COMMISSION OF THE EUROPEAN COMMUNITIES 
CCM(93) 247 final 
Brussels, 2 June 1993 
$. .-is 
COMMUNICATION FROM THE COMMISSION TO THE COUNCIL 
AND THE EUROPEAN PARLIAMENT 
i^' 
CONTENT 
1. INTRODUCTION 
1.1 IMPORTANCE OF THE POSTAL SECTOR 
1.2 OPERATIONAL PROBLEMS 
13 THE GREEN PAPER AND ITS PROPOSALS 
1.4 THE PUBLIC CONSULTATION PROCEDURE 
2. THE APPROACHES WHICH EMERGE FROM THE CONSULTATION PROCEDURE 
2.1 GENERAL APPROACH 
22 COMMON DEFINITION OF UNIVERSAL SERVICE 
23 MAINTAINING RESERVED SERVICES 
2.4 SERVICE QUALITY STANDARDS 
2.5 MEASURES TO PROMOTE HARMONIZATION 
2.6 SEPARATE REGULATORY AND OPERATIONAL FUNCTIONS 
2.7 TERMINAL DUES 
2.8 INTERNATIONAL ASPECTS 
3. IMPLEMENTATION 
3.1 THE ACTION PROPOSED 
32 THE CONSULTATION PROCEDURE 
4. CONCLUSION 
Annex 1: Main options in the Green Paper 
Annex 2: Reactions to the Green Paper 
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1. INTRODUCTION 
1.1 IMPORTANCE OF THE POSTAL SECTOR 
The importance of postal services within the Community is illustrated by some statistics. 
They produce a turnover of more than ECU 60 billion, i.e. 13% of GDP; they are labour 
intensive and employ more than 1 700 000 workers, which makes them one of the principle 
employers in the Community. In addition, the sector enjoys steady and continuous growth. 
Because they are an essential vehicle of communication and trade, postal services are vital for 
all economic and social activities, even if in some cases they may be replaced by other means 
of communication. In fact the importance of postal services even seems to be increasing as 
economic operators use them more and more. 
The most important of these are mail order companies, direct marketing firms and magazine 
and newspaper services, particularly for specialized publications. 
A final important fact is that exchanges of letters help to reinforce social contact and to 
develop links between individuals and companies in different areas. 
1.2 OPERATIONAL PROBLEMS 
However, the current performance of the postal service causes a number of problems, which 
justify action at Community level. 
Inadequate service quality 
As far as internal mail is concerned, the quality of the universal service in the Member States 
varies considerably from one postal authority to another. In some countries, 90% of letters 
arrive the day after posting, while in others the figure is as low as 15 or 16%. 
Such variations considerably affect those sectors which are particularly dependent on the 
postal services. In some key sectors like magazine and newspaper services, financial services, 
mail order and advertising, this can constitute a real barrier to trade. This has the effect of 
limiting the freedom of choice of individual consumers. 
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Guidelines for the Development of Community Postal Services 2-
The average delivery time for cross-border mail is four days compared with between one and 
a half and two working days for internal mail. The generally stated aim of a three-day 
delivery time for cross-border mail is in fact achieved in only 40% of cases. 
This difference in service quality serves to emphasize borders and thus disrupts the single 
market. It has the effect of penalizing those companies who use the postal services to market 
their products in a Member State other than their own, giving firms based in that 
Member State an advantage. 
Lack of harmonization 
Operators of the universal service work in many different ways and there is no common 
definition. Standard mail categories also differ from one Member State to another. Hence 
there is room for improvement in the interoperability of the postal networks of the different 
Member States. 
Differences in service quality 
Differences in the quality of postal services hamper the internal cohesion of the Community, 
since those regions where the quality of postal services is inadequate are at a disadvantage in 
terms of both communication needs and distribution of goods. 
Trade distortions 
Apart from the distortions which affect companies dependent on the postal services for their 
commercial activities, there are trade distortions in the postal sector itself, in those cases 
where the reserved area is greater than that necessary to provide the universal service. 
13 THE GREEN PAPER AND ITS PROPOSALS 
In September 1989, the Coucnil of Ministers invited the Commission to prepare measures 
intended to develop the postal sector. In the Green Paper on the development of the single 
market for postal services submitted on 11 June 1992, the Commission proposed a set of 
measures designed to solve these problems, and examined various policy options: complete 
liberalization, complete harmonization, status quo and a scenario combining liberalization 
and harmonization. 
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The Commission favoured the last scenario, which combines a gradual opening up of the 
market with consolidation of the principle of the universal service and selective 
harmonization, in accordance with the following policy objectives: 
1. TO ESTABLISH A COMMUNITY DEFINITION OF THE UNIVERSAL POSTAL SERVICE 
REQUIRED; THEN TO ENSURE ITS PROVISION THROUGHOUT THE COMMUNITY AT PRICES 
AFFORDABLE TO ALL THROUGH THE ESTABLISHING (INASMUCH AS IT WAS NEEDED IN 
MEMBER STATES INDIVIDUALLY) OF A SET OF RESERVED SERVICES WHICH WOULD 
CONFER SOME SPECIAL AND EXCLUSIVE RIGHTS, IN ORDER TO MAINTAIN THE 
RESOURCES NECESSARY FOR THE UNDERTAKING OF THE PUBLIC SERVICE MISSION IN 
SOUND CONDITIONS; AT THE SAME TIME, CONSISTENT WITH THIS OBJECNVEJTO HAVE 
THE LARGEST POSSIBLE PART OF THE SECTOR OPERATING IN FREE COMPETITION 
2. TO HAVE COMMON OBLIGATIONS FOR THE UNIVERSAL SERVICE OPERATORS OF THE 
COMMUNITY IN RESPECT OF THE SPECIAL AND EXCLUSIVE RIGHTS GRANTED TO THEM 
BY THE RESERVED SERVICES IN ORDER TO PROVIDE UNIVERSAL SERVICES, IN 
PARTICULAR WITH REGARD TO THE QUALITY OF SERVICE PROVIDED. 
3. TO MAKE ANY NECESSARY EFFORTS TOWARDS COMMUNITY COHESION THROUGH 
APPROPRIATE HARMONISATION MEASURES. 
The options set out in the Green Paper are described in detail in Annex 1. 
1.4 THE PUBLIC CONSULTATION PROCEDURE 
The public consultation involved all interested parties, continued until the beginning of 1993 
and provoked considerable response.1 The Commission received more than 200 written 
submissions from a wide range of sources. In addition to comments from the authorities 
(European Parliament, Economic and Social Committee and national authorities), there were 
many contributions from public and private operators and users (consumer associations and 
businesses). 
1 See in Annex: "Results of the public consultation". 
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Guidelines for the Development of Community Postal Services 
It is no doubt due to the complexity of the issue that some contributions arrived relatively 
late2* The list of written contributions which have been received is contained in the latest 
annex. 
The Commission regrets however that some governments and public operators did not respond within the time 
limit. 
Guidelines for the Development of Community Postal Services - 5 -
2. THE APPROACHES WHICH EMERGE FROM THE CONSULTATION PROCEDURE 
2.1 GENERAL APPROACH 
The need for action at Community level, identified by the Council in 1989 and developed in 
the Green Paper, has also been felt by all the parties involved in the postal sector who are 
looking for a harmonisation of the principles and the concepts in the postal sector. The 
concensus which has emerged in this regard during the consultation is based on the following: 
- the dysfunctions observed, particularly in relation to cross-border traffic, are damaging to 
the creation of the Single Market and impede the reinforcement of economic and social 
cohesion as well as general economic competitiveness; to remedy this frontier effect, a 
Community response which will reduce existing disparities is called for; 
- national policy, which retains its important role, should be complemented by Community 
action with the aim of responding better to the needs of users, for an improved quality of 
service and of reinforcing the effectiveness and competitiveness of the sector. 
A large majority of contributors endorsed the main approaches proposed by the Commission 
and there was virtually unanimous approval by all concerned of the basic scenario adopted 
and the main principles on which it was based. 
The same applies to the concept of the universal postal service, which almost all contributors 
consider essential. A very large majority of commentators were in favour of a reserved sector. 
All considered that emphasis should be placed on improving service quality. It seems clear 
that the present system of terminal dues should be changed and it was unanimously felt that 
regulatory and operational functions should be separated. 
Finally, the general opinion was that consultation should not stop at this stage but should 
continue throughout the process of defining and establishing Community rules on postal 
services. 
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Guidelines for the Development of Community Postal Services 
12 COMMON DEFINITION OF UNIVERSAL SERVICE 
2.2.1 Outcome of the consultation procedure 
The concept of the universal service was considered as the basic concept. All 
contributors considered that a common definition of universal service was 
essential before tackling all the other issues. 
Most contributors felt that the definition of universal service should be broad and 
should apply to all mail (some mentioned a 2 kg weight limit). The universal 
service should be based on a uniform structure of reasonable prices and a 
universal network. 
Opinions were divided on the sending of goods by post (parcel post). 
2.2.2 Approach proposed by the Commission 
Development of the postal sector must be based on the concept of universal 
service. This implies that Member States must provide a high quality postal 
service available to all at reasonable prices throughout the Community, including 
both national services and cross border services. 
The concept of universal service should therefore be defined at Community level. 
This definition would be taken as a minimum reference, after which each Member 
State would be allowed to adopt a more extensive definition in accordance with its 
own legitimate interests. The reference definition should mention provision of the 
service, categories of mail and the specific services concerned. 
As regard provision of the service, the universal service should provide easy access 
to the postal network in terms of location and availability as well as convenient 
delivery of mail. 
As regards the mail categories and services concerned, the universal service should 
include: 
- the following addressed items: letters, postcards, direct mail, catalogues, books, 
publications, other printed papers and parcels (goods transport); this would 
include letters and packets up to a weight of 2 kg and parcels up to 20 kg, which 
are the limits applied by the universal postal union, whose rules on packaging 
and the dimensions of items could also be applied; 
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Guidelines for the Development of Community Postal Services - 7 -
- both national services and cross border services, both first class and, where 
applicable, second class; 
- a special service: registered deliveries; however, other special services like 
express mail are not included in the universal service. 
This definition of the universal service should also take account of the following 
points: 
- each Member State should take the necessary measures to guarantee continuity 
of the universal service; in particular, universal service providers should be 
required to accept mail from Member States or from other countries for 
distribution in their territory, providing a quality of service equivalent to that 
provided for national users; 
- for reasons of adaptability, the universal service should be subject to regular 
review so that it develops in accordance with technological innovations in the 
sector and the demands of users. 
23 MAINTAINING RESERVED SERVICES 
23.1 Outcome of the consultation procedure 
Virtually all contributors considered that a set of reserved services should be 
maintained provided these included only what was necessary to provide the 
universal service in accordance with the principle of proportionality. 
The views expressed during the consultation focussed on the link between the 
universal service obligation and the wide-ranging area which is reserved. The link 
between the reserved services and the need to ensure financial viability in the 
provision of the universal service has also been stongly highlighted. 
With regard to the services which should be reserved, there was: 
- general agreement that magazine and newspaper services, parcel services and 
express services should not be reserved, as is already generally the case; 
- an agreement in principle for special and new services, to be in the competitive 
sector, after an examination on a case by case basis; 
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Guidelines for the Development of Community Postal Services - 8 -
- general agreement that letter services should be reserved and that there should 
be specific price and weight limits, although the parties involved in the 
consultation procedure had different views on what these should be; 
- support for liberalization of self-posting and self-delivery provided that there is 
a clear definition of this type of service. 
The consultation procedure revealed conflicting views on direct mail and cross-
border mail: 
- direct mail: most contributors considered that this should be kept in the 
reserved sector for two main reasons: 
* the need to ensure that the operators bound by universal service 
obligations had the necessary resources; 
* the difficulty of defining direct mail and preventing abuse, such as the 
fraudulent distribution of bulk reserved mail by operators not 
authorized to do so, since mail is inviolable. 
Nevertheless, a number of companies which use the postal services, or associations 
of such companies, together with some private operators and one public operator, 
emphasized the potential advantages of liberalization in terms of price, choice, 
and quality of service. They did not feel that liberalization would undermine 
provision of the universal service. 
- Cross-border mail: a considerable number of contributors distinguished 
between: 
* outward and transit traffic, where collection and carriage are already 
liberalized in several Member States: many commentators were in 
favour of liberalization, although some postal operators were in favour 
of liberalization only if the terminal dues system were changed; 
* inward traffic: most operators opposed liberalization of this stage of 
the cross-border mail service, chiefly because of the risk of national 
mail being routed through other countries; most of the companies 
using the cross-border postal service and private operators mentioned 
the poor quality of the service and emphasized the advantages of the 
same operator being responsible for the service from beginning to end. 
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23.2 Approach proposed by the Commission 
To guarantee the financial viability of the network of postal operators on which 
the universal service obligation has been imposed, the Member States should be 
able to maintain a set of reserved services. 
Accordingly, it is appropriate to determine to what extent restrictions on 
competition, even to the exclusion of all competition, are necessary to assure to 
the universal service providers the means to achieve their task of general 
economic interest, without endangering their financial equilibrium. 
It is clear from the current situation in the Member States that the postal 
authorities can meet the obligation to provide certain services (like a parcel 
service throughout the Community and distribution of printed papers in many 
Member States), even if these services are not in the reserved sector. 
Accordingly, it must be ensured that the reserved area is sufficiently wide to 
guarantee the financial equilibrium of activities linked to the universal service 
while at the same time, in conformity with the principle of proportionality, not 
exceeding what is strictly necessary in order to carry out the obligations imposed 
in this regard in a framework of financial equilibrium. 
Hence the reserved area of the postal sector will be a sub-set of the universal 
services. The non-reserved services could be provided by both public and private 
operators. 
The list of the set of reserved services would have to be decided at Community 
level. If a Member State felt that specific liberalization proposals could prevent it 
from achieving the objective of providing a universal service, it might consider 
limiting the extent to which it was prepared to open up its market, provided this 
solution were proportional to the objective and compatible with Community 
regulations. 
The following criteria should be used to define the reserved area: 
- only those services which are part of the universal service may be considered for 
reservation; accordingly the other services not in this category, particularly 
express services, self-delivery and self-posting and distribution of non-addressed 
items, will be open to free competition, as will those new services which are very 
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Guidelines for the Development of Community Postal Services - 10 
different to reserved services; 
- however, those services which entail a universal obligation, like distribution of 
consignments of goods (parcel service) or of non-personal material (e.g. 
newspapers, magazines, brochures or other types of printed paper for mass 
distribution, each having the same content) will not be reserved; 
- in fact, it would be the basic postal consignments which would constitute the 
target of reserved services, with price and weight criteria being used to 
determine the limits of these services; 
- finally, it should not be possible for the national (internal) mail covered by" the 
reserve services of one Member State to be physically transported outside that 
Member State by another operator and sent back for distribution by the 
universal service operator, as if it were cross-border mail. 
There are two issues where further discussion is necessary: 
- direct mail: the Commission has noted the problems identified during the 
consultation but considers that they are not in the long term insurmountable 
either regarding the financial or control aspects. The Commission therefore 
considers that discussion of this issue should continue and that there should be 
more detailed analysis of the implications of opening up this market. 
- cross-border mail: the Commission considers that liberalization of the collection 
and carriage of outward and transit traffic would not cause serious difficulties, 
although, as discussed later, the Commission does recognize the importance of 
putting an end to the distortions caused by the current system of terminal dues. 
However, the Commission takes the view it is advisable to continue to study the 
implications of liberalizing the delivery of inward traffic and its financial 
impact, taking into account that this liberalisation would bring an improvement 
in performance quality through a single end to end service, in order to reply to 
the preoccupations expressed during the consultation about possible diversion 
of national mail. 
Another alternative approach could be examined. This would foresee the 
maintenance of the final delivery of mail remaining in the reserved sector whilst 
other upstream operations (collection, transport, sorting) would be liberalized, 
with no distinction between domestic and cross-border mail. 
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Guidelines for the Development of Community Postal Services 
A priori, certain advantages are apparent: 
- given that the fixed costs of the universal service are essentially concentrated in 
the final phase of delivery, the maintenance of this phase in the reserved sector 
would, in theory, be able to guarantee the financial viability of the operators 
charged with the universal service; 
- by avoiding a distinction between domestic and cross-border traffic, this option 
would be coherent with the logic of the Single Market; however it would be 
advisable to recognize the differences in the performance between operators 
and also the difficulty in this framework of ensuring the provision of an efficient 
end to end service; 
- the problems of controlling the diversion of traffic, mentioned during the 
consultation regarding cross-border mail and direct mail, could be avoided. 
These different issues would have to be examined in more detail within the 
framework of further consultations. 
2.4 SERVICE QUALITY STANDARDS 
2.4.1 Outcome of the consultation procedure 
Contributors considered service quality standards an important matter justifying 
regulatory and operational measures. The majority were in favour of adopting 
high quality standards at Community level. It was emphasized that deadlines for 
adoption of these common standards would have to take account of the present 
situation in some Member States. 
However, this would not prevent Member States from adopting more stringent 
measures if they saw fit. In any case, it was emphasized that Community standards 
should not have the effect of reducing national standards where they were already 
higher. 
Community or national standards should be published and there should be checks 
on mail services at all stages of the process, even in the case of cross-border mail. 
Opinions were more divided as to whether service quality standards should be 
imposed only on the reserved sector or on the whole universal service. 
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Guidelines for the Development of Community Postal Services - 12 
Some suggested setting up an independent body or using special monitors to 
maintain standards and carry out inspections. 
Furthermore, some of the groups emphasized in their comments that failure by an 
administration to implement the standards should lead to a penalty. While the 
comments referred to the difficulties this might entail, it was suggested linking the 
amount of terminal dues to the service of quality provided, and even reducing or 
abolishing the reserved sector if a postal administration did not meet its 
obligations with regard to service quality. 
2.4.2 The approach proposed by the Commission 
With regard to service quality, standards should be laid down for the universal 
domestic and cross-border services, systems should be introduced to monitor the 
service actually provided and the results should be published. The standards for 
the cross-border service should be laid down at Community level. The standards 
laid down in each of the Member States by the national postal authorities should 
be compatible with the Community standard on cross border mail, although the 
authorities could lay down even stricter quality requirements for the providers of 
the universal service in their own country. 
The quality standards should be laid down as follows: 
- Time limits for basic products or services forming part of the universal service 
should be set for: 
- first and second class letters and postcards 
- parcels (up to the universally defined weight limit) 
- periodicals (daily and weekly publications) 
- bulk printed items. 
The time limits would cover the service provided from the mailing of the item to 
its delivery to the recipient (end to end control). 
- Although standard time limits might suffice in general, specific standards could 
be laid down for certain traffic flows (exchanges between large towns and cities, 
long-distance mail, close cross-border operations, etc.). 
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- Security and confidentiality must be total and absolute. To ensure compliance 
with this intangible principle, an annual report should be drawn up covering: 
* the number of instances where mail is lost, stolen or damaged; 
* the number of instances where confidentiality is violated. 
- Rules regarding the liability of universal service operators and the payment of 
compensation to customers in the event of excessive delay or loss, deterioration 
or theft need to be clearly spelt out. 
- An external body or a group of specialists should check the results obtained and 
compliance with the standards. 
2.5 MEASURES TO PROMOTE HARMONIZATION 
2.5.1 Outcome of the consultation procedure 
Although there is a consensus that efforts should be made to increase 
harmonization in the sector, the comments in general say very little about the 
specific areas in which a policy should be pursued. 
The comments all point to the fact that non-discriminatory conditions of access to 
the universal networks and services should be guaranteed and that transparency 
should be ensured. 
A number of different opinions were put forward with regard to cross-subsidies: 
the principle of geographical cross-subsidies to ensure a single unitary tariff, in 
Member States which wish to have it, is not called into question. However, the 
justification for subsidizing operations provided on a competitive basis even if the 
service, such as parcels, is a universal service obligation, was challenged by private 
operators and a number of professional users. 
Action on technical standardization and the need to achieve a certain amount of 
harmonization on the tariff principles for the basic services provided by the public 
operators are also seen as priorities. 
Furthermore, private operators propose harmonization of the accounting methods 
used by the postal administrations. 
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Guidelines for the Development of Community Postal Services " 14 
Lastly, it was emphasized quite frequently that harmonization should not lead to a 
reduction in the level of the service or to an increase in prices for users. 
Two ways of achieving this are suggested: 
- first, voluntary and even mandatory action on the part of the regulatory 
authorities; 
- second, the idea that harmonization should come about automatically through 
market forces as a result of the interplay of supply and demand. 
2.5.2 The approach proposed by the Commission 
The Commission takes the view that efforts should be made to achieve 
harmonization in four areas: the conditions of access to the networks and the 
services, the tariff principles, and commercial and technical harmonization. 
The conditions of access to the network and the universal service 
Definition of the conditions of access is the responsibility of the Member States, 
the principle being that access to the postal services should be ensured for all users 
on equal terms. This should be a clear, published definition. 
Tariff principles 
The tariffs should be linked to the cost of providing each service in order to ensure 
the long-term financial viability of operators and to avoid the risk of 
uncompetitive cross-subsidies. This objective would mean a need for transparent 
accounting, this being even more essential if the postal administrations used the 
same network to provide both reserved and non-reserved services. 
The geographical cross-subsidies intended to ensure a single unitary tariff and the 
subsidies from the non-reserved sector to the reserved sector would be accepted, 
while cross-subsidies from the reserved sector to the non-reserved sector would 
be authorized if they proved to be necessary to provide a universal service and 
were compatible with the rules of competition. 
Commercial and technical harmonization 
A certain level of commercial and technical harmonization should make it possible 
to attain the essential objective of providing continuity of service within the single 
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Guidelines for the Development of Community Postal Services 
market, which will be to the benefit of users and will improve the competitiveness 
of the sector. If it brought significant benefits to users, harmonization of the 
reserved services could be compulsory. Recommendations only could be given in 
the competitive sector. 
Two kinds of action should be taken to ensure the interoperability of the postal 
networks. Harmonisation in the conditions of sale should be reinforced as well as 
technical standardization in the handling, transport and delivery of mail. 
The technical standardization would be assigned to the specialized European 
bodies on the basis of mandates in conformity with the principles enunciated in 
Directive 83/189/EEC. In actual fact, the Commission would give a mandate to 
the CEN, which would then cooperate with the ISO. 
2.6 SEPARATE REGULATORY AND OPERATIONAL FUNCTIONS 
2.6.1 Outcome of the consultation procedure 
The principle of separation is accepted by everyone and is considered to be 
essential to ensure the provision of a universal service, the establishment of limits 
to the reserved services, clarity with regard to the regulatory framework, the 
consideration of user requirements, and the effective application of the rules 
(protection of the reserved area and fair competition in the non-reserved area) in 
all of the Member States. 
2.62 The approach proposed by the Commission 
The regulatory functions must be separated from the operational functions in all 
of the Member States. 
Because of the degree of latitude on the part of the Member States inherent in the 
application of the overall scheme described, it is clear that the national regulators 
will play an important role both in terms of regulation and in terms of monitoring 
and control. Consequently, separation of the regulatory powers from the 
operational functions (already in progress) should be broadened and deepened. 
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2.7 TERMINAL DUES 
2.7.1 Outcome of the consultation procedure 
Most of the comments received indicated that reform along the lines of 
rationalization was essential. However, there is hesitation as regards the 
advisability of bringing terminal dues into line with actual costs too rapidly. 
The international aspects of this matter are a main concern, in particular the role 
of the Universal Postal Union which was stressed in a number of documents. 
The existence of certain types of remail which have come about as a result of the 
present terminal dues arrangements was also referred to in various comments. In 
particular, it is felt that it is essential to resolve the problem of A B A remail and 
its possible impact on the control of the exclusive rights of the providers of 
universal services. 
2.12 The approach proposed by the Commission 
The reference levels of financial compensation (terminal dues) paid between 
operators should reflect the actual costs incurred by each operator providing 
cross-border services and should conform to Community competition rules. 
Although bilateral agreements can be concluded to take account of the special 
features of certain flows, such as the volume of traffic, the regularity of dispatch, 
the preparatory work, the physical presentation of the items, etc., it would appear 
to be highly desirable to introduce an overall reference system to ensure that the 
universal service is not interrupted or disturbed in the event of disagreement 
between operators regarding the price of the services provided. 
The Commission takes the view that it is not for the Community to take any prime 
action in this area, which is essentially the responsibility of the operators. The 
consultation procedure nevertheless revealed agreement on certain basic 
principles, which the Commission can help to implement: 
- The operator ensuring distribution should receive remuneration for the services 
provided to cover the actual costs plus a normal commercial profit margin. For 
his part, the operator responsible for dispatch (or transit) should not pay more 
than the tariffs applied by the operator in the country of destination to other 
users of the national service in a comparable situation (with regard to volume, 
Guidelines for the Development of Community Postal Services -17 
pre-sorting, etc.). 
- The most practical and the best solution would be to refer to the domestic 
tariffs applied by the post office in the country of destination, varied to take 
account of any preparatory work and possible penalties regarding the quality of 
service actually provided. 
- The accounting procedures to invoice for terminal dues should be reliable and 
inexpensive and should also not slow down the forwarding of the mail, which 
would contradict the objective of a major improvement in the quality of service. 
2.8 INTERNATIONAL ASPECTS 
2.8.1 Outcome of the consultation procedure 
A number of comments referred to the international aspects of the postal sector 
with regard to: 
- the definition of the universal service, which could take account of the postal 
service obligations adopted within the UPU framework; 
- remail, which Article 25 of the acts of the UPU allows to be challenged, in 
particular ABA remail (mail from country A posted in country B to a recipient 
in country A) or mail originating in a third country; 
- terminal dues, the proposal to fix the level of these dues on the basis of the cost 
in the country of destination being feasible only if it is adopted within the UPU 
framework; 
- the possible creation of an international system of arbitration to settle disputes 
over remail or to be applied if no agreement is reached on the application of a 
new system of terminal dues. 
With regard to the positions of the Member States, the need was pointed out: 
- to coordinate these positions within the international fora concerned; 
- to ensure coherence between commitments undertaken vis-à-vis third countries 
and the Community postal system. 
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Lastly, a large number of comments referred to possible changes in the 
international aspects of the postal service during discussion on the GATS. 
2.8.2 The approach proposed by the Commission 
The Commission view is that it is essential to guarantee compatibility between the 
international commitments entered into by the Member States and Community 
legislation and policies, to continue to cooperate on improving the organization 
and performance of the world postal markets and to ensure the requisite 
coordination between the positions expressed by the Community and the 
Member States in the various bodies responsible. 
A new reference system of remuneration should be introduced for postal 
operations between the Member States. Its extension to all of the postal 
administrations in the CEPT, with specific variations where necessary, would be 
desirable. 
This also applies to relations with the main industrialized third countries. A 
solution of this kind based on domestic tariffs might create difficulties in the short 
term as far as other countries are concerned, in particular the developing 
countries. It would therefore seem to be desirable to coordinate the positions of 
the Member States within the UPU. 
Ways must be found and implemented to prevent large volumes of purely intra-
Community traffic (originating in and bound for the Community and eventually 
the EEA, and for both A-B-A and A-B-C traffic) from being routed through third 
countries simply because the postal administration in the intermediate country is 
trying to benefit from the shortcomings of UPU rules and refuses to accede to 
agreements based on sounder economic considerations. 
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Guidelines for the Development of Community Postal Services - 19 -
3. IMPLEMENTATION 
The logic of the internal market and Community law require certain actions to be undertaken 
at Community level in the postal sector to assure the resolution of the problems mentioned in 
Section 1.2. This is to guarantee the continuity of basic postal services throughout the 
Community, the application of the principle of proportionality for determining the reserved 
area and the improvement in cross-border quality of service, to state the most obvious 
examples. 
But Member States will maintain important powers by application of the principle of 
subsidiarity; for example, the Community definition of universal service will permit the 
development throughout of a universal service, but this definition will be considered as a 
minimum reference definition, each Member State will be able to adopt a more extensial 
definition in line with its legitimate requirements. 
The principle of subsidiarity should also be applied in the setting of norms for quality of 
service. Hence, norms for quality of service in each Member State established by national 
postal authorities will permit higher standards from the providers of the universal service. 
In conformity with the principle of subsidiarity, what is needed is the minimum action 
necessary to ensure the harmonization and liberalization which are essential for the 
development of the Community postal services. The Community's responsibility in this is to 
define the common principles which will enable this to be attained. Within this framework, 
the Member States will continue to develop their own postal policies, with the national 
authorities retaining prime responsibility for regulation in each individual country. 
Therefore, it is essential to take account of the following four issues in the development of the 
Community postal services: 
- The implementation of these guidelines will require some actions, in particular legislative 
action, at Community level. The completion of an impact analysis, which has already 
begun, should preceed these actions, accompanied by a consultation procedure. 
- Regarding measures which would have particularly noticeable social consequences, an 
impact analysis on the financial equilibrium of the provision of the universal services and 
the consequences in terms of employment, will take account of the financial conditions, 
regional disparities and the diversity of social situations existing in the different Member 
13 
Guidelines for the Development of Community Postal Services - 20 
States. 
- Adoption of the guidelines set out in this communication must not lead to a deterioration 
in the level of service in Member States where this level is currently higher than what is 
proposed, e.g. as regards the scope of the universal service or the quality of the service. 
Other Member States, on the other hand, may need short periods of adjustment to apply 
some of the guidelines. 
- The present structure of the postal markets shows that the regulatory framework 
appropriate at the moment in terms of definition of the universal service, service quality 
standards, harmonization and reserved services may no longer be suitable in the medium 
term. A balanced, stepwise approach is therefore desirable and will provide the flexibility 
required to allow the various aspects of the framework to be reviewed as the markets 
develop and the situation changes. 
The stages which follow the meeting of the Council will continue to be based on a dialogue 
between the Commission and those involved in the sector, within the committees mentioned 
at point 3.2 below, in order to produce the most appropriate and balanced solutions which will 
allow the harmonious development and reinforce the effectiveness of the postal sector, while 
at the same time ensuring users' needs and employees' interests as well as the contribution of 
the sector to economic, cultural and social development and cohesion within the Community 
are taken into account. 
3.1 THE ACTION PROPOSED 
Between the various means of action to establish and to develop the guidelines, a distinction 
should be drawn between those with a legislative objective and other forms of action. 
Legislative action: 
These actions at the Community level will permit the establishment of a true internal market 
for postal services while respecting the application of the principle of subsidiarity. The 
legislative measures envisaged are the following: 
- Directives concerning the definition of the universal service as a means of reference, with 
regulatory issues (such as the division between operational and regulatory functions) and a 
description of the obligations of the providers of the universal service (tariff principles, 
non-discriminatory conditions of access to networks, etc.) and defining the services which 
could be reserved at Community level. 
o il 
Guidelines for the Development of Community Postal Services - 21 
- Directive on service quality laying down service quality standards, creating systems to 
monitor the services provides and setting out the principles applicable to the treatment of 
complaints about cross-border traffic, in particular that within the Community. 
- Directive on commercial harmonization and technical standardization laying down the 
overall objectives to be attained and the means of action. 
Other actions: 
After the universal services have been defined, a detailed assessment will be undertaken of 
the position in the different areas of the Community, taking into account in particular the 
specification and performance of the services offered. This evaluation will enable the 
identification of the necessary measures to reduce the regional disparities. 
Universal service should not stop at the Community's borders. The non-EC dimension should 
also be kept in mind. This concerns the impact of developments both on the EFTA countries 
and countries of Central and Eastern Europe, in order to implement the Community's vision 
of a larger Europe. The issues of fair market access and the current multilateral negotiations 
underway in the Uruguay Round should also be addressed as well as developments in the 
Universal Postal Union. 
Necessarily there is a relationship between internal liberalisation and access for Community 
operators to third markets. The Community must pursue by all the means at its disposal this 
goal with the firm intention to create effective, comparable and lasting market opportunities 
for its own operators elsewhere. 
The question of financial compensation to be paid between service suppliers, for which a 
number of solutions are emerging, will nevertheless continue to be a subject for the 
Commission to consider. 
If current problems concerning terminal dues still occur (distortions in the market and to 
competition and endangerement in the provision of the universal service), the Commission 
will propose appropriate measures. 
In compliance with the principle of subsidiarity, the Commission will ensure that the 
reference framework on Community postal services is progressively implemented and that 
developments in this field are in keeping with other Community policies, in particular those 
on transport, customs, VAT and data protection. 
u 
Guidelines for the Development of Community Postal Services "22 -
32 THE CONSULTATION PROCEDURE 
The necessary steps as well as the timetable for implementing the Community postal policy 
will have to follow an in depth consultation with the involvement of all the interested parties, 
in particular user representatives (be they major customers or consumers), operators and 
those employed in the sector. 
Consultation will have to take place through the existing working groups (Senior Officials 
Group on Posts - SOGP) and two new committees: 
- The Consultative Group on Postal Services, which consists of operators and users in 
particular. 
- The Joint Committee for the Postal Sector, which consists of representatives of the public 
and private operators and trade unions. 
l& 
Guidelines for the Development of Community Postal Services - 23 
4. CONCLUSION 
The consultation procedure on the Green Paper on postal services generated a large response 
on the part of the parties concerned, brought out the need to develop the single market in 
postal services and revealed a consensus on a relatively large number of major issues. 
The Commission has noted the reactions to the Green Paper and takes the view that it is now 
possible to take a further step towards the regeneration of the Community postal sector by 
updating the basic guidelines set out in the Green Paper, describing a more detailed approach 
to the action called for at Community level (which is to be analysed in detail by the 
abovementioned Committees) and by detailing the measures required. 
The Commission would ask the Council of Ministers to discuss the various approaches set out 
in this communication and the measures recommended. 
?^ 

ANNEX 1 
MAIN OPTIONS OF THE GREEN PAPER 
PART I: GENERAL REGULATORY ISSUES 
1. ESTABLISH A SET OF UNIVERSAL SERVICES 
The key social requirement for postal services is the maintenance of the universal service. 
Universal service without any conditions about price can be provided in the competitive 
(non-reserved) sector. But, in order for the service to be at a price affordable to all, it is 
necessary to have sufficient economic returns to scale. These can only be achieved through 
the granting of some special and exclusive rights - hence the need for reserved services. 
(Although it is possible for there to be more than one reserved service provider in each 
Member State, this is unlikely; for the sake of simplicity, all the proposals refer to only one 
reserved service provider - assumed to be the postal administration - in each Member 
State.) 
2. DEVELOP THE DEFINITION OF UNIVERSAL AND RESERVED SERVICES 
Detailed work is still needed before such a Community definition of the possible set of 
reserved services can be made. Throughout this analysis, the objective will be to seek the 
least restrictive solution. Conditions in some Member States may permit the scope of the 
reserved services there to be less than the set defined at a Community level, but always 
consistent with the objective of ensuring universal service. Whatever the result, the 
definitions must be such as to distinguish clearly between what is in the reserved area and 
what in the non-reserved area.. 
ENSURE COMPATIBILITY OF OTHER MEMBER STATE COMMITMENTS 
WITH COMMUNITY LEGISLATION AND POLICIES 
As with all sectors, efforts need to be made to reduce the possible tensions between, on the 
one hand, Community law and policies and, on the other, potential obligations arising 
from other conventions or treaties that Member States may have signed 
4. SEPARATE REGULATORY AND OPERATIONAL FUNCTIONS 
In order to ensure tliat the user's interests are best served through the impartial treatment 
of all operators, it is essential that regulatory and operational functions should be 
separated The independence of the regulatory function will better enable it to achieve the 
best balance between public and private operators, and between reserved and non-
reserved service providers. It will monitor the effectiveness of the reserved services, in 
terms of the service provider both maintaining a good universal service and meeting its 
other obligations shown below at Proposals 5, 6 and 8. If the situation arises, it will need 
to consider what action may be necessary in the case of performance falling short of the 
obligations. 
n^ 
PART II: OBLIGATIONS OF UNIVERSAL SERVICE PROVIDERS 
5. ACCESS CONDITIONS TO UNIVERSAL SERVICES TO BE SAME FOR ALL 
The rule must be equality of treatment of users (customers) of universal services. Within 
this rule, it is recognised that customers have varying requirements and can co-operate 
with universal service providers to varying extents. This is partly a function of size, but 
particularly of the ability to prepare mail in ways that are beneficial to the postal 
operation of the universal service provider, thus allowing the latter to offer discounts. 
6. TARIFFS OF UNIVERSAL SERVICES TO BE RELATED TO AVERAGE COSTS 
The guiding principle should be that tariffs should be related to average costs. The 
consistent application of this principle is the best guarantee of the financial soundness of 
the postal services. Cross-subsidies can be permitted across geographic areas in order to 
allow the péréquation tarifaire and from the non-reserved area to the reserved area 
There could also be cross-subsidies from the reserved to the non-reserved area if they were 
necessary to assure the universal service and if they were compatible with competition 
rules. With these exceptions, in order to ensure fair treatment for all, cross-subsidies, 
whether from one service to another or, because of discounts, from one group of 
customers to another, should be minimised and phased out. 
7. INTER-ADMINISTRATION COMPENSATION TO REFLECT DELIVERY COSTS 
The existing system of charging between postal administrations (called terminal dues) is 
not cost based, leading to significant distortions between remuneration and actual delivery 
costs incurred The same principle of basing on tariffs on costs should apply to the 
financial compensation system between postal administrations.. 
8. SERVICE STANDARDS FOR UNIVERSAL SERVICES TO BE SET AND 
PERFORMANCE MONITORED 
The justification for establishing a set of reserved services is based on the social 
requirement for universal service. The actual service performance is therefore crucial in 
ensuring that the social requirements are met. Standards therefore need to be set for the 
universal services, performance monitored and control systems put in place. It is 
important to note that such standards are only thresholds - universal service providers 
should still try to have a performance higher than the standards. 
(? 
PART III: HARMONISATION AND COHESION 
9. HARMONISATION APPROPRIATE WHERE BENEFICIAL TO CUSTOMERS 
The more tangible the benefit for the consumer, the stronger the case for harmonisation. 
The clearest benefits would seem to be gained from some harmonisation of access 
conditions and from harmonisation of service standards and performance monitoring 
(described above at Proposal 8). 
10. COHESION ASPECTS TO BE TAKEN INTO ACCOUNT 
It is important always to keep in mind the need to ensure that the Community throughout 
has an effective postal sector that properly meets the postal needs of the whole of the 
Community. Most of the improvements necessary can be gained through better 
management. However, some capital investment could be needed, which, particularly in 
less favoured regions, could entail a significant financial burden. 
-\( 

ANNEX2 
RESULTS OF PUBLIC CONSULTATION H^gEjN.flli^lf!QN .PÇ)SO\l|SEBy IGESS 

CONTENTS 
1. INTRODUCTION 
2. BACKGROUND 
2.1. The postal service 
22. The Council mandate 
23. The Green Paper 
2.4. The options in the Green Paper 
2.5. Public consultation 
3. OVERVIEW 
3.1. Main areas of agreement 
3.1.1. The notion of universal service 
3.1.2. Balance between harmonization and opening up the market 
3.1.3. Agreeing to maintain a reserved area 
3.1.4. Improving the quality of services 
3.1.5. Relating terminal dues to costs 
3.1.6. Separating regulatory and operational functions 
3.1.7. The need for ongoing consultation 
32. Areas of disagreement 
3.2.1. Precise definition of universal services 
3.2.2. The extent of the reserved area 
3.2.3. Universal services versus reserved services 
3.2.4. The universal network 
2>C 
(6) 
3.2.5. Implementation 
33. Other issues 
3.3.1. The level of harmonization desirable 
3.3.2. Methods of controlling the regulation process 
3.3.3. The role of users 
3.3.4. The impact of other Community policies (customs, data protection, 
etc.) 
3.3.5. Community cohesion 
3.3.6. The international aspect 
3.4. Applying the principle of subsidiarity 
3.4.1. Support for Community action 
3.4.2. Achieving a balance between national measures and Community policy 
4. THE SOURCE-BASED APPROACH 
4.1. Institutional sources 
4.1.1. The European Parliament 
4.1.2. The Economic and Social Committee 
4.1.3. The Member States 
42. Professional users 
4.2.1. The trade associations 
4.2.2. Specific customers 
4.2.3. Small businesses 
43. The postal industry 
u 
4.3.1. The postal administrations 
4.3.2. Other postal operators 
4.3.3. Others involved in the postal industry 
4.4. Consumers and trades unions 
4.4.1. Consumers 
4.4.2. Trades unions 
4.5. Reaction from outside the Community 
4.5.1. The international postal institutions 
4.5.2. The EFTA countries 
5. CONCLUSIONS 
AN N EX: List of written contributions 
ïï *> 

-1-
1. INTRODUCTION 
Because of the economic and social importance of the postal service to the 
Community, its future organization and development deserves particular attention. 
The postal service is currently facing a number of problems which would be better 
solved within the context of the single market. The individuals and companies who 
use the Community's postal services are well aware of its shortcomings, and of the 
disparities and distortions of competition. 
In view of these factors and because of the importance of the postal service to the 
public, the Council of Ministers for Posts and Telecommunications asked the 
Commission to come up with a Community postal policy. 
The first stage was publication of the Green Paper on the development of the single 
market for postal servicesC) which formed the subject of a Commission 
communication of 11 June 1992. 
The next stage in the process was to organize widespread consultation on the Green 
Paper with all the interest groups concerned. 
The public debate was valuable and extremely instructive. In view of the need for 
transparency, it seems appropriate, and useful, for the Commission to give a public 
account of the debate. That is the purpose of this communication, which gives a 
general summary of the various oral and written comments made to the Commission. 
However, the main value of the exercise, which involved all those concerned in the 
future of the postal market, is to identify the main expectations and the areas of 
agreement which could be used as a basis for a policy on the postal service, so that it 
meets the real needs of its users. This summary thus provides a sound basis for 
reconsidering the options set out in the Green Paper. The next step will be to publish 
a communication setting out guidelines for development of Community postal policy. 
Because of the wide range of questions on postal activities, a number of very different 
topics were considered during the consultation exercise, and because the various 
contributors represented a number of very different interests, opinions on some of the 
points at issue were very divergent. 
However, despite these divergent and contrasting opinions, there was general 
appreciation of the Commission's analysis, endorsement of the basic guidelines 
proposed and recognition of the need for Community action. 
This is evident from this communication which, after describing the background to this 
consultation process, gives a general overview of the comments received. 
The document goes on to highlight the main areas of agreement and the important 
points on which opinions diverged. It then considers other factors which do not have 
the same priority but are nevertheless important. It also considers the question of 
subsidiarity. 
Finally, the last chapter examines reactions in terms of the opinions of the main 
interest groups involved rather than the points at issue. 
OcOM (91) 476 final 
31 
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2. BACKGROUND 
Before analysing the comments received, it is worth describing how the process 
leading to a Community postal policy started. 
It was primarily the postal service which set the process in motion. Described below 
are the important preliminary stages: the Council's intervention, the Green Paper and 
initiation of the public consultation process. 
2.1. The postal service 
For a full understanding of all the issues regarding organization of the postal 
market, it is important to have a precise idea of the scale of the postal service. 
In order to do this it is essential to consider not only its economic importance 
but also its subtler role as a key element of the economy and of society. 
The importance of postal services within the Community is illustrated by some 
statistics. The postal services account for 1.3% of GDP, they employ more than 
1 700 000 workers and they produce a turnover of more than ECU 60 billion. In 
addition, the sector enjoys steady and continuous growth. 
Because they are an essential vehicle of communication and trade, postal 
services are vital for all economic and social activities, even if in some cases 
they may be replaced by other means of communication. In fact, the 
importance of postal services even seems to be increasing as economic 
operators use them more and more. This has the effect of making certain 
economic sectors virtually dependent on postal services. 
The most important of these are mail order companies, direct marketing firms 
and magazine and newspaper services, particularly for specialized publications. 
A final important fact is that exchanges of letters help to reinforce social contact 
and to develop links between individuals and companies in different areas. 
For all these reasons, postal services play an essential structural role. 
22. The Council mandate 
Aware of the economic and social importance of the sector, the Council of 
Ministers of Posts and Telecommunications decided in September 1989 to 
instruct the Commission to do the groundwork on a Community postal policy. 
In particular, the Council envisaged introducing new European measures to 
regulate postal services based on the public interest of the postal authorities and 
defining a set of reserved services. 
It proposed the setting up of the Senior Officials' Group on Posts (SOGP), to 
act as the channel for official consultation with the Member States. 
Other Councils of Ministers subsequently confirmed this desire to have the 
Commission prepare proposals for organization of the postal market. 
The first task of the SOGP was to help the Commission prepare a Green Paper. 
'-I D 
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23. The Green Paper 
The Commission's views were set out in a Green Paper on the development of 
the single market for postal services which was published on 11 June 1992. 
The Commission communication contains: 
- an analysis of the current situation 
- an examination of the problems 
- a description of the issues 
- an assessment of the possible solutions 
- a list of political options. 
The Green Paper is a discussion document. The options it proposes are 
designed as guidelines to be evaluated by the interest groups concerned in order 
to stimulate a wide ranging debate. 
2.4. The options in the Green Paper 
The basic principal of the initiative is the universal postal service. The basic 
approach adopted is a balanced solution, combining further opening up of the 
market with measures to reinforce the concept of universal service. 
In order to maintain the universal service, certain restrictions on the free play 
of market forces may be allowed. The proposal could result in the 
establishment of a set of reserved services by granting exclusive or special rights 
to providers of the universal service. 
However, the extent of the reserved service will have to be strictly proportional 
to the objective of providing the universal service in accordance with the Treaty 
and secondary legislation. 
With these basic considerations as a starting point, the thrust of the Green 
Paper is towards: 
- a universal service of quality 
- liberalization 
- more harmonization. 
As regards liberalization in particular, proposals include: 
- liberalizing express courier services, parcel services, magazine and newspaper 
services, and self-posting; 
- putting in the non-reserve sector those new services which are significantly 
different to standard postal services. 
It is also envisaged: 
- to liberalize cross-border traffic; 
- a priori, to liberalize direct mail. 
Ui 
The Green Paper also contains options regarding: 
- the separation of regulatory and operational functions; 
- compatibility of the international commitments of Member States with 
Community policy; 
- the obligations of universal service providers (equal access, relating tariffs to 
costs, establishing a system of compensation between postal administrations 
which reflects actual delivery costs, and setting service standards); 
- Community cohesion. 
A more detailed description of all these options is given in Annex. 
Community policy should be implemented progressively without seriously 
endangering continuity of the universal service. The principal aims will be to 
consolidate those areas which are already working well and to improve those 
areas where performance is inadequateC). 
2.5. Public Consultation 
The Commission called for all parties interested to participate in the initial 
discussions on decisions which will affect the future of Europe's postal services. 
In fact, dialogue is ah essential prerequisite if the service is to be properly 
regulated and if policies are to meet users' needs. 
The consultation period ran from the date of publication of the Green Paper to 
the beginning of 1993. This relatively long period - more than six months -
seemed necessary because of the complexity of the issue and the number of 
parties potentially interested. 
The Commission received a wealth of comments, remarks and suggestions from 
a wide range of different sources, most of them in the form of written 
contributions (An Annex lists all the contributions and their sources). Other 
comments were made orally at meetings. 
The debate was sustained, valuable and wide-ranging: 
- sustained because of all the different stages which marked the debate 
(seminars and symposia), and because of the continual assistance given by 
the national authorities in the Member States, who also generally organized 
consultation at their own level, as the Commission had hoped; 
- valuable because comments were indisputably of high quality and made an 
extremely useful contribution to discussions; 
- wide-ranging because of the level of participation, which reflects the value of 
the postal service to large sections of the economy and society in the 
Community. 
' ' See Green Paper, Summary (pp. 11 to 13) and Chapter 9 (pp. 241 to 254) for more details. 
Li 
The consultation process emphasized the desirability of ongoing discussion 
between Community authorities, national officials, European citizens and those 
involved in administrative, economic and social activities in order to identify 
those Community policies which best suit the needs of all concerned. 
4} 
-6 
3. OVERVIEW 
There was clear consensus on the desirability of Community action and support for 
the general approach proposed by the Commission for the future of postal services. 
In fact, none of the contributors contested the need to discuss organization of the 
postal market at Community level, even if opinions on the extent and nature of 
Community intervention differed. 
Many of these opinions will have to be examined in the context of application of the 
principle of subsidiarity. 
Similarly, most of those who took part in the debate fully endorsed the Commission's 
analysis of the situation, its findings and the issues it identified. The few criticisms 
concerned only matters of detail (e.g. some of the statistics in the Green Paper should 
already be updated) or additional features to be added to the already broad and 
detailed canvas of the Green Paper. 
Basically, there was broad agreement on the main options proposed by the 
Commission and virtually all concerned gave their unanimous approval of the basic 
scenario. 
Naturally a number of often very crucial points remain to be settled, some issues are 
being vigorously discussed and other areas will have to be explored in order to 
regulate the postal services coherently and effectively. 
However it is very clear that the Green Paper is a sound basis for developing 
Community action on postal services in the coming years. 
3.1. Main areas of agreement 
Discussed below are those key elements to which the large majority of the 
organizations that contributed, reacted very favourably. 
In fact, there was virtually unanimous approval of the essential concepts and 
principles which form the basis for the whole scenario set out in the Green 
Paper. 
The same applies to the concept of universal postal service, which seems to be a 
prime concern of all contributors. Tlie attempt to arrive at a solution of gradual 
change was also generally preferred to scenarios where the short-term impact 
would be much more radical. 
The idea of a reserved sector was accepted with a few rare exceptions. All 
agreed that emphasis should be placed on improving the quality of the service. 
The need to change the current system of terminal dues was particularly 
evident, and it was unanimously felt that regulatory and operational functions 
should be separated. 
Finally there was a general request that consultation should not stop at this 
stage but should continue throughout the process of defining and introducing a 
Community postal policy. 
4 
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3.1.1. The notion of universal service 
This was considered to be the fundamental concept. There was a call for a 
precise definition of universal service as this would be essential for developing 
the other facets of postal policy. 
The definition should take account of economic and social aspects, and it would 
be essential to have a clear idea of users' expectations. 
Frequent mention was made of two factors closely linked to the notion of 
universal service: 
- equal treatment; 
- the possibility of geographical cross-subsidies. 
Certain essential features of the universal service will have to be defined, and in 
particular: 
the type of service covered; 
proximity, continuity and accessibility; 
speed and reliability; 
the responsibilities of the service provider. 
3.1.2. Balance between harmonization and opening up the market 
The balanced scenario proposed by the Commission was broadly approved. 
As regards opening up the market, it was generally accepted that the reserved 
area should be the least restrictive solution. 
Several contributors also suggested that, under certain circumstances, the 
exclusive service could be provided by several operators, the postal authorities 
and others. 
As regards harmonization there will have to be further work on certain points 
which are particularly affected by the proposed regulatory measures, namely 
conditions of access to the universal service and tariff policy. 
Any harmonization in the competitive sector should rather be thé result of the 
free play of market forces. 
3.1.3. Agreeing to maintain a reserved area 
Virtually all contributors considered it justifiable to maintain a reserved area. 
However, this area should be no greater than is necessary to provide the 
universal service. The aim is to apply the principle of proportionality, which 
everyone understands and accepts. 
Consequently, as is already the case, not all universal services will necessarily 
result in the establishment of reserved areas. 
However it should be pointed out that there are those who consider that 
ultimately exclusive rights for postal services could disappear. 
Us 
-8-
Whatever happens, a clear and precise definition of the reserved sector is 
essential, the most widely accepted criteria being price and weight. 
Finally, the comment was made that the universal service and the reserved 
sector could be allocated to different operators (tendency towards a duopoly, 
for example). 
3.1.4. Improving the quality of services 
It emerged that the basic question is where to concentrate efforts (regulatory 
and operational). It would appear that service quality should be improved both 
at national level (even though standards in some Member States already seem 
relatively satisfactory) and at Community level. 
Policy on service quality must be ambitious. 
Contributors demanded that sufficiently high quality criteria be set at 
Community level, although they do ask for time to adjust to these quality 
standards in view of the ground which certain Member States have to make Up. 
This should not prevent Member States from setting more stringent standards if 
they so wish. It was stressed that Community standards should not, under any 
circumstances, serve as an excuse for reducing domestic standards where they 
are already high. 
It was strongly recommended that these standards should be published and that 
there should be a blanket measure on quality control. Some contributors asked 
whether it was worth setting up an independent body or using external 
observers to do the work of setting standards and controlling their application. 
Several also emphasized that authorities who fail to respect the standards 
should be sanctioned. Even though this could prove difficult, it was suggested 
that: 
- the amount of terminal dues received should be related to the quality of the 
service provided; 
- that the reserved sector might even be reduced or discontinued if a postal 
authority failed to fulfil its obligations in respect of service quality. 
There was a wider range of opinions on whether service quality standards 
should apply only to the reserve sector or to all universal services. 
Lastly, it was suggested by some commentators that quality standards and 
control of those standards should also apply to services provided by private 
operators. 
3.1.5. Terminal dues 
It is clear from the contributions received that a more rational system should be 
adopted. 
It was widely felt that relating terminal dues to costs exactly can cause 
complications and practical problems. It might be worth considering establishing 
as a reference percentage of domestic tariffs (at least when they themselves are 
related to costs). 
The international dimension is essential here, particularly the role of the 
L 
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Universal Postal Union, which is widely mentioned. 
Many contributors raise the issue of the relationship between terminal dues and 
certain kinds of remail service which exist only because of the present terminal 
dues system. It is essential to tackle the problem of type A-B-A remail and its 
possible impact on the control of the exclusive rights of universal services. 
3.1.6. Separating regulatory and operational functions 
All agree to this principle. Since it is necessary to have in each Member State a 
regulatory function which can: 
- ensure that the universal service is provided, 
- set limits on reserved services, 
- provide clear information on regulatory matters, 
- take account of users' needs, 
- apply regulations effectively (protection of the reserved area and fair 
competition in the non-reserved area). 
Progressive changes in regulations mean an even more important role for the 
regulators, particularly in view of application of the principle of subsidiarity, 
which is considered to be an additional level in between action by the 
Member States and Community policy. 
Also important is the way in which regulatory authorities exercise their power. 
It was considered that they should remain neutral and it would appear that 
many of the parties concerned will remain extremely vigilant on this point. 
Finally, users also raise the question of representation on these regulatory 
bodies. 
3.1.7. The need for ongoing consultation 
Many of the parties concerned very much wished to be involved in the process 
of establishing a Community postal policy. 
Operators and users in particular strongly welcomed the proposal in the Green 
Paper to set up working parties on some of the important issues. It was also 
suggested that independent economic experts be involved. 
Finally, the workers representatives in particular clearly want to see the Joint 
Committee on Postal Affairs set up very soon. 
32. Areas of disagreement 
Whereas there is broad agreement on the most important aspects, there are 
other by no means negligible issues where opinions differ, sometimes to the 
point where there are two largely opposing views. 
The areas of disagreement include the precise definition of universal services, 
the extent of the reserved area, the link between universal and reserved 
services, the network and the method of implementation of Community postal 
regulation. 
U* 
- 10-
3.2.1. Precise definition of universal services 
As far as mail is concerned there are two main positions, reflecting two 
different points of view. 
On the one hand, there are those who support the idea of an extensive universal 
service and propose extending this definition to all correspondence (a 2 kg limit 
would seem to be acceptable). This universal service would be based on 
standard reasonable prices and a universal network. 
Each Member State would be able to impose even more stringent obligations in 
order to provide a more extensive service. 
On the other hand, there are those who would prefer a more limited definition 
and suggest that universal services apply essentially to correspondence between 
individuals, although this could also include the mailing requirements of small 
businesses. 
Opinions were also divided on parcel post and goods transport. It was widely 
considered that they should not necessarily form part of the universal service. 
3.2.2. The extent of the reserved area 
Some contributors consider that the zone should be very extensive in order to 
increase the supply of universal services. They suggest that a very limited 
reserved area could hamper the development of the universal service provider. 
Other contributors, particularly private, and in some cases public, operators and 
certain major customers propose that the reserved area should be as small as 
possible. 
Many of them argue that some of the universal service obligations should not 
necessarily be compensated for with reserved areas. 
They consider that social costs should be specified and external subsidies paid. 
It would then be possible to have a small reserved sector. 
Some suggested that more than one universal service provider could be allowed, 
e.g. by establishing a legal duopoly system. 
On the subject of reserved services, reactions included: 
- general agreement that magazine and newspaper services, parcel services and 
express services should not longer be reserved as is usually the case at 
present; 
- widespread agreement that special services and genuinely new services 
should be in the competitive sector; 
- agreement that letter services should be a reserved service with price and 
weight limits, although the limits proposed were very different; 
- support for liberalization of self posting provided that there is a precise 
definition of this type of service; 
- intense discussion on applying to the letter service the content criterion and 
the rules governing cross-border traffic. 
/ <s 
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To summarize, the views expressed during the debate are as follows. Firstly, it 
is proposed to reserve distribution of all types of addressed correspondence. 
The content criterion cannot be applied because of the inviolability of mail (and 
for this reason direct mail must be reserved). Even if this obstacle were 
overcome, it would not be possible to give a precise definition of direct mail to 
distinguish it from letters. 
It was felt that liberalization of cross-border mail might have the effect of 
eroding the national reserved area. 
On the other hand, a number of major customers and private operators 
proposed liberalizing direct mail (and some even wanted to liberalize all non-
addressed direct mail) and all of cross-border traffic. 
An intermediate position (adopted by many of the postal authorities) was to 
establish an "average" reserved area using price/weight as a criterion. They 
consider that a distinction could be made between outward cross-border traffic 
(to be liberalized) and inward cross-border traffic (to be reserved), but they do 
not consider it feasible to liberalize direct mail without adversely effecting the 
financial viability of the postal authorities. 
In most cases, the reserved sector was seen as an area which would change over 
time. It was assumed that there would be more and more liberalization as time 
went on. 
3.2.3. Universal services versus reserved services 
Most contributors welcomed the fact that the universal service and reserved 
service were not of the same size. It was generally accepted that the universal 
service would be more extensive than the reserved service. 
However, this could lead to problems of competition in the non-reserved part of 
the universal service where universal service providers with specific obligations 
(e.g. to provide the service and to operate a standard tariff) are in competition 
with other operators who are not subject to the same obligations. As a result: 
- the "other" operators can cream off the market 
- the postal authorities can cross-subsidize the non-reserved area from the 
reserved area. 
To avoid these problems and to simplify regulation, some contributors 
suggested that the same definitions should apply to universal service and 
reserved services. 
Some went on to propose that the present reserved area be extended to make it 
exactly the same size as the universal service area. 
Others preferred to limit the universal service in each Member State to the area 
reserved at Community level. 
Mention was also made of the possibility of imposing the same obligations on 
all operators working in the non-reserved part of universal services. This could 
be done for example by using contracts between the Member State and the 
operators concerned, who would have exclusive or special rights. 
Some even envisage for the competitive sector of the universal service different 
obligations to those in the reserved sector, particularly with regard to tariffs 
,' A. Ui 
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(e.g. much greater freedom to conclude contracts on tariffs, or even tariff 
obligations which apply only to charges to the general public). 
Finally there were questions regarding application of the proportionality 
criterion. Some preferred a direct formula (once the costs of providing the 
universal service are known) and others envisaged more flexible application as 
in other sectors. 
3.2.4. The universal network 
It was agreed that universal services can only be provided if there is a universal 
network, and it is in fact the cost of this network which to a large extent dictates 
the need for a reserved area. 
There was also acceptance of the idea that the universal network can be used to 
supply both reserved and non-reserved services, i.e. services other than 
universal services. It was felt that conditions on access to networks should be 
non-discriminatory. Following on from this principle, a number of points were 
made on tariffs and subsidies. 
In general, the postal authorities considered that: 
- cross-subsidies, when they are necessary to provide the universal service, give 
users an advantage; 
- close attention should be given to the relationship between "péréquation 
tarifaire" and the potential for creaming off the market; 
- tariff reductions should generally follow cost reductions. 
Private operators expressed other concerns particularly that: 
- effective measures should be taken to put a stop to state aid or special rights 
for services in the competitive sector; 
- there should not be discriminatory application of tariff reductions nor should 
they be used as a means of obtaining cross-subsidies between users. 
Finally there were a number of comments on the setting of tariffs. Some were 
in favour of tariffs based on market prices while others preferred tariffs related 
to costs. Views differed however on whether tariffs should always be based on 
average costs or whether, under certain circumstances, they could be based on 
marginal costs. 
In any case, with regard to the accounts of the postal authorities, there was 
general recognition of the need for transparency and for itemized accounts. 
3.2.5. Implementation 
There was general agreement on the basic conditions for implementation of 
Community postal regulation. 
Because of the complexity of the area implementation should be gradual giving 
the Member States reasonable time to make the adjustments required. 
Similarly, the postal authorities should also be given enough time to make the 
necessary changes. 
Nevertheless, it was generally felt that the adjustment period should be clearly 
ç 
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defined, although opinions on the length of this period differed with regard to 
implementation of postal policy in general and rules on cross-border traffic in 
particular. 
On the one hand, some postal authorities and some users suggested: 
- a relatively long transitional period, not only to give postal authorities time to 
adjust to the new system but also to allow operators and users to make the 
commercial changes required; 
- sufficient time to establish and apply the new system of terminal dues before 
liberalization of cross-border traffic. 
On the other hand, some major customers and private operators preferred: 
- relatively swift general implementation; 
- immediate liberalization of cross-border traffic. 
With regard to implementation procedures, much emphasis was placed on the 
complementary role to be played by Community bodies and the national 
authorities in the Member States. 
Repeated mention was made of the legal basis for the directives required, 
particularly the possible directive on reserved services. It was generally 
considered that, at least initially, the Commission should not use Article 90(3) 
so as to allow sufficiently wide-ranging consultation of all parties and 
institutions concerned. 
However, it was felt in some quarters that Article 90(3) was the most suitable 
legal instrument for a directive on reserved services or even for settling the 
matter of terminal dues. 
33. Other issues 
Certain issues were mentioned by only some contributors, notably those 
particularly concerned by them. 
Other issues were mentioned more frequently but were clearly not considered 
to have the same priority as those discussed in the two previous sections. 
Finally, other matters were raised in certain contributions but often were not 
discussed in sufficient detail to provide any real insight. 
However, all these various issues are nevertheless key elements for 
establishment of a Community postal policy and for this reason are summarized 
in this section. 
3.3.1. The level of harmonization desirable 
Although it was generally agreed that there should be more harmonization in 
the sector than at present, there was very little clear indication of the specific 
areas where there should be more harmonization. 
However, some priority areas were mentioned: post codes, bar codes, tracking 
and tracing, and dimensions of envelopes. 
It was also considered useful to implement the CEN standards. 
-14-
It is probably possible to achieve a reasonable level of harmonization of 
universal services only in the medium term, according to the opinions 
expressed. 
On tariffs, contributors agreed that it would be possible to harmonize the tariff 
structures of public operators for basic services. 
On the other hand, only a few commentators suggested introducing a single 
Community postal tariff. Even those who supported the idea considered that it 
wouid take a relatively long time to achieve. 
Private operators proposed harmonizing the accounting methods used by the 
postal authorities. 
Finally, it was emphasized that harmonization measures should not have the 
effect of reducing levels of service or increasing the price for users. 
There were two schools of thought on implementation procedures: 
- some considered that the regulatory authorities should take deliberate action 
or even impose harmonization; 
- others considered that harmonization should be allowed to take place 
naturally as a result of market forces and the laws of supply and demand, and 
that it could even result from pressure by customers. 
3.3.2. Methods of controlling the regulation process 
There are two areas where it was considered particularly important to control 
the regulation process. 
Firstly, there should be control measures to protect reserved areas. To this end, 
regulations should be clear, simple and precise and should give rise to no 
serious practical or legal difficulties. Also, the cost of control measures should 
be relatively small. 
Many contributors emphasized that these conditions would not be met if direct 
mail or inward cross-border traffic were liberalized. Unless there were a 
control system, this liberalization would have the effect of seriously eroding the 
reserved sector. 
However, liberalizing direct mail would entail using the content criterion, which 
would mean defining what may be contained in ordinary letters as distinct from 
direct mail letters. It was widely felt that it would be impossible to check the 
content of letters, particularly sealed letters, because of the problem of 
confidentiality. 
In order to liberalize inward cross-border traffic, it would be necessary to be 
able to distinguish national mail from cross-border mail. Many felt that this 
would not be easy. 
Secondly, frequent reference was made to the need to monitor operation of the 
market to ensure fair competition in the non-reserved area. This was 
mentioned by all the main users and private operators. 
3.3.3. The role of users 
At the very least, users wish to receive detailed information on the studies 
C2 
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carried out and the measures envisaged by the regulatory authorities so that 
they are fully aware of the approaches adopted and the issues involved. 
Users would also like to play an active role in helping to develop Community 
regulations. They heartily endorse the Commission's proposals that they should 
be systematically consulted and given the opportunity to express their opinions. 
There should not be participation only at Community level; there is also 
considerable demand for participation at Member State level too. This raises 
the question of proper representation of users, and the consultation procedures 
which should be introduced, and the way in which the whole regulation process 
should be organized. Some contributors suggest that users should be 
permanently represented on national regulatory bodies. 
The areas where users' opinions are considered essential are primarily service 
quality and harmonization measures. 
3.3.4. The impact of other Community policies on the postal service 
Repeated mention is made of the essential economic and social role which the 
postal service plays in the Community. This explains why various other 
Community policies can also affect the postal service. 
Many contributors wondered about the effect of specific sectoral or general 
policies on operation and development of the postal service. It was widely 
considered, for example, that any changes in the VAT rules applicable to postal 
services would considerably affect the current financial stability of the sector. 
Customs legislation and data protection measures are other areas of concern. 
There is also frequent reference to Community transport policy and particularly 
the European Parliament resolution on the Green Paper on Postal Services. 
This raises two points with regard to the transportation of postal consignments, 
namely combined transport and environmental impact. 
In any case, there is a clear need for0closer coordination between Community 
postal policy and other Community regulation which could have an appreciable 
effect on the former. 
Finally, these various policies should be applied to all postal operators in the 
non-reserved sector in a similar manner. All forms of discrimination which 
could falsify competition should be avoided. 
3.3.5. Community cohesion 
Some mention was made of Community cohesion in connection with the postal 
sector. 
On the one hand, an efficient and harmonized postal service will certainly 
facilitate Community cohesion and the harmonious development of the internal 
market. On the other hand, Community cohesion requires that postal services 
be equally efficient throughout the Community so that individuals and 
companies are not discriminated against because they happen to be in a 
particular part of the Community. 
Although these points are made in many of the submissions, in most cases no 
details are given of how a cohesion policy could be implemented in the area of 
postal services. 
r *> 
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Nevertheless, there were two contradictory proposals on the financial resources 
which could be used to encourage Community cohesion: 
- any funds made available for improving quality in the less developed regions 
should come from a central budget and not from the cross-subsidizing of the 
least efficient authorities by the most efficient authorities; 
- terminal dues might be one way of constituting a fund for Community 
cohesion; this proposal was made by postal regulators and the postal 
authorities. 
3.3.6. The international aspect 
Frequent reference was made to the international dimension of postal services: 
- with regard to the definition of universal service, where it was thought useful, 
or even essential, to refer to the obligations of the Member States set out in 
the UPU Convention; 
- in connection with control of remail, with regard to the implication of 
Article 25 of the UPU Convention, which provides a legal basis for objecting 
to the various types of remail, particularly the ABA system (where mail is 
taken from one country A to a second country B for mailing back to the first 
country A) or remail via a third country; 
- with regard to terminal dues, where the proposal to base rates on the costs 
borne by the country of destination would be feasible only if adopted by the 
UPU; 
- with regard to the possibility of establishing an international arbitration 
system designed to monitor the different routes used for remail or to 
intervene in cases where there is no agreement on application of a new 
system of terminal dues. 
Contributors considered that Member States should: 
- coordinate their positions in international forums; 
- be consistent in their commitments to non-Community countries and on 
Community postal policy. 
Finally, frequent reference was made to possible international developments in 
the postal sector in the context of GATT/GATS. 
3.4. Applying the principle of subsidiarity 
Although the principle of subsidiarity was mentioned fairly frequently at 
seminars or meetings held during the consultation period, very few of the 
written contributions mention it at all. 
Nevertheless, the question of subsidiarity is clearly behind many of the 
comments, and those to which it is relevant are listed below. 
3.4.1. Support for Community action 
Generally there is considerable support for development of a common postal 
policy. Consequently the Community authorities should play an essential role. 
The main areas for Community action are: 
% 
-17-
- developing and implementing the concept of a Community universal service; 
- defining the set of reservable services; 
- setting standards and taking the other measures required to improve the 
quality of the postal service within the Community; 
- measures on compliance with competition rules; 
- the role to be played by users in achieving commercial and technical 
harmonization, and with regard to the quality of cross-border services; 
- settling the issues of remail and terminal dues. 
Naturally there is sometimes disagreement as to whether the specific measures 
proposed by the Commission on each of these points are appropriate. 
However, comments are very rarely unanimously in favour of a particular 
approach. In any given case there are those who consider the Commission's 
proposals too precise, or even excessive, while others consider that they don't go 
far enough or are even virtually worthless. 
3.4.2. Achieving a balance between national measures and Community policy 
It can be concluded from the contributions that, given the reference framework 
established at Community level, the role of the Member States should be: 
- to define the concept of universal service at national level; 
- to draw up a list of reserved services; 
- to ensure provision of the universal service; 
- to guarantee protection of the area reserved for the operator responsible for 
the universal service; 
- to set quality standards for national services; 
- to monitor and control operation of national markets. 
Those contributors which comment on the subject suggest some kind of co-
responsibility between the Community and the Member States, as is clear from 
the comments on this point in the European Parliament resolution. 
According to the principle of subsidiarity, this co-responsibility should allow 
action on the coordination, continuity and quality of postal services within the 
Community to be taken at the most effective level, whether national level or 
Community level. 
Although the majority endorsed this view, there were some dissenters: 
- those who considered that action should be taken virtually exclusively at 
national level; 
- those calling for standard regulations (particularly on the reserved sector) at 
Community level, and hence for much more Community involvement. 
^<T 
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4. THE SOURCE-BASED APPROACH 
The approach followed in Chapter 3 has been to analyse the results of the consultation 
procedure in terms of individual subjects and according to the basic principles of the 
future common postal regulation proposed by the Commission in the Green Paper. 
In order to facilitate comprehension and readability, only a general reference has been 
give as regards the sources of the various contributions. The effect of this may be 
that: 
- the overall strength and intrinsic consistency of individual reactions is to some 
extent lost in the general review; 
- individual socio-professional groups, e.g. major users or postal administrations, may 
appear to be in agreement, whereas the various organizations within a particular 
category often expressed different views on certain aspects of the postal field. 
The summary may be rendered somewhat more lucid by presenting the reactions 
received during the consultation procedure in therms of the opinions of the main 
interest groups involved rather than the points at issue. 
This Chapter is therefore structured accordingly. 
4.1. Institutional sources 
At the Community level, the European Parliament (EP) and the Economic and 
Social Committee (ESC) studied the Commission's Green Paper in great depth. 
The study involved long discussions both in committees and in plenary sessions. 
Finally, these two Community bodies adopted an opinion on the Green Paper. 
Some of the Member States also sent the Commission their positions on the 
options set out in the Green Paper, along with the position, if any, of the 
national Parliament. 
4.1.1. The European Parliament 
During the January 1993 part session, Parliament discussed and by a large 
majority approved the report prepared by Mr Simpson, which had itself been 
the subject of detailed discussion in the Committee on Transport and Tourism. 
The subject had also been discussed by the Committee on Economic and 
Monetary Affairs and Industrial Policy on the basis of an opinion prepared by 
Mr Merz. 
The resolution contains a very positive assessment of the Green Paper in terms 
of its analysis of the sector, its description of the problems at issue and its 
presentation of the options available. While emphasizing the justification of 
Community action, the resolution approves the basic principles set out in the 
Green Paper, in particular the concept of universal service, the need to 
maintain a balance between harmonization and opening up of the market and 
need for efforts to improve the conditions under which the service is provided. 
However, the resolution does depart from the options suggested by the 
Commission on certain points of application. Parliament proposes that: 
- the distribution of direct mail and cross-border mail should not be liberalized 
£& 
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as this might endanger the continuity of supply of the universal service and, 
for the same reason, not to ensure that new services will automatically be in 
competition with each other; 
- the Commission should not have recourse to Article 9(3) of the Treaty as the 
legal basis for the development of the common postal policy for the reserved 
services because the use of that Article would mean that Parliament and 
other Community bodies would be unable to play a full part in the 
organization of the postal sector. 
Parliament's suggestion to take fuller account of the transport policy dimension 
should be emphasized, in particular the scope offered by combined means of 
transport, and the impact of the transportation of postal items on the 
environment. 
4.1.2. The Economic and Social Committee 
In the sections in particular but also in plenary session, the discussion focused 
mainly on the extent to which the market should be opened up and the ways of 
implementing such a policy. 
Two points were made: 
- the need for broad and rapid liberalization, which would mainly allow market 
forces to operate, thus enabling services to be provided in line with customer 
expectations; 
- a limited and in all events phased opening up of the market would be an 
essential requirement of Community policy if the prime objective is to 
guarantee the continuity of the universal service. 
4.1.3. The Member States 
The Member States which communicated their positions at this stage of the 
consultation warmly welcomed the Green Paper and supported most of its 
proposals. 
In this respect, there is no dispute as regards, inter alia, the concept of universal 
service, the maintenance of a reserved area, separation of the functions of 
regulation and operation, the need to have postal services adapted to users' 
requirements and the need for an able, effective postal administration. 
Where views were at variance with the options set out in the Green Paper, these 
concerned in particular the liberalization of the distribution of direct mailing 
and cross-border mail. 
A majority of the Member States do not want the direct mail sector to be 
opened up. With regard to cross-border traffic, a distinction was often made 
between outward traffic, which could be liberalized, and inward traffic which 
should be kept in the reserved area. 
The justification given for these positions was the need to ensure the long-term 
financial viability of the universal service provider. It was feared in particular 
that the opening of direct mail and cross-border traffic would enable private 
operators to erode the remaining reserved sector substantially. 
s} 
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42. Professional users 
There was a massive response from these users during the public consultation 
procedure, with reactions from trade associations and other bodies representing 
such users at both national and Community level. A number of companies also 
privately submitted their views on the Green Paper. 
4.2.1. The trade associations 
Whether they were speaking on behalf of all the undertakings concerned or only 
the largest of them, the trade associations welcomed the concept of universal 
service but generally felt that a distinction should be made between major users 
and other customers. 
This distinction should cover not only the operational aspects (conditions of 
open access to universal networks) and tariffs (scope for negotiation of 
contracts) but also the regulatory side. It was proposed that, in some cases, the 
concept of universal service should not cover bulk mail and that the distribution 
of such mail should not fall within the reserved sector. 
Separation of the regulatory from the operational aspects was considered to be 
essential for the development of the sector (opening up of the market, control 
of competition). 
As regards harmonization, it was felt that, notwithstanding any standards 
adopted, major customers should continue to be able, where necessary, to 
obtain special conditions from their service providers. 
4.2.2. Specific customers 
As would be expected, most of the response during the public consultation 
procedure came from those sectors most dependent on the postal services. 
The mail order companies attached importance to being able to have access to 
the postal services throughout the EC and to the quality of the service. The 
third essential point for them was the tariff conditions. 
Commercial and technical harmonization, which offers interesting opportunities 
provided it is not turned into a rigid framework that does not allow for change, 
is considered to be desirable, although in general no specific points in this 
respect were made in the comments received. 
The need to solve the problems of cross border trade (customs, different VAT 
systems and rates, etc.) was also stressed as being vital. If these problems 
continued, they would restrict the scope for creating a genuine Community and 
international market in mail order. 
The links with other policies (distance selling, data protection, liability of service 
providers) were also extremely important. 
Direct marketing companies were divided as to the possibility of obtaining a 
clear definition of direct mail items. If the distribution of these items were to 
be liberalized without an appropriate definition, it would be difficult for 
envelopes containing such items to be recognized. 
An equally important aspect is the possible impact of Community data 
protection policy on companies in the sector, which might, if the need arose, 
have to start looking for means of advertising other than direct mail. 
Ç* 
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The press (especially weekly and specialized publications) took the view that a 
definition is needed for printed postal items, with specific characteristics in 
terms of network access, service quality and tariff conditions. The press should 
be considered in two ways: 
- in terms of a cultural policy taking account of the social importance of the 
press, and 
- by recognition on the part of the postal operators that senders of publications 
are major customers with specific needs with whom a cooperative 
customer/service supplier relationship needs to be developed. 
Book publishers have different postal requirements to other publishers as 
regards the weight of the items to be transported, the requested distribution 
times and the regularity of delivery. Their products are also cultural products 
which should be granted concessionary tariffs, these being traditional in many 
countries. 
The trade and industry sector representatives stressed, in particular through the 
Committee on Commerce and Industry, that the importance of intra-
Community services would increase with the completion of the single market 
and that this type of service should therefore be given very special attention. 
It was furthermore recommended that the postal administrations should listen 
very closely to their customers, in particular people in business who would 
increasingly be expressing their particular requirements. 
Lastly, companies in the financial sector (banks, insurance companies) 
expressed two concerns: 
- first, the need to ensure a high-quality universal service, which was essential 
to maintain regular contacts in line with customer requirements, e.g. for 
sending out bank statements and canvassing customers before offering new 
financial services); 
- second, it was essential to ensure fair competition. They took the view that in 
some Member States and in certain areas the financial services offered by the 
post office were not always subject to the same rules as other banking or 
insurance activities. They also wondered what advantage the post office may 
have by offering its financial services at a low cost through the universal 
network, in particular the network of post office counters. 
4.2.3. Small businesses 
All of the comments setting out the expectations of small businesses, be they 
from associations which represent them in the stricter sense or from 
organizations with a broader remit, e.g. chambers of commerce, etc., make it 
quite clear that the postal requirements of small businesses need to be 
considered in depth and covered by a specific approach. 
Because of their size, individual small businesses expressed their fear that postal 
operators would not take sufficient account of their requirements. 
In particular, the fact that some small businesses are located in regions in which 
the postal services are least developed means that the concept of a universal 
. service needs to be associated with action with regard to Community cohesion. 
The customers of non-standardized services, in particular those who use 
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document exchange systems, these mainly being small businesses or the liberal 
professions, wish to be able to continue to use these services outside the 
reserved area, without a minimum price limit being laid down. 
43. The postal industry 
Although the major postal service operators, be they the postal administrations 
or the major international courier services, are the largest and the best known 
part of the postal sector, they are not all of the postal industry. This also 
includes: 
- the operators who work at national, regional and even local level in certain 
gaps in the market for end-to-end services and those who operate in the pre-
distribution phase (mail preparation, pre-sorting, sorting, collection, etc.); 
- manufacturers of franking and sorting equipment and stationery 
manufacturers. 
All of these people also took part in the public consultation procedure and their 
views are set out below. 
4.3.1. The postal administrations 
Although their positions were in general very similar on matters of principle, 
the postal administrations nevertheless had divergent views on a number of key 
points. 
The overall assessment of the situation in the sector, the need to adapt the 
regulations to the changes taking place and the establishment of a clear 
reference framework for the near future were in general well received. 
The concept of universal service with its principle features such as network 
accessibility, frequency of services, speed and reliability, affordable prices and 
the maintenance of a single unitary tariff, at least for small customers, were 
largely welcomed. 
The maintenance of a reserved area was justified by the need for economies of 
scale and the desire to ensure a minimum revenue to pay fixed costs, which for 
the universal network required to provide a universal service were relatively 
high, and was also unanimously considered to be essential. 
A large group of postal administrations take the view that they should retain a 
more commercial approach and act on the basis of fair competition in the non-
reserved sector. For this reason, they accept a large number of the options in 
the Green Paper, in particular as regards the conditions of access, the basic 
criteria for the establishment of tariffs, and the introduction of Community 
service quality standards. 
The harmonization aspects are approved of provided they are in keeping with 
customer requirements and enable operators to be more efficient. 
The postal administrations also raised a number of questions on other aspects 
such as: 
- precise definitions of universal service and reserved services; 
- the maintenance of a single unitary tariff; 
Go 
-23-
- the obligations of the postal administrations; 
- the need for simple, easily controllable regulations. 
They suggested in particular that their obligations in the non-reserved sector 
should be kept to a minimum and that they should be able to compete 
efficiently with other operators. In particular, a creaming-off of the most 
lucrative parts of their market should be avoided. 
They also proposed that thereserved area should be adequately extended. 
They agreed that the definition of the limits in the reserved sector should be 
based on weight and price. The proposed levels for these limits varied according 
to the proposer. 
A large number of the administrations took the view that the distribution of 
direct mail should be reserved. 
A distinction was made as regards cross-border traffic between outward mail 
and inward mail. 
Views on the former were divided. Some administrations wanted it to be 
reserved, while others accepted liberalization. A majority of the latter wanted 
this to be conditional upon the advance establishment of a new system of 
terminal dues based on costs. 
Nearly all of the administrations felt that inward mail should be in the reserved 
sector. 
However, some of them would accept all cross-border mail being liberalized in 
due course, provided a new system of terminal dues was laid down in advance. 
The new services, however, could only be liberalized if they had been clearly 
defined and placed in the competitive sector on a sufficiently clear basis. Views 
were divided on the regulatory system to be adopted with regard to the physical 
transportation, in particular outside of the distribution phase, of hybrid mail 
(postal electronic mail). 
Finally, they requested that the undesirable types of remail, in particular A-B-A 
remail, should be controlled and a new system of terminal dues drawn up. If 
necessary, this system could be restrictive. 
On the outer fringe of this group are the postal administrations which, without 
wishing to maintain the current situation, take the view that some of the 
Commission's proposals (especially, but not only, as regards the opening up of 
the market) go too far and that the action proposed is too fast. In this way, the 
basic principle, namely the continuity of the universal service, would no longer 
be guaranteed. 
Conversely, one other postal administration took the view that the 
Commission's approach (especially as regards liberalization) was the minimum 
action required to resolve the problems in the sector and to improve the 
efficiency and quality of the services. 
In particular, the reserved sector would be needed for a limited period only and 
not in the long term. 
Lastly, it was pointed out, with regard to concessionary tariffs for the 
Qf 
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distribution by post of press items, that fair compensation for the postal 
administrations should come from a subsidy in the general budget rather than a 
cross subsidy from the reserved sector. 
4.3.2. Other postal operators 
There was general agreement on the overall view of the sector, although 
differences could be identified on less important matters. Local operators, in 
particular, did not always express the same point of view or interest as the 
major operators. The local operators in particular referred to specific problems 
they met at national level. 
All of these operators regretted to some extent that, in their view, the Green 
Paper seemed to focus more on the future of postal administrations than the 
development of the postal sector. 
They did not dispute the need for a universal postal service, even if in general 
they considered it should be on a minimum scale. 
Their suggestion therefore was that the universal service should cover the 
requirements of private individuals only and that the postal requirements of 
companies should be met solely by the action of free market forces. 
Some of them proposed distinguishing between the distribution of mail in built-
up areas or by a certain date, for which free market forces would establish the 
level of service, and distribution in rural areas where State intervention was 
essential to avoid the disappearance of mail as a means of communication. 
While recommending the total opening up of the market in the longer term, 
they accepted the maintenance of a reserved sector in the short term. However, 
the area encompassed by this sector should be very small. They nevertheless 
called for immediate, full liberalization of cross-border mail. 
They approved the use of price and weight as criteria for delineating the 
reserved sector, some of them proposing a threshold of 20 g for weight and of 
twice the general tariff in the first step by weight for price. All services above 
these thresholds should be competitive. 
Furthermore, they particularly called for a clear, effective separation between 
regulatory and operating functions and asked the Commission to guarantee the 
neutrality of action of the national regulator. The task of the latter would in 
particular be to ensure fair competition in the postal sector. 
They requested the abolition of all distortion of competition, the current 
situation in their view still being a long way from this objective. 
They particularly emphasized the disparities in customs procedures. 
The problem was the same as regards VAT from which the public postal 
services were exempt under Article 13 of the Sixth VAT Directive of 1977. They 
felt there was no justification for the system in the non-reserved sector differing 
according to whether the operator was public or private. 
They therefore recommended that the activities of the postal administrations in 
the competitive sector should be subject to VAT and therefore advocated the 
drawing of a legal distinction between these activities. In particular, they took 
the view that parcel and express services now handled by the postal 
administrations should be run by individual, legally separate companies offering 
6>\ 
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the reserved sector services. 
They referred to the possibility of abuse of a dominant position on the part of 
the postal administrations and thus expressed their keen interest in the 
abolition of all discrimination as regards access to the universal postal network. 
The various postal operators should have access to the network of the universal 
service provider on the same terms as all other users, including the terms 
offered to other postal administrations. 
They also expressed concern with regard to the principles underlying the tariffs 
laid down by the postal administrations and the possibility of providing cross-
subsidies. In this regard, they did not accept the possibility of a cross-subsidy 
from the reserved sector to the competitive universal services. 
On the subject of compliance with competition rules, a number of operators 
wondered what the consequences would be of creating joint ventures between 
the postal administrations and private operators. 
The agreement between TNT and five postal administrations, for example, 
seems to pose a threat to other operators. 
Lastly, there were various views regarding the systems for the exchange of 
documents. It was proposed that these systems should fall within the 
competitive sector throughout the Community since they would not be 
detrimental to the development of the universal service, in particular because 
of: 
- the small volume of mail handled; 
- the fact that the services were in competition with express services and not 
basic services. 
4.3.3. Others involved in the postal industry 
A whole series of people are involved in the postal sector. Manufacturers of 
sorting equipment, mail consolidators, transport firms, envelope manufacturers, 
printers. 
Their expressed wish is for the postal services to develop as their own future will 
depend on this development. 
For this reason, they are particularly keen on actions that will help to improve 
the performance of the postal services and to make the postal operators more 
dynamic. 
In this respect, they support all measures which guarantee the continuity of the 
service and promote quality. 
They also mentioned the importance they attach to harmonization. Any 
standards adopted will have a direct impact on their production activities. For 
this reason, they wish to be able to play an active part in the various aspects of 
the standards-making process. 
The subjects they propose should be dealt with in a Community framework 
include: 
- the physical characteristics of standardized postal items; 
61 
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- code control techniques; 
- reading techniques for coded items; 
- item monitoring systems; 
- the development of electronic mail; 
- the automated handling of mail. 
Lastly, they emphasized that, when drawing up the postal regulations, it would 
be in the Community's interest to take account of the possible consequences of 
these industries' production centres relocating outside the Community and the 
advisability of recovering Community markets which have been lost to suppliers 
outside the Community. 
4.4. Consumers and the trades unions 
These play a particularly important role in the postal sector and to a large 
extent are responsible for giving it the political dimension which ensures that it 
receives very close attention. The consultation procedure revealed the way in 
which these groups, mainly of consumer representatives and employees of the 
postal administrations, will help to shape the future of the postal sector. 
Various other social welfare organizations and charities expressed the need for 
a high-quality universal service and their wish to have specially adapted services 
and tariffs. An example of this was societies for the blind. 
4.4.1. Consumers 
Consumers are very strongly in support of the development of a high-quality 
universal service, taking the view that this service should include not only letter 
mail but also parcels. 
They therefore attach particular importance to the conditions of accessibility to 
the network, in particular as regards post office counter services, especially the 
sale of stamps, various financial transactions and other more specific services, 
e.g. the payment of pensions in some Member States. 
They particularly support the maintenance of a uniform price, which they 
believe is a fundamental characteristic of basic postal services. 
It emerged from their comments that their main concern is service quality. In 
this regard, they support all of the Commission's proposals on distribution times 
(setting of standards, external end-to-end control, publication of results). 
Other points mentioned in addition to the aspect of time are waiting times at 
counters and the treatment of complaints by the postal authorities. 
They are also very keen on the possibility of the service provider being liable in 
the event of any failure to provide the service and feel that the present system 
under which the postal authorities may be held liable is inappropriate. 
Lastly, they call for ambitious harmonization projects and regret the lack of 
uniformity in postal services between Member States of the Community. 
Consumer representatives also very strongly expressed their desire to play a full 
part in any future thinking on the construction of the European postal services, 
61, 
-27-
in particular as regards service quality and harmonization. 
4.4.2. Trades unions 
Contributions were received first and foremost from the organizations 
representing postal workers but also from more general trade union 
confederations. 
In general, they regretted the fact that insufficient account had been taken of 
social provisions in the Green Paper, in particular that changes in employment 
in the postal sector, working conditions, training policy and social 
harmonization had not been covered in greater depth. They expressed keen 
interest in the Joint Committee on Postal Affairs which is soon to be set up in 
order to deal with these matters. 
They were also very firmly in favour of the public service tasks carried out by 
the postal authorities and therefore keenly supported any plans to develop the 
universal service. However, they were extremely reticent about measures to 
open up the market. 
In their view, the Commission's proposals to open up the market would lead to 
a creaming off of the most profitable sectors, thus weakening the postal 
administrations and possibly leading to job losses. 
Lastly, four other points were firmly supported: 
- to need to continue to apply the Commission's 1979 recommendation on 
extending the inland rate to letters under 20g sent anywhere in the 
Community; 
- to allow cross-subsidies; 
- to reject the concept of an open network (they expressed strong support for a 
reserved area covering all postal functions: collection, sorting, transport, 
distribution) and even of non-discriminatory access for private operators to 
the universal network; 
- not to use Article 19(3) of the Treaty as the legal basis for Community 
legislation on the definition of the reserved postal service. 
4.5. Reactions from outside the Community 
The Green Paper aroused a great deal of interest beyond the Community's 
borders because of its scale, which constitutes a departure from the traditional 
national approaches to the postal sector, and because many of the problems it 
discusses also exist in other parts of the world. 
The interest visible in certain exchanges of views with some of our international 
partners was particularly strong in Europe but was also shown by countries such 
as the USA, Japan and Australia. 
This interest generated a large number of comments in particular on the part of 
the international postal bodies of several postal administrations and national 
authorities of the European Free Trade Association (EFTA) countries. 
4.5.1. The international postal institutions 
The Green Paper is still being studied by the Universal Postal Union (UPU). 
Is 
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The UPU merely drew attention to the need for compatibility between 
Community regulations and the international postal rules as laid down in UPU 
documents. It took the view in particular that measures to combat unlawful 
remail operations or the introduction of a new system of terminal dues should 
be decided at UPU level. 
The UPU was also concerned that any reform of the rules applicable to 
international mail services should take account not only of the interests of the 
developed countries, between which most mail was exchanged, in particular the 
Community countries, but also of the needs of the developing countries. 
The Postal Regulators Committee (CERP) of the European Conference of 
Postal and Telecommunications Administrations (CEPT), which includes 36 
European countries, also submitted comments on the Green Paper, mainly 
emphasizing the need for the following: 
- development of the universal postal service (the minimum level laid down on 
a Community scale, each Member State able to work to a higher level); 
- a balance between liberalization and harmonization (for the liberalization of 
cross-border mail, it is planned, at least for outward mail and subject to 
certain conditions such as the introduction of a new system of terminal dues, 
to establish relevant control systems, with an appropriate timetable for this to 
be laid down); 
- to preserve the financial viability of the universal service provider (caution 
thus being needed to prevent the most attractive parts of the market from 
being creamed off). 
The CERP made the point that it was essential to take account of UPU 
obligations. 
It also asked to be sent a timetable for the introduction of the measures 
required. 
4.5.2. The EFT A countries 
A number of countries, in particular those in Scandinavia, proposed to maintain 
a universal service but at the same time to open up the postal market widely if 
not completely, their view being that this is the best way to develop the sector 
and to obtain a range of services that best meets users' expectations. 
In their plans, it is proposed that the cost of public service tasks carried out by 
the post office should be mainly funded from the national budget or even with 
local authority assistance. 
They also distanced themselves from the Green Paper by proposing charges for 
services based not on costs but on market prices. 
Other countries, in particular Switzerland, on the other hand, attached 
particular importance to the range of social services which the universal service 
had to provide. Their approach to the reserved sector was quite similar to that 
proposed by the Commission, i.e. progressive, controlled opening up of the 
market to guarantee the universal service. 
The contributions also showed an interest in the need to solve the problems of 
terminal dues and remail. 
é£ 
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5. CONCLUSIONS 
The broad consultation procedure obviously aroused a great deal of interest. 
The public discussion without doubt provided an opportunity for clarification, 
understanding and constructive thinking; 
- clarification because all interested parties in the Community now support the same 
concepts with regard to the postal sector and have similar analytical viewpoints. 
This educational aspect of the discussion is essential for a constructive dialogue; 
- understanding because the consultation procedure also provided an opportunity for 
genuine exchanges of views not only between the Commission and the various 
groups operating in the postal sector but also between these groups themselves. In 
this way, each group described its main expectations, its chief interests and its prime 
concerns. This openness will be of great help in paving the way ahead and enable 
compromises acceptable to the broad majority to be reached; 
- constructive thinking because concurring views were expressed on a large number 
of crucial issues. The objective is to establish the future basis of Community postal 
policy. Where there were differences of opinion, the matters concerned were 
considered in great detail and in some cases will require further analysis and 
scrutiny. This extremely positive approach has meant that it has been possible to 
overcome initial opposition in numerous areas. 
In the light of its summary of the discussion, the Commission will be able to publish 
firm guidelines for the development of the single market in postal service to follow on 
from the Green Paper. 
a 

-1 -
ANNEX 
LIST OF WRITTEN CONTRIBUTIONS 
SENT TO THE COMMISSION DURING 
THE CONSULTATION PERIOD 
OF THE POSTAL GREEN PAPER 
A. WITHIN THE EEC <J> 
I. INSTITUTIONS 
1. Community Bodies 
- Résolution du Parlement Européen adoptée le 22 janvier 1993 
- Avis du Comité Economique et Social adopté le 25 mars 1993 
2. Governments of the Member States 
- Belgium 
- Germany 
- France 
- Greece 
- Ireland 
- Italy 
- Netherlands 
- Portugal 
- Spain 
3. Parliaments of the Membre States 
- Assemblée Nationale française (rapport de M. Durieux) 
4. International Bodies 
- Conférence européenne des Postes et Télécommunications (Comité 
européen de la réglementation postale) 
Universal Postal Union (UPU) 
(i) or European or international organisations which include the 12 Member States. 
é* 
-2-
5. Groups with a Community Perspective 
- Comité Consultatif des Consommateurs 
- Comité du Commerce et de la Distribution 
6. Others 
- Bundesrat (Germany) 
- Commission Supérieure du Service Public des PTT (France) 
- POUNC - Post Office Users' Council (Royaume-Uni) 
II. INTERESTED PARTIES 
7. USERS 
7.1. CONSUMERS ASSOCIATIONS 
- Arbeitsgemeinschaft der Verbraucherverbânde e.V. 
- Association Etudes Consommateurs - CFDT 
- BEUC - Bureau Européen des Unions de Consommateurs 
- Consumers Association 
- Consumers in the EEC Group 
- CSF - Confédération Syndicale des Familles 
- Fédération Nationale des Familles Rurales 
- Union de Consumidores de Espana 
- Union Fédérale des Consommateurs 
- Verband der Postbenutzer e.V. 
7.2. BUSINESS USERS 
- AEMD Venta por Correo 
- AEVD - Association des Entreprises de Vente à Distance 
- Agence Centrale des Organismes de Sécurité Sociale. 
• Allied Irish Bank 
- American Express 
- ASEMPRE - Asociacion Profesional de Empresas de Reparto y 
Manipulado de Correspondencia 
- Association espagnole de Marketing Direct 
- Association Française des Banques 
-. Barclays Bank Pic 
- BDZV - Bundesverband deutscher Zeitungverleger 
- Belgische Veringing van Banken 
- Boersenverein des deutschen Buchhandels e.V. 
- Bundesverband deutscher Industrie e.V. 
- British Printing Industries Federation 
- CAEJ - Association Européenne des Editeurs 
- Caisse Nationale d'Assurance Vieillesse 
- Caisse Nationale de Crédit Agricole 
• Caisse Nationale des Allocations Familiales 
- CEEP - Centre Européen des Entreprises à Participation Publique 
- Chambre Commerce et d'Industrie de Paris 
- CNPF - Conseil National Patronat 
- Comité National Français - Chambre de Commerce Internationale. 
- Confederacion Espafiola de Organizaciones Empresariales 
^û 
-3-
Confédération Générale des Petites et Moyennes Entreprises 
Confederation of Irish Industries 
Deutschen Industrie und Handelstag 
Direct Mail Services Standards 
Direct Marketing Association 
Dublin Sollicitors Bar Association 
Electricité de France 
Electricity Supply Board - ESB 
EMESUA - European Mail and Express Services Users Association 
EMOTA/AEVPC - European Mail Order Traders 
Association/Association Européenne de Vente par Correspondance 
EUROCHAMBRES 
FEB - Fédération des Entreprises Belges 
Federacion Nacional de Empresas Publicidad 
Fédération Bancaire de la CE. 
Fédération Française des Sociétés d'Assurance 
Fédération Nationale de la Presse Française 
FEDIM - Fédération Européenne du Marketing Direct 
FNPS - FAEP / Fédération Nationale de la Presse d'Information 
Spécialiée - Fédération des Associations d'Editeurs de Périodiques 
de la CE. 
Garantie Mutuelle des Fonctionnaires 
Gesamtverband der Deutschen Versicherungswirtschaft e.V. 
Groupement Européen des Caisses d'Epargne 
Imperial Chimical Industry 
IFSDA-International Federation of Stamp Dealers's Association 
IOD - Institute of Directors 
Law Society 
Marketing y Publicitad directa 
Mutuelle Générale des PTT 
National Newspapers of Ireland 
NOTU - Nederlandse Organisatie van Tijdschrift-Uitgevers 
Office des Transports et PTT de l'Ile de France 
Paul Spain Group Ltd 
Periodical Publishers Association 
Postal Users' Platform 
Postbank 
Reader's Digest 
Royal National Institute for the Blind 
Syndicat des Entreprises de Vente par Correspondance et à 
Distance 
Syndicat National de la Communication Directe 
The Irish Mail Order Ass. 
The Irish Trade Board 
The Packing Shop 
Timewarner 
UNICE - Union des Confédérations de l'Industrie et des 
Employeurs d'Europe 
Union des Offices des Transports et des PTT 
Union Internationale Editeurs 
Union Nationale Interprofessionnelle pour l'Emploi dans l'Industrie 
et le Commerce 
Voluntary Health Insurance Board 
It 
-4-
8. OPERATORS 
8.1. PUBLIC 
- Amministrazione délie Poste e Telecomunicazioni (Italie) 
- Correos y Telégrafos (Spain) 
- An Post (Irlande) 
- La Poste (Belgique) 
- La Poste (France) 
- Plateforme La Poste/Postdienst (France/Germany) 
- Postdienst (Allemagne) 
- PostEurop 
- PTT Nederland (Pays-Bas) 
- The Post Office (Royaume-Uni) 
8.2. PRIVATE 
- AEEC - Association of European Express Carriers 
- AICES - Association of International Courier and Express Services 
- Air France 
- Association française des Transports Routiers Internationaux 
- Association of European Document Exchange (branche irlandaise) 
- Belgian International Express Carriers Association 
- Business Post Holdings Ltd 
- DHL Espagne 
- EEO - European Express Organisation 
- Entrega en Mano 
- European Association of Document Exchange 
- Francedoc S.A. 
- Groupement des Activités de Transport et de Manutention de la 
Région Ile de France 
- Irish Association of International Express Carriers 
- Société Nationale des Chemins de Fer 
- Syndicat Français de l'Express International 
- Syndicat Français des Entreprises de Transports légers 
- Syndicat National de Messagerie et Abonnements Périodiques 
- Syndicat National des Entreprises de Logistique et Publicité 
9. POSTAL INDUSTRY SUPPLIERS 
- CALIBAN S.A. 
- Compagnie Générale Automatisme 
- GPMU - Graphical Paper & Media Union 
- Néopost - Société pour l'Affranchissement et le Timbrage Automatique 
- Pitney-Bowes (France) 
- Sociedad de Desarrollo Postal S.A. 
- Société d'Etude et de Construction d'Appareils de Précision 
- Syndicat Général des Fabricants d'Enveloppes, Sachets et Pochettes 
10. EMPLOYEES 
- Association des Administrateurs des PTT 
- Confédération Européenne des Syndicats 
- CFDT - Confédération Française Démocratique du Travail 
- CGP - Christliche Gewerkschaft Post 
- CIF - Confédération Internationale des Fonctionnaires 
- Confédération Française Encadrement - Confédération Française des 
Cadres 
ii 
-5-
- Confédération Générale du Travail 
- Confédération Générale du Travail Force Ouvrière 
- CVVU Communication Workers Union 
- DBB - Deutscher Beamtembund 
- Deutsche Postgewerkschaft 
- Deutscher Postverband 
- DGB - Deutsche Gewerkschaftsbund 
- EUROFEDOP 
- Federation of Irish Employers 
- Fédération Syndicale des Travailleurs des PTT 
- IPTT - Internationale des Postes, Télégraphes et Téléphones 
- Irish Congress of Trade Unions (see CVVU) 
- Post Office Unions' Council 
- Sindicato Federal de Correos y Telegrafos 
- Syndicat Chrétien Communication et Culture 
- Syndicat Libre de la Fonction Publique 
- Vereniging Van Hoger Personeel PTT 
11. RESEARCH INSTITUTES AND CONSULTANTS 
- Fachhochschule des Bundes fur ôffentliche Verwaltung, Deutsche 
Bundespost Telekom, Dieburg 
- Omega Partners 
- Rickard Johnson 
- WIK - Wissenschaftliches Institut fiir Kommunikationsdienste GmbH 
B. EFTA 
1. STATES 
Ministry Transport Communication (Suède). 
Gouvernement Suisse 
2. OPERATORS 
- Post Finland 
- PTT Suisses 
li 
ISSN 0254-1475 
COM (93) 247 final 
DOCUMENTS 
EN 10 
Catalogue number : CB-CO-93-288-EN-C 
ISBN 92-77-56486-5 
0 ^ial Publications of the European Communities 
ourg