Four mega-railroads now control over 90% of U.S. rail traffic. A transcontinental merger would all but erase rail-to-rail competition, leaving farmers, manufacturers, and energy producers with even fewer choices.
The number Class I railroads have collapsed from 23 in 1983 to just 6 today—a more than 70% consolidation that stands among the most sweeping in U.S. transportation history. With competition gutted, shipping costs for farmers, manufacturers, and energy producers have surged. Rail rates have jumped more than 40%, rising twice as fast as trucking and overall inflation, and far outpacing demand or operating costs.
The stakes are especially high for chemical producers, who are among the largest customers of freight rail by both volume and revenue. Reliable, competitive rail service is critical not just for our industry, but for the entire U.S. economy.
For the chemical industry, freight rail isn’t just a logistical concern - it’s a lifeline that delivers chemical products that protect public health and support virtually every sector of the economy. Because end users of chemicals are part of every community in the country, huge volumes of chemicals are transported each year.
Figures compiled by the American Chemistry Council (ACC) show that 1.0 billion tons of chemicals were shipped in the United States in 2024 at a cost of around $76.2 billion.
In 2024, Class I railroads originated 2.2 million carloads of chemicals (8.2% of total carloads) and earned $13.3 billion in revenue from chemicals (16.5%).
Top 3 Shippers by Originated Units
- Intermodal (42%)
- Coal (11%)
- Chemicals (8%)
Top 3 Shippers by Tonnage
- Coal (24%)
- Chemicals (13%)
- Intermodal (10%)
Top 3 Customers by Revenue Generated
- Intermodal (18%)
- Chemicals (17%)
- Coal (10%) / Food Products (10%)
Sources: ACC’s Economic and Statistics Department; Association of American Railroads, The Transportation of Chemicals Volume 29/July 2025
Producing and moving more chemistry here at home is key to growing the economy. We need a competitive and reliable freight rail system that supports American innovation, manufacturing, and global leadership.
The American Chemistry Council (ACC) and its members are deeply concerned about the impact of further consolidation in the U.S. freight rail industry. We urge policymakers and regulators to reject any rail merger that does not clearly enhance competition and improve service.
- Monopoly power and loss of rail-to-rail competition: Four mega-railroads now control over 90% of U.S. rail traffic. Many rail customers are already only served by one railroad. A transcontinental merger would all but erase rail-to-rail competition, leaving farmers, manufacturers, and energy producers with even fewer choices.
- Service declines after mergers: Past mergers have triggered chronic delays and resulted in reduced service quality and fewer service offerings - disrupting supply chains and hurting the U.S. economy.
- Inflated shipping prices from consolidation: The number Class I railroads have collapsed from 23 in 1983 to just 6 today - a more than 70% consolidation that stands among the most sweeping in U.S. transportation history. With competition gutted, shipping costs for farmers, manufacturers, and energy producers have surged. Rail rates have jumped more than 40%, rising twice as fast as trucking and overall inflation, and far outpacing demand or operating costs.
If approved, it would be a huge concentration of market power in an industry already dominated by just a few U.S. railroads. The number of Class I railroads has collapsed from 23 in 1983 to just 6 today - a more than 70% consolidation that stands among the most sweeping in U.S. transportation history.
Four mega-railroads control 90% of the market. As a result - Service is unreliable. Rates have skyrocketed. A merger between UP and NS would create the first transcontinental railroad in the U.S. that would control almost half of the rail traffic in the U.S. and have an outsized control over our supply chains.
| | Chemicals | | Total |
| Million Tons | % of Total | | Million Tons | % of Total |
| BNSF | 35.6 | 18.8% | | 433.3 | 30.5% |
| CPKC | 10.8 | 5.7% | | 65.9 | 4.6% |
| CSX | 26.3 | 13.9% | | 238.6 | 16.8% |
| CN | 13.4 | 7.1% | | 105.3 | 7.4% |
| NS | 14.5 | 7.6% | | 210.0 | 14.8% |
| UP | 89.1 | 47.0% | | 369.6 | 26.0% |
Total | 189.5 | 100.0% | | 1,422.7 | 100.0% |
Creating a transcontinental rail giant threatens to leave American manufacturers, farmers and energy producers with even fewer competitive options to ship by rail.
Previous mergers have shown that bad things often happen when railroads consolidate - service declines, prices spike, all of which hurt consumers in the long run.
Sources: ACC’s Economic and Statistics Department; Escalation Consultants, Analysis of Proposed Merger Between Union Pacific and Norfolk Southern Railroads, September 2025; Association of American Railroads, The Transportation of Chemicals Volume 29/July 2025
The number Class I railroads have collapsed from 23 in 1983 to just 6 today—a more than 70% consolidation that stands among the most sweeping in U.S. transportation history.
