Railway Vehicle Identification and Registration

Colin Buchanan and Partners Introduction
COLIN
BUCHANAN
AND PARTNERS
Planning, Transport,
Economics
Software, Market Research
European Commission
Vehicle Identification
and Registration
Final Report
Project No: 60751

May 2003
Newcombe House, 45 Notting Hill Gate

London W11 3PB
Telephone: 020 7309 7000

Fax: 020 7309 0906
email: CBP@CBUCHANAN.CO.UK
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1. INTRODUCTION 1-4
1.1 Authority and Brief 1-4
1.2 The Study Team 1-4
1.3 Background 1-5
1.4 Study Methodology 1-9
1.5 Assistance Provided 1-11
1.6 Structure of Report 1-11
2. CURRENT ARRANGEMENTS 2-1
2.1 Placing Vehicles in Service 2-1
2.2 Vehicle Numbering Systems 2-9
2.3 Railway Coding Systems 2-18
2.4 Relevant EU Directives 2-20
2.5 Legal Obligations 2-24
2.6 Number of Vehicles 2-32
2.7 Uses of Numbering Systems 2-33
2.8 Particular Issues for non-UIC Members 2-36
2.9 Interface with OSJD 2-37
3. ANALYSIS OF EXISTING SYSTEM 3-1
3.1 Legal Compliance 3-1
3.3 Numbering Systems 3-6
3.4 Functions of Numbering Systems 3-8
3.5 Vehicles Owned by non-UIC Members 3-9
3.6 Access Rights to Systems 3-11
4. COMPARISONS 4-1
4.1 Objective and Terminology 4-1
4.2 Comparison Philosophy 4-1
4.3 Other Transport Modes 4-3
4.4 Other Industries 4-15
4.5 Railway Systems Elsewhere 4-21
4.6 Conclusions and Parallels 4-29
5. INDUSTRY’S VIEWS AND PROPOSALS 5-1
5.1 Overview of Section 5-1
5.2 Commission’s Proposals in RWP II 5-1
5.3 Industry Views 5-6
5.4 The Vehicle Numbering System 5-8
5.5 CODIRAIL 5-9
5.6 RICS Study 5-10
5.7 The Steria Study 5-15
6. OPTIONS FOR CHANGE 6-1
6.1 Key Objectives 6-1
6.2 Key Questions 6-2
6.3 Placing Vehicles in Service and Allocating Identifiers 6-3
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6.4 Database and Register Issues 6-3

6.5 Definition of a Vehicle 6-5
6.6 Form of Identifier 6-6
6.7 VIN Issues 6-9
6.8 Maintenance and Insurance 6-11
7. ANALYSIS OF OPTIONS 7-1
7.2 Database and Register Issues 7-3
7.3 Form of Identifier 7-8
7.4 VINs 7-15
7.5 Maintenance and Insurance 7-20
7.6 Cost Benefit Analysis 7-22
7.7 Evaluation of Identification System Options 7-28
7.8 Evaluation of Numbering System Options 7-32
8. CONCLUSIONS 8-1
8.1 Organisational 8-1
8.2 Technical 8-2
9. RECOMMENDATIONS 9-1
9.1 Organisational Recommendations 9-1
9.2 Technical Recommendations 9-3
LIST OF APPENDICES
A. EC STUDY SPECIFICATION
B. PARTIES CONSULTED
C. BIBLIOGRAPHY
D. COUNTRY STUDY – FRANCE
E. COUNTRY STUDY – GERMANY
F. COUNTRY STUDY – GREAT BRITAIN
G. COUNTRY STUDY – POLAND
H. USES OF VEHICLE NUMBERS IN FREIGHT SYSTEMS
I. IT SYSTEM TYPES TO WHICH ACCESS IS REQUIRED
J. VALUES USED IN COST BENEFIT ANALYSIS
K. CODING OF RECOMMENDED RUNNING IDENTIFIER
L. LIST OF ABBREVIATIONS
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1. INTRODUCTION
1.1 Authority and Brief
1.1.1 In May 2002 a consortium led by Colin Buchanan and Partners

(CBP) supported by Pegasus Transconsult Ltd (PTC) was appointed by
the Directorate-General for Energy and Transport of the European
Commission (the Commission) to undertake a study into “Vehicle
Identification and Registration” (Contract No 2002/B27040B/E2/
SO7.11682/ETU).
1.1.2 The study’s purpose was to investigate the way in which rail
vehicles are identified and placed into service, in the context of the
changing organisational structure of the rail industry; with specific
emphasis on the operation of the Single Market and compliance with EU
legislation and policy objectives in the sector.
1.1.3 The main tasks defined by the Commission were to:

Examine the position of vehicle identification and registration in
relation to current EU legislation.
Analyse and describe current registration systems.
Assess current reform projects
Develop proposals for a European coding and registration system.
1.1.4 The Commission’s specification for this study is included as

Appendix A to this Report; providing a full description of its
requirements.
1.2 The Study Team
1.2.1 The Consortium consisted of the following members:

Colin Buchanan and Partners (UK/Ireland)
Pegasus Transconsult (UK)
SchlumbergerSema (France/UK)
Patricia Leefmans (The Netherlands)
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1.3 Background
1.3.1 Up to the end of the last century Europe’s rail networks were
organised on national lines, which for the preceding half century had
been almost exclusively in the hands on monolithic state owned
organisations (subsequently to as national railways/national railway
undertakings herein). With the exception of government direction and
some safety regulation these organisations were totally responsible for all
matters pertaining to rail networks and their operations, including the
acceptance of vehicles into service and their numbering.
1.3.2 The provision of services across national boundaries required a

degree of co-operation between railways. Accordingly, railways and
their governments began to agree the arrangements for exchanging traffic
and the outline specifications of vehicles permitted to run on the
networks of other states. A notable milestone was the 1882 Bern
Technical Union, which inter alia defined the standard “Berne” loading
gauge. This co-operation led to the railways founding the International
Union of Railways (UIC) in 1922, following intergovernmental
conferences in Portorosa and Genova.
1.3.3 Amongst the issues covered by UIC agreements is the mutual

acceptance of hauled rolling stock, if it accords to agreed standards, the
conclusion of international contracts for use and the numbering and other
markings borne by vehicles.
1.3.4 The exchange of traffic between states requires a specific legal

structure to govern applicable law, rights and obligations and the
resolution of disputes at an international level. The first international
treaty was signed in 1890. Its successor is the COTIF Treaty. These
treaties are concluded by Governments and take effect through national
law. A substantial revision, COTIF 1999, is in the process of being
ratified. This new treaty extends the scope of COTIF to new areas
including the adoption of mandatory standards for railway equipment and
the technical approval of equipment.
1.3.5 The relative importance of rail as a mode has declined sharply in

Europe for both passenger and freight traffic over the past half century.
This is shown, for the last thirty years, in terms of traffic volume in
Figures 1.1 and 1.2, and in terms of modal share in Figures 1.3 and 1.4.
Rail’s performance for international traffic is particularly disappointing;
measured across Europe the modal share for international traffic is lower
than for domestic traffic, which is counter-intuitive. Poor information
exchange and international control plays a major part in this state of
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affairs1. The role of vehicle identification systems needs to be seen

within this context.
Figure 1.1 EU15 Goods transport - billion tonne kilometre 1970 – 2000
3500
Road
Rail
3000 Inland waterway
Pipelines
Sea
Total
2500
Billion tonne kilometres
2000
1500
1000
500
0
1970 1980 1990 2000
Source EU Energy and Transport in Figures 2002, European Commission (for figures
1.1 – 1.4)
Figure 1.2 EU 15 Passenger transport - billion passenger kilometres

1970 - 2000
5000
Car
4500 Bus, coach, tram & metro
Rail
4000 Air
Total
3500
Billion passenger kilometres
3000
2500
2000
1500
1000
500
0
1970 1980 1990 2000
1
See for example, the major study examining this issue The Integration of
National Conventional Rail Systems, Symonds Travers Morgan, May 1997.
1-6
Figure 1.3 EU15 Goods Transport - Market share by mode 1970 -2000
Figure 1.4 EU 15 Passenger Transport - Market share by mode 1970 -

2000
1.3.6 To counter this sharp decline the Commission has spearheaded a

process that had already been started by several national governments to
liberalise the rail industry and to create a Single European rail market.
The process was set out in the Commission’s White Paper 2 on the
revitalisation of rail in 1996 and reinforced in January 2002 in the
2
See EC White Paper A Strategy for Revitalising the Community’s Railways,
COM(96)421 final.
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Commission’s communication on the integration of rail3. In many

Member States this process will require considerably greater
liberalisation in the sector, which in turn will make many of the current
arrangements, responsibilities and processes inappropriate.
1.3.7 A number of key pieces of legislation have become European Law

in furtherance of this strategy to improve the performance of Europe’s
railways (some which also cover a range of other industries), including
the following EU Directives and Decisions:
91/440/EEC, on the development of the Community’s railways;
93/38/EEC, co-ordinating the procurement policies of the water
energy transport and telecommunications sectors;
93/465/EEC, concerning the modules for the various phases of the
conformity assessment procedures and the rules for the affixing and
use of the CE conformity marking, which are intended to be used in
the technical harmonisation directives;
95/18/EC, on the licensing of railway undertakings;
95/19/EC, on the allocation of railway infrastructure capacity and
the charging of infrastructure fees;
96/48/EC, on the interoperability of the trans-European High-Speed
rail system;
2001/12/EC, amending Directive 91/440/EEC on the development of
the Community’s railways;
2001/13/EC, on the licensing of railway undertakings;
2001/14/EC, on the allocation of railway infrastructure capacity and
the levying of charges for use and safety certification;
2001/16/EC, on the interoperability of the trans-European
conventional railway system.
It is noted that the first, fourth and fifth of the above directives have been
amended or replaced by the so called infrastructure package comprising
Directives 2001/12/EC, 2001/13/EC and 2001/14/EC.
1.3.8 The two interoperability Directives have the greatest relevance to

this study. When fully implemented these will make significant
differences to the process of placing rolling stock in service, with a new
method of assessing conformity through certification by independent
notified bodies. Once a piece of equipment has been accepted by an
accredited notified body in one EU State it must be accepted by those in
3
Towards an integrated European railway area, COM (2002) 18 Final,
23.1.2002.
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all others, subject only to assessment of conformity with specific aspects

of national railway systems that have been agreed as being problematic.
This is expected to improve considerably the Single Market for railway
equipment, provide a non-discriminatory approval regime and facilitate
interoperation and international services.
1.3.9 The basic prerequisite upon which the process of pan-European

approval by notified bodies takes place is the creation of common
European standards in the form of Technical Specifications for
Interoperability (TSIs), which are currently being drawn up by the
Association Européenne pour l’Inteoperabilite Ferroviaire (AEIF). These
are supported by the detail contained in the relevant Euro Norms (ENs)
drafted by CEN, CENELEC and ETSI. The TSIs for high speed
interoperability under Directive 96/48/EC came into force in December
2002 and the first batch of drafts under Directive 2001/16/EC were
issued in September 2002. These will come into force in due course once
the drafting process is complete and they have been approved.
1.3.10 The objectives furthered by the TSIs will only be achieved if the
entire process of placing a vehicle in service meets Single Market
criteria. If there are any other steps between that of technical approval
and the commencement of day-to-day operations that could be used to
frustrate the objectives of EU policy then these need to be removed. The
processes and systems used to register and identify railway vehicles
therefore require examination; this fits into the context of removal of
barriers to fair competition for the suppliers of railway equipment and
between railway undertakings.
1.3.11 A further important issue in the context of this study is the

requirement for a Register of Rolling Stock in Article 24 of Directive
2001/16/EC, which would appear to require a high degree of
commonality in the form and format in which data is held.
1.4 Study Methodology
1.4.1 The study has been undertaken in six stages as follows:

1 data collection and research;
2 assessment/interface with current reform projects;
3 analysis;
4 formulation of appropriate solutions/identification of
measures;
5 evaluation of options for change/cost benefit analysis;
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6 development of recommendations.
1.4.2 To assist and advise the Consortium the Commission assembled an

Expert Advisory Group (EAG), with whom four meetings were held at
critical stages of the study to discuss arising issues and advice on future
progress. The minutes of the three meetings held prior to preparation of
this Report can be found in Appendix Error! Reference source not
found.. The EAG consisted of the Commission, OTIF, the UIC, UNIFE,
the AEIF, the UIP and the CER. In addition, meetings were held with all
of the members of the EAG on a one-to-one basis to obtain their
individual views.
1.4.3 The study considered the entire process of placing vehicles in

service, however the prime focus has been on vehicle identification and
the systems and processes associated with it. The process of technical
approval has been briefly considered for completeness, but this has not
been a major focus of the work. Consideration has also been given to
systems that use vehicle numbers in service where these impact on either
vehicle identification or the way in which vehicle data is or will be held
on registers, databases, etc.
1.4.4 Data gathering and research encompassed investigation of the

existing processes for placing vehicles in service and allocating them
with numbers, the overall legal and legislative context within which these
systems must exist and current reform projects. In the course of this
process, interviews were held with over thirty interested parties and over
one hundred questionnaires were sent out to others, to gather information
and to obtain views on the way forward. The bodies canvassed included
governmental and regulatory bodies, safety bodies, infrastructure
managers, railway undertakings, vehicle owners and leasers,
representative bodies and the rolling stock manufacturing industry.
1.4.5 To highlight the issues the general pan-European research was

supplemented by four detailed case studies in France, Germany, Great
Britain4 and Poland. These were selected in association with the
Commission to provide a reasonable cross section of the issues
encountered in states with differing circumstances and national
approaches. These case studies can be found in Appendices D to G.
1.4.6 Similar issues faced by other transport modes and industries were
also examined to consider if any lessons can be learnt that may be
applicable to the rail industry.
4
Not the United Kingdom, because the railways of Northern Ireland are entirely
separate in organisation, control, orientation and operate in entirely different
circumstances and face quite separate issues.
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1.4.7 The options for change were evaluated against a matrix to

determine which solutions appear to offer the most appropriate ways
forward, this included a cost-benefit analysis. At this stage the views
obtained from interested parties in the consultation process were again
taken into consideration as were those of the EAG.
1.5 Assistance Provided
1.5.1 The Consortium would like to formally record their gratitude to all
those who assisted them in the course of this study, a list of these parties
can be found in Appendix B to this Report.
1.6 Structure of Report
1.6.1 This Report is structured in nine sections as follows:

1. Introduction
2. Current Arrangements
3. Analysis of Existing System
4. Comparisons
5. Industry’s View and Proposals
6. Options for Change
7. Analysis of Options
8. Conclusions
9. Recommendations
1.6.2 Additional information is contained in the Appendices to this

Report, which can be found in a separately bound volume.
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Colin Buchanan and Partners Current Arrangements
2. CURRENT ARRANGEMENTS
2.1 Placing Vehicles in Service
Outline of Process
2.1.1 Current arrangements for placing vehicles into service consist of a

set of linked processes that are undertaken sequentially or in parallel.
These are:
1. commercial concept to construct vehicle(s);
2. establishment of commercial case for vehicle(s);
3. outline design process;
4. development of technical specification;
5. discussions with rail haulier/licensed undertaking;
6. discussions with infrastructure provider(s)/manager;
7. obtain acceptance for vehicle(s) in principle;
8. identify appropriate number series for vehicle(s);
9. design process;
10. formal design approval;
11. let construction contract;
12. construction and supervision of construction;
13. obtain certificate of compliance;
14. number allocated and applied to vehicle, in association with
acceptance into fleet of rail haulier/licensed undertaking
which is prepared to attach it to its fleet;
15. permanent contract for use concluded between owner/keeper1
and rail haulier/licensed undertaking (non-railway owned
vehicles).
A flow chart illustrating this process can be seen in Figure 2.1.
1
The term keeper is used herein to refer to the person or body in legal charge of
the vehicle and its use, which may or not be the owner of the title to the vehicle.
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Figure 2.1 Bringing a Rail Vehicle into Service
Commercial idea originated to meet a need
Commercial case made.

Includes an outline design of the vehicle with a technical
specification.
Implicit or explicit discussion with rail undertaking.
If vehicle is outside normal specifications then discussion
with Infrastructure Manager.
Agreement in principle.
(Vehicle meets standards or is containably outside them)
Vehicle designer looks for appropriate number series. Formal design approval.
Vehicle type may not be catered for. National railway or in future notified
Formal process exists for requesting a number series body approves design of vehicle in
and acceptance in principle by rail undertaking. accordance with standards/TSI.
Tenders issued for construction.

Contract let
Construction process.
Overseen by approved
Conformity check with original design.

Can be performed by manufacturer when it has appropriate
internal procedures and is approved by notified body.
Number painted on body of vehicle.

Manifests acceptance of vehicle into fleet of rail undertaking
and that it is fit to run.
Permanent contract for use with schedule of

vehicles to which it applies
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2.1.2 The process is broadly similar whether a vehicle is owned by a rail

undertaking or by some other entity, but with one significant difference.
Where a rail undertaking is bringing its own vehicle into use then many
of the actions may be internal or implicit. Where a vehicle is not owned
by the rail undertaking itself, but needs to be attached to its fleet, a
"contract for use" is agreed.
2.1.3 For private wagons Article 2 (Acceptance of wagons for

international traffic) of the RIP (Regulations concerning the International
Haulage of Private Owners' Wagons by Rail, Annex II to Appendix B to
the Convention concerning International Carriage by Rail (COTIF) of 9
May 1980) has served as the sole legal basis for technical approval in
international rail traffic. This article stipulates: "To be accepted for
international traffic, wagons shall be registered in the name of a private
party (whether an individual, a firm or a corporate body) by a railway to
whose lines the Uniform Rules apply and shall be marked by that railway
with the distinguishing mark".
2.1.4 The arrangements discussed above relate to an item of hauled

rolling stock for international operation. In the case of vehicles to be
used for purely domestic operation, there can be differences in the final
three steps of this procedure, which are discussed further below.
2.1.5 In the case of traction, whilst the process is essentially the same it
is more complex. Approval to operate traction across borders generally
requires a check of the compliance of the vehicle with each of the
national infrastructures involved. The primary complications being the
differing track:train interfaces for the signalling and control system and
differences in electrification systems, such as pantograph width and
contact strip material as well as voltage. At present no international
standards exist and none are likely until the appropriate TSIs have been
drawn up.
Technical Approval
2.1.6 The process for technical approval of vehicles varies considerably

around Europe, as does the relationship of the party responsible for the
process to the rest of the railway industry and the difference between
approving vehicles for international operation with those restricted to
solely domestic use.
2.1.7 The increasingly complex technical environment of Europe’s

railway system has resulted in vehicle approval becoming more complex,
lengthy and expensive. The significant technical divergence that has
occurred both between and within states has fuelled differing approaches
to vehicle approval. Acceptance testing has become important to
maintain overall system safety, because of the complex interaction
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between sub-systems and need to verify that new equipment interfaces

appropriately with existing equipment. This increasing rigour has also
been driven by the need to move to higher levels of safety in line with
increasing public expectations and the greater performance and
functionality required of assets, placing greater demands on them for safe
and reliable performance in service.
2.1.8 International approvals are considerably simpler for hauled rolling

stock running under the RIC or RIV regime than for traction.
Compliance with common UIC technical specifications for hauled rolling
stock facilitates and mandates mutual acceptance. This process will be
strengthened once the TSIs supersede the UIC leaflets.
2.1.9 The acceptance process for hauled rolling stock is in any case
simpler than for traction, because it is technically simpler and has less
potential for adverse reaction with the infrastructure. For the reasons
discussed above the technical approval process for traction has become
increasingly complex and costly. Particular problems occur with
approval for international operation because of technical diversity and the
lack of agreed international standards. Thalys is an extreme example of
these difficulties and is something that a single independent railway
undertaking would have found impossible to implement.
2.1.10 Liberalisation is changing the responsibility for technical

approval of vehicles. Some states such as Germany, Sweden and the UK
have moved to independent agencies and/or governmental bodies,
whereas in others such as Belgium and France responsibility remains
with the national railway. The introduction of notified bodies under the
interoperability directives can be expected to increase the independence
of those undertaking technical approvals from former national railway
undertakings.
2.1.11 The full and proper implementation of TSIs and notified bodies is
therefore expected to make the technical approval neutral for
manufacturers, railway undertakings and vehicle owners/keepers.
Administrative Aspects
2.1.12 Once a vehicle has been accepted technically it still has to be

issued with a number and formally accepted into traffic.
2.1.13 At present the process of issuing a number permitting normal

domestic use generally remains with the national railway undertaking,
even in states which have liberalised the technical approval process (see
below under Case Studies). There are exceptions to this, however, such
as in Great Britain, where an independent body known as the Rolling
Stock Library issues numbers and places vehicles on the national register.
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2.1.14 If a vehicle is to be placed in normal international use, the

number has to be allocated by a UIC-member railway (with a few
exceptions the national or former national railway) and then attached to
its fleet, this process is discussed below under “Vehicle Numbering
Systems”. There are no automatic rights to this, and at present a UIC
member railway undertaking accepts significant potential liabilities in
accepting a vehicle into its fleet. However, few examples of anti-
competitive behaviour have emerged or UIC-member railways behaving
irresponsibly. Legal challenge to unreasonable refusal may theoretically
be possible.
2.1.15 Other important issues need to be resolved before a vehicle can

enter service. Arrangements need to be made so that the vehicle is
appropriately maintained. The keeper needs to carry sufficient insurance
or other suitable means of underwriting liability so that if damage is
caused to persons or property by a vehicle defect appropriate recompense
can be paid. Finally, a railway undertaking or undertakings have to be
prepared to use the vehicle.
Contracts for Use
2.1.16 If a privately owned vehicle is to be used internationally, under

current arrangements, it is necessary for the keeper to have an
understanding with a UIC rail undertaking to ensure that an appropriate
legal structure is in place, that the vehicles are maintained while in
service and to ensure their acceptance in other states. This is called the
contract for use. The contract provides for undertakings by the keeper to
keep his vehicle safe and by the rail undertaking to provide services, an
agreement on liability to avoid case by case disputes and a structure for
providing services away from the home state. This formula has been
retained in the 1999 COTIF as the CUV, Appendix D to the Convention.
2.1.17 In practice the contract has a number of parts which include:

agreement of the owner/keeper not to modify the vehicle;
a maintenance schedule for the vehicle;
traffic/usage obligations, for example, what happens when the vehicle
has been unloaded.
Under this arrangement the vehicle keeper undertakes or contracts for

maintenance to be performed on its vehicles
2.1.18 This arrangement fits into a chain of responsibility where a

private owner/vehicle keeper is responsible to the rail undertaking for
ensuring that the vehicle is maintained in accordance with agreed
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standards, and the rail undertaking is responsible to the infrastructure

manager for assuring the safety of any train that it operates.
Maintenance
2.1.19 Traditionally verification that vehicles are maintained to

appropriate standards has been dealt with by attaching vehicles to the
fleets of national railway undertakings (or similar), which mutually
recognise each other’s standards and competence. They in turn
agree/dictate maintenance standards and insurance arrangements with/to
vehicle keepers. In general this still occurs, although there is an
increasing recognition in the industry that this is inappropriate in a
liberalised environment.
2.1.20 Under this traditional model the maintenance regime is therefore

mandated or agreed as a part of placing a vehicle into service. The
regime may be reviewed and updated over time as circumstances change.
The enforcement of standards is in the hands of the railway undertaking
to whose fleet the vehicle is attached. In a more open liberalised market
alternative arrangements need to be found to verify that all vehicles in
circulation are maintained to appropriate standards, whatever their origin.
2.1.21 The traditional approach can also mandate where and by whom
maintenance can be undertaken as a part of placing the vehicle into
service. The innovative arrangements now used in a liberalised market in
Britain are discussed below under Case Studies. Although this is only
one possible solution and it does not relate to wagons that are used
internationally.
Insurance
2.1.22 The same process of attaching vehicles to the fleet of a UIC

member railway undertaking is used to provide mutual insurance for
international operations. In essence, for vehicles owned by UIC
members the railway undertaking with possession of the vehicle is
regarded as being responsible for it and therefore liable for both accidents
it causes and damage it sustains. The contract for use provides for a
more complex arrangement for privately owned2 freight wagons in which
UIC railway undertakings in effect pass all the liability for incidents
caused by wagons to owners/keepers and then agree to take it back again
in return for the payment of an indemnity premium. For damage caused
to wagons, the railway undertakings accept liability. The fact that a
vehicle bears a number issued by a railway undertaking is taken as proof
that a contract for use is in place.
2
Including those of non-UIC member railway undertakings attached to the fleet
of a UIC member railway undertaking.
2-6
2.1.23 No standard arrangements exist for tractive stock or carriages that

are either privately owned or are owned by non-UIC member railway
undertakings. These are agreed on an ad hoc basis as part of the process
of placing a vehicle in service.
2.1.24 The clear distinction which the number makes between railway
and privately owned vehicles and the identification of the railway to
which a vehicle is attached allows this system to work effectively at
present.
2.1.25 There are now anomalies in this process. For example, in

Germany, where the national railway undertaking does not require
vehicle keepers to hold insurance and carries this risk itself it has now
been forced to attach vehicles owned by rival railway undertakings to its
fleet and consequently holds a risk without a benefit.
Case Studies
2.1.26 The four country case studies (See Appendices D to G) provide

interesting contrasts in the attitude and progress towards liberalisation
and reform. They also reveal some practical problems that will need to
be resolved in the overall process of placing vehicles into service, if the
EU’s objectives in the rail sector are to be realised and also some of the
inequalities that exist between national and ex-national railway
undertakings and other vehicle keepers.
2.1.27 Of the four France represents the most traditional, with the
technical approval and the administrative activities associated with
placing vehicles into service being entirely in the hands of SNCF. The
infrastructure provider (RFF) stated that it had no involvement in the
process and directed all enquiries to SNCF. The interviews with other
parties revealed no plans to alter current responsibilities; there appears to
some doubt whether this will be compliant with Directive 2001/16/EC.
Technical approval is facilitated in France by construction to “highest
common factor” international railway specifications, with specifications
following the normal UIC model. All privately owned vehicles used on
the national rail system are attached to SNCF’s fleet, which therefore
approves the maintenance arrangements, using facilities approved by
SNCF only. On the other hand SNCF, having accepted the maintenance
arrangements, carries the liability for technical failures of vehicles itself,
although this is understood to be under review.
2.1.28 In Germany and Britain, by contrast, the process of liberalisation

is further advanced, although there are some interesting contrasts
between them. In both States, technical approval of vehicles is
undertaken by completely independent bodies. In Germany by a single
governmental body and in Britain by one of a number of private sector
2-7
Vehicle Approval Bodies. These approaches differ yet both would appear
to require little effort to fit into the notified body framework.
2.1.29 However, the administrative arrangements for placing vehicles in

service differ markedly between Germany and Britain. In the latter, the
vehicle is entered onto a national database and numbers are allocated by
the Rolling Stock Library, an independent body jointly funded by the
whole industry, whose management and operation is contracted out.
Once this happens a vehicle is free to travel anywhere on the national rail
network (subject only to technical restrictions) used or hauled by any
railway undertaking and its owner/keeper has access to all national
railway operating IT systems. The only exception is when vehicles are
allocated with international numbers. Because of the way in which the
UIC system works and restrictions in the Channel Tunnel usage contract,
all British freight vehicles in international service must be attached to
EWS’s fleet and access to international IT systems is obtained is also via
EWS.
2.1.30 In Germany, however, there is no national database and railway

undertakings allocate their own numbers, DBAG has retained control of
the administration of the combined national and international numbering
system and all railway operating IT systems that feed off them.
Accordingly, in practice all other railway undertakings which wish to
either have vehicles hauled on a DB train or internationally need to have
these vehicles attached to the DB fleet. The rights to do this are enforced
by Government, although all those interviewed for this study still found
the process unsatisfactory. Other railway undertakings are free to create
their own registers, allocate their numbers and use their own systems for
vehicles that run on their own trains.
2.1.31 The above cases raise significant issues (and contrasting

approaches) to the confidentiality of systems using vehicle numbers as a
data field. These issues are discussed further on in this Section.
2.1.32 Innovative arrangements have been created in Britain for the

maintenance of vehicles, the maintenance regime being approved by the
technical approval body. Work can be carried out by the vehicle owner,
lessee, maintenance contractor, railway undertaking, or by any
combination of these in varying degrees. In the context of the innovative
safety regime this works well. Insurance is required under British law.
2.1.33 Poland has made great strides in aligning its law and practice to
EU principles. Vehicle approval is by a wholly independent body closely
modelled on the German EBA although in practice there are few
independent railways and most private participation in the industry is by
conventional private wagon owners. The process for allocating numbers
is administered by PKP.
2-8
2.1.34 Maintenance is not prescribed by PKP; owners/keepers are

required to adhere to standards set by the UIC and prescribed by Polish
law, however, provision of overhaul facilities is entirely private.
2.2 Vehicle Numbering Systems
Number Formats
2.2.1 Railway vehicles are currently identified by means of numbers

painted on the sides of vehicles. The differing systems that are currently
used around Europe are discussed below. In essence numbering systems
can be of two types: structured or unstructured.
2.2.2 A structured number is where the number is coded so that it

conveys information about the vehicle, which is used for operational,
administrative or other purposes.
2.2.3 A totally unstructured number is where numbers are allocated “at

random”, generally in chronological order as vehicles are placed on the
register. In most unstructured systems numbers are allocated in blocks,
with specific blocks relating to particular types or batches of vehicles,
although there is no coding of information within the number format. In
some cases this system is sufficiently clear for the number to be regarded
as semi-structured, for example SNCB Class 27 locomotives are
numbered 2701 to 2760 inclusive.
Current European International Systems
Overview
2.2.4 The UIC/OSJD numbering system is used for all vehicles in

international traffic between railway undertakings that are members of
UIC or OSJD3; in practical terms the whole of Europe and large areas of
Asia. The UIC system uses twelve digits. However, although OSJD are
party to the agreements, in practice vehicles involved in international
movements over the former SZD network retain their eight digit Soviet
era numbers.
2.2.5 The UIC system is defined in a set of three UIC leaflets dealing
with the numbering of all rail vehicles. They had their origins in 1971 at
the time when the widespread availability of commercial data processing
equipment began to provide a logic for structured numbers. The
3
Организация Сотрудничества Железных Дорог (Organisation for the Co-
operation of Railways), sometimes also referred to as the OSShD.
2-9
numbering system is consistent across all three UIC leaflets and

consistent with the OSJD system insofar that a vehicle number
unambiguously identifies the vehicle type, its origin (and in most cases
somewhat more) for any vehicle in the geographic area covered.
2.2.6 The system is defined (for UIC railways) in UIC leaflets 438-1
(hauled passenger stock), 438-2 (freight rolling stock) and 438-3 (tractive
stock). Coaches formed into multiple units are commonly numbered in
the tractive stock range, rather than the hauled passenger stock range
defined in the UIC leaflets. Baggage vans, mail vans and car carrying
vehicles used in passenger trains are numbered as passenger stock.
2.2.7 Changes to the system have been proposed by the RICS working
group. Fuller details are provided in Section 5 of this Report. At the
time of writing the UIC had approved the changes for freight vehicles but
in practice none of the changes have yet been implemented. Proposed
changes for passenger vehicles have yet to be ratified and those for
traction renumbering have not yet been presented.
2.2.8 Vehicles used purely for domestic purposes also tend to be

numbered in the international sequence to avoid having two systems in
use. The system makes allowance for this. Under all the systems defined
in all three leaflets the number is structured. The structure is such that
numbers are unique and from the number the type of vehicle and many of
its characteristics may be defined.
Hauled Freight Rolling Stock
2.2.9 The system defined in leaflet 438-2 is structured as follows:

Digits 1 & 2 - exchange regime code
Digits 3 & 4 - railway to which the vehicle is attached
Digits 5 to 8 - vehicle type
Digits 9 to 11 - vehicle serial number within the criteria above
Digit 12 - check digit
These codes are briefly described below.
2.2.10 The regime of use indicates whether a vehicle is owned privately

or by a railway. This information currently determines who has the right
to decide on the next use of the wagon or coach and if there are
restrictions on its use. The regime of use may also indicate if it is
approved for international use or if it is equipped to run on railways with
different gauges. Responsibility for its maintenance and for incidents
caused by a vehicle also depends on its status. Only regimes of use
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covered by the RIC, RIV and their equivalents in OSJD States are
currently provided for; there is no “other” regime.
2.2.11 The regime of use is therefore currently a mixture of commercial,

operating and technical criteria. It distinguishes bogie and axle vehicles,
vehicles equipped to run on non-standard gauge railways and vehicles
fully or partially meeting RIV technical standards (technical criteria). It
currently distinguishes vehicles in railway owned pools (operating
criterion) and it distinguishes privately owned from railway owned
vehicles (commercial/operating criterion; responsibility for its repair and
for incidents caused by a vehicle currently depend on its status). Lastly,
it distinguishes vehicles able to operate internationally from those limited
to domestic traffic (this may be a technical, operating or commercial
criterion).
2.2.12 The railway to which the vehicle is attached is a two-digit code

for the railway undertaking which owns the vehicle or, in the case of a
privately-owned vehicle, to which the vehicle is attached. It normally
indicates where a vehicle is to return to in the absence of orders and
which railway should be contacted in case of an incident or requirement
for maintenance. Only UIC and OSJD railway undertakings are currently
covered. Accordingly, other railway undertakings which wish to use
their wagons internationally have to attach them to the fleet of a
UIC/OSJD member, even if they are in direct competition. In practical
terms it is very difficult, although possible, to operate internationally
without recognised twelve digit numbers.
2.2.13 The vehicle type is a code for the type of vehicle. More than one
four-digit code is necessary for populous vehicle types to allow all of
them to receive unique serial numbers. This part of the number allows
vehicle ordering systems to specify the vehicles that are required to meet
traffic demands. Staff become familiar with vehicle numbering
sequences and the coding system is a real aid to ground level operations.
In the case of RIV wagons, wagon type is a factor in the process of
determining hire charges. Many railway undertakings and infrastructure
managers use the vehicle number to drive other railway computer
systems, for example to check that technical data input is consistent with
the declared vehicle type.
2.2.14 Wagon type is also identified by a “literal” which is composed of

up to twelve letters, possibly suffixed with a number. The letters have
standard meanings as defined in leaflet 438-2 (for example, ss means
able to run at 120 km/h) and for railway owned wagons they are marked
on the vehicle. The codes are intended to differentiate wagons in a
meaningful way; indicating the capacity and length and speed
characteristics and the types of fittings. These letter codes are widely
used in the industry and by customers to identify vehicles for loading.
One or more four digit number series is identified with each literal. More
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than one four-digit code is necessary for populous vehicle types to allow
all of them to receive unique serial numbers; these numeric type codes
are normally but not necessarily contiguous.
2.2.15 The serial number is simply the unique serial number identifier,
within the vehicle type, for the vehicle itself.
Photograph showing the twelve digit number and literal
2.2.16 The existing arrangements require numbers to be recorded

frequently by manual means. To reduce the likelihood of errors when
2-12
these numbers are input into systems or manually transcribed, the current
system incorporates a check digit as the twelfth character of the number.
The mechanism for the calculation of the check digit is defined in UIC
leaflet 913; it is designed to detect incorrect digits and also transposition
of correct digits. It uses the "modulus 11" system4.
2.2.17 The Photograph above provides an example of this numbering

system and the other information displayed on the vehicle.
Hauled Passenger Rolling Stock
2.2.18 The system defined in leaflet 438-1 is similar in format to that for
hauled freight rolling stock: twelve digits divided into six groups, two
digits for the operating regime, two digits for the railway to which the
vehicle is attached, two groups each of two digits for the operating and
technical characteristics of the vehicle, three digits for the serial number
of the vehicle within the category and lastly a single check digit. These
fields are dealt with individually below.
2.2.19 The operating regime field can take values 50 to 79 (thus not
duplicating the freight or traction numbering sequence). With two
exceptions it only reflects technical characteristics. The technical criteria
which determine the choice of a code include whether a vehicle is:
• adaptable to run on different gauges (and which gauges);
• air conditioned or not;
• pressure tight;
• not a passenger vehicle; and
• whether it is a service vehicle.
Further criteria include whether vehicles are limited to domestic traffic
and whether they are operated in joint pools (which affects the
“compensation” arrangements). The allocation of numerical values is as
consistent as possible but the characteristics are not as immediately
obvious from the code as is the case for freight vehicles.
2.2.20 The code for the railway to which the vehicle is attached is
identical to that for freight vehicles.
4
In this process the digits in the odd numbered positions of the twelve digit number are
summed ignoring carrying over of second order of magnitude terms. The digits of the
first five even numbered positions of the twelve digit number are summed after
multiplying each by two, ignoring second order of magnitude terms at each stage (and
subsequently). The two numbers derived are then added together and subtracted from
11; the result provides the check digit.
2-13
2.2.21 The first digit of the operating characteristics field indicates the
basic type of vehicle (sleeping car, First Class, etc), values are provided
for vehicles owned by others5 and for vehicles of “special design”. The
second digit essentially indicates the size of the vehicle in terms of its
carrying capacity. In the case of privately owned vehicles and specially
designed vehicles, this second digit provides more information about the
type. Staff become sufficiently familiar with the coding structure to
interpret the type of vehicle from the number.
2.2.22 The technical characteristics field indicates the speed regime of

the vehicle and the train-lines (for heating and services) with which it is
equipped. As heating and air-conditioning equipment, for example,
become more standardised, many of the code values will become
redundant and it will be possible to use this section to indicate other
parameters.
2.2.23 The remaining fields are identical to those for hauled freight
rolling stock.
Traction
2.2.24 The numbering system for locomotives and other tractive units
under UIC leaflet 438-3 is more tentative than those defined in the
parallel leaflets 438-1 and 438-2. Coaches and wagons require a
complex coding structure to identify type, return arrangements, terms for
payment for use etc. None of this is necessary for tractive stock because
of limited interoperation in traditional European operation. Historically
international operation of traction in Europe has been both rare and
subject to highly specific agreements.
2.2.25 In contrast to leaflets 438-1 and 438-2, few railway undertakings

currently follow the requirements of leaflet 438-3 completely.
2.2.26 The system defined in leaflet 438-3 allows railway undertakings

to use a “national number” composed of six or seven digits and many
railway undertakings use this in effect as the sole vehicle number.
Otherwise the structure is structured as follows:
Digits 1 - powered vehicle indicator (always 9)
Digits 2 - check digit
Digits 3 & 4 - railway to which the vehicle is attached
Digits 5 - differentiation between locomotive and unit
5
Vehicles attached to UIC member railways fleets that are owned by non-UIC railways
and private owners.
2-14
Digits 6 to 11 - running number (unstructured)

Digit 12 - check digit
2.2.27 The second check digit allows the last seven digits of the number
at the twelve digit level to be the same as the number at the last seven
digit level.
2.2.28 A distinction is made between locomotives and power-cars in the

coding structure but otherwise railway undertakings are invited to
number tractive units how they wish within a twelve digit system in
which in practice only six plus a check digit are active. The full twelve-
digit system maintains the same structure of owning railway and check
digit is preserved.
Other International Systems Used in Europe
2.2.29 As noted above the broad gauge railways of the CIS still use
Soviet era eight digit numbers. Vehicles are numbered in series;
accordingly CIS rail staff can interpret vehicle characteristics from
numbers. CIS computer systems continue to be run by RZD (Russian
Railways) on behalf of all the CIS states but changes have been made to
accept twelve digit numbers. The CIS community is not prepared to
embark on renumbering however unless it can be convinced there will be
stability in any pan-European system adopted.
National/Domestic Systems
2.2.30 Although the UIC international system is in widespread use

throughout Europe there are numerous systems used within individual
states. Some of these are national systems whereas others are in more
restricted use, for example by new open access railway undertakings.
This Report considers only the permitted systems for vehicles that are
commonly used on the national network.
2.2.31 The majority of the systems used are entirely numeric. However
some systems, for example that most commonly used for Swedish
traction, are alpha-numeric. Other systems are officially alpha-numeric
but only display only the numeric part on the rolling stock, as for
example for Finnish traction.
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2.2.32 The current numbering systems used in each state, for vehicles
that are not used internationally, are shown in Table 2.1.
Table 2.1 – Current Numbering Systems
Numbering System
Locomotives Multiple Hauled Hauled
State Units Passenger Freight
Vehicles Vehicles
Semi-struct 4
Semi-
digit (dmu)/
Belgium structured 4 UIC 438-1 UIC 438-2
unstructured 3
digit
digit (emu)
Denmark Various1 Various Various Various
Germany Various2 Various2 Various2 Various2
Structured: Structured:
Spain UIC 438-1 UIC 438-2
3+3+1 digit 3+3+1 digit
Semi-struct, 6 Struct: 1 letter
France UIC 438-1 UIC 438-2
digit + 2 to 5 digit
Semi-struct 3
Greece UIC 438-3³ UIC 438-1 UIC 438-2
digit
Unstructured: Unstructured: Unstructured: Unstructured:
Ireland
3 digit 4 digit 4 digit 5 or 6 digit
Various struct Various struct
Italy Various Various
alphanumeric4 alphanumeric4
Semi-struct 3 Semi-struct 4
Luxembourg UIC 438-1 UIC 438-2
to 4 digit digit
The Netherlands UIC 438-1 UIC 438-2
to 4 digit to 4 digit
Structured: Structured:
Austria UIC 438-1 UIC 438-2
4+3+1 digit 4+3+1 digit
Portugal UIC 438-1 UIC 438-2
digit digit
5+1 digit/2
Semi-struct 2 Unstructured: Unstructured:
Finland letter + 6+1
to 4 digit 4 digit 5 digit
digit
Sweden Various5 Various Various UIC 438-2
Unstructured/
United Kingdom Structured: Structured: Unstructured:
Semi-struct:
(Great Britain) 2+3 digit 3+3 digit 4 to 6 digit
6 digit
United Kingdom Unstructured: Unstructured: Unstructured:
n/a
(N. Ireland) 3 digit 4 digit 2 or 3 digit
Czech Republic UIC 438-3 UIC 438-3 UIC 438-1 UIC 438-2
Estonia Various Various Various Various
Latvia SZD6 SZD7 SZD SZD
Lithuania SZD6 SZD7 SZD SZD
Hungary Struct: 1 letter UIC 438-3/3 UIC 438-1 UIC 438-2
2-16
Numbering System
Locomotives Multiple Hauled Hauled
State Units Passenger Freight
Vehicles Vehicles
+ 4+3 digit/3 or 4 letter + 3
alphanumeric digit
+ 3 to 4 digit
Structured: 2 Structured: 2
Poland letter + 3 digit letter + 2 digit UIC 438-1 UIC 438-2
+ 3 digit + 4 digit
Slovakia UIC 438-3 UIC 438-3 UIC 438-1 UIC 438-2
Slovenia 3+3 digit 3+3 digit UIC 438-1 UIC 438-2
Switzerland Various8 Various Various8 UIC 438-2
Structured: 2
Structured: 2
Norway letters + 3 to 4 UIC 438-2
+ 3 digit
digits
Bulgaria 2+3 digit 2+3 digit UIC 438-1 UIC 438-2
Romania 2+4+1 digit 2+4+1 digit UIC 438-1 UIC 438-2
CIS SZD6 SZD7 SZD SZD
Notes: 1. DSB use a structured 2 letter + 3 or 4 digit alpha-numeric system; other
railways also use alpha-numeric systems.
2. DBAG use UIC System (438-1, 438-2 and 438-3).
3. Renumbering from 1 letter + 3 digit system has just commenced.
4. For locomotives, FS use 1 letter + 3 or 4 digits + 3 digits; for multiple
units they use 2 or 3 letters + 3 + 4 digits.
5. SJ constituents use structured 2 letter/3 alpha-numeric/3 letter 3 digit + 3
or 4 digit system.
6. Structured: 1 digit + 1 to 3 alphanumeric + 1 to 2 digit + 1 alphanumeric
7. Structured: 2 alphanumeric + 1 to 2 digit + 1 to 2 alphanumeric.
8. SBB are moving to UIC 438-3 for locomotives and use 438-3 for hauled
passenger vehicles, as do BLS.
2.2.33 It can be seen that in the case of most states the system used for
hauled rolling stock in domestic service is identical to the current
international one. There are, however, some significant exceptions,
particularly the isolated networks of the British Isles (Ireland and the
UK) and for independent and open access operators in Germany for stock
that is not interchanged with DBAG’s railway undertakings.
2.2.34 In the case of traction the system is rather more mixed, with a
disparate variety of systems in use, some of which comply with the rather
loose requirements of UIC leaflet 438-3 but many do not. Furthermore,
in a significant number of states the system used for locomotives differs
from that used for multiple units. There are even some states which have
more than one system in use.
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Case Studies
2.2.35 The case studies illustrate the sharp distinction between traction
and hauled rolling stock in the degree of commonality between the
numbering systems used in the four countries.
2.2.36 Naturally all four examples use the systems described in UIC
leaflets 438-1 and 438-2 for rolling stock in international use. The same
system is used for all stock in domestic service on the national rail
network in France and Poland. In Germany, as noted above the system is
used by DBAG and AAE rolling stock (the vast majority of national
rolling stock, at present) but it is not available to other railway
undertakings unless they attach their wagons to its fleet, they therefore
have their own systems and number series. In Britain historic isolation
means that a unique national system of unstructured numbers is used It is
interesting that solutions have been found to enable this to work quite
satisfactorily alongside the international numbering system in IT systems,
etc. However, this is aided by the limited range of international vehicles
that can run in Britain, due to technical differences.
2.2.37 The system used for traction varies between the four States. The
only common feature is that all of the systems used are structured.
French and DBAG locomotives use the system described in UIC leaflets
438-3. Although French multiple units use a unique national system and
other German railway undertakings use their own systems. Unique
national systems are used in Britain and Poland. The Polish system is as
an example of one of Europe’s alphanumeric numbering systems.
2.2.38 The use of an unstructured system for hauled rolling stock and
structured systems for traction in Great Britain provided an opportunity
to compare the operation of two systems side-by-side. The first point is
that vehicles with unstructured running numbers are rarely renumbered
(although this does occur, for example, when a vehicle transfers from the
revenue earning fleet to railway internal use). In contrast, it is more
common to renumber traction, which has structured numbers, for
example, when it is modified into a different sub-class, or even into an
entirely new class, for example, some Class 47s into more powerful
rebuilt Class 57 locomotives. The second point is that intensive
operation and close control of wagon diagramming is possible with
unstructured numbers if the operating systems used are designed around
them.
2.3 Railway Coding Systems
2.3.1 Railway coding systems have a close relationship with railway

data systems. Information technology requires coding systems and the
2-18
coding only makes sense when there is capacity to process it. It is not
surprising therefore that railway coding dates from the period when
commercial computer systems began to be widely available. The
UIC/OSJD railway coding system dates from 1 January 1971 when the
standard system of numbering vehicles was introduced. Whilst the
primary purpose was vehicle numbering, the coding system was intended
to be all-purpose and thus to cover operating, commercial, financial,
information technology, etc, purposes.
2.3.2 Railway codes are used as an indication of fleet ownership of

vehicles, on tickets to show issuing railway undertaking, on consignment
notes to identify the stations, in data messages to identify recipient and
for many other purposes. These ambitious objectives caused a certain
amount of ad-hoc allocation of codes. The codes were needed for
example not only for a railway undertaking but also for the relevant
country and currency, extra codes were therefore necessary for currencies
without a railway, such as the US dollar or SDR6.
2.3.3 Railway undertakings are allocated two digit codes from 01 to 99.
Each of the mainline UIC/OSJD members possesses a code and indeed
some quite small railway undertakings with a vehicle fleet (such as the
Aarus Alstätter Eisenbahn) have codes. The minor Swiss railways share
a code however. Originally all UIC member railways in Europe, Asia
and North Africa had a code, even where there was no sensible exchange
of traffic (for example, Japan). Given the all purpose nature of the codes,
shipping lines (involved in tickets and revenue sharing) also needed
codes. The allocation of the codes has traditionally been determined by
the railway’s RIV status (non-member, full member, partial member etc).
For some long-forgotten reason, initially only codes in which the second
digit was equal to or less than the first were allocated (for example, 88
was allocated, but not 89). This coding structure is defined in UIC leaflet
920-1.
2.3.4 This system worked well for some twenty years during which
other organisations developed standard coding structures (for example
ISO 3166 for currency codes, ISO 4127 for country codes). However, at
the beginning of the 1990s it became clear that the range of 99 available
codes would no longer suffice. The political changes in the Balkans and
former Soviet Union were spawning new railways and at the same time
there was a need to reflect the restructuring of a number of railways into
operators and infrastructure managers together with a need to allow for
open access.
2.3.5 Ad hoc measures have been adopted to provide short-term

solutions to the shortage of numbers in the current coding system: ISO
6
Special Drawing Rights: an international reserve asset valued on the basis of a
basket of key currencies.
2-19
three letter currency codes have allowed UIC codes simply required for
currencies to be liberated, combinations such as 89 are now used and a
few railway undertakings (such as the Budapest Local Railway BHEV)
have been deprived of their code. Separate series for the African and
American railways have also been set up.
2.4 Relevant EU Directives
Overview
2.4.1 In the context of the study the infrastructure package comprising

Directives 2001/12/EC, 2001/13/EC and 2001/14/EC and the
interoperability Directives 2001/16/EC and 96/48/EC are the most
pertinent pieces of EU legislation. These Directives built on earlier
legislation and sought to remove many of the technical, legal, operational
and administrative barriers to a functioning Single Market for rail
services. This sub-section describes the main relevant requirements and
objectives of these Directives and assesses implications of these for the
study (Directive 96/48/EC is not specifically discussed, since the
requirement for a vehicle database emerged in Directive 2001/16/EC).
Directive 2001/12/EC
2.4.2 One of the main requirements of the Directive is to clarify the

separation of accounts between infrastructure managers and rail
undertakings by revising the requirements of Article 6 of Directive
91/440/EEC. While this has no significant implications for this study in
itself, one of the factors underlying the separation of railway undertaking
and infrastructure manager accounts is the need to clarify and attribute
costs, and where there is a monopoly situation, ensure that charges for
services are appropriate.
2.4.3 One of the major elements of the Directive is the extension of

access rights for individual railway undertakings. First to operate
international rail freight services over a defined network until 2008 and
second, after that date over the whole of the EU rail infrastructure. The
requirements in the Directive relating to access rights are contained in
Article 10; in the context of this study particular note should be made of
the requirements of paragraphs 1, 2, 3, 5, 6 and 8, which are discussed
below.
2.4.4 Paragraphs 1 to 3 indicate the clear intention to create access rights

to railway infrastructure and that this access must be equitable. For this
to be achieved, it is essential that other operational impediments do not
exist. A vehicle identification system is essential for the free operation of
2-20
services and exchange of vehicles and therefore these paragraphs imply

the need to ensure that the vehicle identification system does not impede
the use of the access rights created.
2.4.5 Paragraph 5 requires a railway undertaking using the access rights

created under paragraphs 1 to 3 to conclude the necessary agreements
with the relevant infrastructure managers. Infrastructure managers will
wish to ensure the compatibility of rolling stock with their infrastructure
and these characteristics need to be accessible through the vehicle
identifier. In view of this it is important that infrastructure managers
must also find the identification system acceptable and that it must
adequately satisfy their needs
2.4.6 Paragraph 6 requires that terminals and ports must also accept
freight rolling stock on their rail infrastructure from railway undertakings
using the access rights created by paragraphs 1 to 3. The vehicle
identifiers are therefore likely to be important to them and thus
consideration needs to be given to their interfaces with any system.
2.4.7 Article (10a) describes the Trans European Rail Freight Network,
which defines the minimum network on which a single railway
undertaking will have the right to offer international rail freight services,
and therefore the minimum area over which the identification system
must be able to accommodate additional railway undertakings. However,
the fact that the feeder lines can be almost anywhere means that in
practice the vehicle identification system needs to be able to satisfy the
requirements of Article 10 over virtually the entire European rail network
from March 2003.
2.4.8 The Directive prohibits (in Annex II) railway undertakings from
certain functions that are defined as “essential functions”, because they
determine access to the rail infrastructure. These are defined as follows:
“preparation and decision making related to the licensing of railway
undertakings including granting of individual licenses”;
“decision making related to the path allocation including both the
definition and the assessment of availability and the allocation of
individual train paths”:
“decision making related to infrastructure charging”; and
“monitoring observance of public service obligations required in the
provision of certain services”.
It is of note that none of these explicitly covers the vehicle identification
system and therefore do not prevent a railway undertaking from
performing this function; however please refer to the legal analysis
below.
2-21
2.4.9 This Directive makes a number of technical amendments to the

requirements of Directive 95/18, which relates to a Community licence
for a railway undertaking. The Directive does not appear to contain any
elements that are of relevance to this Study.
2.4.10 This Directive addresses the areas of railway infrastructure

charges and capacity allocation. However, in so doing, it impinges on a
number of other areas.
2.4.11 The rights of access to the infrastructure are defined in Article 3.

One of the conditions is likely to be an appropriate identifier on the
vehicle to assure the infrastructure manager of its conformity with the
infrastructure and of the identity of its keeper. The absence of such an
identifier is likely to result in the infrastructure manager imposing more
onerous conditions on the use of the vehicle. In setting out the nature of
the infrastructure available, the infrastructure manager should ensure that
it is relatively straightforward for a railway undertaking to assess the
conformity of its vehicles with the infrastructure.
2.4.12 Article 5 and Annex II lists the services that should be made
available to railway undertakings, amongst these, point 1(e) of Annex II
is relevant to the study. This requirement appears to impose an
obligation on the infrastructure manager to verify that the rolling stock
can operate over the route requested and that this verification is included
in the minimum access charge for the use of the infrastructure.
2.4.13 Article 7(3) requires charges for the minimum access package
and track access to service facilities to be set at the cost that is directly
incurred as a result of operating the train service. Depending on how
strictly this is interpreted, or even as a result of their own interest in
reducing costs, infrastructure managers could take a greater interest in the
wear caused by different types of vehicles and set charges to take account
of this. This would require use of the vehicle identifier in some way.
2.4.14 The procedures for certifying that a sub system is interoperable

(by notified bodies) are defined in Article 18 and the verification
procedure is described in Annex VI. This includes the following
requirements: “verification of a subsystem7 shall begin at the design
stage and cover the entire manufacturing period through to the
7
An item of rolling stock in this instance.
2-22
acceptance stage before the subsystem is put into service. It shall also
cover verification of the interfaces of the subsystem in question with the
system into which it is incorporated” and “the technical file … must
contain all the necessary documents relating to the characteristics of the
subsystem and, where appropriate, all the documents certifying
conformity of the interoperability constituents. It should also contain all
the elements relating to the conditions and limits of use and to the
instructions concerning servicing, constant or routine monitoring,
adjustment and maintenance”. This therefore places obligations both on
the process of placing a vehicle in service and implicitly on either the
vehicle identification system or the database within which vehicle data is
held and requires its exchange for interoperability.
2.4.15 A further implication is that there is a clear linkage between the

TSI for freight telematics, the approval and interoperability information
generated by notified bodies and the vehicle identification system. The
Directive therefore obliges “joined up thinking”. It should be further
noted that, under Article 23, the freight telematics TSI is listed as a
priority action, to be drawn up no later than 20 April 2004.
2.4.16 Article 24 is crucial in the context of this study: it requires the

establishment of registers of rolling stock and infrastructure. Specifically
it requires that:
1. “The Member States shall ensure that registers of

infrastructure and of rolling stock are published and updated
annually. Those registers shall indicate the main features of
each subsystem or part subsystem involved (e.g. the basic
parameters) and their correlation with the features laid down
by the applicable TSIs To that end, each TSI shall indicate
precisely which information must be included in the registers
of infrastructure and of rolling stock.
2. A copy of those registers shall be sent to the Member States

concerned and to the joint representative body and shall be
made available to the public.”
The rolling stock register needs to contain specific and accurate

information in the required level of detail. The TSIs must each specify
the information to be included in the register. It is clear that the
requirement for registers only to be updated annually would make them
insufficient for use for operational purposes where information would
need to be completely up to date. No such register currently exists.
2.4.17 Annex II lists the subsystems comprising the rail system. Section
2.5 and in particular part b) cover vehicle identification.
2-23
2.4.18 Annex III, section 2.7.1 lists “the essential requirements for
telematics applications”; this has important requirements for vehicle
identification and its associated databases by requiring that: “databases,
software and data communication protocols are developed in a manner
allowing maximum data interchange between different applications and
operators, excluding confidential commercial data” and “easy access to
the information for users”.
2.5 Legal Obligations
Overview
2.5.1 This sub section of the Report is an inventory of the obligations to

register rolling stock under EC law, COTIF and Unidroit. It goes on to
briefly list the legal requirements under competition law that have to be
met by a railway identification and registration system. It primarily
considers the legislation currently in force and that, which has been
agreed internationally8, but it also pays attention to the changes that the
adoption of the new Railway Package (RWP-II) will bring about. RWP
II is discussed in more detail in Section 5.
EU Legislation
Introduction
2.5.2 EU railway legislation contains several obligations in the field of

registration, numbering and information provision. However, the
legislation does not invariably make it clear who has to register what, in
which way, when and on behalf of whom. This sub-section is confined
to the provisions that currently contain an obligation to register certain
data.
2.5.3 At present only Directive 2001/16/EC contains an obligation for

Member States to create a rolling stock register. It lays down rules for
interoperability on the Trans-European conventional network. After
amendment by RWP-II the scope of Directive 2001/16/EC will change
and the entire European conventional rail system will come under its
provisions. RWP-II will also change the Directive on the interoperability
of the trans-European high speed network (Directive 96/48/EC). The
8
COTIF 1980 is in force; however, the changes brought by the 1999 revision,
which are primarily discussed herein, are expected to come into force in 2004.
The UNIDROIT convention has been signed but requires ratifications to come
into force.
2-24
same obligations on the registration of the rolling stock will be included

in Directive 96/48/EC (see “Commission proposals in RWP-II”).
2.5.4 In terms of scope the Directive, at present, obliges Member States

to keep (with a parallel infrastructure register) a register of rolling stock9.
This rolling stock register covers all stock that is likely to travel on all or
part of the conventional rail network for international as well as for
national/domestic use10. There are two important requirements that this
must include:
1. the main features of the rolling stock (“the basic
parameters”); and
2. their compliance (or otherwise) with the TSIs.
2.5.5 Each TSI will have to indicate precisely what information must be
included in the register11. The basic parameters of conventional rolling
stock will be determined by the “Article 21 committee”12.
2.5.6 The Directive requires that the register be published and updated
annually. A copy of the register has to be made available to the public
and has to be sent to the Member States concerned and the AEIF.
2.5.7 The wording of the Directive does not state clearly who will
manage the rolling stock register. Unlike the provisions on the national
register (see Commission proposals in RWP-II) the Directive does not
indicate either that the register relates to “vehicles put into service” or
that the manager of the register has to be an independent body (these
requirements should be contrasted with Article 14 paragraph 4 of the
directives as proposed by RWP-II).
2.5.8 A possibility could therefore be to register vehicles at an earlier

phase than “putting into service” (for example directly after the
assessment by a notified body) and by a different body (for example the
notified bodies, the railway undertakings, the contracting entity, or the
infrastructure manager).
International Legal Obligations
Unidroit Convention on International Interests in Mobile Equipment
2.5.9 Under the aegis of Unidroit13 the Convention on International

Interests in Mobile Equipment has been concluded (Cape Town, 2001).
9
Required under Article 24.
10
For a complete definition see Annex I point 2.
11
Article 24 paragraph 1
12
See Article 23 paragraph 3 of Directive 01/16/EC.
2-25
The “Joint Unidroit/OTIF Committee of governmental experts” is

preparing a Protocol to this Treaty which specifically covers railway
rolling stock (the “Rail Protocol”).
2.5.10 It is anticipated that Unidroit/OTIF will convene a diplomatic

conference to complete and sign the Rail Protocol in late 2004 or in
2005. The Convention makes provision for the possibility of the
Regional Economic Integration Organisations, such as the European
Union, to be a party to the Convention and analogous provisions are
contained in the draft Rail Protocol. The Commission was represented at
the Convention in Cape Town and expects shortly to receive a mandate
to sign the Treaty. It is understood that the Commission will request a
mandate in due course to start negotiations in respect of the draft Rail
Protocol.
2.5.11 The aim of the Convention is to provide creditor protection at an

international level, protecting the property rights (defined as
“international interests”) of a vendor selling an asset with the reservation
of title, of a lessor leasing an asset to a third party and of a financier
financing an asset by the way of a loan agreement and taking an interest
in the rolling stock as collateral14. The asset must be “uniquely
identifiable”15. A holder of an international interest will be able to
register its interest in an international registry16 which, with minor
exceptions, will secure its priority over later registered interests and
international interests which are not registered. The holder of the
international interest will be granted certain specific remedies to
repossess the asset concerned in case of default or bankruptcy.
2.5.12 Operation of various aspects of the Convention, including the

international registry, will be supervised by a Supervisory Authority,
which it is understood will probably be different for each transport mode.
The Supervisory Authority is responsible for appointing and dismissing a
Registrar who will operate and administer the International Registry17.
The draft Rail Protocol envisages that OTIF will act as the Supervisory
Authority18 in the rail sector.
2.5.13 The draft Rail Protocol creates the possibility that a designated
entity may be stipulated by the Contracting States in a closed
geographical area to act as an access portal to the International
13
The International Institute for the Unification of Private Law, an
intergovernmental organisation based in Roma.
14
Article 2 of the Convention
15
ibid
16
Article 16 of the Convention.
17
18
Article XI
2-26
Registry19. This entity could be the ERA for example. The unique
identification criteria proposed by such a designated entity would be
accepted by the Supervisory Authority if they were consistent with the
operation of the international registry and the intent of the Rail Protocol.
There is also unresolved discussion of certain contracting States being
able to designate an autonomous registry authority which would then be
outside the jurisdiction of the Supervisory Authority and would not be
part of the international registry.20
2.5.14 The Convention leaves it to each industry Protocol to determine

what data should be registered at the international registry and the
appropriate unique identification criteria. The draft Rail Protocol leaves
it to the Supervisory Authority to prescribe in regulations “such
identification criteria as will enable an item of railway rolling stock to be
uniquely identified” and contemplates that different criteria may be
prescribed for different classes of railway vehicle21.
2.5.15 The International Registry has to be operated and administered

on a twenty-four hour basis22. It is proposed that all registration and
searches will be conducted through the Internet. Any designated entity
has to operate “during working hours in its territory”23.
2.5.16 Under the Treaty “any person” is entitled access to the

information registered at the international registry and will receive a
search certificate24. The draft Rail Protocol prescribes that the
Supervisory Authority will establish the search criteria25.
COTIF
2.5.17 If the EC becomes a contracting party to COTIF it will be bound

to its provisions, and its appendices insofar as it does not derogate from
those that allow derogation. Any rules of Community law will have to be
in conformity with COTIF and should not jeopardise in any way its
further development.
2.5.18 Conversely the EC is not allowed to bind itself internationally to

rules that might be contrary to the EC Treaty (those with particular
relevance to this study are Articles 81 and 82). A conflict with the EC
Treaty would make it legally impossible to transpose international
obligations into the European legal order, as the EC Treaty has
19
Article XIII paragraph 2.
20
Article XIV
21
Article V(1)
22
23
24
25
Article XV paragraph 2.
2-27
precedence over EC legislation. The EU Member States and the

European Commission will have to take account of this fact when
developing further COTIF rules through the COTIF committees (see
below).
2.5.19 Article 3 of the COTIF on international co-operation should also

be noted, although in the view of the Consortium this merely accepts that
the Community has certain powers in the area of rail policy. However,
Article 3 does not stop the EC or Member States needing to use
Article 42 on declarations and reservations if they choose not to apply
certain treaty obligations. If a Member State ratifies COTIF (and COTIF
comes into force) and no Article 42-declaration is made, when the
COTIF comes into force it will be bound to COTIF obligations, Article 3
does not change that.
2.5.20 The COTIF permits the option of not applying certain treaty
obligations, including parts of the appendices. Article 42 covers that
possibility. Therefore, in principle the EC could choose not to participate
in the international register discussed below. Nevertheless when signing
the new COTIF in Vilnius in 1999 no EU Member State expressed any
reservation to any of the appendices.
2.5.21 As long as the EC is not a party to the COTIF, this could cause a
complicated legal situation26. Member States (which have individual
membership of the COTIF and are therefore bound by COTIF rules)
could be faced with contradictory obligations if EC legislation deviates
from the international rules or if international rules conflict with the EC
Treaty. It is therefore important that Member States consider their EU
obligations when ratifying the new COTIF and/or perhaps make use of
the possibilities that Article 42 of COTIF offers. In practice, however,
the policy co-ordination arrangements within the EU (if Member States
reach consensus) and the fact that, if voting en-bloc, the EU States form a
substantial minority, mean that the EU will be able to have a strong
influence on COTIF policy. Emphatically so if candidate States are
taken into account.
2.5.22 A greater risk may be if the EC decides to join but to derogate

from the technical appendices. In doing so it would be denied a voice in
drawing them up. This could leave the situation in which COTIF
technical standards apply in one part of Europe and EU standards in
another, without any guarantee that they would be the same.
2.5.23 The scope of COTIF is broad: to promote, improve and facilitate

international railway transport, consequently the scope of Appendix F
(APTU) and Appendix G (“Uniform Rules concerning the Technical
26
The Commission announced a policy of joining COTIF in its Communication
Towards an integrated European railway area in January 2002.
2-28
Admission of Railway Material used in International Traffic”, otherwise

known as the ATMF) is confined to railway equipment to be used “in
international traffic”.
2.5.24 Article 13 of Appendix G requires a data bank to be set up under

the responsibility of OTIF. The vehicle data bank will contain
information about railway vehicles “admitted to circulation or use in
international traffic”. Paragraph 3 makes it clear that the sole objective
of the data bank is to provide evidence that the vehicle has been
technically approved (for the infrastructure in question). The actually
data necessary for this purpose are to be defined by the Committee of
Technical Experts but it might be surmised that very little data is
necessary for this somewhat limited purpose. It is not self evident for
example that vehicle weight, length or braking characteristics are a
necessary part of this information.
2.5.25 The “data necessary” for the purposes of the ATMF must be
transmitted by “the competent authorities” to OTIF. In all cases the
competent authorities will have to provide notice of the following
necessary data:
withdrawals from service;
official immobilisations (sic);
withdrawals of admission to operation (sic); and
modifications to a vehicle which derogate from the admitted type of
the construction.
2.5.26 The logic of the data bank is that it acts as a list of approved
vehicles to support the requirement that these must be accepted in
international traffic. It is not clear if supplementary information (for
example, whether the maintenance-due date has been exceeded) will be
held.
2.5.27 COTIF specifies that the only data that may be stored is that
which the Committee of Technical Experts (CTE) decides is necessary.
Indeed the text of the ATMF states that:
the competent authorities have to send the necessary data;
the CTE will decide which data has to be sent;
the data will include that stated by the CTE
Accordingly CTE can only put an obligation on the authorities to send
other data if it is “necessary” (for keeping a database on approved
vehicles). The Consortium therefore considers that under the strict
wording of the COTIF the necessary data cannot include all of the
information required by other legal and operational requirements.
2-29
2.5.28 This would seem to exclude both the possibility of a “variable

geometry” file holding additional data from those states able to provide
it, as well as the extension of the file to include further data that is useful
for operational and safety purposes. Two hierarchical files could
however satisfy this requirement, the first holding COTIF administrative
data on technical approval and the second data for day to day use.
2.5.29 It should be noted that the view of OTIF is that Article 13

paragraph 2 of the ATMF only specifies the minimum requirements and
that the holding of additional data is my no means excluded. Indeed
OTIF (through the CTE) is obviously prepared to require additional data
to be provided. Assurances provided by OTIF to the Consortium during
the course of the Study suggest that a pragmatic attitude will in fact be
taken. Accordingly extension of the file to include further data that is
useful for operational and safety purposes can be envisaged.
2.5.30 The wording of Appendix G does not include any stipulation

about the frequency with which the register will be updated. It appears
that this aspect still has to be worked out. The Appendix places
responsibility for the international register with OTIF, OTIF themselves
however have made it clear that it is a task which they would seek to
delegate.
2.5.31 Access to the register is permitted under Article 13 paragraph 4

Appendix G for the following:
the Contracting States;
railway undertakings engaged in international traffic and having their
place of business in a contracting state;
infrastructure managers having their place of business in a
Contracting State and on whose infrastructure international traffic
runs;
manufacturers of vehicles, but only as it concerns their vehicles;
keepers of railway vehicles but only as it concerns their vehicles.
Another committee (the Revision Committee) will decide what data these
bodies will have access to and under what conditions27.
The Requirements of Competition Law
2.5.32 In considering new legislation, the Commission and Member

States have to take into consideration the legal restrictions imposed by
Articles 81 and 82 of the EC Treaty and Regulation 1017/68 (as
amended) in the field of competition law. In short, these restrictions
27
Article 13 paragraph 5 Appendix G.
2-30
prohibit abuse of a dominant position and anti-competitive agreements

between competitors.
2.5.33 When considering abuse of a dominant position, precautions have

to be taken to prevent measures that would enable an undertaking to
abuse its dominant position. This could for example be the case if an
established railway undertaking was allowed to manage the register with
the consequent risk that it would favour its own undertaking to the
detriment of competitors. Another risk could arise when giving railway
undertakings unlimited access to vehicle information. This might enable
established railway undertakings to use the information in some way at
the expense of newcomers.
2.5.34 When considering the issue of agreements between competitors,

one risk would be the mutual exchange of information between
competitors through the register (for example between railway
undertakings or between manufacturers). If such an exchange potentially
leads to a distortion of competition, it is in principle prohibited under the
rules of competition law. Exceptions to this principle will have to bear
among other things, the test of proportionality: is there no conceivable
alternative measure that achieves the required purpose (safety,
interoperability, exchange of stock, etc) which has a less negative effect
on competition?
2.5.35 To assess whether a “competition risk” will occur, one has to

make an analysis of the markets (product and geographical markets) in
which the competitors operate. In this process attention should be paid to
the character of these markets. For example, if one of these markets has
an oligopolistic character (that is few sellers, high barriers to entry,
relatively little product differentiation possible, etc) an exchange of
information will cause more problems than in a more open and
competitive market.
2-31
2.6 Number of Vehicles
2.6.1 The most reliable data available to the Consortium indicates that
the number of vehicles in each state that would be affected by any
renumbering scheme is shown in Table 2.2 (it is based on UIC figures
and only includes UIC members, the totals for other railway undertakings
and privately owned vehicle are unknown, except in the case of Great
Britain, Sweden, Romania and for German and Swiss wagons where the
national total has been obtained by responses in the information
collection process):
Table 2.2 – Number of Vehicles Effected
Numbering System
Locomotives Railcars & Hauled Hauled
State Multiple Passenger Freight
Units Vehicles Vehicles
Belgium 969 701 3 501 13 385
Denmark 187 466 918 2 236
Germany 7 254 2 402 14 715 200 578
Spain 988 1 006 4 310 19 754
France 4 983 2 175 15 694 46 359
Greece 159 85 517 3 526
Ireland 110 62 372 2 811
Italy 3 175 1 522 11 937 74 795
Luxembourg 79 34 146 2 201
The Netherlands 120 1 845 2 742 3 331
Austria 1 201 362 3 468 18 525
Portugal 256 333 1 399 3 931
Finland 623 112 1 012 12 292
Sweden 910 220 1 030 15 000
United Kingdom
1 873 11 255 3 088 29 624
(Great Britain)
United Kingdom
4 122 0
(N Ireland)
Czech Republic 2 713 966 5 252 47 768
Estonia 117 77 241 4 154
Latvia 252 181 702 7 326
Lithuania 278 141 563 10 117
Hungary 1 107 346 3 232 10 444
Poland 4 027 1 266 9 761 94 355
Slovakia 1 209 361 2 273 22 175
Slovenia 186 114 461 5 952
Switzerland 1 407 253 3 255 13 069
Norway 127 165 918 2 446
Bulgaria 680 82 2 099 24 910
2-32
Numbering System
Locomotives Railcars & Hauled Hauled
State Multiple Passenger Freight
Units Vehicles Vehicles
Romania 1 809 151 4 037 58 000
European CIS 16 027 9 971 41 937 547 796
Other UIC 6 868 1 744 16 253 173 555
Total 59 698 38 398 155 955 1 470 415
2.6.2 Although the above numbers should be treated with caution,

approximately 1.5 million European rail vehicles are or shortly will be
numbered using the UIC/OSJD system.
2.6.3 Assuming that, on average, locomotives, multiple units and

carriages should have an economic life of 30 years and that wagons
should have an economic life of 20 years28. This would mean that, at the
present fleet size and composition (see Section 7 of this Report for a
discussion of this issue) that approximately 1,800 locomotives, 1,200
multiple units, 4,600 carriages and 65,000 wagons enter service each
year.
2.7 Uses of Numbering Systems
Recording Numbers
2.7.1 The numbers are painted on the side of the vehicle. It is useful to
establish an understanding of the occasions when vehicle numbers are
currently recorded. In the case of wagons for example these include:
on loading: on the consignment note (written or IT based) (the note
is always provided by the customer, the number is either provided by
the customer if he loads the vehicle himself, or by the rail
undertaking if it loads the vehicle);
transferral of number to rail undertaking’s operating system;
marshalling yards: used for correct attribution of the wagon;
removal from the train due to malfunction: used for billing for
repairs (settled on an aggregated basis between rail undertakings);
28
It is noted that the age profile of the current fleet is not compatible with these
figures; due to the decline of the industry and historic factors, investment in
new equipment has been limited, resulting in an ageing fleet across Europe as a
whole.
2-33
train list: compiled by rail undertaking and an abstract is supplied to

the infrastructure manager;
dangerous goods: to ensure that the vehicle is appropriately
configured;
arrival at destination: input to the receipting process;
repositioning for next customer: contact to the wagon keeper to
identify the next customer;
accounting system: uses consignment number and wagon number;
maintenance: used by keeper and/or person contracted to perform
maintenance.
Roles
2.7.2 A unique identifying number has a number of potential uses for the
railway industry. These include operational, accounting, engineering and
legal functions. The nature of freight operations means that freight train
operators are likely to make considerably more use of the identification
number than do passenger operators. Freight vehicles need to be sent
singly or in different sized batches to differing destinations. Billing is an
issue and damage is more likely. Vehicle types are more varied and
appropriate ones are required to move the type of traffic on offer over the
route to be taken. These requirements all place much greater demands on
the numbering system than passenger traffic.
2.7.3 In passenger traffic the number is likely to be used only for

identifying vehicles for a consist list, charging for use, identifying
vehicle type in a reservation system, for maintenance purposes, for defect
reporting and repair, and in the event of an accident.
Uses in IT and Other Systems
2.7.4 Vehicle numbers are used in numerous systems; these include both
IT and manual systems. The structure of the number is therefore both
embedded in physical systems and in the intellectual processes of staff.
Systems that use vehicle numbers include:
operating and traffic management systems;
tracking and tracing systems;
vehicle maintenance systems;
billing and accounting systems for both railway undertakings and
infrastructure managers;
customers’ systems;
2-34
databases and registers of ownership/responsibility;

customs and other official systems.
The current uses are not exhaustive and vary from state to state; further
valid uses for vehicle identification systems could undoubtedly be found,
particularly through more advanced IT applications.
2.7.5 Uses of the vehicle number tend to be more numerous for wagons
and the rail freight business than for other types of traffic; Appendix H
examines the mechanics of the use of wagon numbers in various freight
systems in more detail.
2.7.6 There is a diverse range of IT systems around Europe, the

overwhelming majority of which are discrete national systems. The four
country reports included as Appendices D to G give outline details of the
national systems used in each. If these are multiplied by the twenty-eight
EC, CEEC and EFTA states with national rail systems and customers'
and other systems are added in, the investment in the current numbering
system can be seen. The costs and implications of changing numbering
systems are discussed in Section 7 of this Report.
2.7.7 It should be noted, however, that IT and other systems have a

discrete life span and the liberalisation that is occurring in the industry is
rendering many of the current systems obsolete or is demanding their
substantial revision to cope with a multi-operator environment. This
point was illustrated clearly in the four national case studies that were
undertaken for this Report. In the British case study, the national
operating system29 has been opened up to multiple access by railway
undertakings and other interested parties (with variable levels of access
rights), the lack of confidentiality filters and some inconsistencies in the
level of access rights are causing some difficulties.
2.7.8 Accordingly, two issues come into play when considering the
impact on IT and manual systems of changing the numbering system.
First, the impact on these existing IT and manual systems, and second, to
what extent do these systems have to change in any event because they
are inappropriate for the current environment? This issue is also
discussed further in Section 7 of this Report. It is understood that the EC
are currently providing funding for the development of new international
rail freight information exchange systems. It is important that the
minimum dataset requirement of any vehicle database is mutually
compatible with those exchanged by these new systems.
29
TOPS (Total Operations Processing System).
2-35
2.8 Particular Issues for non-UIC Members
2.8.1 Under current arrangements the UIC mandates UIC leaflet 433
(Standard General Conditions for the introduction into service and
operation of privately owned wagons) for the relationship between its
member railway undertakings and keepers of privately owned wagons.
No UIC provisions exist for the relationship between owners/keepers of
privately owned coaches or locomotives and non-member railway
undertakings.
2.8.2 The UIC leaflet provides a template contract for the relationship
between the vehicle keeper and a railway undertaking. The contract
provides for the keeper to ensure that the vehicle is properly maintained
and is not modified without approval.
2.8.3 There are terms which lay down a framework for liability for
damage caused to or by the wagon. The railway undertakes to ensure the
wagon will be accepted by other railway undertakings and that “Good
Samaritan” repair arrangements are in place outside the home country.
Within the railway community the mutual inter-railway obligations of the
UIC and RIV ensure that the contracting railway undertaking’s
obligations can be honoured everywhere the wagon goes. The system
acts as a funnel to limit and channel legal relationships; each railway has
agreements with “its” vehicle keepers and has rights and obligations
deriving from membership of international bodies.
2.8.4 All of these agreements are standard and avoid keepers having to
have understandings with every railway undertaking. Evidence for the
wagon being attached to the fleet of a railway undertaking and the
subject of an Agreement is provided by the wagon being numbered in the
number series of the railway undertaking. This system has worked well
in practice.
2.8.5 The keeper:railway undertaking relationship is preserved in the

1999 COTIF. The CUV, Appendix D to the Convention, sets down
optional general conditions for use for all vehicles (not just wagons).
There are a number of important differences from the UIC arrangements
however. The CUV is not mandatory; COTIF contains no requirement
for a vehicle to be attached to a railway undertaking at all although, when
interviewed in the course of the Study OCTI staff believed that a contract
for use, implicit or explicit was essential. Furthermore the CUV does not
mandate the terms of the contract but simply defines what will apply
unless the parties agree something else. The CUV does not deal with the
question of maintenance (that is dealt with by Article 15 of the ATMF).
Likewise the issue of liability is dealt with as a principle without the
complex provisions of the UIC formula, more intended to resolve
2-36
practical questions. The CUV requires the home railway to be marked on

the vehicle, where applicable, but is silent on the question of numbering.
2.9 Interface with OSJD
2.9.1 The OSJD (which in role is something of a combination of OCTI,

the UIC, RIV and RIC) looks after railway issues in the former
COMECON States. As such it represents railways with a number of
gauges, the 1524mm gauge of the former Soviet Union, the 1435 network
of the PRC and PDRK and the metre gauge networks of Vietnam (and
indeed the 1435mm railways of the former COMECON states in Eastern
Europe). In practice interchange of vehicles between the gauges is rare,
although the 1524mm network is operated almost as one system. The
scope of this report is logically limited to the 1524mm network
contiguous with the 1435mm network.
2.9.2 The CIS railways abutting the Western European railways use
their own numbering system inherited from SZD. RZD which continues
to manage rolling stock issues on behalf of the Commonwealth have a
pivotal role in determining future policy. As noted above, when
interviewed for this study, OSJD declared that RZD would be prepared to
move towards a standard European solution if they could be assured that
such a system would be stable.
2-37
Colin Buchanan and Partners Analysis of Existing System
3. ANALYSIS OF EXISTING SYSTEM
3.1 Legal Compliance
Overview
3.1.1 The following represents the Consortium’s analysis of the legal

compliance of the existing system. As the texts of RWP-II and the
UNIDROIT Rail Protocol on Matters specific to Railway Rolling Stock
are not yet definite, this section does not consider compliance with these
rules.
Comparison of Specific Rules on Numbering and Registration
3.1.2 The specific rules on registration (under COTIF and the

interoperability directives) are, in principle, not mutually irreconcilable.
They however contain different principles and requirements. Directive
2001/16/EC, for example, states that “databases are developed in a
manner allowing maximum data interchange between different
applications and operators”, while COTIF has a more limited purpose.
3.1.3 Although each of the rules has a limited scope and in itself leaves
little room for “broadening” the registration regime, they do not contain
any legal barriers for Member States (or the railway industry) to fulfil
their obligations on:
setting up a register;
using data for the set purpose;
appointing an authority to manage the register;
obliging actors to provide data;
giving entry to the register to specific actors.
3.1.4 However, other legal barriers resulting from EC legislation, the EC

Treaty and COTIF have to be taken into account (see below).
EC Law
3.1.5 The interoperability Directive 2001/16/EC contains an obligation

to keep a rolling stock register (Article 24). Although no such registers
3-1
are kept currently, implementation of this obligation is required before 20

April 2003.
Directive 91/440/EEC
3.1.6 Directive 91/440/EEC (as amended by Directive 2001/12/EC)

creates (limited) equitable and non-discriminatory access rights for
railway undertakings to railway infrastructure. Certain aspects of the
current numbering and registration process appear to be in conflict with
the basic assumptions of the Directive. UIC members effective
monopoly in the allocation of international numbers and the obligation to
enter into a contract for use are clear examples of impediments for non-
UIC members to exercise their rights and get vehicles accepted into
service and numbered for international operation. The same goes for
requirements for non-UIC members to attach their vehicles to a fleet of a
UIC member.
3.1.7 Furthermore Directive 91/440/EEC requires a separation of

accounts of railway undertakings and infrastructure managers. The
Directive prohibits bodies or firms that provide railway transport services
to be entrusted with certain functions that relate to infrastructure. These
functions, which are “determining equitable and non-discriminatory
access to infrastructure”, are (see Annex II to the Directive):
preparation and decision making related to licensing, including
granting individual licenses;
decision making related to path allocation including both the
definition and assessment of availability and the allocation of
individual train paths;
decision making related to infrastructure charging; and
monitoring observance of public service obligations associated with
service provision.
3.1.8 Although the function of numbering and registration of vehicles is

not explicitly listed in Annex II, a close link clearly exists between this
function and the infrastructure functions mentioned in the Annex. It is
therefore questionable whether a situation in which numbering and
registration is assigned to railway undertakings is compatible with the
basic concept of separating transport and infrastructure functions.
3.1.9 In this respect it should be noted that it is not clear whether the
Directive allows Member States to prohibit other functions than the ones
mentioned in the Annex. The question of whether the list is exhaustive
or not is left open by the text of the Directive.
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Article 82 of the EC Treaty
3.1.10 Even if Directive 91/440/EEC stills leave scope for the present
arrangements (see above), EC competition rules could give rise for
concern. Upholding the present practice of numbering and registration
by, in general, national railway undertakings, seems to increase the risk
of acting contrary to (Article 10 in conjunction with) Article 82 (abuse of
a dominant position) of the EC Treaty.
Article 81 of the EC Treaty
3.1.11 Another cause for concern could be the compatibility with Article
81 of the EC Treaty. Exchange of confidential data between competitors
could lead to a distortion of competition and therefore be in conflict with
Article 81. Under the current arrangements vehicles that are privately
owned or owned by a non-UIC railway undertaking have, in practice, to
be attached to the fleet of a UIC railway undertaking to be able to operate
internationally. This could enable the undertakings concerned access to
data containing recent, sensitive and individualised information.
COTIF
3.1.12 When COTIF 1999 comes into force, an “international database

of rolling stock” will be required. At present no such database exists.
Legal Conclusions
3.1.13 To conclude, the Consortium considers that the present system is

not completely compatible with legislative requirements, once the
interoperability directives and the new COTIF have come fully into
force. The following aspects of current arrangements appear to be
problematical:
apparent lack of commitment to the independence of notified bodies
from national railway undertakings in some states;
the involvement of national railway undertakings in the processes of
allocating numbers to vehicles and maintaining the national database
in numerous states, with consequent concerns under Article 82 of the
EC Treaty;
the need to attach a vehicle to the fleet of a UIC member railway (in
the main national railway undertakings) to operate a vehicle
internationally under the prevailing rules, with consequent concerns
under Article 82 of the EC Treaty in particular;
the attachment of vehicles to the fleet of a UIC railway undertaking
where these are either privately owned or owned by another railway
undertaking gives rise to serious concerns on data confidentiality
3-3
grounds: the ability to “see” what competitor’s vehicles are doing via
data access rights within railway operational systems is not
considered to be compatible with Article 81 of the EC Treaty;
there is currently no rolling stock register as will be shortly be
required by Directive 2001/16/EC;
a future problem is likely since there is currently no International
Registry of international interests as will be required under the
UNIDROIT Protocol on Matters specific to Railway Rolling Stock;
there is currently no international database of rolling stock as will be
required under the ATMF (COTIF).
3.1.14 As noted above registers of equipment/rolling stock of vehicles in

international service are required under Directive 2001/16/EC and
Appendix G of the revised COTIF. The information that is required
differs substantially between Directive 2001/16/EC and the COTIF.
Accordingly, as the legislation currently stands, separate registers will be
required to meet each of these legal requirements. Whilst this is
unfortunate it is not considered to be an insuperable difficulty and could
be met by reporting options under defined (and differing) access rights
from a single database, even if under the strictest interpretation of the
phraseology separate databases are required. Indeed, as noted in
Section 2, the interviews undertaken with the responsible authorities. in
the course of this study revealed a willingness to adopt a pragmatic
approach to this issue.
3.1.15 The issues of technical compatibility between any standards that

are mandated under the COTIF and those required under the TSIs are far
more complex and may be considerably more difficult to resolve,
however, detailed consideration of this issue is outside the scope of this
study. The relationship between the revised COTIF and EU law is
somewhat complex and has been discussed in Section 2 of this Report, to
which reference should be made.
3.1.16 Otherwise sitting the International Registry required under the

Unidroit Rail Protocol (see paragraph 2.4.12 et seq) alongside the other
two registers appears to present few difficulties. However, it requires a
“unique identification criterion” on a vehicle to enable a potentially
permanent interest in the asset to be registered. In practice, this may be
difficult to achieve without some kind of permanent identifier, something
that cannot be guaranteed under the structured numbering system that is
currently widely used in Europe (see below). It is to be noted that the
Unidroit Rail Protocol register will be publicly available to all via the
Internet1.
1
Art. 22 of the Cape Town Convention and letter from Chairman of Rail
Working Group to Consortium 29 July 2002.
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3.2.1 The technical approval process should become neutral for

manufacturers, railway undertakings and vehicle owners/keepers, given
full and proper establishment of independent notified bodies working to
appropriately drafted TSIs.
3.2.2 There are however, other potential impediments to appropriate

operation of the Single Market in the process of placing vehicles in
service. The primary concerns are processes that are either only
undertaken by established railway undertakings or involve attaching
vehicles to the fleets of established railway undertakings in order to gain
access to a particular market, be it domestic or international.
3.2.3 It is considered that the following functions in the process of

placing vehicles in service should be controlled by neutral bodies2:
allocation of vehicle identifiers;
management of vehicle database/register3;
arrangements for international use, where these are not tied to a
particular railway undertaking (for example in wagonload
operations);
agreement/specification of maintenance standards, where not
mandated by TSIs (and inspection and enforcement);
verification of insurance arrangements (including self-insurance
where appropriate).
3.2.4 The present system of attaching vehicles to UIC member railway

undertakings “who can be trusted”, provides important safeguards that
vehicles are maintained to appropriate standards and that liability cover
exists. If, as recommended, this is no longer mandated to gain access to
the Single Market suitable alternative arrangements will need to be
provided to verify that vehicles are in an appropriate standard of
maintenance and that suitable liability insurance is provided when injury
and/or damage is caused by vehicle defects.
3.2.5 The issue of insurance needs to be examined in parallel with

Article 9 of Directive 95/18/EC, which requires that railway undertakings
have some type of insurance cover as a condition of their licence.
However, the level of cover and the terms of the insurance are not
2
These could include governmental bodies, infrastructure managers, regulatory
bodies, independent commercial organisations or joint bodies established by
industry with open membership and equal rights for all.
3
Also proposed under RWP II, which also requires independence from any
infrastructure manager: see Section 5 of this Report.
3-5
defined in the Directive: the Commission has neither looked into

appropriate levels of cover, nor, it is understood would Member States
have agreed to any harmonisation of these.
3.3 Numbering Systems
3.3.1 There are a variety of numbering systems, differing substantially

in format, presently in use in Europe. The greatest differences occur with
the systems used for traction (locomotives and multiple units). In many
cases even the running number format used for locomotives and multiple
units differs within the same state. The greatest degree of commonality
exists for hauled rolling stock, where the overwhelming majority is
numbered under the UIC/OSJD systems, although there are still some
significant exceptions.
3.3.2 The majority of the systems in use are structured. With these
systems, when changes occur to a vehicle, for example its keeper or its
operating regime, the vehicle number changes in response. The more
complex the numbering system, the greater the instance of running
number changes. Where unstructured numbers are used it is much rarer
for vehicles to be renumbered, although this still occurs on occasion.
3.3.3 It therefore appears difficult for a structured running number to

provide a permanent identifier that could meet the needs of the
International Registry. Issues of temporal co-incidence between the
running number marked on the vehicle and the information held in the
registry, the possibility of errors or fraud when vehicles are renumbered
and also the reuse of numbers, as occurs under the present system, can
make it hard to establish the identity of the original asset.
3.3.4 An unstructured identifier merely needs to be unique, apart from

that it could be a random number. Any additional information that
relates to it is contained in a database and is accessed using the identifier.
Because a structured identifier has information about the item embedded
within it and, because of the need for it to allocate specific codes to
attributes which can then not be used for items not satisfying those
attributes, the utilisation of codes is less efficient than with an
unstructured identifier. With a structured identifier, the length of the
code is determined by the number of attributes to be identified and the
number of items sharing attributes whereas with an unstructured
identifier the number of codes and the consequent length of the identifier
need simply be the total number of items.
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3.3.5 There are also practical considerations in defining what comprises

a vehicle before any new numbering system can be imposed. There are
four primary issues here:
the numbering of multi-element vehicles;
major vehicle rebuilds;
innovative concepts: and
which vehicles should be included?
In considering these issues a distinction needs to be drawn between the
requirements of a running identifier and those of a permanent identifier,
to which the majority of these issues are relevant. It should be noted that,
dependent on the option(s) selected, the definitions adopted for the two
types of identifier need not necessarily coincide.
3.3.6 As noted in Section 2 the UIC convention is to renumber the

complete vehicle whereas the British one is to number the chassis. This
results in a British multi-element/articulated vehicle having more than
one number whereas elsewhere in Europe it would only have one.
Whilst, normally, the only event that results in multi-element/articulated
vehicles being reformed is major accident damage, this is still possible.
Thus, issues of permanent asset identification are aided by British
practice in this area.
3.3.7 Rebuilding and re-engineering of railway vehicles is not

uncommon, occurring most frequently for locomotives, because of their
cost, and for wagons, to carry different commodities and meet changes in
the market. These can vary from minor refurbishment, which would not
normally trigger alterations to a structured number4, to construction of a
new wagon chassis and body around the existing running gear (which
generally comprises about 70% of the asset value for a wagon), which
may or may not trigger a renumbering. The problems that arise for an
owner seeking to permanently identify a particular asset can be seen from
the following list of examples:
minor refurbishment;
re-engineering retaining the chassis and major components;
replacement of vehicle body;
replacement of vehicle body and some parts of the chassis;
replacement of vehicle body and chassis;
a number of identical wagons are refurbished simultaneously,
efficient process means that the major components do not go back on
the vehicle that they came from;
4
Although it can do, for example, changes to doors.
3-7
as above but some of the wagons require new bodies and chassis in
whole or in part.
There are, of course, an almost infinite number of steps between these

and none of the above examples is uncommon. It can be seen that the
process of allocating the identity to the chassis makes the process of
defining the continuous existence of a vehicle easier, but even then there
are questions of degree to be resolved. Furthermore, if the chassis is to
hold a vehicle’s identity that raises questions about a structured number
that in part is determined by its body.
3.3.8 Some innovative concepts have troubled conventional numbering

systems, for example, road:railer systems, where the bogies and bodies
are randomly disposed and are continually rearranged in use. It is clearly
impossible to be prescriptive in this area and the only appropriate
approach is to arrive at pragmatic solutions, as presently occurs.
3.4 Functions of Numbering Systems
3.4.1 The functions requiring vehicle identification are as follows:

to provide permanent identification of the vehicle structure for the
following reasons:
- to provide identification for legal reasons;
- to provide legal title (claim on ownership);
- to enable legal charges to be made (ownership or mortgage
by financier);
to identify vehicles and vehicle parts5 (this is required in case of
either damage caused by or to the vehicle);
commercial functions, as follows:
- identity for CIM consignment note purposes (it is necessary
to say which vehicle is carrying which goods);
- charges: (hire or infrastructure) where these are based on
type of vehicle, ownership/responsibility, capacity, maximum
load, etc;
- internal accounting systems (for example, maintenance cost
analysis);
tracking and tracing;
5
At present only wheelsets are individually accounted for.
3-8
to permit staff to identify vehicles (for example, to enable traincrew

to find the vehicle to which they have been rostered, defect
rectification, etc);
to locate the vehicle for allocation to its next duty, in this context it
helps operational staff if the number is of a recognisable type;
as access to systems containing characteristics of a vehicle:
- to enable the infrastructure manager to verify that it is
permitted to operate on the infrastructure;
- to enable a rail undertakings to calculate how to operate it in
a train;
- for the regime to know what to do with the vehicle next;
- to establish vehicle configuration in a reservation system;
- for charging between rail undertakings;
- for charging customers;
- maintenance history and management;
as a contact function;
for fleet management;
indicating what is permitted to be carried in a vehicle.
3.5 Vehicles Owned by non-UIC Members
3.5.1 In addition to those issues discussed above, although the UIC

system as it relates to privately owned vehicles has worked well to date,
there are a number of quite evident problems with its structure. These
are:
completeness;
maintenance provisions;
liability arrangements; and
access to data.
3.5.2 As noted in Section 2, the current arrangements relate solely to

privately owned wagons and no UIC provisions exist for the relationship
between keepers of privately owned coaches or locomotives and non-
member railway undertakings.
3.5.3 It is increasingly inappropriate for the railway undertaking to

whose fleet the vehicle is attached to supervise maintenance
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arrangements; the system does not encourage fleets composed of wagons

based in different states. This is considered to have a deleterious impact
on the proper operation of the Single Market in railway vehicle
maintenance services. Nevertheless the Consortium considers it to be
imperative that any (future) system “ensures” that all vehicles in use on
Europe’s rail system are maintained to an appropriate standard.
3.5.4 The liability arrangements, which can make railway undertakings

liable for the faults of all vehicles attached to their fleet, when in
international operation, are not appropriate for railways which do not
work in a co-operative pool. Equally the Consortium consider it
important that whatever system is provided in future it enables proper
recompense to be obtained for injuries and damage caused by defective
vehicles.
3.5.5 The legal concerns in respect of inequality of access to data have

been discussed above.
3.5.6 When the new COTIF takes effect, the simpler provisions of the
CUV are likely to influence owners/keepers and railway undertakings to
review contractual terms. The Consortium’s discussions indicate that
owners/keepers want standard terms signed once with one railway which
would then apply everywhere. Existing arrangements for owners/keepers
(in the form of the UIP) and railways (in the form of the UIC) to discuss
and agree contractual conditions are likely to continue. (It is worth
noting that the dispositive nature of the CUV protects both parties from
unreasonable contractual demands). It would also seem, however, that
there is an option to have a “free” vehicle (known in the aviation world
as a “white tail”); if so these free vehicles must have a right to a standard
number.
3.5.7 The Consortium considers, therefore, that whilst it is clear that a

vehicle attached to a railway undertaking will have to have that marked
on the side; there is no supportable requirement for vehicles to be
numbered in the railway undertaking’s own series of numbers. There can
therefore be no requirement for the process to be carried out by a railway
undertaking or a UIC member.
3.5.8 The possibility of vehicles without a relationship to a railway

undertaking raises public policy and railway operating questions. Under
current circumstances liability issues are resolved between keepers and
the whole of the railway community by the UIC-433 contract for use, it
seems clear that this cannot be a suitable model for the future. Further
consideration of this issue lies outside the scope of this study but it is
known that work on the issue has already commenced. Likewise,
arrangements for repair of wagons are funnelled through mechanisms set
up by the contract for use, to the extent that fleet operators do not enter
3-10
into these arrangements they voluntarily accept the need to make other
arrangements
3.6 Access Rights to Systems
3.6.1 The study has highlighted the issues of equality of access to and
confidentiality of data systems which use and hold vehicle details and
numbers. The problem stems from the historic structure of the rail
industry, where monolithic organisations were in complete charge of
national rail systems. Accordingly, the architecture of IT systems used
by railway undertakings and infrastructure managers does not provide
internal confidentiality filters.
3.6.2 In time, information systems can be modified or replaced so that

they act in a neutral manner for all participants. However, this process
will inevitably take time and the problem has to be faced in the interim.
It is considered that, in general, insufficient attention is being given by
the rail industry to development of neutral systems that hold and make
use of vehicle information.
3.6.3 There are also issues of confidentiality between railway

undertakings and infrastructure managers as the integration between the
two functions is loosened. Similarly, there are issues associated with
which party in a liberalised environment owns IT and other systems that
were developed under monolithic state organisations.
3.6.4 As noted above there are significant difficulties associated with

vesting inherited IT systems in national railway undertakings or their
successors, not least legality under Community competition law. The
alternative is to vest all essential national vehicle databases, operating
and similar systems either with the infrastructure manager, a regulatory
body, or some other neutral body and to open access to these systems to
all railway undertakings, vehicle owners, vehicle keepers, etc.
3.6.5 The case studies revealed Britain as an example of a country which

has, to an extent, adopted the latter approach for many key systems,
including the national vehicle database. The national operating system
has insufficient confidentiality within it, permitting railway undertakings
to monitor each other’s operations, should they so wish. Nevertheless
whilst this situation is undesirable, Britain has experienced growth in
passenger kilometres of over 35% and freight tonne kilometres of 50%
since liberalisation, figures which are contrary to the EU15 trend. It can
therefore be seem that whilst achieving appropriate commercial
confidentiality is important it is demonstrably less important than market
liberalisation. However, even here there are problems with differential
3-11
access rights; the former parts of BR have greater access rights to data
than other players in some competing areas.
3-12
Colin Buchanan and Partners Comparisons
4. COMPARISONS
4.1 Objective and Terminology
4.1.1 Comparable systems that are used in other modes, in other

industries and in other parts of the world have been examined. The
objective is to identify requirements that are similar in part or whole to
those in the European rail industry and to explore whether there are
lessons, systems and concepts that can be learned from these other case
studies that could be applicable to rail vehicle identification and
registration systems in Europe.
4.1.2 The term identifier is used to indicate a coded means of identifying

items. A distinction is made between permanent and operating
identifiers. The term permanent identifier is used to denote an identifier
that uniquely identifies an item and is unchanging. Examples include
serial numbers, production numbers and international standard number
series. The term operating identifier is used to denote a means of
classing items to enable their retrieval or identification for operational
reasons. These may refer to a unique item or to a small class of items;
examples include vehicle registration marks or classification systems.
4.2 Comparison Philosophy
Selection of Comparators
4.2.1 Identifiers are used in all areas of human activity. Examples

include road vehicles, aircraft, domestic and industrial equipment, books,
retail products and computer software. They may be used to identify the
specific asset, to identify property rights, to enable batches to be
identified in case of defects, to provide information on the item such as
its composition or to prevent fraud.
4.2.2 There some railway vehicle characteristics that determine the need
for and application of identifiers, which may differ from those required
by identification systems for applications in other industries and modes.
The key attributes of rail vehicles are that: they are mobile, they have to
conform to appropriate technical standards, they can be valuable, they are
often unaccompanied, and they have a wide range of important
characteristics, some of which limit their scope or method of operation.
Information about the asset and its characteristics must be readily
available, and the information required by different bodies varies.
4-1
4.2.3 To provide an appropriate comparator for rail vehicles an industry

needs to exhibit similar needs or operational requirements to those that
arise for vehicles in the rail system, at least in part. Other transport
modes share, to a greater or lesser degree, the majority of these
characteristics, and thus provide some of the most relevant potential
comparisons; some examples are aviation, road transport and deep-sea
containers. The extent to which the attributes of these modes match rail
varies. For example, from this group, only deep-sea containers normally
travel unaccompanied. However, there is little or no need for them to be
subject to any kind of agreed maintenance regime. On the other hand,
the registration process for aircraft and road vehicles includes technical
certification to ensure that agreed international and national standards are
met. Both these modes also have periodic re-certification requirements
to verify that the asset remains in a safe condition; there are safeguards to
prevent operation without such approval, via the registration process.
Despite their imperfect comparability these modes also show some clear
similarities in terms of information and mobility that enable useful
comparisons to be made.
4.2.4 Relevant examples outside the transport field are harder to find. In
many cases, a single permanent identifier is used. In the field of express
parcels, unique identifiers are used for the package, but there is no
requirement for a permanent identifier, nor an overriding need for the
identifier to carry any information. The identifier could, however,
indicate information such as origin point or date of consignment to avoid
the need to look these up in a database. Nevertheless some examples
have been identified that may be of interest for different aspects for
example, international usage, use of two different identifiers.
4.2.5 The parallels that can be drawn with railways in other parts of the
world are somewhat easier to make, since similar issues are faced to
those covered in this Report. The Consortium thought three examples
were worthy of comparison: North America, Southern Africa and
Australia.
Facets Explored
4.2.6 The main uses of railway vehicle numbers were discussed in

Section 2 of this Report. These fall into five main areas:
permanent identification of item;
identification of liability;
commercial functions;
tracking and tracing; and
operational functions.
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4.2.7 In addition a number of essential attributes for the identification

system as a whole have also been identified. These can be described in
general terms as:
permits operation of the single market;
verification of conformity of item with initial standards; and
verification of continuing conformity of item with standards during
its life.
4.2.8 The different identifiers will be assessed to understand how they

perform the first five functions listed above. The systems considered will
be measured against their ability to satisfy the subsequent three system
attributes.
4.3 Other Transport Modes
Road Vehicles
Vehicle Approval
4.3.1 For a vehicle manufacturer to be able to sell a vehicle in Europe a

European whole vehicle Type Approval certificate is required, depending
on the category of vehicle. There are around fifty technical directives in
total to be complied with. As a large majority of vehicle components are
manufactured or assembled by suppliers to the vehicle industry it is often
necessary for these components to be separately approved.
4.3.2 The Type Approval procedure is essentially the same for a vehicle
as for a component. This procedure is defined in Directive 70/156/EEC
and subsequent amendments. Both the item and the production process
must be approved, the latter known as Conformity of Production (CoP)
assessment.
4.3.3 The client provides the documents specified in the Directive

together with the required number of sample products for assessment and
testing. The client, with advice if required, prepares a "worst case"
analysis of the product range together with a draft test plan. This
analysis is assessed in a "worst case review" meeting with the Technical
Service.
4.3.4 Where the product is a single component, this meeting may simply
be a document exchange. Where a number of products are derived from
a basic design they are assessed to identify a worst case version for
testing in order to limit the amount of test work to be carried out. A
documented worst case assessment is produced for the approval body as
4-3
a record of the agreement. The test plan is finalised and the Type
Approval fees are confirmed. Testing is carried out on the sample
product(s) with the Technical Service witnessing the test work as
necessary.
4.3.5 Test reports are prepared and the Technical Service provides a
complete set of technical documentation and test reports to the approval
authority. Subject to a satisfactory review of the submitted documents
and CoP assessment, the approval body issues a type approval certificate
which authorises the manufacturer to put the "e" mark, or "E" mark, on
the product(s).
4.3.6 The following diagram produced by the UK Vehicle Certification

Agency illustrates the type approval process:
4-4
Identifiers
4.3.7 Road Vehicles are provided with a unique Vehicle Identification

Number (VIN) by the Manufacturer. This is fixed to the chassis on a
plate which also usually contains other information about the vehicle for
example, model and colour. A Directive makes the use of VINs
compulsory for powered vehicles in the EU although a year digit or
factory code is not mandatory. The format of VINs is described in ISO
3779 and comprises three elements: World Manufacturer Identifier
(WMI), Vehicle Descriptor Section (VDS) and Vehicle Identifier Section
(VIS). If a year code is used then ISO recommends that this should be in
position 10 while if a factory code is used this should be in position 11.
VINs may use capital letters A to Z except I, O and Q and numbers 0 to
9.
4.3.8 The WMI is described in ISO 3780 and occupies the first three
positions of the VIN. It is alphanumeric, the first character defines a
geographical region, the second a specific country, the third defines the
manufacturer. Specific arrangements exist where a manufacturer
produces less than 500 vehicles per year.
4.3.9 The VDS occupying positions 4 to 9 of the VIN may be used by

the manufacturer at its discretion to identify attributes of the vehicle. In
the USA position 9 of must be used as a check digit.
4.3.10 The VIS occupies the last 8 characters of the VIN and the last
four of these must be numeric.
4.3.11 In addition to the permanent identifier, a government authority

also allocates an operating identifier, its registration number, to road
vehicles. This is to a national standard format and is usually fixed to the
front and rear of the vehicle. The two numbers will be linked in a
database and both appear on the vehicle's registration document. The
identity number of the major component (the engine) is also recorded in
the vehicle’s registration document and database, this serial number also
being stamped on the engine.
4.3.12 Fees have to be paid, generally on an annual basis, to register the

vehicle for use on the road network; this is signified either by annual
change of registration plates or the supplementary display of an official
marker either on the registration plates or in the car windows. This is
also linked to the registration and VIN numbers in official databases so
that the relevant authorities can verify legality of use in real time. The
advent of number plate reading devices is enabling the enforcement of
annual payments and procedures to be automated.
4-5
4.3.13 In most states, including all EU States, vehicles over a set age
have to undergo annual safety checks. In some cases this is linked to an
annual taxation process which also requires proof of valid insurance
before the annual taxation disc can be obtained. In other cases (for
example, France), insurance is controlled by an insurance vignette on the
windscreen. Where there is a linkage, the annual element of the process
imposes a check on whether a vehicle is maintained to appropriate
standards and is carrying appropriate insurance. Mutual recognition of
these standards applies throughout the EU and Europe.
4.3.14 The VIN is intended to be permanent, and tampering with it will

usually be detectable. It is used for definitive identification of the vehicle
as well as for reference in case of servicing, recall, etc, with the engine
number being used on a supplementary basis. The registration number is
used for identification of the vehicle in normal use.
4.3.15 Registration numbers differ between states although similar

formats exist in different states. However, even where the format is
similar, in combination with the state of registration, the registration
number will be unique. The registration number may contain additional
data such as year of registration and/or locality where the vehicle is
registered. In some states the registration number changes when the
vehicle changes ownership or its keeper changes his address whereas in
others the registration number normally stays with the vehicle throughout
its life.
Technical Inspection
4.3.16 In 1977 the European Community adopted a Directive on the

technical inspection of vehicles, which was amended in 1992 to include
private cars. A later amendment details the items that must be checked
on a vehicle when it is inspected. All the requirements have been
consolidated in Directive 96/96/EC. The competent national authorities
must inspect commercial vehicles at least once a year and private cars at
least every two years, although Member States may require more
frequent testing if they wish.
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Table 4.1- Performance of Main Identifier Functions: Road Vehicles
Function How Performed
Permanent Identification VIN.
Identification of Liability Based on operating identifier.
Commercial Function May be based on operating identifier.
Tracking and Tracing Not required.
Operating Functions Based on operating identifier or fleet number.
Permits Single Market to Function Yes. Permanent identifier harmonised.

Operating identifier neutrally operated
although not harmonised.
Conformity with Standards Yes. Checked before allocation of operating

identifier.
Ongoing Conformity with Not intrinsic to identifier, but can be linked

Standards to issue of other identifying mark, for
example, on an annual basis. A database with
information on the operational identifiers can
also store this information and trigger
requests.
Civil Aviation
Approval
4.3.17 Independent state agencies ensure compliance based on the Joint

Aviation Rules issued by the Joint Aviation Authorities (JAA). Technical
standards are agreed by the JAA and there is a resulting mutual
recognition of airworthiness certification. Within the EU this is assured
by Regulation 3922/91/EEC.
Identifiers
4.3.18 For a civil aircraft a permanent identifier is the construction

number, allocated by the manufacturer and permanently fixed to the
airframe. The position of fixing varies by aircraft type. The serial
numbers of the major components, such as the engines are also recorded.
Registration of legal interests is facilitated by reference to this permanent
identifier (see the reference to UNIDROIT in Section 2 of this Report).
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4.3.19 There will also be an operating identifier (the registration mark)

allocated by the national aviation regulatory authority painted on to the
aircraft exterior. The format is defined in the international standard
ICAO Annex 7, so for example the lettering is required to conform to the
English alphabet while other requirements relate to size of the characters,
colour, slant and position. A fireproof metal plate is also fixed to the
aircraft bearing the registration mark of the aircraft.
4.3.20 The format of these registration marks comprises a national

identification code, of one or two letters separated by a dash from a
following unique code for the aircraft. Aircraft registration marks do not
have to be allocated sequentially, although in many cases they are. It is
possible for aircraft owners to request a specific mark, for example
incorporating the initials of their company. As an aircraft moves from
one operator to another, the registration mark may change, even within
the same state. In the UK, for example, registration marks are never
reused, even if the aircraft has been scrapped or lost. Normally
registration marks must be shown but in a few special circumstances (for
example preserved ex-military aircraft) some dispensations are possible.
4.3.21 The information linking the registration mark, the construction

number of the aircraft, the owner and other relevant information is held
by the relevant aviation authority, for example the CAA in the UK and
the FAA in the USA.
4.3.22 In normal operation an aircraft will be accompanied by crew who

are familiar with and have manuals for the aircraft, thus there is no
requirement for the identifier to indicate its technical characteristics. For
most other operational requirements, the model designation provides
adequate information. In any event each aircraft is under the control of a
single operator which is fully aware of the characteristics and capabilities
of each type of aircraft that he operates and therefore will only deploy
aircraft on appropriate services and routes.
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Table 4.2 - Performance of Main Identifier Functions – Civil Aviation
Permanent Identification Airframe construction number.
Identification of Liability Based on operating identifier, can be

confirmed by airframe number.
Commercial Function May be based on operating identifier.
Tracking and Tracing Not required.
Operating Functions Based on operating identifier.
Permits Single Market to Function Yes. Operating identifier neutrally operated

and harmonised internationally.

identifier.
Ongoing Conformity with Not intrinsic to identifier, but database with

Standards information on the operational identifier can
store this information and trigger requests.
Shipping
Background
4.3.23 Because of the international nature of the shipping industry,

action to improve safety in maritime operations is more effective if
carried out at an international level rather than by individual countries
acting unilaterally. A United Nations conference in 1948 adopted a
convention establishing the International Maritime Organisation (IMO).
From the very beginning, the improvement of maritime safety has been
one of IMO's most important objectives. IMO promotes measures to
achieve its objectives; these include conventions, protocols, codes and
recommendations concerning maritime safety among other matters. One
of the first was the International Convention on Safety of Life at Sea
(SOLAS) which covers a wide range of measures designed to improve
the safety of shipping including rules relating to construction and a
harmonised system of survey and certification.
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Classification
4.3.24 Commercial vessels are classified according to the type of

journeys that they are capable of undertaking. Classifications exist at
both national and EU level with some overlap.
4.3.25 The rules relating to ship construction and maintenance are

subject to constant revision and updating in line with changes and
developments in ship building and current research. Classification sets
and maintains standards of quality and reliability. A vessel must
conform to the standards required by published rules, and periodic
surveys must be carried out, if a vessel is to be classed and class
maintained.
4.3.26 The complete process of construction of a vessel must conform to

the rules, from the plans to the materials used. The design is thoroughly
assessed to ensure it will cope with likely loads and deformations. This
assessment includes 3D finite element analysis and simulation of events
such as ingress of water. Every part of the vessel is inspected and
approved, from the steelwork to the electrical systems. Any
modifications or conversions during its life must also be approved.
4.3.27 Within the EU, Council Directive 94/57/EC as amended sets out
which bodies are approved to perform inspection, survey and
certification of ships in order to ensure effective application of the
international Conventions. Those approved bodies are:
American Bureau of Shipping (ABS);
Bureau Veritas (BV);
China Classification Society (CCS);
Det Norske Veritas (DNV);
Germanischer Lloyd (GL);
Hellenic Register of Shipping (HR);
Korean Register of Shipping (KR);
Lloyd’s Register of Shipping (LR);
Nippon Kaiji Kyokai (NK);
Registro Italiano Navale (RINA);
Maritime Register of Shipping (MRS).
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Registration
4.3.28 Registration is a requirement of international maritime law and is

the responsibility of national registration authorities. For example, the
official British registration authority is the Registry of Shipping and
Seamen in Cardiff and this maintains the central register of UK merchant
ships, fishing vessels and pleasure vessels down to and including small
yachts. .A simplified register is available to private owners of pleasure
vessels.
4.3.29 Additional reasons for registering a vessel are to prove its

nationality and to use it as security to obtain a marine mortgage, which in
turn is registered. When applying to register a vessel, ownership details
are therefore fully investigated. For example, purchasers of British
registered ships can obtain a Transcript of Registry which shows the
registered owners of a ship and whether there are any outstanding
Mortgages lodged against that vessel. When a vessel is registered, any
changes that would affect the Certificate of Registration must be notified.
4.3.30 To register a ship in the UK it is necessary to supply, in addition

to the application to register:
declaration of eligibility;
original documents of sale such as bills of sale, invoices, builders
certificate, that cover the last five years;
certificate of survey for tonnage and measurement issued by a
classification society;
certificate of incorporation (if a company is applying);
registration fee.
4.3.31 The ship owner proposes a name for the vessel that will only be
allocated once the registry has confirmed that it is not already in use.
Lloyds Register of Ships
4.3.32 Lloyds Register maintains on a commercial basis a register which

records the details of all merchant ships of the world over 100 gross
tonnes, which are self-propelled and sea-going, regardless of
classification. Vessels are listed alphabetically by their current name and
their entries provide the following details:
place of build;
ship type;
rig (for sailing vessels);
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classification;
shipbuilder;
former names;
survey dates;
date of build;
official number;
navigational aids;
call sign;
cargo facilities;
destined voyage;
speed; manager;
port of registry and flag;
dimensions;
machinery; and
owner.
4.3.33 The current register contains details of approximately 87 000

ships and is available on CD-Rom and to subscribers via the Internet.
Enforcement
4.3.34 There are international conventions, codes and protocols

concerning ship safety and marine pollution as agreed by the
International Maritime Organisation. The conventions and codes, which
are statutory surveys, usually stipulate inspection and issuance of
certificates as part of enforcement. Fourteen different types of certificate
relate to different classes of vessel. Some are issued by the classification
agency with others by the national registry authority.
4.3.35 In addition, many Member States instigate national regulations

which incorporate IMO standards and apply them to their own and
visiting foreign vessels.
4.3.36 Council Directive 95/21/EC concerns the enforcement, in respect

of shipping using EU ports and sailing in the waters under the
jurisdiction of Member States, of international standards for ship safety,
pollution prevention and shipboard living and working conditions. The
purpose of this Directive is to improve maritime safety in Community
waters by enforcing compliance with international standards. It applies
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to all merchant shipping and crews using a seaport of a Member State or

offshore terminal or anchored off such a port or installation.
4.3.37 The Directive places an obligation on Member States to establish

and maintain national maritime administrations ("competent authorities")
for the inspection of ships in their ports or in the waters under their
jurisdiction. Each Member State is under an obligation to inspect at least
25% of the vessels flying other countries' flags that enter their ports.
Selection criteria for deciding which vessels to inspect are laid down. No
further inspections are carried out on ships that have been inspected
within the previous six months. A list of the certificates and documents
to be inspected and of the types of inspection to be carried out is laid
down, together with the rules to be followed if a more detailed inspection
proves necessary. Enhanced controls must be carried out on certain
categories of higher risk vessels.
Table 4.3 - Performance of Main Identifier Functions: Shipping
Permanent Identification Via continuous updating of international

register of operating identifiers.
Identification of Liability Based on operating identifier.
Commercial Function Might be based on operating identifier.
Tracking and Tracing Not required (continuously crewed).
Permits Single Market to Function Yes.

identifier.
Ongoing Conformity with Regular checks under Port State Control

Standards regime.
ISO Containers
Identifiers
4.3.38 ISO intermodal containers move goods throughout the world in a

complex and extensive transport system, and each year there are over 500
million container movements, a number that is typically growing in deep-
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sea trade at approximately 5.5% per annum. To facilitate this there are
numerous databases, for example for port planning, ship stowage and
loading programmes. Many of these utilise container numbers as a basic
field.
4.3.39 ISO containers have many similarities with rail freight wagons in
their method of use and the international codes used were designed to be
compatible with AAR freight car codes. The container is transported,
unaccompanied, using different powered vehicles and is subject to
transhipping at various points on its journey. Backloads may be arranged
and there is a need for owners to be able to manage their pool of assets.
However, containers have low capital cost, short operational lives and do
not require much maintenance. Poor maintenance generally only results
in damage to the consignment and consequent loss for the owner. The
rugged simplicity of the standard design also means that, other than in a
few specialised cases such as tank containers, there is little prospect of a
technical failure of the container causing consequential losses to vessels,
infrastructure or other containers. Thus the holding of insurance by the
container owner or shipper is of little consequence to shipping operators,
vessel owners or port authorities.
4.3.40 The International identification code of containers proposed by

the Bureau International des Containers (BIC) has been standardised
since 1972 by the International Organisation for Standardisation (ISO).
It forms an essential part of the ISO 6346 standard: Freight Containers -
Coding, Identification and Marking. This standard also describes some
complementary features such as size and type code, state code and
various operational marks). Only ISO Alpha-codes for identification of
container owners registered with BIC may be used as the unique marking
of containers in all international transport and customs declaration
documents and are used in 110 states by about 1 200 owners or operators
representing approximately 90% of the world container fleet.
4.3.41 The code comprises:

an owner/operator code of four letters, the last one being “U”;
a six number serial;
a seventh digit (check digit) providing a means of validating the
recording and/or transmission accuracy of the data.
4.3.42 The code provides a unique identification for the container. It

permits both the identification of the owner or principal operator, and the
identification of the unit by its owner or operator in his own database.
The six serial numbers are not allocated by BIC but by the owner or
operator.
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4.3.43 BIC does not monitor the positions of containers, or register the
individual serial numbers allocated by companies; its database simply
contains details of the companies registered. A payment must be made
by a company to register for a four digit code, of which there are 17 576
possible combinations.
4.3.44 The serial number facilitates international use and temporary

admission, and the control of containers, manually or automatically by
computerised and/or remote control systems at any stage of the supply
chain and especially in intermodal transport. The code may be linked in
databases with other information for example the contents of the
container the stacking position or the origin or destination.
Table 4.4 - Performance of Main Identifier Functions: ISO Containers
Permanent Identification No, unless there a manufacturer’s serial

number is also provided.
Identification of Liability If appropriate, based on operating identifier.
Commercial Function Based on operating identifier.
Tracking and Tracing Based on operating identifier.
Permits Single Market to Function Yes, operating identifier is neutrally operated

and harmonised.
Conformity with Standards No.
Ongoing Conformity with No.

Standards
4.4 Other Industries
Cataloguing and Numbering Systems
4.4.1 A multitude of cataloguing and numbering systems exist in

different industries. Some examples include International Standard Book
Number (ISBN), International Standard Serial Number (ISSN),
International Standard Music Number (ISMN), International Standard
4-15
Recording Code (ISRC), International Standard Work Code (ISWC),

International Standard Audiovisual Number (ISAN), and Digital Object
Identifier (DOI). In addition, URNs (Uniform Resource Names) are
being developed as an umbrella system for internet use that can
accommodate any of the existing identifier systems.
4.4.2 There is considerable similarity between these different systems.

Usually each has an international office responsible for allocation of the
high level part of the identifier, while individual identifiers are allocated
by the body that has registered. In addition an ISO standard usually
covers the format of the identifier.
Book Identification Systems
Selection of Example
4.4.3 Book identification systems have been selected as an example

because of their extensive international use, the interplay that exists
between them and library cataloguing systems and the way that they have
been able to successfully evolve as technology and the market has
changed.
International Standard Book Numbers
4.4.4 The International Standard Book Number (ISBN) was approved as

ISO standard 2108 in 1970. The purpose of the international standard is
to co-ordinate and standardise the international use of ISBNs to uniquely
identify a single title or edition of a title, published by a specific
publisher. The original standard has been revised as book and book-like
items begin to appear in new forms of media, although the basic structure
of the ISBN, as defined in that standard, has not changed and is in use
today in some 150 countries. The international administration and co-
ordination of the ISBN system occurs through the International ISBN
agency in Berlin.
4.4.5 An ISBN consists of ten digits preceded by the letters ISBN. The
ten-digit number is divided into four parts of variable length, which must
be separated clearly by hyphens or spaces, e.g. ISBN 0 571 08989 5 or
ISBN 90-70002-04-3.
4.4.6 For purposes of data processing the ten-digit string is used without
hyphens or spaces. Interpretation and human legible display is
effectuated by means of the tables of group numbers and publisher
identifier ranges.
4.4.7 The number of digits in the first three parts of the ISBN (group
identifier, publisher identifier, title identifier) varies. The number of
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digits in the group number and in the publisher identifier is determined

by the quantity of titles planned to be produced by the publisher or
publisher group. Publishers or publisher groups with large title outputs
are represented by fewer digits.
4.4.8 The first part of the ISBN is a group identifier, identifying a

country, area or language area participating in the ISBN system. Some
members form language areas (for example German language group: 3)
or regional units (for example South Pacific: 982). A group identifier
may consist of up to five digits. All group identifiers are allocated by the
International ISBN Agency in Berlin.
4.4.9 The second part of the ISBN identifies a particular publisher

within a group. The publisher identifier usually indicates the exact
identification of the publishing house and its address. If publishers
exhaust their initial contingent of title numbers, they may be allocated an
additional publisher identifier. The publisher identifier may comprise up
to seven digits. Publisher identifiers are assigned by the ISBN group
agency responsible for the management of the ISBN system within the
country, area or language area where the publisher is officially based.
4.4.10 The third part of the ISBN is the title identifier, identifying a
specific edition of a publication of a specific publisher. A title identifier
may consist of up to six digits. As an ISBN must always have ten digits,
blank digits are represented by leading zeros.
4.4.11 The check digit is the last digit of an ISBN. It is calculated on a

modulus 11 with weights 10-21.
4.4.12 The number of digits in each of the three parts of the identifier is
variable, although there are always nine digits, which with the check
digit, make up the ten-digit ISBN.
4.4.13 For ease of reading, the four parts of the ISBN are divided by
spaces or hyphens. The position of the hyphens is determined by the
publisher identifier ranges established by each group agency in
accordance with the book industry needs. The hyphens are generated by
a hyphenation output programme, which helps reduce work at input,
reducing the number of characters, eliminating manual checking of
hyphenation, and ensuring accuracy of format.
Library Classification
4.4.14 While ISBNs uniquely identify publications, they provide no

information about the content. When searching in a library for
1
See description in footnote in Section 2.
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information about a particular field it is necessary to have a means of

pointing to publications that may be of interest. Different library
classification systems have evolved; two well known systems are Library
of Congress Classification (LCC) and Dewey Decimal Classification
(DDC).
4.4.15 In the LCC system the first character is a capital letter and
denotes a broad area such as Law or Agriculture. Each of these is
subdivided by a second capital letter into more discrete subject areas and
these are then further subdivided by the addition of numbers for discrete
areas. For example, QA76.4 denotes analogue computers, where Q
denotes Science and 76 denotes electronic computers.
4.4.16 The Dewey Decimal Classification system (DDC) is similar to

LCC but purely numerical. It is a general knowledge organisation tool
that is continuously revised to keep pace with knowledge. The system
was conceived by Melvil Dewey in 1873 and first published in 1876.
DDC is the most widely used library classification system in the world.
It is used in more than 135 countries and has been translated into over
thirty languages. DDC aims to classify books and other material on all
subjects in all languages in every kind of library. There are one thousand
codes for specific areas and then these are further sub divided in a
hierarchical manner after a full stop. So for example, 663.224 concerns
making sparkling wine. Codes from 600 to 699 cover technology and
applied sciences. Codes from 660 to 669 cover chemical engineering and
related technologies. Code 663 denotes beverage technology while 663.2
is specific to wine and wine making and 663.22 narrows this down to
making grape wine. The final digit distinguishes white, red or sparkling
wine. More relevantly Codes from 620 to 629 cover engineering. Code
623 denotes military and nautical engineering (!) whilst 623.6 is specific
to military transport technology and 623.63 narrows this down to
railways. The final digit distinguishes rolling stock from trackwork .
There is an occasional revision of the system to take account of new
concepts and the Dewey system is currently in its 21st edition.
4.4.17 Both identifiers facilitate identification of a specific publication,

but from very different initial information. In general libraries have a
searchable database listing their contents with both ISBN and for
example DDC. Starting with either of these it is possible to ascertain
publishers, authors and titles of relevant publications. Using an
operational identifier (for example, DDC) enables the user who requires a
publication in a certain area to narrow that search down to a few
publications in a large library without knowing anything about who
wrote or published them. On the other hand knowledge of the ISBN
enables the immediate identification of the author, publisher and other
characteristics without knowing anything of the subject matter. Although
it is structured, it would be difficult to recognise more than the
geographic area from the ISBN.
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4.4.18 Determination of the different elements of the ISBN is performed

by different bodies: ISBN agency, group agency and publisher.
Table 4.5 - Performance of Main Identifier Functions: Book ID Systems
Permanent Identification ISBN
Identification of Liability If appropriate, ISBN
Commercial Function Based on ISBN
Tracking and Tracing Based on ISBN in commercial applications
Operating Functions Based on operating identifier
Permits Single Market to Function Yes. Permanent and Operating identifiers are
harmonised. Allocation of codes is neutrally
operated.

Standards
Product Codes
Selection of Example
4.4.19 Identifiers are widespread in widespread use in the retail trade.

Virtually all products are bar-coded with a product code. These can have
various forms. These unique identifiers are likely to be used in
collaboration with other systems of retrieving products.
EAN-UCC codes
4.4.20 With the expansion of global trade and computerisation, plain

language descriptions of products and services need to be replaced by
identification systems that are usable in all trade and industry sectors
world-wide. The EAN-UCC system has been developed to meet this
need by providing solutions that guarantees unique and unambiguous
identification. Manufacturers, exporters, importers, hospitals,
wholesalers, retailers, etc, can use the system to communicate
information regarding the goods or services they trade.
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4.4.21 These unique identification numbers can be represented by bar

code symbols. This enables inexpensive and accurate data capture thus
providing the required information at all points of the supply chain.
4.4.22 One of the main concepts of the EAN-UCC system is that any
item (product or service) upon which there is a need to retrieve pre-
defined information and that may be priced or ordered or invoiced at any
point in any supply chain can be allocated a unique identification
number: the Global Trade Item Number or GTIN for short.
4.4.23 A GTIN can be constructed using four numbering structures

depending upon the exact application and bar code structure to be used.
However, in databases all GTIN are unique and unambiguous when right
justified in a fourteen-digit field. Shorter numbers simply have zeros
placed in the left most positions of the identifier.
4.4.24 A number of different arrangements exist, with variations for

example, trade items intended to cross the retail point of sale, trade items
not intended to cross the retail point of sale, small items and North
America. The systems are all fundamentally similar and a brief
description is provided of the numbering structure used for trade items
intended to cross the retail point of sale.
4.4.25 Once assigned, the GTIN can then be bar coded onto the trade
item using the EAN/UPC structure. All identical trade items use an
identical GTIN and bar code. Any item which crosses the retail point of
sale should be bar coded using the EAN/UPC structure. The two most
widely used numbering structures for this are the EAN/UCC-13 and
UCC-12. The GTIN is constructed as follows:
EAN/UCC-13 identification number (GTIN)

EAN•UCC company prefix Item reference Check
digit
------------------------------> <------------------------------
EAN/UCC-13
N1 N 2 N3 N4 N5 N6 N7 N8 N9 N10 N11 N12 N13
UCC-12
0 N1 N 2 N3 N4 N5 N6 N7 N8 N9 N10 N11 N12
4.4.26 EAN•UCC company prefix: any company wishing to identify

their products will be allocated an EAN-UCC company prefix upon
joining an EAN Member Organisation or the UCC. The company prefix
is variable in length and is normally determined by the capacity of
GTINs required (10, 100, 1,000, etc).
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4.4.27 Item reference: this part of the numbering structure is allocated

by the user company. Each different trade item is allocated a different
number and, for ease of administration, it is recommended that
companies do this sequentially (001, 002, 003, etc).
4.4.28 Check digit: EAN- UCC has a standard check-digit algorithm for
all GTINs. This is calculated using the preceding digits.
Table 4.6 - Performance of Main Identifier Functions – Product Codes
Permanent Identification Yes - UPC
Identification of Liability If appropriate, based on UPC
Commercial Function Can be based on UPC
Tracking and Tracing
Operating Functions Probably based on warehouse or supermarket

aisle location
Permits Single Market to Function Yes. Identifier is neutrally operated and

harmonised.

Standards
4.5 Railway Systems Elsewhere
North America
Background
4.5.1 The North American situation is instructive. The most notable

characteristic of North American railway operation is the almost total
delegation of the national sovereign functions of the three principal states
(USA, Canada and Mexico) to the railway industry. In this way the trade
association, the Association of American Railroads (AAR), exercises a
number of quasi-regulatory roles on behalf of the US Federal Railroad
Administration (FRA). It sets standards and polices them on behalf of
the community with little or no intervention by the governments
themselves. American railroads benefit from almost ideal conditions for
4-21
the creation of standards; the railroads operate across two countries with
largely uniform laws, a single language and similar operating conditions.
Mexico in effect has to accept the standards of Canada and the US and
largely does so by buying second-hand equipment from them.
Acceptance into Service
4.5.2 Vehicle builders are certified by the AAR as being competent to

construct vehicles. Manufacturers, railroads and car owners are all
required to sign agreements that vehicles will be built and maintained to
comply with AAR technical standards. These standards all include
quality systems, so controls on vehicle compliance are all audit based
controls with few physical inspections.
4.5.3 North American vehicle designs and the components used in

vehicle manufacture are highly standardised, much more so than in
Europe. Consequently new designs are rare. New designs and
components are specifically approved by AAR committees on the basis
of tests carried out (notably at the railroad Technology Test Center in
Pueblo, Colorado)
Numbering System
4.5.4 The states of North America have a common numbering system

organised by the Association of American Railroads, The railroads have
standardised rolling stock and a single system of rolling stock
management. Widespread use is made of information technology for all
railway processes and in particular fleet management, operations control,
accountancy and billing. Sophisticated customer information systems are
in place.
4.5.5 The AAR system makes use of a code comprised of two to four
letters to identify the owner of the vehicle, this code is in the main
mnemonic, for example, BNSF for the Burlington Northern Santa Fe
Railway. An X as the last character identifies a vehicle that belongs to a
private owner rather than a railroad, for example, GATX. (U and Z as
the last characters are reserved for containers and road trailers). Some
36 000 of the theoretical 405 000 combinations are used. Control over
the letter codes is held by the National Motor Freight Traffic Association
although administration of railroad codings is undertaken by RAILINC2
on behalf of the AAR. Allocation of a letter codes is conditional on
approval as a railroad by the US Department of Transportation and a
commitment to the vehicle being entered on the vehicle master file (see
2
A subsidiary company of the AAR with responsibility for the neutral
administration of industry-wide IT systems (for example UMLER).
4-22
below). In the case of hauled rolling stock the remainder of the number
comprises up to six digits as a serial number and is defined by the owner.
4.5.6 The code guarantees unique identification of the vehicle. It

permits the identification of the owner or principal operator, and the
identification of the vehicle in railroad databases.
4.5.7 The AAR master file is notably comprehensive; this issue is

addressed in detail below but of particular interest is the mandatory
inclusion of owner (as distinct from the operator) and the cost of the
vehicle when new.
4.5.8 The number is used as the key when interchanging equipment

between railroads and as a key to extract information for determining the
safe load of a vehicle, calculating train weight and length, scheduling
maintenance and accounting purposes.
4.5.9 Data from the master file is used in railways’ own railway
operating systems, for example when containers are carried on flat cars,
the rail wagon and container data both are extracted from the master file
for operating purposes.
4.5.10 Traction follows an essentially similar principal, the same letter

code of up to four letters followed by up to four digits. Although the
structures of locomotive and hauled stock numbers clearly overlap,
controls are in place to ensure that numbers are not duplicated. It should
be noted that whereas the letter code is always marked on hauled stock, it
is normally omitted on locomotives.
UMLER
4.5.11 The UMLER (Universal Machine Language Equipment Register)

file is the AAR master file of vehicle characteristics, UMLER has a long
history and was originally issued annually in paper form and is still
publicly available in this form. At present the file includes
approximately 1 500 000 freight vehicles plus a further 2 300 000
containers. Locomotives and passenger rolling stock are also included.
The file is managed by RAILINC. In managing this file, RAILINC is in
part providing an operating tool for the railway community and in part
exercising a para-statal activity on behalf of the Federal Railroad
Administration.
4.5.12 The file is keyed by vehicle running number which is not a

permanent attribute of the vehicle (since it changes with the sale of a
vehicle from one company to another). There is no permanent identity
information on the file and indeed if a change of number takes place, the
new record is not associated with the old. The record for each piece of
4-23
equipment contains some 700 characters, highly coded and so a

considerable amount of data is held in the file for each vehicle. The
majority of the data is physical and permanent. The file also includes
ephemeral technical data (for example the brake test date) and
commercial data such as exceptional charging information. From the
viewpoint of the present study the inclusion of first cost and ledger value
of the vehicle is interesting as well as the mandatory requirement for
owner as well as operator to be included. A special flag indicates
vehicles that are lost or stolen. Vehicles that are prohibited from
exchange by the FRA are also indicated.
4.5.13 In summary therefore this file, designed primarily for the

purposes of railway operation, is also used for quasi regulatory purposes.
It includes both permanent and volatile data but makes no use of a
permanent vehicle identifier. Whilst it appears to break several rules of
good practice it nevertheless works.
Enforcement
4.5.14 The Agreement to observe AAR standards signed by

manufacturers, railroads and car owners likewise commits them to keep
vehicles properly maintained. Again the systems to check compliance
are internal to the industry and rely extensively on internal audit. The
AAR does not perform external audits; however it is understood that
quality systems similar to those of ISO 9001 are required, which are
audited and if problems are encountered accreditation is lost.
4.5.15 The FRA also holds extensive regulatory powers over railroads,
with the power to enforce action on safety or even to suspend railroad
operations.
4-24
Table 4.7 - Performance of Main Identifier Functions: North American

Railways
Permanent Identification No
Identification of Liability If appropriate, based on operating identifier
Commercial Function Based on operating identifier
Tracking and Tracing Based on operating identifier
Operating Functions Based on operating identifier
Permits Single Market to Function Yes, identifier is neutrally operated and

harmonised (Also satisfies US legislation)
Conformity with Standards In part, owners and builders make separate

undertakings to comply with standards.
Ongoing Conformity with No

Standards
Australia
Background
4.5.16 Australian railways work to a number of gauges; the interstate

network, however, is to 1435mm gauge and represents a parallel with
European operations. The remarks below refer only to the interstate
network. Australian railways have been restructured to a model which
closely resembles the British one. Infrastructure and operation are
therefore entirely divorced.
4.5.17 A substantial part of the trunk route infrastructure belongs to or is

operated by the Australian Rail Track Corporation, a Commonwealth
Government organisation; however, State owned infrastructure continues
in New South Wales and Western Australia. A number of private
operators provide freight services and a mixture of state owned,
franchised and private operators provide passenger services. Australian
freight operations form a series of point to point flows without much
pretence of being a network.
4-25
4.5.18 The various operators are required to warrant that their train
operations are safe and to register their rolling stock.
4.5.19 Rolling stock is approved by infrastructure managers. Each

infrastructure manager works to slightly different standards although
there is substantial mutual recognition of equipment and an on-going
process (almost complete) of aligning standards to achieve a single
Commonwealth set of standards.
Numbering System
4.5.20 Despite the fact that the discrete nature of the various operators’
freight services means that numbers need only to be relevant to the
operator in question, freight stock is required to be numbered to a
common system using the former Railways of Australia system, a system
specifically designed to facilitate interchange of vehicles.
4.5.21 The numbering system comprises four letters followed by up to

five numbers. The four letters have the meaning owner, main type, sub-
type, bogie and braking system. The allocation of a single character for
the owner reflects the fact that privately owned wagons are rare in
Australia. The structure of the maximum of five digits which follow the
letters is not specified in the standards, some operators use them to
identify vehicles within the letter code, others as an independent
accession number.
4.5.22 Given that passenger vehicles tended to captive within their

states, no overarching numbering system was imposed on them and they
remain numbered to a mixture of standards, normally numeric but
otherwise with little in common. Some states use structured numbers,
within vehicle class or as a function of the multiple unit to which they
belong, other states merely use an accession number.
4.5.23 Likewise traction rarely crosses state frontiers and there is

therefore no need for a common standard for numbering it. Again a
variety of numbering systems have evolved, normally structured by class
and then serial number, although class itself is numeric in some systems,
alphabetic in others. Some states use accession numbers with the class
identifier rather than a serial number within class.
Computer System
4.5.24 Each railway undertaking has its own computer system to

organise its own traffic. In addition infrastructure managers have their
own systems (which accept details of traffic moved by all the operators).
4-26
The infrastructure managers systems are largely designed to raise charges

for infrastructure use.
Enforcement
4.5.25 Continuing maintenance is overseen by operators themselves.

Operators are required to warrant that equipment is keep in good order
and do so using their own systems, normally by a formal quality
management system. There is no requirement however for a quality
management system.
Table 4.8 - Performance of Main Identifier Functions: Australian

Railways
Identification of Liability Yes, based on identifier
Commercial Function Based on identifier
Tracking and Tracing Based on identifier where provided (railway

undertakings provide their own services)
Operating Functions Based on identifier
Permits Single Market to Function Yes, identifier is neutrally operated and

harmonised (also compliant with Australian
competition legislation)

identifier

Standards
Southern Africa
Background
4.5.26 The railways of Southern Africa: those of South Africa itself,

Botswana, Congo, Mozambique, Namibia, Swaziland, Tanzania, Zambia,
and Zimbabwe, are independent state-owned railways with a common
gauge and very similar operating conditions. It will be evident that the
countries are at different stages of economic development. South Africa
4-27
is the economic powerhouse of the region and traffic to and from South
Africa predominates. Nevertheless traffic is exchanged between all the
railways and the majority of the wagon fleets are interchangeable.
Passenger rolling stock operates internationally; traction tends not to, but
in exceptional cases can do (for example the need to provide hotel power
to passenger rolling stock).
4.5.27 Each of the states has its own vehicle approval process with
common standards agreed under the aegis of the Southern African
Railway Association. Approvals are mutually recognised.
Numbering System
4.5.28 Each of the railways concerned numbers all of its vehicles in its
own series. All these number series are structured, however the
structures are not the same and there has been no attempt to rationalise
the numbering sequences between railways.
4.5.29 All vehicles, whatever the number format, are entered on

Spoornet’s (South African Railways) computer system Sprint. Sprint has
terminals over the whole of Southern Africa and in effect is an
international railway operating and commercial control system. It both
distributes vehicles to where they are needed and calculates the charges
for their use. Vehicles are in process of being fitted with automatic
vehicle identification tags to automate this process.
4.5.30 This system provides an interesting example of a wholly

integrated solution using dissimilar numbering structures. Whilst all the
numbers are structured, there has been no attempt to rationalise them, and
the only integrating feature is the Sprint computer system. This model
depends on having a single system to control all movements. It works
well in the circumstances of having a single powerful railway with
satellites but is difficult to visualise in a pan-European context.
Enforcement
4.5.31 Each state operates its own enforcement regime, reinforced by

checks at frontiers for vehicle compliance.
4-28
Table 4.9 - Performance of Main Identifier Functions: South African

Railways
Identification of Liability Yes
Commercial Function Yes
Tracking and Tracing Yes
Operating Functions Yes
Permits Single Market to Function No, presumes state railways
Conformity with Standards

Standards
4.6 Conclusions and Parallels
General Points
4.6.1 None of the non-rail comparative examples discussed exhibits the

full range of requirements that have been identified for rail vehicle
identifiers. Nevertheless different aspects of the identifiers and systems
are worthy of note. These are discussed below.
4.6.2 One significant factor in defining what is required of an identifier

is whether the item is accompanied or whether the identifier must provide
information without human intervention. In the case of three of the
transport examples considered, the items to be identified will in general
be accompanied.
4.6.3 In the case of the three examples from rail systems in other parts of
the world, none of them does all that would be required from a
comparable new European system. The North American system is the
most interesting, particularly in regard of the UMLER vehicle database.
Again the points that are worthy of note are discussed below.
4-29
Permanent Identifiers
Use
4.6.4 Across a range of industries permanent identifiers appear to be

more commonly used than either operational identifiers or a combination
of the two. Most of the transport examples discussed illustrate the use of
both types of identifier, the notable exception being the rail sector, where
the only permanent identifiers are manufacturer’s serial numbers, which
have no real official recognition as such.
4.6.5 Virtually all products have unique serial numbers in addition to the
types of identifiers described above. The need for a permanent identifier
has been solved in the case of road vehicles and aircraft by having a plate
fixed to the structure in a manner which makes tampering apparent. The
use of separate permanent and operating identifiers is particularly notable
in the automotive sector, where official government databases handle
tens of millions of records linking the two numbers together and holding
a wide variety of associated data and where the permanent identifier
(VIN) is used for fraud detection, etc.
Form
4.6.6 In many of the cases where a permanent identifier is used, the

identifier is structured. Often part of the identifier indicates the
manufacturer of the item. The allocation of production numbers within
the overall identifier is often left to the manufacturer themselves, with the
system of self-regulation by manufacturers working well.
4.6.7 Since the permanent identifier only conveys a limited range of

information, most of the detailed information required relating to the item
is actually contained in databases maintained by the various actors.
International Aspects
4.6.8 For permanent identifiers used internationally, in general, an

international agreement or standard determines the format of the
identifier. Frequently this forms an ISO standard. There is often an
office responsible for allocating the first parts of the codes, which
identifies the responsible party. A fee generally must be paid for this
registration but in general no fee is payable for individual identifiers
issued.
Compatibility
4.6.9 Permanent identifiers are usually a defined length, although in the

case of UPCs, the systems have been devised to enable different length
4-30
codes to be recognisable and compatible. Although, for example, North

American automotive VINs provide more information than European
ones the two systems are still compatible because the extra information is
contained in digits that are left for manufacturers’ use elsewhere.
Operating Identifiers
Use
4.6.10 In other transport modes operating identifiers are common and

are usually allocated by State bodies, this being the case for three of the
examples considered.
4.6.11 Operating identifiers are less common in non-transport industries,

there being no need in most cases. Indeed none of these other industries
considered uses operating identifiers, with the arguable exception of
library classification systems.
4.6.12 The character of rail operations means that operating identifiers

are de rigueur and as one would expect the three non-European rail
systems studied use them. The fundamental difference with other
transport modes is that they are required for the railway industry’s own
purposes and are therefore allocated by the rail industry itself rather than
Government.
Form
4.6.13 Most operating identifiers have at least a simple structure,

enabling basic assimilation of the place where the asset is registered or
the owner, if little else. In the case of other rail systems sometimes (as in
the Australian example) limited technical information is also contained
within the structure of the number, although this is emphatically not the
case for North America.
4.6.14 As with (the linked) permanent identifier the limited range of

information conveyed means that most of the detailed information
required relating to the item is actually contained in databases maintained
by the various actors.
International Aspects
4.6.15 In the case of aircraft there is an international agreement covering

the format of the operating identifier, while in the case of road vehicles,
the format traditionally varied from state to state.
4-31
4.6.16 Of the examples considered for railway systems in other parts of

the world only North America and Southern Africa involve international
operation and in both of these cases disproportionate power has enabled
the most powerful state to effectively dictate standards to its neighbours.
Compatibility
4.6.17 Compatibility between operating identifiers and the systems that

used them is normally achieved by having a standard format, often
structured.
Databases and Registers
4.6.18 In the examples for other transport modes described, there is in

general no international database kept. Instead a national register is kept
in each state relating to road vehicles and aircraft. However, in the case
of containers, which are unaccompanied, an international database of
owners was created. Lloyds Register of Shipping falls somewhere
between the two being a purely commercial register, which only covers
vessels over a set size.
4.6.19 In the case of the examples for rail systems elsewhere in the
world the UMLER database in North America provides an example of an
international database for North America and Sprint for Southern Africa.
Standards
4.6.20 For an identifier to be accepted sufficiently widely to become a

standard, it must either be so good as to replace others through the choice
of users, or it must be mandated by a body with sufficient authority to
ensure its use.
4.6.21 For the majority of the identifiers considered in the comparison,

an international standard exists, prepared by the International Standards
Organisation. In the case of aircraft, there is an international standard but
it was prepared by the International Civil Aviation Organisation.
4.6.22 In contrast the rail industry is notable for the lack of international
standards defining identifiers, international adoption of particular
numbering systems has only really occurred through international
industry organisations such as the AAR, the UIC and the OSJD, each
with geographical constituencies. Whilst there has been co-operation
between the UIC and OSJD, there has been no attempt to develop a
world-level numbering system. In consequence the systems selected
have limited compatibility with each other (see below).
4-32
Compatibility Issues
4.6.23 In some of the cases considered for other modes and industries,
compatibility issues arise, either from the use of different length
identifiers or their containing different amounts of information.
Compatibility has been assured between the different formats in these
cases. The case of UPCs is interesting, where shorter codes simply have
additional zeros inserted at the left end of the identifier to complete the
standard size. A similar system could be posited for rail vehicles which
would enable two numbering systems to co-exist without confusion.
Systems Issues
The Single Market
4.6.24 The requirement for the identifier not to hamper the operation of
the single market translates into a number of requirements. From the
examples that have been described these can be defined as:
the allocation of identifiers and their management must be performed
by a neutral body;
the identifier should enable an entity to identify its own assets;
there should be no disadvantage to an entity arising from the form of
identifiers allocated to it;
essential data systems should be available on an equal basis to all
users.
Verification of Conformity
4.6.25 The verification of conformity with standards (for example,

technical compatibility or the holding of insurance cover) prior to
allocation of an identifier or during its validity will usually only arise
where there are strong reasons, for example public safety issues. These
can occur in the transport field and it is no surprise that both road
vehicles and aircraft are subject to these checks.
4.6.26 The verification of conformity with standards, both initially and

during the asset's life essentially comprises slightly different aspects of a
similar task. It is difficult for an indicator alone to indicate this
satisfactorily since taken alone it is unverifiable. Effective verification
requires an information system enabling the identifier to be linked to data
indicating checks of conformity. The information system must itself be
operated by a reputable independent body. In two of the other transport
modes considered, databases are maintained by governmental bodies to
confirm compliance. It is vital that the system enables auditing of the
process to verify compliance.
4-33
4.6.27 A potential solution would be for a master database, where the

relevant information relating to the vehicles is stored, to be run
independently of the users of the vehicles. If based on a permanent
identifier, this database then separately receives from the relevant parties,
data on the vehicle from its owner, data indicating insurance from the
insurer, and data on technical conformity from the notified body, and
these are linked within the database it is possible to effectively check
conformity.
4-34
Colin Buchanan and Partners Industry’s Views and Proposals
5. INDUSTRY’S VIEWS AND PROPOSALS
5.1 Overview of Section
5.1.1 To date this Report has mainly discussed the current position when
placing vehicles in service and identifying them. However, there are a
number of potential changes that need to be considered. Some of these
concern potential changes in the legislative environment, which will
require the current arrangements to be amended, where appropriate, and
which any proposed revisions to the system for other reasons will need to
take account of. Other changes to the system have been proposed or are
being proposed by interested parties to deal with perceived weaknesses in
the system.
5.1.2 This section of the Report commences with a discussion of the

proposed legislative changes. This is followed by a summary and
discussion of the views obtained on the present system and proposals for
change in the consultation exercise undertaken as a part of the Study.
Finally, some of the schemes to reform the system that have been
proposed are briefly discussed.
5.2 Commission’s Proposals in RWP II
Interoperability Directives
5.2.1 Directives 96/48/EC and 2001/16/EC lay down rules for the
interoperability on the Trans-European high speed network and the
Trans-European conventional network respectively. After amendment by
RWP-II the scope of Directive 2001/16/EC will change: the complete
European conventional rail system will come under the provisions of the
Directive.
5.2.2 The Commission’s proposals for the interoperability directives

will contain two registration undertakings that are relevant for this study.
These are firstly the rolling stock register and secondly the national
register.
5.2.3 The requirement for a rolling stock register for conventional

rolling stock has already been discussed as part of the narrative on
Directive 2001/16/EC. The proposal is that the same register will
become obligatory for high-speed rolling stock (in accordance with
5-1
article 22bis Directive 96/48/EC after amendment by RWP-II). The

register will cover both conventional stock and high-speed stock1.
5.2.4 The basic parameters for high-speed rolling stock can be found in
Annex II point 3 of the high speed directive (for example, axle loading,
maximum train length, gauge of rolling stock, minimum braking
characteristics, etc). The requirements for the rolling stock register (e.g.
frequency of publication, access rights, etc) are otherwise identical to
those already discussed under the current requirements for Directive
2001/16/EC.
5.2.5 The only other, relevant, substantive change is that it is proposed

that a new European Railway Agency (ERA) will take over the role of
the AEIF.
5.2.6 The requirements for national registers are given in Article 14

paragraph 4 of Directive 2001/16/EC and Directive 96/48/EC, after
amendment by RWP-II. The national register covers the same type of
vehicles as in the rolling stock register, however in this case the Draft
Directive makes it clear that the registration concerns “vehicles put into
service”.
5.2.7 The details of the content of the register have to be included in

common specifications that will be adopted by means of Article 21
procedure, on the basis of a draft prepared by the ERA2. The Draft
Directive specifies the data that it is mandatory to record3, which is:
references to the EC declaration of verification and the issuing body;
references to the register of rolling stock contained in Article 24 and
Article 22bis respectively;
identification of the owner of the vehicle and of the railway
undertaking using it;
any restriction on how the vehicle may be used; and
data relating to the state of maintenance of the vehicle.
The Draft Directive further prescribes that registration has to take the
place of the “alphanumeric identification code” that has to be assigned to
each vehicle when authorised to enter service4.
1
See for a full definition of the latter: Annex I point 2 of Directive 96/48/EC, to
be amended by RWP-II.
2
See Article 21 paragraph 2 of the Directives.
3
Article 14 paragraph 5 as proposed by RWP-II.
4
Article 14 paragraph 4 as proposed by RWP-II.
5-2
5.2.8 The Draft Directive does not mention how frequently the database
will have to be updated. It is considered to be logical however that this
should depend upon the purpose of the register. If the register has to play
a role in day-to-day operational acts, a corresponding content will
obviously be needed; therefore, there will be a requirement to keep the
register up-to-date. It is recommended that when drafting the common
specifications of the register attention should be paid to this aspect.
5.2.9 The body responsible for keeping the register up-to-date must be
independent of the infrastructure manager or of any railway undertaking5.
5.2.10 The draft Safety Directive requires that “national safety

authorities” supervise that rolling stock is duly registered and that safety
related information in the national register is “accurate and kept up-to-
date”6. However, the Draft Directive does not clarify whether the safety
authorities would be expected to manage the register by themselves or
can delegate. It merely prescribes that the safety authorities are not
allowed to transfer their tasks to any infrastructure manager or railway
undertaking7. This matches the wording of the interoperability directives
(as proposed by RWP-II).
5.2.11 The proposal in the draft legislation is that access rights to the
register will exist for:
the authorities designated in Articles 12 and 18 of the Safety
Directive, it is noted however that it was probably intended to refer to
Articles 15 and 20, which refer to national safety authorities and
investigating bodies;
the national regulatory bodies (to be assigned by the Member States
on the basis of Article 30 of Directive 2001/14);
the ERA;
infrastructure managers; and
railway undertakings.
It is proposed that more limited rights of access will exist for:
safety authorities and investigating bodies, but only insofar as it
concerns “information concerning railway safety”; and
for any other party with a “legitimate interest”.
5
Article 14 paragraph 4.
6
Article 15 paragraph 3 of the draft Directive.
7
Article 15 paragraph 4 of the draft Directive.
5-3
Safety Directive
5.2.12 It is proposed that the Safety Directive will apply to the whole
European railway system (all sub-systems, including rolling stock). The
explanatory memorandum indicates that the directive aims at
harmonising safety rules, removing obstacles to a functioning internal
market, providing transparency and information about safety issues and
investigating accidents and incidents.
5.2.13 The Draft Directive determines, amongst other things, common

standards for certification of safety management systems of railway
undertakings. The safety certificates issued by the national safety
authorities will be valid throughout the EU. Safety certification
information will be included in a public register maintained by the ERA.
When national safety authorities issue, renew, amend or revoke
certificates, they will have to inform the ERA. This information that they
are required to disclose will be name and address of the railway
undertaking, the issuing date, scope and validity of the certificate and in
case of revocation, the reasons for the decision. Whilst this does not
appear to be directly relevant to the present study the ERA may add to
this public list any document or link relevant to the objectives of ERA
Regulation8.
5.2.14 The Draft Directive does not state how often the register has to be
updated. The ERA regulation, however, states that the national
authorities (in this case the safety authorities) responsible for issuing the
documents (for example safety certificates) will have to notify the ERA
within one month of each individual decision to issue, refuse or withdraw
a document9.
5.2.15 The ERA Regulation requires the ERA to keep a public list (also
referred to as public register of documents and public database) of issued
safety certificates10.The register will be open for public scrutiny.
ERA Regulation
5.2.16 The draft ERA Regulation refers to a number of registers

established or to be established by other Directives or draft Directives, as
follows:
a public register of licenses and safety documents11;
a public register of interoperability documents12;
8
Article 11 paragraph 3 of the draft ERA Regulation.
9
Article 11 paragraph 2 of the draft ERA Regulation.
10
Article 11 paragraph 1 sub b of the draft ERA Regulation.
11
Article 11 draft ERA Regulation.
5-4
a national register13.
5.2.17 Under the proposed requirements for a register of licenses and

safety documents the ERA must keep lists/registers of the following:
licenses issued in accordance with Directive 95/18/EC;
safety certificates issued in accordance with the Safety Directive;
inspection reports forwarded to the ERA in accordance with the
Safety Directive;
national provisions notified to the Commission in accordance with
the Safety Directive; and
any document or link that the ERA may deem relevant to the
objectives of the ERA Regulation.
5.2.18 Under the requirements for a register of interoperability

documents the ERA will be required to hold a list of the following
documents:
declarations of verification of subsystems;
declarations of conformity of constituents;
authorisations for putting assets or vehicles into service, including the
associated registration numbers; and
registers of infrastructure and rolling stock.
5.2.19 In the national register information must be kept as described

above for the Interoperability Directives.
5.2.20 In respect of the register of licenses and safety documents

national authorities responsible for issuing the documents, will have to
notify the ERA within one month of each individual decision to issue,
refuse or withdraw a document14.
5.2.21 ERA Regulation does not contain a provision about the frequency
with which the register of interoperability documents must be updated.
5.2.22 The ERA will be responsible for the public registers and national
authorities (which must be independent of infrastructure managers and
railway undertakings) will be required to keep national registers up to
date. Whilst the former will be open for public scrutiny, access to the
national registers is limited as noted above.
12
13
14
Article 11 paragraph 2.
5-5
5.3 Industry Views
5.3.1 A wide variety of views were obtained in the interviews and

questionnaires undertaken for the Study, although in the main these could
be anticipated from the relative position of the respondents in the railway
industry and were reasonably consistent within each part of the industry.
In some cases, however, views from different parts of the industry were
diametrically opposed.
5.3.2 Manufacturers of rolling stock pressed for unification of

procedures and standards. There was a balance of view on whether
standards should be prescriptive or whether the objective should be
defined but not the means of meeting it. Manufacturers acknowledged
that the majority of railway undertakings follow UIC specifications
closely but pointed out that in many areas (particularly for tractive stock)
specifications and practices are not particularly firm. For hauled rolling
stock manufacturers stated that different railways interpreted
specifications differently. Given the likely impact of the Interoperability
Directives in resolving many of the foregoing issues, manufacturers’
principal complaint however was over the timescales, cost and sheer
over-burden of the approval process which they pointed out is an
impediment to the industry’s competitiveness.
5.3.3 Manufacturers had no strong views on numbering per se nor on the

concept of the VIN. The manufacturers interviewed had no strong
objections about being involved in the process of defining and allocating
VINs, should this be required.
5.3.4 UIC member railway undertakings pointed out that reconsideration

of the numbering structure was already taking place within the UIC (see
section 5.4 et seq). They emphasised that this was being driven by
changes to the wagon regimes themselves changing as a result of
liberalisation. They pointed out that the current arrangements offered
clarity and simplicity and any new arrangements should do the same.
They were prepared to accept alternative arrangements provided they
offered similar clear relationships and in particular provided that the
costs and disruption of change were not too great. No railway
undertaking objected to change on the grounds that they would be paying
for changes that would benefit third parties.
5.3.5 Non UIC member railway undertakings responses varied as a

function of the traffic they operated. Most were reasonably satisfied with
the process of approving vehicles but some were concerned by the
conditions for operation. They drew attention to the problems of
operating their own fleet of vehicles without the benefit of twelve digit
international numbers, where these are denied to them.
5-6
5.3.6 Wagon owners’ responses were less consistent than other parts of
the industry. The same comments were made as made by manufacturers
about the timescales, costs and differing emphases in the approval
process. By contrast there was general satisfaction with the relationship
with railway undertakings although there was a strong demand for
greater international freedom away from national constraints. This was
manifested in particular by a demand to be able to maintain vehicles
outside their parent country and for freedom of choice in the maintenance
of their vehicles. Concerns were also expressed about the competition
implications of attaching their wagons to the fleets of railway
undertakings and the consequent ability of railway undertakings to get
details of their major customers and flows by tracking through railway IT
systems.
5.3.7 Vehicle owners were not in favour of changing the numbering

logic because of the costs it might involve. They strongly supported a
permanent VIN, given the problems under current circumstances of
tracing wagon histories as they were successively renumbered. Owners
also supported the concept of an international database whilst recognising
the problems of confidentiality. They favoured any such database being
under independent control.
5.3.8 Regulatory authorities’ responses were amongst the most incisive,

although responses were only received from states where the process of
liberalisation had gone furthest. They identified the problems of the
development of open access in the climate of a structure operated by a
trade association and designed for a limited number of large railways
which did not compete. All the respondents had already developed their
own national technical approval systems although the details of these
varied quite considerably. They had considered how this could be linked
in with vehicle numbering. There was general support for a structured
twelve digit system with a country code. There was less support for a
VIN. Most respondents thought the systems for numbering vehicles
ought to be run by the state, perhaps delegated. The exception, Great
Britain, thought that an industry scheme was to be preferred provided it
was transparent and independent.
5.3.9 The only issue on which universal consensus appears to exist is

that if VINs are adopted, they should be applied before the vehicles leave
the manufacturer’s facility when first built or when reconstructed. The
necessity for this, who should allocate it and the information that it
should contain are, however, issues where wildly disparate views exist.
5-7
5.4 The Vehicle Numbering System
Background
5.4.1 The Vehicle Numbering Study (VNS) was undertaken by Railned,

the independent Dutch infrastructure manager. It identified problems
linked to the process of UIC railway undertakings providing numbers.
The problem identified was that there was no provision for a licensed
railway undertaking which was not a member of the UIC with its own
two digit code to get twelve-digit numbers for its vehicles without going
to such a railway and presenting these as private vehicles. There was no
guarantee that a railway could be found that would accept such vehicles.
5.4.2 Furthermore the apparent status: “private vehicle” was

inappropriate and could lead to problems in competition law. Railned
noted that in practice twelve digit numbers were essential because the
overwhelming majority of railway systems used them. The issue, as
perceived by Railned, was to find a solution which preserved enough of
the existing structure to be accommodated in existing systems but which
allowed these vehicles to be recognised without having to attach them to
the fleet of a UIC member.
5.4.3 Railned accordingly made a proposition to the UIC in late 1997 to

resolve this issue in the short term and to provide a possible solution in
the longer term. Their final report was tabled in September 1998.
Methodology and Findings
5.4.4 The VNS report saw the objectives as being to accommodate the
vehicles of new railway undertakings simply and without putting the
costs of doing so on UIC members.
5.4.5 The solution proposed by the VNS was simple: to allocate four
codes from amongst the unused exchange regime codes to identify
vehicles from non-UIC members and then use the “parent railway” code
to indicate the home state of the licensed railway undertaking. In this
way every organisation involved with the movement of vehicles would
recognise them as being outside the normal regimes and would treat them
accordingly. Two of the regime codes were intended for passenger
vehicles and two for freight. The report pointed out that a similar
initiative could be adopted for traction.
5.4.6 The proposal was overtaken by the continuing work on

CODIRAIL which recommended four digit coding of railway
organisations to allow every railway undertaking an explicit code (see
below). This implied extending carriage and wagon numbers to fourteen
digits. When the implications of a change to fourteen digit numbers
5-8
(perceived as having significant costs but offering few benefits) became

clear, the Railned initiative was taken up again and its author formed one
of the group which prepared the RICS study (also see below).
Summary of VNS
5.4.7 It is considered that the VNS report was accurate in identifying the
problems allocating numbers in the new railway environment. Its
solution was simple and neat. It made the implicit assumption however
that the existing system of allocating numbers for UIC members would
continue and that the number was allocated within the industry rather
than being a quasi official mark of acceptance. Both these assumptions
are now under examination. Furthermore it did not suggest how the
numbers within the series reserved for non-UIC railway undertakings
would be allocated, which might be contentious.
5.5 CODIRAIL
5.5.1 The problems with the inadequacy of the current UIC/OSJD

railway coding system and the short term palliatives that have been
applied have been discussed in Section 2 of this Report. The CODIRAIL
project was set up to look at the longer term problem of accommodating
large numbers of railway businesses within each country in the coding
structure again with the intention of providing a code for all railway
purposes.
5.5.2 Views on the coding of railway organisations proved to be

disparate: at the extremes, some railway undertakings were in favour of
quite complex systems involving up to six characters whilst others
thought that the national clearing house (required in any event for
national inter-railway transactions) could accommodate international
issues without any change to the coding structure. The final solution
decided in 1997 was to adopt an unstructured four digit code. Existing
railways with two digit codes would retain these but preceded by two
zeroes. In this way, it was intended that every business in the
restructured environment would have its own code to be used for all
purposes
5.5.3 Steps were taken to introduce this new coding structure in the
accounting function first, which perhaps had the most pressing need to
discriminate between rail businesses.
5.5.4 The implications of this four digit structure on vehicle numbers

were only realised slowly; it implied a move to fourteen digit numbers.
This brought with it changes to almost every computer system and a long
5-9
transitional period in which there would be numbers of differing lengths.

Railways were convinced that costs and dislocation would be significant
and were likewise convinced that there would be little if any benefit to
the commercial business of running the railway. It was decided therefore
not to proceed with allocating fourteen digit numbers to vehicles but
instead study if the effects of railway restructuring could be carried
through to twelve digit numbers with the specific objective of avoiding
mass renumbering of vehicles. This study became the RICS study which
is discussed below.
5.6 RICS Study
Background
5.6.1 The RICS (Railway Interchange Coding System) project emerged

from the CODIRAIL project. The study was set up to investigate how
vehicle numbering could respond to the implications of liberalising the
railway industry. The impetus for the project had come from UIC
member railways’ refusal on the grounds of cost and disruption to accept
a mass renumbering of vehicles to accommodate four digit railway codes.
Instead they wanted a twelve digit system which reflected the new
requirements but preserved as much continuity as was possible.
5.6.2 By the time the project commenced, however, it was becoming

clear that the whole philosophy of numbering of vehicles by railway
undertakings was being called into question. The study accordingly
specifically acknowledged interoperability, the requirements of open
access, the technical approval process, creation of the ERA, new
commercial relationships and changes within the RIV.
Methodology and Findings
5.6.3 The study looked at freight vehicles first, since these are both the
most numerous and were considered to be the priority, in view of the
numbers exchanged. Passenger vehicles and tractive units were to be
considered by the study, but only after the freight vehicle study was
complete. The study is still in progress at the time of writing and the
work that still has to be undertaken is summarised below.
5.6.4 The study was set up in 2001 by the UIC with seventeen
representatives from the principal interests (infrastructure managers,
railway undertakings, coding specialists, IT specialists, finance
specialists and the UIC itself). It was chaired by SNCF. The OSJD was
also represented. Its terms of reference included:
that vehicle numbers must be unique;
5-10
the number must indicate the organisation which allocated it;

the number should be “meaningful”, it should allow the
characteristics of a wagon to be immediately recognised; and
the costs of change should be containable.
5.6.5 Given the driver of a strong resistance to the costs of mass change,
it was not surprising that the study reiterated two basic principles:
vehicle numbers should remain at twelve digits and mass
renumbering was to be avoided; and
the structure of the number should remain the same as currently with
fields for operating regime, parent location, type code, serial number
and check digit.
5.6.6 Two further conclusions qualified these findings:

the operating regime field would require to be redefined as an
“interoperability” field primarily to indicate compliance with TSIs;
and
the parent railway undertaking field would be redefined to be the
parent state rather than the parent railway undertaking.
The paragraphs below deal with each of these issues in turn.
Operating Regime
5.6.7 As noted in Section 2 of this Report, the operating regime field,

the first two digits of the current UIC/OSJD numbering system, is
currently a mixture of commercial, operating and technical criteria. This
field is therefore somewhat mixed. The current practice of the parent
railway allocating the number has masked the extent to which its contents
are not “pure”.
5.6.8 The RICS study proposed to make this first field

“interoperability”, in line with this philosophy the distinction between
exchangeable axles/bogies and single gauge wagons would continue to
be made. The distinction between bogie wagons and axle wagons would
continue to be made and the distinction between vehicles fully compliant
and partially compliant with TSI/RIV standards would be made.
5.6.9 The study’s objective of making this field simply a function of

technical characteristics was however compromised by the desire not to
see change and the need to accommodate distinctions currently needed in
railway operations. Distinctions between the way different types of
vehicle are operated need to be indicated in the wagon number and this is
the only field available for it. Accordingly, the recommendation was that
5-11
the existing distinction between privately owned and RIV railway owned
wagons be continued (under current conditions arrangements for control
of these wagons are different). They did however recognise the
possibility of wagons not being part of a RIV railway’s fleet.
5.6.10 The study also recognised the disappearance of railway-owned

wagon pools. Some way of indicating vehicles for domestic use only is
also required and the study recommended that this be retained. To the
extent that the domestic use is for reasons other than technical, the
question of who will allocate numbers and how arises.
5.6.11 The Consortium further note that if the recommendations of the

RICS study are adopted, traffic vehicles which are demoted to service
use or restricted to domestic operation will still require to be renumbered.
This immediately runs counter to the principal of permanence, which the
study also recommended.
Parent Railway Undertaking
5.6.12 As discussed in Section 2 of this Report, the third and fourth digit
of the number is currently the railway undertaking to whose fleet the
vehicle is attached. The RICS study recognised that this principle could
not be retained since many railway undertakings cannot have UIC two-
digit codes. The study recommended that this field became the country
“in which the wagon was registered” rather than parent railway.
5.6.13 There are a number of issues following from this, not the least the
meaning of “registered”, which could, for example, refer to the state in
which technical approval took place, where a vehicle was manufactured,
where the owner or keeper has his principal office, the state in which an
owner/keeper chooses to base his wagons because of a favourable fiscal
regime or the state from which the vehicle habitually operates. Important
issues arise from each of these choices.
5.6.14 There are two key issues: first, that this field is actually used in
railway operations and; second, the question of how the numbers actually
get onto the wagons.
5.6.15 On the first question, the railway code is used as a surrogate for
“home” in railway computer systems, for confidentiality criteria in IT
systems and in myriad other applications. If this were to mean home
state then many (but not all) of these problems would go away. Home
state would have a meaning similar to that used for personal taxation,
where normally resident.
5.6.16 To identify the wagons, an authority has to choose and allocate

the numbers; allocation of numbers on approval will clearly produce
5-12
different results from allocating numbers on manufacture. Allocation

based on the vehicle’s fiscal home could be logical; it might likewise be
logical to use the keeper’s place of business but a mechanism needs to be
provided to allow the local competent body to act. Issues of “flags of
convenience”, taxation and others have simply been overlooked in the
RICS study. For example, the process of numbering by a competent
authority clearly implies an ongoing policing role of maintenance and
similar issues. This will self-evidently be a problem if the numbering is
distant from operation (for example, the vehicle has been approved in
Greece but habitually operates in Scandinavia).
5.6.17 The text of the RICS report referring to the state “in which the
wagon is registered” would appear to be merely the state in which the
official record of the vehicle is held. It is unclear if the study believes
this will be the country of initial technical approval. If it is linked to
approval then the issue of how to treat subsequent approval of
modifications arises. If it is not linked to approval, the issue of how
numbers will in practice be allocated becomes acute: if the number is a
function of state of approval then issues arise if the vehicle is modified, if
it is not linked to approval then the issue of deciding how the number is
allocated has to resolved and what policing mechanism there will be.
5.6.18 The RICS study team informed the Consortium that the sale of a
vehicle from one state to another would not entail a change of number.
This together with the fact that the state holding the record may well not
be the state in which a vehicle is actually based raises operational issues.
In most railway operating IT systems digits 3 and 4 of the number are
used as an indication of destination when repatriating a wagon. This
information would have to be fed to operating systems from another
source, requiring major IT systems revision. However, this potential
problem is also indicative of the lack of sophistication of most railway
operating systems; nevertheless although this lack of sophistication may
be insupportable in the abstract, in practice the need to replace or upgrade
existing IT systems is a severe impediment to implementation of the
recommendations.
Vehicle Type Code
5.6.19 The RICS study considered that the type code field had proved
satisfactory and that is an adequate range of numbers to accommodate
future designs, therefore no change was proposed.
Serial Number
5.6.20 The RICS study proposed no change to current practices. Note

that since the number format only allows 999 digits, where there are
5-13
currently more than one thousand wagons of a given type (quite often the
case for standard types) additional type codes have to be allocated.
Check Digit
5.6.21 No changes were proposed.
Allocation of Numbers
5.6.22 The RICS study recognised that it was no longer appropriate for
railway undertakings to allocate numbers; it likewise recognised the
variety of approaches to railway regulation in the various states and
proposed therefore that states devise their own solution to vehicle
numbering. This might be numbering by the state itself, by an agency of
the state or indeed by the railway industry subject to safeguards which
the state might apply. As outlined above, unless the process of
numbering is linked to that of approval, the means of allocating numbers
will need careful definition.
Status of the Study
5.6.23 The recommendations for freight vehicles summarised above

were accepted by the UIC Freight Commission in November 2002
together with commensurate changes to UIC leaflet 438-2. Given the
present study, for the UIC railway community to agree change in the
short term might be thought premature. The study was undertaken with
the support of the OSJD and also has their approval
5.6.24 The first draft proposals for passenger stock were produced in
January 2003 and a discussion document was produced for traction
renumbering at the same time. The same principles of a desire to avoid
renumbering and an acceptance of a governmental role in the process
have guided their work. The plan is that the study team will now move
on to develop proposals for tractive stock.
Passenger Vehicles
5.6.25 The RICS group’s proposals for passenger stock follow the
general lines adopted for freight. The number remains structured; the
first field becomes an indication of interoperability overlain with
technical characteristics, the second field state of registration, the third
vehicle type, followed by serial number and check digit as before. The
RICS group proposals are similar to those made by the consortium in
Appendix K. The RICS group expect to pass their proposals through
UIC bodies to get approval for implementation on 1 January 2004
5-14
Traction
5.6.26 The RICS group has produced an interim discussion paper on

numbering traction. It observes that despite the UIC principles (which in
any event leaves considerable flexibility), a diverse variety of traction
numbering systems are in use. It notes that traction is increasingly
expected to cross frontiers and that the numbering system ought to take
account of that. It proposes that any system should create unique
numbers but at a minimum cost of migration.
5.6.27 The discussion paper proposes three possible variants, in each

case the first digit is 9 (the “traction digit”), the third and fourth digits are
the state of registration and the last digit a check digit. The first of these
variants is the status quo in which the second digit is a second check
digit, the fifth a general type code, and digits 6 to 11 are series and sub-
series identifiers and serial numbers. The second option makes the
second digit a general type code and the fifth digit a secondary
characteristic code. The last variant is similar in making the second digit
a general type of vehicle but this time digits 5 to 11 are allocated to
series, sub-series and serial number. The RICS group do not believe that
standardisation in the series, sub-series fields is likely to be worthwhile
but they see merit in a general type code which indicates traction type
and whether a locomotive or unit, etc.
Summary of RICS Study
5.6.28 Much of the work of the RICS group has now been done and the
general principles that have been followed appear to be clear. The
Consortium considers that the RICS study has been diligent in
accommodating the needs of a restructured and more liberalised railway
industry. The proposals of the RICS study however still leave a large
number of, and perhaps too many, unresolved questions.
5.7 The Steria Study
5.7.1 In mid-2001 the UIC invited tenders for a project to design a

centralised rolling stock database. The project had been inspired partly
by comparing the European approaches with the North American
database UMLER. Indeed, preparatory work had already been done by a
seconded specialist from the US. An impetus for the work also came
from a realisation that EU and OCTI requirements would mandate the
creation of a database at some level and there might be value in having a
single database to satisfy all requirements as effectively happens in the
US.
5-15
5.7.2 The remit for the study included design of the functional
specification, the data to be held, the overall architecture and the
provision of financial estimates. The remit recognised the pre-eminence
of freight in the study but also that passenger and tractive stock needed to
be taken into account. The contract was placed by the UIC IT
department under the tutelage of the Freight Department. The contract
for the study was won by the French IT group Steria and the study took
its name.
5.7.3 The study had a strongly technical orientation to resolve such

issues as the size of files, the structure of the data, transmission protocols
etc. Questions of how the proposed database might mesh into the
framework of official databases and how the various parties might have
their interests protected were not to be examined by the study although it
did take note of the requirements set down in the ATMF.
5.7.4 The study presumed current operating practices, conventional

relationships between railway undertakings and the application of
existing rules (for example those of the RIV). The Consortium considers
that this represents a logical base line; current rules are well understood
and changes can be factored in relatively easily. A full analysis of the
needs of UIC members, their customers and third parties (for example
customs) was made. If implemented, the single largest use of the
database is expected to be to initialise a wagon’s technical details before
each journey, a task which is primarily operational and safety related.
5.7.5 The recommendations are for a centralised database holding

technical details of all freight wagons attached to UIC member railways’
fleets fed and interrogated by individual railway undertakings. It is
proposed that variable architecture is provided, holding core data for all
vehicles but enabling some railway undertakings to provide more and for
the database to be extended as necessary. Within the core element, only
technical data will be held, including permanent technical data and
volatile data such as the date that the next overhaul is due. Within the
optional element multipurpose data such as the identity of a long-term
hirer or private wagon owner could be held. There is no intention to hold
journey or traffic data; thus, the file will not develop (as has the US file)
into an all-purpose railway database for operational and commercial
purposes.
5.7.6 As a technical report, the report was silent on proposals for

managing the database and who could participate but that there is an
intention to open it to the entire railway industry is clear. Confidentiality
criteria are foreseen but not defined. The report provides significant
detail for freight vehicles but in explaining that the need for data for
passenger vehicles and tractive stock to be exchanged at the international
level is slight, however, it provides no details of passenger and tractive
solutions.
5-16
5.7.7 From the viewpoint of the present study, the Steria study provides
some pointers to what the railway industry wants to see in a database and
how a railway database might be configured in technical terms. It does
not, however, address the more fundamental question of whether a single
database can adequately respond to official and railway industry needs,
the official needs imposed by Directives and COTIF and the railway
industry needs for a real time technical database. Nor does it address the
question of how such a multi-purpose database might be managed to
reconcile the interests of all the stakeholders.
5-17
Colin Buchanan and Partners Options for Change
6. OPTIONS FOR CHANGE
6.1 Key Objectives
6.1.1 Any system of placing vehicles in service, allocating them with

numbers and then storing, accessing and using vehicle data that makes
use of the number must meet a number of high level objectives. These
high level objectives can be disaggregated into two sets of requirements:
absolute requirements and important requirements. No system which
fails to meet every one of the former set can be accepted, whereas it is
merely desirable that each of the latter set of requirements is met.
6.1.2 Considering the system as a whole, it is considered that the

absolute requirements that the system must meet are as follows:
reconcilability with EC Law;
compatibility with COTIF;
does not obstruct appropriate operation of the Single Market;
be practicable;
be cost effective;
provide no constraints for new railway undertakings;
cover all types of rail vehicles.
6.1.3 Considering the system as a whole, it is considered that the

important requirements are as follows:
flexibility for the future;
ability to accommodate technical innovation;
ability to accommodate new operating and working practices;
provides no constraints for new contractual structures in the industry;
maximal acceptability for all geographic areas;
facilitates good customer interfaces;
facilitates good interfaces with regulatory, control and government
authorities;
facilitates good interfaces between service providers.
6.1.4 The overall objective is to find a system of placing vehicles in

service, allocating them with numbers and then storing, accessing and
6-1
using vehicle data making use of the number that meets every absolute
requirement and best meets the important requirements.
6.2 Key Questions
6.2.1 In deriving a system that meets the objectives set there are a
number of important questions that must be answered. These include:
Who should allocate vehicle identifiers?
In what form should vehicle identifiers and data be stored?
How can a database of vehicle information be reconciled between the
differing requirements of EC law, other international legal obligations
and railway operational requirements?
Who should manage any vehicle database(s)?
What should be the structure of any vehicle database(s)?
Who should have access to what vehicle data?
What constitutes a vehicle?
What form should vehicle identifiers take?
Is there a need for a separate VIN?
If a VIN is required:
- Who should allocate it?
- What relationship should it have to the running identifier and
its database?
- What form should it take?
- Should a database also include serial numbers for major
vehicle components, if so what components?
If vehicles are no longer attached to the fleet of UIC-member railway
undertakings, how is it to be verified that vehicles are appropriately
maintained?
Similarly, without attachment to the fleet of a UIC-member railway
undertaking, how is it to be verified that vehicles are appropriately
insured?
6.2.2 Each of these key questions is considered in turn (grouped by

subject) and the options available for each are listed. The options are
then analysed in the next Section.
6-2
6.3 Placing Vehicles in Service and Allocating Identifiers
6.3.1 The issue of technical approval has already been settled by the
Interoperability Directives, thus the key issues are the procedure for
allocating identifiers and placing vehicles in traffic. Specifically who
allocates numbers and undertakes the administrative necessities
associated with placing vehicles in traffic, and safeguarding that this is
performed in a neutral and non-discriminatory manner.
6.3.2 It has already been found (see Section 3) that it is inappropriate

that the allocation of identifiers and associated processes are undertaken
by national railway undertakings in a liberalised environment and that
this is considered to be incompatible with Community Law. Accordingly
there appear to be nine possible ways that these could be allocated:
by a supranational authority;
by the state1 of vehicle manufacture;
by the state of vehicle approval;
by the state in which the vehicle is used;
by the state in which the vehicle is owned;
by any state of the vehicle owner or keeper’s choice;
by an independent body jointly owned by the rail industry, with
membership automatically available to all;
by any licensed railway undertaking;
by an infrastructure manager.
6.4 Database and Register Issues
6.4.1 In holding vehicle information digitally the first issue that emerges
is what should the structure of the database/register be? The fundamental
architecture choice is between holding data in a single central database or
distributing it in a series of different databases, for example national
databases, that are linked together and can exchange information between
them. At the extreme some data (for example maintenance data) could
be held digitally on board each vehicle and read/reset locally.
6.4.2 A further problem is the differing information requirements

demanded by the Interoperability Directives, Unidroit, the
1
The term state relates to a neutral governmental department or body.
6-3
ATMF/COTIF and railway operational requirements2, in particular the

specific prohibition on any additional information in the ATMF to that
required by the Committee of Experts. This raises further questions on
whether separate databases are required for each and the extent to which
these can be linked together, or whether the requirements can be met by
differing reporting options from a single database or linked set of
databases. Since the option of a common database or databases meeting
each of the above requirements is plainly preferable and is considered by
the Consortium’s legal team to be capable of complying with EC and
international law only this option has been taken forward.
6.4.3 There are considered to be five main options for the structure of
the database(s), as follows:
single central pan-national database;
single central pan-national database, which would drive other pan-
national databases each forming a discrete register/database meeting
a specific requirement (for example rolling stock register,
International Databank, necessary data, railway operating database,
etc);
individual national databases linked together to transfer information
between them and which also would be linked to a pan-national
database or databases, which would do little more than meet
international legal obligations and provide an international reference;
individual national databases linked to pan-national database(s),
through which all exchange of data would be undertaken;
individual national databases with no linkages between them.
6.4.4 Once the broad architecture of the database(s) has been determined
the next decision that has to be made is who should run it? To an extent
this is governed by the option selected, in the case of an international
database the main options are considered to be as follows:
by an international supra-governmental organisation (for example the
ERA or OTIF);
by an international railway organisation (for example the UIC);
membership automatically available to all.
2
For example none of the legal requirements include important railway
operating data such as vehicle capacity. Furthermore railway operating data
needs to be kept continuously up-to-date.
6-4
In the case of national databases the main options are considered to be as

follows:
by national governments or governmental bodies (for example
national rail safety agencies);
by the national infrastructure manager;
membership automatically available to all;
by some other independent national body.
6.4.5 Equitable access rights to information held on vehicle databases

and other railway IT systems has emerged as a key issue from this study,
there is an important need to balance openness against the needs to
restrict access to information that is genuinely confidential. The
Consortium have few doubts that there is a tendency on the part of
several national railway undertakings to claim that almost anything is
confidential and to use this as a protectionist tool to prevent would-be
rivals gaining access to vital operational IT systems3. It is therefore
considered vital that firm legal definitions are imposed on the
information that can be considered confidential (see Section 9 of this
Report for proposed definition). There is a trade-off between access and
confidentiality. Where a decision has to be made between equality of
access and maintenance of confidentiality comparison of the case studies
for Germany and Great Britain indicates that liberalisation of access to
systems is more important than restriction of access to confidential
information.
6.4.6 As noted previously the international legal obligations define those

who should have access to the information held on the international
vehicle databases and registers, for example having to be publicly
available in the case of the rolling stock register and the International
Databank for example. Nevertheless it is considered that mandatory
access rights are essential to all national railway operating, etc, systems
that use vehicle data for all licensed railway undertakings and vehicle
keepers. Naturally, these access rights must be equal and non-
discriminatory. This is considered to be an essential pre-requisite to
achieve EU policy in the sector and is discussed further in Section 9.
6.5 Definition of a Vehicle
6.5.1 As has already been noted in Section 2 there are two issues where
the meaning of “vehicle” needs to be clearly defined: what is defined as
3
See Appendix I for a definition of what “vital operational IT systems”
comprises.
6-5
a single rail vehicle and the retention of identity after major rebuilding.
The draft TSI for conventional rolling stock provides no definition of
what constitutes a vehicle accordingly it is considered that one is needed.
It is understood however that the Railway Working Group established in
drawing up the UNDROIT convention has been developing a definition
of a rail vehicle.
6.5.2 The Consortium does not consider that it is appropriate to list a

range of options in this area, accordingly only a recommended definition
is given in Section 9.
6.6 Form of Identifier
6.6.1 There are an infinite number of potential numbering systems

however it is considered that the list of those that are plausible is limited
to those given below in Table 6.1. In this table a spot means that the
option is plausible/possible, whereas a cross indicates that it is not and
has not therefore been considered further.
Table 6.1 – Potential Numbering Systems
Without With
Numbering System
VIN VIN
No change to present numbering systems z z
Universal1 UIC 12 digit z z
Universal modified UIC 12 digit2 z z
Universal OSJD 8 digit z z
Universal AAR 10 character z z
Universal 8 digit structured z z
Universal 12 digit structured (non-UIC based) z z
Universal unstructured 8 digit z X
Universal unstructured 12 digit z X
6-6
Without With
Numbering System
VIN VIN
New system for new vehicles only (existing vehicles

z z
retain their old numbers) - modified UIC system

z z
retain their old numbers) - OSJD system

z z
retain their old numbers) - AAR system

z z
retain their old numbers) - structured 12 digit system

z z
retain their old numbers) - structured 14 digit system

z z
retain their old numbers) - unstructured 8 digit system

z z
retain their old numbers) – unstruct. 12 digit system
Vehicle keepers free to choose between a system of

z z
their own and modified UIC system

z z
their own and OSJD system

z z
their own and AAR system

z z
their own and structured 12 digit system

z z
their own and structured 14 digit system

z z
their own and unstructured 8 digit system

z z
their own and unstructured 12 digit system
Free choice of system for vehicle keepers z z
6-7
Notes: 1. Universal means applied to all vehicles operating on a national rail system
in Europe.
2. First four digits modified to make non-discriminatory (see below).
6.6.2 In the case of an unstructured system it is assumed that the number

will be permanently allocated to a vehicle, it is therefore illogical to
combine this with a separate VIN. Accordingly in Table 6.1 for systems
where every vehicle in Europe has an unstructured number the options
which include an additional VIN have not been included.
6.6.3 It is considered that there are three areas where the current UIC
twelve digit system would benefit from modification to better meet
Single Market objectives: these are the exchange regime code (first two
digits), the railway undertaking identifier (third and fourth digits) and the
need to identify TSI compliant vehicles. In the first case a coding system
that separately identifies railway owned and privately owned vehicles
and demands that they be treated and charged differently has clear
problems from a Single Market perspective (whichever way the
advantage falls), all vehicle keepers should be able to select their
operating regime and charging system. Secondly, as discussed in Section
2, there are insufficient railway undertaking codes for a liberalised
environment, the most logical solution appears to be to change the UIC
member code to a national identifier. Thirdly, widespread support was
obtained from respondents interviewed in the course of the study for the
concept that TSI compliant vehicles should be instantly identifiable by
their number, it is proposed that this is indicated within the first two
digits. These three changes are referred to as the “modified UIC twelve
digit system”.
6.6.4 If a structured system is selected a decision has to be made about

what information should be/needs to be coded into the number. Possible
information includes:
compatibility with TSIs or other technical standards;
vehicle characteristics;
owner/fleet manager responsible;
state of ownership/use;
charging information;
usage regime (“can I use it”);
maintenance regime (“who should maintain it”);
liability regime;
serial number of vehicle;
check digit.
6-8
6.6.5 Whatever numbering system is adopted it is considered that it

should be accompanied by symbols and lettering describing the vehicle
characteristics as at present. Accordingly there are no alternative options
in this regard. However, the extent to which this information meets the
needs of the information that would otherwise be contained in any
structured number must be considered.
6.7 VIN Issues
6.7.1 If VINs are applied to vehicles it may be appropriate for them to

be allocated by different bodies to running numbers. For security reasons
it is considered appropriate that any VIN is allocated at the earliest
possible stage of a vehicle’s life. It is further considered that it is
unimportant whether all vehicles which are allocated VINs are actually
built or not; cancellation of orders may result in gaps in number
sequences but this is considered to be of no consequence. Similarly it is
not material whether particular vehicles are approved for operation or
not; even if a vehicle is ultimately refused technical approval to operate
anywhere on the European rail system it is still an asset on the books of
its owners and it also needs to be recorded as a non-compliant vehicle for
future reference.
6.7.2 The issue of VIN allocation is wider than operation on the

European rail system, as some vehicles will fall outside the need to
allocate running numbers as foreseen for this Study. For example
vehicles used internally by industrial customers or used on railways not
forming part of the European rail system. These vehicles may
subsequently appear on the European rail system and also are assets
which financiers need to track and thus need VINs. It is therefore
considered that any mandatory requirements for VINs apply more widely
than the purview of the Interoperability Directives, COTIF, etc.
6.7.3 It is considered that the possible options for the bodies responsible
for allocating VINs are as follows:
vehicle manufacturers/rebuilders;
by a supranational authority;
by vehicle approval body;
by the state of vehicle manufacture/rebuild;
by national infrastructure manager or safety authority;
membership automatically available to all.
6-9
6.7.4 It is a fundamental principle of a VIN that a number is only

allocated once, so that when a vehicle is scrapped, this is marked against
the number and it is retired. As there are getting on for two million
vehicles in Europe it is clear that an eight digit number would provide a
sufficient number of combinations for well over a century into the future.
However, if it is desired to structure the number to convey information a
greater number of digits will be required to provide the necessary number
of combinations. Information which could be coded within a VIN
includes:
manufacturer identity;
plant of manufacture;
state of manufacture;
date of manufacture;
lot or batch information;
state where orderer is based;
type of use manufactured for;
serial number.
6.7.5 The form of a VIN also impinges on the technology used; a VIN
might not be a conventional number at all but could be an electronic tag
or a bar code for example. One of the key functions of a VIN is to
attempt to prevent fraud; in particular wagons can wander over almost
the entire European rail system (and beyond) without supervision from
their keeper. Thus if a VIN consists of a number painted onto a vehicle it
is entirely conceivable that these numbers could be adulterated and the
vehicles misappropriated. VINs therefore need to be tamperproof, to the
extent that it is both practicable and cost effective. Thus if one discounts
painting VINs on a vehicle (other than as a secondary means of
identification), the possible options include:
stamp VIN into vehicle structure;
permanently affix cast plate to vehicle bearing VIN;
irremovable self-adhesive label bearing VIN, possibly incorporating
other security devices such as holograms and/or barcodes;
electronic tag, possibly also used to store other vehicle data.
6.7.6 The fundamental measure to provide value in the system is to

provide a searchable database enabling vehicles to be identified and
sought. This implies a need for a database which links VINs with
running numbers, however the database is managed. It is considered that
there are only two credible options for the management of the database:
6-10
as a part of the overall database(s) of vehicle numbers and data;

discretely as an International Databank meeting the requirements of
Unidroit, but linked to the other database(s).
6.7.7 A VIN would be allocated to a vehicle structure, however, a

considerable proportion of the value of a vehicle is invested in its
components4. There is therefore a case for major components, which are
transferable to be separately identified and linked to the main VIN in the
database, a link which would only be changed if the components were
resold or legally exchanged5. The list of components that the Consortium
considers should be included is given in Section 9.
6.7.8 If a system of VINs is applied it will be desirable to apply them to

existing vehicles, so that the system as a whole is “watertight” and
workable and so that interests can be registered without need to recall
vehicles for marking. Many vehicles already have unique identifier in
the form of a manufacturer’s works number, which is often either
stamped into the vehicle chassis, painted on the vehicle, or affixed to a
plate. However, some of these numbers have been lost and are, in any
case, of differing formats. The following options for allocating VINs to
existing vehicles appear to exist:
use manufacturer’s works number;
base VIN on current running number;
allocate an entirely new sequence of numbers.
It is recommended that preserved vehicles that are over forty years old be
excluded from any requirements to apply VINs retrospectively.
6.8 Maintenance and Insurance
6.8.1 As noted in Section 2 the present system provides safeguards that

vehicles are appropriately maintained at least insofar as vehicles in
international operation are concerned. Changes to the system for placing
vehicles in service, changes in the arrangements under which vehicles
operate in traffic and liberalisation and open access all mean that the
4
For example, manufacturers state that a wagon chassis and body only
comprises around 30% of its cost, which if sophisticated bogies are fitted can be
less than the value of the bogies alone.
5
It should also be noted that it is also necessary for owners and maintainers to
be able to identify components for traceability in the safety audit process.
However this is considered to be a separate issue, with the exception that it is
plainly appropriate to use the same component numbers for both purposes.
6-11
methods of verifying that vehicles are appropriately maintained must be

reviewed.
6.8.2 It is considered that the concept of requiring vehicles to be

attached to the fleet of a UIC member railway undertaking is
incompatible with the free operation of the Single Market. The 1999
COTIF however presumes a contract for use with a railway undertaking
to regulate the many interfaces between the parties. This provides a
potential legal conduit to funnel the many relationships including those
of liability and maintenance6. For example this relationship provides a
means to funnel back information on the work the wagon does so that the
fleet operator can base his maintenance on the work the wagon does. It is
not yet clear however whether new contracts between keepers and
railway undertakings will have universal applicability. If contracts do
not cover the entire railway industry then new arrangements are required.
The TSIs on maintenance do not appear to provide the necessary
safeguards either, for example the high-speed maintenance TSI being
concerned with the interfaces with toilet discharge systems and with
water and power connections.
6.8.3 Accordingly it is considered that arrangements are put into place

providing consistent European rules to verify that vehicles are
appropriately maintained, but which also enable a Single Market in
vehicle maintenance systems to flourish and give owners, keepers, etc,
appropriate freedom of choice. It is strongly recommended that
prescriptive standards are not adopted, except where these are both
absolutely essential and entirely non-controversial.
6.8.4 It is considered that the solution lies in requiring vehicle keepers to

have their maintenance regime and practices audited either by a notified
body or the independent national railway licensing/safety authority and to
lodge an annual deposition from the relevant body to the effect that an
audit has been carried out and that these are still satisfactory. In the
event that this deposition is not lodged all vehicles under the
responsibility of the keeper concerned would be prohibited from normal
use on the European rail system. This has a further implication that it
must be possible to instantly identify vehicles from a “rogue keeper”
either via the vehicle identifier or through the vehicle database. There
are a number of options for managing this, as follows:
by a supranational agency (for example the ERA);
6
The Consortium is not altogether comfortable with this approach however, for
example, vehicle leasing companies should be able to provide any vehicles
freely for hire by any party or railway undertaking and without a railway
undertaking to whose fleet it is attached being able to track its movements.
Nevertheless it will become international law and the Consortium’s concerns
are therefore of little consequence.
6-12
by the national rail safety authority;

by whoever manages the vehicle database;
self-regulation;
“British solution”, see Appendix F for a description.
6.8.5 The issue of making sure that every vehicle circulating on

Europe’s rail system carries sufficient insurance to pay for incidents and
damage that they might cause is closely linked to the issue of verifying
that vehicles are appropriately maintained. As has been noted in
Section 2 the present indemnity arrangements have become inappropriate
for national railway undertakings as they have moved onto more
commercial footing. A conventional insurance solution appears
inevitable.
6.8.6 It is considered that the solution lies in making each keeper

produce a certificate of valid insurance covering the next twelve months,
annually. There are a number of bodies which could manage this
process, as follows:
a supranational agency (for example the ERA);
national rail safety authorities;
national infrastructure managers;
whoever manages the vehicle database;
self-regulation.
6.8.7 It should be noted that this proposed solution is similar to that

required for road vehicles where, generally, each vehicle has to undergo a
government technical inspection every year and to have its insurance
documents submitted for inspection. However, in rail the result would be
considerably simpler and less bureaucratic in operation, since rather than
the tens of millions of individual vehicles and their details being
inspected every year, as happens for road vehicles, it would only be
necessary to inspect the bona fides of each vehicle keeper and railway
undertaking to be verified, amounting to a few thousand checks in a
liberalised environment.
6-13
Colin Buchanan and Partners Analysis of Options
7. ANALYSIS OF OPTIONS
Legal Analysis
7.1.1 EC law does not explicitly require a specific procedure for

allocating numbers and placing vehicles in service. It merely puts some
limiting conditions on the arrangements. The procedure will have to be
neutral and non-discriminatory for all applicants whether UIC-members
or not and whether private owners or not.
7.1.2 The question of who should allocate the numbers and place
vehicles in service is to be answered by taking into account these same
principles. If the body or state that will be charged with the numbering
and placing in service is also responsible for safeguarding the neutrality
and non-discrimination, this will be difficult to reconcile with the duties
of an infrastructure manager (see also RWP-II) and with railway
undertaking activities (see especially Directive 91/440/EEC).
Technical and Practical Analysis
7.1.3 The use of a supranational authority to allocate numbers and place

vehicles in service, whilst it may be the arrangement most likely to
guarantee neutrality and independence it is also the one which is most
likely to prove bureaucratic, inflexible and to have costs that are hardest
to control. It also has the disadvantage of being physically remote from
applicants in another state; however as the function is primarily
administrative in the age of digital communications this is of little
importance. Potential language difficulties need careful thought for cases
in which a discussion is needed or when standard forms do not suffice1.
Conversely a single authority should enable more rapid responses to
changes in technology or working practices, since only a single body
would need to change, rather than trying to co-ordinate simultaneous
changes by upwards of thirty independent national bodies.
7.1.4 The points made above in respect of bureaucracy, inflexibility and

difficulty of controlling costs apply to all of the options involving
governmental bodies undertaking the tasks, albeit to a slightly lesser
extent. The problems of independent national bodies jointly reacting to
change have been discussed above.
1
At a quick count, approximately twenty-two different main languages are
involved.
7-1
7.1.5 If a system is adopted which operates on a national basis, the issue

of which state is actually responsible in each case is a significant one
which needs to be clearly defined. As defined in Section 6 there are a
number of options: the state of manufacture, approval, use, ownership,
or by any state chosen by the vehicle owner/keeper. Viewed from one
perspective it can be argued that it does not particularly matter which
option is adopted as long as the matter is clearly defined, since in every
case the body will be a responsible governmental organisation.
However, the Consortium consider that some options are preferable to
others; the option of vehicle keepers selecting an approval state might
lead to accusations of “flags of convenience”, however this should also
facilitate the Single Market, giving owners/keepers an option if there is
problem with the independence of the body responsible in a particular
state. It is further considered that there are slight interface advantages if
the state concerned is either the state of ownership or the state of use.
7.1.6 The use of an independent body jointly owned by the rail industry
as a whole has a number of advantages; the example of Great Britain (see
Appendix F) shows just how well such a system can work. Potentially it
combines the advantages of a pan-European supra-national body with
greater flexibility, responsiveness and control over costs. The
disadvantages lie in the possibility that a joint industry body might
become a “closed shop”, excluding new entrants. However this is merely
a risk; which could be excluded by providing an appropriate constitution
and structure for the body.
7.1.7 From a practical viewpoint, although the option of allowing any

licensed railway undertaking to accept vehicles into service and allocate
numbers would represent a liberalisation of the present system it would
still tie vehicle keepers to particular railway undertakings even if the
vehicle is only to be used domestically2. The system would also only
work if a railway undertaking code is to continue to be a part of the
identifier, something that appears to be difficult to achieve in a
liberalised environment with a proliferation of railway undertakings if a
twelve digit number is to be retained (see below), otherwise duplication
of numbers is practically inevitable. This option is also likely to be one
that will find it hardest to respond to change; co-ordinating and
implementing changes in the system where there are several thousand
railway undertakings is a task bordering on the impossible.
7.1.8 Allocating the tasks to the infrastructure manager would appear to

be more appropriate than allocating them to railway undertakings not
least because, generally, there should only be one per state, avoiding the
proliferation of agents. If all infrastructure managers become genuinely
independent from national railway undertakings this option can be
2
Although if the vehicle concerned is to be used internationally the 1999
COTIF requires this anyway, despite the Consortium’s competition concerns.
7-2
considered to be similar to the options of using national governmental

bodies from a technical and practical standpoint.
Migration Analysis
7.1.9 It is not considered that there are any particular migration issues
associated with any of the options; the new organisations or departments
can be set up and the associated systems put into place and rapidly
introduced, without any impact on any other aspects of the rail industry
or any disruption to IT systems, etc.
7.2 Database and Register Issues
Legal Analysis
7.2.1 This issue is closely linked with the numbering and placing in
service (see above). If the numbering and placing in service is
undertaken by railway undertakings themselves, the institution of an
independent body will be required to manage the database, to safeguard
the neutrality and non-discriminatory behaviour of the railway
undertakings and to give equitable and non-discriminatory access rights
to applicants.
7.2.2 Of the options discussed in Section 6, holding data in a single

database is not in line with the requirements of the interoperability
directives. These lay down national rolling stock registers and national
registers on the placing in service (after RWP-II).
7.2.3 The other options are considered to be compatible with EC law.
The Starting Point
7.2.4 The railway industry benefits from having a significant number of

existing databases. Whilst these are designed to different standards and
hold differing amounts of information with differing arrangements for
management, updating, etc, in general the data held is to a common
standard. Field lengths and meanings are common (for example tare
weights of vehicles are always in kilograms, lengths over buffers in
decimetres, etc). This standard approach makes the job of constructing
an international database easier and permits distributed solutions which
otherwise would not be possible.
7-3
7.2.5 Technical data for vehicles has been exchanged between railway
computer systems for some twenty years to support international freight
train operation, albeit not as effectively and universally as would be
desired. It is understood that this issue is currently being addressed by a
separate research project funded by the EC.
Objectives
7.2.6 Different members of the railway industry require differing data to

different levels of abstraction and updated to differing standards. The
question of an international database therefore needs to be studied as a
matrix of different requirements measured against different users.
7.2.7 In designing a database system the objectives of not duplicating

data, keeping users close to data and reducing data transfer to a sensible
minimum have been adopted. It has been assumed that in addition to
official needs (databases defined under interoperability legislation, those
required under COTIF legislation and any needs identified to monitor
maintenance and liability) there is a need for railway undertakings and
infrastructure managers to have a ready source of authoritative
information. This information is to help them use vehicles efficiently
and safely and include (for example) vehicle capacity and the presence of
train heating circuits. It is also clear that the design of the database must
consider the design approval process as this feeds the initial record into
the database. Likewise it is considered that administrative supervision of
maintenance and liability will need to be closely linked to vehicle records
held on the database.
Relationship to Unidroit
7.2.8 It appears that Unidroit register of interests will have to be a

separate database, both because its legal and management status implies
that and also because uniquely it is a register of interests rather than a
register of rolling stock. That it is a separate database does not prevent
links being created between it and any other master file (see further
comments below under “Vehicle Identification Numbers”).
National Databases
7.2.9 The future of national databases comes into the question of the
design of the international configuration. In most EU states “national
databases” are in fact controlled by national railway undertakings being
linked into operating systems that they also control and integrated into
their business fabric. These databases need to evolve to assist
liberalisation by being opened to other operators. It would seem most
likely that there will be a move towards national databases including all
7-4
vehicles with the active encouragement of supervisory authorities in the

states in question3.
7.2.10 It is axiomatic that whatever solution is adopted for the

international database, railway interests will want to retain a national one
for national purposes. It is also most likely that access to databases (to
enquire or update) will come from within the state itself. This does not
of course prevent the smaller or more closely linked states in Europe
from running common systems and databases in conjunction with each
other or with other states. An analogy can be seen in North America
where despite the central systems provided by Railinc (including
UMLER) Class 1 railroads all run their own systems.
7.2.11 The option of using national databases would mean that each
would have a twin function of being a storehouse of all the data for
vehicles from its own state and a temporary storehouse for data for
vehicles from other states temporarily in the state in question. The logic
of the temporary record being to allow the state with the vehicle the
authority to update its record in the case of repair or maintenance work.
Single Central Database
7.2.12 A single central master database, whilst superficially seductive,

would raise the issue of how data would be fed to it and how it would in
turn supply data. The question would be what value the central database
would add. It is difficult to avoid the conclusion that there would be
duplication in having an international database holding the same data as
national databases. This would raise questions of which was
authoritative and in all probability it would be the national databases,
which would be the primary sources of data and therefore authoritative.
Links to and from a central database also need to be considered and the
question of the value added by transfer of data to and from a central
database would have to be answered.
Linkages Between Databases
7.2.13 For a European system based on national databases to work

effective linkages between them are essential, so that they appear to users
as a single database. Responsibility for holding the record of a vehicle
would need to lie with the state indicated as the state of registration in the
third and fourth digits of the running identifier. The central element to
the database would thus be conceptual rather than physical, enquiries
could be made via any national database which would then pass them
forward as necessary.
3
The obligation on Member States to prepare registers under Directive
2001/16/EC is significant in this respect.
7-5
7.2.14 Unless permanent (unstructured) running identifiers are used, the

master key to the records will be the VIN (see below). The operating
identifier would then be a secondary key. It is to be expected that the
majority of updates to technical files would be based on the VIN, but the
majority of enquiries would be based on the operating identifier.
7.2.15 If permanent unstructured identifiers were adopted the system

described above would be practically unworkable, since there would be
no national identifier to indicate who should maintain the record and on
which database it could be found.
Database Management
7.2.16 Management of such a database is clearly an issue that needs to

be addressed. EU legislation places the primary duty on Member States
and COTIF on its Central Office (but with the power to delegate). The
question will be determined by the database structure adopted, however
the option of using linked national databases is consistent with this.
Nevertheless some supranational management, with real power, is
imperative to forge effective links between the national databases and
thus make the system work. This could possibly be undertaken by the
ERA.
Migration Analysis
General Comments
7.2.17 Migration issues are a significant determinant of the optimum

database strategy. In making the necessary changes to existing systems,
there are two imperative requirements: firstly rail systems must operate
properly and continuously during the transition period, secondly the
benefits sought must be delivered as cost effectively as possible.
National Database Option
7.2.18 The initial assumption must be that the responsibility for the
management of the national database, both freight, passenger and
traction, will pass to some independent national organisation. This could
consist of national authorities constructing a database from new or taking
over an existing system. This does not prevent any organisation retaining
its own database, but it could no longer be regarded as the authoritative
database for official purposes.
7.2.19 The migration would therefore consist of the enhancement of

those databases, firstly to include all types of vehicles (some existing
databases exclude passenger or tractive equipment). Secondly databases
need to be enhanced to include all the data required for official purposes
7-6
(such as details of technical approvals and compliance records). Lastly

the databases need to be enhanced to include all such data that the EC,
regulatory bodies, railway undertakings and infrastructure managers
consider to be necessary (although most will have been derived from
systems which already have this). Input from such groups as the AEIF
group on “telematics” can be expected to form a major part of this work.
Note that these databases need not be identical in design, but they would
need the same “international” functionality. In view of previous poor
performance in this area, mandatory specification and enforcement of
interfaces will be required.
7.2.20 The programming of appropriate standard data-exchange

protocols, the construction of standard confidentiality filters, creation of
interfaces with industry partners, documentation and training would
follow.
7.2.21 All vehicles from the state in question including those from new
entrant railways would then be loaded on to the database.
Single Central Database Option
7.2.22 In contrast to the option of using linked national databases, the

adoption of a central database model would imply the construction of a
new system. This need not of itself be complex but arrangements so that
it always has the most up to date information would need to be put into
place. Particular difficulties would reside in the question of keeping
national and central data consistent.
7.2.23 Migration to a central system would involve the construction of

national databases as described above to fulfil the obligations placed on
the states of having their own databases. The same stages of populating
the national databases would have to take place and then finally the
subset required internationally and responsibility for it would be
transferred to the central system. A management structure and
responsibility would need defining and training of staff would be
required. In modern terms the central system need not be that large, for
purposes of comparison both the British national datafile and the US
UMLER file currently have about seven hundred characters of
information for each vehicle.
7.2.24 The alternative of a simple central system with just reference data
and message switching software would paradoxically have the greatest
programming complexity. The same stages of development would need
to take place, as discussed above, save that the physical transfer of data to
a central site would not be needed.
7-7
7.3 Form of Identifier
Legal Analysis
7.3.1 The cast in which any new identifier has to be moulded, is not
compulsory instructed by EC law. The Commission proposal on
changing the interoperability directives merely prescribes an
“alphanumeric identification code” that has to be assigned to each
vehicle when authorised to enter service. Accordingly it is considered
that any of the options identified in Section 6 is equally capable of being
compliant with EC law.
7.3.2 Limiting conditions that need to be considered in the preceding

statement are the need to safeguard an equitable and non-discriminatory
access to the “identifier”.
Structured and Unstructured Numbers
7.3.3 Of the twenty-six different systems identified the first fundamental

issue that needs to be addressed is that of the relative merits of structured
and unstructured numbers.
7.3.4 Possibly the greatest drawback of a structured number is that

because vehicle attributes are coded into the number, every time that
these change the number changes. Accordingly a structured number
cannot be a permanent identifier and thus a separate VIN will be required
to give a permanent identifier. Meaning that every vehicle will carry two
numbers and which need to be linked together in databases and registers.
7.3.5 In contrast an unstructured number can be permanent, meaning

that a vehicle need only carry one number. However, the number itself
conveys no information other than being a unique identifier. This is not a
problem for a modern database and IT system which could instantly
produce the details coded in the present number (and more), but it would
produce problems for most national railway IT systems in Europe
(outside Finland, Ireland and the UK) which make use of the structure of
the conventional twelve digit number for hauled rolling stock,
undoubtedly leading to resistance to change from many quarters, making
the option of unstructured numbers unattractive.
7.3.6 Further problems with unstructured numbers arise where no access

to a modern IT system is available to staff “on the ground”, as applies in
many locations outside the eastern border of the EU, meaning that staff
are unable ascertain anything about a vehicle from its number. However,
this concern is only relevant to wagons operating in wagonload and part
7-8
trainload operations and most information contained in the number is

available by studying the markings on the side of wagons and the
consignment documents. This issue turns on the value of coded
information beyond this extra information, which is available on
inspection. The Consortium are not convinced that the extra value of a
structured number in this context is particularly great, although some
changes to existing practices might be required (for example
consignment notes on all empty wagons where satisfactory universal IT
systems do not exist) these should be relatively simple and cheap to
implement.
7.3.7 A more significant problem with a move away from structured

numbers is that charging systems for the international use of vehicles
work off the structure of the vehicle number and that unstructured
numbers would destroy the basis of present charging systems. In contrast
if structured numbers are retained multi-operator environments can be
dealt with through national clearing house type arrangements “piggy-
backed” onto existing systems.
A Change from Twelve Digits
7.3.8 As can be seen in Appendix H twelve digit numbers for hauled

rolling stock are deeply embedded in the national IT systems of the states
where twelve digit numbers are the common national system. This
effectively means all EU states with the exception of Finland, Ireland and
the United Kingdom and all CEEC states with rail systems with the
exception of the Baltic States.
7.3.9 Changes in the number of digits would have a more profound

effect than changes in the structure of a twelve digit system (which
would still necessitate IT system modifications and changes in the
intellectual investment in staff). Accordingly to change from a twelve
digit system in there would have be benefits achieved by such a change
that outweighed the costs of change and which cannot be achieved by a
modification of the twelve digit system. Considering the EU and CEEC
states alone, the Consortium cannot find any such benefits. This would
imply that the running identifier should remain at twelve digits.
7.3.10 There is one other factor to consider; it is clearly desirable to

harmonise the numbering systems of Western and Central Europe and the
CIS. As noted the OSJD system is an eight digit system and there are
more railway vehicles running in the CIS and “its satellites” than in the
remainder of Europe. It could therefore be argued that it would be more
appropriate to adopt a universal eight digit system throughout the entire
European area. Set against this however is the fairly rudimentary nature
of IT systems “on the ground” throughout the CIS area. The cost benefit
analysis has indicated that the costs of adopting a twelve digit system in
7-9
the CIS area would be less than that of an eight digit system in Europe,
which also has a greater functionality. This is supported by the
discussions held during the course of the study with the OSJD, which
expressed willingness, in principle, to adopt a twelve digit system if an
appropriate system can be devised.
7.3.11 The other harmonisation measure that would involve a change

from twelve digits would be to adopt the AAR ten digit system. This
would have two benefits in that it would create a world standard and it is
a system supported by advanced IT systems available on a proprietary
basis, which would facilitate common European IT standards. However,
the downsides are considerable: every vehicle in Europe, the CIS, the
UIC and OSJD areas would require renumbering and it is an alpha-
numeric system which would cause significant problems in areas that do
not use the Latin alphabet.
Continuation of Existing Systems Alongside a New System
7.3.12 It is impractical to renumber over 1.5 million vehicles

simultaneously, especially given the geographic area involved and the
distribution of vehicles within it. Accordingly old and new systems must
co-exist; this is a migration issue, discussed below. This family of
options, however, relates to the long term retention of existing systems
alongside any new system.
7.3.13 The advantage of this option is that no vehicles need to be

renumbered as only new vehicles adopt the new numbering system.
There are a number of downsides, however, these include: the need to
keep existing IT and manual systems running alongside new systems,
with consequent complex interface issues, problems in constructing a
workable database with vehicles numbered under different systems, the
non-sustainability of the existing UIC system and the potential for
confusion.
7.3.14 Accordingly continuing existing systems alongside a new one

while superficially attractive and likely to go down well with existing
owners it is not considered that is a feasible option.
Giving Owners/Keepers Freedom of Choice
7.3.15 Giving owners/keepers complete freedom of choice has the virtue

of complete liberalism; unfortunately it is also a recipe for confusion,
duplication of numbers and an unworkable proliferation of incompatible
systems. What might happen if owners/keepers have complete freedom
of choice can be discerned from the example of Germany (see Appendix
E), where the proliferation of railway undertakings and the retention of
the international numbering system by the state railway has led to a
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proliferation of numbering systems. Although since the international

numbering system is still available to owners, where vehicles are
exchanged, the situation is less confusing than it might be.
7.3.16 If owners/keepers are to be given freedom of choice, the system

can only be workable if there is an agreed common system for vehicles
that have to be exchanged or pass between different infrastructure
managers. In essence this would defeat the concept of freedom of choice
for most vehicles used on the common European rail system and so it
would still be essential that this common system is open and non-
discriminatory.
7.3.17 There appears to be no reason, however, that owners/keepers

should not have total freedom of choice for vehicles which are not used
on the common European rail system (for example, on isolated lines and
networks).
Relationship with OSJD System
7.3.18 See above.
Information Contained in Operating Identifier
7.3.19 The only information which is unquestionably required in a

unique serial number to identify the vehicle, indeed in an unstructured
number that is all that the number consists of. The other options for the
information that is included within the number are matters for debate.
7.3.20 The consultation process for the study has indicated widespread
support for the concept that vehicles’ interoperability characteristics/TSI
compliance to be coded into the running identifier. If a structured
number is adopted it is considered that this is possibly the most important
attribute that should be coded into the identifier, probably as a part of the
first two digits.
7.3.21 As noted in Section 2, the first two digits in the existing UIC
numbering system for hauled vehicles are the exchange regime code and
is currently a mixture of commercial, operating and technical criteria.
Whilst it is not appropriate to distinguish privately owned vehicles, so
that they can be treated and charged differently it is appropriate that there
are different exchange and charging regimes, freely selectable by vehicle
owners/keepers. Whether this needs to be coded into the number is an
issue that is more open to question, the desirability of doing this is driven
by the integration of current charging codes with this field. The same
comment applies to technical information such as whether the vehicle is a
bogie vehicle or not.
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7.3.22 If a structured number is adopted based on the present twelve

digit system one of the obvious characteristics that can be coded in is a
national identifier, using the third and fourth digits of the number. The
need for a national identifier is governed by two factors: the method of
allocating numbers and railway operating practices. If numbers are
allocated on a national basis, national coding will be required so that each
number is unique. As discussed in Section 2 of this Report national
codings are currently used by staff to return vehicles to their “home
state” as soon as they are empty. It is however hard to defend the
efficiency of this practice, which unquestionably contributes to the poor
backload performance of rail.
7.3.23 The next four digits of the existing number are the type code for
the vehicle, again these are used by existing IT systems to search for
appropriate vehicles to meet traffic needs and their loss is likely to lead to
transitional issues.
7.3.24 The extent that the above pieces of information can be

accommodated, will be largely governed by the format of the number
selected. Sufficient allowance is also required for technical and
commercial developments requiring increases in the number of codes
required.
7.3.25 It is considered that there is little case to code in any information

that is not currently provided, with the extent of TSI compliance. More
advanced searchable databases are postulated by the study, which can be
expected to gradually reduce the need to code information within the
number structure4; the principal need to do this is mainly driven by the
need to keep existing IT and manual systems running.
7.3.26 The recommended information that should be included within the

number and its format can be found in Section 9.
Migration Analysis
General Comments
7.3.27 Two basic sets of solutions may be identified, those that

essentially modify the present twelve digit structure only slightly and
those that make a fundamental break with the past. In the first group
come the proposals for allocating vehicle numbers by state of ownership
or use coupled with the allocation of a VIN. In the second group come
the solutions involving permanent unstructured numbers and solutions
4
One exception to this is the national coding, which if the recommended option
of using individual national databases to store vehicle data, the national code
will be required to find the appropriate national database to search.
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based on AAR or CIS numbering principles. The paragraphs below

explain migration paths for those two types of solution.
Fundamental Break with the Past
7.3.28 The characteristic of this group of solutions is the abandonment

of the existing structured numbering system. This existing structured
numbering system is currently used for operating, commercial and
technical purposes (as explained in Section 2 and in more detail in
Appendix H). For this reason alternative means to perform these
functions will need to be programmed into railway computer systems
before any renumbering can start. Fortunately the changes currently
being made to the RIV system seem likely to align the regimes for
railway owned and privately owned vehicles. Nevertheless, the software
changes required to accommodate a change of structure are quite
significant, doubly so where the existing twelve digit format is replaced
by an alternative format.
7.3.29 If a new number structure also reduces the amount of information

held in a number structure as well, the software changes will also require
characteristics which are at present implicit to be held explicitly in
databases (for example if the state in which the vehicle is based if it were
to be no longer coded in). The software changes will require a database
to be consulted for basic characteristics of a vehicle every time that a
decision on how to deploy it is to be made. Secondly because the ability
of staff to recognise characteristics from number series will have gone,
alternative means will have to be found. As explained in Appendix H,
use of the literal is an inadequate replacement for numeric codes for
some aspects of manual use. Some additional hardware provision (such
as more computer screens in freight terminals) will also therefore be
required to be installed before a radically different system which reduces
the amount of information coded into the number can be introduced.
7.3.30 Given the preconditions noted above it will be possible to start

allocating numbers to new vehicles on the new basis.
7.3.31 For options requiring vehicles to be numbered to a new structure

(for example following the AAR or CIS system). The adoption of a
fundamentally new system presumes the renumbering of existing
vehicles and it will be possible to start that immediately. There will
pressure to reduce the time that two numbering formats are in use to the
minimum. Nevertheless it would seem impossible in practical terms to
reduce this below the general overhaul cycle of up to some six years.
During this period the characteristics of vehicles can be derived from the
database.
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7.3.32 Were unstructured numbers to be adopted, given a logic to

allocate these numbers, numbers may immediately be allocated to new
vehicles. For existing vehicles, given that the database will hold details
of all vehicles and the logic will be written to extract details from the
database rather than rely on structure, there is no need to renumber
existing vehicles whether their characteristics change or not.
7.3.33 For options which involve new numbering systems for new
vehicles only, whilst new vehicles could use the new system as soon as
the appropriate new systems are in place and staff have been trained new
vehicles can start be numbered to the new system. The problem is that
two (potentially incompatible) systems have to run in parallel for several
decades, which would cause significant difficulty and cost.
7.3.34 This family of solutions therefore requires significant software

work as a precondition of allocation of new numbers. Some new
hardware is also required. In addition to the changes in IT systems, staff
will have to be trained in their use and in the use of the new numbering
system. Existing forms and paperwork which use the current number
format will need to be redesigned and issued. Once these changes have
been put into place, new numbers may be allocated. Some variants
require renumbering of existing vehicles, the wholly unstructured variant
however is a neat solution in that it requires no renumbering of vehicles.
Structured Twelve Digit Options
7.3.35 This family of solutions represents an evolution of current

numbering systems. The nature of the twelve digit structures would
continue but certain fields would be redefined. This existing structured
numbering system is currently used for operating, commercial and
technical purposes (as explained in Section 2).
7.3.36 Depending on the exact variant chosen, limited reprogramming of

railway computer systems may be necessary before any renumbering can
start. This reprogramming will affect such fields as regime of use and
railway undertaking to which the vehicle is attached. In most cases this
reprogramming is in any event required to permit liberalisation.
Fortunately the changes currently being made to the RIV system seem
likely to align the regimes for railway owned and privately owned
vehicles. The software changes will also require characteristics which
are at present implicit (such as state in which the vehicle is based) to be
held explicitly in databases. Retention of the structure however allows
the logic of the type code and everything following from it (such as
charging and allocating for new loads by type) to be retained “as is” in
computer systems and thus avoid significant work.
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7.3.37 Following these software changes, new vehicles may be

numbered to the new standards. Some existing vehicles will definitely be
required to be renumbered (such as those operated by minor UIC
railways in Italy, Germany and Switzerland). This will need to be put in
hand but there is no over-riding reason for accelerated renumbering so
the renumbering can be allowed to extend over the full six years of the
maintenance cycle. Existing vehicles which are modified or which
change their state of registration will require renumbering; this must be
done currently because the country and vehicle type elements of the
number structure will continue to have meaning.
7.3.38 This family of solutions therefore does not presume significant

system changes. They do require renumbering of some vehicles (with
the numbering considerably depending on the option, from perhaps
10 000 to virtually the entire fleet) but over a timescale of six years.
Subsequently renumbering will only be required as a function of a
change to a vehicle or its circumstances.
7.4 Vehicle Identification Numbers
Legal Analysis
7.4.1 See comments above for the specific procedure for allocating
numbers and placing vehicles in service.
VIN Allocation
7.4.2 Of the options discussed in Section 6, it is considered that the

option of allocating VINs by manufacturers is significantly preferable to
the other options, for the following reasons:
the importance of allocating any VIN at the earliest stage of a
vehicles’ life, something which the manufacturer is considerably
better placed than any of the other parties to do;
the overwhelming view expressed during the consultation process for
the study that the manufacturer should perform this task;
the acceptance, in principle, of the task by the manufacturers
interviewed during the course of the study;
successful previous experience with this approach in other transport
modes (see Section 4).
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7.4.3 The allocation of numbers by manufacturers does not mean that

involvement by other parties will not be required. In the first place
manufacturers will have to be approved by Government as fit to issue
VINs, which in most cases should be a trivial but nonetheless important
task. Secondly some other body will have to gather the VINs from
manufacturers and collate them into a register/database (see below).
7.4.4 Some major vehicle construction projects are now delivered

through collaborative ventures by consortia of manufacturers. It is
therefore necessary to define which manufacturer and plant is responsible
for allocating the VIN. It is considered that the manufacturer and plant
of final assembly should be responsible for allocating the VIN.
Format of VIN
7.4.5 The possible information contained within any VIN will depend to
an extent who allocates it. However, if as proposed that these are
allocated by manufacturers then it is essential that as a minimum the VIN
contains the following:
manufacturer’s ID (identification) code;
unique serial number for the vehicle.
7.4.6 Since most vehicle manufacturers are now part of large

multinational corporations it may also be beneficial for the plant of
manufacture to be included in any VIN as well. Partly because it will
make subsequent tracing easier and partly for reasons of administrative
efficiency, since VINs could be issued more expeditiously autonomously
by a plant than by referring the matter to and from a corporate
headquarters, possibly based in a different state. However, the
alternative to this would be for manufacturers to allocate vehicle numbers
to particular plants in blocks.
7.4.7 Of the other possible information that could be coded in, as

discussed in Section 6, it would be an unnecessary duplication to code in
the state of manufacture if the plant of manufacture is coded in, as
recommended. All of the other information listed could be held in the
vehicle file in the registry/database, if required, and would appear to have
little added value within the VIN itself.
VIN Technology
7.4.8 There is no way to mark a vehicle such that a determined thief

cannot deface the identifying mark, rather the purpose of the mark is to
establish rights in case of doubt or after multiple changes in the running
number. Permanent and undefaceable marking is a desirable but
probably unachievable goal. Nevertheless it is considered that every
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reasonable and cost effective measure should be taken to make fraudulent

misuse of VINs difficult.
7.4.9 In providing a “tamperproof” VIN, stamping the number into the

vehicle chassis structure provides the simplest and lowest cost solution.
However, some interviewees have expressed reservations about this
concept stating that they would resist the measure on the grounds of the
potential for stress propagation in aluminium vehicles. It is noted that
one wagon lessor interviewed stated that he gets round the problem by
stamping the manufacturer’s serial number in the external buffer support
gussets. There are two further weaknesses with the concept of stamping.
Firstly, the numbers can be difficult to see, particularly once they have
been covered by several layers of paint, making casual detection of VINs
all but impossible. Secondly, the degree of fraud prevention is low since
it would be relatively easy to deface or remove the original numbers and
substitute others.
7.4.10 Well designed cast plates, bearing clear and deep characters,
bearing VINs will be more legible, even after a lifetime’s worth of paint
has been applied to them. The key to security lies in the method of
fixing: bolted or riveted on plates can be removed easier than even a
stamped in identifier, however welded or firmly bonded on plates are
more secure. Welded or bonded plates can still be ground off or
otherwise adulterated however, and issues with the potential to propagate
stress fractures with welded-on plates exist.
7.4.11 Adhesive label technology has improved considerably over recent

years and security can be provided relatively inexpensively by super-
adhesive brittle plastic labels that cannot be removed without destroying
them. Further security can be provided by use of holographic images and
controlled suppliers5 Based on quotes received the cost of such labels
will be around 25-50 cents (€0.25-0.50). Further added value can be
provided through features such as bar coding, if required. The major
weakness of this solution is that for maximum security the labels would
have to be affixed to bare metal and the danger of them being painted
over, which would necessitate a large label size because of inevitable
over-painting around the edges. None of these drawbacks is considered
to be serious and overall this is considered to represent the best option of
displaying numbers.
7.4.12 The other way that identifiers can be applied is to affix an

electronic tag to vehicles. This has the advantages of being proven
technology (being applied to virtually all North American wagons for
5
Preferably no more than three in number, appointed periodically by tender.
7-17
example), having added value capability6 and being relatively cheap

(approximately €100 per vehicle). The disadvantages are that tag readers
would need to be installed or issued to staff wherever these needed to be
read (albeit these would be far fewer in number than if the tags were used
for tracking and tracing), that the tags have a value which would be
attractive in some of the less well developed areas where wagons would
venture and that the first cost of the tags would be less affordable to users
in these areas, particularly as they are unlikely to exploit the additional
functionality available.
Database Issues
7.4.13 In any database the key issue that needs to be borne in mind is
that whilst the VIN of a vehicle many of the other properties associated
with it are liable to radical change, for example the running identifier,
technical characteristics, etc, in some cases passenger vehicles will even
become freight vehicles in the course of their lives.
7.4.14 The concept of VIN that is proposed treats technical approval of a

vehicle as a property of a VIN not a condition for the issue of a VIN7.
Likewise the operational identifier is a property of the VIN in the
database. Paradoxically however the logic of the prime use of the
database being in terms of operational identifier (for example, “is this
vehicle acceptable on my infrastructure?”) means that the most logical
prime key within the databases is likely to be operational identifier. A
clear parallel with motor vehicle practice is apparent here.
7.4.15 The detailed structure of national databases will be a function of

national preference and whilst there may be opportunities for exchange
of views on best practice, there is no compelling reason why each should
be identical. Indeed since individual states have longstanding
requirements for individual national data items there is every reason to
expect diversity. The only essential requirement is for seamless
exchange of data between them to create a virtual pan-European
database, subject only to legitimate confidentiality controls.
7.4.16 As noted above, despite the fact that the key to vehicle identity is
the VIN in all probability most enquiries to the database will be made
using the running number.
7.4.17 The suggested process for creation of a record is for the

manufacturer which has issued a VIN for a vehicle (or VINs for a series
6
For example the ability to interface directly with IT systems, cutting out the
manual interface, and the ability to hold additional data, for example technical
data about the vehicle, maintenance data, etc.
7
This of course provides for exports and non-compliant vehicles to have VINs
and is a necessary condition of the Unidroit register.
7-18
of vehicles) will then go through the vehicle approval process, as

appropriate. The manufacturer must then ask for its vehicles to be
registered on the relevant database of its choice providing documentation
certifying construction and approval. The database authority chosen will,
as appropriate, provide operating numbers and enter the vehicles on its
database. In this way freedom of choice for technical approval is
guaranteed, but controls on the status of data being entered on the
database are maintained.
7.4.18 Likewise on modification of a vehicle, approval of the

modification would be a condition for updating the vehicle record.
7.4.19 The freedom to change state of registration is an important part of

a liberal market. In these cases the vehicle operator will be required to
advise both the old and new state, then the record will be transferred and
of course a new operating number issued. In compliance with EU and
COTIF law no new technical approval will of course be necessary.
7.4.20 It is recommended that the UNIDROIT International Register, be

entirely separate and free standing, since this will only be required where
a financial interest is registered in a vehicle and it is worldwide and needs
only the VIN. Accordingly there will be numerous vehicles that appear
on it that are constructed and run outside Europe and vehicles that will
appear on European registers/databases which will not appear on the
International Register. As VINs will be unique and permanent there are
no data compatibility issues, other than data entry errors and notification
of the end of vehicle’s life, which it is considered is something that is
most effectively handled by liaison between the respective database
managers.
Allocation to Existing Vehicles
7.4.21 The system of allotting numbers to existing vehicles is one that is

principally governed by migration issues; it is inconceivable that two
million vehicles can be renumbered overnight, on the other hand for the
system to work it is important that vehicles’ VINs can be identified at an
early stage and certainly not by waiting six years for the scheduled
general repair process to have (theoretically) completed a cycle.
Accordingly it is important the VINs allocated to existing vehicles can be
identified before they are physically applied to them. This immediately
rules out the option of allocating a completely fresh sequence of
numbers. Similarly use of manufacturers’ serial numbers can be
discounted, since in many cases these will not be obvious, or indeed
always marked on the vehicle, a further issue is that of duplication of
numbers. Accordingly it is considered that the only valid system is one
based on the existing running identifier; see Section 9 for a recommended
system.
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Migration Analysis
7.4.22 Apart from the issue of allocating VINs retrospectively to

existing vehicles, discussed above, there are not considered to me any
particular migration issues in this area, since the introduction of
formalised VINs would be a new concept. The issue is merely one of
establishing the required systems, databases, etc, which is something that
is similar for both options.
7.5 Maintenance and Insurance
Legal Analysis
7.5.1 The concept of requiring vehicles to be attached to the fleet of a

UIC member railway undertaking is considered to have a negative effect
on a proper operation of the Single Market in railway vehicle
maintenance services and is considered to cause concern under EC
competition rules. However, the 1999 COTIF requires vehicle keepers to
have a “contract for use” with a railway undertaking (not necessarily a
UIC member) to regulate the many interfaces between the parties. This
provides a potential legal conduit to funnel the many relationships
including those of liability, maintenance and insurance.
7.5.2 The supervision on the maintenance and insurance regime of

vehicle keepers could be modelled in a variety of forms (see paragraph
6.8.2 et seq). From a legal point of view none of these is preferable to
any other.
Maintenance
7.5.3 Within the maintenance area there are a number of facets to

consider. Firstly any numbering and database system has to support the
process of maintenance and secondly there must be provision for the
audit processes which are chosen.
7.5.4 The process of maintenance is becoming ever more sophisticated.

Maintenance schedules are increasingly part of the process of technical
approval (as implied by Article 10 paragraph 2(a) of COTIF ATMF).
Increasingly they are linked to the performance of the vehicle and thus
rely on records of the work the vehicle does. To the extent the work is
international so must the data. Likewise the maintenance schedule itself
is built up from experience of wear and failure in service, this data too
comes from railway data systems. Vehicle operators therefore need
access on a non-discriminatory basis to this data. There may be problems
7-20
of confidentiality, for example where an operator has leased his vehicle

to a third party there can be a debate about how much data about the
operations of that vehicle he is entitled to. For example, there have been
instances in Great Britain in which railway undertakings have refused
journey data to the owners of locomotives they have hired.
7.5.5 The data in respect of the work done by individual vehicles clearly
only refers to that vehicle and the format of the number and the nature of
the database is irrelevant. By contrast, establishing the basis for
maintenance requires data to be collected by vehicle type and possibly
sub-type. Collection of data at an international level for a type based in
many states may indeed be desirable (given that rolling stock
manufacturers are increasingly organised at international level and sell at
an international level, maintenance programmes organised at an
international level are wholly logical).
7.5.6 Recording of maintenance work on the national database is a clear

requirement, where the work is done within the state in question that
poses few problems, and in most states is already part of normal
practices.
7.5.7 Similarly, the Single Market requires that maintenance work can
be undertaken anywhere. Provision of maintenance records by the
vehicle keeper to the contractor poses no problems but where
maintenance has been done outside the home state, some means of
updating the record of maintenance in a controlled way will be necessary.
This might be simple: supplying certificated paper records to the
national database controller, or direct electronic updates under controlled
conditions.
7.5.8 The monitoring of maintenance is itself likewise increasingly a

monitoring of systems to verify that those who hold responsibility for
maintenance have systems in place to initiate maintenance, to check
standards and organise follow up action. The audit arrangements
therefore do not check vehicles themselves but rather the process. This is
a much more effective means of verifying compliance. The audit process
depends therefore on the systems described in the previous paragraph
being in place and audits their completeness, accuracy and the
promptness of the information
7.5.9 The logic of a system where vehicles are accepted into traffic and
have numbers allocated by national authorised bodies of the state of
ownership of the vehicle/of the state chosen by the owner/keeper implies
that it is the authorities of this state that have the mandate to monitor that
maintenance is undertaken in accordance with the standards laid down
and approved in the technical approval. It should be noted that the state
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undertaking the work of monitoring maintenance might not have been

involved in the approval process.
7.5.10 Creating these records for maintenance imposes no particular

difficulties, indeed most national systems will already have the necessary
functionality.
Insurance
7.5.11 Most railway undertakings have stop-loss policies covering them

against major catastrophes but are otherwise self-insuring. To be noted is
that in Great Britain where there is a formal requirement to insure, most
railway undertakings have such large excesses that they are, in effect,
self-insured. It is to be expected that for a number of reasons (principally
those of cost) that this pattern will continue.
7.5.12 Nevertheless there is increasing reluctance within the industry to

accept risk without being able to control it and so the “knock for knock”
approaches adopted hitherto are likely to be replaced by requirements for
formal insurance, at least to cover major claims. These questions lie
outside the mainstream of this study. Answers are still being debated but
the acceptance of vehicles into traffic, database and numbering system
need to monitor the insurance status of rolling stock. It is quite
conceivable that rolling stock could be insured for limited or all
international movements or indeed just domestic movement. The vehicle
record in these cases will need to reflect that. Again it is logical that the
national authorities of the state of registration will have the responsibility
to monitor compliance.
7.5.13 Creating the record of insurance does require enhancement of

national databases. Whilst logically insurance records will be held at the
level of vehicle, input is equally logically likely to be needed at the level
of operator. Provision for updating and flagging an absence of update is
also required.
7.6 Cost Benefit Analysis
Outline
7.6.1 Cost Benefit analysis (CBA) is a method of assessing investment

projects taking into account social, rather than just financial, costs and
benefits. In doing so it aims to identify and measure gains and losses of
economic welfare. This sub section, therefore, aims to set out:
• the key costs and benefits of a new system of placing vehicles in
service and identifying them;
7-22
• provide an indication of the scale of those costs and benefits; and

• broadly assess who bears the costs and who are the main beneficiaries.
7.6.2 It is considered that a CBA is only relevant to two aspects of the

system:
• the selection of the numbering system itself; and
• the form of the database or databases holding the information.
It is not considered that there are identifiable differences in quantifiable
benefits and costs between aspects such as who allocates identifiers and
VINs, in these cases the appropriate option will be selected by the legal
and practical requirements and not by the outcome of any CBA.
Numbering Systems
Options Evaluated
7.6.3 Section 6 identified twenty-eight plausible numbering systems,

which with VIN options added produces a grand total of, roundly, fifty
options. However, the vast majority are either impracticable or fail to
comply with the relevant Directives and Regulations and many are
similar in concept. It would also be unfeasible to undertake a sensible
analysis for each one. Therefore the cost benefit analysis has been
undertaken for a short list of four options, namely:
• Base Case;
• random 12 digit number;
• two number option;
• 14 digit plus unique number;
7.6.4 The base case is the modified UIC 12 digit option whereby the
third and fourth digits that presently indicate which railway undertaking
the vehicle is attached to is replaced by two digits that identify the
country that the vehicle is attached to.
7.6.5 The first variant involves allocating unstructured permanent twelve

digit running numbers to all vehicles, which would be used in operating
systems. As new vehicles enter the fleet the number they are allocated
will be unstructured and therefore it will not be possible to discern any
information about the vehicle form the number without accessing a
database. Access to a database could be once on the arrival of a vehicle
on each railway (with storage of data) or every time a vehicle was
handled. Use, ownership, etc, of the vehicle could then change without
any change to its number.
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7.6.6 The second option provides vehicles with two numbers, the first is
a permanent vehicle identification number allocated on vehicle approval
and then permanent. It is assumed existing vehicles use their existing
twelve digit numbers as the permanent ones. In addition to the VIN
vehicles would receive a running number. The running number taken in
this option is a "modified UIC 12 digit system" one.
7.6.7 The third option is similar again a VIN would provide permanence
but in addition there would be a fourteen digit running number allocated
by any licensed railway undertaking.
7.6.8 Besides examining different numbering options, three

implementation options have been considered:
• “Big Bang”;
• gradual phased approach;
• new vehicles only.
7.6.9 The Big Bang approach assumes that all vehicle numbers change
on a particular day. On a practical level vehicles could be renumbered
over for example, a two year period and carry two numbers both the old
and new with the former still being used till change over day and the
latter thereafter.
7.6.10 For the gradual approach it is assumed that numbers are changed
over a six year period as vehicles (are scheduled to) complete standard
maintenance cycles.
7.6.11 For the new vehicle option it is assumed that only new vehicles
are numbered under any new regime with the remainder of the fleet being
renumbered between years 7-12. This would ensure that between a
quarter and a third of the railway fleet would not need to be renumbered.
7.6.12 From the above the relativities of the cost and benefits of all the
other options can be derived.
Identifying Costs
7.6.13 The main costs of railway vehicle renumbering have been

identified as follows:
• physically renumbering the vehicle: covers the cost of putting a new
number on the vehicle, entering that number into the railway’s
databases, the cost of affixing a VIN and overall management of the
process;
7-24
• opportunity cost: if a vehicle has to be taken out of service to be

renumbered then it is not available for revenue earning work;
• movement cost: applies if a vehicle has to be moved especially to and
from workshops to be renumbered;
• information systems: vehicle numbers are widely used for a variety of
purposes and if a new numbering system is introduced these systems
will need to be reprogrammed or data re-entered, there may also be
cases where new hardware or telecommunications are needed to allow
rail staff to access data sources;
• training costs: any new system will require staff training which will
depend on the extent to which the new system differs from the
existing one;
• operational costs: a substantially different numbering system may
take time to “bed in” causing operational problems such as delay in
clearing trains and returning empty wagons leading to lost revenues
and business; and
• database use: interrogating databases has a staff cost and a computer
time cost.
Identifying Benefits
7.6.14 The key benefits of a new system should be:

• competition: ability to obtain an international number and hence to
operate internationally will increase competition;
• synergy with other regulatory changes: difficult to quantify but
another step in radically changing Europe’s railways by allowing open
access and competition and changing historic railway operating
practices;
• opportunity benefits: amending software or introducing new hardware
may provide opportunities to improve operational and business
efficiency;
• enhancement of European integration: common European-wide
numbering system embracing countries of central and eastern Europe;
• VIN: may increase number of institutions prepared to provide
financing for railway equipment.
7.6.15 It should be noted that not all of these are dependent on the
format of the number, but will in fact be due to changes in the system for
placing vehicles and allocating them with numbers (for example
competition benefits, opportunity benefits), which therefore generate
constant benefit for all numbering system options.
7-25
Measuring Costs and Benefits
7.6.16 Europe’s national railway systems differ markedly in terms of

efficiency, exposure to competition, type of traffic carried and cost
structures. This has meant that measuring the costs and benefits
attributable to each option is subject to a degree of uncertainty and
should be regarded as indicative.
7.6.17 Costs are highly dependent on the speed with which any new
system is introduced. For example, if any new numbering scheme is
introduced over a six year timeframe, then vehicles could be renumbered
during their standard maintenance cycles and no additional movement
costs would be incurred. However, if it was proposed to transfer between
the present and a new numbering system “overnight” then enormous
costs would be incurred in both moving vehicles to workshop and in lost
revenues as the total rail fleet was taken out of service. Appendix J sets
out the costs and benefits and assumptions used in deriving the following
results.
Results
7.6.18 Tables 7.1 and 7.2 set out the results for the four options and
three timing periods considered and two scenarios with regard to
benefits. The minimum benefit scenario takes a cautious approach and
assumes a minimal increase in competition arising as a result from the
new numbering and registration scheme. The maximum benefit scenario
takes a more robust approach and assumes that the new system is one of
the last steps to liberalisation and could therefore deliver the types of
growth in freight traffic that has been achieved in Sweden and Great
Britain. In both scenarios the costs are the same but the benefits differ by
a factor of ten. The analysis shows the net present value in 2003 prices
of the cost and benefits over a twenty year time horizon using a discount
rate of 10%
7-26
Table 7.1- Evaluation of Number Format Minimum Benefits (€ net

present value)
Base Option Random 12 Digit

Gradual Big Bang New Vehicles Gradual Big Bang New Vehicles
Total Cost 15,000,000 18,000,000 13,000,000 124,000,000 144,000,000 93,000,000

Total Benefit 150,000,000 150,000,000 150,000,000 150,000,000 150,000,000 150,000,000
Net Benefit 135,000,000 132,000,000 137,000,000 26,000,000 6,000,000 57,000,000
Two Numbers 14 Digit

Total Cost 62,000,000 123,000,000 56,000,000 156,000,000 234,000,000 75,000,000

Total Benefit 187,500,000 212,600,000 187,500,000 187,500,000 212,600,000 187,500,000
Net Benefit 125,500,000 89,600,000 131,500,000 31,500,000 -21,400,000 112,500,000
Table 7.2- Evaluation of Number Format Maximum Benefits (€ net

present value)
Base Option Random 12 Digit

Total Cost 15,000,000 18,000,000 13,000,000 124,000,000 144,000,000 93,000,000

Total Benefit 1,500,000,000 1,500,000,000 1,500,000,000 1,500,000,000 1,500,000,000 1,500,000,000
Net Benefit 1,485,000,000 1,683,000,000 1,487,000,000 1,376,000,000 1,557,000,000 1,407,000,000
Two Numbers 14 Digit

Total Cost 62,000,000 123,000,000 56,000,000 156,000,000 234,000,000 75,000,000

Total Benefit 1,875,000,000 2,126,000,000 1,875,000,000 1,875,000,000 2,126,000,000 1,875,000,000
Net Benefit 1,813,000,000 2,003,000,000 1,819,000,000 1,719,000,000 1,892,000,000 1,800,000,000
7.6.19 Under the Minimum benefit scenario the option with the highest
net present value is the base option for new vehicles. This is due to costs
being minimised. With the Maximum benefit scenario the permanent
VIN and 12 digit modified UIC numbering system performs best. Whilst
7-27
the Big Bang (that is, rapid introduction of the system) is the best
performer given that there is more uncertainty concerning costs than
benefits and the practical difficulties it may be more appropriate to go for
the new vehicle or gradual introduction options.
7.6.20 If the two number option was chosen then the net present value
under the gradual option would range from €125m to €1813m
7.6.21 The costs of any new scheme would fall heavily on existing
railway undertakings and (if successful in improving rail’s
competitiveness and market share) on road hauliers. The benefits would
accrue mainly to non-UIC member railways and to society. The latter
arising from increased competition on the rail network leading to reduced
haulage costs for users and a reduction in environmental and road
congestion costs arising from modal switch from road to rail.
Form of Databases
7.6.22 With regard to setting up and operating the requisite database,

three options have been considered
• a central fully populated database with links to national databases
• a central reference data base with links to national databases
• A virtual central base created by links from national databases
The present value costs of each database option ignoring all common
operating costs, is broadly estimated as follows:
• Central full populated database €3.6m

• central reference database €3.4m
• virtual database €2.4m
7.7 Evaluation of Identification System Options
7.7.1 Table 7.2 is an evaluation matrix for the options defined in Section
6 for the system of placing vehicles in service, allocating them with
numbers and associated issues involving the use numbers in service.
This uses the Key Objectives defined in Section 6.1.
7-28
Table 7.2 - Evaluation Matrix – Attributes of Identification System
Essential Requirements Desirable Requirements
Technical Innovation
Flexibility for Future
New Contract. St.ruc
Maximal accept.abty
Accommodates New
Cont. & Govt Auths

Interfaces with Reg.
New Rly Undertaks
Compatibility with
Cost Effectiveness
No Constraints for
No Constraints for
Covers all Vehicle
Does not Obstruct
Reconcilable with
for all geogr areas
Service Providers
Accommodates
Interfaces with
Interfaces with
Single Market
Practicability
Option
Customers
Total
Practices
Property
EU Law
COTIF
Types
Weight n/a n/a n/a n/a n/a n/a n/a 20% 10% 10% 10% 20% 10% 10% 10% 100%
Existing System x x x 9 9 x P - - - - - - - - 0%
Single Central x x 9 9 P 9 9 - - - - - - - - 0%
Central: Driving
9 9 9 P P 9 9 5 7 7 9 8 8 9 9 55%
Other Pan-National
Database /Register
Linked Individual
National: Driving 9 9 9 P P 9 9 6 7 7 9 8 8 9 9 57%
Pan-Nat Database
Independent Nat:
Driving Virtual Pan 9 9 9 9 9 9 9 7 7 8 9 9 9 9 9 83%
National Database
Independent Nat:
9 x x x 9 9 9 - - - - - - - - 0%
No Interfaces
7-29
Maximal accept.abty
Accommodates New
Cont. & Govt Auths

New Rly Undertaks
Compatibility with
Cost Effectiveness
No Constraints for
No Constraints for
Covers all Vehicle
Does not Obstruct
Reconcilable with
for all geogr areas
Service Providers
Accommodates
Interfaces with
Interfaces with
Single Market
Practicability
Option
Customers
Total
Practices
Property
EU Law
COTIF
Types
Supranational
9 9 9 9 9 9 9 8 6 6 8 4 4 8 5 61%
Authority
State of Manuf 9 9 9 9 9 9 9 7 5 5 8 6 5 7 5 61%

Running Number Allocation By
State of Approval 9 9 9 9 9 9 9 7 5 5 8 6 5 7 5 61%
State of Use 9 9 9 9 9 9 9 7 5 5 8 6 6 7 5 62%
Owner’s State 9 9 9 9 9 9 9 7 5 5 8 6 6 7 5 62%
Any State 9 9 9 9 9 9 9 7 5 5 8 6 5 7 5 61%
Independent Rail
9 9 9 9 9 P 9 7 7 6 7 6 7 5 7 55%
Industry Body
Licensed Rail Und. x 9 x 9 9 9 9 - - - - - - - - 0%
Infrast. Manager x P 9 9 9 9 9 - - - - - - - - 0%
7-30
Maximal accept.abty
Accommodates New
Cont. & Govt Auths

New Rly Undertaks
Compatibility with
Cost Effectiveness
No Constraints for
No Constraints for
Covers all Vehicle
Does not Obstruct
Reconcilable with
for all geogr areas
Service Providers
Accommodates
Interfaces with
Interfaces with
Single Market
Practicability
Option
Customers
Total
Practices
Property
EU Law
COTIF
Types
Vehicle Identification Number
No VIN 9 9 9 P 9 9 9 5 10 10 10 3 10 1 1 48%
By Manufacturer 9 9 9 9 9 9 9 8 10 8 10 6 10 6 4 76%
Allocation
By Approval Body 9 9 9 9 9 9 9 8 7 7 10 7 10 7 4 75%
By Supranat Auth 9 9 9 9 9 9 9 7 6 6 10 6 10 6 4 68%
By State 9 9 9 9 9 9 9 6 7 7 10 7 10 7 5 72%
By Rail Industry 9 9 9 P 9 9 9 7 7 7 10 5 10 5 6 69%
Key
9 = Fully meets essential requirement.
P = Does not fully meets essential requirement, but achieves minimum permissible standard, 10% deducted from Total Score.
x = Does not meet essential requirement, option rejected.
7-31
7.7.2 It can therefore be seen that on the basis of the above that:
• continuation with the existing system is not an option (as previously
noted);
• the preferred database option is for a series of independent national
databases containing vehicle data linked together to provide a virtual
pan-European database;
• there is a demonstrable advantage in the acceptance of vehicles into
traffic and issuing them with numbers being undertaken by a
governmental agency either nationally or on a pan-European basis,
however there is little difference in score between any of the options
for this;
• there is a clear preference for a separate VIN from a holistic
perspective;
• in respect of the decision on who should allocate VINs, the highest
scores were for either the manufacturers or the approval body to
allocate it.
7.8 Evaluation of Numbering System Options
Table 7.3 is an evaluation matrix for the numbering system options

defined in Section 6 and using the Key Objectives defined in Section 6.1.
7-32
Table 7.3 - Evaluation Matrix – Attributes of Identifier

Systems Using Running Numbers Only (No Vehicle Identification Numbers)
Clear & Logical
Contact Details
Discriminatory
Vehicle Struct.
TSI Compliant
Indicates Type
Cost Effective
Self Checking
with Previous
Acceptability
of Vehicle &
with non-EU
Identifier for
Identifier for
Identifier of
Compatible
Compatible
Operations
Option
Maximum
Facilitates
Universal
Property
Structure
Indicates
Liability
Systems
Systems
Total
Unique
Unique
Unique
Charge
Rights
Non-
Weight n/a n/a n/a n/a n/a 15% 25% 15% 15% 10% 10% 5% 5% 100%
Existing Systems x x 9 9 9 - - - - - - - - 0%
Universal UIC 12 digit x x 9 9 P - - - - - - - - 0%
Universal Mod UIC 12 digit x 9 9 9 P - - - - - - - - 0%
Universal OSJD 8 digit x P P P P - - - - - - - - 0%
Universal AAR 10 character x 9 9 P x - - - - - - - - 0%
Universal 8 Digit Structured x 9 9 9 x - - - - - - - - 0%
Universal 12 Digit Structured x 9 9 9 P - - - - - - - - 0%
7-33
Clear & Logical
Contact Details
Discriminatory
Vehicle Struct.
TSI Compliant
Indicates Type
Cost Effective
Self Checking
with Previous
Acceptability
of Vehicle &
with non-EU
Identifier for
Identifier for
Identifier of
Compatible
Compatible
Operations
Option
Maximum
Facilitates
Universal
Property
Structure
Indicates
Liability
Systems
Systems
Total
Unique
Unique
Unique
Charge
Rights
Non-
Univ. Unstructured 8 Digit 9 9 9 9 x - - - - - - - - 0%
Univ. Unstructured 12 Digit 9 9 9 9 P 5 4 0 5 1 0 0 10 21%
New System for New Vehicles

x 9 P P 9 - - - - - - - - 0%
Only – Modified UIC system

x 9 P P P - - - - - - - - 0%
Only – OSJD system

x 9 P P x - - - - - - - - 0%
Only – AAR system

x 9 P P 9 - - - - - - - - 0%
Only – Structured 12 digit

x 9 P P x - - - - - - - - 0%

9 9 P P P - - - - - - - - 0%
Only – Unstructured 8 digit
7-34
Clear & Logical
Contact Details
Discriminatory
Vehicle Struct.
TSI Compliant
Indicates Type
Cost Effective
Self Checking
with Previous
Acceptability
of Vehicle &
with non-EU
Identifier for
Identifier for
Identifier of
Compatible
Compatible
Operations
Option
Maximum
Facilitates
Universal
Property
Structure
Indicates
Liability
Systems
Systems
Total
Unique
Unique
Unique
Charge
Rights
Non-

9 9 9 9 P 7 3 0 8 1 0 0 0 21%
Only – Unstructured 12 Digit
Own System/Modified UIC x 9 P P P - - - - - - - - 0%
Own System/OSJD x 9 P P P - - - - - - - - 0%
Own System/AAR x 9 P P x - - - - - - - - 0%
Own System/Struct. 12 digit x 9 P P P - - - - - - - - 0%
Own System/Struct. 14 digit x 9 P P x - - - - - - - - 0%
Own System/Unstruct. 8 digit x 9 P P x - - - - - - - - 0%
Free Choice of System x 9 x x 9 - - - - - - - - 0%
Key
7-35
Systems Using Separate Running and Vehicle Identification Numbers
Clear & Logical
Contact Details
Discriminatory
Vehicle Struct.
TSI Compliant
Indicates Type
Cost Effective
Self Checking
with Previous
Acceptability
of Vehicle &
with non-EU
Identifier for
Identifier for
Identifier of
Compatible
Compatible
Operations
Option
Maximum
Facilitates
Universal
Property
Structure
Indicates
Liability
Systems
Systems
Total
Unique
Unique
Unique
Charge
Rights
Non-
Existing Systems 9 x 9 9 P - - - - - - - - 0%
Universal UIC 12 digit 9 x 9 9 P - - - - - - - - 0%
Universal Mod. UIC 12 digit 9 9 9 9 P 8 9 8 9 10 10 5 10 78%
Universal OSJD 8 digit 9 P P P P 2 9 2 3 10 0 0 0 3%
Universal AAR 10 character 9 9 9 9 x - - - - - - - - 0%
Universal 8 Digit Structured 9 9 9 9 x - - - - - - - - 0%
Universal 12 Digit Structured 9 9 9 9 P 7 9 10 7 8 10 10 10 77%
7-36
Clear & Logical
Contact Details
Discriminatory
Vehicle Struct.
TSI Compliant
Indicates Type
Cost Effective
Self Checking
with Previous
Acceptability
of Vehicle &
with non-EU
Identifier for
Identifier for
Identifier of
Compatible
Compatible
Operations
Option
Maximum
Facilitates
Universal
Property
Structure
Indicates
Liability
Systems
Systems
Total
Unique
Unique
Unique
Charge
Rights
Non-

9 9 9 9 P 10 5 8 10 6 4 6 5 60%
Only – Modified UIC system

9 9 9 9 x - - - - - - - - 0%
Only – OSJD system

9 9 9 9 x - - - - - - - - 0%
Only – AAR system

9 9 9 9 P 7 5 8 7 6 4 7 5 52%

9 9 9 9 x - - - - - - - - 0%
Own System/Modified UIC 9 9 P P 9 10 5 3 10 6 2 5 0 38%
Own System/OSJD 9 9 P P P 3 5 1 4 8 0 0 0 3%
Own System/AAR 9 9 P P P 1 4 2 2 1 0 5 0 0%
7-37
Clear & Logical
Contact Details
Discriminatory
Vehicle Struct.
TSI Compliant
Indicates Type
Cost Effective
Self Checking
with Previous
Acceptability
of Vehicle &
with non-EU
Identifier for
Identifier for
Identifier of
Compatible
Compatible
Operations
Option
Maximum
Facilitates
Universal
Property
Structure
Indicates
Liability
Systems
Systems
Total
Unique
Unique
Unique
Charge
Rights
Non-
Own System/Struct. 12 digit 9 9 P P P 9 5 4 8 6 2 5 0 25%
Own System/Struct. 14 digit 9 9 P P P 7 5 4 7 3 2 5 0 17%
Mod UIC System, VIN Tagged

9 9 9 9 P 7 9 8 9 10 10 8 10 78%
Electronically
OSJD System, VIN Tagged

9 P P P P 2 9 2 3 10 0 3 5 7%
Electronically
AAR System, VIN Tagged

9 9 9 9 x - - - - - - - - 0%
Electronically
St. 12 Digit Syst, VIN Tagged

9 9 9 9 P 6 9 10 7 8 10 10 10 75%
Electronically
St. 14 Digit Syst, VIN Tagged

9 9 9 9 x - - - - - - - - 0%
Electronically
Free Choice of System 9 9 x x 9 - - - - - - - - 0%
7-38
Key
7-39
7.8.1 Only the following options achieved positive scores (in descending
order):
• universal modified UIC 12 digit system and VIN (78%);
• universal modified UIC 12 digit system and VIN tagged electronically
(78%);
• universal 12 digit structured system and VIN (77%);
• universal 12 digit structured system and VIN tagged electronically
(75%);
• new system for new vehicles only - modified UIC 12 digit system and
VIN (60%);
• new system for new vehicles only - 12 digit structured system and
VIN (52%);
• vehicle keepers free to choose between a system of their own and
modified UIC 12 digit system and VIN (38%);
• vehicle keepers free to choose between a system of their own and 12
digit structured system and VIN (25%);
• unstructured 12 digit system (21%);
• new system for new vehicles only - unstructured 12 digit system
(21%);
• vehicle keepers free to choose between a system of their own and 14
digit structured system and VIN (17%);
• OSJD 8 digit system (3%);
• vehicle keepers free to choose between a system of their own and
OSJD 8 digit system (3%).
7.8.2 It is therefore absolutely clear that a twelve digit running identifier

plus a VIN is the only logical choice of numbering system. It is also
appears that a structured number is strongly to be preferred.
7-40
Colin Buchanan and Partners Conclusions
8. CONCLUSIONS
8.1 Organisational
8.1.1 It is considered that the present system of allocating vehicle

numbers and placing vehicles into service is not compatible with either
EC law or EU policy objectives. Furthermore there are no vehicle
databases/registers that meet the forthcoming requirements of EC
Directives, the COTIF and Unidroit. It is therefore considered that the
present system is insupportable and must change. Accordingly the only
issues that need be considered further are what the system must be
changed to.
8.1.2 It is anticipated that technical acceptance issues should be resolved

once independent notified bodies and appropriately drafted TSIs are in
place.
8.1.3 All administrative procedures associated with placing vehicles in

service, including the allocation of running identifiers needs to be placed
in the hands of independent bodies which have no organisational links
with any railway undertakings.
8.1.4 Similarly it is considered essential that the database/register

containing vehicle details is managed by an independent body. The
requirements of the Interoperability Directives, COTIF and railway
operational requirements are not consistent. It is considered possible,
however, to meet all of these requirements via differing reporting options
within the database structure.
8.1.5 Inequality of access rights to railway operating IT systems which

use vehicle numbers and other vehicle data has emerged as a major
concern in this study. In some cases these national systems have been
expropriated by national railway undertakings, claiming that they are
their property and quoting “confidentiality” concerns to prevent other
railway undertakings gaining access to these vital systems. This is also
considered to be incompatible with EC competition law. It is considered
that any such systems should be vested in the infrastructure manager or
another neutral body and should operate in a neutral manner, with equal
access rights to all (see Section 9).
8.1.6 It is considered that if separate Vehicle Identification Numbers are

allocated in addition to running identifiers that these are allocated by
vehicle manufacturers. These can be used to meet UNIDROIT
requirements.
8-1
Colin Buchanan and Partners Conclusions
8.2 Technical
8.2.1 If the requirements to provide a unique identifier are to be met

with a single number this can only be accomplished via an unstructured
number. If a structured number is to be provided then a Vehicle
Identification Number will be required in addition to a running identifier.
The VIN would become the official identity determinant of any vehicle
and vehicle databases would use the VIN as the file reference in a vehicle
record file.
8.2.2 At present the majority of hauled vehicles in the EU carry twelve

digit numbers, there are significant costs and migration issues associated
with changes to this format. The number is structured and this structure
is used by current IT and manual systems, for migration reasons it is
desirable that this format is changed as little as possible in achieving a
system that is legally compliant and has the maximum cost effectiveness.
8.2.3 It is considered that the only sensible form of vehicle database is

one which is structured on a national basis with effective links that create
a virtual single European database. Whilst each national database should
be managed by national governmental bodies it is considered that these
links need to be overseen and enforced by a pan-European body.
8.2.4 There are inconsistencies in the way that vehicles are defined
between states, which need to be resolved. It is further considered that
the matter needs to be thought through from first principals to provide
appropriate permanent identification of divisible assets; this need not
necessarily alter definitions currently used for vehicle running numbers,
if these are taken as an attribute of the permanent identifier. Similarly it
is considered desirable to include the serial numbers of major vehicle
components in the vehicle master record.
8-2
Colin Buchanan and Partners Recommendations
9. RECOMMENDATIONS
9.1 Organisational Recommendations
Placing Vehicles in Service
9.1.1 It is recommended that the EC takes steps to ensure the

independence of notified bodies in all EU states.
9.1.2 It is recommended that railway undertakings, any subsidiary

company of a group containing a railway undertaking, or any staff
employed either directly or indirectly by railway undertakings cease to
play any role in the process of placing vehicles in service, allocating
them with numbers and placing them on databases and common
operational systems, other than as an applicant for their own vehicles,
and this be expressly prohibited. It is considered that these tasks can
only be undertaken by one of the following bodies:
supra-national government agency;
by independent national government agencies;
by a joint industry body.
9.1.3 On balance, it is considered that the option of using independent

national government agencies is to be preferred, although both the
alternate options are workable. It is considered however to vital that it is
clearly defined which state should be responsible in a particular case. A
number of options have been put forward in Section 6 for which state
should be responsible, of these it is considered that giving the
owner/vehicle manufacturer freedom to select a state of his choice is
perhaps the best option
9.1.4 Any “contracts for use” required to place vehicles in service

should be the same for all vehicle owners and keepers within the
geographic area and be open to any owner/keeper on the same terms.
These “contracts for use” must not convey extra powers or rights to any
individual or groups of vehicle owners/keepers or railway undertakings,
either explicitly or implicitly. This need not exclude the availability of
alternative “contracts for use” offering a choice of terms, provided that
all are open to any owner/keeper and meet these tests.
Vehicle Database Management
9.1.5 It is recommended that vehicle databases are managed on a

national basis by independent bodies (see below). It is further
9-1
recommended that effective interfaces between them are supervised and

mandated by a pan-national body, such as the ERA, which would also be
responsible for ensuring that these drive separate virtual databases
required under the Interoperability Directives and COTIF.
9.1.6 It is recommended that the International Registry that is to be

required under UNIDROIT is made a free standing and separately
managed database.
Access to Systems
9.1.7 It is recommended that vital railway national IT systems that make

use of vehicle numbers and data (for definition see Appendix I, for
example operating systems, capacity management tools, tracking and
tracing systems, train planning systems, infrastructure charging systems,
etc) be removed from the control of national railway undertakings where
this occurs and vested in neutral bodies, such as the infrastructure
manager, governmental bodies or joint industry bodies open to all.
National railway undertakings should continue to retain any internal
commercial systems and management tools associated with these, but
this disaggregation should be entirely their own responsibility and failure
to do so or to remove confidential information should not be a reason to
fail to open systems up.
9.1.8 The provision of adequate confidentiality filters between users in

systems not originally designed for a multi-user environment is important
but is considered to be less important than the imperative of permitting
the Single Market to operate by providing equal and non-discriminatory
access to systems for all those who legitimately need it.
9.1.9 It is recommended a pan-EU definition is made of the information

and systems which national railways can consider to be confidential, to
stop situations where a wide variety of information is claimed to be
confidential as means of frustrating potential rival railway undertakings
and thus EU Policy. It is recommended that only the following
information and systems can be held to be confidential:
internal costs (other than infrastructure costs and charges);
internal costing and charging systems;
customer lists;
joint systems with customers;
freight charges;
freight charging and billing systems;
charter passenger train charges and charging systems;
9-2
commercial contracts with third parties;

business planning systems and information;
internal financing information
any private systems developed after national operating systems have
been vested in a neutral agency and opened to all legitimate users and
potential users.
Maintenance and Insurance
9.1.10 In the European Single Market vehicle owners and keepers must
have the freedom to determine the maintenance regime for their vehicles
and who undertakes this work. It is recommended that keepers are forced
to have the adequacy of their maintenance regime and the maintainer
certified by a notified body on an annual basis. The state in which the
vehicle is registered would then be responsible for verifying that this has
been obtained on the due date and for withdrawing approval for the
vehicles concerned should this approval not be obtained
9.1.11 It is considered that vehicle keepers should obtain adequate

insurance1 and as with maintenance the state where the vehicle is
registered should be responsible for verifying that fresh insurance has
been obtained on expiry of the previous policy. Again the state of
registration will need to be responsible for withdrawing approval for the
vehicles concerned should the relevant certification not be produced.
9.2 Technical Recommendations
Numbering System
9.2.1 It is recommended that a structured twelve digit number be used,

supplemented by a Vehicle Identification Number (VIN) be adopted as
the standard European system for all vehicles and that this system be
freely available to all who wish to have one.
9.2.2 It is considered that the only credible options for the number
format are as follows:
universal modified UIC 12 digit system and VIN;
universal modified UIC 12 digit system and VIN tagged
electronically;
1
International agreement will be required what value “adequate insurance”
represents.
9-3
universal 12 digit structured system and VIN;

universal 12 digit structured system and VIN tagged electronically;
new system for new vehicles only - modified UIC 12 digit system
and VIN.
Of these options it is recommended that the first option be adopted.
9.2.3 The precise coding and format of the number recommended by the
Consortium is discussed in depth in Appendix K.
9.2.4 For traction it is recommended that a twelve digit numbering

system is also adopted and at least the last ten digits are displayed on the
vehicle’s sides. The practice of displaying “short numbers”, as occurs in
many states, could continue by using larger numerals for these.
Database and Register Issues
9.2.5 It is recommended that databases and registers holding vehicle

data are structured as a series of independent national (or regional where
states which to co-operate) databases, linked together to form a virtual
pan-European database. This virtual database would generate the
registers and databases required by legislation as reporting options.
9.2.6 The exchangeable datasets in any new pan-European railway

information exchange systems need to be compatible with those specified
in the vehicle database.
Definition of a Vehicle
9.2.7 As noted in Sections 2 and 6 there are two ways in which the
meaning of “vehicle” needs to be clearly defined: what is defined as a
single rail vehicle and the retention of identity after major rebuilding.
9.2.8 In respect of the first issue it is recommended that a running

identifier is allocated to the each element of a vehicle that can be divided
and wheeled away on its own set of wheels (which might, for example,
include each bogie set for a road:railer train), and for each body or
chassis element that is customarily removed from a train or unit
formation. It is recommended that permanent identifiers (VINs) are
applied more widely: to every chassis/body unit, so that in addition to the
above in an articulated unit every section would have a unique VIN2.
This should provide clarity of ownership for every removable main
2
If an unstructured number is adopted, not requiring a VIN, the allocation of
running numbers would have to follow the recommendations for VINs, thus
necessitating more renumbering.
9-4
element but would avoid the need for widespread renumbering of

articulated units.
9.2.9 This proposal would provide differing definitions of vehicle

identity for the running and permanent identifiers. Whilst this is
undesirable there is no overriding need for identical definitions of vehicle
identity. This is because the permanent identifier would form the vehicle
master record and the running identifier would be merely an attribute and
thus the VIN would always be definitive,
9.2.10 The issue of defining a continuous identity for an asset is difficult

and is inevitably fraught with potential problems. It is recommended that
the VIN is allocated to the chassis unit of a vehicle, or if the vehicle is
integrally constructed (one without a separate chassis unit) to the body,
and that this forms the legal identity of the vehicle. It is recommended
that the continuous identity of a chassis be defined as only ending when
one of a number of specified events occurs, these being as follows:
manufacturer certifies that vehicle was never constructed;
chassis certified scrapped by the owner;
vehicle is amalgamated with another vehicle (certified by
remanufacturer, both existing VINs being cancelled and a new one
issued).
9.2.11 Vehicle Identification Numbers
9.2.12 It is recommended that the following information be coded or

indicated within the VIN:
manufacturer;
manufacturing plant (or other coding of the manufacturer’s choice);
serial number.
9.2.13 It is recommended that VINs be allocated by manufacturers, this

means that manufacturers need to be certified as fit to issue VINs and be
allocated with a code. In view of the pan-national nature of
manufacturers this needs to be done at an international level, worldwide
international agreement will be required on who does this. It is
considered that the best option is to have one regional body responsible
for this (for example, for Europe, the Americas, South East Asia,
Australasia, etc) and manufacturers active in more than one global region
(for example, Bombardier, Siemens, etc) are separately certified and
coded for each region.
9.2.14 No VIN number should be used more than once; once a vehicle
has been certified as no longer existing the VIN should be withdrawn.
9-5
9.2.15 It is important that the format of a VIN is different from that of

running identifiers, to prevent the numbers being confused
administratively. The need to accommodate existing vehicles dictates an
eleven digit serial number (see below), in addition codes of at least four
digits will be required for the manufacturer and plant code. The
manufacturer and/or plant codes could consist of letters, however, since
the Latin alphabet is not common across the geographic area of use,
numeric coding is recommended. It is suggested a nineteen digit VIN be
adopted which could be in the following form:
Manfact. Plant Serial

Code Code Number
0000 0000 00000000000

If manufacturers were to allocate numbers to their plants in blocks then
the four digit plant code could be dispensed with, shortening the VIN to
fifteen digits. However, it is considered that as a new system
unconstrained by past practice the future flexibility offered by the
nineteen digit number suggested is to be preferred.
9.2.16 UNIDROIT is supposed to be a world-wide system accordingly

the actual system will need international agreement, as it is recommended
that a single international system is adopted.
9.2.17 If a system of VINs is adopted approximately two million

existing European vehicles will require VINs (plus several million in
other parts of the world). It is recommended that the existing vehicle
running numbers are used, less the check digit, made up to the required
length by zeros added to the left of the number. In the case of vehicles
bearing twelve digit numbers, it is recommended that the first eleven
digits of this number are used as the serial number before being made up
with zeros in place of the plant code. In place of the manufacturer code it
is recommended that to avoid duplication around the world that a simple
code is used to identify the region, so that the various European
numbering systems could be prefixed 0100 to 0199, North America to
have the range 0200 to 0299 allocated, etc. Manufacturers’ codes would
start at 1000 and thus any pre-existing vehicle would be immediately
identifiable by its leading zero.
9.2.18 It is recommended that, as a minimum, the unique identification

numbers of the following major components are held on official
databases (which does not preclude additional information being held on
a national basis, if desired):
9-6
Traction
prime mover (engine);
transformer (electric traction);
wheelsets;
any removable component assembly costing more than 5% of the
first cost of the vehicle.
Multiple Unit Stock

VINs of other vehicles in unit;
prime mover (diesel multiple units);
transformer (electric multiple units);
bogie frames;
wheelsets;
Hauled Passenger Stock

bogie frames;
wheelsets;
Hauled Freight Stock

bogie frames;
wheelsets;
any major removable component assembly costing more than 5%
of the first cost of the vehicle.
Scope of Any Renumbering
9.2.19 With the exception of the above states it is recommended that any
new numbering system is applied to all vehicles used on the common
European rail system. The results of the cost benefit analysis depend on
the contribution that liberalisation of the vehicle numbering and entry to
service process would be likely to make to the to total benefits
anticipated from liberalisation of the rail sector. If a conservative
assumption is made that the overall contribution of liberalising these
activities is modest, the cost benefit analysis indicates that the option
9-7
generating the lowest Net Present Cost is to only apply the system to new
vehicles initially and allow existing vehicles to retain their old numbers.
However the need to change regime codes to meet Single Market
requirements and to indicate TSI compliance is likely to necessitate at
least some renumbering of existing vehicles and a phased introduction of
a new numbering system on a universal basis over a period of, say, six
years is recommended, subject only to the possible exceptions outlined
below.
9.2.20 If a new European numbering system is mandated it is

recommended that all railway networks which do not form a part of the
common European rail system with no regular exchange of vehicles with
other parts of Europe (for example, isolated networks and lines, narrow
gauge networks, etc) are excluded from the requirements. It is further
suggested that consideration is given to excluding states with unique
national numbering systems which would be disruptive to change for
vehicles which are not exchanged with the remainder of the common
European rail system. Similarly, it is recommended. However, it is
recommended that VINs are required in all cases, other than for
preserved vehicles over forty years old.
9.3 Tabulation of Recommendations
9.3.1 The recommendations are tabulated in Table 9.1, together with the
suggested prioritisation of each and the estimated timescale for
implementation. Short implementation timescale is defined as that which
it is considered can be implemented in less than five years, medium term
measures are those which it is judged can be implemented in a five to ten
year timeframe and long term measures are those which are likely to take
at least ten years to implement.
9-8
Table 9.1 – Summary of Specific Recommendations
Nature of Timescale for

Measure
Measure Implementation
Highest Priority Measures

Independence of Notified Bodies to be ensured Organisational Short
Process of placing vehicles in service, allocating them with numbers and placing them on
databases and common operational systems to be placed in the hands of independent bodies, Organisational Short
none of whose staff have either direct or indirect employment link with any railway undertaking.
Any contracts for use should be the same for all vehicle owners/keepers and be totally non-
Organisational Short
discriminatory.
Vehicle databases to be managed on a national basis by independent bodies. Organisational Short/Medium
Effective interfaces between national vehicle databases to be mandated and enforced by a supra- Organisational/
Short
national agency (e.g. ERA). Technical
Virtual international vehicle database to be established and managed by an independent supra- Organisational/
Short
national body. Technical
Vital national IT systems that use vehicle data or numbers (e.g. operating systems) should be
vested in independent bodies (e.g. infrastructure manager) with equal and non-discriminatory
access available to all those legitimately needing access. Accompanied by pan-European
definitions of the information on these systems than can be considered to be confidential.
9-1
Nature of Timescale for

Measure
Measure Implementation
All vehicle owners/keepers to carry conventional insurance for their fleet, with State of vehicle
registration to be responsible for verifying that it is held.
Structured twelve digit running number to be adopted, based on a modified version of the current
Technical Medium
UIC system.
Separate Vehicle Identification Number (VIN) to be used, to act as official identifier for vehicle,
Technical Short
a nineteen digit system is recommended, although a simpler fifteen digit system is also possible.
The term “vehicle” needs to be adequately defined, in terms of the vehicles to which VINs
Technical Short
should be applied, what a single vehicle comprises and the continuous identity of a vehicle,.
High Priority Measures
International Registry required by the UNIDROIT convention to be free standing & separate Organisational/
Short
database. Technical
Confidentiality filters to be provided in national IT systems not originally designed for multi- Organisational/
Short/Medium
user environments. Technical
State of vehicle registration to be responsible for verifying that vehicle owners/keepers are
maintaining their vehicles to acceptable standards. In association with freedom for vehicle Organisational Short
owners and keepers to chose the maintenance regime and maintainer for their own vehicles.
Exchangeable datasets of any new pan-European IT systems to be compatible with those

Technical Medium
specified for the vehicle database.
9-2

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Railway Vehicle Identification and Registration

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Colin Buchanan and Partners Introduction

Project No: 60751

Newcombe House, 45 Notting Hill Gate

Telephone: 020 7309 7000

6.4 Database and Register Issues 6-3

D. COUNTRY STUDY – FRANCE

E. COUNTRY STUDY – GERMANY

F. COUNTRY STUDY – GREAT BRITAIN

G. COUNTRY STUDY – POLAND

H. USES OF VEHICLE NUMBERS IN FREIGHT SYSTEMS

I. IT SYSTEM TYPES TO WHICH ACCESS IS REQUIRED

J. VALUES USED IN COST BENEFIT ANALYSIS

K. CODING OF RECOMMENDED RUNNING IDENTIFIER

1.1 Authority and Brief

1.1.1 In May 2002 a consortium led by Colin Buchanan and Partners

1.1.3 The main tasks defined by the Commission were to:

1.1.4 The Commission’s specification for this study is included as

1.2 The Study Team

1.2.1 The Consortium consisted of the following members:

1.3.2 The provision of services across national boundaries required a

1.3.3 Amongst the issues covered by UIC agreements is the mutual

1.3.4 The exchange of traffic between states requires a specific legal

1.3.5 The relative importance of rail as a mode has declined sharply in

affairs1. The role of vehicle identification systems needs to be seen

Figure 1.2 EU 15 Passenger transport - billion passenger kilometres

Figure 1.4 EU 15 Passenger Transport - Market share by mode 1970 -

1.3.6 To counter this sharp decline the Commission has spearheaded a

Commission’s communication on the integration of rail3. In many

1.3.7 A number of key pieces of legislation have become European Law

1.3.8 The two interoperability Directives have the greatest relevance to

all others, subject only to assessment of conformity with specific aspects

1.3.9 The basic prerequisite upon which the process of pan-European

1.3.11 A further important issue in the context of this study is the

1.4 Study Methodology

1.4.1 The study has been undertaken in six stages as follows:

1.4.2 To assist and advise the Consortium the Commission assembled an

1.4.3 The study considered the entire process of placing vehicles in

1.4.4 Data gathering and research encompassed investigation of the

1.4.5 To highlight the issues the general pan-European research was

1.4.7 The options for change were evaluated against a matrix to

1.5 Assistance Provided

1.6 Structure of Report

1.6.1 This Report is structured in nine sections as follows:

1.6.2 Additional information is contained in the Appendices to this

2.1 Placing Vehicles in Service

2.1.1 Current arrangements for placing vehicles into service consist of a

A flow chart illustrating this process can be seen in Figure 2.1.

Figure 2.1 Bringing a Rail Vehicle into Service

Commercial idea originated to meet a need

Commercial case made.

Tenders issued for construction.

Conformity check with original design.

Number painted on body of vehicle.

Permanent contract for use with schedule of

2.1.2 The process is broadly similar whether a vehicle is owned by a rail

2.1.3 For private wagons Article 2 (Acceptance of wagons for

2.1.4 The arrangements discussed above relate to an item of hauled

2.1.6 The process for technical approval of vehicles varies considerably

2.1.7 The increasingly complex technical environment of Europe’s

between sub-systems and need to verify that new equipment interfaces

2.1.8 International approvals are considerably simpler for hauled rolling

2.1.10 Liberalisation is changing the responsibility for technical

2.1.12 Once a vehicle has been accepted technically it still has to be

2.1.13 At present the process of issuing a number permitting normal