ERA-GUI-100.pdf - Europa

Guide for the application of the Art 14 (a) of the Safety Directive and Commission Regulation (EU) No 445/2011
on a system of certification of entities in charge of maintenance for freight wagons – VERSION 1.0
It is not regulated who should appoint the ECM. This is left to decisions of stakeholders. Article 33
of the Interoperability Directive indicates that the registration holder is responsible for providing the
information for registration of vehicles to the registering entity. This information includes among
others the denomination of the ECM.
Unless otherwise specified in the registration documents, the keeper of the vehicle is considered to
be the “registration holder” in the meaning of Article 33(3) of the Interoperability Directive (See
Annex 3.2.3 of the NVR Decision[11].
Nevertheless it is important to consider that, in practice, the tasks and obligations of RUs
and ECMs have to be described in contractual arrangements. These contractual
arrangements may also concern intermediaries such as keepers.
9.2 You are a Keeper, what are your responsibilities?
• restore the
vehicle in its
conditions of use
(design
operating state)
MAINTENANCE
DESIGN
OPERATING STATE
USE
USE
DEGRADATION OF
PERFORMANCE
• described in the
technical file
• the vehicle is
operated
• vehicle no more
in a design
operating state
RU
KEEPER
Page | 55