includes  information  on  traffic  density,  electronic  charts  are  likely  to  have  more  of  an 
impact in this regard. More details on the topic of reduced negative environmental impact 
are included under EQ 6d on increased environmental protection. 

26 

Figure 5. Causal pathway – Electronic navigational charts 

Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

27 

 
 
Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

C. 

Notices to Skippers (NtS) 

Context  

Availability of notices to skippers  

The RIS Directive stipulates that Member States shall ensure that “notices to skippers, 
including  water  level  (or  maximum  allowable  draught)  and  ice  reports  of  their  inland 
waterways,  are  provided  as  standardised,  encoded  and  downloadable  messages”70. 
According  to  the  Directive,  these  standardised  messages  should  contain  “at  least  the 
information  necessary  for  safe  navigation”  and  be  provided  at  least  in  an  “accessible 
electronic format”71. In its Annex, the Directive further specifies that notices to skippers 
shall respect “a standardised data structure using predefined text modules and encoded to 
a high extent in order to enable automatic translation of the most important content into 
other languages and to facilitate the integration of notices to skippers into voyage planning 
systems”; and “the compatibility of the standardised data structure with the data structure 
of inland ECDIS to facilitate integration of notices to skippers in inland ECDIS”72. Detailed 
technical  standards  were  imposed  through  Commission  Regulation  (EC)  No  416/2007 73, 
and  subsequently  updated 
through  Commission  Implementing  Regulation  (EU) 
2018/203274.  In  short,  this  means  that  RIS  authorities  are  required  to  provide 
messages  that  are  necessary  for  safe  navigation  via  Internet  following  a  standardised 
structure and encoded format, using the NtS “extensible markup language” (XML) schema 
definition75.  

The  following  messages  need  to  be  provided  by  all  RIS  authorities  on  all  waterways  to 
which the Directive applies:  

 

fairway  conditions  and  traffic  (FTM),  containing  information  on  any  limitations 
relating to a fairway or a specific location; 

  water levels (WRM), containing the water level measurement at a specific location;  

 

ice (ICEM), containing information about the ice conditions for a fairway. 

Weather-related  messages  (WERM),  containing  information  about  (dangerous)  weather 
conditions on a fairway, may be provided but are optional.  

All information that is important for the safety of inland navigation (e.g. obstacles that can 
post safety risks) or voyage planning (e.g. unforeseen closure of locks) must be encoded, 
while  additional  information  that  is  not  relevant  for  safety  or  voyage  planning  (e.g.  the 
cause  of  such  a  closure)  can  be  provided  using  free  text76.  The  use  of  free  text  should, 
however, be restricted to a minimum77.  

70 Article 4 (3d), Directive 2005/44/EC 

71 Article 4(3d), Directive 2005/44/EC 

72 Annex II (4), Directive 2005/44/EC 

73 Commission Regulation (EC) No 416/2007 of 22 March 2007 concerning the technical specifications for Notices 
to Skippers as referred to in Article 5 of Directive 2005/44/EC of the European Parliament and of the Council 
on harmonised river information services (RIS) on inland waterways in the Community 

74 Commission Implementing Regulation (EU) 2018/2032 of 20 November 2018 amending Commission Regulation 

(EC) No 416/2007 concerning the technical specifications for Notices to Skippers 

75  This  XML  schema  was  first  detailed  in  Commission  Regulation  (EC)  No  416/2007  and  later  revised  through 

Commission Implementing Regulation (EU) 2018/2032.  

76  Commission  Implementing  Regulation  (EU)  2018/2032,  section  1.2  Primary  functions  and  performance 

requirements for Notices to Skippers (NtS) 

77  Commission  Implementing  Regulation  (EU)  2018/2032,  section  1.2  Primary  functions  and  performance 

requirements for Notices to Skippers (NtS) 

28 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

The  use  of  a  standardised  encoded  format  allows  for  the  notices  to  be  automatically 
translated; it also facilitates the data-exchange among the systems of different countries 
and towards other applications making use of notices to skippers’ data, including Inland 
ECDIS.  

The Directive and associated technical standards only require the Member States to make 
notices available online and via standardised Web Services. The notices can additionally be 
provided via mobile apps or e-mail services, though this is not mandatory. 

Lastly, the 2007 technical standards stipulate that data exchange between the authorities 
is recommended78. The RIS authorities can integrate notices to skippers of other authorities 
and  countries  in  their  own  services,  by  transmitting  the  XML  messages  by  push  or  pull 
services directly. The revised standards in 2018 state that data exchange among notices 
to skippers’ systems in different countries may be carried out79. 

Benefits of notices to skippers  

No formal impact assessment was carried out prior to the adoption of the RIS Directive. 
Therefore, there are no official expectations of economic, social or environmental benefits 
against  which  to  measure  actual  benefits  brought  about  by  the  RIS  Directive  through 
changes regarding notices to skippers.  

Nevertheless, prior to its adoption, it was envisaged that80 the RIS Directive would produce 
a  number  of  benefits  through  the  standardisation  of  notices  to  skippers.  As  notices  to 
skippers  provide  information  about  issues  regarding  the  waterway  that  might  influence 
safety and accessibility to users of the waterways, they are intended to lead to cost savings 
from  better  resource  planning  on  the  side  of  RIS  users.  They  are  expected  to  lead  to 
harmonised data exchange and communication across borders as standardised notices are 
auto-translated and can be integrated in other systems (i.e. those of other countries and 
other  software like Inland ECDIS) and should also contribute to improved safety.  In the 
long term, cost savings and harmonisation of notices to skippers are  expected to lead to 
an  interoperable  RIS  system,  and  in  turn  improve  the  competitiveness  of  the  inland 
navigation  sector  as  a  whole.  Ideally,  this  would  lead  to  a  modal  shift  and  reduce  the 
negative  impact  of  the  sector  on  the  environment.  The  degree  to  which  these  expected 
benefits  have  been  achieved  is  outlined  below,  and  presented  in  the  elaborated  causal 
pathway in Figure 6. 

Box 3. Summary of findings on EQ 1c - notices to skippers 

Availability of notices to skippers  

All relevant Member States make mandatory notices to skippers (containing information 
on FTM, WRM, ICEM) available on waterways of CEMT class IV and above to some extent.  

 

In  Hungary, Poland and Slovakia, coverage  of  the relevant waterways has not  yet 
reached 100%.  

However, there are indications that the notices to skippers are not always in line with 
the  requirements  of  the  Directive  in  terms  of  being  encoded,  downloadable,  and 
following the common technical standards detailed in the relevant Implementing Acts.  

As a result, there is a lack of consistency across Member States in the degree to which 
notices  to  skippers  are  made  available,  which  in  turn  limits  the  degree  of 

78 Commission Regulation (EC) No 416/2007, section 4: Way of Distribution  

79 Commission Implementing Regulation (EU) 2018/2032, section 2: Provision of notices to skippers  

80 These expectations are based on the 2006 “Assessment of the implementation of river information services in 
Europe”  prepared  by  ViaDonau  in  the  context  of  the  SPIN-TN  project,  combined  with  the  intervention  logic 
prepared at the onset of the present study.  

29 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

interoperability.  This  in  turn  hinders  the  effectiveness  of  standardised  notices  to 
skippers.  

  Variance  in  the  means  of  distribution  makes  notices  difficult  to  access  from  a 
skipper’s perspective. Skippers need to visit several websites to collect the necessary 
information for an international trip.  

  There is very limited automatic exchange of notices between skippers across borders. 
Only Austria and the Netherlands share notices automatically via their web services 
in  line  with  the  new  NtS  standard  version  4.0.  Although  it  is  not  required  by  the 
Directive, cross-border exchange is encouraged.  

The  availability  of  notices  to  skippers  is  reportedly  hindered  by  the  complexity  of  the 
technical  requirements,  which  require  time  and  technological  know-how.  There  are 
indications  that  clearer  or  simpler  guidelines  might  help,  although  they  are  already 
extensive and periodically improved through the expert group on notices to skippers.  

Benefits of notices to skippers  

Findings  from  this  study  do  not  allow  for  robust  conclusions  to  be  drawn  on  the 
extent to which standardised notices to skippers have brought about economic, social, 
or  environmental  benefits  due  to  limitations  in  the  quantitative  evidence  available  to 
support stakeholder claims.  

Nevertheless,  it  is  apparent  that  relevant  stakeholders  acknowledge  the  usefulness  of 
standardised  notices  to  skippers,  and  that  they  are  an  improvement  relative  to  the 
situation prior to the RIS Directive. The main benefits experienced by stakeholders are 
as follows:  

  Better voyage planning resulting from the availability of real-time information on 
traffic,  weather,  water  levels,  etc.,  although  this  benefit  only  materialises  when 
authorities provide up-to-date information in an accessible format;  

  Improved  safety  and  lower  accident  rate  resulting  from  better  planning  through 

traffic information, as perceived by skippers and authorities alike;  

  Improved  communication,  facilitated  by  the  automatic  translations  of  encoded 
notices to skippers, which is conditional to the messages being provided in line with 
the requirements of the Directive.  

Although  expected,  there  is  no  convincing  evidence  to  suggest  that  standardised 
notices  to  skippers  have  led  to  time  or  cost  savings  resulting  from  more  efficient 
navigation and better information. On the contrary, there are indications that skippers 
still waste time collecting notices from several websites due to the lack of cross-border 
exchange of notices.   

Findings  

  Notices to skippers are made available in all relevant Member States but 
there  is  variance  in  the  degree  to  which  they  conform  to  the  technical 
specifications  

In 2018, the fact-finding study on the practical and operational measures in application of 
the RIS Directive81 found – on the basis of self-reported data - that all relevant Member 

81 STC-NESTRA and TNO, Fact-finding study on the practical and operational measures in application of the RIS 
Directive, 2018. The 2018 fact-finding study was based on a survey to collect and analyse practical information 
about River Information Services as implemented in the Member States. It gathered data from the 13 Member 
States  to  whom  the  RIS  Directive  applies  (Austria,  Belgium,  Bulgaria,  Croatia,  Czechia,  France,  Germany, 
Hungary,  Luxembourg,  Netherlands,  Poland,  Romania  and  Slovakia),  as  well  as  the  voluntary  implementers 
(e.g. Spain, Portugal, Italy). The survey did not cover non-EU Member States implementing the RIS Directive 

30 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

States, except Hungary, Poland and Slovakia, fully complied with the requirements of the 
Directive  with  regards  to  making  available  the  mandatory  notices  to  skippers 
(containing information on FTM, WRM, ICEM) on waterways of CEMT class IV and above. 
Hungary, Poland and Slovakia reportedly do make notices to skippers available, although 
they did not reach 100% coverage of the relevant waterways82. In most cases, the notices 
are reportedly provided in an encoded and downloadable format. 

However, evidence collected in the context of this study points to  some gaps in actual 
availability  of  the  notices  and  therefore  contradicts  some  of  the  self-reported  data 
presented  in  the  fact-finding  study.  Although  all  eleven  Member  States  that  were 
interviewed  indicated  that  the  mandatory  notices  to  skippers  have,  in  general,  been 
adequately  made  available  in  the  relevant  countries83,  three  private  sector  interviewees 
stated that Hungary stopped providing notices to skippers digitally, and that the service 
level in Romania is also limited84. Two interviewees (one port authority in Belgium and one 
skipper in Romania) also mentioned that ports do not provide notices to skippers at all, or 
that their notices are not integrated in national-level portals.  

Even in countries that provide notices to skippers on all relevant waterways as required by 
the Directive, there are a number of limits to their availability. Seven interviewees pointed 
out that some countries use too much free text rather than applying the XML coding, 
which in turn hinders the automatic translation and interoperability with ECDIS systems 
envisaged by the RIS Directive. Romania and Bulgaria were listed as examples, although 
the authorities in those countries did not comment on those concerns.  

  There is no harmonised approach to the availability and sharing of notices 

to skippers, which impacts their effectiveness  

There are differences between Member States in the dissemination methods and ability 
to deliver information on time. All relevant Member States publish their notices on their 
respective  websites85,  most  countries  send  notices  via  e-mail86,  and  a  few  disseminate 
them via mobile phone apps87 or SMS notifications88. Some authorities (e.g. Belgium, the 
Netherlands) provide their services 24 hours, seven days a week, while others work with 
closing  hours  (e.g.  Austria,  Slovakia,  Serbia).  As  a  result,  the  quality  of  information 
delivered through notices to skippers is also affected.  One RIS authority suggested that 
including requirements about the timing of notices to skippers, e.g. mandating that they 
should be made available 24/7, rather than only what they need to look like, might solve 
this discrepancy.  

Similarly, although the Directive does not mandate data exchange, it encourages Member 
States to share data by integrating other countries’ notices in their own systems. This is 
made possible by the use of standardised, encoded notices (that can be auto-translated), 

(e.g. Serbia, Ukraine, Switzerland). The surveys were pre-filled with publicly available data, and completed by 
respondents themselves. As such, the findings are predominantly based on self-reported data and may not be 
fully reliable. 

82 A detailed overview of the types of notices and their degree of coverage is presented in Table 17 in Annex 2 

“Assessment of implementation at the level of individual Member States”. 

83 See section 6.1. on notices to skippers, Annex 2 “Findings from the interviews” to the Stakeholder Consultation 

Report.  

84  One  skipper  active  in  Romania  explained  that  until  recently,  notices  to  skippers  were  printed,  signed,  and 
photographed,  and  the  resulting  pdf  file  uploaded  to  the  Romanian  RIS  portal  (RoRIS).  Their  quality  has 
improved, but a quick scan of the portal shows that not all notices are automatically translated, indicating a 
lack of adequate encoding.  

85 except for Luxembourg who makes notices available via ELWIS (the German platform). This is in line with the 

requirements of the Directive, as it does not specify that each country should have its own website.  

86 Austria, Belgium, Bulgaria, Czechia, Germany, France, Hungary, Luxembourg, Netherlands, Poland, Romania 

(possible but not in use), Slovakia 

87 Austria, Bulgaria, Luxembourg  

88 Belgium, Luxembourg, Slovakia  

31 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

but requires Member States to take an additional step in providing and receiving encoded 
data from each other. In reality, only the applications of Austria (DoRIS web app) and the 
Netherlands (vaarweginformatie web app) are mutually exchanging data in line with WSDL 
2.0.4.089,  although  a  number  of  interconnections  between  national  applications  are  in 
preparation or planned for the near future90.  

While these aspects are not all directly related to provisions in the Directive, they affect 
the actual effectiveness of notices to skippers and reduce the benefits that can 
be achieved. Checking the degree to which the Member States comply with the technical 
specifications is beyond the scope of this study. Nevertheless, such factors influence the 
availability of notices to skippers, and thereby have an impact on the degree to which they 
bring about benefits for skippers and the sector as a whole, and as such are important to 
record here. More details about the benefits and factors which hinder benefits are detailed 
under EQ 8c.  

  Member  States  encountered  a  number  of  hindering  factors  to  making 

notices to skippers available 

The differences between Member States can in part be explained by a number of factors 
which hindered the authorities’ ability to make notices to skippers available. Four out of 
the six RIS authorities (Austria, Belgium (Flanders), Czechia, Slovakia) that completed the 
questionnaire as part of this study indicated that they encountered difficulties in making 
notices  to  skippers  available,  most  notably  due  to  technical  issues  with  the 
software/hardware  needed  to  publish  standardised,  encoded  notices  to  skippers, 
aggravated  by  limited  IT  knowledge.  Providing  encoded  and  downloadable  messages 
requires the availability of an up-to-date RIS Index, and the involvement of someone who 
understands how encoding works (i.e. implying the mobilisation of additional resources91, 
adept with IT issues). A lack of resources was cited by two national level interviewees as 
being a hindering factor in some countries, though these interviewees did not experience 
the issue themselves.  

Three interviewed stakeholders, among which a representative of the Danube corridor and 
two  national  administrations,  explained  that  there  is  scope  to  further  clarify  the 
requirements  on  notices  to  skippers,  citing  a  lack  of  guidance  as  a  reason  why 
harmonisation has not yet been achieved. Although the RIS Directive itself indeed is limited 
in its explanation of what notices to skippers should look like (beyond being “standardised”, 
“encoded”  and  “downloadable”),  its  accompanying  Implementing  Acts  outline  in  great 
detail  the  technical  specifications.  This  includes  a  detailed  encoding  guide92  and  XML 
schemes93  providing  information  on  how  to  code  messages  and  what  the  coded  data 
means.  Three  authorities94  specified  that  the  new  standards,  as  recently  revised  in  the 
Expert Group on Notices to Skippers (RIS-NTS)95, are a great improvement.  

Relatedly, two RIS authorities96 highlighted that the lack of enforcement of the Directive is 
to blame for the lack of a harmonised approach. Although a statement by two people is 
not sufficient to base conclusions on, this concern was raised by others in the context of 

89 Based on an assessment from June 2018, retrieved from: 

http://www.ris.eu/library/expert_groups/nts/implementation_status (Last accessed 9th October).  

90 See http://www.ris.eu/library/expert_groups/nts/nts_version_4_0  

91 Prior to the adoption of the RIS Directive, many countries already provided notices to skippers, though in paper 
format. As such, some degree of training was necessary to switch over to digital notices, especially considering 
the complex XML coding standards. 

92  Appendix  A  “NtS  Encoding  Guide  for  editors”  and  B  “NtS  Encoding  Guide  for  application  developers”  to 

Commission Implementing Regulation (EU) 2018/2032 

93 Appendix C “NtS XML Schema Definition” to Commission Implementing Regulation (EU) 2018/2032 

94 France, Slovakia, Serbia  

95 See https://ris.cesni.eu/  

96 Austria, Belgium (Flanders)  

32 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

the Directive more broadly as well. These interviewees did not provide much detail on why 
they believe the Directive was not adequately enforced, however, the results from the open 
public  consultation  shed  more  light  on  this97.  Not  a  single  respondent  believes  the  EU 
properly implemented the monitoring of the application of the Directive, detailing that there 
is  no  visible  enforcement  or  pressure  towards  the  Member  States  to  comply  with  its 
requirements.  

  In general, notices to skippers are highly valued and considered useful to 

skippers  

Stakeholder  consultations  carried  out  in  the  context  of  this  study  confirm  that  the 
overwhelming  majority  of  RIS  stakeholders  acknowledge  that  standardised  notices  to 
skippers have been beneficial to the sector as a whole, and are useful to skippers. Notices 
to  skippers  were  listed  as  the  second  most  useful  RIS  technology,  with  only  one 
respondent98 indicating them to be “mostly not useful” in the open public consultation. Of 
the seven waterway users that replied to the questionnaire, five99 confirmed that notices 
to  skippers  have  been  useful  for  them  in  their  day-to-day  activities.  The  other  two  are 
respondents who do not make use of notices to skippers in their day-to-day operations, so 
their  responses  do  not  carry  much  weight.  A  total  of  23  interviewees100  confirmed  this, 
listing  the  automatic  translation  of  encoded  messages  and  the  integration  with  Inland 
ECDIS software as main enabling factors in this regard.  

Thus,  although  there  is  limited  evidence  on  the  creation  of  tangible  economic,  social  or 
environmental  benefits  of  the  RIS  Directive  through  the  standardisation  of  notices  to 
skippers, it is an improvement relative to the situation prior to the RIS Directive primarily 
because they have reportedly simplified the day-to-day operations of skippers and has not 
had any negative impacts. 

  There  is  limited  evidence  on  the  existence  and  magnitude  of  benefits  of 

notices to skippers  

Desk  research  produced  no  evidence  on  the  actual  benefits  brought  about  by  the  RIS 
Directive concerning standardised notices to skippers. Thus, the assessment of magnitude 
of benefits of the notices to skippers presented in this report is based only on stakeholder 
feedback and the contractor’s own judgement. In general, the perception of standardised 
notices to skippers is positive  – twenty-eight interviewed stakeholders across all groups 
believe they bring added value to the sector, and only one was of the opinion that they did 
not bring any101.  

Economic benefits  

  Notices  to  skippers  improved  information  and  planning  but  there  is  no 

evidence of actual cost savings for skippers  

Seventeen  stakeholders  across  all  different  groups  agree  that  standardised  notices  to 
skippers have led to the availability of timely information through notices to skippers, 
which in turn allows for better planning. However, only two of them highlighted that 

97 See Question 13 in section 7.2.8., Annex 3 “Findings from the open public consultation” to the Stakeholder 

Consultation Report.  

98 This is a skipper who is primarily active in the Netherlands. It is possible that the notices are just not useful to 
him specifically, because he makes no use of them. The reasoning was not specified, however. See Question 2 
in section 7.2.2., Annex 3 “Findings from the open public consultation” to the Stakeholder Consultation Report. 

99 Two of them operate primarily on the Danube, two on the Rhine, and one on the Elbe. 

100 Including two European-level user associations, three national-level user associations and six RIS developers, 

as well as 11 public bodies. 

101 This was stated by a skipper active in Romania, who believes there are no benefits because the system does 
not  work  there.  Nevertheless,  the  interview  suggested  he  knows  notices  to  skippers  can  have  significant 
benefits, so his opinion does not extend to other Member States.  

33 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

this led to actual savings in terms of time and costs – one of them stating that the time 
and money spent on administration decreased only marginally.  

Interviewed skipper associations and RIS authorities explained, in line with the  expected 
economic benefits of notices to skippers, that skippers can adapt their course if they can 
anticipate obstacles on their route102. For example, low water messages allow skippers to 
optimise the path they are sailing, and fairway traffic messages can help skippers avoid 
traffic. This was confirmed by all four questionnaire respondents (a vessel owner/broker; 
a vessel owner/shipper; two vessel owners) who indicated they use notices to skippers - 
they  believe  notices  are  necessary  because  they  contain  the  latest  information  about 
changes on the waterway, which in turn helps them with voyage planning. Although the 
expectation  is  that  better  planning  should  lead  to  cost  savings  from  arriving  at  one’s 
destination faster (e.g. by avoiding traffic or a non-operational lock), there is no robust 
evidence to support that such savings actually occurred.  

  There is no evidence of improved competitiveness as a result of notices to 

skippers  

There is no evidence to suggest that notices to skippers have (directly or indirectly) led to 
increased competitiveness of the inland navigation sector, although one RIS developer did 
indicate that the standardised notices have led to innovation, which in turn improves the 
competitive advantage of inland navigation over other modes of transport.  

Social benefits  

  Stakeholders  believe  notices  to  skippers  have  improved  safety  and 

communication in inland navigation  

Although it cannot be confirmed through quantitative data analysis103, it is safe to conclude 
that relevant stakeholders believe the inland navigation sector has become safer as a result 
of standardised notices to skippers.  

As a result of better-informed voyage planning, all six RIS users who provided input via 
the questionnaire believe notices to skippers have increased safety as they are important 
for  safe  navigation  and  they  helped  avoid  accidents.  They  explained  that  water  level 
messages  concerning  bridge  passages  can  avoid  collision  with  infrastructure,  and 
messages  related  to  traffic  can  help  avoid  collisions  between  ships.  Three  interviewed 
stakeholders (one European-level association and two authorities) shared this perception.  

Similarly, although evidence collected suggests that there is limited automatic cross-border 
exchange  of  notices  to  skippers,  waterway  users  themselves  believe  it  has  improved 
cross-border communication. All six questionnaire respondents agree that using notices 
to skippers improved communication; though they did not provide further clarifications, a 
total of 10 interviewees104 cited automatic translations as a helping factor in this regard.  

Environmental benefits  

  There is no evidence of environmental benefits of the notices to skippers  

Although  four  waterway  users  who  responded  to  the  questionnaire  believe  notices  to 
skippers have led to a reduction in fuel consumption through better voyage planning105, 
there is no evidence to suggest this is indeed the case. They explained that having up-to-

102 See section 6.1. on notices to skippers, Annex 2 “Findings from the interviews” to the Stakeholder Consultation 

Report.  

103 See Annex 6 “Ex-post social cost-benefit analysis” for details on the reliability of the data  

104 Three user representative organisations and seven national/international organisations 

105  See  Question  46  in  section  5.3.4.,  Annex  1  “Findings  from  the  survey  questionnaires”  to  the  Stakeholder 

Consultation Report 

34 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

date information about the fairway can help skippers get to their destination faster or allow 
them  to  adjust  their  speed  for  temporary  obstructions.  Indirectly,  this  should  lead  to  a 
reduced negative environmental impact, but this is mere speculation and not backed up 
by concrete evidence.  

35 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS)  

Figure 6. Causal pathway - Notices to skippers 

36 

 
 
Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.1.2.  Electronic ship reporting  

EQ 2: Compared  to  what  would  have  happened  in  absence of  the Directive,  in  quantitative  and qualitative 
terms, to what extent have electronic ship reports reduced re-submissions when crossing a border and led to 
cost savings for the users of the waterways and Competent Authorities? 

Context  

The RIS Directive mandates that Member States should “enable, as far as ship reporting is 
required  by  national  or  international  regulations,  the  competent  authorities  to  receive 
electronic  ship  reports  of  the  required  data  from  ships.  In  cross-border  transport,  this 
information  shall  be  transmitted  to  the  competent  authorities  of  the  neighbouring  State 
and  any  such  transmission  shall  be  completed  before  arrival  of  the  vessels  at  the 
border”106. As such, it does not make the submission of electronic ship reports mandatory, 
but merely regulates their processing when they are submitted. The main change brought 
about  by  the  RIS  Directive  in  this  context,  therefore,  is  that  it  outlines  the  need  for 
competent authorities to share the ship reports with the relevant neighbouring states.  

In its Annex107, the Directive further specifies that the technical specifications for electronic 
ship  reporting  in  inland  navigation108  should  (a)  facilitate  the  electronic  data  exchange 
between  competent  authorities,  between  participants  in  inland  as  well  as  maritime 
navigation  and  in  multi-modal  transport  where  inland  navigation  is  involved;  (b)  be 
standardised  to  ensure  compatibility  with  maritime  navigation;  (c)  be  based  on 
internationally  accepted  code  lists  and  classifications,  and  (d)  make  use  of  a  unique 
European vessel identification number.  

In  2010,  the  European  Commission  adopted  an  Implementing  Regulation  detailing  the 
technical requirements and standards to be followed for electronic ship reporting in inland 
navigation109. It details requirements for four different messages:  

 

(Dangerous) goods reporting (IFTDGN) — ERINOT 

  Passenger and crew lists (PAXLST) 

  ERINOT response and receipt message (APERAK) — ERIRSP 

  Berth management port notification (BERMAN) 

The  technical  requirements  also  reiterate  that  they  are  applicable  “in  the  case  that 
electronic ship reporting in inland navigation is required by national or international law”110. 
They  further  detail  that  “the  use  of  XML  technology  is  another  possibility”  but  does  not 
make this mandatory.  

The  common  European  reporting  standard  intends  to  help  facilitate  electronic  data 
exchange and should eliminate (or at least reduce) the number of resubmissions of vessel 
reports during an international voyage. The electronic reporting uses a set of codes that 
translates  information  concerning  cargo,  origin  and  destination  in  any  given  language, 
which facilitates this process.  

106 Article 4 (3c), Directive 2005/44/EC  

107 Annex II (3) “Electronic ship reporting”, Directive 2005/44/EC  

108 Article 5 (1b) mandates that the Commission shall define “technical guidelines” and “technical specifications” 

for electronic ship reporting  

109 Commission Regulation (EU) No 167/2010 on the technical specifications for electronic ship reporting in inland 
navigation referred to in Article 5 of Directive 2005/44/EC of the European Parliament and of the Council on 
harmonised river information services (RIS) on inland waterways in the Community, 25th January 2010.  

110 Commission Regulation (EU) No 167/2010, p. 4 

37 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

In turn, this would lead to cost savings previously associated with resubmissions for users 
of  waterways,  cost  savings  for  providers  and  users  of  waterways  resulting  from  more 
optimised  use  of  infrastructure  and  better  resource  planning  and  improve  cross-border 
coordination through removing technical barriers to continuous cross-border traffic. In the 
long  run,  this  is  expected  to  help improve  interoperability, improve  safety  and  security, 
increase the competitiveness of the inland navigation sector and promote a modal shift. 
The  degree  to  which  these  expected  benefits  have  been  achieved  is  outlined  below  and 
presented in the elaborated causal pathway in Figure 7. 

Box 4. Summary of findings on EQ 2 - electronic ship reports  

Despite  the  lack  of  reliable  quantitative  evidence  to  signal  a  change  in  resubmissions 
when  crossing  borders  on  an  international  trip,  evidence  collected  from  stakeholders 
consulted  strongly  suggests  that  there  has  not  been  a  reduction 
in 
resubmissions, as vessel information still needs to be reported more than once on an 
international voyage. The evidence is considered robust because of the large number of 
interviewees who share the same views, and the examples given in support thereof.  

The main hindering factor to electronic ship reporting is the lack of harmonisation 
across countries. The Directive does not mandate specific requirements or details on how 
electronic ship reports are to be shared. As a result, Member States have different legal 
obligations,  requiring  different  vessel  information,  which  hinders  the  reduction  of 
resubmission even if authorities share data across countries.  

Additionally,  data  protection/privacy  concerns  hinder  the  degree  to  which  data  is 
shared between competent authorities.  

There  is  no  evidence  of  cost  savings  for  users  of  the  waterways,  notably  because 
there has not been a reduction in resubmissions. Despite this, there is a strong indication 
that cost savings, among other (indirect) benefits such as efficient calamity abatement, 
would  materialise  if  electronic  ship  reporting  was  implemented  in  a  harmonised, 
interoperable way.  

Findings  

  There  has  not  been  a  reduction  in  the  number  of  resubmissions  when 

crossing a border  

No  reliable  quantitative  evidence  on  the  number  of  electronic  ship  reports  received, 
processed and  passed  on was provided by RIS authorities, and the lack of a baseline in 
this  regard  makes  it  impossible  to  compare  the  changes  brought  about  by  the  RIS 
Directive.  Nevertheless,  there  is  a  clear  common  acknowledgement  across  stakeholder 
groups  that  the  number  of  resubmissions  has  not  decreased  since  the  Directive 
entered into force.  

Given the fragmented technical, procedural, organisational and regulatory environment in 
the IWT sector, barge operators indicate that they still need to file the same data multiple 
times to comply with different aspects of legislation and dealing with different jurisdictions 
in cross-border operations111. Although the questionnaire produced mixed results, with two 
RIS users indicating a small reduction in resubmissions and two indicating no change112, 

111 European Commission (2017), Digital Inland Waterway Area - Towards a Digital Inland Waterway Area and 
Digital Multimodal Nodes, see https://ec.europa.eu/transport/sites/transport/files/studies/2017-10-dina.pdf 

112 In case of the former, both respondents operate on the Danube. In case of the latter, one skipper operates on 
the Danube and one on the Rhine, so there is no clear geographical pattern. It should be noted that there were 
more users operating on the Danube that responded to the questionnaire in total, so this can also skew the 

38 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

the  majority  of  interviewed  stakeholders113  believe  that  there  has  not  been  a  decrease. 
The five interviewees114 who speculate that there has been a decrease, note that this differs 
between countries/regions – two of them stating there has been a decrease on the Rhine 
because of the CCNR obligation to report for container115 and tanker barges116, but not on 
the Danube117.  

Although based on stakeholder views, this finding is considered robust because so many 
interviewees from different stakeholder groups and different countries agreed, and because 
of  the  examples  provided  in  support  of  their  claims118.  For  example,  according  to  one 
skipper, on a trip between Constanța and Budapest, he needs to report on his voyage and 
cargo  around  five  times.  Representative  associations  listed  similar  examples:  several 
reports from Flushing to Liège; from Basel to Rotterdam; from Constanța to Rotterdam; 
and even within countries, e.g. Romania and Bulgaria119.  

  The lack of a harmonised approach hinders interoperability and impedes a 

reduction in resubmissions  

There  is  a  clear  lack  of  a  harmonised  approach  to  electronic  ship  reporting.  When 
systems  are  not  interconnected  across  countries,  they  cannot  automatically  share  data, 
and  as  a  result  vessel  information  needs  to  be  reported  more  than  once,  or  different 
information needs to be reported in different countries.  

The lack of harmonisation, in turn, is the result of the lack of EU-wide legislation mandating 
the use of electronic ship reports. As mentioned above, the Directive specifies the technical 
requirements of electronic ship reports required by national or international rules, and that 
these need to be transmitted to the relevant competent authorities in neighbouring states. 
The Directive does not, however, mandate the use of the messages as such. As a result, 
not all types of messages are supported in all relevant Member States, and they are often 
not automatically shared. PAXLST, for instance, is not supported anywhere, except for a 
pilot in Hungary. ERINOT is used in most countries120, though not always in an electronic 
format121;  ERIRSP  is  used  only  in  Austria,  Germany,  the  Netherlands  and  Romania; 
BERMAN is not supported anywhere; and ERIVOY is supported only in Germany and the 
Netherlands.  

Clearly,  these  differences  make  it  difficult  to  streamline  the  information  requested,  and 
greatly hinder the degree to which notices are shared between the relevant authorities. 
This  was  confirmed  by  eleven  interviewed  stakeholders,  who  highlighted  the  lack  of  a 
mandatory  standard,  or  the  lack  of  enforcement  of  the  RIS  Directive  in  this  regard,  as 
hindering factors. This was mentioned by RIS authorities and private sector organisations 

results. See Question 74 in section 5.3.6., Annex 1 “Findings from the survey questionnaires” to the Stakeholder 
Consultation Report. 

113 This was stated by interviewees from all different stakeholder groups and different regions. A total of 28 out 

of the 33 who discussed e-ship reporting voiced this opinion.  

114 Four RIS authorities (1 non-EU) and one RIS developer  

115 CCNR (2007), Decisions 2007-II-20 and 2009-I-17, mandatory e-ship reporting for certain ships that transport 

containers, enforced since 2010. 

116 CCNR (2018), RPR article 12.01, Decision 2017-I-11, mandatory e-ship reporting for tanker barges.  

117  See  section  6.1.  on  electronic  ship  reporting,  Annex  2  “Findings  from  the  interviews”  to  the  Stakeholder 

Consultation Report.  

118  Five  different  private  sector  interviewees  provided  examples.  One  of  them  is  a  skipper,  the  others 

representative organisations.  

119  See  section  6.1.  on  electronic  ship  reporting,  Annex  2  “Findings  from  the  interviews”  to  the  Stakeholder 

Consultation Report.  

120 Especially on the Rhine, where the use of ERINOT for container ships with more than 20 containers on board 

or ships transporting containers with dangerous substances was made mandatory in 2010.  

121 i.e. a considerable share of ERINOT messages are still reported using VHF or other means such as e-mail or 

fax. 

39 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

alike,  primarily  from  Western  European  countries.  This  does  not,  however,  indicate  that 
there is a difference between regions in this regard. 

  Data privacy concerns hinder cross-border coordination  

Aside from the lack of common standards on the type of information requested, there is 
the issue of agreements for international data exchange. According to four national and 
international  level  interviewees,  primarily  from  the  Danube  region,  privacy  concerns 
hinder the exchange of vessel data between countries. As specified by one RIS provider 
in  the  open  public  consultation:  “The  benefit[s]  of  electronic  reporting  ha[ve]  not  been 
[reaped] until now. Legal issues have to be solved to introduce electronic ship reporting 
and to [fully reap the] benefits”122. There are differences across Europe in the interpretation 
of  sensitive  personal  data,  and  the  legality  of  sharing  that.  Notably  Germany  was 
mentioned by two interviewees as being strict in this regard.  

The RIS Directive states that Member States shall “ensure that processing of personal data 
necessary for the operation of RIS is carried out in accordance with the Community rules 
protecting  the  freedoms  and  fundamental  rights  of  individuals,  including  Directives 
95/46/EC”123 (since 2016, this has been repealed by Regulation 2016/679, i.e. the GDPR). 
It is beyond the scope of the current study to assess to what extent the sharing of vessel 
data between competent authorities is in line with the requirements of the GDPR, however, 
stakeholders do not believe this should impose issues, as long as the  vessel data is not 
linked to any personal information of persons who own or operate it.  

  There is no proof of cost savings for waterway users  

Although  the  RIS  Directive  aims,  through  its  technical  standards  for  electronic  ship 
reporting and international data exchange across border to reduce resubmissions, to lead 
to cost savings for users of the waterways, there is no evidence to suggest that this indeed 
occurred. As there has  seemingly not been a reduction in resubmissions, there has also 
not been a reduction in costs for vessel owners/operators.  

No  concrete  cost  data  was  provided  by  users  of  the  waterways,  and  their  views  on 
whether costs had increased or decreased vary – two indicated a small increase in costs, 
and  two  others  a  decrease  in  costs.  In  terms  of  workload,  one  indicated  this  decreased 
because of time savings associated with the digitalisation of ship reports, while the other 
experienced an increase in costs because “everything needs to be done twice”124.  

  There is no proof of cost savings for waterway managers  

It  can  be  assumed  that  if  electronic  reports  are  shared  directly  between  the  relevant 
authorities  on  an  international  voyage,  these  authorities  save  time  otherwise  spent  on 
collecting  reports  themselves.  In  other  words,  with  more  electronic  reporting  and  fewer 
resubmissions  on  cross-border  voyages,  the  administrative  burden  for  authorities  is 
expected to decrease. 

Nevertheless,  there  is  no  concrete  cost  data  to  suggest  that  authorities  indeed 
experienced cost savings. On the contrary, those who provided input rather believe costs 
associated with electronic reporting remained stable or increased over time125.  

The lack of data exchange across countries, and the fact that different types of messages 
are used throughout Europe underlines this, as it implies that competent authorities have 

122 See Question 5(bis) in section 7.2.4., Annex 3 “Findings from the open public consultation” to the Stakeholder 

Consultation Report.  

123 Article 9 (1), Directive 2005/44/EC  

124 The former operates primarily on the Danube and the latter on the Rhine, although the sample is too small to 

make generalisations to this effect.  

125  See  Question  56  in  section  5.2.7.,  Annex  1  “Findings  from  the  survey  questionnaires”  to  the  Stakeholder 

Consultation Report.  

40 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

not experienced cost savings as a result of changes in electronic ship reporting brought 
about by the RIS Directive.  

  Electronic ship reports could produce social and environmental benefits if 

implemented in the same way across Europe  

Despite the lack of actual cost savings and the lack of interoperability between countries, 
stakeholders seem positive about the potential benefits of electronic ship reporting. 
For instance, as explained by six national and international level interviewees, electronic 
reporting aids calamity abatement – if the correct information about a vessel, including its 
cargo and the number of crew members on board, is known, rescue agencies immediately 
know what to do and how many people to rescue126. In the case of dangerous cargo being 
transported,  this  can  help  avoid  excessive  pollution,  but  can  also  help  save  the  lives  of 
crew on board.  

126 A German interviewee mentioned the example of a 2011 tanker accident on the Rhine as one example where 
this information facilitated calamity abatement. The accident involved a tanker, the “Waldhof” containing 2,400 
tons of sulphuric acid capsized on the Rhine on 13th January 2011. Knowing the content it was carrying (sulphuric 
acid)  and  the  number  of  crew  members  on  board  (4)  in  advance  helped  calamity  abatement  agencies  in 
prioritising  their  efforts.  See  also:  https://www.spiegel.de/international/germany/the-shipwreck-and-the-
lorelei-traffic-remains-blocked-after-rhine-tanker-accident-a-740322.html (Last accessed 14th October 2019)  

41 

                                                
Figure 7. Causal pathway – Electronic ship reports 

Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

42 

 
 
 
 
Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.1.3.  Type-approval of RIS equipment  

EQ 3: Compared to what would have happened in the absence of the Directive, in quantitative and qualitative 
terms, to what extent, with regard to the type-approval of equipment, has the implementation of the Directive 
led to the mutual recognition of RIS equipment as foreseen in Art. 7.1? 

 Context  

Article 7 of the RIS Directive details the provisions for type-approval of RIS equipment. It 
states  that,  where  necessary  for  safe  navigation  and  required  by  the  relevant  technical 
specifications,  “RIS  terminal  and  network  equipment  and  software  applications  shall  be 
type-approved  for  compliance  with  those  specifications  before  being  put  into  service  on 
inland  waterways”.  Additionally,  all  type-approvals  issued  by  the  relevant  bodies  of  the 
Member States are to be mutually recognised by all others127. 

As such, all RIS equipment for which the relevant technical standards require them to be 
type  approved  need  to  be  certified,  and  all  Member  States  need  to  recognise  this 
certification. Currently, only Inland ECDIS viewers in navigation mode128 and Inland AIS 
transponders129 are required to be type-approved in the EU. All type-approvals need to be 
carried out following the test standards outlined in ES-TRIN.  

The aim of this mutual recognition of type-approved equipment is to ensure that firms can 
get equipment efficiently and effectively type-approved throughout Europe, which in turn 
eliminates technical obstacles to continuous cross-border traffic and makes hardware and 
software  more  affordable.  As  a  result,  the  market  should  grow,  which  increases  its 
competitiveness  and,  in  the  long  run,  should  help  lead  to  a  modal  shift.  The  degree  to 
which these expected benefits have been achieved is outlined below, and presented in the 
elaborated causal pathway in Figure 8. 

Box 5. Summary of findings on EQ 3 – type approval of RIS equipment  

All type-approvals are carried out by the Wasser- und Schifffahrtsverwaltung des Bundes 
Fachstelle der WSV für Verkehrstechniken (FVT) in Germany. Although there is a clear 
limit in knowledge of type-approval in the Member States, none of the Member States 
experienced difficulties with mutual recognition. As such, it can be safely concluded that 
type-approved  RIS  equipment  is  mutually  recognised  across  Member  States  as 
foreseen in Article 7 of the RIS Directive.  

However, the extent to which this is attributable to the RIS Directive is unclear. The 
lack of evidence on the number of mutually recognised type-approvals before and after 
the implementation of the Directive makes an assessment of attributability impossible. 
On  the  contrary,  there  are  indications  that  the  RIS  Directive  did  not  bring  about  any 
significant change in this regard.  

There are indications that this mutual recognition of type-approved equipment certified 
in Germany saves other RIS authorities time and money that would otherwise be 
spent on approving equipment themselves. However, there is no quantified evidence of 
costs or time saved to reliably conclude this.  

127 Article 7 (3), Directive 2005/44/EC 

128  Commission  Implementing  Regulation  (EU)  2018/1973  of  7  December  2018  amending  Implementing 
Regulation  (EU)  No 909/2013  on  the  technical  specifications for  the  electronic  chart  display  and  information 
system for inland navigation (Inland ECDIS) referred to in Directive 2005/44/EC of the European Parliament 
and of the Council. 

129 Commission Implementing Regulation (EU) 2019/838 of 20 February 2019 on technical specifications for vessel 

tracking and tracing systems and repealing Regulation (EC) No 415/2007. 

43 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Similarly,  there  are  indications  that  type-approvals  are  beneficial  to  the  sector  as  a 
whole, as they improve the quality of equipment and improve interoperability. There is 
no evidence to reliably conclude this, however.   

Findings  

  All type-approvals in Europe are issued by the same body in Germany  

Research  and  consultations  carried  out  in  the  context  of  this  study  finds  that  all  type-
approvals of RIS equipment have been issued by the Wasser- und Schifffahrtsverwaltung 
des Bundes Fachstelle der WSV für Verkehrstechniken (FVT), located in Germany. Type-
approved  equipment  includes  six  Inland  ECDIS  viewers  and  46  AIS  transponders,  24  of 
which conform to Test Standard 2.0 (CCNR) and are permitted to be installed on board 130. 
Four RIS authorities131 and the CCNR specifically mentioned that this system works well, 
and  that  there  is  no  need  for  other  authorities  to  carry  out  their  own  type-approvals. 
Although  only  four  of  them  stated  this,  there  is  a  strong  indication  that  others  are  of  a 
similar opinion, as none of the interviewed authorities has the need to carry out their own 
approvals. 

It  should  be  noted,  however,  that  there  was  a  clear  lack  of  knowledge  among  RIS 
authorities with regards to type-approval of RIS equipment. As they do not carry out their 
own  approvals,  and  the  technical  details  are  often  dealt  with  by  other  staff  than  those 
consulted in the context of this study, the evidence collected in this regard is limited132.  

  Type-approved  RIS  equipment  is  mutually  recognised  across  Member 

States, though the attributability to the RIS Directive is unclear  

Although  desk-based  research  provided  no  evidence  on  this  topic,  stakeholder 
consultations carried out within the context of this study provide a strong indication that 
all type-approved RIS equipment is mutually recognised across Member States as 
mandated by the Directive.  

All twelve interviewed stakeholders who provided comment on the topic are of the opinion 
that  mutual  recognition  of  type-approved  equipment  works  well.  This  includes  RIS 
authorities  from  Austria,  Belgium,  Czechia,  the  Netherlands,  Romania,  Serbia,  Slovakia 
and Switzerland, highlighting that mutual recognition works throughout the EU, and even 
beyond its borders. No issues were highlighted.  

However, it is unclear whether this mutual recognition is attributable to the RIS Directive. 
Two RIS authorities who responded to the questionnaire indicated that there had not been 
a change in mutual recognition since the RIS Directive, and one thought there had been. 
Interviewed  stakeholders  were  similarly  divided  –  three  of  them  did  not  experience  a 
change  as  a  result  of  the  RIS  Directive,  while  two  did.  According  to  one  RIS  authority, 
“even  without  the  RIS  Directive  this  [mutual  recognition]  would  be  the  case,  but  the 
Directive just made a place for  everyone to accept it easily into national legislation”. As 
none  of  the  authorities  were  able  to  provide  details  on  the  numbers  of  type-approvals 
mutually recognised, no reliable conclusions on attributability can be made.  

130  See  https://listes.cesni.eu/2030-en.html  and  https://listes.cesni.eu/2050-en.html  (Last  accessed  15th 
October 2019). The other 22 transponders conform to Test Standard 1.0 and can therefore still be used but not 
installed  on  board.  It  should  be  noted  that  as  per  CESNI  requirements,  Inland  AIS  equipment  with  a  type 
approval  according  to  Edition  1.0  and  1.01  of  the  Test  Standard  for  Inland  AIS  and  installed  before  the  1st 
December 2015 may continue to be used, and Inland AIS equipment which has received an approval on or after 
19 October 2012, pursuant to the requirements of the Test Standard for Inland AIS, Edition 2.0, adopted by 
Resolution CCNR 2012-II-20 may continue to be installed and used. 

131 Czechia, France, Slovakia, Serbia  

132 See section 6.1. on type approval of RIS equipment, Annex 2 “Findings from the interviews” to the Stakeholder 

Consultation Report. 

44 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  There are indications that mutual recognition of type-approved equipment 

leads to cost savings for RIS authorities is beneficial for the sector  

Although  no  reliable  evidence  in  support  of  this  question  was  obtained  through  desk 
research,  interviews  listed  a  few  benefits  created  by  the  mutual  recognition  of  type-
approved  equipment.  First  and  foremost,  the  mutual  recognition  of  type-approved 
equipment (and the fact that only one organisation issues type-approvals) means that the 
Member States do not need to take care of type-approvals themselves, which saves them 
time and money133. However, as above, the degree to which this is attributable to the RIS 
Directive is unclear. A more detailed assessment of costs and benefits for RIS authorities 
is covered under EQ 10.  

  There are indications that mutual recognition of type-approved equipment 

is beneficial to the sector as a whole 

Although  no  reliable  evidence  in  support  of  this  question  was  obtained  through  desk 
research, interviewed private sector RIS developers agree that mutual recognition of type-
approved  equipment  has  been  beneficial  to  them.  They  explained  that  having  shared 
standards throughout Europe promotes higher quality of products, ensures the equipment 
will work everywhere, and thereby safeguards investments.  

Nevertheless, it seems they were referring to the existence of shared standards as such, 
rather  than  their  mutual  recognition  specifically.  As  the  Directive  does  not  make  type-
approvals mandatory, it is unlikely that these listed benefits are directly attributable to the 
RIS  Directive.  As  explained  by  the  CCNR,  type-approval  was  first  developed  by  them. 
Although their standards have been consolidated with those of the EU under the ES-TRIN, 
they do not believe the RIS Directive had a direct effect on type-approvals being carried 
out. 

133 This was mentioned by RIS authorities in Czechia, France and Slovakia  

45 

                                                
Figure 8. Causal pathway – Type-approval of RIS equipment 

Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

46 

 
 
 
Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.1.4.  Establishment of a harmonised, interoperable RIS  

EQ 4: Compared to what would have happened in the absence of the Directive, in quantitative and qualitative 
terms,  to  what  extent  has  the  Directive  been  overall  effective  in  establishing  an  interoperable,  harmonised 
RIS? 

Context  

The  overall  aim  of  the  RIS  Directive  is  “to  establish  harmonised  RIS  in  the 
Community”134,  which  it  claims  cannot  sufficiently  be  achieved  by  the  Member  States 
themselves.  The  Directive  aims  at  establishing  “a  Europe-wide  framework  for  the 
implementation  of  the  RIS  concept  in  order  to  ensure  compatibility  and  interoperability 
between  current  and  new  RIS  systems  at  European  level  and  to  achieve  effective 
interaction  between  different  information  services  on  waterways”135.  This  question 
assesses the degree to which this objective has been reached.  

Box 6. Summary of findings on EQ 4 – establishment of a harmonised, interoperable RIS  

The RIS Directive has led to the establishment of a harmonised, interoperable 
RIS, but has not yet reached its full potential in this regard.  

The  degree  of  harmonisation  differs  depending  on  the  different  RIS 
technologies,  with  most  harmonisation  in  type-approval  of  RIS  equipment  and 
electronic  navigational  charts,  slightly  less  in  data  for  navigation  and  planning  and 
notices to skippers, and the least harmonisation in electronic ship reporting.  

Despite the lack of full harmonisation, stakeholders agree that harmonisation of RIS 
has  been the  strongest  benefit  brought  about  by  the  Directive,  indicating  that  the 
progress  made  so  far  is  highly  valued.  If  the  Directive  and  its  associated  technical 
standards  are  fully  implemented  in  all  Member  States,  it  is  highly  likely  that 
harmonisation will further improve.  

Findings  

  The RIS Directive has led to progress in harmonisation of RIS but has not 

yet reached its full potential in this regard  

As  detailed  under  the  previous  evaluation  questions,  the  implementation  of  harmonised 
RIS has made significant progress since the adoption of the Directive in 2005. Common 
technical  standards  have  been  put  in  place,  national  RIS  implementation  and  technical 
system installation has evolved with the support of EU projects, and pilot implementations 
for international data exchange have been successfully achieved. To summarise:  

  Data relevant for navigation and voyage planning is not fully harmonised 
across  relevant  Member  States.  There  are  differences  in  the  measurements  and 
provision of data.  However, progress has definitely been made as a  result of the 
RIS Directive and is expected to continue.  

  Electronic  navigational  charts  seemingly  do  not  suffer  from  a  lack  of 
harmonisation.  Differences  may  occur  as  a  result  of  the  above-mentioned 

134 Preamble (12), Directive 2005/44/EC  

135 COM(2004) 392 final, Proposal for a Directive of the European Parliament and of the Council on harmonised 
River  Traffic  Information  Services  on  inland  waterways  in  the  Community,  p9.  See  https://eur-
lex.europa.eu/legal-content/EN/HIS/?uri=COM:2004:0392:FIN  

47 

 
                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

differences  in  data,  but  in  general  the  RIS  Directive  has  led  to  considerable 
harmonisation in this regard.  

  Notices to skippers are not fully harmonised across Member States. There are 
differences in the means through which they are made available and how often, and 
there is limited data exchange.  

  Electronic ship reporting suffers the most from a lack of harmonisation. The 
Member States have different legal obligations for electronic reporting, and there is 
limited cross-border data exchange, which leads to resubmissions.  

  Requirements for type-approval of RIS equipment are harmonised. There are 
no  issues  with  the  mutual  recognition  of  type-approved  equipment  between 
different Member States.  

When  asked  to  indicate  the  degree  to  which  the  RIS  Directive  has  been  successful  in 
creating a harmonised, interoperable RIS, participants at the RIS Week in Galați agreed 
that it had, at least to some extent136. Interviewed stakeholders largely agree that progress 
has been  made, but that RIS is far from harmonised  – the  RIS Directive has not yet 
reached  its  full  potential  in  this  regard  and  more  needs  to  be  done.  In  fact,  a  lot  of 
stakeholders  across  all  groups  believe  that  harmonisation  of  RIS  is  the  strongest 
benefit  of  the  RIS  Directive,  and  that  this  could  not  have  been  achieved  to  the  same 
degree  in  the  absence  of  the  Directive  (see  EQ  20).  This  indicates  that  although  some 
aspects are lagging behind, the progress made so far is highly valued and appreciated.  

Similar  views  were  reported  through  the  open  public  consultation.  Although  there  has 
clearly been an improvement  across different  RIS aspects and technologies, in terms  of 
standardisation  and  harmonisation,  various  stakeholders  suggested  there  was  room  for 
further improvement. The stakeholder consultations suggest that:  

  Progress has been made across all key technologies since the adoption of the RIS 
Directive  in  2005,  but  there  are  differences  between  countries/regions.  For 
example, as explained by a respondent from a user representative organisation in 
the Danube region; in Western Europe, position and ETA data is already being used 
in port and terminal management, whereas the Danube region is only now starting 
with digitalisation processes in ports. 

  As a result, there is a considerable lack of harmonisation. Many stakeholders 
believe that the services often are not interoperable. This requires cooperation and 
coordination  between  Member  States  and  companies,  which in  some  instances  is 
missing.  

3.1.5.  Unintended positive effects  

EQ 5: Compared to what would have happened in the absence of the Directive, in quantitative and qualitative 
terms, to what extent, has the Directive had unintended economic, social, or environmental effects? 

Context  

Beyond the causal pathways shown in the previous sections, and the intended effects and 
impacts  of  the  RIS  Directive  as  a  whole,  it  is  possible  that  additional  effects,  that  were 
unexpected at the time of its adoption, occurred. This question assesses whether any such 
unintended effects, notably positive economic, social or environmental effects occurred.  

136 13 people believe it had “to a large extent”, 30 people “to some extent” and 10 people “to a limited extent”. 
Only 1 person believes the RIS Directive had not been successful in this at all. See Question 2 in section 8.1, 
Annex 4 “Findings from the events attended” to the Stakeholder Consultation Report.  

48 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Box 7. Summary of findings on EQ 5 – positive unintended effects  

There is no strong, reliable evidence to conclude that the RIS Directive has brought 
about  unintended  positive  effects.  However,  there  are  indications  derived  from 
qualitative assessments of stakeholders that it may have led to the following: 

  Unintended  economic  effect:  creation  of  new  opportunities  in  the  context  of 

market developments such as (semi)-autonomous sailing; 

  Unintended social effects: creation of high-tech working places, the expansion of 
educational programmes to include RIS technologies, and the political salience of the 
inland navigation sector, within and beyond Europe;  

There is no indication of positive environmental effects beyond what was intended 
at the time the RIS Directive was adopted.  

It is beyond the scope of this study to assess whether these reported unintended positive 
effects have indeed materialised, hence the supporting evidence is based on stakeholder 
assessments and mostly unsubstantiated.  

Findings  

  There is no strong evidence of unintended positive economic effects of the 

RIS Directive  

There  is  no  concrete,  reliable  evidence  that  the  RIS  Directive  has  had  any  positive 
economic effects that were unexpected or not intended when the Directive was adopted. 
According  to  four  interviewees  from  the  public  and  private  sectors,  however,  the  RIS 
Directive paved the way for innovation in inland navigation. Although market growth was 
an intended result of the Directive, new developments such as (semi)-autonomous sailing 
were not considered at the time it was adopted. As such, the impact of RIS in this regard 
can  be  seen  as  an  unintended  effect.  Considering  the  influence  of  the  Directive  on  the 
overall implementation of RIS in Europe, it can be assumed that it indirectly contributes to 
this  effect.  At  the  RIS  Week  Common  Issues  meeting  in  Galați,  this  was  confirmed  by 
attendees, who believe the Directive created “new and interesting opportunities”137. 

  The  RIS  Directive  seemingly  brought  about  unintended  positive  social 

effects  

In terms of unintended positive social effects, consulted stakeholders mentioned a few. 
In relation to education and employment, for example, three public sector interviewees at 
national  and  international  level  stated  that  the  Directive  had  indirectly  (i.e.  through  its 
promotion  of  the  use  of  RIS),  led  to  the  creation  of  new  educational  programmes  for 
students, that now include training on AIS and ECDIS. Similarly, two of them believe it led 
to the creation of high-tech working places, and “significantly improved the quality of work 
in the sector”138. 

Relatedly, the RIS Directive is believed to have improved the political salience of RIS and 
the inland navigation sector, at least in countries where it was not already near the top of 
a  country’s  political  priorities139.  According  to  an  interviewee  from  an  international 
organisation, it even led to the expansion of the RIS concept beyond EU borders, e.g. to 

137 See Question 8 in section 8.1, Annex 4 “Findings from the events attended” to the Stakeholder Consultation 

Report.  

138 Stated by RIS authority in a country in the Danube region  

139 This was stated by two RIS authorities, one in the Rhine region and one in the Danube region. However, they 
did  not  indicate  that  this  was  the  case  in  their  country,  rather  speculating  that  this  might  have  occurred 
elsewhere in Europe.  

49 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Russia, the United States, and Asia. There is reportedly also a possibility for strengthened 
cooperation through the RIS Directive to reduce cross-border crime140. Whether this has 
actually occurred is unclear, and none of the stakeholders consulted within the framework 
of this study mentioned this as an unintended effect of the Directive.  

Checking whether these social effects have indeed materialised is beyond the scope of the 
present  study.  However,  the  fact  that  stakeholders  believe  the  RIS  Directive  has  had 
positive social effects beyond what it intended to achieve underlines the added  value of 
the Directive.  

  There is no strong evidence of unintended positive environmental effects  

The  RIS  Directive  intends  to  improve  the  environmental  friendliness  of  the  inland 
navigation  sector  through  a  more  efficient  use  of  existing  infrastructure,  which  should 
reduce fuel use through more and better information for waterway users. It reportedly can 
also support waste management141, and pave the way towards a paperless environment in 
shipping142  (i.e.  through  electronic  ship  reporting  and  standardised  electronic  notices  to 
skippers). The former is not attributable to the RIS Directive, as it does not currently cover 
waste management, and the latter is underway, but judging from findings on EQ2, still has 
potential  for  improvement.  Consulted  stakeholders  did  not  highlight  any  positive 
environmental effects of the RIS Directive beyond those which were intended or expected 
(see also EQ 6d on increased environmental protection). 

3.1.6.  Achievement of general objectives  

EQ 6: At the level of its general objectives and compared to what would have happened in the absence of the 
Directive, to what extent (in quantitative and qualitative terms) has the Directive contributed to (a) increased 
competitiveness of the inland waterway sector across Europe; (b) an optimised use of existing infrastructures; 
(c) improved safety in river navigation; (d) reduction of the sector's negative impacts on the environment?  

Context  

The RIS Directive aims, at the level of its general objectives, to provide four interrelated 
strategic benefits143:  

  To increase the competitiveness of inland waterway transport; 

  To optimise the use of existing infrastructure;  

  To improve safety and security of inland navigation; and  

  To increase environmental protection.  

Competitiveness is expected to improve through the time and money saved by waterway 
users as a result of better voyage planning, efficient ship loading based on current fairway 
conditions, and interoperability with the full supply chain and other modes of transport in 
Europe.  The  optimised  use  of  public  infrastructure  also  plays  a  role  in  this  regard  as  it 
improves  efficiency  in  inland  navigation,  making  the  sector  more  attractive  for  shipping 
purposes.  In  the  long  run,  the  Directive  is  expected  to  contribute  to  a  modal  shift  from 
road and rail freight transport towards shipping.  

140  ViaDonau  (2016).  Recommendations  for  improved  border  controls  along  the  Danube  and  its  navigable 
tributaries  -  EU  Strategy  for  the  Danube  Region,  Priority  Area  1a  –  To  improve  mobility  and  multimodality: 
Inland waterways.  

141 IRIS Europe (2009). Implementation of River Information Services in Europe, Final technical report, p. 23. 

142 PIANC Permanent Working Group 125 (2018). Technical report on the status of River Information 2011-2018, 

p. 21. 

143 COM(2004) 392 final, Proposal for a Directive of the European Parliament and of the Council on harmonised 

River Traffic Information Services on inland waterways in the Community. 

50 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

The optimised use of public infrastructure is expected to occur through accurate planning 
and  scheduling  of  Required  Times  of  Arrival  (RTA)  by  lock/bridge/terminal  operators  on 
the basis of vessel, traffic and positioning data. The automation of collection of customs 
data also plays a role in this, as it is expected to result in reduced public spending.  

Safety  and  security  of  inland  navigation  are  expected  to  be  improved  through  the 
availability  of  a  complete,  up-to-date  overview  of  fairway  and  traffic  information,  which 
allows  skippers  to  make  well-informed  navigational  decisions  that  should  reduce  the 
number  of  accidents  in  inland  navigation.  Through  the  monitoring  of  dangerous  goods 
transport,  shipping  accidents  can  be  further  avoided,  or  at  least  efficiently  resolved. 
Security  is  improved  through  the  contribution  of  RIS  to  the  transparency  of  freight 
transport through the smooth exchange of data between all relevant partners in a transport 
chain. 

Lastly, environmental protection is the result of the expected reduction in fuel consumption 
resulting from adjustments in travel speeds on the side of skippers when avoiding waiting 
times at locks and terminals, as well as the timely response to potential accidents involving 
environmentally harmful dangerous goods. Through its expected impact on a modal shift, 
increased competitiveness also plays a role in this - a modal shift of cargo from road to 
waterway is expected to lead to a reduction of exhaust gases such as CO2 and NOx, as 
well as noise nuisance.  

This question assesses the degree to which these expected benefits have been achieved 
and through which pathways.  

Box 8. Summary of findings on EQ 6 - achievement of general objectives 

Competitiveness  

Although there has been a positive trend in the growth of the inland waterway transport 
sector since the adoption of the RIS Directive, there is no statistically significant evidence 
to prove that the RIS Directive impacted this trend. However, the correlation can also 
not be disproved, and despite the fact that there is no quantitative evidence, a lot of 
stakeholders believe the RIS Directive has impacted the competitiveness of the sector 
to some extent.  

Nevertheless,  the  intended  increase  in  comparative  competitiveness  of  the  sector 
compared to other modes of transport (i.e. a modal shift) has not been achieved, as 
the modal share of the sector has remained stable since 2005. Stakeholders are hopeful, 
however, that the Directive can have an impact on this shift in the future, provided that 
it is implemented to its full potential.  

Use of infrastructure  

Very  limited  evidence  on  the  use  of  infrastructure  is  available,  which  makes  it 
impossible to prove or disprove whether the RIS Directive optimised its use. There are 
indications that there is a potential for RIS to achieve this, although in reality it has 
not promoted  change in lock or terminal management in the Member States  yet. The 
degree to which the Directive itself plays a role in this is unclear.  

Safety and security 

There is no statistical evidence available to prove that there has been a decrease in 
the number of accidents (and thus an increase in safety) over the 2005-2019 period, let 
alone  that  the  RIS  Directive  played  a  role  in  this.  Accident  data  is  not  measured 
consistently across countries and over time, so it is likely to be inaccurate. Therefore, 
although it cannot be proven statistically, there is a possibility that the RIS Directive has 
nevertheless had a positive impact in this regard.  

In fact, waterway users and their representative organisations indicate that they feel a 
sense  of  improved  safety  in  inland  navigation.  Although  not  all  stakeholders  are 
convinced that this change is attributable to the RIS Directive rather than RIS as such, 

51 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

it is an important finding because it constitutes an important benefit for inland waterway 
users.  

There are indications that Member States revisited their approach to data security as a 
result of the RIS Directive, however, an extensive assessment of national laws in this 
regard was not conducted.  

Increased environmental protection  

There  are  indications  that  the  use  of  RIS  has  reduced  fuel  consumption,  and 
thereby reduced emissions and pollution. However, it is unclear whether this is directly 
attributable to the RIS Directive.  

As there is no statistical proof of reduced accidents resulting from the RIS Directive, it 
is unlikely that it improved environmental protection in this way. Nevertheless, there is 
an  indication  that  if  international  exchange  of  electronic  ship  reports  is  further 
implemented, the RIS Directive will have a positive effect on the reduction of oil spills 
through more efficient calamity abatement (see also EQ 2).  

Similarly, the lack of statistical evidence to prove a modal shift suggests there has not 
been  a  reduction  in  the  emissions  and  pollution  caused  by  other  transport  sectors 
through a shift towards inland waterway transport.  

Findings  

A.  Increased competitiveness  

  There  is  no  statistically  significant  proof  that  the  RIS  Directive  had  any 
impact on the performance or growth of the inland navigation sector  

Based on the econometric modelling144 carried out in the context of the present study, it 
could not be proven nor disproven that the RIS Directive had an impact on the performance 
or growth of the inland navigation sector.  

The  model  suggests  that  there  was  a  1%  growth  of  tank  barge  tonne.km  from  2009 
onwards, further to the implementation of the RIS Directive. However, this correlation is 
not statistically significant, which means that although this suggests that the RIS Directive 
led to an increase in tank barge cargo volume transported over the 2009-2016 period, this 
cannot be confidently concluded. Considering the pattern of tonne.km changes in the tank 
barge sector is quite volatile, it is even more unlikely that the RIS Directive played a role. 
The same is true for the dry cargo sector - the implementation of the RIS Directive did not 
have a statistically significant impact on the tonne.km changes in the dry cargo sector in 
North-Western  Europe145.  Growth  in  the  inland  navigation  sector,  rather,  is  seemingly 
caused  by  external  effects,  such  as  economic  growth,  industrial  production  and  other 
factors. 

  Stakeholders  are  divided  as  to  the  impact  of  the  RIS  Directive  on  the 

growth of the inland navigation sector  

Despite the lack of quantitative evidence to prove whether  or not the RIS  Directive had 
any impact on the growth of the inland navigation sector in terms of tonne.km transported, 
the  majority  of  consulted  stakeholders  believe  it  has  had  some  impact  on  the  sector’s 
development.  

Although  they  acknowledge  they  do  not  have  a  means  to  prove  it,  a  total  of  eleven 
interviewees believe the RIS Directive has to some extent impacted the competitiveness 

144 See Annex 5 “Econometric modelling”  

145 The model was based on the total tonne.km transport quantity in the Netherlands, Belgium and Germany for 
the dry cargo sector. Although this does not allow for extrapolation at the EU level, these countries constitute 
a large share of the market.  

52 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

of  the  inland  navigation  sector.  This  includes  three  RIS  Expert  Group  chairs,  two  RIS 
authorities,  two  River  Commissions,  two  international  organisations  and  two  RIS 
developers. However, most of them think this effect is indirect, or not solely attributable 
to  the  Directive,  primarily  because  they  believe  RIS  would  likely  have  been  developed 
without the Directive as well. Five others, however, think the harmonisation brought about 
by the RIS Directive, compared to what could have been achieved by Member States or 
River Commissions (see EQ 20), has improved the sector’s competitiveness.  

  There is no indication of a modal shift towards inland navigation occurring 

as a result of the RIS Directive  

Although some stakeholders believe the competitiveness of the sector has increased as a 
result of the RIS Directive, they acknowledge that this probably did not have an effect on 
its competitive position in relation to other modes of transport, i.e. did not contribute to 
a modal shift. This perception, which was outlined by nine interviewees across different 
stakeholder groups, is confirmed by the lack of quantitative evidence to suggest a modal 
shift has occurred.  

An assessment of the modal share of the inland navigation sector on EU level shows hardly 
any  change  since  2005,  consistently  accounting  for  not  more  than  6.9%  of  total  freight 
transport in Europe146. However, this figure is based on aggregated data at EU-28 level, 
thus including countries which do not have a significant inland waterway freight transport 
sector. In the Netherlands alone, for example, inland waterway transport accounts for a 
modal share of 44.7%, followed by 27.4% in Romania and 24.9% in Bulgaria. In Czechia 
and  Poland,  however,  this  share  is  less  than  0.1%,  showing  that  even  across  Member 
States to which the RIS Directive applies, there are considerable differences.  

There is no clear pattern in terms of the modal share of inland waterway transport 
in the Member States of relevance to the RIS Directive. In fact, over the 2005-2017 period, 
only the Netherlands, Belgium, Croatia and Romania experienced an increase in the modal 
share of the sector. In Austria, Bulgaria, Germany, Luxembourg and Slovakia, this share 
decreased. In France and Hungary, it remained stable. As such, it is safe to conclude that 
no modal shift has yet occurred, although stakeholders consulted within the context of this 
study are hopeful that it will in the future, and that the RIS Directive may play a small role 
in this development.  

B.  Optimised use of infrastructure  

  Although it cannot be proven or disproven, it seems unlikely that the RIS 

Directive led to the optimised use of infrastructure  

There is very limited data available to assess whether existing infrastructure has been 
used more optimally as a result of the RIS Directive. Although RIS authorities were asked 
to provide details on lock, bridge and fairway utilisation, none were able to provide such 
data. In fact, there is not even any consensus in their qualitative assessments on whether 
the degree of utilisation has changed as a result of the RIS Directive, indicating that it is 
difficult to estimate without concrete data147.  

Based on an assessment of Dutch national data concerning delays (i.e. waits of more than 
30 minutes) at locks, there has not been a decrease in delays since the implementation of 
the RIS Directive148. However, the Netherlands is a special case with considerable inland 
waterway transport, and a much denser waterway network than most European countries, 
so  the  data  likely  is  not  representative  for  Europe  as  a  whole.  It  can  therefore  not  be 

146  Based  on  Eurostat  data  that  is  aggregated  at  the  level  of  EU-28,  although  not  all  Member  States  have  an 
inland waterway transport sector, and many are not addressed by the RIS Directive. See more details in section 
6.2.2.1 “Modal share” in Annex 6 “Ex-post social cost-benefit analysis” 

147 See section 5.2.9, Annex 1 “Findings from the survey questionnaires” to the Stakeholder Consultation Report  

148 See section 6.2.2.4 “Time costs: the case of lock delay” in Annex 6 “Ex-post social cost-benefit analysis” 

53 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

concluded on the basis of this data whether or not the RIS Directive made an impact on 
more efficient lock planning.  

In  reality,  it  seems  RIS  is  not  yet  used  for  more  efficient  lock  planning  in  most 
Member  States.  In  many  cases,  locks  operate  on  a  first  come  first  served  basis,  which 
simply does not allow for any advanced slot planning. Although user associations and RIS 
developers  acknowledge  that  this  can  be  done,  none  of  them  indicated  it  was  indeed 
happening in their Member State. A few pilot projects in Belgium and the Netherlands were 
highlighted by interviewees, but this was also specifically said not to be the result of the 
RIS Directive.  

Nevertheless,  three  user  representative  organisations  and  two  RIS  developers  do 
acknowledge  the  potential  for  efficiency  gains  in  the  future149.  Although  not  all  of  them 
believe the Directive specifically plays a role in this, one of them explained that work on 
lock and bridge digitalisation being carried out in the context of the RIS COMEX project, 
which would not exist without the Directive, will promote efficiency gains. 

C.  Improved safety and security  

  There is no robust evidence to prove that the RIS Directive has improved 

safety in inland navigation  

An assessment of the correlation between  changes in the number  of  accidents recorded 
and the implementation of the RIS Directive does not show a statistically significant 
relationship150. This indicates that, at least at the level of individual Member States151, it 
cannot be proven whether or not the RIS Directive had an effect on safety.  

It should be noted, however, that accident data in Europe is not yet measured in a 
standardised  way,  and  is  therefore  difficult  to  compare  across  countries,  but  also  not 
always accurate. In Belgium and the Netherlands, for example, consulted RIS authorities 
specified  that  the  accident  data  they  collect  has  changed  over  time  to  be  much  more 
detailed and granulated. As such, data might show an increase in accidents, but this does 
not necessarily mean there has been an actual increase in accidents, just an increase in 
(voluntary) reporting of such accidents.  

As a result, when looking at data from the Netherlands, the RIS Directive seems to have 
led to an increase in accidents (and therefore, a decrease in safety), but this relationship 
is not statistically significant and unlikely to be correct.  

  Despite the lack of quantitative evidence, consulted stakeholders strongly 

believe safety in inland navigation has improved  

Considering the inaccuracy of available quantitative accident data, it is relevant to assess 
the  Directive’s  effect  on  safety  qualitatively.  The  overwhelming  majority  of  the 
stakeholders consulted, both public and private, believe the RIS Directive had a positive 
impact on safety.  

Of  the  fifteen  waterway  users  and  their  associations  consulted,  eleven  specifically 
highlighted an improvement in the degree of safety as a result of the RIS Directive. 
They explain that they feel safer because they are quickly made aware of threats to safe 
navigation, can use AIS to see other vessels and avoid collisions, and use electronic charts 
with the necessary details about the fairway to avoid collisions with infrastructure. A similar 

149 See section 6.1. on optimised use of infrastructures, Annex 2 “Findings from the interviews” to the Stakeholder 

Consultation Report. 

150 See section 6.2.2.3 “Accidents” in Annex 6 “Ex-post social cost-benefit analysis” 

151 Bulgaria, Croatia, Hungary, Austria, Slovakia, Romania, Germany  

54 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

pattern  emerged in the open public consultation, where 42 respondents believe the RIS 
Directive to have contributed to enhanced safety in inland navigation152. 

The one skipper who indicated through the questionnaire that they did not feel safer as a 
result  of  the  RIS  Directive  did  not  detail  why.  Based  on  the  assessments  of  eight 
interviewed RIS authorities across different Member States, it can be speculated that this 
is simply because of a doubt in the degree of attributability to the RIS Directive. As 
explained above, there is no reliable evidence to conclude that there has been a reduction 
in the number of accidents in inland navigation in Europe at all, and even if there has been, 
it might not be due to the RIS Directive specifically.  

  It is unclear whether the RIS Directive had any effect on security in inland 

navigation  

Although  a  cross-check  of  national  security  and  data  protection  rules  resulting  from  the 
RIS Directive falls outside the scope of the present study, consultations with stakeholders 
shed light on some changes in this regard. 

Three  interviewed  RIS  authorities  (Austria,  Bulgaria,  the  Netherlands)  specifically 
mentioned that the RIS Directive had an impact on their legal approach to data safety. 
For instance, in Austria they specified access rights and storing times for RIS in their inland 
waterway  transport  law,  and  in  the  Netherlands,  the  “Scheepvaartverkeerswet”  was 
updated to clarify which data should be used for what purpose. Another authority, however, 
stated that although security measures in their country have developed over time, this is 
not because of the RIS Directive, as “the inland waterway sector does not have [enough] 
power to change national law”.  

Despite  this,  however,  the  existence  of  online  websites  such  as  vesselfinder.com, 
marinetraffic.com and others, are offering services that are in complete opposition to the 
Directive’s  articles  concerning  privacy  and  re-use  of  public  information  because  they 
publish vessel information illegally. Paired with the evidence collected in the context of EQ 
2 (i.e. the lack of international data exchange because of privacy concerns), this indicates 
that there is room to further streamline approaches to data security and protection. One 
RIS  authority  explained  that  this  is  being  done  through  the  RIS  COMEX  project,  which 
ensured that “if the data owner (skipper) wants to allow someone to look at his position 
information, he can give him the rights to do so”. If this is a success, it will imply a positive 
effect of the RIS Directive on security through its funding for cross-border projects like RIS 
COMEX.  

D.  Increased environmental protection  

  There is no robust evidence base to suggest that the RIS Directive has led 

to a reduction in fuel consumption  

Several sources indicate that RIS have the potential to decrease the energy consumption 
in inland navigation by anywhere between 0% and 25.4%153. On the basis of the available 
evidence,  the  study  team  could  estimate  the  average  annual  decrease  of  the  energy 
efficiency of final energy consumption of domestic navigation for the 13 relevant Member 
States  between  2009  and  2017  at  1.86%.  However,  the  data  does  not  take  into 
consideration external factors such as the more stringent technical requirements and the 
fleet renewal which often included engine renewal as well. The assessed time period also 
reflected relatively high fuel prices, which created an incentive for vessel owners to find 
ways  to  decrease  their  energy  consumption,  e.g.  through  more  ecological  sailing.  As  a 

152  See Question 1  in  section  7.2.1.,  Annex  3  “Findings  from  the open  public  consultation”  to  the Stakeholder 

Consultation Report.  

153 See section 6.2.2.5 “Energy consumption” in Annex 6 “Ex-post social cost-benefit analysis” 

55 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

result,  this  general  decreasing  trend  in  energy  consumption  cannot  reliably  be 
attributed to the RIS Directive.  

Although  a  total  of  thirteen  interviewed  stakeholders  from  the  public  and  private  sector 
acknowledged that it might be possible for RIS, through improved lock management and 
planning, to reduce fuel consumption on vessels, they also acknowledge that it is difficult 
to measure the degree to which this is attributable to the RIS Directive alone. According 
to  three  of  them,  external  factors  such  as  advancements  in  technology  and  training  of 
skippers, as well as a shift towards more ecological thinking, also play a role.  

  There is no proof that the RIS Directive improved environmental protection 

through the timely response to environmentally harmful accidents  

Environmental  protection  through  more  efficient  calamity  abatement  was  also 
acknowledged by interviewed stakeholders as a potential way for the RIS Directive to bring 
about positive change. As briefly assessed under EQ 2, interviewees from the private and 
public  sectors  speculate  that  if  there  are  fewer  accidents,  there  will  be  fewer  oil  spills, 
which thus decreases the negative environmental impact. Relatedly, if information about 
a ship (i.e. through e-ship reporting) is known, calamity abatement will be faster and more 
efficient, which can also reduce the impact an accident has on the environment. According 
to  29  respondents154  to  the  open  public  consultation,  calamity  abatement  has  indeed 
improved since the introduction of the Directive.  

Nevertheless, the lack of proof of an actual decrease in accidents resulting from the RIS 
Directive,  and  the  lack  of  international  exchange  of  electronic  ship  reports  makes  it 
unlikely that the RIS Directive had any significant impact in this regard.  

  Although  limited,  there  is  evidence  of  a  reduction  in  pollution  and 

congestion, but stakeholders believe there is potential for more  

Eurostat data shows a decrease in the overall emissions of carbon dioxide, nitrous oxide, 
and methane for water transport in the 13 relevant Member States since the adoption of 
the RIS Directive155. This trend makes sense considering the indication that overall energy 
consumption in inland waterways transport has decreased as well. However, once again it 
is difficult to attribute this effect to the RIS Directive because it cannot be proven 
that it had a significant effect in this regard. Rather, it is likely that external factors such 
as technical requirements on engines and after-treatment systems, cleaner diesel (more 
use  of  EN  590  low  sulphur  content)  and  on-shore  electrification  influenced  this  change 
instead.  

However, the RIS Directive primarily intended to decrease emissions and pollution not in 
the inland waterway transport sector, but rather through the modal shift away from more 
polluting sectors like road transport. In this context, considering the lack of evidence of a 
modal  shift  actually  having  occurred,  it  does  not  appear  to  have  met  its  goal.  Although 
only one interviewee believes the Directive reduced the negative impact of transportation 
on the environment through a modal shift away from road transport to inland navigation, 
there is shared acknowledgement that the Directive has the potential to do so156, 
provided that it is fully implemented and RIS technology is used to its full potential. 

154 Out of the 42 respondents who provided input to the question, 14 believe there were significant improvements, 
15 moderate improvement, 7 no improvements, and 1 believes it got worse. The others indicated they could 
not provide an answer to this question. See Question 3 in section 7.2.3, Annex 3 “Findings from the open public 
consultation” to the Stakeholder Consultation Report.  

155 See section 6.2.2.6 “Emissions, Greenhouse gases and well-to-tank” in Annex 6 “Ex-post social cost-benefit 

analysis” 

156 A total of nine interviewed stakeholders from the public and private sector believe there is potential in this 

regard. 

56 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.2. EFFICIENCY 

3.2.1.  Preparation of the relevant Regulations  

EQ 7: What costs/negative impacts have been associated with the preparation of the relevant Regulations and 
how  are  they  distributed  amongst  those  involved?  (excluding  the  comitology  process  for  adopting 
Implementing Acts). Are there areas, including organisational aspects, with potential for efficiency gains? 

Context  

The RIS Directive was prepared by the Commission services, which culminated in a policy 
proposal  to  the  European  Parliament  and  the Council in  2004157.  The  preparation  of  the 
subsequent Implementing Acts, which detail technical specifications for the different RIS 
technologies, were prepared by the Commission on the basis of technical inputs by the RIS 
expert groups. This question considers the costs incurred in this process, on the side of the 
Commission, as well as the relevant Member States through their participation in the expert 
groups.  

Box  9.  Summary  of  findings  on  EQ  7  –  costs  associated  with  the  preparation  of  the  relevant 
Regulations  

The Commission incurred costs associated with the preparation of the RIS Directive 
and associated Implementing Acts, but there is no indication that the costs incurred 
were  disproportionate  to  the  achieved  outcome,  nor  whether  there  is  potential  for 
efficiency gains in the process.  

The  Member  States  incurred  costs  associated  with  the  preparation  of  the 
Implementing Acts, though it is unclear exactly how much time and money was spent 
on this. However, there are indications that their costs were  not disproportionately 
high, and there are no indications of possible efficiency gains.  

Findings  

  There  are  no  indications  of  disproportionate  costs  associated  with  the 
preparation  of  the  RIS  Directive  and  associated  Regulations  from  the 
Commission’s side 

On  the  side  of  the  European  Commission,  the  preparation  of  the  RIS  Directive 
reportedly involved 1 FTE. The Implementing Acts involved 1.5 FTE respectively. There 
is  no  clarity  about  how  much  money  was  spent  in  this  process,  including  on  studies 
commissioned to prepare for the relevant acts.  

The  preparation  of  the  Implementing  Acts  was  done  in  cooperation  with  technical 
expert groups, which continue to exist today158. The expert groups carry out the technical 
work towards standardisation of RIS. They produce the standards and updates, as well as 
corresponding  technical  guidelines.  The  expert  groups  are  composed  of  various 
representatives  active  in  inland  navigation,  such  as  governmental  bodies,  branch 
organizations, research institutes, consultants and industry. The costs incurred by these 
expert groups were not collected.  

157 COM(2004) 392 final, Proposal for a Directive of the European Parliament and of the Council on harmonised 

River Traffic Information Services on inland waterways in the Community. 

158 There are four expert groups, for each of the RIS key technologies: ECDIS expert group, ERI expert group, 

NtS expert group, VTT expert group.  

57 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

It was not suggested that these costs were disproportionately high. On the contrary, it was 
suggested  that  the  process  would  take  more  time  and  effort  now,  considering the  strict 
requirements brought about by the Commission’s Better Regulation Guidelines159. There 
are no indications of possible efficiency gains.  

  It is unclear how much time and money were spent by the Member States 
in the preparation of the Implementing Acts, though their costs were not 
disproportionately high  

The Member States estimate the preparation of the Implementing Acts to have involved 
anywhere between 0.2 and 8 full-time public staff160. On average, across Belgium, Austria, 
Slovakia, Czechia and Serbia, this totalled 4,5 FTE.  

Only three Member States provided an indication of the monetary  costs associated with 
this process. In Czechia, where the lowest FTE rate was reported, this only cost EUR 8,640. 
In Romania, this was estimated at EUR 20,000, and in Serbia at EUR 40,000.  

However,  the  above  is  all  self-reported  data,  and  was  not  cross-checked  for  accuracy. 
Additionally, the data samples are not adequate and reliable enough to be extrapolated to 
other Member States. As such, this information should only be considered as an indication 
of  the  cost  associated  with  the  preparation  of  the  Implementing  Acts  in  those  Member 
States that provided the data.  

Nevertheless, it can be assumed that there is no disproportionate cost associated with 
this  preparation  process,  because  all  six  RIS  authorities  that  provided  input  via  the 
questionnaire indicated that there were no disproportionate costs. There are no indications 
of possible efficiency gains, except for complaints about slow standard-setting (see EQ 13).  

Costs and negative impacts of RIS technologies  

EQ 8: What costs/negative impacts has the Directive given rise to in order to advance resource planning of 
users  of  the  inland  waterways  through  improved  (a)  data  for  navigation  and  planning,  (b)  electronic 
navigational charts and (c) notices to skippers? How do these compare to the benefits established? 

A.  Data for navigation and planning  

Context  

This section assessed the costs associated with data for navigation and planning on the 
side  of  RIS  authorities  and  users  of  the  waterways,  based  on  quantitative  cost  data 
collected through targeted questionnaires, as well as qualitative data where applicable. It 
also compares these costs to the benefits established under EQ 1a, in order to conclude 
whether or not the RIS Directive has been cost-effective in this regard.  

159 European Commission (2017), Better Regulation Guidelines, SWD(2017) 350 

160 The Romanian authority indicated 157 staff members, but this is assumed to be a mistake so is not included 
here. See Question 4 in section 5.2.2., Annex 1 “Findings from the survey questionnaires” to the Stakeholder 
Consultation Report.  

58 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Box 10. Summary of findings on EQ 8a –data for navigation and planning  

RIS authorities incur significant one-time implementation costs associated with 
making data for navigation and voyage planning available to waterway users. Despite a 
lack  of  reliable  cost  data  to  prove  this,  a  qualitative  assessment  of  changes  in  costs 
strongly indicates the RIS Directive led to increased costs in this regard.  

RIS authorities also incur annual, ongoing costs associated with keeping data up-
to-date and accessible to users. It is unclear, however, based on the limited evidence 
available, whether these costs increased or decreased over time. External factors, such 
as the costs of individual service providers and software in different Member States, are 
likely to influence this, making an EU-wide comparison difficult.  

Users of the waterways do not incur any one-time or annual ongoing costs in 
relation to data for navigation and planning, because the data is made available to them 
free  of  charge.  Paired  with  the  benefits  accrued  to  them  (i.e.  better  voyage  planning 
resulting  from  more  accurate  and  timely  information),  this  implies  that  benefits 
outweigh costs for users. 

There is no indication of social or environmental costs or negative impacts resulting from 
data for navigation and planning.  

Findings  

Economic costs  

  RIS authorities incur significant one-time implementation costs for making 

data for navigation and planning available  

Among the five RIS authorities that provided input to the questionnaire for this question161, 
all indicated having incurred one-off costs in relation to making data for navigation and 
planning available to comply with the RIS Directive. Nevertheless, there is no consensus 
on  the  change  in  costs  associated  with  making  the  data  available  –  two  reported  a 
significant increase in costs, one a small increase, and two believe costs remained stable. 
No surveyed RIS authority therefore believes the RIS Directive led to a decrease in costs 
in this context. Interviews further clarified that the one-off investment costs were relatively 
high  due  to  the  need  to  invest  in  human  resources  and  software,  as  well  as  in  new 
measurement systems in some cases (e.g. Romania)162.  

In the Netherlands, for example, it is estimated that it cost around EUR 600,000 to prepare 
for the provisions of navigation and planning data.  In Austria, the costs associated with 
the implementation of “national lock management, the national fairway availability services 
and the national Smartphone App” totalled EUR 322,000 in 2006 and EUR 92,000 in 2013, 
after  which  annual  adaptation  costs  decreased  but  remained  significant.  Romania 
reportedly spent EUR 1 million in 2005 and EUR 2.9 million in 2013 on “new communication 
and measurement systems”163.  

However, these costs are self-reported by RIS authorities and have not been fact-checked 
for their accuracy. Additionally, as cost estimations were only provided by four authorities 
and they vary considerably, it is not possible to reliably extrapolate this to estimate 
the total costs associated with making data for navigation and planning available across all 

161 Austria, Belgium (Flanders), Czechia, Romania, Slovakia  

162 See Question 46 and Question 47 in section 5.2.6., Annex 1 “Findings from the survey questionnaires” to the 

Stakeholder Consultation Report. 

163  It  was  considered  that  perhaps  this  figure  was  reported  in  Romanian  leu  rather  than  Euro’s.  However,  an 
interviewee further commented that Romania spent “a few million Euro’s on a RIS app”. It is unclear whether 
this is an estimation or is factually correct.  

59 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Member  States.  Based  on  qualitative  evidence  collected,  however,  it  can  be  reliably 
concluded that one-off implementation costs were incurred by all relevant Member States.  

  There  are  indications that  RIS  authorities  incur  annual ongoing costs  for 

data for navigation and planning, but these seem insignificant  

After  the  initial  investment  costs,  data  for  navigation  and  planning  implies  annual 
ongoing  costs  for  RIS  authorities  for  the  collection  and  distribution  up-to-date 
information.  Three  out  of  the  four  RIS  authorities  who  provided  input  through  the 
questionnaire indicated that they incurred annual ongoing costs. Very few details on these 
were provided, however.  

In  Romania,  for  example,  costs  associated  with  the  maintenance  of  equipment  and 
software totalled EUR 40,000 in 2006. It decreased somewhat over the years, totalling EUR 
17,000  in  2018.  A  total  of  10-12  additional  hours  were  reportedly  spent  within  the 
Romanian national authority in order to make data for navigation and planning available. 
Such  details  were  not  provided  by  any  other  authorities.  In  Austria,  annual  operational 
costs  of  “national  lock  management,  the  national  fairway  availability  services  and  the 
national Smartphone App” increased over time, from an average of EUR 26,800 per year 
between 2006-2013, to an average of EUR 37,300 per year in the 2014-2019 period. They 
noted that the time spent on making this data available is not quantifiable.  

The  lack  of  concrete,  reliable  and  comparable  cost  data  does  not  allow  for  robust 
conclusions on the change in costs associated with making data for navigation and planning 
available. A qualitative assessment indicates that costs exist, but may not be significant, 
as  there  is  disagreement  as  to  the  magnitude  of  costs  and  whether  they  increased  or 
decreased over time. Factors such as the costs of service providers chosen for the relevant 
software  and  equipment  can  greatly  influence  costs  across  Member  States  as  well,  so 
extrapolating costs to the EU level is not possible.  

  It  is  unclear  whether  the  benefits  of  data  for  navigation  and  planning 

outweigh their costs  

Due  to  the  limited  reliability  of  available  cost  data,  it  is  difficult  to  assess  the  cost-
effectiveness of data for navigation and planning. As discussed under EQ 1a, there 
is  no  evidence  of  cost  savings  for  RIS  authorities,  and  the  other  apparent  benefits  are 
created for the sector as a whole.  

Nevertheless,  four  RIS  authorities164  believe  the  costs  are  proportionate  to  the  overall 
benefits achieved. None of them indicated the opposite, so it is assumed that all Member 
States agree that despite significant costs, the data is useful to have, and costs are at least 
balanced  with  the  benefits  accrued  to  the  sector  as  a  whole.  This  is  underlined  by  the 
findings from the open public consultation: 11 out of the 13 public authorities who provided 
input believe the provision of data for navigation and planning requires medium to high 
effort, but that compared to the benefits brought about, this effort is adequate165.  

  Waterway  users  do  not  incur  any  one-time  or  ongoing  costs  associated 
with  data  for  navigation  and  planning,  indicating  that  benefits  outweigh 
costs  

All  relevant  data  concerning  navigation  and  voyage  planning  on  inland  waterways  is 
provided free of charge by the Member States, which implies that waterway users do not 
incur any one-time or annual  ongoing costs in this regard. This is substantiated by 
the fact that four of the five waterway users who responded to this part of the questionnaire 
believe costs associated with data for navigation and planning had not changed since the 

164 Austria, Belgium, Czechia, Romania  

165 See Question 4 and Question 5 in section 7.2.4, Annex 3 “Findings from the open public consultation” to the 

Stakeholder Consultation Report for details.  

60 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

adoption  of  the  RIS  Directive,  despite  the  belief  that  the  information  provided  had 
increased.  The  fifth  respondent,  a  port  business  association,  indicated  that  costs  had 
actually  decreased  as  a  result  of  the  Directive.  While  findings  from  the  open  public 
consultation highlight the opposite, with all private sector respondents indicating a medium 
to high effort, it is likely that the question was misunderstood166, so these findings do not 
carry much weight.  

Users did  not highlight any  negative impacts or problems associated with data for 
navigation and planning. Paired with the fact that there are no costs involved, it is safe to 
assume that the benefits outlined under EQ 1 (i.e. users being better informed and making 
more  informed  navigational  decisions,  which  in  some  cases  can  lead  to  cost  savings 
through more efficient sailing) outweigh the costs.  

Social and environmental costs  

  There  is  no  evidence  suggesting  any  social  or  environmental  costs  or 

negative impacts associated with data for navigation and planning  

There is no evidence to point to any costs or non-monetisable disbenefits associated with 
data  for  navigation  and  planning.  As  there  is  also  no  concrete  evidence  of  social  or 
environmental benefits directly related with data for navigation and planning (see EQ 1a), 
no  assessment  of  the  degree  to  which  the  social  and  environmental  costs  and  benefits 
compare can be made.  

B.  Electronic Navigational Charts (ENC)  

Context 

This section assessed the costs associated with electronic navigational charts on the side 
of RIS authorities and users of the waterways, based on quantitative cost data collected 
through  targeted  questionnaires,  as  well  as  qualitative  data  where  applicable.  It  also 
compares these costs to the benefits established under EQ 1b in order to conclude whether 
or not the RIS Directive has been cost-effective in this regard.  

166  Throughout  the  data  collection,  many  interviewees  seemingly  did  not  know  what  is  meant  by  “data  for 
navigation and planning”, and the contractor had to explain that it concerned the minimum data included in 
Annex I of the Directive. We assume that this same issue may have presented itself in the OPC, as skippers 
and  NGOs  should  not  have  incurred  any  costs  resulting  from  the  requirements  on  data  for  navigation  and 
planning.  

61 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Box 11. Summary of findings on EQ 8b – electronic navigational charts  

RIS authorities incur significant one-time investment costs associated with making 
electronic  navigational  charts  available.  Although  limited  quantitative  evidence  is 
available,  and  the  available  data  is  not  comparable  across  cases,  there  are  strong 
indications that these costs are significant in all Member States.  

Costs for RIS authorities seem to decrease over time, as updates to existing charts 
are less  costly than providing new charts.  However, there is little to no concrete data 
available  to  support  this,  and  the  available  data  is  not  comparable  across  countries 
because  costs  vary  significantly  based  on  the  density  of  waterways  and  the  rate  of 
updates. 

Despite the significant costs incurred by RIS authorities in making electronic navigational 
charts available, there are strong indications that the costs are outweighed by the 
benefits accrued to the sector as a whole.  

This  is  substantiated  by  the  fact  that  the  costs  incurred  by  waterway  users  are 
marginal. They need to invest in the necessary hard- and software to be able to use 
the  charts  for  navigation,  but  those  costs  are  low.  All  consulted  users  and  their 
associations believe the benefits outweigh these costs.  

There  is  no  evidence  of  social  or  environmental  costs  or  negative  impacts 
produced by the RIS Directive in the context of electronic navigational charts.  

Findings  

Economic costs  

  RIS  authorities  incur  significant  one-time  investment  costs  for  making 

electronic navigational charts available  

Making electronic navigational charts available implies  landslide investment costs for 
RIS authorities. Developing the charts costs time and money, as the authorities either 
need  to  measure  the  relevant  data  and  provide  the  charts  themselves,  or  contract  an 
external service provider to do so. However, it is near impossible to isolate the one-time 
costs  associated  with  making  electronic  navigational  charts  available  from  the  overall 
investment costs associated with the RIS Directive, as they are interlinked (e.g. electronic 
charts are in part based on data for navigation and planning) and because RIS authorities 
seemingly do not make this distinction. Through the questionnaires, RIS authorities from 
five  Member  States  indicated  that  they  incurred  one-time  costs  associated  with  making 
electronic navigational charts available, notably through costs associated with investments 
in  additional  software  tools  or  application  development.  Limited  details  on  actual  costs 
incurred were provided167.  

In  Flanders,  for  example,  the  RIS  authority  indicates  that  these  one-time  costs  totalled 
EUR  140,000  in  2009,  EUR  37,000  in  2010,  and  EUR  34,000  in  2014.  In  Austria,  these 
costs fluctuated over time, with the most significant investment being EUR 24,190 in 2008, 
assumingly resulting from the adoption of the Implementing Act concerning Inland ECDIS. 
In  Slovakia,  investments  totalled  EUR  17,900  in  2005,  EUR  147,600  in  2006,  and  EUR 
7,260 in 2010. An interview with the RIS authority in the Netherlands, however, indicated 
that the production of electronic charts cost a total of EUR 1.5 million, which is due to the 
fact that the Netherlands has the densest inland waterway network in Europe.  

The variance in one-time investment costs makes it difficult to extrapolate costs associated 
with making electronic navigational charts available to the EU-level. Based on qualitative 

167 See Question 23 and Question 24 in section 5.2.4., Annex 1 “Findings from the survey questionnaires” to the 

Stakeholder Consultation Report. 

62 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

evidence collected, however, it can be reliably concluded that one-off costs were incurred 
in all relevant Member States, and are considered significant.  

  Annual  ongoing  costs  for  RIS  authorities  exist  but  are  much  lower  than 

investment costs 

After  the  initial  investment,  RIS  authorities  incur  annual  ongoing  costs  associated 
primarily  with  the  updating  of  electronic  navigational  charts.  This  also  implies  that  staff 
needs to be trained to create the charts, which costs time and money.  

Member  State  authorities  agree  that  they  incur  annual  costs  associated  with  keeping 
electronic  navigational  charts  up  to  date168,  although  they  differ  between  countries. 
According to the authorities in Austria, Czechia and Slovakia, costs for making electronic 
navigational  charts  available  have  increased  somewhat  over  time.  Austria  specified, 
however, that this is not the result of the Directive, but rather technological evolutions in 
the  production  of  the  charts.  In  fact,  they  believe  the  standardisation  of  the  charts 
through the RIS Directive has lowered costs throughout Europe due to harmonisation. 
Authorities in Belgium and Romania agree that costs decreased  over  time, as the initial 
production of charts is much more costly than keeping them up-to-date.  

The annual costs for maintenance of equipment and software is estimated at an average 
of EUR 4179 per year for the 2006-2019 period in Slovakia, with an additional EUR 1740 
spent every year on other ongoing costs for making charts available. Similarly, in Serbia, 
this amounted to a total of EU 4500 per year, since the implementation of RIS in 2015. In 
Austria, however, these costs amounted to an average of EUR 10,607 per year between 
2006-2019, which is significantly higher. Other authorities did not provide a breakdown of 
annual costs, so it is difficult to assess how this compares across Europe.  

It can be assumed, however, that countries with more frequent update rates incur more 
costs than those countries who rarely provide updates to their charts. As the frequency of 
updates is not mandated by the RIS Directive (see EQ 1b), this is considered an external 
factor influencing costs. Proof of this influence is not available due to the lack of reliable 
and comparable cost data.  

  Despite  high  costs  for  RIS  authorities,  electronic  navigational  charts  are 

perceived to be a cost-effective measure  

There are strong indications that despite the one-time and annual costs incurred by RIS 
authorities and the limited benefits brought about for them, the benefits accrued to users 
of the waterways make the investments worthwhile.  

None of the RIS authorities consulted through the interviews and targeted questionnaire 
believe costs associated with making charts available are disproportionately high. In the 
open public consultation, three of them indicated that their provision required a high effort 
overall, in light of the benefits brought about, although they did not specify whether this 
effort is disproportionately high. RIS authorities from a total of ten countries169 specifically 
indicated,  through  the  questionnaire,  open  public  consultation  and  interviews,  that  the 
benefits  outweigh the costs.  This  was  confirmed  at  the  DINA  Expert  Group  meeting, 
where all 15 participants agreed with this finding170.  

168 Flanders indicated in the questionnaire that they do not incur such costs. However, the fact that the charts 
are updated once a year (where necessary) indicates that they may have misinterpreted the question. However, 
this was not further clarified in the interviews.  

169 Austria, Belgium, Bulgaria, Croatia, Czechia, France, Germany, Romania, Serbia, and Slovakia  

170 11 participants agree with the preliminary finding that the benefits of electronic navigational charts outweigh 
their costs, and 4 strongly agree. None of the participants disagreed with this finding. See Figure 217 in section 
8.2, Annex 4 “Findings from the events attended” to the Stakeholder Consultation Report. 

63 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  Cost incurred by waterway users related to electronic navigational charts 

are marginal and outweighed by their benefits  

The 2014 Panteia study on RIS Implementation for the 2006-2011 period found that the 
initial  investment  cost  for  Inland  ECDIS  (i.e.  purchase  of  the  necessary  hardware, 
software and GPS services) lays between EUR 970 (basic) and EUR 3,400 (advanced)171. 
Additionally, the maps cost between 0 and EUR 250 per year - they are made available for 
free, though users pay for the added services (e.g. radar overlays) by developers on the 
market to be able to use the charts for navigation. Paired with annual update costs between 
EUR 50 and  EUR 340,  and the assumption that most vessels already  had the necessary 
hardware (i.e. a computer with internet connectivity) on board, this implies that costs for 
users of the waterways are marginal, especially compared to the overall cost of a vessel.  

Although  this  is  based  on  2012  cost  data,  evidence  collected  within  the  context  of  the 
present study further confirm that costs are low. Through the questionnaire, a total of 
four user associations and two skippers indicated not having incurred any costs additional 
to what they would have spent in the absence of the RIS Directive. Three user associations 
did  experience  one-time  investment  costs,  although  they  did  indicate  that  their  costs 
decreased  over  time.  Details  on  the  exact  costs  were  not  provided,  although  one 
interviewed user association based in Poland estimates this investment cost to be EUR 250 
for the software and EUR 500 for the computer172, which many skippers already had on 
board prior to the RIS Directive. Annual maintenance contract costs are marginal – Tresco 
services cost skippers EUR 1 per day, and Periskal charges EUR 395 per year.  

There  is  thus  widespread  agreement  that  costs  associated  with  electronic  navigational 
charts  are  low,  and  benefits  (i.e.  more  informed  navigational  decision-making,  and  a 
perception of improved safety) are considered significant (see EQ 1b). As a result, it can 
be concluded that the benefits of electronic navigational charts outweigh the costs incurred 
by users, which is apparent from the results of the questionnaire and interviews173.  

Social and environmental costs  

  There  is  no  evidence  suggesting  any  social  or  environmental  costs  or 

negative impacts associated with electronic navigational charts  

There is no evidence to suggest that the RIS Directive, through its provisions on electronic 
navigational charts, produced any social or environmental costs or negative impacts. On 
the contrary, as there are indications that the charts have simplified the daily operations 
of skippers and potentially improved safety in inland navigation, it seems the charts have 
only brought about benefits but no costs in this regard.  

C. 

Notices to Skippers (NtS) 

Context 

 This section assessed the costs associated with standardised notices  to skippers on the 
side  of  RIS  authorities  and  users  of  the  waterways,  based  on  quantitative  cost  data 
collected through targeted questionnaires, as well as qualitative data where applicable. It 
also  compares  these  costs  to  the  benefits  established  under  EQ  1c  in  order  to  conclude 
whether or not the RIS Directive has been cost-effective in this regard.  

171 See Table 9.2, Panteia (2014), Evaluation of RIS Implementation for the period 2006-2011 

172 This estimation is based on the Navigo software. Other software applications may be more or less expensive, 

but such details were not provided by interviewees.  

173  See  Question  29  in  section  5.3.3.,  Annex  1  “Findings  from  the  survey  questionnaires”  to  the  Stakeholder 

Consultation Report.  

64 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Box 12. Summary of findings on EQ 8c – notices to skippers  

The RIS Directive, through its requirements for making available notices to skippers, has 
produced the following economic costs for RIS authorities:  

  One-off compliance costs, notably with regards to the software needed to provide 
standardised,  encoded  and  downloadable  notices  as  required  by  the  Directive. 
Although limited concrete data is available, it is clear from stakeholder consultations 
that this is the main cost incurred for authorities.  

  One-off development and training costs, as the coding guidelines are extensive 
and complex, and require a certain level of IT knowledge and know-how. No concrete 
data to prove this is available, but there are indications from stakeholders that this 
is the case.  

  Ongoing implementation costs, notably for updates to software due to changes 
in technical requirements, and time and money spent on day-to-day operations. Very 
limited data is available to prove this, and there is no indication that costs incurred 
in this regard are even attributable to the Directive.  

Despite  incurring  costs,  RIS  authorities  did  not  experience  negative  impacts  and 
acknowledge the benefits standardised notices to skippers bring to the inland navigation 
sector  as  a  whole,  and  agree  that  their  costs  are  therefore  proportionate  to  the 
benefits. 

As notices to skippers are made available free of charge, RIS users did not incur any 
additional costs as a result of the RIS Directive. Although there is not enough evidence 
to conclude that costs have decreased either, the negligible costs combined with a lack 
of  negative  impact  and  considerable  benefits  provide  a  strong  indication  that  the 
benefits outweigh the costs for users.  

No negative social or environmental impacts or costs resulting from standardised notices 
to skippers were identified. No negative impacts of the RIS Directive in relation to notices 
to skippers were identified.  

Findings  

Economic costs  

  RIS authorities incurred one-off compliance costs for making standardised 

notices to skippers available  

RIS authorities incurred additional investment costs in the form of one-off costs for the 
software necessary to encode notices to skippers, or setting up a website for dissemination. 
Although  there  are  countries  where  notices  to  skippers  were  already  being  provided 
digitally  prior  to  the  adoption  of  the  RIS  Directive  (e.g.  Belgium,  Netherlands),  changes 
needed to be made to bring the notices fully in line with the requirements of the Directive.  

As  only  four  RIS  authorities174  provided  data  in  this  regard,  these  cannot  reliably  be 
compared.  In  Belgium,  for  instance,  the  initial  set-up  of  the  relevant  webservice 
(nts.flaris.be) cost €302,855 in 2008. In Romania, software costs amounted to €42,150 in 
2005,  with  an  additional  €138,287  spent  in  2013  and  €200,000  in  2018  on  software 
updates. Austria and Czechia provided breakdowns of software costs spread over several 
years, ranging from €1,200 in Austria in 2019 to €67,315 in Czechia in 2011. This data is 
self-reported, and their verification is beyond the scope of this study.  

174 Austria, Belgium (Flanders), Czechia, Romania 

65 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  No  adequate evidence to conclude  whether year-on-year  implementation 

costs were significant  

RIS authorities incurred limited implementation costs on an annual basis. This includes 
software updates, as well as time and money spent making notices available. The former 
is considered negligible because most Member States were already providing them (albeit 
in paper format) prior to the adoption of the Directive. Such costs are incurred occasionally, 
when technical standards are updated (i.e. the move from NtS 3.0 to NtS 4.0).  

With  regards  to  the  time  and  money  spent  on  making  standardised  notices  to  skippers 
available, no reliable details were collected175. Although all Member States were asked to 
provide such data, limited year-on-year data was provided176. The data that was provided 
is not comparable across countries and can therefore not be extrapolated to all relevant 
Member States. This is reportedly because RIS authorities do not distinguish between the 
time  and  money  spent  specifically  on  the  provision  of  standardised  notices  to  skippers 
compared to  other RIS-related activities. Even  if this data was adequately collected and 
made available, it is unlikely that it could be attributed to the RIS Directive  as  such, as 
that would require a comparison to costs incurred before its implementation.   

Despite the lack of concrete quantitative data, some indications on changes in costs were 
provided. Among the six authorities that returned the questionnaire with an indication of 
costs for notices to skippers, three (all from Eastern European countries)177 believed the 
overall costs associated with the provision of notices to skippers had increased somewhat 
as a result of the RIS Directive, one believed they had increased significantly178, and one 
believed they remained stable179. They indicated that administrative costs decreased (due 
to digitalisation), while operational costs (e.g. software to publish notices online, keeping 
up with changing standards) increased.  

  Despite costs borne by RIS authorities, they perceive notices to skippers 

to be a cost-effective measure  

Despite the existence of costs for RIS authorities, and the disparities in their magnitude 
across  countries,  all  authorities  believe  the  benefits  associated  with  standardised 
notices  to  skippers  outweigh  their  costs,  notably  because  of  digitalisation  (i.e. 
reduction  in  “paperwork”)  and  online  availability,  automatic  translations,  and  their 
influence on the safety  of inland navigation. All six questionnaire respondents180 believe 
that  the  costs  associated  with  providing  notices  to  skippers  are  proportionate  to  the 
benefits they bring to the inland navigation sector. In interviews, three of them 181 further 
explained that this is because the costs are marginal, and yet notices to skippers are widely 
used by skippers.  

Although  this  is  a  limited  number  of  interviewees  to  base  conclusions  on,  nobody 
indicated  that  costs  are  disproportionate  to  benefits.  In  fact,  respondents  to  the 
open public consultation ranked notices to skippers as the RIS technology for which the 
effort needed is most appropriate considering its benefits, with only two of them indicating 

175 RIS authorities in all 13 relevant Member States were asked via a questionnaire to estimate the time spent 
making notices to skippers available (in FTE), as well as indicating the associated full-time salary equivalent of 
staff members providing notices, and the number of hours spent doing so.  

176 See Question 35 and Question 36 in section 5.2.5., Annex 1 "Findings from the survey questionnaires" to the 

Stakeholder Consultation Report. 

177 Romania, Slovakia, Czechia 

178 Belgium  

179 Austria 

180 Austria, Belgium (Flanders), Czechia, Romania, Slovakia, Serbia 

181 Czechia, Slovakia, Serbia  

66 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

the  effort  is  high  in  comparison  to  the  benefits182.  This,  combined  with  the  evidence 
outlined  under  EQ  1c  above  makes  it  safe  to  assume  that  authorities  highly  value  the 
standardised  notices  to  skippers  and  believe  their  implementation  is  cost-effective.  No 
negative impacts were identified.  

  Users incur no significant additional costs but there is also no evidence of 

costs saved  

When it comes to users, it can be assumed with quite some certainty that the RIS Directive 
did  not  create  additional  costs183.  The  notices  are  provided  online,  free  of  charge. 
Therefore, skippers do  not incur additional costs to access them (assuming they have a 
computer or mobile phone with Internet access). 

In some cases, where notices to skippers are integrated with other key technologies, it is 
possible to receive them through an ECDIS viewer. More specifically, this is possible on the 
Periskal Viewer in six Member States184. In that case, the skipper needs to invest in the 
technology (i.e. Periskal Viewer). However, this is not an additional cost that is directly 
attributable to the RIS Directive for notices to skippers specifically, as it is required to 
access electronic navigational charts on board.  

At the same time, however, as already outlined under EQ 1c, there is no concrete evidence 
to suggest that the Directive led to cost savings for RIS users.  

  Low costs paired with considerable benefits for users make standardised 

notices to skippers a cost-effective measure  

Among  the  four  users  who  provided  input  to  the  questionnaire  on  this  topic,  three  (all 
operating mainly on the Danube corridor) believe benefits are higher than costs. The fourth 
respondent, who is active primarily on the Rhine, indicated that benefits do not outweigh 
costs, but specified that they sail a set route on a set schedule, thus indicating they do not 
make use of notices to skippers in their daily lives. Although this number of user responses 
is  too  low  to  derive  any  robust  conclusions,  the  general  perception  emerging  from 
interviews was comparable – benefits outweigh costs associated with notices to skippers, 
with benefits being more noticeable in Danube countries than Rhine countries.  

Only one RIS user was able to provide an example of negative experiences using notices 
to skippers, though this was related to the inaccuracy  of data contained therein (bridge 
heights  and  lock  rings  incorrectly  indicated).  No  negative  impacts  were  highlighted. 
Considering the extensive benefits brought about for skippers, it is safe to assume that the 
benefits outweigh the costs on the side of RIS users.  

Social and environmental costs  

  No evidence of social or environmental costs or disbenefits associated with 

standardised notices to skippers  

There is no evidence to point to any costs or unmonetizable disbenefits associated with the 
standardisation of notices to skippers. On the contrary, as detailed under EQ 1c, there are 
indications  that  there  may  have  been  benefits  in  this  regard  (i.e.  improved  safety  and 
communication, less fuel consumption). Although there is limited evidence to back up those 

182  See Question 5  in  section  7.2.4.,  Annex  3  “Findings  from  the open  public  consultation”  to  the Stakeholder 

Consultation Report.  

183  The  only  questionnaire  respondent  that  indicated  costs  had  changed,  believed  that  they  had  somewhat 

decreased. 

184  As  per  the  2018  fact-finding  study,  this  is  possible  in  Austria,  Belgium  (Flanders),  Germany,  Hungary, 
Netherlands, Slovakia. This pertains to NtS standard version 3.0  only. Details on the integration with Tresco 
Navigis and Innovative Navigation (IN) are not available and were not highlighted by stakeholders consulted in 
the context of the current study.  

67 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

claims,  it  indicates  that  notices  to  skippers  definitely  brought  about  more  benefits  than 
costs in these areas.  

3.2.2.  Electronic ship reporting  

EQ 9: What costs / negative impacts has the Directive given rise to in order to advance cost savings through 
the reduction in re-submission of electronic ship reports when crossing a border? How do these compare to 
the benefits established? 

Context  

This section assessed the costs associated with electronic ship reporting on the side of RIS 
authorities and users of the waterways, based on quantitative cost data collected through 
targeted  questionnaires,  as  well  as  qualitative  data  where  applicable.  It  also  compares 
these costs to the benefits established under EQ 2 in order to conclude whether or not the 
RIS Directive has been cost-effective in this regard.  

Box 13. Summary of findings on EQ 9 – electronic ship reporting  

It  is  unclear  whether  the  RIS  Directive,  through  its  provisions  on  electronic  ship 
reporting, has created benefits that outweigh the costs. However, there is an issue of 
attributability, as the requirements for electronic ship reporting are largely left up to 
the Member States and the River Commissions.  

There  is  inadequate  evidence  to  make  conclusions  about  the  costs  incurred  by  RIS 
authorities as a result of the RIS Directive, although there seems to be agreement that 
costs can be reduced in the future if electronic ship reporting is further implemented in 
line  with  the  Directive  (i.e.  if  reports  are  actually  shared  across  border  to  reduce 
resubmissions).  

On  the  side  of  RIS  users,  costs  and  time  spent  have  increased  for  some  but 
decreased for others. This may be the result of reporting requirements on the Rhine 
(e.g. if reporting is mandatory, users spend time reporting when they previously did not 
have to), which are mandated by the CCNR instead of the RIS Directive. It is unlikely 
that costs have changed significantly in either direction as a result of the RIS Directive, 
although there is no reliable cost data to back this assumption up.  

There  is  no  evidence  suggesting  the  RIS  Directive  brought  about  any  social  or 
environmental costs or negative impacts with regards to the provisions on electronic ship 
reporting.  

Findings  

Economic costs  

  It  is  unclear  whether  costs  incurred  by  RIS  authorities  for  processing 

electronic ship reports are proportionate to the benefits achieved  

RIS authorities incur one-time investment costs related to setting up the necessary 
systems  for  receiving  and  processing  electronic  ship  reports.  This  was  highlighted  by 
authorities  in  Austria,  Czechia,  France,  Luxembourg,  the  Netherlands,  Romania,  and 
Slovakia, and can reasonably be expected to apply to the other relevant Member States as 
well.  

68 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Although none of the consulted authorities could provide a breakdown of the costs 
associated with receiving, processing and passing on electronic ship reports respectively185, 
there  are  some  indications  of  the  total  costs  associated  with  this  process  in  four  of  the 
relevant Member States186. There seems to be no clear pattern across Member States in 
terms of the magnitude of these costs, and there are doubts about the reliability of the 
available data. 

There  seem  to  be  no  significant  recurring  annual  costs  that  result  specifically  from 
provisions on electronic ship reporting. Three RIS authorities believe their costs remained 
stable over time, while one experienced a small increase and one a significant increase187. 
A RIS authority in Flanders, who believes costs remained stable over time, detailed that 
recent investments in digitalisation will lead to cost savings in the future.  

This trend seems to be in line with the general view held by authorities – considering the 
limited data exchange between countries and the inefficiencies brought about as a result, 
there  is  considerable  room  to  further  reduce  resubmissions  and  thereby  save  time  and 
costs for public authorities. With more electronic reporting and fewer resubmissions, the 
administrative  burden  for  authorities  is  expected  to  decrease.  However,  as  previously 
assessed (see EQ 2), there is no robust evidence base to suggest cost savings have already 
taken place.  

As a result, it is unclear whether the benefits of electronic ship reports outweigh 
the costs. Considering the limited benefits (see EQ 2), and varying costs, no conclusion 
can be made in this regard. Even consulted stakeholder are divided – three RIS authorities 
believe their costs are proportionate to the benefits, while three others do not. They agree, 
however, that there is potential for improvement, and value the concept of electronic ship 
reporting regardless of its high costs.  

  There are indications that electronic ship reporting has led to time savings 
for  some  waterway  users  but  additional  costs  for  others,  so  their  cost-
effectiveness is unclear  

As discussed under EQ 2, users of the waterways are expected to experience cost savings 
as a result of reduced resubmissions. As resubmissions have not reduced in reality, these 
cost savings seemingly have not materialised (yet).  

In principle, there are no significant costs associated with the voyage reporting on the 
side of RIS users – they only need a computer with internet access, which they likely have 
on board already and do not need to invest in specifically to comply with the RIS Directive. 
The costs savings, instead, are supposed to result from time saved by (1) submitting ship 
reports in an electronic format, and (2) this format being standardised so reports can be 
shared across relevant Member States so the vessel operator does not have to submit the 
information more than once.  

According  to  four  interviewees,  costs  for  skippers  have  decreased  as  a  result  of  the 
Directive  because  their  administrative  burden  decreased.  However,  three  of  them 
represent RIS authorities and one is a RIS developer, so they may not be well-informed. 
In reality, most consulted waterway users and their representative organisations did not 
experience time savings as a result of the RIS Directive in this regard. Three private sector 
associations and an interviewee from a river commission, for example, acknowledged that 

185  Austria  estimated  this  at  EUR  1.7  per  e-ship  report,  calculated  based  on  the  assumption  that  2/3  of  the 
operational costs for DoRIS are spent on e-ship report processing. Based on the total number of e-ship reports 
received,  this  would  reportedly  add  up  to  EUR  1.7  per  report.  However,  based  on  the  numbers  of  reports 
received and operational costs reported, this does not seem to add up so is not considered a reliable number.  

186 See Question 57 and Question 58 in section 5.2.7., Annex 1 “Findings from the survey questionnaires” to the 

Stakeholder Consultation Report.  

187 This was stated by Austria and Slovakia, respectively. Austria specified that this is due to the operational costs 

of the DoRIS portal, but that the costs are outweighed by benefits.  

69 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

the administrative cost has in fact increased188 because skippers need to resubmit e-ship 
reports more than once. An increase in costs, however, is unlikely to be the result of the 
RIS  Directive  specifically,  as  it  does  not  make  reporting  mandatory  for  waterway  users, 
and does not stipulate the type of information requested from them, which is left to the 
Member States themselves.  

Therefore, although there is no consensus on the magnitude of costs for waterway users 
and the direction in which these changed over time, it is unlikely that the RIS Directive has 
led to an increase or decrease in costs. Although two users experienced time savings from 
not having to hand over the reports in paper form, this benefit is likely weighed out by the 
additional time spent reporting the same information more than once because of the lack 
of data exchange between RIS authorities.  

Social and environmental costs  

  There is no evidence pointing to social or environmental costs or negative 

impacts stemming from electronic ship reporting  

No  evidence  was  found  to  suggest  that  the  RIS  Directive,  through  its  provisions  on 
electronic ship reporting, produced any social or environmental costs or negative impacts. 
On  the  contrary,  the  digitalisation  of  ship  reporting  should  reduce  the  amount  of  paper 
used in inland navigation, which should positively impact the environment. Although there 
is no evidence to support that this is indeed the case, it can be speculated that such an 
effect may exist.  

3.2.3.  Type-approval of RIS equipment  

Context  

This  section  assessed  the  costs  associated  with  type-approval  of  RIS  equipment  on  the 
side  of  RIS  authorities  and  the  private  sector,  based  on  quantitative  cost  data  collected 
through  targeted  questionnaires,  as  well  as  qualitative  data  where  applicable.  It  also 
compares these costs to the benefits established under EQ 2 in order to conclude whether 
or not the RIS Directive has been cost-effective in this regard.  

EQ 10: What costs/negative impacts has the Directive given rise to in order to advance cost savings for users 
of  the  inland  waterways  brought  about  by  changes  in  the way equipment  is  type  approved?  How  do  these 
compare to the benefits established? 

Box 14. Summary of findings on EQ 10 – type approval of RIS equipment  

Very limited evidence regarding the costs associated with changes to type-approval 
of RIS equipment as a result of the RIS Directive is available, because type-approvals 
are only issued by one organisation based in Germany.  

As type-approved equipment is mutually recognised across Europe, it can be assumed 
that no additional costs are incurred by RIS authorities. However, this also does 
not imply that costs are saved, except for the opportunity costs saved as a result of not 
having to issue type-approvals in their own country.  

The  private  sector  (i.e. RIS developers) incur  costs associated with getting their 
products type-approved. However, these  costs  are  seemingly not that significant, and 
weighed  out  by  the  benefits.  The  mutual  recognition  of  type-approved  equipment 

188 This is likely the result of electronic reporting being made mandatory on the Rhine for container ships in 2010. 
Hence, this is not attributable to the RIS Directive. See section 6.2., Annex 2 “Findings from the interviews” to 
the Stakeholder Consultation Report.  

70 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

ensures a product only needs to be certified once to be used all across Europe, which is 
beneficial for the market as a whole.  

There  is  no  evidence  to  suggest  any  social  or  environmental  costs  or  negative 
impacts resulting from changes in type-approval as a result of the RIS Directive. 

Findings  

Economic costs  

  There is no evidence of any additional costs created by the RIS Directive 

through changes in type-approval of RIS equipment 

As  assessed  under  EQ  3,  there  is  only  one  body  in  the  EU  that  issues  type  approvals  - 
Wasser- und Schifffahrtsverwaltung des Bundes, Fachstelle der WSV für Verkehrstechniken 
(FVT) in Germany. Thus, they are the only ones who incur costs for issuing type approvals. 
Considering the fact that mutual recognition works well (see EQ 3), other RIS authorities 
should not incur any additional costs. Unexpectedly, the consulted RIS authorities indicated 
indeed not having occurred any one-time or recurring costs, because they don’t carry out 
their own type-approvals. On the  contrary, they benefit with regards to the  opportunity 
costs of not having to issue their own type-approvals themselves.  

Due to a lack of data, there is no evidence to suggest that RIS authorities have saved 
money through the mutual recognition of type-approved RIS equipment as established by 
the Directive. Although one authority believes this is the case, it is unlikely that cost savings 
have actually occurred, as these authorities would never have carried out their own type-
approvals anyway.  

  Type-approval  of  RIS  equipment  implies  costs  for  the  private  sector  but 

these are likely outweighed by their benefits  

Type-approval  does  imply  one-time  costs  for  the  private  sector  that  has  to  get  the 
equipment type-approved. One RIS service provider estimated this to cost at around 5000 
EUR  per  product,  though  another  said  it  was  around  EUR  500  instead.  No  other 
interviewees  could  provide  estimations  of  these  costs,  and  no  quantitative  evidence  to 
compare their assessments to was made available.  

However, given that type-approvals are mutually recognised across Europe, means that all 
equipment  only  needs  to  be  certified  once.  Therefore,  developers  save  costs  otherwise 
spent ensuring their product is approved in all Member States, which would in turn drive 
up costs for consumers. Given that RIS developers believe that mutual recognition of type-
approved equipment has been beneficial to the sector as a whole (i.e. improved quality of 
products that is guaranteed to work across Europe, which safeguards investments, see EQ 
3), it can be assumed that they believe these costs are outweighed by the benefits.  

Social and environmental costs  

 

 There is no evidence of social or environmental costs or negative impacts 
resulting from changes in type-approval of RIS equipment  

No evidence was collected to suggest that the changes to type-approval of RIS equipment 
brought about by the RIS Directive produced any social or environmental costs or negative 
impacts.  

71 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.2.4.  Establishment of a harmonised, interoperable RIS  

EQ  11:  What  costs/negative  impacts  has  the  Directive  given  rise  to  overall  in  order  to  establish  an  inter-
operable, harmonised RIS? How do these compare to the benefits established? 

Context 

The establishment of a harmonised, interoperable RIS implies costs both for RIS authorities 
and users of the waterways. This section considers how the overall costs compare to the 
benefits achieved, at the level of the RIS Directive as a whole. Thus, it serves as a summary 
of EQs 8-10, with the addition of findings that apply to the Directive more generally, rather 
than  one  of  its  components.  This  question  presents  a  qualitative  assessment,  and  is 
complemented  by  a  more  quantitative  assessment  of  costs  compared  to  benefits  at  the 
level of general objectives in EQ 14.  

Box 15. Summary of findings on EQ 11 – costs and benefits of a harmonised, interoperable RIS  

Although  the  costs  of  RIS  implementation  incurred  by  RIS  authorities  and  inland 
waterway users cannot accurately be extrapolated to the level of the RIS Directive 
as a whole, there are indications that costs are outweighed by benefits.  

  For  RIS  authorities,  despite  considerable  investment  and  implementation  costs 
overall, there is widespread agreement that these are outweighed by the benefits 
created. No negative impacts of the RIS Directive were identified.  

  For inland waterway users, although not all of them agree, the costs associated 
with the implementation of the RIS Directive were marginal. As such, and considering 
no  negative  impacts  were  identified,  it  can  be  concluded  that  their  costs  are 
outweighed by the benefits.  

Findings  

  The costs of RIS implementation cannot be extrapolated to the level of the 

RIS Directive as a whole  

As detailed under  EQ 8, EQ 9 and  EQ 10, there is very limited evidence  as to the costs 
associated with the implementation of the different aspects of the RIS Directive. In many 
cases, RIS authorities are unable to distinguish between the overall costs related to the 
implementation of the RIS Directive, let alone distinguish between costs associated with 
RIS  as  such  and  the  RIS  Directive  specifically.  As  a  result,  very  limited  data  was  made 
available, and that which was cannot be compared or extrapolated to the level of the RIS 
Directive as a whole.  

Nevertheless, a qualitative assessment of the overall costs compared to the benefits of the 
RIS Directive has been undertaken189.  

  Benefits seemingly outweigh costs incurred by RIS authorities  

In the questionnaire, RIS authorities were asked to indicate the main benefits and costs 
associated with the implementation of the RIS Directive as a whole. The most often cited 
benefits of the Directive as a whole were as follows:  

  Harmonisation  of  equipment  that  can  be  used  all  over  Europe  through  common 

technical standards;  

189  A  quantitative  assessment  of  costs  compared  to  benefits  at  the  level  of  the  general  objectives  of  the  RIS 

Directive is included under EQ 14.  

72 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

 

Improved safety in inland navigation, including through a reduction in accidents;  

  Availability of fairway information;  

 

Improved awareness and political salience of RIS;  

  The creation of a legal framework to justify costs and investments.  

In terms of negative consequences, only two of the six RIS authorities provided input. They 
highlighted a lack of harmonisation and occasionally outdated service standards, as well 
as the lacking legal basis for international data exchange as problems. One RIS authority 
explicitly noted that there were no negative consequences.  

Three  RIS  authorities  indicate  that  the  benefits  outweigh  their  costs,  and  two  did  not. 
Considering  the  fact  that  the  individual  inputs  of  the  Directive  are  primarily  considered 
cost-effective, as discussed under EQ 8, EQ 9 and EQ 10, it is safe to conclude that  RIS 
authorities believe the benefits of the RIS Directive outweigh its costs.  

  Benefits largely outweigh costs incurred by inland waterway users  

In the questionnaire, inland waterway users and their representative organisations were 
asked to indicate the main benefits and costs they believed to be brought about by the RIS 
Directive. The most often cited benefits were as follows:  

 

Improved safety;  

  Better access to information;  

  Better communication;  

 

Improved planning and management;  

Two  of  them  also  specifically  mentioned  reduced  costs  as  one  of  the  benefits  of  the 
Directive. However, two others indicated that costs had increased because of the Directive, 
as initial investments needed to be made.  

Nevertheless, the fact that the costs for waterway users at the level of the different inputs 
are marginal, and their benefits are significant, it is safe to conclude that the benefits for 
waterway users largely outweigh their costs.  

3.2.5.  Unintended negative effects  

EQ 12: Has the Directive had unintended negative economic, social or environmental effects?  

Context  

Similar to EQ 5, it is possible that additional negative effects, that were unexpected at the 
time of adoption of the RIS Directive, occurred. This question assesses whether any such 
unintended effects, notably negative economic, social or environmental effects occurred.  

Box 16. Summary of findings on EQ 12 – unintended negative effects  

There  is  no  strong  evidence  that  the  RIS  Directive  has  brought  about  unintended 
negative economic, social or environmental effects.  

Although  there  are  indications  of  negative  social  effects  such  as  the  deskilling  of 
workers and threats to data privacy, these concerns are not shared by enough consulted 
stakeholders to base firm conclusions on, and no further evidence is available. 

73 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Findings  

  There  is  no  evidence  suggesting  the  RIS  Directive  produced  unintended 

negative economic effects  

No evidence was found of unintended negative economic effects brought about by the 
RIS Directive.  

  There are indications that the RIS Directive produced unintended negative 

social effects  

In terms of negative social effects that were not intended by the RIS Directive, a number 
of examples were provided by consulted stakeholders.  

Three interviewees190 highlighted data privacy issues that come with digitalisation of the 
sector, e.g. illegal online vessel tracking. One of them explained that digitalisation makes 
the  sector  more  vulnerable  to  cyberattacks  and  blackouts.  In  turn,  they  believe  this 
negatively impacts the reputation of the sector, though there is no concrete evidence to 
back up this claim. The possibility of negative effects on the privacy of skippers and the 
availability of sensitive information as a result of RIS were already identified in the 2006 
SPIN-TN assessment of RIS implementation191, though it was not quantified or estimated.  

Another  negative  social  effect  following  digitalisation  in  inland  navigation  through  RIS 
mentioned by two interviewees is the possible deskilling of skippers and boat masters. 
They believe the RIS technologies have become unmissable in skippers’ lives, especially 
for  younger  people,  which  can  create  problems  if  something  is  not  working  or  e.g. 
electronic charts are not up to date. According to one interviewee, this is intensified by the 
fact that the RIS Directive only applies to waterways of CEMT class IV and above, which 
can lead to a loss of safety and efficiency on smaller waterways because many people no 
longer can sail without technology on board. 

There is no concrete reliable evidence to prove or disprove these findings. However, 
unintended effects are largely assessed qualitatively, so the experiences of stakeholders 
are highly relevant in this regard.  

  There  is  no  evidence  suggesting  the  RIS  Directive  produced  unintended 

negative environmental effects  

No evidence was found of unintended negative environmental effects brought about by 
the RIS Directive.  

3.2.6.  Simplification and reduction of regulatory burden  

EQ 13: Is there a potential for simplification and reduction of regulatory burden in the process? 

Context  

This question assesses  the extent to which there are any  regulatory burdens associated 
with the implementation of the RIS Directive, and identifies ways in which these can be 
minimised  or  simplified,  if  relevant.  Although  not  directly  covered  in  the  question,  the 
administrative burden associated with implementing the Directive, both for RIS authorities 
and RIS users, is also briefly covered here.  

190 One RIS authority, one international organisation and one user representative organisation  

191 ViaDonau, Assessment of the Implementation of River Information Services in Europe. Working Paper, 2006, 

p. 18.  

74 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Box 17. Summary of findings on EQ 13 – simplification and regulatory burden  

There  are  no  disproportionate  administrative  costs  for  RIS  authorities  nor  for 
waterway users. However, in both instances there is still a potential to further reduce 
the administrative burden associated with day-to-day operations.  

  For RIS authorities, more and better international data exchange can reduce double 
work.  Especially  in  the  context  of  electronic  ship  reporting,  there  is  room  to 
harmonise approaches for efficiency gains.  

  For inland waterway users, there is a need to further digitalise RIS services, and 
also  to  reduce  the  burden  associated  with  double  reporting,  which  would  be 
eliminated through better and more data exchange on the side of the authorities.  

The fact that technical standards take time to be adopted across the EU is considered a 
regulatory burden. This creates problems, because technology is constantly evolving, 
and the technical requirements need to keep up to remain relevant.  

Findings  

  There are no disproportionate administrative costs but there is a potential 
to further reduce the administrative burden placed on RIS authorities  

Most  RIS  authorities  believe  there  are  no  disproportionate  administrative  costs 
associated with the implementation of the RIS Directive. Even the three authorities who 
specifically believe the costs to be significant, state that they are not disproportionate to 
the outcomes. They highlight costs associated with changing national regulations, the need 
for RIS experts, internal coordination and coordination with other countries in case of cross-
border voyages. One national authority from outside of the EU expects the administrative 
costs  to  increase  further  with  the  introduction  of  CESNI  working  groups,  while  another 
authority  from  an  EU  Member  State  expects  costs  to  decrease  because  of  further 
advancements in digitalisation.  

Nevertheless,  there  is  a  widespread  agreement  among  authorities  that  there  are 
administrative burdens that can be further reduced. The most notable bottleneck is 
found in international data exchange. As detailed under EQ 1 and EQ 2, there is still a lack 
of  cross-border  data  exchange,  e.g.  for  electronic  ship  reporting.  If  this  exchange  is 
facilitated,  it  is  expected  to  save  the  authorities  time  currently  spent  receiving  and 
processing the information.  

A  suggested  possible  solution  to  this is  to  re-use  public  sector  information  and improve 
access  to  private  sector  data  for  public  authorities  with  a  view  to  lowering  the 
administrative  burden  of  collecting  and  analysing  necessary  data192.  Four  different 
authorities  highlighted  a  need  to  work  together  across  borders  through  projects  and 
potentially a single portal to share data and information. 

  There seems to be a potential to reduce the administrative burden placed 

on users of the waterways  

A similar pattern emerges on the side of waterway users. They are divided on the degree 
to  which  the  RIS  Directive  impacted  their  administrative  costs  –  four  skippers  did  not 
experience any change, while two experienced an increase in costs and two a decrease in 
costs. Those who noted a decrease in administrative costs detailed that this was the result 

192 See COM(2018) 232 final – Communication from the Commission to the European Parliament, the Council, 
the European Economic and Social Committee and the Committee of the Regions “Towards a common European 
Data Space” and “Good Navigation Status – towards achieving a Good Navigation Status” (EU Commission  – 
STC-Nestra) January 2018. 

75 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

of  less  administrative  paperwork.  Those  who  highlighted  spending  on  new  equipment, 
training to be able to use the equipment, and time spent on cargo declaration.  

As a result, although a total of six interviewed user representative organisations believe 
there is no disproportionate administrative burden, they do acknowledge that there 
are still considerable cumbersome processes like double reporting, booking slots at locks, 
and paperwork where there is room for simplification.  

For example, barge operators need to comply with relevant legislation – both safety-related 
and  non-safety  related  (e.g.  provision  of  statistics).  In  many  cases,  this  includes  filing 
certain  declarations  to  the  authorities,  e.g.  on  voyages  with  dangerous  cargo  and 
containerised freight. Currently, due to the lack of data exchange between RIS authorities, 
barge  operators  often  have  to  file  the  same  data  multiple  times,  either  to  comply  with 
different  aspects  of  legislation  or  because  they  are  dealing  with  multiple  jurisdictions  in 
cross-border operations, or both. The underlying problems are the  existing ‘declaration-
based’ reporting system and the limited re-use of data by authorities193.  

Similarly, several studies in the transport sector show that further digitalisation of data is 
urgently needed. The limited availability of up-to-date information on traffic conditions is 
a problem for barge operators because it makes it difficult for them to adapt their voyage 
plans  based  on  real-time  conditions.  Several  studies  in  the  transport  sector  show  that 
further digitalisation of data is urgently needed.  

However, it should be noted that the issue of data exchange may be difficult to address 
through the RIS Directive. Although rules can be established, reporting legislation is left 
up  to  the  Member  States  and  River  Commissions,  which  is  why  different  requirements 
persist.  As  such,  even  if  data  is  shared,  but  one  Member  States  requires  additional 
information not reported in the first instance, users will still have to resubmit their reports.  

  A regulatory burden emerges from the speed at which technical standards 

are updated and adopted  

There seems to be agreement among stakeholders that the RIS Directive suffers from a 
lack of flexibility and slow implementation194, in that it takes a long time for technical 
standards  to  be  updated,  which  is  not  in  line  with  the  speed  of  IT  and  technological 
advancements. One expert who has been closely involved in this process explained that 
new standards for Inland ECDIS and notices to skippers developed through working groups 
took 1-3 years to be reflected because of the slow regulatory process. According to a RIS 
authority:  “The  procedure  for  the  updating  of  the  technical  specifications  is  much  too 
complicated and the Commission has not been able to publish the specifications within the 
timeframe defined by the directive. A simplified and faster procedure is urgently needed”.  

Stakeholders’  suggestions  for  simplifications  related  directly  to  faster  adaptation  to  new 
technical  standards.  Two  authorities  suggested  that  they  should  not  try  to  reinvent  the 
wheel – the initial years of implementation were difficult but the newer Member States can 
learn from those that are more advanced, and avoid double work. Regular updates, e.g. 
every  two  years,  are  considered  more  useful and  adequate  in  this  regard.  Although  not 
specifically noted by interviewees, the switch to CESNI/TI standards is expected to at least 
partially  solve  this  problem.  Assessing  whether  it  will  do  so,  however,  falls  beyond  the 
scope of this study.  

193 European Commission (2017), Digital Inland Waterway Area - Towards a Digital Inland Waterway Area and 

Digital Multimodal Nodes. 

194 This was highlighted in interviews with two RIS authorities, two River Commissions, and a RIS developer. It 

was also highlighted in open text responses to the open public consultation given by five respondents. 

76 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.2.7.  Costs and negative impacts at the level of general objectives  

EQ 14: What costs/negative impacts has the Directive given rise to in order to advance its general objectives 
and how do these compare to the benefits established under TOR EQ6 (benefits-at level of general objectives)? 

Context  

The  achievement  of  the  general  objectives  of  the  RIS  Directive  comes  with  costs.  This 
question  considers  what  these  costs  are,  their  magnitude,  and  their  division  between 
stakeholders. The costs are subsequently compared to the benefits achieved at the level 
of the RIS Directive’s general objectives, as outlined under EQ 6.  

Box 18. Summary of findings on EQ 14 – overall costs and negative impacts  

There is a lack of reliable data on expected benefits of the RIS Directive (i.e. related 
to  optimised  use  of  infrastructure,  increased  competitiveness  and  improved  safety), 
which  makes  it  difficult  to  carry  out  an  ex-post  cost-benefit  analysis.  The  study  team 
experienced the following problems:  

  Total investment costs of the RIS Directive cannot be granulated at the level of the 

achievement of its general objectives;  

  Benefits such as the number of accidents cannot be quantified reliably at EU level 
because  there  is  a  lack  of  data,  and  the  data  that  is  available  is  not  comparable 
across Member States;  

  Even for benefits that could be quantified, there is limited proof to suggest they are 
directly  attributable  to  the  RIS  Directive  rather  than  the  use  of  RIS  technology  as 
such.  

Nevertheless, if we assume that the RIS Directive directly reduces fuel consumption by 
1.86% per year, and that at least 12% of the vessels that are equipped with RIS actually 
use it for this purpose, then the RIS Directive has experienced a return on investment.  

Findings  

  The costs  of  RIS  implementation  cannot  be  granulated  at  the  level  of  its 

general objectives  

As the RIS Directive’s general objectives (i.e. increase competitiveness, optimise the use 
of infrastructure, improve safety and security, and increase environmental protection) are 
long-term outcomes rather that direct results of investments, it is impossible to granulate 
the costs associated with their achievement specifically. Nevertheless, on the basis of the 
total investment costs and the benefits established under EQ 6, one can assess the overall 
cost-benefit ratio in this respect.  

  Not all benefits can easily be quantified due to a lack of reliable data  

In order to carry out a cost-benefit analysis, benefits need to be quantified and compared 
to  the  monetary  costs  incurred.  However,  not  all  expected  benefits  were  supported  by 
evidence (see EQ 6), or not be identified by the available data. For instance, accidents at 
EU level could not be calculated and quantified because there is no EU-wide methodology 
to  monitor  and  report  on  such  data,  which  makes  an  aggregation  of  national  level  data 
(which also is not available for all relevant Member States) highly unreliable.  

77 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Nevertheless,  the  benefits  accrued  by  a  reduction  in  fuel  consumption  and  resulting 
reduction  in  emissions  could  be  quantified195,  and  have  been  used  to  inform  the  cost-
benefits analysis carried out for the present study.  

  There  are  indications  that  the  RIS  Directive  has experienced  a  return  on 
investment considering the benefits to environmental protection, although 
this link cannot be confidently proven  

With a total investment cost set at EUR 52,090,984196, and based on the assumptions that 
40% of RIS users use their equipment for the purpose of fuel reduction and that there is 
an average annual fuel reduction of 1.86%, the cost-benefit ratio is 3.11197. This positive 
ratio  holds  true  as  long  as  at  least  12%  of  all  equipped  vessels  use  the  on-board  RIS 
equipment for fuel consumption reduction. As soon as less than 12% of all vessels do this, 
the business case becomes negative, meaning that the total investment costs have not yet 
been outweighed by these benefits. 

Although  the  other  expected  benefits  (improved  competitiveness,  optimised  use  of 
infrastructure, and increased safety) could not be proven to be the result of RIS or the RIS 
Directive,  the  fact  that  stakeholders  believe  there  may  be  an  impact  is  nevertheless 
relevant to consider. In the cost-benefit analysis, considering it was not possible to quantify 
these additional possible benefits, they have not been taken into consideration. As such, it 
can be assumed that the positive business case stemming from the return on investments 
produced  by  the  improved  environmental  protection  of  RIS  is  further  magnified  when 
considering additional benefits such as safety and infrastructure use.  

However,  it  should  once  again  be  noted  that  none  of  these  benefits  can  confidently  be 
accrued to the RIS Directive rather than RIS technologies as such. Although there is no 
doubt  that  the  RIS  Directive  has,  at  least  in  some  countries  that  were  previously  less 
advanced in inland navigation, had a considerable impact on the use of RIS. However, it is 
impossible  to  prove  that  these  advancements  would  not  have  occurred  without  the  RIS 
Directive.  

3.3. RELEVANCE  

3.3.1.  Continued relevance of RIS Directive objectives  

EQ 15: Do the original objectives, incorporated in the RIS Directive and in the five related RIS regulations, 
match the needs of the sector today and in the foreseeable future? Please take into account legal, technological 
and market developments. 

Context  

The Directive states that “the development of RIS should be based on objectives such as 
safety,  efficiency  and  the  environmental  friendliness  of  inland  navigation  (…)”198.  These 
increasing 
three  objectives  would  also  naturally  contribute 
competitiveness  in  the  sector  across  Europe.  In  order  to  achieve  these  objectives,  the 

to  another  goal: 

195 See section 6.2.3 “Calculation of identified benefits” in Annex 6 “Ex-post social cost-benefit analysis”. 

196 This amount covers all projects since 1996 that were finished before 2009 and are considered to be crucial to 
allow  the  RIS Directive  to  be  implemented.  The  number  is  based on  data from CEF funding  in  RIS  between 
1995-2022, in EUR (current prices).  

197 See Table 18 “Results of the ex-post SCBA of RIS” in Annex 6 “Ex-post social cost-benefit analysis”. 

198 Preamble (6), Directive 2005/44/EC 

78 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Directive  foresaw  the  implementation  of  tasks  like  “traffic  and  transport  management, 
environment and infrastructure protection and the enforcement of specific rules”199.  

Additionally, the RIS Directive established RIS “with a view to enhancing safety, efficiency, 
and environmental friendliness and to facilitating interfaces with other transport modes”200. 
Nonetheless, the overarching objective of the Directive, mentioned in paragraph (12) of 
the preamble to the RIS Directive, is “to establish harmonised RIS in the Community”.  

In short, the objectives set out in the RIS Directive are:  

  Enhance safety in inland ports and rivers 

  Enhance  efficiency  of  inland  navigation  –  optimise  resource  management  of 
waterborne transport by enabling information exchange between vessels, locks and 
bridges, terminals and ports 

  Better  and  more  effective  use  of  the  inland  waterway  infrastructure  –  providing 

information on the status of fairways 

  Environmental  protection  –  providing  traffic  and  transport  information  for  an 

efficient calamity abatement process and for reducing emissions  

  Better integration of IWT into multimodal supply chains through accurate and timely 

information to support transport management.  

Box 19. Summary of findings on EQ 15 – relevance of the RIS Directive’s objectives  

There is a high degree  of  alignment between the needs of the inland  waterway 
transport  sector  and  the  objectives  laid  out  in  the  Directive.  The  original 
objectives will continue to remain relevant, although the focus will need to shift towards 
those  objectives  that  have  not  yet  been  (fully  achieved),  such  as  the  creation  of  a 
harmonised RIS.  

At the same time, new needs have emerged that should be considered to ensure that 
the RIS Directive remains relevant and addresses the sector’s needs.  

  A strong digitalisation wave has introduced technological developments that need 

to be addressed, especially with regard to data exchange and availability.  

  An increase in political salience of RIS, and hence the development of the sector, has 
prompted the necessity to provide specific training and education on the new tools 
and technologies used in the sector. 

The RIS guidelines and technical standards are still relevant and necessary but need to 
be more flexible to keep up with new needs. Considering the fast pace of technological 
developments, stakeholders consider the process for updating technical RIS standards 
too heavy and slow.  

Findings  

  The needs of the IWT sector and the RIS Directive’s objectives are broadly 

aligned 

When  adopted,  the  RIS  Directive  sought  to  address  the  need  for  more  information  that 
would be shared in a harmonised way, to ensure safety throughout the inland waterway 
transport sector201. The existence of a clear alignment between the objectives set out 

199 Preamble (6), Directive 2005/44/EC 

200 Article 1 (1), Directive 2005/44/EC 

201 Already in 1990, administrations in charge of navigation on the River Rhine considered that the provision of 
essential  information  would  be  crucial  in  dealing  rapidly  and  efficiently  with  accidents  involving  dangerous 

79 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

in the RIS Directive and the needs of the sector was not only confirmed by several 
sources in desk research, but also by all consulted stakeholders.  

Although  the  relevance  of  the  RIS  objectives  seems  to  be  almost  unanimously 
confirmed,  it  appears  that  not  all  objectives  are  regarded  as  being  equally  important. 
Consulted stakeholders consider increased safety as being the most salient and relevant 
objective  of  the  RIS  Directive,  followed  by  enhanced  efficiency  of  inland  navigation, 
optimised use of infrastructure and environmental protection. It seems that safety is the 
primary  need  for  skippers;  while  efficiency  is  fundamental  for  port  authorities  and  RIS 
operators.  The  better  integration  of  inland  waterway  transport  into  multimodal  supply 
chains  was  reported  by  several  interviewees  as  being  a  key  objective  which  will  gain 
prominence  in  the  near  future.  Only  half  of  the  questionnaire  respondents,  however, 
considered this objective to be relevant202.  

  The objectives remain relevant, notably because they have not been fully 

achieved  

As  previously  detailed  under  EQ  4  and  EQ  6,  there  is  limited  proof  of  the  general  and 
specific objectives of the RIS Directive having been met to date. Nevertheless, there is a 
widespread agreement that the Directive has the potential to achieve these goals.  

As  a  result,  a  considerable  number  of  the  stakeholders  consulted  agree  that  these 
objectives not only remain relevant for the future, but also require a shift in focus 
in  order  to  be  fully  achieved203.  Notable  in  this  regard  are  the  need  for  further 
harmonisation204  and  standardisation205,  as  reported  by  interviewed  authorities  and  RIS 
users.  The  partial  achievement  of  relevant  objectives  ultimately  undermines  the  overall 
relevance of the Directive, as it fails to address the sectors’ needs, so it is important that 
these objectives continue to be adequately addressed in their entirety.  

  New needs have emerged as a result of technological developments  

Evidence indicates that the inland waterway transport sector has undergone and will likely 
continue  to  undergo  significant  changes  in  the  future,  due  to  key  developments  that 
brought  about  innovations  as  well  as  disruptions  to  the  sector.  Most  notable  are 
technological changes, such as the automation of vessels and further digitalisation and 
technical innovation of RIS related software and hardware. These technological advances, 
in turn, require better and faster data exchange. Based on desk research and discussion 
with  stakeholders,  technological  developments  are  expected  to  continue  gaining  pace. 
Therefore,  both  waterway  users  and  RIS  authorities  stressed  it  is  fundamental  that  the 
Directive takes them into account.  

Without  clearer  guidelines  on  how  to  develop  and  manage  emerging  technologies  and 
shorter adaptation times to technological disruptions, the RIS Directive will fail to remain 
relevant in the future. Without these elements the Directive will not be properly equipped 
to respond to the new challenges posed by digitalisation in the sector. In relation to the 
emergence of these new needs, several documentary sources and consulted stakeholders 

goods.  As  a  result,  in  the  late  1990s,  several  countries  started  working  on  information  systems  for  inland 
shipping.  However,  their  work  was  not  very  coordinated,  and  this  could  have  led  to  the  implementation  of 
different technologies in each country: skippers would have had to install several systems for their international 
voyages. This would have resulted in extra costs and low acceptance of such solutions among users. 

202 See section 6.3, Annex 2 “Findings from the interviews” and Questions 98a-98e in Annex 1 “Findings from the 

survey questionnaires” to the Stakeholder Consultation report for additional details 

203 This was mentioned by 13 interviewees, both from the public and private sectors. There is no pattern in terms 

of the stakeholder type or geographical location.  

204 The need for further harmonisation was underlined by 12 interviewees. See section 6.3, Annex 2 “Findings 

from the interviews” to the Stakeholder Consultation Report for details.  

205 The need for further standardisation was underlined by four interviewees. See section 6.3, Annex 2 “Findings 

from the interviews” to the Stakeholder Consultation Report for details. 

80 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

from  the  relevant  Member  States  pointed  to  a  key  issue  in  the  legal  framework  of  the 
Directive: the RIS Directive leaves too much room for interpretation, and it is too slow to 
adapt to technological advancements. This in turn, is thought to prevent the Directive to 
fully achieve its current and future objectives, and therefore, to potentially lose relevance 
because of it206.  

  New needs have emerged as a result of market developments  

Aside  from  technological  developments,  another  source  of  changing  needs  are  market 
developments. Since the introduction of the RIS Directive, more and more awareness on 
the inland waterway transport sector and its needs has been achieved. Consequently, the 
sector has gained momentum and received increased attention, in terms of investments 
and funding. The resulting development of the sector has prompted the emergence of new 
needs  in  the  sector.  In  particular,  the  emergence  of  new  tools,  technical  standards  and 
technological  innovations  in  the  sector  has  implied  a  growing  need  for  specific  training. 
This  need  emerged  both  through  desk  research  and  questionnaires207.  The  user  needs 
analysis  conducted  in  the  framework  of  IRIS  Europe  showed  that  there  is  an  increasing 
need for trainings in the IWT Sector208. It is essential that all RIS users have the necessary 
knowledge  to  operate  key  tools  and  applications  for  safe  and  efficient  inland  waterway 
navigation.  Developing and  deploying  the  necessary  tools  and  infrastructure  but  lacking 
the  relevant  knowledge  to  operate  them  would  entail  a  significant  bottleneck  in  the 
implementation of the RIS Directive and the achievement of its key objectives.  

In  parallel,  new  needs  involving  all  transport  modes  have  emerged.  Green,  smart  and 
congestion-free transport and logistics are the key concepts on which the whole transport 
sector will be focusing. It is therefore essential that the IWT sector responds and adapt to 
these changes. A few initiatives have already emerged, calling for a single window enabling 
traffic,  route,  voyage  and  logistics  planning.  To  summarise,  in  the  coming  years  traffic 
management  will  shift  from  safety  management  to  an  operational  service  that  supports 
the logistic transport chain in a more intensive way. 

  The RIS guidelines and technical standards are still relevant and necessary 

but need to be more flexible to keep up with new needs  

Stakeholders  largely  agree  that  the  technical  specifications  for  key  RIS  technologies  (in 
order of magnitude: Inland ECDIS, notices to skippers, Inland AIS, electronic ship reporting 
and the RIS guidelines) are still relevant and needed today, even in light of technological 
developments  since  2005.  Clearly,  they  are  valued,  despite  not  always  being  fit-for-
purpose.  

As outlined under EQ 13, there are strong indications that the technical standards are not 
updated quickly enough, which may cause problems in terms of their continued relevance 
in the future. Additionally, as detailed by respondents to the open public consultation, there 
may be scope to add additional standards, most notably with regards to data for navigation 
and planning209. As discussed under EQ1a, the minimum requirements for the provision of 
this  data  are  considered  too  vague,  and  lead  to  differences  in  interpretations  across 
Member  States.  Introducing  more  detailed  technical  requirements  was  suggested  by 
stakeholders as a possible solution to this problem.  

206 See section 6.3, Annex 2 “Findings from the interviews” to the Stakeholder Consultation Report 

207  See  Question  11  in  section  5.3.2.,  Annex  1  “Findings  from  the  survey  questionnaires”  to  the  Stakeholder 

Consultation Report. 

208  IRIS  Europe  –  Implementation  of  River  Information  Services  in  Europe.  Final  Technical  Report,  see 

https://www.riscomex.eu/wp-content/uploads/2016/12/IRIS_Europe_Final_Technical_Report_V1p01.pdf  

209 See Question 10(bis) in section 7.2.7., Annex 3 “Findings from the open public consultation” to the Stakeholder 

Consultation Report.  

81 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

3.4.COHERENCE 

3.4.1.  Internal coherence of the RIS Directive and its Implementing Acts  

EQ 16: To what extent is the RIS legislation (in scope of this evaluation) internally coherent? Are there any 
internal inconsistencies? 

Context 

The  RIS  Directive  aims  to  establish  “a  framework  for  the  deployment  and  use  of 
harmonised river information services (RIS) in the Community in order to support inland 
waterway  transport  with  a  view  to  enhancing  safety,  efficiency  and  environmental 
friendliness and to facilitating interfaces with other transport modes”210. This overarching 
objective results in the provision of specific (minimum) requirements that are necessary 
to attain the establishment of a common framework for river information services. 

Articles 4 and 5 of the RIS Directive provide for rules regarding the synergy between the 
tasks of the Member States and the European Commission, stating that "the Commission 
shall define […] technical guidelines for the planning, implementation and operational use 
of  the  services  (RIS  guidelines)  as  well  as  technical  specifications  in  particular  in  the 
following areas: 

1)  Electronic  chart  display  and  information  system  for  inland  navigation  (inland 

ECDIS); 

2)  Electronic ship reporting; 

3)  Notices to skippers; 

4)  Vessel tracking and tracing systems; 

5)  Compatibility of the equipment necessary for the use of RIS."211 

As a result, the following Implementing Acts have been adopted: 

  Commission  Regulation  (EC)  No  414/2007  of  13  March  2007  concerning  the 
technical guidelines for the planning, implementation and operational use of River 
Information Services (OJL L 105, 23/04/2007) - based upon the PIANC-guidelines.  

  Commission  Implementing  Regulation  (EU)  No  416/2007  of  22  March  concerning 

the technical specifications for Notices to Skippers 

  Commission Implementing Regulation (EU) No 164/2010 of 25 January 2010 on the 

technical specifications for electronic ship reporting in inland navigation 

  Commission Implementing Regulation (EU) No 909/2013 of 10 September 2013 on 
the technical specifications for the electronic chart display and information system 
for inland navigation 

  Commission Implementing Regulation (EU) No 689/2012 of 27 July 2012 amending 
Regulation 415/2007 concerning the technical specifications for vessel tracking and 
tracing systems 

In line with the Better Regulation guidelines, the evaluation of the coherence of the RIS 
Directive means assessing whether the RIS Directive is construed in a logical and consistent 

210 Article 1 (1), Directive 2005/44/EC 

211 Article 5, Directive 2005/44/EC 

82 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

manner and whether this logic and consistency is extended in relation to the Implementing 
Acts. Therefore, the following criteria were taken into account during the analysis: 

  Coherence and synergy of the RIS Directive and the Commission Implementing Acts  

  Legal clarity and non-ambiguous interpretation of the provisions of the selected EU 

legislation 

 

Identification of any legal shortcomings (inconsistencies, overlaps, gaps) that stand 
in the way of the effective implementation of the RIS Directive or which prevent the 
achievement of its objectives 

Box 20. Summary of findings on EQ 16 – Internal coherence  

From  the  perspective  of  an  internal  legal  coherence-check,  the  RIS  Directive  and  its 
Implementing  Acts  provide  clear  and  coherent  minimum  requirements  to  enable 
cross-border compatibility of national systems. 

The assessment of the RIS Directive as a whole leads the study team to conclude that 
the RIS Directive and its Implementing Acts set up a coherent legal framework for the 
achievement of the Directive’s objectives: the main mechanisms of the Directive, namely 
the establishment of certain requirements for data communication and RIS equipment 
as well as the imposition of a minimum level of RIS services through the Implementing 
Regulations, are coherent and set forth in a logical manner.  

There are no conflicts to report. 

Findings  

  The RIS Directive is coherent internally (within itself) 

Articles 4 and 5 of the RIS Directive provide the outline for the setting-up of RIS, ensuring 
internal  coherence  with  the  wider  context  of  the  RIS  Directive.  Aforementioned  articles 
explain the interplay between on the one hand the tasks and measures Member States will 
need to take in order to develop an efficient, expandable and interoperable RIS application, 
and on the other hand the role of the European Commission in defining technical guidelines 
for notices to skippers, electronic chart display and information systems, vessel tracking 
and tracing systems and electronic ship reporting. 

  The RIS Directive is coherent with the Implementing Acts 

Articles 6, 7 and 9 furthermore ensure that the RIS in use on the inland waterways in scope 
of the RIS Directive are based on the same technologies, data standards and equipment, 
allowing inland navigation to make use of these services consistently throughout the EU.  

In  line  with  its  overarching  objective,  the  RIS  Directive  forms  the  basis  for  the 
establishment of a common system of RIS on the inland waterways in the Member States. 
A prerequisite for harmonised RIS are the introduction of minimum requirements for the 
RIS equipment and the setting of technical standards. Those prerequisites are included in 
a coherent, clear and logical manner in the RIS Directive and correspond to its objectives. 

No  conflicts  were  identified  with  regard  to  the  interrelation  between  the  Implementing 
Regulations and the RIS Directive. 

3.4.2.  External coherence of the RIS Directive with the relevant international 

obligations of the Member States  

EQ  17:  To  what  extent  is  the  Directive  coherent  with  the  relevant  international  obligations  of  the  Member 
States? 

83 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Context  

At  the  time  of  drafting,  the  RIS  Directive  was  developed  to  take  in  due  consideration 
already existing international legislation in the field of inland waterway transport. In fact, 
the new requirements introduced by the Directive “should build on work carried out in this 
field  by  relevant  international  organisations  such  as  the  International  Navigation 
Organisation (PIANC), the Central Commission for Navigation on the Rhine (CCNR) and the 
United  Nations  Economic  Commission  for  Europe  (UNECE)”212.  The  intention  of  the  RIS 
Directive  to  adhere  to  other  international  obligations  of  the  Member  States  is  further 
confirmed in Article 2, paragraph (1): “For the purposes of this Directive, the Classification 
of European Inland Waterways set out in UNECE Resolution No 30 of 12 November 1992 
shall apply” 213.  

Furthermore,  it  is  stressed  that  “the  Commission  shall  take  due  account  of  measures 
developed  by  relevant  international  organisations,  such  as  PIANC,  CCNR  and  UNECE. 
Continuity  shall  be  ensured  with  other  modal  traffic  management  services,  in  particular 
maritime vessel traffic management and information services”214.  

This question assesses the degree to which the RIS Directive is indeed coherent with the 
international obligations of the Member States.  

Box 21. Summary of findings on EQ 17 – external coherence of the RIS Directive  

A careful review of the legal text of the Directive shows a strong intention to maintain 
coherence and guarantee enough interaction between the RIS Directive and other 
pre-existing relevant international obligations of the Member States.  

All sources consulted show no evidence of incoherence with international obligations 
of  Member  States  and  most  stakeholders  agree  with  this  view.  The  RIS  Directive, 
therefore, can be seen as an overarching piece of legislation under which all other 
relevant obligations in the inland navigation sector fall.  

Nonetheless,  some  contradictions  or  inconsistencies  may  arise,  due  to  the 
Directive’s legal framework and its wording, which is considered too broad and vague 
in some respects.   

Findings 

  The  RIS  Directive  maintains  coherence  with  international  obligations  of 

Member States  

As demonstrated in the brief introductory paragraph above, at the time of its drafting, the 
RIS Directive took in due consideration relevant international obligations of Member States, 
notably the work conducted in the IWT sector by PIANC, CCNR and UNECE.  

The  intention  to  maintain  coherence  between  the  Directive  and  obligations  provided  by 
international organisations operating in the field is further confirmed by the Commission’s 
active  engagement  with  these  stakeholders.  In  2014-2017,  the  European  Commission 
strengthened cooperation with the CCNR and the Danube Commission215.  

212 Preamble (3), Directive 2005/44/EC  

213 See https://www.unece.org/fileadmin/DAM/trans/doc/finaldocs/sc3/TRANS-SC3-131e.pdf.  

214 Article 1(2), Directive 2005/44/EC 

215  Examples  include  cooperation  in  the  CESNI,  both  at  the  level  of  expert  groups  and  standardisation  of 
procedures; and support for the mixed Environmental and Transport External Expert Team whereby workshops 
are given to representatives of ministries of transport and environment in a Danube riparian country.  

84 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

At  the  same  time,  cooperation  with  UNECE  has  continued,  concentrating  mainly  on  the 
exchange of information on ongoing activities, with the Commission actively participating 
in the work of respective bodies.  

Stakeholders  consulted  through  interviews  reported  that  no  incoherence  with  other 
relevant  obligations  of  Member  States  was  present.  Nevertheless,  some  of  them 
indicated some potential incoherence that might emerge due to Member States’ differing 
legislations  which  might  undermine  the  common  guidelines  provided  for  by  the  RIS 
Directive216.  For  instance,  as  suggested  by  some  interviewees,  while  the  RIS  Directive 
provides  common  guidelines  for  electronic  ship  reporting,  Member  States  have  different 
police  regulations  and  requirements  that  lead  to  different  ways  of  requesting,  providing 
and checking the reports (see also EQ 2). A few consulted stakeholders reported that, in 
their opinion, this is to be linked to the way the RIS legal framework is structured. In fact, 
it  is  their  belief  that  the  legal  framework  leaves  too  much  room  for  manoeuvre  and 
implementation. This however, does not highlight any inherent incoherence of the Directive 
with  international  obligations  of  Member  States,  but  rather  a  need  for  more  specific 
guidelines  to  avoid  national  laws  interfering  with  the  proper  functioning  of  the  RIS 
Directive.  

Overall, the positive findings collected on the external coherence of the RIS Directive vis-
à-vis relevant international obligations of Member States can be taken with a fair degree 
of certainty, as the in-depth analysis of the legal text of the Directive, the desk research 
and the targeted interviews all point to the same result. 

3.4.3.  External coherence of RIS Directive with other EU legislation 

EQ 18: To what extent is the Directive coherent with other EU legislation in the areas of (a) inland waterway 
transport policy; (b) EU transport legislation; (c) other EU legislation in areas outside transport policy? 

Context  

The  Directive  specifies  that  for  using  AIS,  “the  regional  arrangement  concerning  the 
radiotelephone  service  on  inland  waterways  concluded  in  Basel  on  6  April  2000  in  the 
framework  of  the  radio  regulations  of  the  International  Telecommunication  Union  (ITU) 
shall apply”217.  

The Directive also makes specific reference to two additional legal texts, in its Article 11. 
Article  11  (1)  established  that  the  Commission  shall  be  supported  “by  the  Committee 
instituted  by  Article  7  of  Council  Directive  91/672/EEC  of  16  December  1991  on  the 
reciprocal  recognition  of  national  boatmasters’  certificates  for  the  carriage  of  goods  and 
passengers by inland waterway”218. Article 11 (2-5), instead, specify that the guidelines of 
“Decision 1999/468/EC shall apply, having regard to the provisions of Article 8 thereof”219. 

The  RIS  Directive  also  strives  to  be  coherent  with  EU  legislation  on  the  protection  and 
processing  of  personal  data.  As  reported  in  paragraph  (10)  of  the  RIS  Directive,  “such 
processing should be carried out in accordance with Community rules, as set out inter alia 
in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 220 
on the protection of individuals with regard to the processing of personal data and on the 
free movement of such data and Directive 2002/58/EC of the European Parliament and of 

216 See section 6.4 on coherence, Annex 2 “Findings from the interviews” to the Stakeholder Consultation Report. 

217 Article 4 (5), Directive 2005/44/EC. See also http://www.ancom.ro/uploads/links_files/Legis_RAINWAT.pdf  

218 Article 11 (1), Directive 2005/44/EC  

219 Article 11 (2,3), Directive 2005/44/EC  

220 Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of 
individuals  with  regard  to  the  processing  of  personal  data  and  on  the  free  movement  of  such  data,  see 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31995L0046&from=en  

85 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

the  Council  of  12  July  2002221  concerning  the  processing  of  personal  data  and  the 
protection of privacy in the electronic communications sector.” 

Finally,  for  RIS  that  require  exact  positioning,  the  use  of  satellites  is  required.  In  this 
regard,  the  Directive  established  in  paragraph  (11)  of  its  preamble  that  “These 
technologies should, wherever possible, be interoperable with other relevant systems and 
should be integrated with them, in accordance with applicable decisions in this field”.  

No additional specific references were made in the RIS Directive to other legislative texts 
in the areas of (a) inland waterway transport policy; (b) EU transport legislation; (c) other 
legislation in areas outside transport policy. Nonetheless, by combining desk research with 
targeted consultation activities, more examples of interaction between the RIS Directive 
and other EU legislation were uncovered, as set out below. 

Box 22. Summary of findings on EQ 18 – external coherence of the RIS Directive  

A careful analysis of the Directive’s legal text uncovers several interactions between 
the RIS Directive and other EU legislation in the areas of (a) inland waterway transport 
policy; (b) EU transport legislation; (c) other EU legislation  in areas outside transport 
policy.  

On the one hand, the RIS Directive took in due consideration pre-existing legislation 
in these fields; on the other, more legislation in these sectors came into being after the 
introduction of the RIS Directive.  

All in all, the RIS Directive was coherently developed to be in line with the key priorities 
of a political agenda focusing on increasing the competitiveness of the whole transport 
sector, whilst reducing its environmental print and increasing its degree of digitalisation.  

Findings 

The in-depth analysis of the Directive’s legal text uncovered several interactions between 
the RIS Directive and other EU legislation both within the field of inland waterway transport 
policy and outside it. It should be highlighted that most of the interactions uncovered relate 
to  legislation  that  chronologically  followed  the  RIS  Directive.  Therefore,  should 
inconsistencies be found, it is fair to assume that the later legislation is incoherent with the 
RIS Directive, rather than the other way around.  

  The RIS Directive is coherent with EU inland waterway transport policy  

Within the area of EU inland waterway transport policy, the clear interaction between the 
RIS Directive and the Directive on the recognition of professional qualifications in 
inland  navigation222  (EU)  2017/2397  emerged,  both  through  desk-research  and 
targeted interviews. If on one hand the RIS Directive aims at creating cross-border IWT 
system, Directive 2017/2397 provides a legal basis for crew members to find work more 
easily in a cross-border environment as the EU certificates of qualification will be valid on 
all EU inland waterways.  

221 Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing 
of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and 
https://eur-lex.europa.eu/legal-
electronic 
content/EN/TXT/PDF/?uri=CELEX:32002L0058&from=EN  

communications), 

see 

222 Directive (EU) 2017/2397 of the European Parliament and of the Council of 12 December 2017 on the 

recognition of professional qualifications in inland navigation and repealing Council Directives 91/672/EEC and 
96/50/EC, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017L2397&from=EN  

86 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

A  strong  complementarity  between  the  RIS  Directive  and  the  Directive  on  technical 
requirements  for  inland  waterway  vessels223  (EU)  2016/1629  was  uncovered. 
Indeed, Directive (EU)  2016/1629 accounts for the  standards established by CESNI and 
the  new  European  standard  laying  down  technical  requirements  for  inland  navigation 
vessels ES-TRIN 2017 has been incorporated into EU legislation via a Delegated Act.  

  The RIS Directive is coherent with EU transport legislation  

The RIS Directive is fully aligned with the goals laid out in the European White Paper on 
Transport224.  The  paper,  published  on  28  March  2011,  entitled  “Roadmap  to  a  single 
European Transport Area – Towards a competitive and resource efficient transport system” 
emphasises the essential role to be played by railways and inland waterways in achieving 
climate  targets.  A  key  goal  of  the  strategy  set  out  in  the  paper  is  to  optimise  the 
performance  of multimodal logistic chains and modal shift of road  freight to waterborne 
transport. Clearly, the RIS Directive responds to the necessities highlighted in the paper 
and plays a key role to help achieve its goals.  

Similarly, as part of the “Europe on the move”225 initiative published in May 2017, a key 
proposal to promote multimodal transport, relevant to IWT, was published on 10 November 
2017.  Once  again,  it  can  be  concluded  that  rather  than  the  RIS  Directive  aiming  to  be 
coherent with this initiative, the ‘reverse’ is true: it is the “Europe on the move” initiative 
that is coherent with the RIS Directive.  

  The RIS Directive is coherent with EU legislation in areas outside transport 

policy 

The RIS Directive is in synergy with the Commission communication of 26 August 2010, 
“A  Digital  Agenda  for  Europe”226.  The  communication  identifies  and  highlights  the 
fragmentation of the Digital market, the lack of interoperability and the rise in cybercrime 
as  major  threats  to  the  full  development  of  the  Union’s  digital  economy.  The  inland 
navigation sector is clearly facing the same challenges and at the same time can be one of 
the solutions to the issue of lacking interoperability.  

  The RIS Directive and the EU political agenda 

Overall, it can be stated with a fair degree of certainty that there are no inconsistencies 
between  the  RIS  Directive  and  other  EU  legislation  in  the  areas  of  (a)  inland  waterway 
transport  policy;  (b)  EU  transport  legislation;  (c)  other  EU  legislation  in  areas  outside 
transport policy.  

Importantly,  as  previously  briefly  discussed,  it  must  be  highlighted  that  virtually  all 
interactions  uncovered  are  between  the  RIS  Directive  and  EU  legislation  that 
chronologically followed it. Therefore, if any inconsistencies were to be uncovered, it would 
have been more accurate to say that these other pieces of EU legislation were incoherent 
with the RIS Directive, rather than the opposite. Equally relevant is the fact that such a 
consistent body of legislation in line with the RIS Directive emerged after 2005. This can 
be interpreted in two ways:  

223 Directive (EU) 2016/1629 of the European Parliament and of the Council of 14 September 2016 laying down 
technical requirements for inland waterway vessels, amending Directive 2009/100/EC and repealing Directive 
2006/87/EC, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016L1629&from=EN  

224 White Paper on Transport: Roadmap to a Single European Transport Area, 

https://ec.europa.eu/transport/sites/transport/files/themes/strategies/doc/2011_white_paper/white-paper-
illustrated-brochure_en.pdf  

225 Resilient Energy Union with a Climate Change Policy, http://www.europarl.europa.eu/legislative-train/theme-

resilient-energy-union-with-a-climate-change-policy/package-eu-mobility-package  

226 COM(2010)245 final, A Digital Agenda for Europe, https://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0245:FIN:EN:PDF 

87 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

1)  The RIS Directive clearly identified the challenges and opportunities ahead, both in 
the IWT sector specifically and in the wider EU single market more generally;  

2)  The RIS Directive acted as a precursor and sparked a whole body of EU legislation 

in the field of IWT sector.  

3.5.EU ADDED VALUE 

3.5.1.  Rationale of the RIS Directive  

EQ 19: What are the benefits of intervening at EU level, over and above what could have been reasonably 
expected from interventions at international level (UNECE structure), regional level (river commission) or local 
level alone? In other words, what is the rationale of public intervention at EU level underpinning the Directive? 

Context 

Preamble (12) of the RIS Directive enshrines the rationale of public intervention at EU level 
underpinning  this  legal  text.  “Since  the  objective  of  this  Directive,  namely  to  establish 
harmonised RIS in the Community, cannot be sufficiently achieved by the Member States 
and can therefore, by reason of its European dimension, be better achieved at Community 
level, the Community may adopt measures, in accordance with the principle of subsidiarity 
as set out in Article 5 of the Treaty.” 

Thus,  what  justifies  the  intervention  at  the  EU  level is  the  realisation that  a  community 
action is the only possible way to achieve the desired objective in the framework of the 
RIS  Directive.  This  question  assesses  the  rationale  of  the  RIS  Directive  as  EU  level 
intervention as assessed by stakeholders, notably in relation to what could reasonably have 
been expected to be achieved by the Member States or River Commissions themselves.  

Box 23. Summary of findings on EQ 19 – rationale of the RIS Directive  

The rationale for public intervention at the EU level is to be found in the cross-border, 
international character of the inland waterway transport sector, that therefore 
requires unified EU-level intervention.  

Evidence  suggests  that  the  RIS  Directive  has  an  advantage  over  international 
interventions such as the UNECE guidelines, as the latter are not mandatory.  

There is no consensus as to whether the River Commissions could have achieved at the 
regional level the same objectives as the RIS Directive.  

Nonetheless, all consulted sources point out that the same results could have not been 
achieved at the national level.  

Findings 

  EU intervention is appropriate given the cross-border nature of the inland 

waterway transport sector  

Desk research and stakeholder consultations highlighted the same factors that justify an 
intervention  at  the  EU  level  rather  than  at  a  regional  or  national  level.  Some  of  these 
factors directly relate to the nature of the IWT sector itself. Notably, the rationale for public 
intervention at EU level is that inland navigation does not stop at the borders of countries 
and the different RIS systems  reach their full potential only when they are harmonised. 
This view is fully supported by the all consulted stakeholders that provided an answer to 
this question.  

88 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

  The  RIS  Directive  has  considerable  EU  added  value  compared  to  the 

benefits that could have been achieved by other interventions  

There is strong agreement among interviewees that the same benefits could have not 
been achieved by comparable interventions at the international, regional or national 
level227.  

Specifically, the reason why the same benefits cannot be achieved at the international level 
is  because  the  guidelines  provided  by  international  bodies,  such  as  UNECE,  are  not 
mandatory.  Therefore,  they  would  not  necessarily  prevent  fragmentation  in  the  sector. 
Fragmentation, as explained above, is a major obstacle that prevents the achievement of 
the full benefits of RIS.  

Views  regarding  what  benefits  could  be  achieved  at  the  regional  level  are  slightly  more 
divided.  Six  respondents  indicated  that  River  Commissions  would  potentially  be  able  to 
provide the same benefits as the RIS Directive; however, four of them reiterated that a 
community  level  response  is  still  to  be  preferred228.  They  explained  that  the  River 
Commissions have a considerable degree of authority and could probably implement RIS 
by themselves, although this would lead to fragmentation at corridor level – different River 
Commissions  are  unlikely  to  work  together  in  the  way  that  is  incentivised  by  the  RIS 
Directive.  

No  sources  indicated  that  the  same  benefits  could  be  achieved  at  the  national  level:  all 
evidence  suggests  that  intervening  at  the  national level  would  be  counterproductive,  as 
this would result in a high fragmentation of standards and implementation practices. This 
in turn, given the highly-interconnected and international nature of the IWT sector, would 
result in issues in type-approval of equipment, increase in the number of resubmissions of 
e-ship reports in international voyages, information comparability and accessibility issues. 
This would consequently impose significant monetary losses and a decrease in efficiency 
both for users and competent authorities.   

3.5.2.  EU added value of the RIS Directive  

EQ 20: In light of the above rationale, what evidence is there on actual EU added value having been created, 
also in terms of order of magnitude of the added value? 

Context 

It is challenging to distinguish between  desired, perceived and observed added value of 
the RIS Directive. The desired EU added value is what is intended to be achieved through 
the  introduction  of  the  RIS  Directive,  as  enshrined  in  and  operationalised  through  the 
Directive’s  key  objectives,  most  notably  to  establish  harmonised  RIS  in  the  Community 
(see EQ 19). The perceived EU added value is that reported by different stakeholders based 
on  their  experience  of  using  RIS  and  regardless  of  whether  this  added  value  has  been 
measured or not. The observed added value is that which only includes measured positive 
impacts linked to the introduction of the RIS Directive.  

Nonetheless, all sources considered point out to the same set of benefits accruing from the 
introduction of the RIS Directive. On this basis, it is possible to assume that at least some 
of the benefits mentioned constitute an observed added value, rather than just a desired 
and/or perceived one. This question seeks to ascertain whether, as described above, there 
is indeed evidence of actual EU added value having been created, and to what extent.  

227 Those who disagreed are likely to have a significant bias.  

228 See section 6.5, Annex 2 “Findings from the interviews” to the Stakeholder Consultation Report  

89 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

Box 24. Summary of findings on EQ 20 – added value of the RIS Directive  

There is agreement among all stakeholder groups that the RIS Directive has strong EU 
added  value.  Most  notable  is  the  impulse  provided  towards  standardisation  and 
harmonisation of river information services across Europe, as a result of the common 
technical standards introduced by the RIS Directive.  

Importantly,  cross-border  projects,  which  likely  would  not  have  materialised  in  the 
absence of EU funding, are considered to have led to stronger cooperation between 
ports and across borders, as well as an increased momentum of the inland navigation 
sector resulting from the increased awareness and knowledge sharing.  

Other  elements  mentioned  as  the  Directive’s  added  value  are  its  contribution  to 
increased  safety  and  a  perceived  optimised  use  of  the  infrastructure,  although  as 
discussed in EQ 6, there is not enough evidence to support these claims.  

Findings 

  There  is  agreement  across  all  stakeholder  groups  that  the  RIS  Directive 

has a strong EU added value  

All sources consulted point to the same result: the RIS Directive has considerable EU added 
value, i.e. brought about benefits that could not have been achieved by interventions at 
national, regional or international level. The main EU added value resulting from the RIS 
Directive can be summarised as follows: improved harmonisation; standardisation through 
common  technical  standards;  increased  cross-border  cooperation;  and  more  funding  for 
the sector.  

Harmonisation and standardisation quite clearly emerge as the main benefits brought 
about by the RIS Directive. As explained by a RIS Authority in a Danube country: “The EU 
RIS  Directive  has  been  the  crucial  trigger  for  the  wide  implementation  of  Electronic 
Navigational  Charts,  Notices  to  Skippers,  Inland  AIS  and  Electronic  Ship  Reporting  at 
European level. These services are well received and appreciated by the inland navigation 
sector”. Especially in the Danube region, there are indications that many of the services 
would not have been implemented to the extent they have been if the RIS Directive and 
associated EU funding instruments had not given certain countries the necessary push to 
invest in inland navigation. Although more work can be done to level the playing field, all 
stakeholders agree that there has at least been some progress towards the achievement 
of a harmonised interoperable RIS, as described under EQ 4.  

For companies, cross-border collaboration between ports can be identified as an added 
value, especially in terms of the increased possibility for industrial symbiosis. Acting at the 
EU  level  rather  than  at  the  regional  or  local  level  is  also  seen  as  beneficial  in  terms  of 
higher availability of funding to support implementation and development activities. It 
emerged that the inland waterway transport sector had benefited from increased market 
and political awareness since the introduction of the RIS Directive. This, in turn, guaranteed 
a place for the sector in the EU political agenda among its key priorities. This resulted in 
higher  funding,  materialised  and  operationalised  through  several  projects  (e.g.  IRIS 
Europe229; RIS COMEX230; etc.) that allow for the continuous development of the sector.  

  The  RIS  Directive  is  perceived  to  have  brought  about  other  benefits, 
although  it  is  unclear  whether  they  constitute  an  added  value  of  the  EU 
intervention specifically  

Interviewees  and  questionnaire  respondents  also  perceive  that  the  IWT  sector  has 
benefitted  from  increased  competitiveness;  optimised  use  of  infrastructure;  improved 

229 

IRIS  Europe 

II, 

see  https://ec.europa.eu/inea/en/ten-t/ten-t-projects/projects-by-country/multi-

country/2008-eu-70000-s  

230 RIS COMEX Website, see https://www.riscomex.eu/  

90 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

safety  during  cross-border  voyages.  Their  perceptions,  however,  cannot  be  neither 
supported nor discarded by statistical evidence at present (see EQ 14).  

Increased safety, for instance, is considered a key added value of the RIS Directive. Most 
respondents, in fact, mentioned safety as a key benefit for the IWT sector resulting from 
the  introduction  of  the  RIS  Directive.  Nonetheless,  it  must  be  specified  that  most 
respondents mentioning safety as a key benefit of the Directive, had no tangible examples 
to support this statement. This suggests that the increase in safety is a perceived benefit 
rather than an actual one (see EQ 6 and EQ 14). It should be noted, however, that although 
this was most often mentioned as the added value of the RIS Directive, there is no proof 
that  the  same  perception  of  increased  safety  would  not  have  been  established  in  the 
absence  of  the  RIS  Directive,  i.e.  if  RIS  was  implemented  by  Member  States  or  River 
Commissions themselves. 

To conclude, the findings on the added value of the RIS Directive are satisfactory but not 
entirely  certain.  This  is  due  to  the  difficulty  of  differentiating  between  observed  added 
values and perceived ones. Nonetheless, a perceived added value such as increased safety 
is not to be disregarded entirely, as it confirms the positive perception that RIS users have 
of the Directive and its effects on the IWT sector. 

91 

 
 
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

4.  CONCLUSIONS AND RECOMMENDATIONS 

There  is  a  considerable  lack  of  reliable  and  comparable  data  that  prevents  an  accurate 
assessment of the effectiveness, efficiency, and added value of the RIS Directive. Identified 
data gaps include:  

  Costs associated with the implementation of the RIS Directive at Member State level 
are difficult to distinguish from costs associated with the implementation of RIS as 
such. National authorities appear not to differentiate between the two, which makes 
it difficult to reliably assess the cost effectiveness of the RIS Directive.  

  Costs associated with the implementation of RIS are also not granulated at the level 
of the implementation of different key technologies. Although investment costs (e.g. 
setting up a website for notices to skippers) are straightforward, the actual day-to-
day  management  of  all  technologies  is  interwoven,  so  costs  cannot  be  reliably 
distributed between them.  

  At  the  level  of  benefits,  data  is  not  measured  consistently  over  time  and  across 
countries. Accident data, for instance, is not collected in all relevant Member States, 
and where it is, the type of data collected is not the same. Even within countries, 
e.g. Belgium, the number of accidents varied considerably over time - not because 
the  rate  of  accidents  changed  considerably,  but  because  they  decided  to  change 
their methodology. This hinders a reliable assessment of the cost effectiveness of 
the RIS Directive as well.  

  The same is true for the data relevant for navigation and planning. Although Annex 
I of the RIS Directive stipulates the minimum data to be provided, it leaves room 
for  interpretation  as  to  how  this  data  should  be  measured.  Water  depth,  for 
instance,  is  not  measured  in  the  same  way  in  all  relevant  Member  States.  This 
hinders the degree to which the Directive can promote harmonisation.  

There  are  also  no  fixed  common  provisions  for  monitoring  performance  towards  the 
achievement  of  the  RIS  Directive’s  objectives.  Having  a  common  approach  to  the 
measurement  and  provision  of  data  would  allow  for  a  more  robust  monitoring  and 
assessment of the RIS Directive’s effectiveness. 

4.1.EFFECTIVENESS 

Extent to which the outcomes generated by the activities correspond 
with the objectives231 

In  terms  of  achieving  the  overall  objective  of  the  RIS  Directive,  which  is  to  ensure  a 
harmonised, interoperable and open navigational aid and information system on the inland 
waterway network of the Community232, significant progress has been made, though gaps 
remain in given Member States, most notably when comparing the Rhine and the Danube 
corridors. 

The RIS Directive has contributed to achieving harmonised, interoperable RIS mainly 
through  the  mobilisation  of  resources  (primarily  through  EU  funded  projects  such  as 
RIS COMEX) needed to implement the Directive’s provisions. Important progress has been 
achieved in the countries where RIS was not a priority prior to the implementation of the 
Directive  (i.e.  countries  mainly  in  the  Danube  corridor,  where  inland  navigation  was 
traditionally less developed). The Directive succeeded in ‘putting RIS on the map’ with the 
need to comply with the requirements of the Directive leading to greater uptake of the RIS 
Directive’s  outputs  in  these  countries.  It  is  possible  that  Rhine  corridor  countries  would 

231  All  evaluation  criteria  definitions  in  this  chapter  are  based  on  the  Better  Regulation  Guidelines: 
https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-
how/better-regulation-guidelines-and-toolbox_en , Chapter VI: Evaluation and Fitness Checks  

232 RIS Directive, Preamble. 

92 

                                                
 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

have continued their development of the inland navigation even without the RIS Directive, 
but this is less likely in the Danube region, where EU level intervention led to considerable 
progress.  

There is no statistically significant evidence that the RIS Directive had an impact on 
the performance or growth of the inland navigation sector. Furthermore, there is very 
limited  data  available  to  assess  whether  existing  infrastructure  has  been  used  more 
optimally as a result of the RIS Directive.  

The analysis of available accident data does not provide evidence of a reduction in the rate 
of accidents having taken place, but skippers believe that RIS technologies have reduced 
the number of accidents and improved safety on the waterways. However, accident data 
is not reliably collected and reported on, so it is possible the Directive did indeed have an 
impact.  

In terms of increased environmental protection, there is limited evidence to suggest 
that the use of RIS has led to a reduction in fuel consumption, although the attributability 
to the Directive is unclear. A reduction in fuel consumption indirectly decreases emissions, 
greenhouse gases and emissions from fuel transport and production (well-to-tank) which 
implies social benefits.  

In terms of specific key RIS technologies: 

  Making available “all relevant data concerning navigation and voyage planning” to 
RIS users has been challenging for RIS authorities. The key factors hampering the 
process of making data for navigation and planning available is the perceived lack 
of  clear  guidelines  on  the  measurement  of  and  reporting  on  data,  and  on  the 
timelines for data updates. As a result, there are differences in the data provided 
across countries, which reduces the benefits for users of the waterways. 

  Most  Member  States  have  made  electronic  navigational  charts  available  for  all 
relevant  waterways,  however,  their  reliability  and  completeness  varies:  not  all 
charts contain the same level of detail, and charts are not always regularly updated. 
There are indications that this is the result of a lack of prioritisation and/or resources 
within national authorities. 

  All  national  authorities  provide  notices  to  skippers,  however,  in  some  cases  the 
notices are not fully in line with the provisions of the RIS Directive, as they are not 
fully  encoded  and  downloadable  following  the  standardised  requirements.  This  is 
likely the result of a lack of adequate technical knowledge  within the authorities. 
Furthermore, some countries use too much free text rather than applying the XML 
coding,  which  in  turn  hinders  the  automatic  translation  and  interoperability  with 
ECDIS systems envisaged by the RIS Directive. 

  There has not been an evident reduction in re-submissions of electronic ship reports 
when crossing a border because the system for cross-border exchange of reports 
does  not  work  optimally.  The  cross-border  exchange  of  electronic  ship  reports  is 
hindered  by  national  requirements  in  the  Member  States:  different  authorities 
require  different  information,  so  even  when  reports  are  shared,  vessel  operators 
often need to report additional data while on an international voyage. 

  All  type-approvals  of  Inland  ECDIS  viewers  in  navigation  mode  and  Inland  AIS 
transponders are carried out by the Wasser und Schifffahrtsverwaltung des Bundes 
Fachstelle der WSV für Verkehrstechniken (FVT) in Germany. None of the relevant 
Member States reported experiencing difficulties with mutual recognition. As such, 
it can be safely concluded that type-approved RIS equipment is mutually recognised 
across Member States as foreseen in Article 7 of the RIS Directive. 

There should, however, be proportional expectations of what could have been achieved by 
the  RIS  Directive,  given  its  legal  nature  (it  is  a  Directive,  rather  than  a  Regulation). 
Directives are legal acts that set out a goal that all EU countries must achieve. However, 
it is up to the individual countries to devise their own laws on how to reach these goals. 

93 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

This  opens  the  Directives  to  a  certain  level  of  interpretation  and  may  lead  to  different 
degrees  of  uptake,  as  is  indeed  the  case  with  the  RIS  Directive.  On  the  other  hand, 
Regulations are binding legislative acts which must be applied in their entirety across the 
EU. 

Recommendation 

Given  the  discrepancies  in  the  means  employed  to  measure  and  report  certain  data 
between different Member States (for example: data for navigation and voyage planning, 
or accident rate on waterways), it is recommended that the Commission consider, in the 
case  of  a  possible  revision  of  the  Directive,  providing  further  clarifications  on  the  data 
standards and potential requirements for updates and maintenance of available data.  

A  common  approach  to  the  provision  of  data  would  facilitate  the  development  of  a 
harmonised, interoperable RIS, and thereby reduce any remaining barriers to cross-border 
voyages on inland waterways.  

4.2.EFFICIENCY 

Extent to which the resources (inputs) used to produce the outputs 
lowest  possible 
are  used  as  efficiently  as  possible  (with 
resources/costs) 

There is no evidence to suggest that what has been spent as a result of the RIS Directive 
(in terms of human resources and costs) has been disproportionate to the results achieved.  

There is no reliable data available on the resources which were required for the preparation 
of the implementation of the Directive and its Implementing Acts in the Member States. 
Yet, overall, the benefits appear to outweigh the costs associated with the implementation 
of the different key aspects of the RIS Directive: 

  RIS  authorities  incur  significant  one-time  implementation  costs  associated  with 
making data for navigation and voyage planning available to waterway users. They 
also  incur  annual,  ongoing  costs  associated  with  keeping  data  up-to-date  and 
accessible to users. On the  other hand, users  of the waterways do not incur any 
one-time or annual ongoing costs in relation to data for navigation and planning, 
because the data is made available to them free of charge. Paired with the benefits 
accrued  to  them  (i.e.  better  voyage  planning  resulting  from  more  accurate  and 
timely information), this implies that the benefits outweigh the costs for users. 

  Although  no  reliable  data  is  available,  there  are  indications  that  RIS  authorities 
incurred  initial  compliance  costs  when  making  electronic  navigational  charts  that 
comply  with  the  RIS  Directive  available.  Moreover,  yearly  costs  associated  with 
keeping  charts  up  to  date  vary  based  on  how  often  charts  are  updated,  who  is 
contracted to create the charts, etc. The costs for users, in terms of equipment and 
software costs, are marginal compared to the total cost of a vessel, and in many 
cases such investment costs have been subsidised. This implies that the costs borne 
by authorities are outweighed by the benefits of electronic navigational charts for 
the sector as a whole. 

  With regards to notices to skippers, RIS authorities incurred significant compliance 
costs  when  the  Directive  was  adopted,  as  they  needed  to  invest  in  the  software 
necessary to provide the notices in an encoded and downloadable format. However, 
yearly (ongoing) costs associated with making notices available have not changed 
significantly since the adoption of the Directive. Although there is scope to optimise 
notices to skippers, the benefits (which are primarily felt by RIS users) do outweigh 
the costs (borne by authorities).  

  The  fact  that  there  is  still  a  lack  of  data  exchange  between  authorities  and  that 
electronic ship reports still have to be re-submitted on international voyages hinders 
the efficiency of RIS. In places where electronic reporting works well, skippers save 

94 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

time and money; but where it does not, time is wasted reporting vessel information 
more than once. The introduction of ship reports in electronic format, however, is 
considered an improvement in this regard.  

The fact that technical standards take time to be adopted across the EU is considered a 
regulatory burden. This creates problems because technology is constantly evolving, and 
the technical requirements need to keep up with the pace of change to remain relevant. It 
should,  however,  be  noted  that  despite  their  long  timeframe  for  adoption,  technical 
standards contained in Implementing Acts react to the changing IWT environment much 
faster than any update of the RIS Directive would. 

Although  not  within  the  scope  of  this  study  due  to  its  recent  establishment,  the 
standardisation  expected  to  take  place  within  the  framework  of  the  CESNI/TI  working 
group  (established  in  June  2019)  might  expedite  the  rate  of  issuing  new  technical 
standards and thus has the potential to reduce the regulatory burden. 

Recommendation 

It is recommended that the Commission continue its efforts to further harmonise RIS in 
Europe. It could consider ways to solve the different interpretations of technical standards 
and  the  lack  of  comparable  data,  e.g.  the  way  in  which  water  depth  is  measured  and 
reported on throughout Europe.  

4.3.RELEVANCE 

Extent  of  appropriateness  to  respond  to  the  needs  of  users  (both: 
target  groups  and  internal  stakeholders)  by  the  objectives  of  the 
intervention 

The objectives set out in the RIS Directive were very much aligned with the needs of the 
sector at the time of the Directive’s publication, and the Directive remains relevant today. 
The RIS Directive clearly addressed the need for more information that would be shared in 
a harmonised way, thus contributing to ensuring safety throughout the IWT sector.  

However,  since  its  adoption,  new  needs  have  emerged  that  should  be  taken  into 
consideration to ensure that the RIS Directive remains relevant and addresses the sector’s 
needs: an ongoing increase in digitalisation introduced technological developments that 
need  to  be  addressed  (for  example,  automated  vessels),  especially  with  regard  to  data 
exchange  and  availability.  Additionally,  market  developments  such  as  the  need  for 
inclusion of inland waterway transport in logistics supply chains, or the move towards 
synchro-modality are the factors affecting the sector that deserve due consideration. The 
social  cost-benefit  analysis  also  highlighted  that  the  digital  infrastructure  offers  great 
development  opportunities,  which  could  be  the  next  step  in  the  further  development  of 
RIS.  

Without  clearer  guidelines  on  how  to  develop  and  manage  emerging  technologies  and 
shorter  adaptation  times  to  technological  disruptions,  the  RIS  Directive  risks  losing  in 
relevance in the future. Without these elements the Directive will not be properly equipped 
to respond to the new challenges posed by digitalisation in the sector.  

Recommendation 

Considering recent changes, in the case of a possible revision of the Directive its objectives 
could be revisited to cover emerging needs resulting from recent developments, as set out 
above.  It is recommended that the Commission further assesses the new and emerging 
needs to ensure the (future) Directive’s ongoing relevance.  

In  order  to  keep  the  (possible  revised)  Directive  relevant,  considering  the  even-newer 
needs and trends which are yet to emerge in the coming years, it is recommended that 

95 

 Study supporting the evaluation of Directive 2005/44/EC  
on Harmonised River Information Services (RIS) 

the  Directive,  if  revised,  be  kept  ‘technology  neutral’  so  as  to  avoid  becoming  outdated 
when new developments emerge.  

4.4.COHERENCE 

Extent  to  which  the  objectives  and  the  implementation  of  the 
activities  are  non-contradictory  (internal  coherence),  and  do  not 
contradict  other  activities  with  similar  objectives  (external 
coherence) 

The RIS Directive and its Implementing Acts are both internally and externally coherent. 
This means that there are no contradictions within the legal acts, as well as between the 
legal acts and the relevant international obligations of  the Member States, nor other EU 
legislation in the areas of inland waterway transport policy, EU transport legislation, and 
other EU legislation in areas outside transport policy. 

Recommendation 

It  is  recommended  that  any  possible  revision  of  the  Directive  take  into  consideration 
upcoming legislation in and beyond the transport area. This will ensure that the Directive 
continues  to  be  coherent  with  any  policy  developments  after  2018,  which  is  the  cut-off 
point for the present study.  

4.5.EU ADDED VALUE 

Extent of changes which can reasonably be argued to be due to the 
EU  intervention,  over  and  above  what  could  reasonably  have  been 
expected from national actions 

There  is  agreement  across  different  stakeholder  groups  that  an  EU-level  intervention 
for  RIS  is  appropriate  and  justified  given  its  benefits,  which  are  considered  to  be 
greater than those brought about by national or regional initiatives.  

While some indicated that  harmonisation and standardisation  could have potentially 
been  achieved  at  the  regional level,  all  agree  that  an  EU  level  intervention  is  still  to  be 
preferred. In fact, even though Member States or River Commissions might have been able 
to achieve similar results, there is a risk that there would have been more fragmentation 
within Europe because they would have operated only on specific corridors or in specific 
regions.  This  would  have  been  in  clear  contrast  with  the  cross-border,  international 
character of the IWT sector, upon which the rationale for an EU level intervention heavily 
relies.  

Notably, the introduction of the RIS Directive led to a significant increase in the perception 
of safety of cross-border voyages. Additionally, the RIS Directive and EU funding for RIS 
and EU-wide RIS projects raised awareness about RIS and gave those countries where the 
IWT  sector  was  lagging  behind  a  push  to  further  invest  in  it,  thus  improving  the 
development of the sector  as a whole and to the creation of a level playing field across 
Europe.  

96 

 
GETTING IN TOUCH WITH THE EU 

In person  

  All over the European Union there are hundreds of Europe Direct information 

centres. You can find the address of the centre nearest you at: 
https://europa.eu/european-union/contact_en  

 On the phone or by email  

  Europe Direct is a service that answers your questions about the European 

Union. You can contact this service:  

  – by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these 

calls),  

  – at the following standard number: +32 22999696, or  

  – by email via: https://europa.eu/european-union/contact_en  

FINDING INFORMATION ABOUT THE EU 

 Online 

  Information about the European Union in all the official languages of the EU is 

available on the Europa website at: https://europa.eu/european-
union/index_en  

EU publications  

  You can download or order free and priced EU publications from: 

https://publications.europa.eu/en/publications. Multiple copies of free 
publications may be obtained by contacting Europe Direct or your local 
information centre (see https://europa.eu/european-union/contact_en ).  

EU law and related documents  

  For access to legal information from the EU, including all EU law since 1952 in 
all the official language versions, go to EUR-Lex at: http://eur-lex.europa.eu  

Open data from the EU  

  The EU Open Data Portal ( http://data.europa.eu/euodp/en ) provides access to 
datasets from the EU. Data can be downloaded and reused for free, for both 
commercial and non-commercial purposes.  

 
 
  
 
 
 
M
I
-
0
3
-
2
0
-
0
8
2
-
E
N
-
N

ISBN : 978-92-76-16283-4 

doi: 10.2832/541263