The misconception
A freight railway undertaking preparing its electronic consignment note (eCN) for the TEL TSI is increasingly likely to encounter the eFTI Regulation (EU) 2020/1056 along the way - usually via its date of 9 July 2027. The natural reading is that this is a second digital deadline stacked on top of the TEL TSI's own. It is not. The two obligations run in opposite directions, bind different parties, and - read correctly - the eFTI date does not touch a freight RU's obligations at all.
The asymmetry, precisely
Under the TEL TSI (Commission Implementing Regulation (EU) 2026/253), the electronic consignment note is a requirement the lead railway undertaking must meet. Under the eFTI Regulation, the obligation runs the other way. From 9 July 2027, competent authorities across the EU must accept regulatory information - including freight transport information - when an economic operator chooses to submit it electronically through a certified eFTI platform.
Economic operators, including freight railway undertakings, are not required to submit that information electronically. Article 4 of Regulation (EU) 2020/1056 is conditional: an operator's electronic-submission duties apply only "where the economic operators concerned make regulatory information available electronically." Nothing in the Regulation compels a freight RU to make that choice.
Article 16(1) requires the European Commission to evaluate, by 21 February 2029, whether an obligation on economic operators to use eFTI should be introduced. A regulation does not schedule a future decision on whether to impose a duty that already exists today. The evaluation clause is itself the clearest evidence that no such duty exists yet.
If an operator does choose the electronic route, eFTI's conditions then attach: a certified eFTI platform, machine-readable data, and a unique identifying link (Arts. 11–13).
Is rail even in scope?
Yes - indirectly. eFTI's Annex I, Part A lists the EU legal acts whose regulatory information falls within scope, and it includes Directive (EU) 2016/797 (rail interoperability - the parent directive of the TEL TSI itself) and Directive 2008/68/EC (the carriage of dangerous goods, RID). There is no standalone CIM consignment-note subset in eFTI's scope list. Rail-relevant obligations enter mainly through dangerous-goods data and through Council Regulation No 11 - the same 1960 instrument the TEL TSI itself uses to define "consignment note" (via its Article 6). eFTI and the TEL TSI ultimately point at some of the same underlying legal furniture, even though they regulate different things.
What actually overlaps
The honest picture is: semantically high, technically low.
The underlying facts overlap substantially. Both the eCN and the eFTI common data set need to know who the consignor and consignee are, where the goods were taken over and where they are to be delivered, what the goods are, their gross mass, and - where relevant - dangerous-goods particulars. A freight RU assembling an eCN is already gathering most of what eFTI would need to know about the same movement.
The technical structures are a different matter. The TEL TSI's eCN derives from the TAF/TAP TSI message family - specifically the UIC RailData ORFEUS ECN v1.6 XML schema - which is organised around the wagon and the train. The eFTI common data set (Delegated Regulation (EU) 2024/2024) is built on the UN/CEFACT Multi-Modal Transport Reference Data Model (MMT-RDM), which is organised around the consignment. UNECE's own analysis of mapping rail data onto the MMT-RDM concluded that a full, automated conversion between the two is not achievable - the structures do not line up cleanly enough for that. Code lists differ too: the eCN uses NHM/ETSNG goods classifications, which would need reconciling against eFTI's own code lists. And a meaningful share of what the eCN carries - wagon numbers, train composition, brake data, estimated times of interchange and arrival - is operational detail that eFTI's common data set has no use for at all.
"Build once, serve both" - what that honestly means
Rail freight discussions sometimes reach for "build once, serve both" as shorthand for this overlap. Taken literally, that claim overstates things. Building the eCN does not, by itself, make a freight RU "eFTI-compliant" - there is no such status to claim in the first place, since eFTI compliance is not a property of an operator's own systems. It is a property of using a certified eFTI platform, which is a separate, externally-audited category of provider (see below).
What is true, and useful, is narrower: the eCN work is a genuine head start on any future eFTI use, because the facts have already been gathered. A mapping and transformation step between the two schemas would still be required, and the eFTI/eIDAS layer - the unique identifying link, the access mechanism, the audit trail - is supplied only by a certified eFTI platform, not by an eCN system. "Head start," not "substitute," is the accurate frame.
The certified eFTI platform boundary
"eFTI platform" and "eFTI service provider" are regulated categories under Articles 11–13 of Regulation (EU) 2020/1056, not descriptive labels any software can adopt. A platform must be certified by a Conformity Assessment Body accredited under Regulation (EC) No 765/2008, and information supplied through a certified platform carries a certification mark under Article 12(3). Nothing about preparing, mapping, or assessing eCN data - the work a compliance tool like this one does - touches that regulated category, and nothing here should be read as implying otherwise.
The dates that actually bind a freight RU
Set the eFTI date aside, and two TEL TSI dates remain squarely relevant to a freight RU:
- 30 September 2027 - the Article 21(4) deadline to deliver the freight sector's own common specification.
- 9 December 2029 - the freight core bundle deadline, which includes the electronic consignment note itself.
9 July 2027 is not one of them. If you arrived at this page because you had heard otherwise, that is the one thing to leave with: it is not your deadline. It is the date competent authorities must be ready to accept what you might, one day, choose to send them electronically.