Community of European Railway and Infrastructure Companies (CER)

CER takes note of the Digital Omnibus package and, in particular, of the proposed amendments to Articles 4 and 5 of the Data Act, which would allow data holders to refuse access to data qualifying as trade secrets where there is a high risk of unlawful acquisition, use, or disclosure, including risks linked to third countries or entities under their control.

CER the Community of European Railway and Infrastructure Companies welcomes the European Commissions initiative to develop a Right to Stay Strategy and strongly supports its central ambition: ensuring that everyone in the European Union can live, travel and work in the place they consider home. Freedom of movement is one of the Unions fundamental achievements and must also support the freedom to stay.

European railway sector, represented by CER welcomes the opportunity to comment on the European Sustainability Reporting Standards. Please find attached CERs consolidated response to the public consultation on the revised European Sustainability Reporting Standards, setting out our comments on the draft Delegated Act amending Delegated Regulation (EU) 2023/2772.

As CER has stated before, the ETD's existing mandatory energy tax exemptions for aviation and maritime shipping (Art. 14(1) (b) and (c)) have a negative impact on the environment and on the level playing field with rail. They should be removed. The optional tax exemption in Art.

Position Paper Brussels, 24 October 2025 Digital Fairness Act CER aisbl ‒ COMMUNITY OF EUROPEAN RAILWAY AND INFRASTRUCTURE COMPANIES Avenue des Arts 53 – 1000 Bruxelles | T: [phone removed] | F: [phone removed] | @CER_railways | E: [email removed] | www.cer.be Position Paper Digital Fairness Act CER welcomes the European Commission's initiative to develop a Digital Fairness Act (DFA) to address the identified gaps…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In 2008, the world reached the peak of conventional oil production (IEA – 2018 World Energy Outlook). It is now estimated that the peak of absolute oil production has already been reached or is on the verge to be reached this year. CO2 emission is therefore not the only challenge we will have to face in the coming decades.

CER believes that data and digitalisation provide new opportunities throughout logistics and mobility systems, and for EU citizens and businesses. Moreover, efforts to digitalise the transport sector will also contribute to achieving the EU Green Deal objectives.

CER welcomes the publication of the Proposal for a Regulation on speeding-up environmental assessments (2025/0391 (COD)). It is a timely piece of legislation as cutting red tape and administrative hurdles can save time and costs.

CER (repr. European RUs & IMs) welcomes the introduction of the CRA and is convinced that it will be a valuable instrument for increasing cyber security. The sector makes use of both sector specific products and services and general purpose solutions and services. The interplay between vertical and horizontal legislation should be further developed and sector specific legislation adapted accordingly. 1.

The Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to provide our views on the Proposal for a Regulation of the European Parliament and of the Council establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013.

The Community of European Railway and Infrastructure Companies (CER) would like to thank the Commission for this opportunity to provide our views on the Call for Evidence for an Impact Assessment for the Reform of the Union customs legislation.

The Electrification Action Plan represents a pivotal opportunity to reinforce the competitiveness, resilience, and sustainability of the European rail system. With over half of the EUs railway network already electrified, further progress must balance ambition with safety, security, and reliability.

The Community of European Railway and Infrastructure Companies (CER) welcomes the Commission's Draft guidance on the Cyber Resilience Act (CRA). Please find attached two comments on spare parts related to the very long life cycles in the railway sector. CER remains at your disposal to further discuss this topic.

The Community of European Railway and Infrastructure Companies (CER) welcomes the European Commission's initiative to develop guidance on the application of the 'do no significant harm' (DNSH) principle under the 2028-2034 Multiannual Financial Framework (MFF).

The Community of European Railway and Infrastructure Companies (CER aisbl) supports the overall intention of the proposed NIS-2 Directive. In our opinion it is fully justified that the EU and the entities in the critical sectors pay more attention to and harmonise the efforts for cyber security.

Please see attached full response of CER. CER welcomes the opportunity to provide feedback to the call for evidence for an evaluation of Connecting Europe Facility 2014-2020 (CEF I). For rail, CEF is the key financing instrument for bridging missing links and removing bottlenecks on the TEN-T Core Network Corridors, thus increasing the competitiveness and market share of the European rail system.

Railway companies are continuously keen to improve the travel experience of people with reduced mobility or passengers with disabilities. That is why CER Members are ready to recognize a potential EU wide European Disability Card, provided existing Public Service compensations apply for national citizens and agreed by the competent authorities no matter if they travel on domestic or international routes.

We have uploaded our position paper on the Regulation on passenger rights in the context of multimodal journeys and Review of the passenger rights Regulations. For a short overview, our main messages are: Responsibilities and duties of each entity need to be better defined and balanced. Proposal introduces many new obligations for carriers, while being unreasonably light on the responsibility of the intermediaries.

CER’s members considers the protection of their customers first and foremost as the sector’s own long-standing commitment. CER members understand that the passenger experience is the decisive factor when customers choose their transport mode.

CER is glad to see carbon accounting on the European decision making agenda thanks to the legislative proposal for the 'CountEmissionsEU' Regulation. For decades CER has been calling for the full implementation of the polluter pays and user pays principles in the transport sector. CountEmissionsEU should be an enabler to internalise greenhouse gas (GHG) emissions from transport.

Driving the transition to zero-emission mobility as required by the EU Green Deal will only be possible by placing the right incentives to transport users. Achieving the 90% greenhouse gas emission reduction in the transport sector by 2050 requires a basket of measures that include a robust carbon pricing, taxation, infrastructure charging and CO2 standards for vehicles complemented by financial incentives to…

CER welcomes the opportunity to provide feedback to the Inception Impact Assessment expressing the intended revision of the Regulation on Union Guidelines for the development of the trans-European transport network (TEN-T).

CER SUPPORTS the Commission’s objective and approach... CER welcomes the launch of the work on the revision of the Combined Transport Directive and the draft roadmap which the Commission published on 19 August 2021 outlining its intended actions until a legislative proposal comes out in Q4 2022.

As railways are the backbone of Military Mobility, the Community of European Railway and Infrastructure Companies (CER) strongly supports this initiative. Military Mobility is inherently dual-use and the three identified gaps regulatory, infrastructure and capabilities must be addressed in a dual-use perspective as to deliver maximum benefits for both civilian and military applications.

In view of the European Green Deal and the European Commission’s goal to reach climate-neutrality by 2050, efficient and optimized capacity management is key to ensure the modal shift to rail. Rail is the backbone of sustainable movement of goods, businesses and people, and fundamental for sustainable and connected economy in the EU.

CER welcomes the opportunity to respond to this roadmap consultation for the Revision of the Directive on intelligent transport systems (ITS). Please find attached CER response to the consultation, which we ask the Commission to kindly consider. CER members represent 92% of rail passenger operations in EU, EFTA and EU accession countries.

97% of the CO emissions from an overnight hotel stay are linked to how guests arrive and depart. This shows that mobility is the key driver of sustainable tourism. Among long-distance transport options, rail stands out as the greenest choice.

Please see attached document for full CER response. CER welcomes the opportunity to provide feedback to the call for evidence for an evaluation of Connecting Europe Facility 2014-2020 (CEF I). For rail, CEF is the key financing instrument for bridging missing links and removing bottlenecks on the TEN-T Core Network Corridors, thus increasing the competitiveness and market share of the European rail system.

Community of European Railway and Infrastructure Companies (CER) would like to thank the European Commission for the opportunity to respond to this public consultation on Proposal for Regulation on foreign subsidies distorting the internal market. Please find CER reply to the public consultation attached.

CER signed joint positions with EIM, UIP, ERFA and UIC, CIT on the revision of Telematics TSI / OSDM. The positions are attached. On the revision: ERA published the TAF/TAP recommendations in January 2022 after 4 years of work by the ERA TAF and TAP working parties according to the TSI revision mandate (decision 2017/1474) and traceability of the modifications in the ERA CCM Revision tool.

Railways provide clean mobility, with a very low carbon footprint compared to aviation. They are ready to help making European transport greener with a modal shift to rail. To support this shift, travel prices must reflect travel-related externalities, such as climate impacts, so that trains are enabled to compete with planes for customers also on prices. The EU ETS can support the shift to low-carbon mobility.

The Community of European Railway and Infrastructure Companies (CER) welcomes the upcoming revision of the Train Drivers Directive (2007/59/EC), scheduled for Q4 2022, as per the Action Plan of the Sustainable and Smart Mobility Strategy.

CER welcomes the opportunity to share the view of its members and to provide input to the European Commission before the presentation of the revised regulation. As a member of the Group of Representative Bodies (GRB), CER also signed the Joint Sector Position on the Revision.

CER, the Community of European Railway and Infrastructure Companies, thanks the European Commission for the opportunity to provide evidence for the impact assessment of the new Transport Block Exemption Regulation (TBER).

The Community of European Railway and Infrastructure Companies (CER) appreciates and fully supports this EC initiative of a "fitness check" for the European Union Agency for Railways (ERA). ERA is a pivotal player and an important interlocutor for the European railway actors. A well functioning and efficient Agency is one of the prerequisites for a vital, high-preforming and competitive European railway sector.