## COMPARISON OF CHARACTERISTICS OF REGULATION/DEREGULATION AMONG THE USA, THE UK AND JAPAN

This comparison table was compiled by the ERI staff members, based on the eleven industry papers presented by the co-study participants. The staffs are responsible to any inadequateness of the references and misunderstandings. For quotations, please use the original industry papers.

ITEMS	JAPAN	UK
A. BRIEF HISTORY	The Road Transport Law, enacted in 1951 and revised in 1953, gave the MoT authority for licensing new entry and approving fare setting. Compared to passenger transport, economic regulation of trucking tended to be much more relaxed. As for fare regulation, the MoT approved tariff band, allowing carriers to set fares; for new entry the law required that the balance of supply and demand would not be disturbed, but a new carrier could prove that to enter. The largest problem of the regulation was the supply-demand balancing clause as a condition to licensing, under imperfect information for the regulator. In 1990 the Motor-truck Transport Business Law was enacted. The law relaxed entry and pricing regulations. The license system was replaced by permission system. Fare and charge regulation was changed from approval system to filing system. Still, some safeguard clauses remain to cope with entry under excessive supply and filing of price much different from costs. The Law repealed the distinction between the area and consolidate operations to allow carriers to introduce more flexible operation, though it introduced a “special consolidate operation” category, which is similar to the former line-haul carriers.	The 1947 Transport Act nationalized long distance haulers, and private haulers were limited to a radius of 25 miles. The limitation of licensing private carriers were subsequently relaxed, but the licensing was strictly operated, rejecting applications in ease of excess capacity, and restricted numbers of vehicles which could carry freight. The nationalized hauler remained the largest with the share of 5% of all hire and reward vehicles. The 1968 Transport Act changed the licensing system from quantity to quality regulation, thus lowered entry barriers. The National Freight Corporation (NFC) was formed to incorporate all the nationalized road freight activities. The Act created a system of licensing (quality licensing) and removed the number of vehicle restriction. To obtain an operator's license, applicants had only to show sufficient financial standing and resources to maintain vehicles. The nationalized NFC was privatized in 1982, after reconstructing its financial basis. The privatization took the form of an employee buy-out. In 1994 the licensing system was further relaxed by introducing continuous licensing instead of fixed term ones.
B. GENERAL ASSESSMENT	The characteristics of Japan's trucking industry regulatory change were that it was brought about by new legislation, that it was accomplished without “foreign pressure”, and that the industry there are large number of small carriers, mostly private. Even before the regulatory change, economic regulations had not been so tight, and the change might be just the ratification of the existing state of affairs. The regulatory reform was substantial, but not complete, and its effect on promoting competition are not clear so far.	The European Commission has had an indirect impact on domestic regulation as a result of successfully promoting changes in the regulations governing international haulage and cabotage, and thereby creating dynamism in the EU freight sector. Before 1985 most national markets were tightly controlled by governments, both in haulage capacity and price charged, but since then there was a change to a more liberal approach. Also since the mid-1980s a gradual harmonization of transport policies has been implemented.