Wagon owners association UIP shared their analysis of the Swiss and European (JNS) approaches with RailFreight.com, so let’s take a closer look at their findings.

It immediately becomes clear that Switzerland has opted for a less nuanced direction. Bern has chosen to reclassify all tread-braked wheelsets as non-thermostable, regardless of design or performance. By contrast, the JNS only targets specific wheelset types that carry proven risks.

This, according to UIP, allows maintenance resources to be concentrated at the vulnerable wheelsets. The Swiss approach, the association says, disregards established technical standards and creates an additional operational burden and maintenance requirements. The safety benefit of this is questionable.

Wheel diameter

A second important regulatory change concerns the minimum required wheel diameter. A larger diameter should lead to more robust wheels. Here too, Switzerland takes a different approach than the JNS.

Switzerland requires many types of wheelsets to have an increased diameter of 864 millimetres, even if they have no history of failure. It also only looks at the nominal axle load at moments of failure, without considering the prior operational life of a wheelset.. The JNS, by contrast, only requires this when there is a documented history of failure that indicates a risk based on a scientific assessment.

The FOT approach “results in the premature withdrawal of functional wheels and reduces wagon availability”, says UIP. Perfectly safe and functional wheels would have to be replaced.

Inspections and monitoring

UIP also compared the approaches to inspections and monitoring. Switzerland opts for distance-based inspection requirements. This, however, “does not take into account that wagons already undergo maintenance interventions at predictable as well as unscheduled intervals, during which wheelsets are inspected”, says UIP.

The system would lead to thousands of additional dedicated workshop visits. Yet, they would not specifically target the highest-risk wheelsets. This threatens overwhelming workshop capacity in Europe, according to UIP.

“Given Switzerland’s central role in Europe’s north–south freight corridors, this additional workshop demand could affect the availability of wagons used in international traffic. This may have implications for cross-border freight flows such as intermodal traffic between North Sea ports and Italy, chemicals transport and other bulk commodities transiting the Swiss network.”

UIP evidently prefers the JNS approach. It is said to achieve comparable safety outcomes by integrating inspections into existing maintenance workflows. It strengthens safety while maintaining operational feasibility.

Deadlines and timeline

The FOT and JNS also diverge when it comes to implementation deadlines. Initially, the Swiss FOT demanded full implementation by 31 December 2025. This was met by much dismay on the part of the rail freight industry. Switzerland later extended some deadlines to late 2026.

UIP looks much more favourably upon the JNS framework, which establishes differentiated timelines matched to the complexity of each measure. “Immediate action is required where urgently needed (e.g. thermo-stability reclassification) while structural changes affecting large parts of the fleet are phased in until 2027 and 2029. The JNS framework also strengthens the crucial role of ECM certification bodies to assess the implementation of the measures in their ECM audits”, explains UIP.

‘Release to Service’ and ‘Release to Operation

’The amendments to the protocols ‘Release to Service’ and ‘Release to Operation’ clarify who is responsible for what, when responsibility transfers, and what information needs to flow between parties., UIP said. What is new is the explicit inclusion of Entities in Charge of Maintenance (ECM) “as the entity responsible for the outcome of maintenance”. Thus, there is a continuous and clear chain of responsibility from the ECM all the way to the RU using the wagons.

GCU Broker Platform

UIP, together with the European Rail Freight Association (ERFA) and the International Union of Railways (UIC), developed the GCU Broker Platform in 2019 and are continuously improving it. Its objective is to digitalise and optimise the obligatory exchange of data on defects and the outcome of repairs processes, UIP underlined. “The platform replaces what were often fragmented, paper-based or bilateral processes with a standardised digital exchange”. This, together with the clarified on-site maintenance rules, is expected to make the maintenance of rail freight wagons seamless and efficient.

“The agreed risk control measures do not justify the introduction of additional national requirements outside the common [JNS] framework”, says the International Union of Wagon Keepers, UIP, in response to the FOT’s decision.

Both the new JNS safety rules and Switzerland’s own rules are a response to the Gotthard Base Tunnel derailment of 2023. A broken wheel caused the accident that led to considerable infrastructural damage and severe disruptions for rail freight for a whole year. An investigation found that new composite break blocks presented a systematic risk of wagon wheel breakage.

The court says “no”

Previously in December, a Swiss court had annulled the unilateral FOT measures relating to rail freight wagon wheel safety. That decision followed a lawsuit that was filed by wagon owners Ermewa, GATX and VTG. The FOT was given an extended deadline to appeal the decision by 24 January, but the Swiss approval of the common European rules made an appeal seem unlikely. However, the Alpine country went ahead with an appeal on 23 January regardless. The FOT will await a new court ruling, expected at the earliest by June 2026, says UIP.

“This sequence of events highlights the difficulty of maintaining consistency when collective efforts are later overridden by unilateral national measures which creates legal and operational uncertainty across the rail system”, comments UIP.

When Switzerland first introduced its rules in September 2025, some stakeholders expressed fear that the extra costs associated with the rule would hinder rail freight’s competitiveness and lead to a reverse modal shift from rail to road.

Safety is paramount, but so is regulatory unity

However, UIP now tells RailFreight.com that this is not the core objection to the Swiss course of action. “The issue is not about whether the Swiss measures are stricter or would lead to higher maintenance costs. Safety in rail freight is non-negotiable and remains the overriding priority for all actors involved.”

Rather, it is the effective introduction of a second set of requirements alongside the existing European framework that “risks fragmenting the coordinated approach that underpins the Single European Railway Area.” With Switzerland being a key transit country, especially on the Rhine-Alpine Corridor, its unilateral rules could harm key European rail freight flows by introducing additional regulatory complexity.

However, this requirement will not be made mandatory, thus road freight companies will be allowed to use the extra space to transport more goods. This is bad news for rail freight for two reasons. First, it makes road transport even more attractive, as prices are likely to lower even more if one journey can transport more goods. Secondly, a significant number of rail wagons will not be able to accommodate EMS, hindering interoperability.

There is still a glimmer of hope

All these problems were (once again) highlighted by six sector associations, including UIRR, ERFA, CER, RFF, UIP and UNIFE. “The road transport sector can expect economic gains – but society will have to wait for any reduction of the environmental footprint of logistics”, they said in a joint statement in reaction to the Council’s adoption of the general approach. Not all is necessarily lost, though. According to the six signatories, there is still hope.

The vision of a real European, interoperable logistics ecosystem can still be achieved if three parameters are met. First, WDD incentives should only apply to zero-emission vehicles or vehicles involved in intermodal transport. Second, interoperability between different modes of transport should be ensured. Finally, Member States should be required to carry out studies on the potential impact of EMS on their roads. “Any outcome falling short of these parameters will trigger an undesirable reverse modal shift from rail to road”, they underlined.

The impact on society

Introducing EMS on European roads would not only hamper the rail freight sector, but also have a negative impact on society and our pockets, as RFF’s latest campaign We All Pay For highlights. More money for road maintenance and more and graver accidents are just the main problems. There would also be more pollution, especially if the reverse modal shift feared by the rail freight industry continues to grow.

What happens now?

The Council’s adoption of a general approach basically means that the EU Member States agreed on the current version of the WDD. This was a key step before the start of trialogue negotiations with the Commission and Parliament, after which the Directive can be adopted.

Persisting doubts

Despite this development, DAC is still a controversial initiative. Its cost, for example, continues to be the subject of many debates. The most optimistic estimates say that the migration to DAC across Europe will cost 8,5 billion euros, while the highest are set at somewhere between 20 and 30 billion euros.

And a probably more important question is who is going to have to pay for this ginormous amount of money. Some argue that the rolling stock industry should absorb the costs, while others think that EU institutions should cover all expenses given the European reach of the initiative. Which takes us to the final issue.

Does DAC really need to be deployed on every rail freight wagon that circulates in Europe? Even DAC ambassadors acknowledge that a full migration will likely never be obtained, especially given the estimated costs. On the other hand, specific segments such as single wagonload could benefit from the technology.

The Swiss rules

The FOT introduced new requirements that could significantly disrupt rail freight flows, especially considering the importance of Switzerland as a transit country. New minimum requirements and more frequent maintenance checks were announced in September, with a deadline for implementation set for the end of 2026. This unilateral move was criticised by many, including the International Union of Wagon Keepers (UIP).

Gilles Peterhans, Secretary General of UIP has been among the most critical regarding this initiative. On one hand, he pointed out how “Switzerland is not respecting its agreements with the EU” by introducing national measures that will have an impact on the flow of goods across the Old Continent. On the other hand, he also scolded EU institutions. “The silence from the EU in defending its Single Market and the JNS process must change. The EU must take a firm stance against Swiss unilateralism”, he added.

Almost 50,000 wagons might be sidelined

The new rules set out by the Swiss Federal Office of Transport (FOT) change the minimum diameter required for wheels from 860 to 864 millimetres and would introduce more frequent maintenance checks. In reality, this new threshold would make many of the wagons currently in operation unfit, leading companies and associations to sound the alarm. “The rules create a range of serious challenges, including to the integrity of the European Single Market”, UIP pointed out.

The Union said it “represents a fleet of a quarter of a million, which is around half of Europe’s wagons. Wagon keepers have strived to adapt so that only 20% of this fleet would be affected by the Swiss FOT ruling.” This means that at least 46,000 wagons are still in danger of not being able to run in Switzerland, a key transit country for European rail freight, UIP stressed.

European recommendations expected for year’s end

Switzerland’s decision comes in the aftermath of the accident inside the Gotthard Base Tunnel, which occurred in the summer of 2023 and disrupted traffic for almost a year. The main issue at hand is that the Joint Network Secretariat is already working on developing updated recommendations on a European level in response to the accident, which are expected for the end of this year.

On the other hand, the Helvetic Federation decided to take matters into their own hands, without considering the impact for other European countries. “By keeping its unilateral national measures on the table, Switzerland is jumping to conclusions without respecting the pan-European processes already in place and, without the necessary multilateral technical debate”, UIP reiterated.

The wagon keepers union is thus asking to use the extended timeframe to find a common and harmonised framework for implementation by the end of 2026. However, Switzerland seems pretty firm on its decision, as it claims it would significantly improve safety. How the story will unfold remains to be seen, but worries remain at a high level, especially for Italy, which heavily relies on Switzerland to move its goods towards northern Europe.

The safety measures come in five parts. For one, the FOT wants wheelsets to have a diameter of at least 864 millimetres. The current European standard is 860 millimetres. Moreover, the Swiss government agency wants more regular maintenance.

Maintenance intervals

“Depending on the type of brake shoes and wheel diameter, the technical inspection must be carried out after 50,000 kilometers or 200,000 kilometers. Currently, in some cases, these inspections are systematically carried out at a later date.”

As part of maintenance checks, wheels should be visually inspected and the minimum diameter checked. Checks should also determine whether the wheels have suffered heat or other damage, and a sound test should be carried out to identify defective wheels.

In the future, every freight wagon must have a valid certificate of its last technical inspection. This allows railway companies to check whether a wagon has been properly maintained before it is included in a train traveling through Switzerland.

The safety of wagon wheels has become a top issue since the 2023 derailment in the Gotthard Base Tunnel, which caused severe infrastructure damage and kept the tunnel closed for a year. The incident posed a major challenge for rail freight on this crucial route. A derailment on Sweden’s Malmbanan line was also the result of a broken wheel.

Wagon owners are furious

Many voices in the rail freight industry are now protesting the FOT’s new rules. The International Union of Wagon Keepers (UIP) calls it “a rogue move”. UIP points out that Switzerland primarily targets wagon owners and those in charge of maintenance.

“We deplore a one-sided view that basically relieves the other rail system actors of their duties and does not consider safety investments on the side of operations and infrastructure”, the association adds. It also points out that in the case of the Gotthard accident, the investigation found that wagon owners complied with maintenance obligations.

The Swiss rail freight association VAP concurs. “With these new measures, the Federal Office of Transport is placing disproportionately high obligations on wagon owners compared to other stakeholders.” VAP highlights the reduced maintenance intervals as particularly disruptive, because it will “massively impact the availability of freight wagons and the profitability of operations.”

The maintenance interval measure, according to VAP, will lead to short-term bottlenecks in the freight industry and harm Switzerland’s supply security. “This topic was frequently discussed in advance and at the roundtables, but surprisingly little was considered in the FOT’s decision-making process.”

The Swiss association also foresees a reverse modal shift, rail freight’s nightmare scenario, because of the additional costs.

Absurdity

Across the border, Germany’s wagon owner association VPI also sharply criticised the FOT’s new rules. It highlights similar issues as VAP and UIP, and says that the new rules ignore the results of the so-called Joint Network Secretariat (JNS), an initiative by the European Agency for Railways (ERA) that aims at EU-wide harmonisations actions following rail accidents or incidents.

“It reduces to absurdity the relevance of the work of the JNS task force, which is expected to publish its European measures by the end of the year”, UIP also says about the step taken by FOT.

Switzerland wants the measures to be fully implemented by the end of the year. VAP, UIP and VPI all question the viability of that plan. Maintenance companies already lack resources, points out VAP, and the new rules will make that situation worse. More freight wagons will be unavailable more often and for longer periods of time.

“This, too, will initially be felt primarily by the freight forwarding companies, as they will need to purchase more wagons to transport the same volume of goods. As a consequence, more and more shippers are likely to turn away from rail freight transport and transport their goods by road in the medium term”, VAP states.

An obstacle to Rhine-Alpine rail freight

Importantly, the new Swiss rules also endanger cross-European interoperability. With its unilaterally introduced measures, Switzerland deviates from common European standards. Wagon owners may have to establish wagon fleets specifically adapted to Swiss rules, adding another cost factor to the mix. With Switzerland centrally located along one of Europe’s most important rail freight corridors (Rhine-Alpine), the rules impact a key artery for international traffic.

Wagon owners’ union UIP hopes that the focus will shift onto railway undertakings (RU) and the infrastructure manager: “It is unacceptable that RUs keep scaling back their technical on-site inspections and cutting investment in staff education, especially in a system that crucially depends on rigorous controls before, during, and after train operations.”

“We would do well to remember that […] the investigation identified areas for action not only for wagon keepers but also railway undertakings and the infrastructure manager”, UIP notes.

More specifically, the top priorities identified in a joint letter sent to the EC were the deployment of the European Train Control System, the Future Railway Mobile Communication System (FRMCS) and the Digital Automatic Coupling. “The TSI amendment related to FRMCS should be made available as soon as the specifications are delivered, expected by the end of 2026 – beginning 2027”, the letter stated.

These are the ten associations that sent the joint letter to the DG Move, the mobility and transport branch of the European Commission.

• European Rail Rolling Stock Lessors (AERRL)
• Alliance of Passenger Rail New Entrants (ALLRAIL)
• Community of European Railways and Infrastructures Companies (CER)
• European Infrastructure Managers (EIM)
• European Federation of Museum & Tourist Railways (FEDECRAIL)
• Notified Bodies Association (NB-Rail)
• International Union of Private Wagons (UIP)
• International Union of Combined Road-Rail Transport Companies (UIRR)
• International Association of Public Transport (UITP)
• The European Rail Supply Industry Association (UNIFE)

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Associations like UIRR, CER and ERFA have stressed that the intermodal measures included in the WDD are irrelevant or ineffective for rail freight transport. For instance, Akos Ersek, chief policy advisor at UIRR, pointed out in an interview with Railfreight.com that deploying heavier and longer commercial trucks could prove tricky since heavy cargo should, in principle, travel on rail and not on trucks.

On the other hand, leading policymakers like Kristian Schmidt, director of land transport at DG Move, underlined to RailFreight.com that the WDD revision would benefit intermodality by “ensuring intermodal compatibility and incentivising road operators to engage in intermodal operations”. However, a study commissioned jointly by ERFA, CER, UIC, UIP and UIRR and carried out by the consultancy firm d-fine seems to challenge this argument.

Widespread use of gigaliners

The five parties insist on their initial position that the WDD revision proposals are “impractical, ineffective, or unnecessary”. Their study found that the “proposed increase in the permissible gross weight of trucks and the authorisation of EMS would lead on average to a modal shift from rail to road of up to 21 per cent for all rail segments and 16 per cent for combined transport”.

Simply put, the five associations warn that the EU Commission’s approach will result in the widespread use of gigaliners, decreasing operational costs by up to 25 per cent and outperforming combined transport, despite simultaneously raising external costs to 2,2 billion euros.

Compatibility a real issue

Despite Kristian Schmidt reassuring that the WDD revision would ensure intermodal compatibility, this does not seem to be the case. The d-fine study found, for instance, that the proposed increase of 30 cm in vehicle height would already pose challenges since “21 EU Member States have a 4-metre height limit for trucks.” At the same time, the WDD revision projects a limit of 4,30 metres for trucks carrying high-cube containers.

Longer trucks will also create challenges for intermodal operations. The joint study points out that “none of the longer EMS truck combinations can be handled in combined transport without increased operational complexity”. Longer than 13,6 metres, semi-trailers are technically incompatible with combined transport assets. At the same time, longer and heavier vehicles will also hinder terminal operations since they will, in many cases, not be suitable for transit via access roads, while many terminals do not possess the proper equipment to handle such heavy loads.

Some proposals

For this reason, the five associations demand that the gross weight limit for border crossing trucks remain at 40 tonnes and not at 44 as the Commission proposed. Only zero-emission vehicles should be allowed an additional gross weight as long as the batteries they use require it. Finally, the five parties stress that standard dimensions for loading units should be maintained despite the introduction of gigaliners because that is the only way to ensure intermodal compatibility as promised by the EU Commission.

“We do not see a positive impact”

All parties involved in the study stressed that they struggled to identify the relevance of such measures and how they could positively impact freight transport and rail. Conor Feighan, secretary general of ERFA, commented that the industry cannot see how the WDD revision could bring forward positive developments. Moreover, Gilles Peterhans, secretary general of UIP, pointed out that longer and heavier trucks will also dictate future rail investments which will not be industry-oriented but instead focus on adapting to road transport requirements.

Alberto Mazzola, executive director at CER, said that “rail freight will lose more volumes than the European Commission predicted,” and the current WDD “is not a measure of greening freight transport”. Indeed, the EC’s prediction spoke of approximately 5,5 billion tonne-kilometres in losses for rail, while the d-fine study illustrated the losses at around 140 billion tonne-kilometres, a substantial difference.

François Davenne, director general at UIC, also raised some interesting points. He mentioned that the EC lacks a systemic approach considering both rail and road transport. He also stressed the issue of batteries by asking a simple but critical question: “Will there be enough batteries to decarbonise the road sector?” he wondered. His point was that if there are not enough resources to decarbonise truck operations, then the WDD measures will end up disrupting the freight market almost irreversibly by benefiting diesel operations.