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Document 52024SC0015

COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2005/44/EC on harmonised river information services (RIS) on inland waterways in the Community

SWD/2024/15 final

Brussels, 26.1.2024

SWD(2024) 15 final



Accompanying the document

Proposal for a Directive of the European Parliament and of the Council

amending Directive 2005/44/EC on harmonised river information services (RIS) on inland waterways in the Community

{COM(2024) 33 final} - {SEC(2024) 38 final} - {SWD(2024) 16 final}

Table of contents



1.2What are River Information Services (RIS)

1.3Political and legal context

1.4Evaluation of the RIS Directive

1.5Sustainable Development Goals

2Problem definition

2.1What is the problem?

2.2What are the problem drivers?

2.3How likely is the problem to persist?

3Why should the EU act?

3.1Legal basis

3.2Subsidiarity: Necessity of EU action

3.3Subsidiarity: Added value of EU action

4Objectives: What is to be achieved?

4.1General objectives

4.2Specific objectives

5What are the available policy options?

5.1What is the baseline from which options are assessed?

5.2Policy measures and policy options

6What are the impacts of the policy options?

6.1Economic impacts

6.2Social impacts

6.3Environmental impacts

7How do the options compare?




7.4Subsidiarity and proportionality

7.5Summary of the comparison of policy options

7.6Sensitivity analysis

8Preferred option

8.1Identification of the preferred policy option and stakeholders views

8.2REFIT (simplification and improved efficiency)

8.3Application of the ‘one in, one out’ approach

9How will actual impacts be monitored and evaluated?

Annex 1: Procedural information

Annex 2: Stakeholder consultation (Synopsis report)

Annex 3: Who is affected and how?

Annex 4: Analytical methods

Annex 5: Competitiveness Check

Annex 6: SME Test

Annex 7: Conclusions of the evaluation

Annex 8: Effectiveness of the different policy options

Annex 9: Overview of RIS


Term or acronym




Automatic Identification System

AIS is an automatic communication and identification system that displays (on electronic charts) the position and orientation of other vessels in the vicinity 


Central Commission for Navigation on the Rhine

The CCNR is an international organization that is responsible for promoting the development and safety of inland navigation on the Rhine and its tributaries. 


Connecting Europe Facility

The CEF is a European Union funding instrument that supports the development of trans-European infrastructure networks in the fields of transport, energy, and telecommunications. 


European Committee for Drawing Up Standards in the Field of Inland Navigation

The CESNI is an intergovernmental organization that develops technical and safety standards for inland navigation in Europe. 

CEMT Class

Classification of European Inland Waterways

An inland waterway classification according to CEMT (European Conference of Ministers of Transport) concerning allowed vessels dimensions on a fairway. 


European Code for Inland Waterways

CEVNI contains the core rules applicable to the traffic on inland waterways in the UNECE region such as marks and draught scales on vessels, visual signals on vessels, sound signals and radiotelephony, waterway signs and markings, rules of the road, berthing rules, signalling and reporting requirements as well as prevention of pollution of water and disposal of waste 


Digital Inland Navigation Area

DINA is a concept to interconnect information between IWT’s stakeholders and with other transport modes. 


Electronic Chart Display and Information System

ECDIS is a computer-based navigation system used on ships to display navigational information and provide real-time information about the ship's position, course, and speed. 


Electronic Freight Transport Information

eFTI is a digital system that enables the exchange of information related to freight transport between different actors in the supply chain. 


European Hull Database

The EHDB is a database kept by the European Commission in which the data of the vessels operating on European inland waterways is collected. The EHDB is used to support the proper functioning of river information services (RIS) in accordance with Directive 2005/44/EC. 


European Maritime Single Window environment

The main aim of the EMSWe Regulation is to lay down harmonised rules for the provision of the information that is required for port calls, in particular by ensuring that the same data sets can be reported to each Maritime National Single Window in the same way. This Regulation also aims to facilitate the transmission of information between declarants, relevant authorities and the providers of port services in the port of call, and other Member States. 


Electronic Navigation Charts

ENC are developed in accordance with the Inland ECDIS Standard for Electronic Chart Display in inland navigation. 


European Reference Data Management System

The ERDMS is a database containing information and data necessary to efficient and harmonise implementation of RIS. 


Electronic Reporting International

The ERI endeavour to harmonise and facilitate standardised electronic inland ship reporting in the EU. 


Estimated Time of Arrival

The ETA, is a frequently used term globally to denote the time of coming. In the shipping & logistics industry, it is used to forecast when the shipment will arrive at its final port of destination. 


General Data Protection Regulation

The GDPR is a regulation implemented by the EU to protect the privacy and personal data of EU citizens. 


Inland Waterway Transport

IWT refers to the transportation of goods and passengers using rivers, canals, and other inland waterways. 


Notices to Skippers

The NtS serve to communicate information such as the status of the inland waterway infrastructure (i.e. bridges and locks), failures of aids to navigation, temporary blockages of waterway sections or other types of infrastructure, works, water level and water depth information, ice information and weather messages. 


River Information Services

RIS are a set of digital services and tools designed to enhance the safety, efficiency, and sustainability of inland waterway transport. 


RIS enabled Corridor Management Execution

A IWT platform aiming at the definition, specification, implementation and sustainable operation of Corridor River Information Services. 


Sustainable Development Goal

The SDGs are a set of 17 goals established by the United Nations in 2015 as a blueprint for achieving a better and more sustainable future. 


Small and Medium-sized Enterprises

SMEs refers to businesses with a limited number of employees and relatively low revenue compared to larger enterprises. 


Sustainable and Smart Mobility Strategy

Comprehensive EU transport strategy adopted in 2020 which lays the foundation for how the EU transport system can achieve its green and digital transformation and become more resilient to future crises.


Trans-European Network - Transport

Key instrument for the development of coherent, efficient, multimodal, and high-quality transport infrastructure across the EU. It comprises railways, inland waterways, short sea shipping routes and roads linking urban nodes, maritime and inland ports, airports and terminals. 



Unit of measure of freight transport which represents the transport of one tonne of goods (including packaging and tare weights of intermodal transport units) by a given transport mode (road, rail, air, sea, inland waterways, pipeline etc.) over a distance of one kilometre. 


United Nations Economic Commission for Europe

The UNECE is a regional commission of the UN. 


Vessel Tracking and Tracing

It is one component of the “River Information Services” (RIS), contributing to more safety and better efficiency of inland navigation.



This Impact Assessment accompanies a legislative proposal for a revision of Directive 2005/44/EC on harmonised river information services 1 (hereinafter “the RIS Directive” or “the Directive”).

The EU’s inland waterways stretch over 42,286 kilometres (km) and are a key means of connecting seaports, cities and industrial centres 2 . The interconnected waterway network of 13,000 km covers 13 Member States 3  serving over 250 TEN-T inland ports in the TEN-T network. A map of the main waterways in the EU is provided below.

Figure 1: Main waterways in the EU

Source: European Commission

Inland Waterway Transport (IWT) plays an important role in the overall European transport system despite its relatively small size. In 2020, 131.7 billion tonne-kilometres (tkm) were transported through inland waters, making up 4.1% of the total freight transport volumes (with road accounting for 54.9%, sea 29.1% and rail 11.9%) 4 . Dry cargo (in particular agricultural products, ore and metals, building materials, coal, etc.) accounted for 59.8% of IWT volume in 2020, liquid cargo (chemicals and petroleum products) for 28.1% and containers for 12.1% 5 .

IWT handles 0.9% of the total imports and exports in terms of weight in the EU. Despite its geographically limited and focused network, it offers an important alternative to transport via road or rail for the European hinterland regions closest to inland waterways. Therefore, IWT is mainly in competition and often classified along with land transport modes 6 , covering 6% of inland freight traffic and 0.01% of passenger inland traffic.

The development of inland waterway activity is highly dependent on geography (location of rivers), on the types of goods that are or can be transported, on the location of production and consumption sites in relation to the inland waterway network and on the availability of transhipment infrastructure. In this context, the sector faces limitations in terms of its structural market accessibility and growth potential related to two factors 7 :

·Geography. Contrary to road and rail, building new waterways is generally not an option. Therefore, the development of Inland Waterway Transport depends essentially on the respective locations of production and consumption sites in relation to the existing inland waterway network. Indeed, depending on each territorial context and the geographical distribution of each site the total cost of Inland Waterway Transport, including handling and last miles, may turn out to be very high.

·Logistics. Inland Waterway Transport is not always an option as IWT vessels cannot carry all kind of goods due to packaging issues (for instance pallets) or size of shipments.

Besides constraints due to geography and logistics, IWT faces some challenges to achieve its growth potential 8 . The growth of IWT can be ensured by meeting the objective of NAIADES III Communication 9 , which suggests investing in the infrastructure and research, further digitalisation of the sector and improvements in the attractiveness for the crew. Some new and growing markets might trigger modal shift towards IWT, for example, waste/biomass transport, circular economy/new materials, urban logistics and passenger transport.

Connected to the geographical distribution of inland waterways, IWT traffic volumes concentrate in a few Member States, with Germany and the Netherlands accounting for 69% of overall EU IWT transport in 2020 10 . In terms of modal shares, IWT plays a significant role in the land freight transport activity 11  within the Netherlands (39.7%), Bulgaria and Romania (28% each) and a lower role in Belgium (10.9%), Luxemburg (8.2%), Germany (7.3%), Croatia (6.0%) and Hungary (4.7%). Furthermore, (freight) IWT tends to be rather limited in the land freight transport activity in Slovakia (2.9%), Austria and France (2.1% each) 12 . 

According to Eurostat, around 5,500 IWT freight transport companies are active in Europe (EU plus Bosnia-Herzegovina, Serbia and Switzerland), employing more than 23,000 persons. In addition, there are around 4,000 passenger companies which employ around 14,000 persons. Thus, it is a small sector when considering the overall number of transport companies. The sector is also small in terms of turnover, reporting a turnover of EUR 7 billion in 2020 (1% of the turnover of the transport sector) 13 .

While no detailed data is available at EU level, one characteristic of the IWT sector is the high number of Small and Medium Enterprises (SMEs). According to the CCNR, the majority of IWT companies in Western Europe are small family owned operating one or two vessels, while companies in the Danube region are bigger as they derive from previously state-owned enterprises 14 .

1.2What are River Information Services (RIS) 

Currently, RIS concern the provision of a range of services to support traffic and transport management in inland navigation 15 . The development of these services is based on four technologies 16 , whose technical specifications govern how the relevant information is shared and presented among the RIS users.

Member States have set up RIS authorities, who are responsible for the implementation and maintenance of RIS. National RIS authorities inform vessel operators (skippers) about the situation on the rivers (current parameters of waterways like fairway depth, clearance under the bridges, closure of waterways due to accidents/works, lock closures, etc.). This helps operators in safe and efficient navigation. In managing traffic, authorities may request vessels to adapt their navigation (e.g. speed) to avoid bottlenecks. On the other hand, vessel operators report important elements to the national RIS authorities, such as their position, carriage of dangerous goods, etc.

Vessel operators need to (re)submit reports at various instances during their voyage, and when crossing a border. The exchange of information can take place by electronic means or radio and may vary depending on the situation and the country of navigation. Basic information on RIS (such as geographical positioning of bridges) is included in databases (e.g. RIS Index in ERDMS) which are updated by the Member States. Vessel operators communicate with inland ports (e.g. to announce their expected time of arrival) individually, often via radio, and there is almost no direct exchange of information with other modes of transport.

Technical specifications for the provision of RIS are adopted by the Commission, with the assistance of RIS experts from the Member States. The Commission is also responsible for monitoring the overall implementation of RIS by Member States. Further technical information on RIS is included in Annex 9. The current setting of RIS in the EU is also illustrated in Figure 2 below.

Figure 2: Current setting of RIS in the EU

Source: European Commission

1.3Political and legal context

International, national and regional context

A range of institutional actors play a role in the development and implementation of RIS activities in Europe. These include, at international level: the United Nations Economic Commission for Europe (UNECE), and the World Association for Waterborne Transport Infrastructure (PIANC 17 ), which have developed non-binding standards and guidelines for RIS. At EU level the European Committee for drawing up Common Standards in the field of Inland Navigation (CESNI) was created by the European Commission and the Central Commission for Navigation on the Rhine (CCNR) to develop technical specifications and requirements for vessels, personal qualifications and digitalisation for IWT. Finally at regional area level, river commissions such as (CCNR), the Danube Commission, the Sava Commission and the Moselle Commission should play a role by facilitating the harmonisation of rules in IWT in the respective rivers. Of these the CCNR is developing and applying mandatory requirements and regulations for their Member States in line with the EU legislation. 

In addition, the Member States are involved in different platform and expert groups. These include the four temporary working groups of CESNI/TI (working group on information technologies) tasked with the development and updating of the technical specifications for the different RIS technologies 18 .

EU policy context

The Commission’s Communication on a Sustainable and Smart Mobility Strategy (SSMS) 19 sets out the EU vision for the transport system of the future. The SSMS recognises that significant steps have been taken to support the deployment of harmonised RIS to enable seamless transport and traffic management on the European inland waterways. The evolution of RIS needs however to take into consideration new requirements stemming from the digital transformation happening in the transport sector (e.g. smart shipping applications that increase performance of IWT operations, port information systems, autonomous ships for inland waterways, etc.). The revision of the RIS Directive has been announced under Flagship 6 of SSMS (Making connected and automated multimodal mobility a reality). 

In 2018, the Council, in its conclusions on Inland Waterway Transport 20 , invited the Commission to develop an implementation strategy for digitalisation, including River Information Services (RIS). Following the Council conclusions and the SSMS, the 2021 NAIADES III Communication 21  set out an action plan to boost the role of inland waterway transport in the EU mobility and logistics systems. The core objectives were to shift more cargo to Europe's rivers and canals, and to facilitate the transition to zero-emission barges by 2050. The importance for IWT to keep up with digital developments to improve the sector’s competitiveness and ensure that it becomes an active part of broader multimodal chains was recognised. Besides the revision of the Directive, the Communication calls on Member States to implement smart traffic and management solutions based on RIS. It also considers that a permanent operational structure to provide a single point of access for RIS-based corridor information services developed by the Member States could be supported financially by the Connecting Europe Facility (CEF). The Communication confirms that the Commission will continue supporting CESNI through the Connecting Europe Facility, with the mandate of developing harmonised EU technical specifications for inland waterway transport.

The 2021 European Parliament report Towards future-proof inland waterway transport in Europe 22 stressed the need to further harmonise river information services. This should simplify procedures in regulating inland navigation, reduce problems arising from different interpretations of technical standards and the lack of comparable data, and allow for the speedy development and deployment of innovative solutions. In its 2022 conclusions on NAIADES III 23 , the Council encouraged the Member States to continue and intensify their cooperation in the harmonised implementation of RIS. It invited the Commission to present a proposal for reviewing the RIS Directive, to establish the Directive as an effective tool supporting multimodal freight operations, with a particular focus on seamless cross-border connections and interoperability.

RIS is not the only digital element for IWT. In accordance with the Directive on technical requirements for inland waterway vessels 24 , the Commission maintains the European Hull Database (EHDB), containing selected information regarding inland waterway craft, including each vessel’s unique European vessel identification number, its name, its dimensions and other data identifying the vessel. The Directive on the recognition of professional qualifications in inland navigation 25  also facilitates the electronic exchange of information about crew members by setting up a system of national registers and a database, kept by the Commission (European Crew Database - ECDB).

RIS has benefited from EU funding support, in particular EUR 29.6 million TEN-T funding for 19 actions during the period 2007-2013 (for projects of total cost of almost EUR 85 million) and some EUR 33 million CEF1 funding for 11 actions (of total cost of EUR 58 million) for the period 2014-2020 26 . Under CEF2 (2021-2027), so far, the EU has supported 1 RIS project with EUR 18.2 million (out of a total cost of EUR 36.4 million).

The RIS Directive

The legislative process to regulate RIS at EU level started in 2005 with the adoption of the RIS Directive. The Directive establishes a framework for the deployment and use of harmonised, interoperable and open RIS aiming to enhance safety, efficiency and environmental friendliness of inland waterway transport in the EU. It intended to facilitate interfaces with other transport modes, thus considering the multimodal potential of IWT. At the same time, however, the definition (Article 3) makes it clear that RIS is aimed at the exchange of information between authorities and between authorities and IWT companies, and not between one or more involved companies (no business-to-business exchange). It specifies though that RIS should be open for interfacing with commercial activities.

One of the objectives of RIS is to enhance the safety of inland navigation by optimizing the waterway and traffic related information exchange between vessels, locks and bridges, terminals, and ports. It does not deal with other traffic safety aspects, which are under the responsibility of the Member States through the European Code for Inland Waterways (CEVNI) 27 , or national Police Regulations.

Within the EU framework established by the Directive, the Directive itself provides the general requirements of how RIS should be set up by the Member States, as well as the areas for which technical specifications need to be developed and the principles to be followed. The actual technical guidelines and specifications are developed by the Commission and are then adopted through secondary legislation. Five implementing acts have been adopted to provide the technical aspects of the RIS Directive’s requirements to make up the RIS framework 28 . Member States are then responsible for implementing the Directive and applying the technical specifications in an efficient, expandable and interoperable way (e.g. establishing RIS centres and designating authorities to oversee its application and the exchange of cross-border data). 

The RIS Directive applies to Member States with cross-border inland waterways of Classification of European Inland Waterways (CEMT) class IV 29 and above (Article 2). In practice, these are 13 EU Member States: Austria, Belgium, Bulgaria, Croatia, Czechia, France, Germany, Hungary, Luxembourg, the Netherlands, Poland, Romania and Slovakia, which have all had transposed the Directive by 2011. Several other countries apply the Directive voluntarily (i.e. Spain, Italy, Portugal, Switzerland, Serbia, Moldova and Ukraine).

Synergies with other EU policy instruments

The TEN-T Regulation 30 establishes guidelines for the development of the trans-European transport network, which also consists of the infrastructure for inland waterway transport. Some of the Regulation’s priorities deal with information and communication technology, such as implementing telematics applications (including RIS), while others deal with multimodal aspects, such as connecting inland port infrastructure to rail freight and road transport infrastructure. As regards IWT, the TEN-T network is based on a minimum classification (CEMT class IV and above), but unlike the RIS Directive, it is not limited to interconnected waterways (for example the Po in Italy, or the Douro in Portugal are part of TEN-T even if not within the scope of the RIS Directive). Therefore, the scope of these two acts is not identical. The European Commission adopted a legislative proposal 31  amending the TEN-T Regulation, where RIS is a requirement for the core network. Under the proposed revision of the TEN-T Regulation, RIS requirements will not be linked any more to the CEMT classification (which are based on parameters for the vessels), but will follow requirements based on the infrastructure (e.g. depth).

The RIS Directive requires continuity with systems of other modes and, in particular, with maritime transport (Article 1). In this regard, the regulation establishing a European Maritime Single Window environment 32 provides for a legal and technical framework for the electronic transmission of information about reporting obligations for ships calling at EU ports. Certain types of this information may be relevant to be further exchanged with IWTs.

The eFTI Regulation 33 , established a legal framework that allows economic operators to share information in an electronic format (i.e. for the transport of goods by road, rail, inland waterways and air in the European Union) with enforcement authorities. Operators are not obliged to make regulatory information available electronically to a competent authority. However, when they choose to make this information available electronically, they must follow a set of requirements. Currently, there is limited interaction between RIS and eFTI, however, there are potential synergies, in terms of use of eFTI platforms for the exchange of cargo information required by RIS.

The new Alternative Fuels Infrastructure Regulation (AFIR) 34  introduces targets for shore-side electricity supply in inland waterway ports, and requires Member States to prepare national policy frameworks, which among others will contain planned initiatives for deployment of infrastructure for alternative fuels in inland waterway transport, such as for hydrogen and electricity. RIS can complement AFIR, by facilitating the exchange of information between inland vessels and ports equipped for such alternative fuels and, in particular, on the (real-time) availability of infrastructure. This in turn can support the uptake of these fuels by the IWT sector.

The RIS Directive enables the exchange of data, and certain elements (such as data relating to the position of the vessel) can be considered as falling under personal data. Two cross-cutting legislative instruments are relevant in the context of digital inland navigation: Regulation (EU) 2016/679 (the General Data Protection Regulation – GDPR) and Regulation (EU) 2018/1725 on processing of personal data by the Union institutions 35 . The GDPR sets forth a single set of rules across the EU to protect and empower all EU individuals with regard to the processing of their personal data, and to hold organisations processing personal data of individuals in the EU accountable for their processing activities. It gives powers to the competent data protection supervisory authorities to impose corrective measures, fines and penalties on companies that do not comply with these rules. Regulation (EC) No 45/2001, mentioned in the RIS Directive, was replaced by Regulation (EU) 2018/1725. A requirement of data protection acquis is to lay down a clear legal framework identifying personal data, which must be shared in situations where the sharing is necessary for an objective of public interest. However, it needs to be taken into consideration that the RIS Directive itself is not obliging the exchange or disclosure of personal data. The RIS Directive is a legal framework providing for the technical requirements, specifications and conditions which ensure the electronic exchange of this data if national or international regulations foresee such exchange. It can therefore only lay down requirements for organisational and technical data protection measures, should RIS be used to exchange also personal data to ensure protection of those data.

Synergies with other non-legislative tools

·At European level, the following central systems include IWT elements: The European reference data management system (ERDMS) is a publicly accessible database kept by the Commission, containing regularly updated data provided by the Member States necessary for the provision of RIS. It contains detailed information about the inland waterway infrastructure (e.g. bridges, locks, terminals), including geolocation (RIS Index), formats of Notices to Skippers in all languages, and unified UNECE coding for cargo and vessels necessary for reporting requirements. In addition, it includes reference data for the European Crew Database (ECDB), and information on the competent RIS authorities. This use of standardised lists and data makes the ERDMS an enabler of interoperability.

·The CEF-funded project RIS COMEX (2016-2022) is a partnership of 13 European countries 36 to develop selected RIS Corridor Services along 7 European inland waterway corridors. This project resulted in a common European RIS system called EuRIS providing reliable fairway, infrastructure, traffic and transport information services, including route and transport planning, for the waterways of the partner countries. In addition, within RIS COMEX another system was developed to tackle administrative barriers and reporting burden for 8 IWT European countries 37  through a common electronic reporting system called CEERIS. CEERIS enables vessel operators to easily fulfil all their reporting duties to the different authorities along their route within the participating countries by reporting-only-once with single-entering-of-data and digital-by-default. The 13 participating Member States and their authorities continue with the use of this system under a separate European Corridor Management Agreement 38 . The project has recently entered a second stage (RIS COMEX 2) with additional CEF funding 39 , with Poland joining the partnership. It shall continue the work of the first stage by extending the quantity and quality of the related services and provided data, by extending the geographical scope to additional waterways and even to additional countries (Poland), as well as by focusing on interconnections and integrations of existing systems and services 40 .

1.4Evaluation of the RIS Directive

An evaluation of the Directive was carried out in 2021 41 . It found that overall, the Directive has been one of the main drivers of digitalisation in IWT, facilitating the introduction of information and communication technologies. 

In terms of effectiveness the evaluation found that standardisation of RIS has been the strongest benefit brought about by the Directive. However, the degree of harmonisation differs across RIS technologies and services (e.g. most harmonisation was achieved in type approval and the least in electronic ship reporting). Moreover, RIS technologies are not utilised to the same extent in all countries and river corridors, which has led to a fragmented development of RIS. Therefore, higher benefits of digitalisation and data exchange are hindered by the lack of full harmonisation of data provided across the Member States.

The evaluation also pointed to a slow development of RIS. Public and private stakeholders reported on major inefficiencies in the adoption speed of the RIS implementing acts, resulting in permanently outdated technical specifications for the sector. In terms of efficiency, potential for simplification was thus identified for the adoption process of technical specifications. Stakeholders also suggested that an improved monitoring of the application of the Directive is required to speed up the development of RIS.

As regards the general objectives of the RIS Directive, the available data did not indicate that RIS had an impact on the growth of the inland navigation sector, on modal shift or on safety. There were some indications that RIS has reduced fuel consumption by 1.9%. Lack of evidence did not however allow to draw conclusions on the optimised use of existing infrastructure. Feedback from stakeholders showed that RIS may have a limited or even indirect impact on competitiveness, a potential for more efficient use of infrastructure (locks), and a positive impact on safety.

Although the evaluation assessed that the Directive is still relevant, it pointed to the fact that its primary focus on safety of navigation is no longer sufficiently aligned with sector’s needs. More specifically, it does not support the need for improving the efficiency of inland waterway transport and its integration into the multimodal supply chains. In addition, it does not sufficiently address new technological challenges, such as automation of vessels, and the further digitalisation of the sector.

The rationale for public intervention at EU level through the RIS Directive is rooted in the cross-border character of the inland waterway transport sector and contributes to avoiding fragmentation between different national or regional (e.g. between the River Commissions) RIS implementation approaches. Stakeholders considered that the same benefits could not have been achieved by comparable interventions at the international, regional or national level. However, higher benefits of digitalisation and data exchange are hindered by the lack of full harmonisation of data provided across the Member States.

Last but not least, it should be noted that the evaluation identified a considerable lack of reliable, sufficiently granular and comparable data (in particular for costs and benefits of implementation), which in turn limited the quantitative evidence supporting the findings. Thus, the findings had to rely primarily on qualitative analysis and input from stakeholders. The links between the conclusions of the evaluation and the impact assessment are summarised in Annex 7.

1.5Sustainable Development Goals

The initiative contributes towards the objectives of the European Green Deal (EGD) 42 (in particular by supporting the shift away from road transport). The revision of the RIS Directive contributes towards Sustainable Development Goal (SDG) 9 (“Build resilient infrastructure, promote inclusive and sustainable industrialisation and foster innovation”) and SDG 13 (“Take urgent action to combat climate change and its impacts”).

2Problem definition

The key problem, corresponding drivers and consequences that are relevant for the revision of the Directive are presented in Figure 3  and further detailed below.

Figure 3: Problem tree

Source: European Commission

2.1What is the problem?

Problem: slow and fragmented deployment of River Information Services that hamper the competitiveness and safety of the sector, and its contribution towards the European Green Deal objectives

Description of the problem

The main challenge that RIS faces today is the slow speed and the fragmentation in its deployment. The TEN-T corridor studies 43  report that the deployment of RIS infrastructure along the Core Network Corridors cover: 100% of the North Sea, Mediterranean and Rhine-Danube Corridors, 95% of the Atlantic Corridor, 90% of the East Mediterranean Corridor and 75% of the Mediterranean Corridor. Thus, despite 17 years since its introduction, it still has not reached 100% level of implementation. The identified differences in implementation relate to prioritisation by Member States of the most important waterways in their territories. 

While the RIS evaluation 44 indicated a positive impact of the Directive in terms of harmonising RIS, it found that there is still room for improvement. This is because, when considering the implementation of the Directive, not all RIS technologies have reached the same level of implementation and maturity and not all RIS technologies have been fully utilised to the same extent in all countries and river corridors. For example, differences in deployment across Member States have been identified for the four key RIS technologies (inland ECDIS, Electronic Ship Reporting, Notices to Skippers, Vessel Tracking and Tracing). This is because Member States have not always followed the same timeline for implementation and/or because technical specifications have not always been applied or interpreted the same way. The evaluation identified that RIS equipment has reached a high level of type approval, which ensures equipment compatibility. Similarly, electronic charts are highly harmonised, which assists in navigation. On the other hand, the low harmonisation in electronic ship reporting and different national reporting requirements 45 result in resubmissions of electronic reports, with time and cost implications for operators. The impact assessment support study estimates that a resubmission of information is required in one out of three times that a vessel crossed a border during its voyage 46 . Therefore, the problem is not so much in relation to the situation within a certain Member State, but in how their heterogeneity affects the international nature of inland waterways.

The slow update of technical specifications has played an important role in the slow development of RIS. In the current setting of adopting implementing acts, it takes between 5 and 12 years until the technical specifications are prepared and introduced in the sector. This in turn reduces the efficiency of IWT operators due to the use of old technical specifications and technology (for example when radio is still used instead of electronic communication for reports between the ship and the authorities) 47 . This contrasts with the approach followed in Directive (EU) 2016/1629 providing for technical requirements for inland vessels, which includes a direct reference to technical specifications developed by CESNI, leading to a regular update of technical specifications every two years. As technological development keeps accelerating, the slow update of technical specifications in the RIS domain becomes a more acute hindrance.

The DINA report (2017) 48 examined factors relating to digitalisation and their impact on the competitiveness of the sector compared to other transport modes. RIS was identified as playing an important role in IWT. Thus, if not properly deployed, RIS can hinder the competitiveness potential of the sector. The DINA report also found IWT to be falling behind other modes of transport in terms of digitalisation and development of intelligent systems for reasons ranging from legal, technical and commercial bottlenecks to sharing of data, the IT set-up of barge operators, and the limited size of the sector (making it difficult to achieve economies of scale for new solutions). So far, the modal split of IWT has remained fairly stable over the past 20 years and the evaluation was not able to conclude if RIS had any impact in this development.

In terms of increased environmental protection, the evaluation pointed to a very modest reduction in fuel consumption by vessels through the use of RIS. However, it can be argued that better planning of trips and increased awareness of the traffic situation, could lead to more efficient navigation (e.g. by slower steaming when anticipating a long wait at a lock, thus improving fuel consumption 49 ). 

The lack of quantitative data, also identified by the evaluation, does not allow for a more detailed and quantitative illustration of the evidence supporting the problem. As the evaluation noted, there is considerable lack of reliable, sufficiently granular and comparable data, which does not allow quantification of the magnitude of the problem. Due to the nature of inland waterway transport being concentrated in navigable waterways, and the scope of application of RIS, the problem is materialising only in those waterways where RIS is introduced and applied. It is thus highly geographically focused and specialised. When considering the size of the sector, the magnitude of the problem will be necessarily limited in any comparison with the rest of the transport sector.

Still, the immediately affected stakeholders consider this to be an important problem. The Members States that participated in the open public consultation (Austria, Belgium, Croatia, France, Germany, the Netherlands, Portugal and Romania) supported the need for revising the Directive. This view was also supported during the first stakeholder survey 50 , where 9 out of 13 administrations indicated that no EU action would lead to negative developments in terms of RIS deployment. This position was reiterated at the first DINA/NAIADES expert groups meetings. It should also be noted, as explained in section 1, that there has been a clear request from both the European Parliament and the Council to revise the RIS Directive.

The respondents to the stakeholder consultation, as explained in Annex 2, acknowledged the problem identified, mentioning clearly that full harmonisation and interoperability of RIS has not yet been achieved due to fragmented implementation. According to the open public consultation, stakeholders find that the identified problem (and the drivers) relate to actual challenges of the IWT, as shown in Figure 4 below.

Figure 4: Importance of challenges in the implementation of River Information Services (RIS) in Europe

Source: Open Public Consultation

Who is affected and how?

The problem identified affects different actors (vessel operators, navigation software service providers, national public administrations and society at large) in different ways:

·Vessel operators are confronted with time consuming notification processes to authorities, as e.g. repeated notifications are required when crossing borders. They are also faced with extra efforts and time spent to obtain accurate information for planning their voyage. Non-accurate information, in particular regarding the navigation conditions on the river, can have negative impacts on the actual voyage of the vessel in terms of timing (e.g. due to congestion at locks) or in rare situations contribute to accidents. Sub-optimal operation can translate into reliability issues for the services (e.g. vessel arriving later than planned), which, in turn, reduce the attractiveness of the sector for the freight shippers. Non-efficient navigation also translates into higher cruising speeds than necessary, which lead to increased fuel consumption and thus increased costs for the sector. Differences in standards between countries and the additional complications in terms of operations that these may require are hindering the provision of services and creating market distortions. An example is the closure of locks not linked to real-time information or the predictions on water level in some countries. This in turn reduces the reliability of IWT and its competitive position with respect to other modes, thus leading to market distortion at multimodal level.

·Navigation software service providers are dependent for the development of their IT solutions on access to accurate basic data. To ensure the accuracy of the data under the current framework, they need to allocate extra efforts to collect the data due to wrong or outdated information.

·National public administrations also face challenges, in particular when handling cargo reports in paper format, which require efforts to process them. Efforts are also required to process repeated reporting, including those required when a vessel is crossing the border. In addition, incomplete information regarding the traffic in the waterways does not allow national authorities to efficiently manage traffic and may hinder their ability to react to emergency situations (e.g. in case of an accident if the dangerous cargo information has been submitted with errors).

·For the society at large, the overall challenges translate into external costs stemming from freight being transported on road.

A number of Member States, without navigable waterways or with waterways out of the scope of the Directive, are not affected by the problem. The Member States withing the scope of the Directive show significant differences driven by the size of their network, the number of ports and the level of traffic. For example, as explained in section 1, Germany and the Netherlands accounted for 69% of overall EU IWT transport in 2020 51 . In terms of national modal split, IWT plays a significant role in the land freight transport activity 52 within the Netherlands (39.7%), Bulgaria and Romania (28% each) and a lower role in Belgium (10.9%), Luxemburg (8.2%), Germany (7.3%), Croatia (6.0%) and Hungary (4.7%).

An important element of IWT is its cross-border dimension. Thus, the challenges are more important when a difference in a technical specification appears between two Member States with high volumes of traffic. Beyond this, there are no specific problems for regions, local authorities, private entities or individual EU areas.

What are the consequences of the problem?

The slow and fragmented deployment of RIS technologies has a number of consequences. The first one relates to the geographical dimension. For example, for the Notices to Skippers (NtS) the coverage has not reached 100% in all countries. This means that there are areas with gaps, where skippers do not receive the same level of information regarding the rivers and their condition. This, in turn, impacts the navigation efficiency of the vessel and may lead to safety risks for those areas. The second consequence has to do with missing technical specifications, where these have not been developed for Vessel Traffic and Tracing (VTT). In the absence of these technical specifications, Member States are making use of the Automatic Identification System (AIS) for their needs, but there is not harmonised way on how, when and for which systems it should be used. And while its use within a specific Member State may not be problematic, this can lead to challenges when the vessel is crossing a border.

Regarding the slow update of technical specifications and what does this mean in view of technological developments, this can be illustrated by the reporting of cargo information. This is often done through VHF, which can lead to mistakes in the information provided. More up to date technical specifications could require the use of electronic exchange. Another illustrative example can be when the technical specification refers to specific software characteristics. When a new and improved version of the software is available, correcting possible challenges and introducing new functionalities, vessel operators are not able to benefit from this new version until the technical specifications have been updated.

IWT is considered generally a safe mode of transport, but accidents can range from minimal incidents (e.g. a ship goes off course and collides with a bank or quay) to more serious collisions with bridges (where ships might completely destroy their wheelhouses).

Statistics on accidents in inland waterways transport are limited. Eurostat collects accident statistics from national statistical offices on a voluntary basis. Not many countries in the EU provide data on accidents and there is no clear evidence on a common methodology used among the countries (see Figure 5). In addition, the current Eurostat data does not provide information about the type or the causes of the accidents.

Figure 5: Accidents in IWT in selected Member States

Source: Scheepsongevallenregistratie Rijkswaterstaat and Eurostat

The German 53 statistics for 1995-2017 provide an indication of the main causes for accidents: grounding, ship gets stuck, collision between ships, collision with infrastructure and bridges, pounding of waves and other accidents. The most frequent types of accidents were the collision with infrastructure and bridges (38-40% of all accidents) and the collision between ships (18-19%). It should also be mentioned that a significant share of total accidents (15-20%) involve small pleasure boats. No information has been obtained from insurance companies.

Due to unavailability and unreliability of data on accidents, the RIS Directive evaluation was not able to identify a direct link between RIS and improved safety on waterways. However, the stakeholders had a positive view on its impact in this regard 54 . An example is the fragmented implementation (i.e. data is available in different national systems), which means that there is currently no harmonised system providing information on dynamic parameters for waterways. If the information is not up-to-date or the technical specifications applied between different Member States are not compatible, this creates workload for skippers (who need to anticipate and account for possible mistakes) and may lead to accidents (if for example skippers do not know exactly the height between the river and the bridge).

One could think that slow speed would have an impact on safety. However, as explained above, the risk to safety comes rather from the lack of accurate information and awareness of the situation on the river. In terms of the causes of accidents, groundings are linked with inaccurate knowledge of the depth of the river at a certain point and time. Likewise, collisions with bridges are caused when the distance between the river and the bridge is not well estimated and the wheel of the barge collides with the bottom of the bridge. Collisions between vessels can happen when vessels operators are not aware of each other when rounding river bends.

As regards environmental concerns, the EGD and the SSMS aim to reduce the environmental impact of the transport sector. IWT is expected to play its role. To this aim, the SSMS set a milestone for transport activity by inland waterways and short sea shipping to increase by 25% by 2030 and by 50% by 2050. Improving the environmental performance of the sector is also one of the aims of the Directive. As this is primarily a digital initiative, its environmental contribution is not expected to be high; however, it can still play a role. On the one hand, improved technology should lead to more efficient navigation resulting in reduced energy use, with clear impacts on emissions. On the other hand, improved reliability of the sector and better integration into the multimodal logistic chains is expected to shift freight from road to inland waterways. The evaluation pointed to a small reduction in fuel consumption (1.9%) through the use of RIS. There is nevertheless further potential for improvement, so that IWT increases its contribution towards greening the transport sector.

2.2What are the problem drivers?

Problem driver 1 (PD1): Missing and non-harmonised RIS information hampers efficient and safe navigation

Users continue to receive fragmented or low-quality information from Member States via RIS, hampering efficient and safe navigation. This is manifested in terms of differences in the data quality of the underlying RIS. According to a stocktaking exercise of the situation in the Member States 55 , the basic requirements of the Directive were implemented (in terms of setting up of RIS centres and introducing legislation regarding the four basic RIS key technologies). However, certain elements (like the ERDMS data), despite their importance, are not mandatory, which introduces gaps and reduces the quality of RIS. Furthermore, the Directive is not prescriptive in the technical aspects but sets the higher-level principles and relies on the implementing acts to define the details. The implementing acts, despite their level of detail, appear to leave a room for manoeuvre in their implementation by the Member States in practice. For example, blockages of locks may be reported in the Notices to Skippers (NtS) as a complete blockage in one country but only as partial in others. This leads ships operators to spend time to properly interpret and confirm the data, in order to avoid surprises when arriving at the lock. These discrepancies impact inland waterways in two ways. On the one hand efficient navigation is hindered, if the skippers require more time to plan their navigation or encounter unexpected delays due to the infrastructure not being available. It was estimated that in 2020 14,800 hours were “wasted” due to these discrepancies 56 . On the other hand, these differences can lead to accidents if they are not identified on time.

Figure 6 illustrates the status of electronic reporting system implementation and related international exchange of ERI messages among neighbouring countries. This is the area where the lowest harmonisation was found, especially due to different reporting requirements in the Member States resulting in resubmissions of electronic reports. It shows that in the Rhine catchment for example, the electronic transmission of reports is generally positive, while in Eastern Europe (i.e. borders between Germany and Poland as well as Germany-Czech Republic) and on the Danube, it is comparatively less harmonised. Thus, the problem is more concentrated in the geographical areas where less IWT freight volumes are moved.

Figure 6: Landscape of electronic reporting systems and services in Europe in November 2020

Source: DIWA Masterplan 57

This problem driver was indicated as very important by 12 out of 13 respondents in the Open Public Consultation (OPC). Furthermore, this was confirmed by the respondents to the first stakeholders’ survey 58 , who considered this driver as relevant to the problem (42 out of 65 respondents). The difference in data formats across countries, together with the unreliability of the RIS Index, as Member States update the information on a voluntary basis, were specifically mentioned as issues in the first survey. For example, 3 stakeholders representing international public bodies indicated that the RIS Index is not sufficiently reliable or clearly defined. 

During the second stakeholder workshop 59 with skippers, it emerged that information on water levels is also crucial for skippers to plan a voyage. They also flagged that missing and non-harmonised RIS information is one of the main drivers hampering efficient voyage planning. Experts participating in the meetings of the DINA and NAIADES Expert Groups 60  mentioned that the RIS Directive is in principle helpful but it should have been implemented better. On the other hand, the Commission did not receive formal complaints regarding its implementation that could have led to infringements. Experts also mentioned that the newly developed EuRIS portal should positively affect the missing and non-harmonised RIS information 61 .

Problem driver 2 (PD2): Inefficient processes for creation and implementation of technical specifications for River Information Services

The current system of updating RIS technical specifications is based on implementing acts adopted by the Commission. With the current setting of working with sectoral experts to support the Commission, this process takes around 10 years, which is very lengthy, particularly in view of the pace of technological developments. For instance, the technical specifications for Notices to Skippers and for Vessel tracking and tracing systems, introduced in 2007, were updated in 2018 and 2019, respectively. The technical specifications for electronic reporting of 2010 were revised in 2019, while those on the electronic chart display and information system for inland navigation (Inland ECDIS) adopted in 2013, were revised in 2018. Moreover, the RIS Guidelines have not been revised since 2007.

Currently, the basic work on the preparation of technical specifications is undertaken by Member State experts who meet and discuss under different groups. These are then used as a basis for the Commission to prepare the relevant implementing acts. The self-organisation of the work by MS experts (with contributions from CCNR) seems to constitute an important bottleneck leading to a lengthy process (sometimes between 7-8 years) which has accordingly been criticised by stakeholders. In the stakeholders’ consultation process accompanying the RIS evaluation, stakeholders expressed the view that the time between updates is too long, which may cause problems in terms of their relevance for the future. This is because outdated technical specifications do not ensure maintaining the highest level of efficiency and do not follow the developments in digital technology. An illustrative example relates to the technical specifications for Inland ECDIS (on points such as the resolution of digital maps, elements to be presented on maps, the way how they should be presented, etc.), where the efficiency of digital maps is linked directly with the technology used (graphic programmes).

In the OPC, 10 out of 13 respondents expressed the view that this a very important problem driver and 3 out of 13 respondents see it as a somewhat important driver. The first stakeholders’ survey showed a similar picture, where 40 out of 65 stakeholders perceived problem driver 2 as important.

Besides the late introduction of technical specifications, the number of relevant implementing acts creates a challenge for the sector. Technical specifications are spread across various legislative measures, with negative consequences on their clarity and consequent uptake. This does not enable the timely uptake of RIS in line with evolving technical innovations for two reasons: a) even minor updates need to “wait” for the appropriate technical specification’s turn and b) it multiplies the efforts and time required to prepare and adopt the implementing acts. Participants in the two stakeholder workshops organised during the stakeholders’ consultation flagged the existence of a wide variety of technical specifications and technical specifications which need to be implemented to allow RIS to remain up to date with current technical developments. New developments and challenges (e.g. digital and green transitions, which were not in focus in 2005) may require additional data to be reported through RIS. To deal with these developments, the sector needs to adapt, for instance, through smart shipping approaches in the context of smart logistics framework. In this context, accurate information on waterway profiles, water levels and dimensions of structures form an absolute necessity. This could be provided through RIS services; however, the current inefficient processes for RIS technical specifications and delayed uptake of evolving technical innovation hinders the adoption of such technologies and makes IWT less competitive compared to other transport modes.

This problem driver is also linked to problem driver 1. The lack of a frequent and regular update of technical specifications does not allow for corrective action to be taken on time.

Problem driver 3 (PD3): River Information Services do not sufficiently support the integration of inland waterways transport into multimodal supply chains (modal shift)

The European Green Deal requires all transport modes, including inland waterway transport, to address the greening and digitalisation transition. This includes a better integration between different modes of transport into a seamless intermodal logistic chain. The RIS Directive anticipates the possibility or need for connecting RIS with systems of other modes, in particular with maritime transport. These links, however, have not been specified by the Directive or the implementing acts and no indication was identified that such connectivity exists at Member State level.

At the same time, the transport sector saw developments in other modes. For example, legal provisions for other cargo tools were introduced (2019 for EMSWe and 2020 for eFTI). The Directive lacks the framework to make the necessary links with these systems, and therefore cannot support the integration of IWT in the logistic chain.

The RIS evaluation concluded that the RIS Directive so far has focused on safety of navigation, while not enabling the integration of inland waterway transport into multimodal supply chains. In the OPC, 11 out of 13 respondents considered this as a very or somewhat important problem driver. This view was further supported by the respondents to the first stakeholders’ survey, where 33 out of 65 respondents found problem driver 3 to be relevant.

The EU transport policy aims to promote less polluting and more energy efficient modes of transport, including for freight, and actions are taken to support intermodal transport. In addition, since the adoption of the RIS Directive, further developments have taken place in relation to synchro-modality, and tools have been developed to improve the efficiency of logistics supply chains. Initiatives such as EMSWe and eFTI, that offer opportunities to integrate IWT in the logistics chain, were developed after the adoption of the RIS Directive. Thus, the Directive does not provide the proper framework to make the necessary links. On the other hand, experts (representing Member State authorities and vessel operators) participating in the DINA and NAIADES expert group meetings, pointed to the different aims and scopes of the initiatives (e.g. eFTI has a clear role for logistic and cargo related information, while RIS is viewed more as a tool for safety and traffic management related information), and cautioned against mixing their purposes. Stakeholders participating at the dedicated workshops also expressed opposing views, with some seeing eFTI as unrelated to RIS, while others considering that eFTI could be used by all modes (creating a one stop-shop solution).

The stakeholders participating in the first stakeholder workshop also shed some light on the need to find a common denominator between different navigation transport modes. In this context, ports play a crucial role as they provide the link between IWT and other modes such as road and rail. However, participants pointed out that technology standards in delivering information are heterogeneous across inland ports as they are developed individually. The smooth integration of IWT in intermodal transport requires efficient and accurate information exchange with inland ports. As an illustration, a vessel operators representative indicated during the workshop that skippers on tanker vessels need to know that ports have available capacity, as they often transport dangerous goods that can only be kept on board for a specific period of time. As this information is not foreseen in RIS, it increases the burden on skippers to plan their voyages. This view is confirmed by the network coverage of the EuRIS portal in Germany. For example, in ports such as Duisburg, Dusseldorf, Neuss, Mannheim and Karlsruhe, information on the dimensions of bridges over port basins and operating times is lacking. This causes the need for extra time when making voyage preparations as skippers need to look up the required information on individual port websites.

This lack of exchange of information with other modes is thus hindering the potential of IWT to perform in a multimodal chain and thus deliver on the objectives defined by the SSMS.

Problem driver 4 (PD4): Inefficient exchange of information (including cross-border) and reporting

An efficient exchange of information across borders between authorities is important for an efficient transport system. Despite improved Member State cooperation over time, not all reports are digitalised and, even when they are, Member States use different reporting applications that are not compatible with each other 62 . According to the evaluation, despite the adoption of the RIS Directive, there has been no substantial reduction in the number of resubmissions of electronic ship reports at borders due to differences in national reporting obligations. The number of resubmissions of electronic reports was estimated at 30% of total number of border crossings (i.e. 106,622 resubmissions in 2020). Each resubmission is estimated to require 15 minutes for vessel operators. Thus, vessel operators are estimated to have spent 25,841 hours for the resubmissions of electronic reports in 2020, equivalent to EUR 689,759 63 . 

In addition, based on the survey and the interviews with inland skippers it is estimated that inland skippers spend on average 10 minutes on reporting obligations in inland ports, with an estimated annual total cost of EUR 1.3 million in 2020 64 . A significant part of these costs stem from duplications that could be reduced or eliminated if a proper exchange of information between RIS and ports were in place.

All 13 respondents to the OPC found problem driver 4 to be very or somewhat important. In the context of the first stakeholders’ survey, 43 out of 65 respondents considered problem driver 4 to be relevant. In addition, 7 out of 25 respondents to a question on efforts spent on reporting (specifically inland waterway operators) indicated resubmission as a high burden. On the other hand, only 3 out of 13 national authorities that responded indicated high or medium costs for processing the electronic reports, 2 out of 13 indicated low costs and 1 authority indicated no costs at all. 7 out of 13 national authorities were not able to answer or indicated that it was not applicable to them.

The DINA (2017) 65 report outlined that during a journey on the Danube, more than 20 different forms have to be filled in different languages. The study estimated that filling in each form was taking ten to twenty minutes per border-crossing, depending on the type of trip.

There are some attempts to solve this problem on the ground through various reporting applications 66  or through elements of the RIS COMEX. However, their application is not harmonised as indicated in the first DINA/NAIADES expert group meeting due to, for example, challenges in having up-to-date information. 

Problem driver 5 (PD5): Lack of legal certainty about processing of personal data by the inland waterway stakeholders

Several studies suggest that data protection concerns from the side of RIS stakeholders hinder the degree to which data from electronic ship reporting is shared between competent authorities. In fact, the RIS Directive currently only requires setting up national RIS that enables sharing of personal data if national or international law requires it (Article 4(3)c). It further refers to the data protection requirements of Data Protection Directive that is replaced by the General Data Protection Regulation (GDPR). RIS is basically a platform for data exchange providing harmonised technical specifications for data, but not the legal basis on which some personal data is actually collected and has to be submitted (e.g. border regulations, police regulations, etc.).

As it emerged during a targeted stakeholders’ workshop, barge owners often live inside their barge. For family-owned companies, the vessel is the home of the skipper and the information about its position is often considered by vessel operators as personal data. In these cases, as explained during the specific workshop held for skippers, the exchange of information and identification of the position of the vessel is often restricted for fear of privacy rule violations. On the other hand, Member States or other authorities are reluctant to share RIS information to avoid potentially breaching privacy rules. This example indicates that both Member States and stakeholders seem to be unaware how far and for which purposes personal data is or could be lawfully exchanged via RIS. Currently there is no personal information exchanged through RIS and there are no actual concerns regarding Data Protection. The issue is therefore only the perceived risk, due to the lack of clarity, which leads stakeholders and Member States to be reserved in the context of exchange of information.

According to the evaluation, to address this issue Member States may conclude additional data exchange agreements for RIS purposes. In addition, to ensure legal certainty Member States should review their national laws and international commitments and ensure that personal data requests are always based on valid legal basis provided by law in line with the GDPR. The incomplete data on the position of surrounding vessels impairs the efficient voyage planning for skippers and may limit the situational awareness of national authorities who have a valid reason for having this information, for reasons of safety. Therefore, an update of the RIS Directive is needed to clarify what are the obligations under the RIS Directive and also clearly make transparent what is the legal basis for personal data exchange in the context of operating RIS.

In the OPC, 11 out of 13 respondents indicated that this problem driver is very or somewhat important. In the context of the first stakeholders’ survey 38 out of 65 respondents found this problem driver to be definitely or somewhat relevant.

Views of stakeholders on the problem drivers

Stakeholders agree with the problem drivers as identified. As shown in Figure 7, the majority of stakeholders responding to the first stakeholders’ survey considered all problem drivers to currently be an issue for the sector.

Figure 7: “In your view, are the problem drivers listed below problems which the IWT/ RIS sector currently faces?” (n=65)