UNIFE

UNIFE - the European Rail Supply Industry Association welcomes the opportunity to answer the public consultation: Simplification - digital package and omnibus. Please find attached the UNIFE reaction statement to the proposal published on 19 November 2025.

While fully committed to EU policy objectives in the digitalisation field, in particular when it comes to the critical topic of cybersecurity, UNIFE - the Association of the European Rail Supply Industry - underlines that certain regulations focus on consumer goods sectors and not on the characteristics of tailor-made industrial goods sectors such as rail (e.g.

UNIFE, the European Rail Supply Industry Association, welcomes the European Commissions call for evidence for an impact assessment on the Circular Economy Act. This upcoming regulation proposal will be vital for the rail supply industry, as circular-economy business models are central to it. Rolling stock can remain in service for over 40 years, transporting millions of passengers and tonnes of freight.

UNIFE the Association of the European Rail Supply Industry welcomes the European Commissions proposal for an Industrial Accelerator Act (IAA) and supports its overarching objective of reinforcing Europes industrial resilience, strengthening strategic value chains, and ensuring that the Union can meet its longterm autonomy and sustainability goals.

In the first half of 2025, the Commission initiated the public consultation regarding the next MFF. Consequently, UNIFE replied to this consultation by filling in the respective questionnaires. Now, after the Commission published its proposal for the next MFF on 16 July, the Commission has opened a new consultation period following the adoption of the proposal.

In the first half of 2025, the Commission initiated the public consultation regarding the next MFF. Consequently, UNIFE replied to this consultation by filling in the respective questionnaires. Now, after the Commission published its proposal for the next MFF on 16 July, the Commission has opened a new consultation period following the adoption of the proposal.

UNIFE, the association representing the European rail supply industry, would like to thank the European Commission for the opportunity to comment on the Roadmap for the Climate Law - the first concrete step following the publication of the European Green Deal Communication. We fully acknowledge that climate change requires urgent action.

• UNIFE - the association of the European rail supply industry - welcomes the opportunity to provide a feedback on the proposal for a regulation establishing a framework for setting eco-design requirements for sustainable products and repealing Directive 2009/125/EC.

Carbon Border Adjustment Mechanism MEETING (CBAM) MINUTES Ref. Ares(2021)6900778 - 10/11/2021 UNIFE position paper November 2021 Executive Summary As one of the most energy-efficient transport modes, rail has a key role to play in the overall climateneutrality goal by 2050, which has been enshrined into legislation through the Climate Law.

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

In early 2025 the US National Vulnerability Database (NVD) the global hub for information on vulnerabilities and vulnerability management incurred the very real risk of being shut down due to lack of funding, only to receive a last-minute extension of less than a year.

UNIFE, the association of European trains-metros-trams builders and rail equipment manufacturers, would like to bring to the attention of the European Commission our comments and reccomendations on the recast ETD proposal. You will find our Position Paper attached. For all information and questions, please contact Mr. [name removed]: [email removed]

UNIFE - the association of the European rail supply industry - supports the European Commission’s objective to increase access to and further use of data, in both the B2B and the B2G contexts. We firmly believe in the added value of data sharing and the development of an inclusive data ecosystem to maximize the benefits of data for the mobility ecosystem.

UNIFE, the European Rail Supply Industry Association, represents European train builders and rail equipment suppliers. The association advocates for 129 of Europes leading rail supply companies from SMEs to major industrial champions that are active in designing, manufacturing, maintaining, and refurbishing rail transport systems (trains, metros, trams, freight wagons), subsystems, and related equipment.

UNIFE is the Association of the European Rail Supply Industry a strategic industry accounting for more than 400.000 jobs across Europe, from industrial champions (Alstom, Siemens, CAF) to small and medium-sized enterprises involved in the design, manufacture, maintenance and refurbishment of rail transport systems, subsystems and related equipment.

Operating in Brussels since 1992, UNIFE represents European train builders and rail suppliers.The association advocates for 119 of Europes leading rail supply companies from SMEs to major industrial champions active in designing, manufacturing, maintaining and refurbishing rail transport systems (trains, metros, trams, freight wagons), subsystems and related equipment.

UNIFE - the European Rail Supply Industry Association - acknowledges the European Commissions proposal on horizontal cybersecurity requirements for products with digital elements, the Cyber Resilience Act (CRA).

UNIFE, the association of European trains-metros-trams builders and rail equipment manufacturers, would like to bring to the attention of the European Commission our comments and reccomendations on the Regulation (AFIR) proposal. You will find our Position Paper attached. For all information and questions, please contact Mr. [name removed]: [email removed]

UNIFE, representing the European Rail Supply industry, welcomes the presence of a much needed official guidance document on the CRA, which complements and corroborate the guidance developed within the rail sector. The comments provided in the table propose some further clarifications and examples to make the guidance more easily applicable.

UNIFE welcomes the opportunity to reply to this public consultation and to contribute constructively to the effective and proportionate implementation of the Cyber Resilience Act (CRA) and the Data Act. As the European rail supply industry association, UNIFE and its members fully support the objectives of strengthening cybersecurity across products with digital elements and improving access to and use of industrial…

UNIFE – the association of the European rail manufacturing industry – acknowledges that a revision of the ‘’Network and Information Security’’ Directive (‘’NIS’’) is nowadays necessary to make it fitter vis-à-vis current cyber-risks. Unprecedented pace in digitalisation, including a huge rise in the use of IoT devices, has substantially increased cyber security risks.

UNIFE – the association of the European rail supply industry – welcomes the Commission’s initiative to review the Network and Information Security (NIS) Directive, in the framework of the ‘’Shaping Europe’s digital future’’ masterplan. The NIS Directive in 2016 marked one of the most important steps towards a more coherent and harmonised cybersecurity management in Europe.

UNIFE acknowledges that CEF grants have provided crucial support to the achievement of the Trans-European Transport Network (TEN-T) policy objectives and the development of sustainable transport system. In this context, the CEF programme should continue to be the cornerstone of the EU Investment Policy in the transport sector also in the post-2027 period.

• UNIFE - the association of the European rail supply industry - welcomes the European Commission (EC) decision to proactively work on a proposal aiming to set up a framework for calculating greenhouses gases (GHG) emissions of transport operations in the freight and passenger transport sectors.

UNIFE, the Association of the European Rail Supply Industry, welcomes the Commission’s proposal for a revised Regulation on Union guidelines for the development of the Trans-European Transport Network (TEN-T), published on 14 of December 2021.

The TEN-T policy is of fundamental importance as it supports and symbolises connectivity and accessibility for all regions of the Union. It also plays a key role in achieving the Green Deal objectives. The EU’s climate neutrality goals can only be fulfilled with the decarbonisation of the transport sector, which accounts for nearly ¼ of overall emissions in the EU.

UNIFE, the association representing the European rail supply industry, would like to welcome the update of the Combined Transport Directive included in the Greening Freight package. The amendment of Directive 92/106/EEC is a step towards reaching the goals of the Sustainable and Smart Mobility Strategy and the European Green Deal objectives with regards to rail freight transport, set by the European Commission.

UNIFE, the European Association of the Rail Supply Industry, shares its views and concerns on some concrete aspects of the new proposed Regulation, namely on the Credit Conversion Factor (CCF) for Technical Guarantees and Effective Maturity recognition for Trade Finance.

UNIFE, the European Rail Supply Industry Association, welcomes the initiative of the European Commission on enhancing Military Mobility across Europe. The European Rail Supply Industry stands ready to supply the needed products, boost harmonisation and actively contribute to Military Mobility preparedness.

As representative of the rail supply industry, UNIFE is very active in making the implementation of the CRA in the railway sector streamlined and efficient. Collaborating to the production of implementing acts and guidelines for the CRA is a key part of this process. The CRA encompasses a very broad ensemble of products in very different sectors, all with their own specificities.

UNIFE feedback to Cross-border rail traffic – better management and coordination initiative UNIFE - the association of the European rail supply industry - welcomes the European Commission (EC) decision to proactively work on a proposal aiming at a better management and coordination of cross-border rail traffic.

UNIFE - the association of the European rail supply industry - welcomes the Commission's proposal aiming to review the Directive on Intelligent Transport Systems from 2010 and recalled that UNIFE members have actively contributed to various Commission preparatory activities (workshop, consultation, Survey) in the past months.

UNIFE acknowledges that CEF grants have provided crucial support to the achievement of the Trans-European Transport Network (TEN-T) policy objectives and the development of sustainable transport system. In this context, the CEF programme should continue to be the cornerstone of the EU Investment Policy in the transport sector also in the post-2027 period.

As previously explained in previous contributions, there is an increasing influx of bidders from third country economic operators. In the rail supply sector, significant price differences (ranging from 20 to 30%) have been observed in projects awarded to certain rail State-owned Enterprises, in the EU and in other continents/countries.

UNIFE appreciates the possibility to comment on the Inception Impact Assessment (IIA) of a Commission proposal(s) for Regulation(s) to address distortions caused by foreign subsidies in the internal market generally and in the specific cases of acquisitions and public procurement.

Green bonds play an increasingly important role in financing assets needed for the low-carbon transition. Delivering on the European Green Deal requires significant massive investment across all sectors and industries, including transport, to accelerate the transition towards a climate-neutral economy and reach the EU’s environmental sustainability objectives – enshrined in EU law and aligned with the Paris…

UNIFE - The European Rail Industry Association - welcomes the opportunity to provide input to the proposed revision of the ERA Regulation (EU) 2016/796. Attached you will find a common input paper by ALE, CER, EIM, ERFA, FEDECRAIL, NB-RAIL, UIP, UIRR, UITP and UNIFE, proposing amendments to the ERA regulation to clarify the mandate of ERA and importantly areas where sufficient resources and expertise are required.

UNIFE - The European Rail Supply Industry - welcomes the European Commission's proposal regarding the Anti-Coercion Instrument (ACI). We believe that in the current world in which the European rail supply companies operate, often influenced by protectionist tendencies or even unexpected actions from third countries interfering with the daily businesses of European companies, it is essential that the European Union…

UNIFE welcomes the European Commissions Proposal on the Screening of Foreign Investments in the Union published on 24 January 2024. Ahead of the legislative debate between the European institutions and in the context of the current feedback consultation process, UNIFE would like to share its first reactions to the Proposal, highlighting positive developments compared to the current FDI Regulation, as well as to…

MEETING MINUTES EU’s Foreign Direct Investment Screening Regulation (EU/2019/452): UNIFE feedback on its evaluation and review 7 July 2023 www.unife.org 0 Introduction The European Rail Supply Industry Association (UNIFE) welcomes the opportunity to express its view on the EU’s Foreign Direct Investment Screening Regulation (EU/2019/452).

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

UNIFE – the Association of the European rail supply industry – strongly welcomes the proposal by the European Commission to establish 2021 as “the European year of rail”. We acknowledge very positively that such “European Year of Rail” would aim to promote rail transport and its supply industry in line with the objectives set out in the Communication on the European Green Deal, in particular with regard to…

UNIFE, the association representing Europe’s rail supply industry, welcomes and supports the roadmap of the evaluation of the EU Agency for Railways. UNIFE appreciates the purpose and scope of the evaluation and the methodology described.