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Time to facilitate European shipping

07 Νοεμβρίου 2018.

ecsafotoThe EU urgently needs a new Reporting Formalities Regulation that cuts administrative burden and improves maritime transport efficiency by harmonising the data that ships report when calling EU ports and simplifying its submission to authorities. This will alleviate pressure on crews, facilitate digitalisation in shipping and ensure that shipping can start properly benefitting from the Internal Market. The European Commission’s proposal (COM(2018)278) is a positive step forward but must also be improved.

In May 2018, the European Commission published a proposal for a revision and replacement of the EU Reporting Formalities Directive (RFD 2010/65/EU). We are pleased that the European Commission has come forward with its proposal to try to rectify the situation. The new draft Regulation is intended to remedy the current costly, unharmonised and burdensome reporting requirements facing ships calling at EU ports, which the previous Directive was not able to fix. Current complex and duplicative reporting requirements result in productivity losses for shipowners and maritime carriers and their customers and create unnecessary workload and stress for ship crews. Indeed, today it is not uncommon for Captains to spend several hours doing administrative tasks repeatedly when navigating between European ports. The impact assessment indicated that 4.6 million hours per year are spent on fulfilling administrative duties for ships calling at EU ports. That time could be much better spent.

A genuine “European Single Window” is required that will enable the same data to be submitted in the same way for the same operations and processes in all EU ports. The European Community Shipowners’ Associations (ECSA) and the World Shipping Council (WSC)¸ which represent maritime carriers, that are the principal parties affected by this legislation, call on the EU Institutions to agree and implement a new European reporting formalities framework that benefits shipowners and maritime carriers and the wider EU economy. The European Commission’s proposal is a very good start, but implementing the following 3 principles will ensure that the draft Regulation attains its overarching aim:

1. Adopt a ‘Harmonised Maximum List’ of Data Reporting Requirements for Cargo and Vessels, valid in every EU Port

Shipowners and carriers face a mosaic of reporting requirements for vessels and cargo that differ significantly between EU Member States and even between ports in the same country. This must be remedied with the adoption of a maximum harmonised data set to 2 meet applicable reporting requirements anywhere in the EU. The European Commission’s proposal for a European Maritime Single Window (EMSW) Data Set is positive but includes a mechanism for Member States to add on top of it any additional information they choose. This will expand the total number of data elements over time if no additional requirements are introduced for adding data elements. Data elements must be properly assessed and deleted if not essential. Any additional data requirements should be exceptional and duly justified. The Regulation should empower the European Commission to assess whether any new additional proposed data elements meet this requirement.

2. Establish a Suitable Harmonised Reporting Interface for Submitting the Data

The 2010 Reporting Formalities Directive replaced costly and divergent paper based submission processes with costly and divergent electronic submission. It generated huge IT costs and disruption for shipowners and carriers as new IT systems proliferated. Any new IT investment costs should bring genuine benefits and be suitable for different shipping companies, large or small. For companies handling smaller quantities of data it is today more efficient for a human to upload this data via a web based, ‘user to system’ connection. It would streamline processes and facilitate training their staff if these different websites had the same look and feel no matter which Member States’ single window was used.

The European Commission’s proposal would do that. For short sea shipping this is an improvement not to be underestimated. However, for bigger shipping companies handling larger quantities of data, it is impossible to process those amounts of data without using a machine- to-machine interface. These require much greater investment to set up, test and maintain. It would be a net cost for companies using machine-to-machine interfaces today to be required to replace all the existing connections they have invested in with harmonised but separate national connections, as per the European Commission’s proposal. We cannot support that particular approach. In order to gain real benefits from investment in improved data processes, companies should have the option of being able to use alongside existing interfaces a single EU level interface to submit their data.

This interface would distribute data to all national single windows and transmit back to the carrier any feedback generated by those national systems. Such a cost-efficient single EU interface, as an alternative to the multiple national and port level interface connections in place today, would be an essential step forward in integrating and simplifying EU trade data flows. For SMEs digitalisation will be more attractive if investments are geared towards one European interface and are future proof. The Regulation should be amended to provide for the establishment of such a ‘voluntary to use’ single EU interface.

3. Implement the Right Principles for Efficient Submission, Exchange and Reuse of Data

The new legal framework and system needs to embody the right approach to digitalisation, including the ‘reporting once’ principle, a single access point and data sharing. The efficient exchange and reuse of data both within and between EU Member States is key to the efficient flow of business-to-authority data. And having the choice to use a single access 3 point for submitting a variety of information to multiple administrations is vastly more efficient. It is also critical that systems changes that are authorised or mandated by the Regulation must be compatible with emerging commercial data management systems.

Put differently, any new systems must be technologically neutral and “future proof” in order to avoid stranding investments or stifling innovation. Implementing these principles will improve the working of the whole logistics chain, boost competitiveness, help bring shipping into the Internal Market and secure through better ship to shore connections and efficiency the enhanced use of environmentally friendly shipping routes in Europe. This is the second opportunity to harness this potential in the maritime sector through EU action on digital reporting. It should not be wasted.

Source: ECSA (European Community Shipowners’ Associations)











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