In its position paper ¹, UIRR welcomes the European Commission’s TSI Telematics proposal, which mandates high-quality and interoperable data sharing in line with the Data Act - Regulation (EU) 2023/2854.

• Quality and accessibility of data are key for the sector to improve transparency and efficiency, and to attract more logistics service providers and shippers to intermodal rail freight. Barriers to data exchange between intermodal and terminal operators should be removed, as provided for in the Rotterdam clause of 2016².
• The missing cross-border freight train identification numbering, various regulatory, legal and contractual barriers — or even data gaps — are only a few examples of the important obstacles rail freight buyers are facing. These digitalisation shortcomings puts rail freight at a disadvantage compared to other transport modes with more advanced data sharing practices.
• Beyond technical barriers, UIRR also expresses concerns about the high investment costs for intermodal stakeholders to access data exchange infrastructure, a concern particularly relevant for SMEs, which operate 85% of intermodal terminals, and cannot afford expensive proprietary interfaces such as the current TAF TSI.
• Data sharing involves the exchange of master and dynamic transactional data between business and/or public stakeholders, and requires 3 elements: willingness to share data, capabilities to share and to monitor the data sharing and continuous improvement. The integrated approach of the TSI Telematics proposal will enable efficient data sharing, and consequently enhance intermodal rail freight’s competitiveness.

In order to satisfy the needs of intermodal rail freight buyers vis-à-vis rail freight service providers, the following should be addressed:

1. Centralising reference databases on the basis of standardised and harmonised master data, as proposed in the TSI Telematics initiative, is a valuable step to improve data consistency, efficiency, and quality. Transitional solutions will still be needed until a unique EU-wide train identification number for cross-border freight trains becomes available, although this may mean accepting some data quality limitations in the meantime.
2. Efforts are needed to standardise transactional data while adapting regulations to reduce data exchange costs among Railway Undertakings, Infrastructure Managers, Terminal Operators, CTOs, Logistics Service Providers, and their customers. Standardising data elements across stakeholders will enhance information av