COMMISSION STAFF WORKING DOCUMENT EVALUATION of Directive 97/67/EC on common rules for the development of the internal market of Community postal services and the improvement of quality of service amended by Directives 2002/39/EC and 2008/6/EC (Postal Services Directive) accompanying the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of the Postal Services Directive (Directive 97/67/EC as amended by Directive 2002/39/EC and 2008/6/EC)
Date: 2021-11-08
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EU competition policy, application of EU law, digitisation, electronic commerce, freight rate, innovation, postal service, provision of services, single market, technological change, universal service

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.11.2021  SWD(2021) 309 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of  Directive 97/67/EC on common rules for the development of the internal market of Community postal services and the improvement of quality of service amended by Directives 2002/39/EC and 2008/6/EC                (Postal Services Directive) accompanying the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL    on the application of the Postal Services Directive  (Directive 97/67/EC as amended by Directive 2002/39/EC and 2008/6/EC) {COM(2021) 674 final} - {SEC(2021) 388 final} - {SWD(2021) 310 final}  
 
 
Table of Contents 

1. 

Introduction ....................................................................................................................................... 1 

Background ....................................................................................................................................... 2 
2. 
2.1 
History of the Postal Services Directive ............................................................................................. 2 
2.2  Main provisions of the Directive ........................................................................................................ 3 
The Baseline ..................................................................................................................................... 10 
2.3 

3. 
3.1 
3.2 

4. 
4.1 
4.2 

5. 
5.1 

5.2 

5.3 

5.4 

5.5 

State of Play ..................................................................................................................................... 13 
Implementation of the Directive ....................................................................................................... 13 
Current trends in the postal services market ..................................................................................... 14 

Method ............................................................................................................................................. 18 
Short description of methodology ..................................................................................................... 18 
Limitations and robustness of findings ............................................................................................. 20 

Q3:  

Q2:  

Analysis and answers to the evaluation questions ........................................................................ 22 
Effectiveness ..................................................................................................................................... 22 
Q1: 
Has the Directive ensured the provision of a postal universal service available at 
all points across the EU territory, at affordable prices and specified quality? ................. 22 
Has  the  Directive  contributed  to  the  achievement  of  an  internal  market  for 
domestic and cross-border postal services? Has the Directive stimulated fair and 
effective competition in the internal market for postal services? ..................................... 35 
Has  the  Directive  led  to  an  expected  level  of  harmonised  regulation  of  postal 
services across the European Union? ............................................................................... 38 
Efficiency .......................................................................................................................................... 41 
Do benefits associated with the application of the Directive outweigh the costs? ........... 41 
Q1:  
Q2:  
Is  there  scope  for  a  more  cost-efficient  application  of  any  provisions  of  the 
Directive, including for simplification and burden reduction? ........................................ 55 
Coherence ......................................................................................................................................... 59 
Q1:  To  what  extent  is  the  Directive  internally  coherent  as  well  as  coherent  with  the 

Regulation on cross-border parcel delivery services? ...................................................... 59 

Q2:  To  what  extent  is  the  Directive  coherent  and  complementary  with  other  EU-level 

Q2:  

legislation and horizontal policy as well as international postal policy?.......................... 60 
Relevance .......................................................................................................................................... 64 
Q1:  
How well do the original objectives, scope and definitions of the Directive still 
correspond  to  the  needs  of  EU  postal  users  in  the  current  technical,  economic 
and social conditions? ...................................................................................................... 64 
How  relevant  are  the  provisions  of  the  Directive  for  achieving  its  main 
objectives  (i.e.,  related  to  universal  service,  internal  market  and  harmonised 
principles)? ....................................................................................................................... 68 
In  the  context  of  the  new  developments  in  the  postal  markets,  are  there  other 
relevant objectives for regulatory  intervention at European level in the  field of 
postal services? ................................................................................................................ 72 
EU Added Value ............................................................................................................................... 72 
Q1:  
Would the benefits delivered by the Directive have been achieved in the absence 
of EU-level intervention? ................................................................................................. 72 
What would be the most likely consequences of withdrawing the Directive? ................. 74 

Q2:  

Q3:  

EN 

  EN 

 
 
 
6. 
6.1 
6.2 

CONCLUSIONS ............................................................................................................................. 75 
Conclusions on the fitness of the Directive....................................................................................... 75 
Lessons learned ................................................................................................................................. 77 

7. 

Annex 1: Procedural information .................................................................................................. 81 

8. 
Annex 2: Stakeholder consultation ................................................................................................ 87 
1. 
The consultation strategy .................................................................................................................. 87 
1.1 
Objectives ......................................................................................................................................... 87 
Stakeholders consulted...................................................................................................................... 87 
1.2 
1.3 Consultation activities ............................................................................................................................ 87 
Synopsis of consultation activities .................................................................................................... 89 
2. 
Consultations of Member States ....................................................................................................... 89 
2.1 
2.2 Consultations of National Regulatory Authorities .................................................................................. 89 
2.3 Consultation of social partners in the context of the Social Dialogue Committee for the Postal 

Sector ................................................................................................................................................ 89 
2.4 Public Workshops ................................................................................................................................... 90 
2.5 Open Public Consultation ....................................................................................................................... 90 
Introduction ...................................................................................................................... 90 
Overview of respondents ................................................................................................. 91 
Summary of responses ..................................................................................................... 92 

2.5.1 
2.5.2 
2.5.3 

9. 

Annex 3: Methods and Information Sources .............................................................................. 102 

10. 

Annex 4: Analysis of the Application of the Postal Services Directive, in view of the 
sixth Application Report to the European Parliament and the Council .................................. 108 

The Market (Overview of the Postal Sector in Europe) ............................................................ 108 
1. 
1.1 
Volumes .......................................................................................................................................... 108 
1.2  Main drivers of change in the postal sector .................................................................................... 111 
Changing User Needs ..................................................................................................................... 118 
1.3 
Prices............................................................................................................................................... 122 
1.4 
Competition, operators, ownership, performance, profitability ...................................................... 126 
1.5 
Employment .................................................................................................................................... 135 
1.6 
Environment.................................................................................................................................... 137 
1.7 

2. 
2.1 
2.2 
2.3 
2.4 
2.5 
2.6 

Application of the Directive ......................................................................................................... 138 
Transposition of the Directive......................................................................................................... 138 
The Universal Service ..................................................................................................................... 139 
Protection of users - complaints resolution ..................................................................................... 153 
Level Playing Field and Competition ............................................................................................. 156 
Interoperability for the Postal Sector/Standardisation .................................................................... 158 
Data Collection ............................................................................................................................... 160 

11. 

Annex 5: Coherence ...................................................................................................................... 162 

12. 

Annex 6: Bibliography .................................................................................................................. 167 

II 

 
 
 
 
Figures 

Figure 1 The Intervention logic of the Directive ............................................................................. 9 
Figure  2  Real  prices  of  domestic  parcels  and  letters  and  transit  times  for  letters,  annual 
percentage differences 2012-2018 ................................................................................................. 15 
Figure  3  Delivery  of  intra-EU  cross-border  mail  (percentage  of  items  of  the  fastest  standard 
category delivered 3 days after posting – EU target is 85 percent): .............................................. 30 
Figure 4 Price developments within the EU, Australia and the US .............................................. 52 
Figure 5 Respondents by Stakeholder Group ................................................................................ 91 
Figure 6 Respondents by country of origin ................................................................................... 92 
Figure 7 Is the Directive still fit for purpose? ............................................................................. 101 
Figure 8 Letter mail volumes, 2008-2019 ................................................................................... 108 
Figure 9 Letter mail per capita, 2018 .......................................................................................... 109 
Figure 10 Growth rate parcels, domestic and international service -dispatch, EU 27................. 110 
Figure 11 Parcels per capita, domestic and inbound, 2018 ......................................................... 111 
Figure 12 Parcel volumes, EU28, 2018 ....................................................................................... 111 
Figure 13 Percentage of enterprises sending e-invoices suitable for automated processing (2018)
 ..................................................................................................................................................... 113 
Figure 14 Individuals’ internet use to participate in social networks, 2014-2018 ...................... 115 
Figure 15 Individuals’ internet use to interact with public authorities in the last 12 months, 2014-
2018 ............................................................................................................................................. 116 
Figure 16 Use of hybrid mail solutions in future (respondents using hybrid mail, in per cent) .. 117 
Figure 17 Stakeholders’ expectations of letter volume development over the next 10 years ..... 119 
Figure 18 Real price for priority domestic letter 20g: CAGR 1998-2019................................... 123 
Figure 19 Public tariff for domestic priority letter 20g (real prices, Euro) ................................. 123 
Figure 20 Parcel prices in EUR, 2 kg, domestic and intra-EEA, 2019 ....................................... 124 
Figure  21  Number  of  geographical  zones  applied  for  the  pricing  of  intra-EEA  standard  2kg 
parcel, 2018 ................................................................................................................................. 125 
Figure  22 Average universal service provider profitability in mail operations, by country group
 ..................................................................................................................................................... 128 
Figure 23 Sources of operating revenues, average for years 2016, 2017 and 2018 .................... 130 
Figure 24 Number of postal service providers with more than 1 percent of the postal market in 
2019 ............................................................................................................................................. 132 
Figure 25 Share of turnover from letters and parcels, 2018 ........................................................ 135 
Figure 26 Persons employed in postal and courier activities ...................................................... 136 
Figure 27 National approaches to implementing the Postal Services Directive .......................... 138 
Figure 28 Percentage of domestic priority letters delivered next day ......................................... 147 
Figure 29 D+3 performance development 1997-2019 for international mail ............................. 148 
Figure 30 Transit time performance D+3 .................................................................................... 149 
Figure 31 Price developments within the EU, Australia and the USA ........................................ 151 
Figure  32  Developments  of  public  tariffs  in  selected  countries  (20g  letter,  fastest  standard 
category) ...................................................................................................................................... 152 
Figure 33 Complaints received by universal service providers per 1,000 inhabitants, 2017-2019
 ..................................................................................................................................................... 155 
Figure 34 Complaints received by regulators per 10,000 inhabitants, 2017-2019 ...................... 155 
Figure 35 Complaints received by universal service providers about cross-border services, 2017-
2019 ............................................................................................................................................. 156 

III 

 
 
 
 
Tables 

Table 1 Evolution of the main provisions of the Directive ............................................................. 4 
Table 2 Expected outcome of the Directive since the last revision in 2008 .................................. 12 
Table 3 Evolution of the carbon-efficiency for letter and parcel delivery between 2013 and 2019
 ....................................................................................................................................................... 17 
Table 4 Delivery/collection requirements and exceptions/derogations ......................................... 26 
Table 5 Calculated net cost / compensation for SGEI provision ................................................... 44 
Table 6 Total budgets of regulators for postal regulation (figures from 2017 or 2018) ................ 49 
Table 7 Profitability of universal service providers (EBIT margin (Earnings before interest and 
taxes), letter and parcel segment) .................................................................................................. 53 
Table 8 The costs and benefits of universal service provision and regulation .............................. 55 
Table 9 Relevance of the universal service features and quality requirements, present and future
 ....................................................................................................................................................... 66 
Table 10 Revisions to the SWD following the RSB recommendations ........................................ 82 
Table 11 Timing of consultation activities .................................................................................... 88 
Table 12 Were the objectives of the Directive achieved? Are they still relevant? ...................... 100 
Table 13 Costs and benefits of universal service provision and regulation ................................ 103 
Table 14 Total budgets of regulators for postal regulation (figures from 2017 or 2018) ............ 104 
Table 15 Costs of regulation (universal service providers) ......................................................... 105 
Table 16 EU-28 costs for compliance with the Directive per capita ........................................... 106 
Table 17 Stakeholders benefitting from universal service provision .......................................... 107 
Table  18  Operating  profit/loss  of  universal  service  providers,  all  activities,  in  mio  Special 
Drawing Rights ........................................................................................................................... 129 
Table 19 Shares of universal service providers on the domestic letter market ........................... 130 
Table 20 Scope of universal services 2018 ................................................................................. 139 
Table 21 EEA Transit time objectives for domestic single-piece priority letter mail ................. 146 
Table 22 Number of universal service providers that achieved domestic transit time targets (FSC)
 ..................................................................................................................................................... 147 
Table 23 Implementation of pricing principles, 2018 ................................................................. 149 
Table 24 Method of price regulation ........................................................................................... 150 
Table 25 Universal service providers’ complaint procedures ..................................................... 154 
Table 26 Access to postal infrastructure ..................................................................................... 156 
Table 27 Product scope ............................................................................................................... 157 
Table 28 Application of the mandatory standards for transit time measurement ........................ 160 
Table  29  Coherence  and  complementarity  between  the  Directive  and  other  key  pieces  of 
legislation .................................................................................................................................... 162 

IV 

 
 
 
 
 
 
 
Access points 

B2B 

B2C 

B2X 

Bulk letters 

Bulk mail  

Bulk parcels 

C2B 

C2C 

C2X 

CAGR 

CEN 

Glossary 

Physical  facilities,  including  letter  boxes  provided  for  the  public 
either on the public highway or at the premises of the postal service 
provider(s),  where  postal  items,  such  as  letters  and  parcels,  may  be 
deposited with or collected from the postal network.  

Business-to-business 

Business-to-consumer 

Business-to-everybody (consumers, businesses, government) 

Letters  that  are  posted  in  significant  quantity.  Note  that  there  is  no 
legal definition of which number of letters constitute bulk mail. 

Physical mail that is commercial in nature, prepared in large volumes 
and mailed at reduced postage costs. Bulk mail may consist of letters, 
newsletters, pamphlets, and other similar products.  

Parcels  that  are  prepared  and  sent  in  significant  quantity,  such  as 
those  mailed  by  e-commerce  operators.  Note  that  there  is  no  legal 
definition of which number of parcels constitute bulk parcels. 

Consumer-to-business (mainly, returns from e-commerce) 

Consumer-to-consumer 

Consumer-to-everybody (consumers, businesses, government) 

Compound average growth rate. 

Comité  Européen  de  Normalisation  –  European  Committee  for 
Standardisation 

CEP 

Courier, express and parcels 

Consolidator 

Operator that collects postal items from different senders and inserts 
them into the postal network for sorting, transport and delivery 

Clearance 

The operation of collecting postal items by a postal service provider 

Cross-border mail 

Mail from or to another Member State or from or to a third country 

D+1  

D+3  

Routing  time  where  mail  is  delivered  the  first  working  day  after 
posting 

Routing  time  where  mail  is  delivered  the  third  working  day  after 

V 

 
 
 
Direct mail 

posting 

Direct  mail  is  a  communication  consisting  solely  of  advertising, 
marketing or publicity material and comprising an identical message, 
except  for 
the  addressee’s  name,  address  as  well  as  other 
modifications which do not alter the nature of the message, which is 
sent  to  a  significant  number  of  addressees.  Bills,  invoices,  financial 
statements and other non-identical messages shall not be regarded as 
direct mail. A communication combining direct mail with other items 
within the same wrapping shall not be regarded as direct mail. 

Distribution 

The  process  from  sorting  at  the  distribution  centre  to  delivery  of 
postal items to their addressees. 

Eurostat 

Statistical Office of the European Communities 

FSC 

GDP 

Fastest standard category 

Gross domestic product 

Item of correspondence  Communication  in  written form  on  any  kind  of  physical  medium  to 
be conveyed and delivered at the address indicated by the sender on 
the item itself or on its wrapping. Books, catalogues, newspapers and 
periodicals shall not be regarded as items of correspondence. 

National regulatory 
authority 

The  body  or  bodies,  in  each  Member  State,  to  which  the  Member 
State  entrusts,  inter  alia,  the  regulatory  functions  falling  within  the 
scope of the Directive 

Package 

Postal item 

Postal network 

Also  referred  to  as  “packets”,  packages  are  postal  items  containing 
goods. These can be either parcels (up to 10kg) or  ‘small packages’ 
which are E-format items conveyed in the letter post. 

An item addressed in the final form in which it is to be carried by a 
postal service provider. In addition to items of correspondence, such 
items also include for instance books, catalogues, newspapers, 
periodicals and postal parcels containing merchandise with or without 
commercial value. 

The system of organisation and resources of all kinds used by the 
universal service provider(s) for the purposes in particular of:  

- 

- 

- 

the clearance of postal items covered by a universal service 
obligation from access points throughout the territory,  
the routing and handling of those items from the postal 
network access point to the distribution centre, 
distribution to the addresses shown on items. 

Postal services 

Services involving the clearance, sorting, transport and distribution of 
postal items 

VI 

 
 
Postal service provider 

Undertaking that provides one or more postal services 

PostEurop 

Receiver 

Remuneration of 
International Mails 
Agreements (REIMS), 
INTERCONNECT 
Remuneration 
Agreement – Europe  

Reserved area 

Sender 

SME 

SMMS  

Terminal dues 

Transit time 

Trade  association  representing  European  public  postal  operators 
(universal service providers) 

Also referred to as “recipient”, it is a natural or legal person to which 
a postal item is addressed. It is currently not defined in the EU legal 
texts. 

The Remuneration of International Mails Agreements is the Terminal 
Dues framework developed by International Post Cooperation and its 
members since 1999. It complements the Terminal Dues framework 
of the Universal Postal Union. Recently it has been complemented by 
INTERCONNECT Remuneration Agreement – Europe which is the 
first multi-lateral Terminal Dues agreement covering both letters and 
parcels products and focusing on e-commerce. The agreement is 
signed by 24 designated postal operators, including all major 
European designated postal operators. One of the main objectives 
targeted under the INTERCONNECT Remuneration Agreement – 
Europe was to lower the Terminal Dues level in order for postal 
operators to be more competitive on the e-commerce market. 

The reserved area means those parts of the letter mail market where 
the  clearance,  sorting,  transport  and  delivery  within  certain  weight 
and  price  limits  was  limited  to  the  designated  universal  service 
provider. 

A natural or legal person responsible for originating postal items 

Small and medium sized enterprises 

The Sustainability Measurement and Management System (SMMS) 
programme is the successor to the Environmental Measurement and 
Monitoring Programme (EMMS) by International Post Corporation.  

The  remuneration  of  universal  service  providers  for  the  distribution 
of incoming cross-border mail comprising postal items from another 
country 

Also  called  “routing  time”,  is  a  quality  indicator  measuring  the 
number  of  working  days  elapsed  between  the  date  of  deposit  of  a 
postal  item  with  an  access  point  and  that  of  its  delivery  to  the 
addressee.  

Universal Postal Union   The Universal Postal Union is the United Nation’s specialised agency 
for  the  postal sector. The Universal  Postal  Union coordinates postal 
policies among  member nations, in addition to the worldwide postal 
system and is a standard setter.  

VII 

 
 
Universal service 
obligation 

The totality of services and conditions a universal service provider is 
designated to provide and respect 

Universal service 
provider 

The  public  or  private  postal  service  provider  providing  a  universal 
postal  service  or  parts  thereof  to  every  citizens  within  a  Member 
State, the identity of which has been notified to the Commission 

VAT 

Value added tax 

VIII 

 
 
 
1. 

INTRODUCTION 

The EU postal services sector is a key enabler of the economy and trade, underpinning 
other  sectors  and  contributing  to  the  resilience  of  the  EU  economy.  Companies  of  all 
sizes  use  it  to  build  their  business,  supply  goods  and  receive  payments.  All  levels  of 
government and public administrations rely on it for public communications. Vulnerable 
users  and  citizens  in  remote  areas  need  it  to  remain  connected  to  an  increasingly 
digitalised  economy.  The  postal  services  sector  hence  plays  a  key  role  in  promoting 
social  and  economic  cohesion  and  connecting  EU  citizens  and  businesses.  In  2018  the 
sector  employed  around  1.5  million  persons  across  the  EU,  among  which  an  estimated 
950 thousand in postal activities falling under the universal service obligation1.   

However,  over  the  last  two  decades,  the  EU  postal  sector  has  been  facing  significant 
structural  changes.  Digital  means  of  communication  have  been  replacing  paper-based 
ones,  impacting  demand  for  letters  and  leading  to  significantly  lower  volumes.  At  the 
same  time,  the  increase  in  online  shopping  (and  e-commerce  in  general)  and  the 
possibility of having goods delivered to one’s home has increased the demand for parcels 
and packets delivery. Postal users’ needs today are hence different from what they were 
24  years  ago  when  the  first  Postal  Services  Directive  was  adopted  in  1997.  These 
developments have created challenges and opportunities for the postal sector.  

Article  23  of  the  Postal  Services  Directive  (hereinafter  the  “Directive”)2  requires  the 
European Commission  (“Commission”)  to  “submit  a report  to  the European  Parliament 
(“Parliament”) and the Council on the application of the Directive, including appropriate 
information on developments in the postal services sector. The latest report3 was adopted 
by the Commission in November 2015 and concluded that the Directive was still fit for 
purpose.  It  nevertheless  highlighted  that  close  monitoring  and  further  analysis  were 
necessary as the postal services sector is evolving continuously and rapidly.  

Considering the significant changes in the postal services sector and the changing needs 
of  postal  users,  the  Commission  announced  an  evaluation  of  the  Directive  in  its  2020 
work programme. The objective is to assess whether the Directive is still fit for purpose 
and  responds  to  the  present  and  future  needs  of  EU  citizens  and  businesses  and  will 
continue to do so in the foreseeable future.   

To  this  end  the  present  evaluation  examines  the  universal  service  obligation,  its 
financing, the quality of services, designation of the universal service providers and the 
regulation of tariffs of universal services. It also examines the impact of the Directive on 

1    Eurostat (2021), annual detailed enterprise statistics for services. 
2   Directive 97/67/EC of the European Parliament and of the Council of 15 December 1997 on common 
rules for the development of the internal market of Community postal services and the improvement of 
quality of service amended by Directives 2002/39/EC with regard to the further opening to competition 
of  Community  postal  services  and  2008/6/EC  with  regard  to  the  full  accomplishment  of  the  internal 
market of Community postal services 

3   Report  from  the  Commission  to  the  European  Parliament  and  the  Council  on  the  application  of  the 

Postal Services Directive, COM(2015)0568 final. 

1 

 
 
                                                      
market  opening  and  competition  in  the  EU  and  national  postal  markets,  as  well  as  the 
level of harmonization achieved by the Directive.  

The  evaluation  covers  developments  since  the  adoption  of  the  last  revision  of  the 
Directive  in  2008  until  2019/20.  It  covers  all  the  then  28  Member  States4  although  in 
some  instances  also  the  European  Economic  Area  (EEA)  countries  are  included.  On 
occasion information and data refers to a limited sample of Member States. 

The Directive has been evaluated against its general objectives to guarantee the provision 
of  affordable,  high-quality  universal  postal  service  to  all  users,  a  well-functioning  and 
competitive  internal  market  and  the  harmonisation  of  principles  of  regulating  postal 
services.  In  line  with  Better  Regulation  principles,  the  effectiveness,  efficiency, 
coherence, relevance and EU added value of the Directive have been assessed. 

2.  BACKGROUND 

2.1  History of the Postal Services Directive 

The  Directive  was  adopted  in  1997  to  address  the  lack  of  harmonization  of  postal 
services at EU level which negatively impacted on cross-border communications which 
were vital to commercial and social life in the EU. The objectives of the EU postal policy 
were, on the one hand, the completion of the single market for postal services56 through 
gradual  and  controlled  liberalisation,  a  higher  level  of  harmonisation  and,  on  the  other 
hand, the maintenance of a reliable, affordable and good-quality postal services available 
to all users across the EU.7 

This  Directive  hence  established  a  common  level  of  universal  service  with  minimum 
requirements regarding: (1) the scope of the universal service (e.g., what products to be 
covered,  minimum  delivery  frequency  requirements  and  density  of  the  access  point 
network);  (2)  quality  of  service  standards  (in  particular  as  regards  transit  times  and 
reliability  of  services),  (3)  a  number  of  tariff  principles  for  universal  service  (“price 
regulation”);  and  (4)  the  creation  of  independent  national  regulatory  authorities.  An 
essential element of the Directive was the start of a gradual and controlled liberalisation 
of  the  market  and  the  establishment  on  an  internal  market  for  postal  services.8  The 
Directive  provided  Member  States  with  a  certain  margin  of  discretion  to  adapt  their 
domestic  postal  services  to  their  own  specificities.  Exceptions  to  the  minimum 
requirements  on  frequency  and  point  of  delivery  were  allowed  for  in  extraordinary 
circumstances or geographical conditions.  

4   References to the “EU” in this document, unless otherwise specified, should be understood as EU28. 
5  Achieving the Single Market required proceeding from markets with State-owned postal monopolists to 
open markets, where users should have a choice between different services and prices. Therefore, it was 
considered important to define a harmonised set of principles for the regulation of postal services. 

6   Directive 97/67/EC, Recital 8. 
7  Resolution  of  Council  of  7 February  1994  on  the  development  of  Community  Postal  Services, 

OJ (1994) C 48/3 quoted in Third Postal Service Directive 2008/6, Recital 1. 

8   Directive 97/67/EC, Recital 8 and Recital 2. 

2 

 
 
                                                      
The next steps towards liberalisation were made by Directive 2002/39/EC, amending the 
1997 Directive9. It further reduced the product scope and price of services that Member 
States  could  reserve  to  universal  service  providers.10  In  particular,  it  put  priority  on 
measures  designed  to  promote  market  entry,  continuing  the  gradual  establishment  of 
competition  in  domestic  and  cross-border  letter  markets  (especially  through  the 
transparent  and  non-discriminatory  application  of  special  tariffs  offered  by  incumbent 
postal  operators  to  senders  of  bulk  mail).  The  Directive  was  set  to  expire  on  31 
December 2008, setting 2009 as the target date for full market opening.  

A  last  set  of  amendments  were  adopted  with the  Directive  2008/6/EC  11  to  achieve 
full  market  opening.  The  Directive  removed  the  area  of  postal  services  that  Member 
States  could  still  reserve  for  the  universal  service  provider  (statutory  monopoly)  and 
provided for full liberalisation. The amendment set out an agreed deadline for full market 
opening  by  31  December  2010  for  16  Member  States12  and  31  December  2012  for  the 
remaining ones13. 

2.2  Main provisions of the Directive 

The  below  table  sets  out  the  main  provisions  of  the  Directive  and  explains  how  the 
provisions  of  the  1997  Directive  have  changed  with  the  two  subsequent  amendments.

9   Directive  2002/39/EC  of  the  European  Parliament  and  of  the  Council  of  10  June  2002  amending 
Directive 97/67/EC with regard to the further opening to competition of Community postal services. 
10   Directive 2002/39/EC reduced the reserved area to postal items below 100 grams from 1/1/2003 and 50 
grams from 1/1/2006. It also set  a price limit to the public tariff for certain items of correspondence. 
11   Directive  2008/6/EC  of  the  European  Parliament  and  of  the  Council  of  20  February  2008  amending 
Directive 97/67/EC with regard to the full accomplishment of the internal market of Community postal 
services. 

12   Austria, Belgium, Bulgaria, Denmark, Estonia, Finland, France, Germany, Ireland, Italy, Netherlands, 

Portugal, Slovenia, Spain, Sweden and the United Kingdom. 

13    Cyprus,  Czech  Republic,  Greece,  Hungary,  Latvia,  Lithuania,  Luxembourg,  Malta,  Poland,  Romania 
and Slovakia. Although Croatia formally joined the EU on 1 July 2013, its postal services sector was 
fully opened as of 1 January 2013. 

3 

 
 
                                                      
Table 1 Evolution of the main provisions of the Directive 

OBJECTIVES 

PROVISIONS 

1997 Directive 

2002 Directive 

2008 Directive 

y
t
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l
a
u
q
-
h
g
i
h

,
e
l
b
a
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o
f
f
a

f
o
n
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a
n
i
a
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a
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U
E
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t

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v
r
e
s

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t
s
o
p
l
a
s
r
e
v
i
n
u

Universal postal service for all users, comprising 
collection, sorting, transport, and distribution at least five 
working days per week of: (i) postal items (e.g., letters, 
parcels, catalogues, newspapers) weighing up to 2 
kilograms and (ii) postal packages (e.g., parcels) up to 10 
kilograms (which may be increased for parcels up to 20 
kilograms) as well as services for registered items and 
insured items in both categories. 
Affordable, cost-oriented, transparent and non-
discriminatory tariffs for universal services. 
Quality of service targets (transit time) for cross-border 
mail (85% for D+3, 97% for D+5 for the fastest standard 
category of service), Member States to set compatible 
national targets for domestic mail. 
Consumer protection measures, particularly with regard to 
complaints and redress procedures for user complaints in 
the universal service. 

No change 

No change 

No change 

No change 

No change 

No change 

Consumer protection rules 
may be extended to all postal 
operators (not only the 
universal service provider). 

The financing of the universal service was done by 
reserving an area of the business exclusively to the 

No change  

Consumer protection rules 
extended to all postal 
operators and rules to 
encourage out-of-court 
dispute resolution schemes for 
disputes between users and 
postal operators.  
Clarification that Member 
States may for the financing 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
designated provider, (financing was limited to the extent 
necessary to ensure the provision of the universal service). 

Requirement for Member States to ensure that the 
universal service is guaranteed and to notify the 
Commission of the designated universal service provider. 

No change 

-
l
l
e
w
a
h
s
i
l
b
a
t
s
E

d
n
a
g
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n
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f

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v
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t
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p
m
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c

t
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a
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e
t
n
I

s
e
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v
r
e
s

l
a
t
s
o
p
r
o
f

Clear limits for reserved services (i.e., letter products 
reserved for exclusive handling by the universal service 
provider). 

Gradual reduction of the 
reserved area; tentative date 
for the full opening of the 
letter market. 

Transparent and separate cost accounting principles to be 

No change 

of the net cost of the universal 
service that represents an 
unfair burden use a 
compensation fund in addition 
to the use of public funds. as 
well as the relevant conditions 
(notably: interchangeability) 
Introduction of additional 
options to ensure the 
provision of universal 
services: (i) by market forces, 
i.e. the government does not 
appoint any universal service 
provider(s), but trusts that the 
providers in the market place 
are willing to provide 
universal services and that 
they do so in the most cost 
efficient way; and (ii) by 
public procurement. 
Possibility to designate 
several universal service 
providers.   
Elimination of remaining 
reserved area; 31 December 
2010 deadline for full letter 
market opening (derogation 
granted to 11 Member States, 
31 December 2012). 
Measures preventing 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
applied by universal service providers; separate accounts 
for reserved and non-reserved universal services, 
discouraging cross-subsidies from the reserved letter 
services to the competitive area. 
- 

- 

Introduction of definitions to ensure harmonisation of 
concepts. 

No change 

Introduction of the possibility for the European Committee 
for Standardisation  to issue technical standards for greater 
inter-operability between postal networks, taking into 
account standardisation measures at international level 
such as those issued by the Universal Postal Union. 
Establishment of independent national regulatory 
authorities to ensure compliance with the Directive.  

No change 

No change 

e
h
t

r
o
f

s
e
l
p
i
c
n
i
r
p
d
e
s
i
n
o
m
r
a
h
t
e
S

n
o
i
t
a
l
u
g
e
r

discriminatory tariffs and 
cross-subsidization from 
universal services to non-
universal services 
Introduction of the possibility 
for Member States to regulate 
access to elements of 
infrastructure or services of 
the universal service provider, 
in the interest of users and/or 
to promote competition. 
Some definitions removed in 
order to adapt the open market 
environment. 
No change 

Powers to request information 
and data from all postal 
operators (compliance with 
Directive and market 
monitoring). 

6 

 
 
 
 
 
 
 
 
 
 
Intervention logic 

The  Directive  has  three  main  objectives:  (1)  guaranteeing  the  sustainable  provision  of 
affordable,  high-quality  universal  postal  service  to  all  users  throughout  the  EU;  (2) 
establishing a well-functioning and competitive internal  market  for postal services;  and 
(3) harmonising principles for the regulation of postal services. 

These objectives are linked to a set of inputs that also correspond to given articles of the 
Directive. Some of the inputs may link to more than one objective: 

  the definition of the minimum scope of the common level of universal service (Article 

3);  

  the conditions of the provision of the universal service, in particular the possibility to 
designate  universal  service  providers  and  to  grant  financial  compensation  for  those 
providers (Articles 4 to 8); 

  the  setting  and  monitoring  of  certain  quality  requirements  for  the  provision  of  the 
universal service and the establishment of complaint handling procedures (Articles 16 
to 19); 

  the  regulation  of  tariffs  for  the  universal  service  that  should  be  affordable,  cost-

oriented, transparent and non-discriminatory (Articles 12 and 13); 

  the  reduction  of  entry  barriers,  such  as  defining  conditions  for  general  authorisation 
and individual licences, and the requirement for Member States to ensure transparent, 
non-discriminatory access conditions to certain elements of the postal infrastructure or 
services within the scope of the universal service (Articles 10 to 12); 

  the development of technical standards (Article 20); 

  the creation of common minimum definitions (Article 2); 

  the  establishment  of  national  regulatory  authorities  to  ensure  compliance  with  the 

objectives of the Directive (Article 22). 

As  a  result  of  the  transposition  and  application  of  these  inputs,  the  following  outputs 
were expected: 

  the provision of a minimum level of an affordable postal universal service offered at 

similar service levels to postal users across the EU; 

  a  universal  service  complying  with  harmonised  quality  requirements,  and  a  better 
protection of the postal user’s interests by requiring all providers to offer transparent, 
simple and inexpensive procedures for complaint resolution; 

  the  opening  of  postal  markets  to  competition  by  facilitating  entry  and  expansion  of 
alternative providers and providing for conditions to establish a level playing field;  

  postal services compliant with harmonised technical standards; 

  harmonised concepts; 

  the improvement of national regulatory oversight. 

7 

 
 
In turn, those outputs should lead to the following results:  

  more  efficient  postal  networks;  full  market  opening  would  result  in  a  more  cost-
efficient use of the postal networks for the provision of affordable universal services; 

  wider access for users and other postal operators to the postal infrastructure;  

  effective competition as full market opening would enable competing postal operators 
to enter the former statutory monopoly market for letter mail services and compete at 
level playing field; 

  improved  quality  of  postal  services  through  the  quality  requirements  and  increased 
innovation  (e.g.,  track  and  trace)  spurred  by  competition  and  technological 
developments; 

  an Internal Market for postal services. 

Finally, there are several external factors outside the remit of the Directive. These include 
digitisation, e-commerce and new business models. Moreover, the harmonisation in the 
EU following the Directive has the following broader impact: 

  more social and territorial cohesion throughout the EU; 

  increased postal users’ satisfaction in the EU; 

  innovation and development of new business models in the EU. 

The figure below provides an overview of the intervention logic for the EU postal sector 
showing the expected sequence of general and specific objectives, inputs, outputs and the 
intended results and broader impact of the Directive. 

8 

 
 
 
Figure 1 The Intervention logic of the Directive 

9 

 
 
 
2.3  The Baseline 

The  baseline  for  this  evaluation  is  the  situation  in  2008,  the  adoption  of  the  2008 
amendment to the 1997 Directive14. There are several reasons why 2008 is chosen as the 
baseline instead of 1997, namely: a fundamental motive for the Directive was to open up 
the postal services sector fully and establish an internal postal services market. That only 
happened  as  of  2008  with  the  complete  abolition  of  the  statutory  monopoly  still 
prevailing  in  Member  States  with  part  of  the  letter  mail  services  being  “reserved”  to 
universal service providers. The requirements regarding the universal service obligation 
have not  changed since  1997 and the objectives  of the Directive also  remain the same. 
Events following 2008 therefore capture the changes that the Directive has brought over 
time. 

Before discussing developments at the time of the baseline, it is necessary to consider the 
extent to which the key objectives from 1997 had been achieved in 2008. In 1997, postal 
services in many Member States were provided by inefficient loss-making postal entities 
with a lack of customer orientation and low and heterogeneous quality of services. Only a 
few Member States had abolished the letter monopoly/reserved area and opened up their 
letter  mail  segment  to  competition:  Finland  (1991)  and  Sweden  (1992).  The  1997 
Directive introduced competition in a gradual and more harmonized manner in order to 
increase the quality of services, lower prices and encourage economic and employment 
growth.  Following  the  2002  amendment,  most  Member  States  partially  opened  their 
domestic markets by reducing the weight and price thresholds.  United Kingdom (2006) 
and Germany  (2008) proceeded to  full market opening.  In  addition,  all outgoing cross-
border mail was opened to competition as of January 1, 2003.  

Over the period 1998 to 2007, letter volumes increased by about 0.52 percent annually.15 
Real prices of the most commonly used letter mail service increased on average by 0.48 
percent  per  year16.  This  moderate  price  evolution  changed  after  the  financial  crisis  in 
2008 when price increases started to accelerate. Profitability in this period improved for 
the wide majority of universal service providers.17 By 2006, 87 percent of Member States 
considered  postal  services  affordable.18  Service  quality  improved  considerably  in  some 
Member  States  between  2000  and  2003,  while  a  few  faced  a  deterioration  of 
performance.19 By 2005, next day delivery had increased to exceed 90 percent of the mail 

14  The reserved area of up to 50 grams accounted for between 70 percent to 85 percent of postal items  – 
Commission Staff Working Document Accompanying document to the Proposal for a Directive of the 
European  Parliament  and  of  the  Council  amending  Directive  97/67/EC,  concerning  the  full 
accomplishment of the internal market of Community postal services, Impact Assessment, SEC(2006) 
1291. 

15   Based on raw data used in WIK (2021). Volumes started declining after 2007. 
16   Based on raw data used in WIK (2021). 
17   Universal Postal Union statistics, operating results, including all activities. 
18  Special Eurobarometer 260 Services of general interest, July 2007.  
http://ec.europa.eu/public_opinion/archives/ebs/ebs_260_en.pdf 
19   Such  deterioration  was  likely  caused  by  less  than  optimal  equipment  and  procedures.  Cf.  the  French 
case  described  in  section  5.2  (Q1),  where  investments  in  modernisation  led  to  quality  improvements 
during this period.  

10 

 
 
                                                      
volume for domestic priority mail in more than half of the Member States.20 The average 
quality of service remained stable between 2005 and 2008. Between 1997 and 2008, the 
Remuneration of International Mails Agreements played a relevant role in the substantial 
improvements in the cross-border quality services  level21. Specifically, the cross-border 
quality service levels (transit time) between 1997 and 2008 increased from 83.5 percent 
to  94.6  percent  of  mail  being  delivered  on  time.  Regarding  regulatory  harmonisation, 
between  1997  and  2008  the  number  of  technical  standards  developed  by  the  European 
Committee for Standardization was only eight compared to 35 standards developed after 
2008. The lacking independence of some national regulatory authorities and the absence 
of  regulatory  harmonisation  prior  to  2007  was  reported  as  major  constraints  on  the 
attainment of an internal market for postal services.22 The first 10 years of application of 
the Directive had therefore coincided with volume increase, improved quality of service, 
real price decrease and the preservation of the universal service already prevailing across 
the EU. The development  of competition  and the level  of harmonisation in  the internal 
market were, however, faulting. 

Around  2008,  the  EU  postal  sector  started  to  undergo  significant  and  wide-ranging 
change.23 The most important drivers of change were gradual regulatory market opening, 
technological  development  which  lead  to  the  rapid  growth  and  falling  costs  of  other 
means  of  communication  (in  particular  digitisation,  e-mail,  mobile  telephony  and 
internet),  new  automation  technology,  and  new  market  developments  with  growing 
parcel  volumes  and  increasingly  demanding  owners/shareholders  of  postal  operators. 
This put increasing pressure on the postal sector operators.  

Although there was  emerging competition  in  many national  markets,  national  universal 
service providers were still the key players with large shares of the domestic letter mail 
segment.  By  that  time,  the  impact  of  the  then  existing  Directive  on  the  level  of 
competition in letter mail markets was very limited, in particular in those Member States 
which had not yet opened their letter mail market.  

The  situation  was  substantially  different  for  the  delivery  of  parcels.  Although  parcels 
form  part  of  the  universal  service  obligation  up  to  a  certain  weight  limit,  the  parcel 
delivery segment had never been part of a statutory monopoly and had therefore seen the 
entry of a number of courier and express service operators.24 The parcel delivery segment 
was at the time already more heterogeneous and complex than the letter mail segment25 

20   See Commission Staff Working Document on the Evaluation of the Performance of Network Industries 

Providing Services of General Economic Interest, SEC(2005) 1781, Brussels, 20.12.2005, p. 12.  

21   The  Remuneration  of  International  Mails  Agreements  have  two  core  principles:  (a)  Payment  of  the 
Terminal Dues will only be made in full if a targeted level of quality of service is met. (b) Payments to 
delivering posts, known as Terminal Dues, must be linked to actual costs and the receiving country’s 
domestic  postal  rates  are  accepted  as  a  proxy  for  costs.  Therefore,  all  REIMS  agreements  provide  a 
system for intercompany pricing based on cost and quality of service for postal operators. 

22   Commission  Staff  Working  Paper,  Annex  to  the  Report  on  the  application  of  the  Postal  Directive, 

SEC(2005) 388 Brussels, 23.3.2005, p. 10.  

23   See  Accompanying  Document  to  the  Proposal  for  a  Directive  amending  Directive  97/67/EC, 
concerning  the  full  accomplishment  of  the  internal  market  of  Community  postal  services  -  Impact 
Assessment {COM(2006) 594 final} {SEC(2006) 1292}  

24   See recital 18 of the 1997 Directive that relates to the essential difference between express mail and the 
universal service that lies in the value added (whatever form it takes) provided by the express services 

11 

 
 
                                                      
 
The impact  assessment accompanying  the 2008 amendment  of the  Directive  mentioned 
that  although  some  Member  States  had  taken  initial  steps  to  redefine  the  universal 
service,  EU  consumers  were  overall  satisfied  with  the  affordability,  accessibility  and 
quality of postal services.26  

However, due to Member States opening up their postal markets at different speeds and 
some implementing below the minimum obligations set by the Directive (particularly in 
terms  of frequency and  quality of service),  there was increasingly a fragmented market 
for  postal  services  in  the  EU.  Moreover,  the  implementation  of  the  provisions  in  the 
Directive  relating  to  complaint  and  redress  had  not  been  fully  satisfactory  for  all 
consumers. In practice there was still discontent about handling of postal complaints. 27 

The  below  table  2  sets  out  the  expected  outcome  of  the  2008  Directive  with  regard  to 
certain main areas. The expected positive outcomes are highlighted in the table, but also 
the risk of facing negative ones, which is consistent with the analysis carried out in the 
impact  assessment  that  preceded  the  2008  amendment.  The  negative  impacts  were 
however deemed at the time to be less likely or less substantial than the expected positive 
impacts.  

Table 2 Expected outcome of the Directive since the last revision in 2008 

Provision 

Expected outcome 

Abolition of the 
reserved area and 
possibility of 
alternative financing 
mechanisms (State 
Aids, compensation 
funds) 

Positive 

  More effective competition in the letter mail segment can lead 
to lower prices, better quality of service and more efficient 
national postal operators. 

  Permitting a broad range of financing mechanisms can ensure 

the maintenance of universal services. 

Negative 

  Competitive pressure may lead to the incumbent limiting loss-

making national universal services provided in parallel to the EU 
universal service obligations, which could in turn have an impact 
on social and territorial cohesion.  

Universal service 

Positive  

and perceived by customers. The fact that express services form part of the postal sector has recently 
been reconfirmed by the European Court of Justice in Case C-259/16 (Confetra).  Express and courier 
services  provide  an  added  value,  clearly  distinguishable  from  the  universal  service,  for  which  postal 
users are prepared to pay a different price. Still, this does not per se exclude that express and courier 
providers may, if they fulfil the material conditions set out in the Directive, provide services within the 
scope of the universal service. 

25   See  Commission  Staff  Working  Document  accompanying  the  4th  application  report  on  the  Postal 

Services Directive, COM(2008) 844. 

26   See  Accompanying  Document  to  the  Proposal  for  a  Directive  amending  Directive  97/67/EC, 
concerning  the  full  accomplishment  of  the  internal  market  of  Community  postal  services  -  Impact 
Assessment, SEC(2006) 1291/2. 

27   See Commission Staff Working Document, SEC(2006) 1293, Accompanying document to the Report 
from  the  Commission  to  the  European  Parliament  and  the  Council  on  the  Application  of  the  Postal 
Directive, 2006. 

12 

 
 
                                                                                                                                                              
scope: no modification 
to SMEs and 
consumers’ access to 
basic products, and 
existing flexibility for 
Member States  

Universal service 
standards: no 
modification in current 
level of minimum 
harmonisation (5 
days/week collection 
and delivery frequency 
of postal items, and 
uniform tariff only 
permitted for 
consumer/single-piece 
items) 

Obliging national 
regulatory authority to 
identify the essential 
means to assess if 
access to 
infrastructure/network 
is necessary, and 
maintaining current 
rules on non-
discriminatory access  

  Citizens and SMEs can have access to basic postal products. 
  Flexibility to adapt the scope of national universal service in light 
of market changes can lead to closer alignment of prices to costs, 
and in turn of users’ needs to willingness to pay for the service. 

Negative 

  Too  much,  or  inconsistent,  specification  of  prices  and  service 
obligations may result in inefficient market intervention and the 
need for complex supervision/regulation at national level. 

Positive  

  Can contribute to fostering efficient market entry. 

Negative 

 

In  some  instances  may  be  inconsistent  with  the  principle  of 
“least market intervention” as it authorises ex-ante regulation on 
uniform  tariffs  where  the  same  would  probably  be  achieved 
through a commercial decision-making. 

Positive  

  Can ensure business and consumer protection. 
  Can allow for risks of distortion to be checked at Member State 

level. 

  Can enable transparency of access costs. 
  The  market  place  is  allowed  to  determine  the  appropriate 
competitive  model  (either  access  to  incumbent’s  network  or 
building alternative networks). 
  Flexibility can allow for zonal pricing. 

Negative 

  Downstream access tariffs may not entirely cover upstream fixed 

costs.  

  May create some incremental costs of opening up these facilities 

that will need to be shared (by users). 

 

Lower  prices  offered  by  competitors  may  result  in  substantial 
savings only to higher volume mailers. 

3. 

STATE OF PLAY 

3.1  Implementation of the Directive 

Member  States  were  required  to  transpose  the  2008  Directive  by  31  December  2010. 
Some Member States were, however, given until 31 December 2012 to fully liberalise the 
postal sector. Complete transposition across the EU was there only achieved in  January 
2013.  

13 

 
 
 
Since 2008 the Commission has initiated infringement proceedings against two Member 
States,  Belgium  and  Croatia,  for  inaccurate  transposition.  Furthermore,  infringement 
procedures  were  started  against  ten  Member  States28  for  non-communication  of 
transposition measures. All procedures were closed before reaching the Court of Justice 
of the EU as Member States either conformed or notified the transposition measures. 

Until  today  11  Member  States  have  used  the  possibility  of  derogating  from  minimum 
requirements  on  frequency  and  delivery  points.  11  Member  States  have  also  departed 
from the minimum level of requirements regarding quality of services. 

Based  on  Article  22  of  the  Directive,  the  Commission  established  the  European 
Regulators  Group  for  Postal  Services  in  201029.  This  Group  serves  as  a  body  for 
reflection, discussion and advice to the Commission in the postal services field. Its task is 
to  facilitate  consultation,  coordination  and  cooperation  among  the  independent  national 
regulatory  authorities,  and  between  the  national  regulatory  authorities  and  the 
Commission  with  a  view  to  consolidating  the  internal  market  for  postal  services  and 
ensuring the consistent application of the Directive in all Member States. 

3.2  Current trends in the postal services market 

Size of the postal services sector 

Since 2008 there has been an average yearly letter mail decline of -4.9 percent in the EU 
(See  Figure  8  in  Annex  4).  This  decline  is  widespread  and  occurring  in  almost  all 
Member States. The contraction of the economy due to the COVID-19 pandemic, where 
letter mail volumes dropped between -12 and -26 percent30 has accelerated the structural 
letter mail volume decline31. Member States with strong e-government initiatives such as, 
for example,  Denmark and Estonia have experienced  a steeper and steadier  decrease in 
letter mail volume per capita than those where the level of digitisation of the government 
is relatively lower.   

In  contrast,  parcel  delivery  services  have  been  growing  because  of  the  significant 
increase in e-commerce. The cross-border share of parcel deliveries represents almost 24 
percent  of  total  online  sales  in  Europe.  On  average,  parcel  delivery  has  grown  by  an 
estimated  9  percent32  per  year  ever  since  2008.  This  growth  notwithstanding,  cross-
border e-commerce delivery may still raise issues from a consumer perspective. Globally, 
the average growth in parcel volumes in the second quarter of 2020, during the COVID-
19 lockdown, was 43 percent. The trend has continued throughout the rest of the year. At 
the  same  time,  international  (extra  EU)  mail  fell  by  27  percent,  especially  flows  from 
China.  Before  the  pandemic,  global  online  sales  were  predicted  to  roughly  double 

28   Cyprus, the Czech Republic, Finland, Ireland, Italy, Latvia, Poland, Portugal, Romania and the United 

Kingdom. 

29   Commission Decision of 10 August 2010, OJ C217/7 of 11.08.2010. 
30 Volume change between first half-year 2019 and first half-year 2020 of eight universal service providers 
in  the  EU.  Source:  European  Regulators  Group  for  Postal  Services,  PL  II  (20)  26  Report  on  the 
consequences of Covid-19 on postal sector, pp.11-12. 

31  European  Regulators  Group  for  Postal  Services,  PL  II  (19)  37,  Report  on  core  indicators;  and  WIK 

(2021), User Needs in the Postal Sector and Evaluation of the Regulatory Framework, p.19. 

32   Commission Postal Statistics. Based on volume trend of universal service providers. 

14 

 
 
                                                      
between  2019  and  2024,  but  recent  trends  suggest  the  COVID-19  crisis  will  push  this 
timeline  forward  and  a  stronger  growth  of  intra-community  parcel  traffic  than  of 
incoming international traffic is likely.  

These two major developments are expected to  continue and intensify over the coming 
years. If the developments of the recent years continue to the same extent, the EU letter 
mail segment will lose around 12 percent of revenue and 32 percent in volume by 2025. 
At  the  same  time,  the  revenue  in  the  EU  parcel  segment  will  more  than  double  and 
volumes will increase by around 46 percent.33

Structure of the market  

The  letter  mail  segment  is  highly  concentrated  and  in  certain  countries  there  is  only 
one single letter services provider. In 2018, 15 out of 28 universal service providers had 
market  shares  above  95  percent  and  only  four  out  of  28  had  market  shares  below  80 
percent34.  

Most of the alternative postal operators are active only on the parcel and express markets. 
Many  are  growing  thanks  to  the  dynamic  competitive  market.  The  universal  service 
providers  have  much  lower  market  shares  in  the  parcel  segment  than  in  the  letter 
segment, with an average around 28 percent for the period 2014 to 2018. The dynamics 
of the letter segment is very different.  

Price developments and qualityof service 

Figure 2 Real prices of domestic parcels and letters and transit times for letters, annual  percentage 
differences 2012-2018 

Source:  EC postal statistics 

Domestic  prices  for  universal  letter  mail  have  increased  constantly  in  real  terms  since 
the major drop in volumes in connection with the financial crisis in 2007, but the largest 
increase occurred after 2014. Universal service providers adjusted their pricing strategy 
to  keep  letter  mail  revenues  stable  in  an  environment  characterised  by  an  accelerated 
volume decline. For universal service parcel delivery there was a  moderate real price 
increase  in  this  period.  More  recent  information  from  the  web  tool  on  cross-border 
parcel  prices35  covering  the  prices  for  1400  of  parcel  and  express  services  from  more 
than  378  operators  shows  a  marginal  increase  overall  for  parcels,  and  for  certain 
operators a small price decrease between 2019 and 2020. 

33   WIK (2021), page 81. 
34   WIK (2021), pp.31-36. 
35   To improve price transparency, the regulation on cross-border delivery services requires that certain 
postal operators communicate the domestic and cross-border prices for up to 15 basic parcel delivery 
products and the Commission publishes those prices on its website: 
https://ec.europa.eu/growth/sectors/postal-services/parcel-delivery/public-tariffs-cross-border_en   

15 

 
 
 
                                                      
Until 2008  service levels  for letter mail  had  improved in  terms  of domestic and cross-
border delivery and transit time. This was particularly evident in the case of cross-border 
delivery of letter mail.  The percentage of letters  delivered on time36 however started to 
drop  right  from  2008.  In  the  case  of  domestic  delivery  of  letter  mail,  the  number  of 
universal  service  providers  who  achieved  their  targets  reached  its  maximum  in  2013, 
when  targets  were  exceeded  for  priority  letters  in  most  Member  States  and  for  non-
priority  mail  in  virtually  all  Member  States37.  This  number  has  been  decreasing 
constantly since then.  

The profitability of universal service providers 

The postal business model essentially relies on delivering large volumes of small items. 
As letter mail volumes fall, the unitary cost of delivery increases. It also pushes up the 
cost of the universal service obligation, making universal service providers look for ways 
to  increase  efficiency  and  improve  customer-oriented  solutions.  They  maintain  their 
through 
labour)  costs, 
profitability  by  cutting  (mainly 
technological  innovation  (for  example  automated  sorting  systems),  and/or  increasing 
prices.  

increasing  productivity 

With  only  a  few  exceptions,  letter  mail  operations  have  been  profitable  for  universal 
service  providers  throughout  the  period  1998  to  2017,  while  profit  margins  have  on 
average  declined  since  2007/08,  with  decline  starting  even  earlier  for  some  postal 
operators.38  With  few  exceptions,  universal  service  providers  report  positive  earnings 
before  interest  and  taxes,  (EBIT)  margins  up  to  5  percent,  some  even  higher  than  10 
percent (e.g., in Belgium, Cyprus, Netherlands and Portugal) in the period 2013-2016.3940  

Employment 

As  the  postal  sector  is  very  labour-intensive,  with  rising  labour  costs  across  Europe, 
significant  restructuring  (including  job  losses  but  also  job  creation)  has  taken  place  in 
several  Member  States.  According  to  the  latest  available  data  by  Eurostat,  the  total 
employment  related  to  activities  falling  under  the  universal  service  obligation  has  been 
decreasing  since  2011,  while  the  number  of  persons  employed  for  other  postal  and 
courier  activities  has  been  increasing,  in  particular  since  2014.41  The  Eurostat  data 
suggests that the total number of persons employed in other postal and courier activities 
is almost equal to the number of persons employed for postal universal service activities.  
In  other  words,  the  job  creation  for  parcel  activities  at  other  operators  seems  to 
compensate for the job losses at universal service providers.  

As regards the quality of employment, Copenhagen Economics reports that an increase in 
new  and  more  flexible  employment  models  has  been  observed,  as  well  as  models 

36   According to the speed of delivery paid for. 
37   Commission Staff Working Document accompanying the Report from the Commission to the European 
Parliament and the Council on the application of the Postal Services Directive, p.78, SWD(2015) 207 
final. 

38 WIK (2021), pp. 23-24. 
39 WIK (2021), p. 212. 
40 Copenhagen Economics (2010), p 47. 
41 Eurostat (2021), annual detailed enterprise statistics for services 

16 

 
 
                                                      
building  on  outsourcing  (subcontracted  workers  and  self-employment),  which  are  used 
by  the  majority  of  universal  service  providers.  Second,  there  have  been  changes  in 
working conditions with the introduction of new wage structure (e.g. performance pay).42 
More detailed information is available in chapter 1.6 (Employment). 

Stakeholders  that  responded  to  the  Commission’s  consultation  have  expressed  mixed 
views  about  employment  developments  in  the  postal  sector.  While  some  argue  that 
market  opening  has  meant  employment  cuts  at  universal  service  providers  and  a 
deterioration  of  working  conditions,43  others  argue  that  it  has  also  partly  facilitated  the 
creation of new jobs by new operators.44 

Environment 

Between 2008 and 2020, a majority of universal  service providers in the EU undertook 
measures  to  limit  the  negative  environmental  impacts  of  postal  service  provision.  The 
most common measures implemented were measures to reduce the energy consumption 
of buildings, CO2 emissions of vehicles, improve the performance of the transport fleet 
by eco-driving schemes and use bio fuels.45 

The  2020  Postal  Sector  Sustainability  Report  indicates  that  carbon  efficiency  of  letter 
mail  delivery  has  decreased  over  the  last  seven  years,  albeit  unevenly,  while  the  CO2 
efficiency for parcels has increased. Given the fact that most of the reporting operators 
are  EU  universal  service  providers,  this  may  be  related  to  the  compulsory  minimum 
frequency of delivery of 5 days a week, which,  with  fewer letter mail items  to  deliver, 
may lead to inefficiencies both in terms of cost and CO2 emissions. This is a preliminary 
assumption that would merit to be looked into further and be substantiated by additional 
data.  

Table 3 Evolution of the carbon-efficiency for letter and parcel delivery between 2013 and 2019 

Delivery efficiency 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Target 
2025 

Letter  mail  (grams 
CO2 per item)  

Parcel  (grams  CO2 
per item) 

37.5 

38.1 

38.7 

38.8 

38.1 

38.9 

40.1 

30.0 

539.0 

495.0 

485.2 

474.3 

466.0 

481.9 

496.2 

431.2 

 Source, 
sector-sustainability-results-2020.pdf  

IPC, 

https://www.ipc.be/-/media/documents/public/sustainability/reports/ipc-postal-

42 Copenhagen Economics (2018), p. 151-156. 
43   https://www.uni-europa.org/2020/11/postal-trade-unions-respond-to-the-consultation-on-the-postal-

services-directive/ 

44   2020 Public consultation on the evaluation of the Postal Services Directive. See summary in Annex 2. 
45   Copenhagen  Economics  (2010),  Main  developments  in  the  postal  sector  (2008–2010);  Copenhagen 

Economics (2018). 

17 

 
 
                                                      
Several challenges increasingly affect the delivery industry46: 

 

 

 

rising parcel volumes pose a challenge on carriers regarding the carbon footprint 
of delivery; 
last-mile  delivery  contributes  to  congestion  and  local  air  pollution,  as  urban 
freight is responsible for up to 50% of urban NOx emissions;  
traffic is also the main cause of local noise pollution, which can cause a variety of 
health problems. 

Non-universal  service  providers47  have  also 
the 
environmental effects of parcel delivery due to growing e-commerce. Measures focused 
on  lowering  the  environmental  effects  of  cross-border  and  domestic  parcel  delivery, 
mainly by improving fuel and network efficiency, and by introducing alternative vehicles 
and fuels.48 

increasingly  acted 

to  reduce 

4.  METHOD 

4.1  Short description of methodology 

A number of external support studies served as input to this evaluation prepared by the 
Commission. No modelling was carried out, but information and evidence was gathered 
and assessed. The present evaluation covers the time period 2008 until 2020.  

External studies 

The Commission commissioned a number of external studies, among which:49 

  Study  on  the  Main  Developments  in  the  Postal  Sector  2013-2016  carried  out  by 
Copenhagen  Economics  (Copenhagen  Economics/CE  (2018)).  It  included  extensive 
data  collection  based  on  literature  review  and  stakeholder  consultation  by  means  of 
surveys and interviews. 

  Study on User Needs in the Postal Sector carried out by WIK Consult (WIK (2021)). 
The study looks at the changing societal and user needs related to postal services, and 
included  a  systematic  review  of  64  user  needs  surveys  in  16  Member  States.  It  also 
incorporated  the  results  of  a  dedicated  online  stakeholder  survey  that  collected  418 
responses, of which 44 from regulators, 44 from operators, and 331 from postal users. 
It also provided a first attempt to evaluate the main provisions of the directive.  

  Study  on  International  Postal  Services,  Remuneration  and  Regulation  (2011-2020) 
carried  out  by  WIK  Consult  (WIK  (2020))  focused  on  how  the  global  system  for 
terminal dues (fees that postal operators charge each other for delivery of international 
letters) were likely to affect the market for international postal services. 

46   WIK (2019) pp 273-286.  
47   These include courier, express and parcel services providers. 
48   WIK (2019), p.349. 
49   https://ec.europa.eu/growth/sectors/postal-services/studies_en 

18 

 
 
                                                      
  Study  on  the  Development  of  cross-border  e-commerce  through  parcel  delivery 
(2013-2017) carried out by WIK Consult (WIK (2019)) explored trends in the supply 
of and demand for delivery solutions in the context of cross-border e-commerce.  

These  studies  were  presented  at  conferences  where  stakeholders  could  also  discuss  the 
main findings.  

Stakeholder consultations 

The  Commission  launched  the  evaluation  on  the  Directive  with  the  publication  of  the 
roadmap  in  March  2020.  In  total,  22  comments  on  the  roadmap  were  received,  which 
were taken into account in the following steps.50 

The  Commission  also  organised  a  stakeholder  consultation,  in  accordance  with  a 
consultation  strategy  established at  the beginning of the evaluation  process.  A 16-week 
online  public  consultation  took  place  between  13  July  and  9  November  2020.  There 
were only 119 responses to the consultation. That puts a clear limitation to the conclusion 
that can be drawn from it. Evidence from the WIK (2021) online stakeholder survey has 
therefore  been  used  to  complement,  where  possible,  the  limited  information  obtained 
through  the  public  consultation.  The  contributions  and  a  factual  summary  report  of  the 
main points raised were published on the Better Regulation Portal. 

Other consultations included: 

  meetings  of  the  Postal  Directive  Committee51,  consisting  of  representatives  of 
Member  States  and  national  regulatory  authorities,  which  was  established  by  the 
Directive; The Postal Directive Committee has discussed the review of the Directive 
based on specific questions tabled by the Commission  at  six  dedicated meetings  (on 
3/12/2018, 3/6/2018, 3/6/2019, 4/12/2019, 6/6/2020 and 1/12/2020); 

  joint contributions from the Social Partners at the European Sectorial Social Dialogue 
Committee for the postal sector on 6 December 201952, and on 13 November 2020.53 

Input from the European Regulators Group for Postal Services  

The European Regulators Group for Postal Services advises and assists the Commission 
in consolidating the internal market for postal services54. It also provided useful input to 
the consultation with annual report on core indicators for monitoring the European Postal 
markets,  annual  report  on  quality  of  services,  reports  on,  among  others,  cross-
subsidisation practices and network developments.  

50   https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/11965-Report-on-the-

Application-and-Evaluation-of-the-Postal-Services-Directive 

51   The Postal Directive Committee was formed by the Directive in order to assist the Commission in its 
implementation. It is composed of representatives of Member States’ ministries and regulatory bodies 
in charge with postal services.   
52   https://www.uni-europa.org/wp-

content/uploads/2019/12/JointStatement_PostalDirectiveReview_PostSDC_20191206.pdf 

53  https://ec.europa.eu/social/main.jsp?catId=521&langId=en&agreementId=5693http 
54   See  Article  1  lit.  a  of  Commission  Decision  of  10  august  2010  establishing  the  European  Regulators 

Group for Postal Services (OJ C 217/7 of 11.8.2010) 

19 

 
 
                                                      
Other sources 

The  present  evaluation  also  incorporates  information  on  the  implementation  of  the 
Directive and trends affecting the main indicators based on the following sources: 

  the  Commission’s  postal  statistics  database  (2014  to  2019)  and  the  Universal  Postal 

Union statistical data base (2008 to 2018);  

  the national regulators’ statistical reports; 
  previous five application reports on the implementation of the Directive; 
  study  on  “Postal  services  in  the  EU”  commissioned  by  the  European  Parliament 

(TRAN Committee) in 2019.55 

4.2  Limitations and robustness of findings 

The following limitations should be taken into account: 

  the Commission’s public consultation did not produce the expected results in terms of 
participation and can therefore not be used to draw any firm conclusion, in particular 
with regard to user needs and satisfaction; 

  the  evaluation  suffers  from  a  substantial  lack  of  quantitative  data.  Postal  operators 
often  keep  their  business  related  data  confidential,  in  particular  financial  data  or 
volumes of the universal service. The evidence base underpinning WIK (2021) builds 
mainly on qualitative research: information collection and review, desk research and 
stakeholder  interaction.  There  was  no  quantitative  work  carried  out,  including  data 
gathering  and  modelling;  Moreover,  the  surveys  and  consultations  are  based  on  a 
limited number of responses;  

  the reports prepared by the European Regulators Group for Postal Services depend on 
the  replies  and  data  available  from  national  regulatory  authorities56.  These  data  are 
often partial in coverage and suffer from diverging interpretation;  

  limited information is available on the net cost of the universal service obligation; 
  disaggregation  of  data  between  parcels  and  letters  is  sometimes  artificial  as  parcels 
can be delivered under a letter format and are therefore counted as letters. Market data 
and  statistics  on  letters  and  parcels  is  often  reported  on  together  and  not  separately, 
This affects the possibility to differentiate between the two segments; 

  the data for the baseline is limited. This concerns in particular the data for cost-benefit 
analysis,  where  time  series  data  of  the  indicators  (relevant  costs  of  regulators  and 
operators) is not available; 

  there  are  generally  no  quantifications  (or  estimates  of  monetary  values)  available  as 
concerns societal benefits of the universal service. Publicly available data on the costs 
of  various  regulatory  aspects  are  used  in  this  evaluation,  and  opinions  from 
stakeholders provide quantitative, where possible, as well as qualitative input on the 
cost amounts induced by the Directive.  

The  Commission  uses  the  work  of  the  national  regulatory  authorities  for  its  own  data 
publication.  However,  a  lack  of  consistent  data  on  regular  variables  such  as  volumes, 
prices  or  employment  continues  to  prevail.  The  Directive  does  not  allow  for  the 

55 https://www.europarl.europa.eu/RegData/etudes/STUD/2019/629201/IPOL_STU(2019)629201_EN.pdf 
56   https://ec.europa.eu/growth/sectors/postal-services/ergp_en 

20 

 
 
                                                      
collection  of  a  harmonised  set  of  data.  Further  co-ordination  of  such  data  collection 
within  the  European  Regulators  Group  for  Postal  Services  would  be  desirable.  The 
Regulation  on  cross-border  parcel  delivery  services  requires  parcel  delivery  service 
providers  to  report  certain  key  information  about  their  activities  including  turnover, 
volumes,  and  staffing  to  the  national  regulatory  authority  where  they  are  established. 
There are no similar requirements for the letter market. In addition, there are usually no 
quantifications  available  as  concerns  societal  benefits.  Such  issues  can  partly  be 
addressed through more regular stakeholder surveys. 

More detailed information on the methodology and its limitations is available in Annex 
3. 

21 

 
 
 
5.  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

5.1  Effectiveness 

Q1:  Has  the  Directive  ensured  the  provision  of  a  postal  universal 
service available at all points across the EU territory, at affordable 
prices and specified quality? 

The  Directive  has  contributed  to  maintaining  the  provision  of  universal  postal  services 
nationwide  in  each  Member  State.  However,  in  recent  years,  Member  States  have 
increasingly  reduced  the  scope  of  the  universal  service  and  extended  the  scope  of 
derogations allowed by the Directive, which indicates that requirements in the Directive 
are  not  always  aligned  with  market  expectations  (i.e.,  expectations  of  users  and 
operators). While adaptations to the scope through the use of derogations may have been 
an expected outcome, the increase in the extent of derogations was not. The Directive has 
also triggered substantial improvements in quality of service (transit time) compared to 
1997, but was not effective enough to prevent a deterioration of cross-border transit time 
performance after the 2008 baseline. In this regard the Directive has only partly delivered 
on  what  it  was  expected  to  achieve,  i.e.,  a  permanent  improvement  of  cross-border 
quality of service. While in  the letter mail segment  relevant  price increases  took  place, 
the  tariff  provisions  seems  to  have  contributed  to  avoiding  even  steeper  increases, 
ensuring cost-orientation, sustainability and affordability.    

Scope of minimum universal service requirements 

The  1997  Directive  did  not  substantially  alter  the  existing  national  requirements  in 
relation  to  the  universal  service  obligation.  It  simply  harmonised  a  minimum  level  of 
universal  services  obligations  leaving  Member  States  with  the  possibility  to  regulate 
other universal services at national level (for e.g., newspapers or magazines).57 The level 
of  harmonisation  and  the  scope  of  harmonised  products  and  services  has  not  changed 
with the subsequent amendments to the 1997 Directive.  

The Directive requires that universal service obligations must evolve in  response to the 
technical,  economic and social context  and the needs of users.  A significant  number of 
Member States have used the flexibility offered by the Directive by taking into account 
the relevant factors, not only of a geographical nature58, but also those that relate to the 
changing needs of the public as a result of new electronic means of communication and 
the need to ensure the economic viability of the service59 to adjust the universal service 
obligation. This was an expected outcome stemming from the flexibility provided by the 

57   For an overview of these kind of other services see WIK (2021), p.182. Note that while newspapers are 
postal items they are not  necessarily part of the  universal  service  scope; their delivery  may also be a 
distinct Service of General Economic Interest. 

58   Note that these factors vary from one Member State to the other and within one and the same Member 

State. 

59   Without  a  sustainable  and  economically  viable  universal  service  the  realistic  possibility  of  providing 
the  universal  service  as  such  would  be  lost.  Recitals  11  and  12  of  Directive  2008/6/EC,  which 
respectively refer to ‘the fundamental objective of safeguarding the sustainable provision of a universal 
service’ and ‘long-term sustainability in the new market conditions’. 

22 

 
 
                                                      
Directive. Changing user (i.e., business and bulk mailers, individual users, consolidators, 
receivers) needs have been the starting point for any adjustment of the universal service 
by Member States. Any derogation is generally preceded by an in-depth analysis of user 
needs60  carried  out  by  national  regulatory  authorities  (and  sometimes  also  by  the 
universal  service  provider)  before  it  is  granted,  and  this  is  followed  by  a  careful 
monitoring of the implementation to ascertain that the requirements of all user groups are 
satisfied. 

The letter mail segment of the postal sector was subject to a legal monopoly until 2013, 
while  parcel  delivery  has  always  been  open  to  competition.  The  continuous  decline  in 
letter  mail  volumes  has  raised  concerns  about  what  the  universal  service  should 
comprise.  In  some  Member  States  this  has  led  to  changes  in  national  postal  legislation 
and reduced universal service obligations to reflect changing postal user needs.  

Product scope 

Basic domestic letter mail, registered mail, insured mail, basic domestic parcel post, and 
cross  border  letter  mail  and  parcels  are  generally  included  within  the  universal  service 
obligation.  However,  there  are  Member  States,  such  as  the  Czech  Republic,  Finland  or 
the Netherlands, where the scope is more limited and only single-piece mail and parcels 
are ensured as a universal service. The status of newspapers and periodicals as universal 
or  non-universal  service  remains  diverse  among  Member  States.  Compared  to  the 
baseline the level of heterogeneity in product scope of the universal service has remained 
very  similar;  as  shown  by  Copenhagen  Economics61  there  have  been  only  very  minor 
changes in relation to the products under the universal service scope in 2008; at the same 
time, there is no indication that the scope will converge more among Member States.62  

There  has  been  a  trend  in  recent  years  to  reduce  the  scope  of  services  ensured  as 
universal services. The European Regulators Group for Postal Services has reported that 
only half of Member States ensure bulk letters (that were originally supposed to be part 
of  the  universal  service63)  as  a  universal  service,  and  in  about  9  Member  States  direct 
mail  falls  outside  the  scope  of  universal  service64.  A  wider  scope  of  universal  services 
has been maintained mainly in Member States where the decline of letter mail volumes 
has been relatively low. The divergences in the scope of the universal service are to be 
expected  given 
the  country-specific  differences  regarding  broadband  coverage, 
digitalisation  and  e-government  initiatives.  There  is  no  evidence  or  complaints  that  the 
existing divergences have resulted in any significant issues with respect to the delivery of 
cross-border  letter  mail65.  This  is  also  the  conclusion  of  WIK  which  finds  that 
divergences  have  not  caused  major  problems  in  the  past.66  Expectations  in  2008  were 

60   Please see the Sub-section on “frequency of delivery and collection” for further evidence. 
61   Copenhagen Economics (2018), table 30, p. 189. 
62   Compare  the  divergences  among  the  Member  States  as  evidenced  by  the  study  WIK  (2006),  Main 

developments in the postal sector, 2004–2006, p. 44ff. 

63   Note  that  these  are  sent  by  business  users  that  dispose  of  a  certain  bargaining  power  in  quantities; 

consequently they are in principle subject to discounts. 

64   European Regulators Group for Postal Services (20) 23, Report on postal core indicators. 
65   In accordance with Article 3(7) the universal service as defined in this Article shall cover both national 

and cross-border services. 

66   WIK (2021), p. 329. 

23 

 
 
                                                      
also  that  there  would  be  a  positive  economic  impact  if  Member  States  have  the 
possibility to adapt the scope in light of market changes.  

Beyond  the  basic  universal  service,  universal  service  providers  increasingly  offer  an 
additional  range  of  services/products  that  are  further  differentiated  and  addressed  to 
specified user needs. In particular in the context of e-commerce, providers offer specific 
services/products for business senders which are commonplace in the market (e.g., track 
and  trace).67  This  development  seems  predominantly  triggered  by  fierce  competitive 
pressure  in  the  parcel  delivery  segment,  especially  in  relation  to  e-commerce  delivery 
which has significantly increased during the last five years68 in all Member States.69  

The intense and dynamic competition in the parcel delivery segment raises the question 
whether it has been necessary to keep parcel delivery in the scope of the universal service 
or  whether  postal  users  could  have  been  equally  served  at  the  same  (or  lower)  price 
without  a  universal  service  obligation.70  Available  evidence  suggests  that  the  response 
may  differ  depending  on  the  Member  State  (or  indeed  part  of  Member  State)  and 
depending  on  whether  one  is  considering  business  to  business  parcels,  business  to 
consumer parcels or consumer sent parcels. The majority of business to business parcels 
and business to consumer parcels are bulk parcels (representing the vast  majority of all 
parcels sent), while consumer sent parcels are single piece (representing only a negligible 
part of the overall parcel delivery segment).  

Available evidence suggests that the majority of businesses have had and still have many 
alternatives to the universal service provider for the provision of parcel delivery services, 
especially in recent years, and can choose from more than 10 parcel delivery operators. 71 
The average number of operators per country serving this customer segment has  almost 
doubled  compared  to  2012.72  One  study  also  suggests  that  e-commerce  shoppers  in  a 
sample  of  eight  Member  States  had  access  to  parcel  delivery  to  the  home  address 
irrespective of where they lived. Moreover, in nearly all markets the delivery prices and 
services  levels  were  the  same  irrespective  of  the  e-shopper’s  location.73  One  tentative 
conclusion  to  be  drawn  from  this  is  that  having  kept  business  to  business  parcels  and 
business to consumer parcels within the scope of the universal service may not have been 
optimal from  an effectiveness  point of view. The fact  that  many  Member States74 have 

67   In  19  Member  States  universal  service  parcels  include  tracking,  albeit  this  is  not  required  by  the 

directive and national legislation – see WIK (2019), p. 54. 

68   Global B2C e-commerce is estimated to have tripled between 2014 and 2019. Cf WIK “International 

Postal Service, Remuneration and Regulation” (2020), p. 46. 

69   The volume of e-commerce has increased by 10 percent in all Member States on average, and more in 

Member States with less developed e-commerce markets – see WIK (2019), p. 47. 

70   See also e.g., WIK (2019), p. 300: “performance of delivery markets has greatly improved in response 
to market forces, and therefore we do not see a need to establish or increase the service levels required 
for universal service by national postal legislation.” Several stakeholders doubt that there is a market 
failure  with  respect  to  parcel,  see  e.g.,  POSTEUROP  submission  to  the  public  consultation;  see  also 
Copenhagen Economics, 2019, Additional EU Mail and Parcel Regulation: What evidence to look for?, 
p. 6. 

71   E.g., Copenhagen Economics (2020), p.7.  
72   E.g., Copenhagen Economics (2020), p.57. 
73   E.g., Copenhagen Economics (2020), p.40.   
74   E.g., European Regulators Group for Postal Services PL II (20) 23, p.120. 

24 

 
 
                                                      
excluded  bulk  parcels  from  the  scope  of  the  universal  service  corroborates  this 
conclusion.   

The question whether it was necessary to keep consumer sent parcels within the universal 
service  obligation  appears  to  generate  a  different  answer.  Available  evidence  suggests 
that there have been (and still are) individual consumers in some Member States, or parts 
of  Member  States,  that  were  not  aware  (and  may  still  not  be  aware)  of  the  variety  of 
parcel  delivery  operators  available.  They  have  therefore  relied  on  the  universal  service 
provider  for  parcel  delivery.  There  are  consumers  that  relied  on  the  universal  service 
provider  out  of  convenience,  as  it  is  the  most  familiar  and  hence  the  easier,  "simple" 
option available. For all  these consumers there is a  good base to  argue that  it has been 
effective to have at least single piece parcels within the universal service obligation. This 
has also kept prices affordable as parcels that fall within the universal service obligation 
have benefitted from a VAT exemption and have been subject to price control under the 
Directive’s tariff rules. 

Available evidence has not allowed this evaluation to conclude on this topic. 

Frequency of delivery and collection  

Within  the  reference  period  all  Member  States  in  general  complied  with  the  minimum 
requirements of collection and delivery at least five days a week, bearing in mind that the 
extent of derogations in relation to delivery frequency has increased (see below). In 2008 
11  Member  States  even  had  a  six-day  frequency.75  In  2019  only  three  Member  States 
exceeded 
six-day 
collection/delivery (i.e., France, Germany and Malta).  

the  minimum  collection/delivery 

frequency  and  have  a 

The  Directive  provides  for  two  types  of  exceptions  to  the  minimum  requirement:  first, 
the  derogation  from  the  five-day  delivery  principle  for  exceptional  geographical 
circumstances and, second, one concerning the modalities of distribution, which must in 
principle take place at the home of any natural or legal person76.  

Compared to 2008, the number of Member States that have granted derogations from the 
five day delivery frequency has remained stable while the extent of derogations related to 
delivery frequency has increased during this period.  

75   Ecorys, 2008, Main developments in the postal sector (2006-2008), p. 42ff. 
76   In Sweden and Finland receivers traditionally pick up their parcels at the nearest post office or contact 
point.  In  eight  Member  States  some  exceptions  from  the  home  delivery  are  applied  (Austria,  Czech 
Republic,  Denmark,  Greece,  Hungary,  Romania,  Slovakia  and  Slovenia);  for  example,  this  concerns 
rural places in Austria where the letter box is located at the street rather than at the house. 

25 

 
 
                                                      
Table 4 Delivery/collection requirements and exceptions/derogations 

# of countries 

Countries 

Notes 

6 day delivery 2004 

6-day delivery 2019 

Exceptions/derogations 
from daily delivery (2010) 

Exceptions/derogations 
from daily delivery (2019) 

10 

3 

11 

11 

Thereof exceptions/derogations due to… 

DE, DK, EE, ES, FR, IT, LT, MT, NL, SI 

DE, FR, MT 

Also in AT for newspapers, in BG 
(only in capital) for letters 

BG, HR, EE, FR, DE, EL, IE, RO, SK, SI, SE77 

BG, DK, EE, EL, FI, FR, HR, IT, RO, SK, SE  

Mountains or island 
areas 

Population density 

Low traffic volumes 

Cost of service 

Poor infrastructure 

Extreme weather 
conditions 

9 

6 

2 

5 

2 

2 

BG, DK, EE, FI, FR, HR, EL, RO, SE 

BG, HR, IT, RO, SK, SE 

IT, RO 

RO, SK, FI, DK, IT 

BG, RO 

RO, EL 

Sources: Based  on  WIK  (2021),  European  Regulators  Group  for  Postal  Services  (20)  22  and  (11)  19, 

adapted. 

The most prominent  derogation  granted until  today  concerns Poste  Italiane. The  Italian 
Regulatory Authority  authorized an alternate delivery model for postal items within the 
scope  of  the  universal  service  setting  specific  criteria  regarding  the  areas  where  this 
model may  apply.78 This  concerned services  to  an important  part of the population  (20 
million)  in  absolute  and  relative  terms.  While  it  is  important  to  bear  in  mind  that 
operators’ needs were an important driving force behind the request for the derogation79 
the needs of users were assessed before and monitored after. According to a research in 
2014, before the derogation was approved, 74.4 percent of a representative sample for the 
Italian  population  found  the  alternate  delivery  day  model  adequate  for  their  needs80. 

77 The reasons are similar in 2010 as in 2019 and are not reported here as not to add to complexity. They 
can  be  found  in  European  Regulators  Group  for  Postal  Services  (11)  19,  Report  on  the  quality  of 
service and end-user satisfaction, p. 44. 

78   Decision  n.  395/15/CONS  of  20  July  2015,  “Authorisation  of  an  alternate  delivery  model  for  postal 
items within the scope of the universal service”. Fully implemented, the alternate delivery model affects 
up to 23.2 percent of Italy’s population. 

79   The  economic  viability  of  universal  service  is  a  very  important  factor,  since  without  a  sustainable 
universal service the realistic possibility of providing the universal service as such would be lost. See in 
particular  Recitals  11  and  12  of  Directive  2008/6/EC,  which  respectively  refer  to  ‘the  fundamental 
objective of safeguarding the sustainable provision of a universal service’ and ‘long-term sustainability 
in the new market conditions’ 

80   Customised Research & Analysis (2014), Research on the possible review of postal delivery frequency, 
p.  7;  Autorità  per  le  garanzie  nelle  comunicazioni  (2016),  The  use  of  communication  services, 
experiences  and  perspectives,  complements 
the  changes  of 
communication needs of the Italian population. 

the  other  study  and 

illustrates 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Moreover,  the  national  regulator  also  closely  monitored  the  gradual  implementation  by 
Poste Italiane81.  

Sweden is also envisaging an alternate delivery model (with reduced delivery frequency 
for  certain  postal  items  within  a  geographically  specified  area)  for  2021  which  adds  to 
models  in  Denmark  and  Finland.  The  study  carried  out  by  the  Swedish  regulatory 
authority  before  allowing  PostNord  to  introduce  its  new  delivery  model  indicated  that 
any changes in the frequency of the delivery of letters with written content would have 
rather  limited  negative  consequences.  Some  60  percent  of  both  private  individuals  and 
enterprises  do  not  think  changing  the  frequency  of  delivery  to  two  days  a  week  would 
cause  them  any  problems  at  all,  but  almost  50%  of  the  enterprises  in  rural  areas  are 
concerned about mail delays affecting their operations. It  also confirmed that reliability 
would be more important than five day delivery for businesses and authorities, and that 
for  small  businesses,  the  elderly  and  socio-economic  vulnerable  groups  it  is  important 
that  changes  are  well  communicated82.  These  cases  are  the  ones  that  present  the  most 
relevant and substantial derogations from the standard model of five-day-delivery83. 

While  the  provisions  of  the  Directive  allow  for  considerable  flexibility,  they  were 
intended  for  circumstances  deemed  exceptional.  The  ever  increasing  scope  of  and 
number of important derogations suggests that the requirements in the Directive are not 
well  aligned  in  certain  Member  States  with  market  needs  (i.e.,  that  of  users  and 
operators)  and  raises  questions  about  the  effectiveness  of  the  current  requirements  on 
frequency of delivery and collection. This is even more so taking into consideration that 
additionally  a  number  of  Member  States  such  as,  for  example,  Estonia,  Finland,  the 
Netherlands  and  Portugal  have  launched  initiatives  in  recent  years  to  start  a  discussion 
with stakeholders on the modernisation of the universal service in the light of changing 
users’ and operators’ needs.84  The vast majority of the Member States consulted via the 
Postal Directive Committee indicated the frequency of delivery as the first feature of the 
universal  service  that  should  be  more  flexible  and  allow  adaptation  to  national  needs. 
From this perspective, current practice by Member States were not expected in 2008. 

Contrary to the letter mail segment, parcel delivery frequency and options for delivery of 
postal  items  have  not  been  reduced  but  rather  evolved  and  increased  compared  to  the 
baseline. Today most universal service providers offer a number of options for delivery, 
such  as  delivery  within  a  specific  time  window,  evening  and/or  Saturday  delivery, 
innovative 
delivery  at  neighbors,  pick-up  points  or/and  parcel 
improvements  are  not  due  to  regulatory  intervention,  but  are  the  result  of  competition, 
consumer demand and expectations and the rapid increase of e-commerce.  

lockers.  These 

81   Autorità per le garanzie  nelle comunicazioni (2018), Relazione annuale  2018 sull’attività svolta e  sui 
programmi  di  lavoro,  p.  172:  „[...]  the  reporting  mechanism  made  available  to  the  mayors  has  been 
successful, as there have been a limited number of alerts (50 from 3.212 municipalities concerned).“ 
82   Post-och  Telestyrelsen,  ”Need  for  physical  postal  services  on  a  digitalised  market”  (2019),  p.9  and 

”Swedish Postal Market Report” ( 2020) p. 11. 

83   The  British  regulatory  authority  Office  of  Communications  has  recently  conducted  a  study  that 
departing  from  a  6  day  delivery  frequency  concluded  that  „[m]ost  participants  were  willing  to  have 
collection  and  delivery  of  their  post  reduced  to  5  days  a  week,  accepting  that  this  would  still  meet 
current  needs.“  – Office  of Communications (2020), United  Kingdom Postal User Needs: Qualitative 
Research Report, p.37.  

84   These processes are still ongoing. 

27 

 
 
                                                      
Density of access points 

The Directive states that postal services must be provided “at all points in the territory” 
without being explicit about how such points are to be identified. It only provides that the 
density  of  contact  points  must  take  account  of  the  needs  of  users.  This  leaves  a  wide 
margin  of discretion to Member States. Access  points are used here to  encompass both 
own post offices as well as places such as shops, petrol stations and kiosks that provide 
for the deposit and pick-up of letters and parcels. 

Compared  to  the  overall  number  of  access  points  in  2006/8  there  has  not  been  any 
fundamental change in the number of access points per inhabitants. In 2006 the number 
of postal access points in the EU was 151,821 (3.3 par 10,000 inhabitants), in 2018 the 
number was 169,026 (3.3 per 10,000 inhabitants). The increase in the number of access 
points is due to the increase in Member States and population of the EU. However, large 
disparities seem  to  exist among  Member States  as in 2018 this ratio ranged 1.19 postal 
establishments per 10,000 persons in Belgium to 12.5 in Cyprus85. 

The increased use of franchised or sub-contracted access points is  largely  a response to 
the  different  demand  for  postal  services  by  consumers  and  small  enterprises  which  are 
the main users of postal access points.  

While, over the last four  years  leading  up to  2019,  the overall number of postal  access 
points of universal service providers has remained fairly stable, access points with longer 
and  different  opening  hours  than  traditional  post  offices  are  becoming  more  relevant, 
considering  the  increasing  importance  of  the  postal  access  network  for  parcel  delivery 
services,  in  particular  pick-up  and  returns.86  The  postal  access  network  is  also  of 
particular  importance  for  e-commerce  and  parcel  delivery  services  (in  particular 
regarding pick-up and returns), which is why the European Regulators Group for Postal 
Services has also described the various improvements as regards access to postal services 
by disabled persons87 and has started monitoring the evolution of parcel lockers.  

Compared to the baseline, the users’ expectation regarding ubiquity of access for parcels 
and letter mail has remained largely the same. Moreover, from a service point of view, 
while post offices might in general offer a broader range of services than subcontractors, 
the latter offer more convenient opening hours (e.g., week-ends, evening) and a variety of 
locations (petrol stations, shopping centres)88.  

Designation of universal service provider(s) 

The  2008  amendment  provided  possible  additional  ways  of  designating  the  universal 
service provider (by way of public procurement procedures) as well as the scope for the 
provision  of  universal  services  (e.g.,  a  specific  geographic  area).  However,  these  new 
options  have  not  been  used  in  practice  by  any  Member  State  except  in  limited  cases 

85   European Regulators Group for Postal Services (20) 23, point 4.5.2. 
86   For a detailed illustration of the share of post offices operated by universal service providers, as well as 

an illustration of the wide variety of different access options available in Europe, see Annex 4. 

87   European  Regulators  Group  for  Postal  Services  (20)  22,  Report  on  quality  of  service,  consumer 

protection and complaint handling, p. 34. 

88 Furthermore, in the reference period parcel lockers have been rolled out systematically (they are relevant 

not only for delivery but also for posting items, including the important segment of returns).  

28 

 
 
                                                      
where  a  public  procurement  procedure  took  place  for  the  distribution  of  newspapers89. 
Member  States  have  continued  to  designate  (by  law  or  administrative  act)  a  single 
provider for the  entire national territory.90 While the basic decision to require universal 
provision  for  the  entirety  of  a  territory  is  for  Member  States  to  take,  it  may  also  be 
motivated  by  the  desire  to  ensure  uniformity  of  services  and  avoid  interconnection 
issues91.  There  is  no  sufficient  evidence  available  to  allow  for  a  proper  assessment  of 
why  the  public  procurement  procedure  has  not  been  used  by  Member  States,  either  to 
procure services for the entire territory of a Member State or for parts of it. This merits 
further consideration as it cannot be excluded that greater recourse to public procurement 
procedures could have contributed to increasing competition. The assessment also raises 
a  question  whether  it  would  have  been  more  effective  to  require  that  Member  States 
analyse  whether  the  designation  for  the  entirety  of  the  national  territory  is  needed, 
appropriate  and  respects  the  principle  of  least  market  distortion  prior  to  making  any 
decisions on designation and the scope of designation. 

Quality of service regulation (transit time) 

Regarding cross-border letter mail services, a majority of Member States set targets for 
monitoring cross-border transit times following the targets set by the Directive.  

After  2008,  the  situation  concerning  cross-border  transit  time  has  however  been 
continuously deteriorating. According to WIK92, the deterioration of transit-time quality 
can be explained by several  reasons, such as the effect of the financial crisis  2008 that 
reduced letter mail volume or the switch to electronic communication. These exogenous 
factors  were  stronger  than  the  incentives  by  the  Directive  and  the  obligations/benefits 
under  different  international  mail  agreements  as  the  volume  decline  reduced  the 
economies  of  scale  and  scope.  This  negative  evolution  of  volumes  has  had  various 
effects,  such  as  finding  less  costly  ways  of  operating  (for  example  by  reducing  night-
shifts  and  using  ground  transport  instead  of  flights)  which  in  turn  have  led  to  lower 
transit time performance as evidenced in Figure 3 below. It illustrates how quality levels 
of  cross-border  letter  mail  increased  following  the  adoption  of  the  Directive  only  to 
diminish considerably as of 2008. 

89   In  cases  where  newspapers  were  part  of  the  universal  service  as  well  as  in  cases  where  they  were 

considered a distinct Service of General Economic Interest. 

90   That  Member  States  may  require  that  the  universal  service  be  provided  throughout  the  whole  of  the 

national territory is explicitly stated in Recital 23 of the 2008 Directive. 

91   It should be born in mind that the competence for postal services always falls into the competence of 

the federal authorities even in Member States with the widest decentralisation of competences.  

92   WIK (2021), p. 228. 

29 

 
 
 
 
 
                                                      
Figure 3 Delivery of intra-EU cross-border mail (percentage of items of the fastest standard category 
delivered 3 days after posting – EU target is 85 percent): 

Period of volume growth 
Period of volume growth 
Period of volume growth 
Period of volume growth 

Volcanic 
Volcanic 
Volcanic 
Volcanic 
eruption 
eruption 
eruption 
eruption 
in IS 
in IS 
in IS 
in IS 

Period of volume declines 
Period of volume declines 
Period of volume declines 
Period of volume declines 

Source:  WIK (2021), based on Copenhagen Economics (2018), IPC, UNEX CEN module 2018 results 

In  any  event,  the  actions  taken  by  universal  service  providers  and  Member  States  in 
response  to  decreasing  letter  volumes  raise  doubts  regarding  the  effectiveness  of  the 
current  high quality  standards  for intra Community cross-border mail.  It  seems  that for 
quite  some  while,  the  fastest  standard  category  has  not  been  aligned  to  user  needs  and 
market context.  

time  performance.  This  has  contributed 

Regarding  domestic  letter  mail,  the  Directive  only  requires  Member  States  to  set 
targets for the domestic transit time and to monitor, independently measure and publish 
transit 
the 
transparency on the quality of service in  national  postal  markets creating  incentives for 
universal  service  operators  to  improve  their  quality  of  domestic  services.  Domestic 
quality  targets  set  by  Member  States  have  been  largely  met  by  the  universal  service 
providers and stayed on a similar level since 200993 (between 80 to 9594 percent for D+1 
delivery,  i.e.,  a  very  high  target  to  achieve)  with  variations  among  Member  States95. 
Since 2013, the  number of  universal  service providers  that achieved their  targets  in  the 

improving  significantly 

to 

93   The  first  data  available  in  the  European  Regulators  Group  for  Postal  Services  (11)  19  Report  on  the 
quality of  service  and end-user  satisfaction do not indicate an average and relate only to D+1,  which 
hinders a direct comparison. However, in general the D+1 figures  were around 90 percent  with some 
strong  upwards  deviations  (e.g.,  Austria  with  95.39  percent)  and  downwards  (Romania  with  52.60 
percent, Poland 53.40 percent). 

94   WIK (2021), figure 18, p. 27. In the  EU Member States 1997 the domestic transit target remained at 
around 90 percent for D+1; in the Member States acceding after 2004 the domestic transit time targets 
remained at around 84 percent for D+1. 

95   In general the quality performance is highest in the Member States that acceded the EU before 2004. 

30 

83,585,690,792,592,093,593,793,793,194,294,194,693,791,793,093,192,590,689,083,279,578,775808590951997199819992000200120022003200420052006200720082009201020112012201320142015201620172018% 
 
 
 
 
 
 
                                                      
fastest  standard  category  has  diminished,  but  remains  at  a  still  high  level96,97).  The 
reasons for the decrease in the last years are the same as discussed for cross-border letter 
mail, the continuing volume decrease and progressive change in users’ needs.  

Although most national regulatory authorities publish monitoring results, not all of them 
are  in  a  position  to  sanction  the  universal  service  providers  if  quality  targets  are  not 
achieved98.  However,  the  Directive  has  not  been  fully  effective  in  ensuring  consistent 
high-quality  service  levels  for  domestic  letter  mail.  Effective  sanction  powers  for 
regulators may be one possible solution to address lack of quality compliance. 

Complaint procedures 

Information  on  complaints  issues  in  2008  is  limited  and  cannot  be  compared  with  the 
analysis  the  European  Regulators  Group  for  Postal  Services99  undertakes  today. 
According  to  a  2008  study  undertaken  by  Ecorys100  postal  users  were  fairly  negative 
about the processing of complaints by universal service providers.   

In its 2019 Report101 on complaint handling, the European Regulators Group for Postal 
Services confirmed that national regulatory authorities are now in most cases competent 
to handle (external) complaints procedures. Furthermore, the majority of Member States 
had  requirements  in  place  for  providers  to  publish  information  regarding  complaint 
procedures, compensation schemes and dispute resolution. In recent years, the number of 
Member  States  where, 
in  addition,  alternative  (out-of-court)  dispute  resolution 
mechanisms  are  available  to  consumers,  has  continuously  been  increasing  (now  in  25 
Member States). The European Regulators Group for Postal Services has also devised a 
quality indicator based on the publication of the number of complaints received and the 
number  of  resolved/unresolved  complaints  (both  for  letters  and  parcels)102.  There  have 
been  relevant  improvements  in  relation  to  the  situation  in  2008  (when  the  complaint 
procedures  were  strengthened  in  the  Directive),  particularly  regarding  monitoring  and 
transparency  of  such  complaints.  However,  there  are  still  certain  Member  States  where 
measuring  of  complaints  and  publishing  complaints  is  not  carried  out.  Complaint 
procedures  can  therefore  be  said  to  only  have  been  partially  effective  throughout  the 
reference period.  

While  the  overall  number  of  consumers  that  responded  to  the  Commission’s  public 
consultation was low, the majority are of the view that the complaint handling procedure 
of the provider was not at all or only to some extent easy to find and simple to file, and 

96   According  to  European  Regulators  Group  for  Postal  Services  (20)  22,  p.  18  the  results  of  2019  are: 

D+1: 85,20 percent; D+2:90,40 percent and D+3: 96,95 percent.. 

97  See  Annex  4  Table  11  for  the  achievement  of  domestic  transit  time  targets  by  universal  service 

providers. 

98   WIK (2021) explains that this may be due to the fact that in light of pressure on costs and profitability, 
the  national  regulatory  authorities  may  not  be  strong  enough  to  enforce  compliance  with  the  quality 
targets.  

99   Since  2011  the  European  Regulators  Group  for  Postal  Services  is  regularly  reviewing  complaint 

handling by universal service providers. 

100  Ecorys (2008). 
101  European  Regulators  Group  for  Postal  Services  (19)  35,  Report  on  the  quality  of  service,  consumer 

protection and complaint handling 2018: An analysis of trends. 

31 

 
 
                                                      
 
 
almost  all  of  the  ones  who  responded  state  that  it  is  very  much  free  of  charge  or 
inexpensive but many state that the procedure was not at all effective in addressing the 
matter and not at all fast. Only a third of the regulators that responded to WIK’s online 
survey fully agree that the Directive has increased consumer protection in their country, 
and only 15 percent of the operators completely agree (47 percent of regulators and 54 
percent of the universal service providers partly agree)103. 

Application  of  tariff  principles  for  universal  services:  affordability,  cost  orientation, 
transparency and non-discrimination. 

The definition and application of the cost orientation principle is left to Member States. 
Different approaches have been followed by referring either to individual tariffs, and/or 
services, or the full scope of universal service or a specific selection of products (i.e., a 
product basket).  

The principle of cost orientation for universal service tariffs was also meant to limit price 
increases. As illustrated in Annex 4 (1.4 Prices), retail letter mail prices104 in the EU have 
increased annually by 2.7 percent on average in real terms between 2008 and 2019. The 
20 gram letter of the fastest standard category used in this comparison is an item that is 
often  used  by  individual  users  and  hence  representative  for  the  development  of  prices. 
The  role  played  by  the  application  of  the  cost-orientation  principle  in  limiting  price 
increase is difficult to demonstrate given the absence of a counterfactual scenario where 
an uncontrolled monopoly would set its prices freely or where universal service providers 
would operate in a competitive environment. However, this principle has contributed to 
keeping  price  levels  limited  to  the  level  of  cost  increases.  This  is  confirmed  by  recent 
decisions  of  regulators  to  reject  price  increases  proposed  by  the  universal  service 
providers105. 

Furthermore, the application of the cost-orientation principle to the wholesale tariff that 
providers  pay  one-another  for  the  delivery  of  cross-border  items  cannot  effectively  be 
made  as  the  provisions  in  the  current  Directive  do  not  provide  the  Commission  and 
national  regulatory  authorities  with  any  oversight  instruments  to  verify  the  tariffs 
established under bilateral and multilateral agreements. Given that the volumes of cross-
border e-commerce deliveries continue to rise this seems all the more important. 

The principle of  transparency,  has been  effectively  applied  across the  EU since 2008. 
The  majority  of  Member  States  require  universal  service  providers  to  publish  tariffs 
online, while the German de facto universal service provider reports tariffs to the national 
regulatory  authority.  In  practice  though  it  appears  that  all  universal  service  providers 
(including Germany) publish at least single-piece tariffs online. 

103 WIK (2021), p.246. 
104  This  relates  to  the  20g  letter  of  the  fastest  standard  category  which  is  an  item  that  is  often  used  by 

105  National 

regulatory  authorities 

individual users and hence representative for the development of prices. 
Institute 

for  Postal  Services  and 
Telecommunications  (BIPT),  in  2017,  and  the  Portuguese  National  Authority  for  Communications 
(ANACOM), in 2020, rejected the proposed price increases on the grounds that the “reasonable profit” 
envisaged by the operator was exceeding a margin allowed.  

the  Belgian 

such  as 

32 

 
 
                                                      
Finally,  the  principle  of  non-discrimination  implies  that  users  who  post  under  similar 
conditions  cannot  be  treated  differently  with  respect  to  tariffs  or  other  associated 
conditions106.  This  means  in  practice  that  discounts  are  subject  to  publications  and 
operators have done so. 

National regulatory authorities ensure that the affordability requirement is respected by 
applying  a  price  regulation  mechanism107.  This  can  take  the  form  of  ex-ante  price 
approval or ex-ante price cap regulation (i.e., setting a maximum for prices, taking into 
account several factors such as costs, inflation and efficiency gains). Notwithstanding the 
limitations  of  the  cost  orientation  principle  in  the  current  market  context,  it  seems  that 
expenses related to universal postal services only  constitute a negligible part of today’s 
household  expenses.  As  today,  less  than  6  percent  of  all  letter  mail  is  generated  by 
individual  users108,  it  can  thus  be  assumed  that  from  the  average  number  of  letters  per 
capita of 108109 (ranging from 306 in Finland to five in Bulgaria) only approximately 7 
letters on average will be originating from individual users.  

While there is no comprehensive study over time how the expenses for postal items have 
developed, every five years the German statistical office110 assesses expenses of private 
households  in  Germany.  In  2008,  they  were  EUR  5.52  for  letters  and  parcels,  in  2013 
they were EUR 4.79 EUR and in 2018 they were EUR 4.44111. This would indicate that 
over time the share of postal expenditure in overall household expenditure is very minor, 
and that tariffs of the universal service have remained affordable compared to 2008.  

The results of the German assessment can also be applied mutatis mutandis to the other 
Member States. Furthermore, on average the corresponding time that an industrial worker 
needs  to  work  to  buy  a  standard  letter  is  3.66  minutes  in  the  EU  (ranging  from  1.33 
minutes in Malta to 8.37 minutes in Italy).112 The assessment of the affordability criteria 
for  parcels  will  depend  on  the  number  of  parcel  items  sent  (most  items  are  again 
originating  with  business  senders,  particularly  in  e-commerce)  as  well  as  household 
income.  Given  the  substantially  higher  tariffs  of  parcels  these  might  not  always  be 
affordable  for  everybody113.  As  far  as  business,  including  small  and  medium  sized 
entities  are  concerned,  they  generally  benefit  from  discounts  and  in  many  cases  from 

106  This  principle  has  been  defined  in  several  judgements  of  the  CJEU.  See  e.g.,  C-287/06  to  C-292/06 
(Vedat  Deniz);  andC-340/13  (bpost  per  sender).  WIK  reports  that  as  of  2015  most  of  the  national 
regulatory  authorities  define  non-discrimination  as  a  requirement  that  tariffs  and  applicable  discounts 
should be offered on the same basis to all postal users. 

107  European  Regulators  Group  for  Postal  Services  (14)  22,  Report  on  tariff  regulation  in  a  context  of 

declining volumes, p. 30. 

108  According to the International Post Cooperation (2019) the average volume send by individual senders 
is  5.8  percent,  the  one  send  by  government  is  10.5  percent  and  the  one  send  by  businesses  is  83.7 
percent, see figure 2.10; In 2006 it had been established that more than 87.5 percent of letter post items 
(EU  wide)  are  sent  by  businesses  and  organisations  rather  than  individuals  –  Report  from  the 
Commission  to  the  Council  and  the  European  Parliament  on  the  application  of  the  Postal  Directive 
(Directive 97/67/EC as amended by Directive 2002/39/EC, COM(2006) 595 final, p.6. 

109  European Regulators Group for Postal Services (20) 23, figure 32. 
110  Statistisches Bundesamt GZ 184424/672089. 
111  ISTAT  data  give  similar,  even  lower,  figures  for  the  household  spending  (including  express  and 

courier): from Euro 4,26 (2010) it decreased to Euro 2,10 (2014). 

112  Deutsche Post (2019), Briefpreise in Europa, p14/15. 
113  Regulation  (EU)  2018/644  has  established  a  dedicated  assessment  procedures  to  address  particularly 

high tariffs of parcels.  

33 

 
 
                                                      
individually  negotiated  tariffs  that  are  much  lower  than  single  piece  prices.  Moreover, 
individually negotiated tariffs do not fall under the universal service obligations relating 
to pricing principles. 

Taking the above  elements  into account  it can be  said that in  general  the Directive has 
been  effective  in  ensuring  the  provision  of  affordable  universal  services.  This  is 
confirmed by the majority of providers and regulators surveyed by WIK: 82 percent and 
89  percent  of  them  respectively  consider  that  overall  the  Directive  has  effectively 
ensured the universal services. The Postal Directive Committee also confirmed recently 
that the objectives of the Directive in relation to the universal service had been achieved. 
Most  Member  States  however  argue  for  the  need  to  adjust  the  universal  service  and  in 
particular  to  give  more  flexibility  to  Member  States  in  view  of  the  changed  user  needs 
and  to  need  to  keep  the  universal  service  sustainable.  In  the  Commission’s  public 
consultation 77 percent of all respondents agree completely or partially that the Directive 
has ensured the universal service to all citizens across the territory.  

Cross-subsidisation 

Cross-subsidisation  occurs  when  high  prices  from  one  set  of  services  allows  a  postal 
operator  to  make  sufficient  profits  to  set  low  prices  on  another  set  of  services.  Not  all 
forms of cross-subsidisation are considered harmful from a regulatory point of view. For 
example, uniform prices for universal postal services cross-subsidises services in remote 
and rural areas using the higher profits generated from the services in densely populated 
and metropolitan areas.  Moreover, revenues from non-universal services can be used to 
finance universal services. Harmful cross-subsidisation may occur when a postal operator 
charges  excessive  prices  in  market  segments  where  it  has  market  power,  and  uses  the 
revenues  it  generates  from  such  prices  to  engage  in  predatory  pricing  in  other  market 
segments (i.e., revenues from the universal service are used in the non-universal service 
market segments). 

Before the full opening of the postal services market, cross-subsidisation was allowed as 
a  source  of  financing  the  universal  service.  As  the  2008  amendment  was  motivated  by 
fully  opening  the  postal  service  sector  to  competition,  the  Directive  strengthened  and 
clarified  the  requirement  that  universal  service  prices  shall  be  cost-oriented  (provisions 
on  tariff  principles)  and  adapted  the  provision  on  the  transparency  of  accounts  (cost 
allocation) to prevent harmful cross-subsidisation from taking place. This also provided 
national regulatory authorities with the appropriate tools to monitor for and detect such 
cross-subsidisation. Most national authorities also have such tools through national law, 
and in most Member States harmful cross-subsidisation is considered illegitimate.  

While national regulatory authorities use various tools in practice to monitor, detect and 
prevent  harmful  cross-subsidisation,  in  response  to  a  survey  carried  about  by  the 
European Regulators Group for Postal Services in 2019, it emerged that among the tools 
used  the  application  of  the  cost  allocation  principles,  and  prices  through  the  tariff 
principles are the most important ones.  

When found to be harmful, national regulatory authorities have powers to address cross-
subsidies (e.g., imposing modifications, or penalties or price changes). 

34 

 
 
In  2019  only  five  of  the  national  regulatory  authorities  surveyed  by  the  European 
Regulators Group for Postal Services, considered that there was a need to regulate further 
with  regard  to  preventing  harmful  cross-subsidisation114.  Possible  additional  tools 
comprised:  monitoring  system  especially  for  ex-post  regulated  services,  prohibition  of 
cross-subsidisation  in  regulation,  more  competences  in  price  control  and  single  piece 
tariff  regulation.  Some  raised  the  concern  that  given  that  competition  in  the  letter  mail 
segment is generally declining and prices increasing, the risk of using pricing strategies 
to skim the letter mail segment and cross-subsidisation should still be a priority concern. 

In  the  last  ten  years,  a  few  national  regulatory  authorities  have  conducted  ex-post 
investigations into specific cases of cross-subsidisation.  

Q2:   Has  the  Directive  contributed  to  the  achievement  of  an  internal 
market  for  domestic  and  cross-border  postal  services?  Has  the 
Directive  stimulated  fair  and  effective  competition  in  the  internal 
market for postal services? 

Contrary to the expectations underlying the full market opening that took place in 2008, 
the Directive has  only contributed marginally to the achievement of an internal  market 
and  stimulating  effective  competition  in  postal  services.  Competition  in  the  letter  mail 
segment has remained very limited and the incumbent universal service postal operators 
have  kept  their  strong  market  position.  The  most  important  reasons  for  the  lack  of 
competition  appear  to  be  high  entry  costs,  the  need  for  substantial  economies  of  scale 
and scope and strong volume declines that do not stimulate market entry. In addition to 
these factors, Member States rely on very different models regarding access to the postal 
network, and there also seems to be only limited transparency as far as access conditions 
are concerned. The Directive does not contain provisions regarding the transparency of 
access conditions and it also does not provide national regulatory authorities with tools 
allowing them to set terms for access to the network thereby providing for the possibility 
to introduce ex ante competition. 

As the parcel segment was already fully open to competition in 2008, the description of 
the  effects  of  the  Directive  in  the  following  section  refers  to  the  (formerly  reserved115) 
letter mail segment. 

The conditions governing the provision of universal postal services were harmonised at a 
minimum level so that postal operators would be able to operate in all Member States to 
provide all postal services (i.e., not just the already liberalised parcel services but also the 
letter mail services) under conditions that are similar.   

In 2008 a few Member States had already opened the letter mail segment using different 
approaches. For example, Sweden had opened up parts of its letter mail market in 1993 
and  Germany  fully  opened  its  letter  mail  market  in  2008.  Estonia,  the  Netherlands  and 
the  United  Kingdom  accomplished  full  market  opening  before  the  2011  deadline 
established by the Directive. By 2013 all Member States had fully opened the letter mail 

114 European Regulators Group for Postal Services PL II (19) 40, Report on cross-subsidization practices; 
115  Note that already at the time the universal service obligation was wider than the reserved area. 

35 

 
 
                                                      
segment.  From  a  purely  legal  perspective,  the  minimum  conditions  for  establishing  an 
internal market were in place and were implemented by Member States. 

However, it is clear that full market opening did not result in effective competition in the 
EU  letter  mail  segment.  With  very  few  exceptions116  the  universal  service  incumbents 
have  increased  or  maintained  their  position  across  national  letter  mail  segments.  In 
certain Member States, the universal service provider is de facto the only operator in this 
segment such as in Ireland, Finland, the United Kingdom and Cyprus. In other Member 
States  the  universal  service  provider  has  a  market  share  ranging  from  95  to  99  percent 
(Austria,  Belgium,  Denmark,  Hungary,  Lithuania,  Portugal,  Latvia,  Malta,  Poland  and 
Slovakia).117  In  Italy118 and the Netherlands the takeover of competitors was authorised 
in  2020  and  as  a  result  the  universal  service  providers  now  holds  shares  equivalent  to 
around 95 to 100 percent. Overall market shares have remained relatively constant over 
the period 1998 to 2018. 

In Member States  where the liberalisation of letter mail  markets  happened in  a time of 
increasing  letter  mail  volumes  (i.e.,  shortly  before  the  financial  crisis  of  2008), 
competitive entry materialised119. In this regard, the price level also played an important 
role:  in  Germany  the  price  level  was  relatively  high  at  the  time  of  market  opening  in 
2008 and this had at the time allowed competitors to offer attractive prices. Other factors 
that have offered competitors opportunities to compete include the low quality of postal 
services of the universal service provider120. These were very specific market conditions 
that created opportunities to enter the postal services market.  

Where some form of competition on the letter mail segment has occurred over the last 12 
years, it has taken mainly the form of access competition whereby alternative operators 
collect  postal  items  from  senders  and  insert  them  in  the  universal  service  provider’s 
network for delivery,  and end-to-end competition where letters  are collected, processed 
and delivered directly to the recipient in direct competition with the incumbent operator 
without the necessity to use the incumbent's network, or access competition in addition to 
end-to-end competition.  

The requirement in the Directive to give all postal operators access to “elements of postal 
infrastructure” has  only  been complied with  by  18 Member States.  In only 16  Member 
States  competitors  actually  rely  on  the  possibility  to  use  the  incumbent’s  network.  In 

116  Based on the information provided by WIK (2021) at figure 30, Romania is the most notable exception 
where  the  universal  service  providers  has  the  lowest  market  share  in  the  EU  (61  percent  only).  It  is 
important to note however that the market share of the universal service provider relates to the scope of 
universal services which does not include bulk mail which typically accounts for the majority of postal 
volumes. It  is reasonable to expect that the universal  service provider’s share  would be  much  high if 
total letter mail market was taking into account. Reasons for the low market share can be found in the 
very low quality of services. Until today the Romanian universal service provider has not been able to 
achieve its service quality targets. 

117  WIK (2021), p. 34, table 8.  
118  In Italy the competition authority concluded that the merger (between Nexive and Poste Italiane) will 
still  lead  to  a  market  structure  characterised  by  the  presence  of  a  single  end-to-end  infrastructure 
network throughout Italy. - Provvedimento n. 28497, C12333 - POSTE ITALIANE/NEXIVE GROUP 
of 22 December 2020. 

119  European Regulators Group for Postal Services (13) 38, Report on end-to-end competition and access 

in European postal markets; Copenhagen Economics (2018). 

120  E.g., in Poland, Croatia, Greece and Romania.  

36 

 
 
                                                      
most  Member  States  where  network  access  exists,  it  is  interpreted  as  requiring  the 
incumbent  to  offer  bulk  mail  tariffs  to  bulk  mailers,  competitors  or  intermediaries  in  a 
transparent  and  non-discriminatory  way.  This  has  amongst  others  resulted  in  a  certain 
specialisation in the postal market in that it has  opened up possibilities for providers to 
specialise in specific mail preparation activities (such as pre-sorting of postal items and 
consolidation  of  postal  items  from  different  senders).  National  experiences  have  been 
mixed  and  in  the  most  prominent  case  of  imposed  access  regulation  by  the  national 
regulatory  authority  (namely  the  United  Kingdom121)  end-to-end  competition  did  not, 
even after a long period of such regulation, materialise at substantial levels. 

Even  if  there  are  clear  limitations  to  the  comparison  between  the  postal  sector  and  the 
telecommunications  sector,  as  telecommunications  are  largely  technology  based  while 
much  of  the  postal  business  (letters)  relies  heavily  on  staff  and  offers  very  few 
opportunities  for  the  development  of  new  types  products  and  services,  the  one  lesson 
from the telecommunication sector that appears directly relevant for the postal sector is 
that clear and transparent access provisions arguably contributed to competitive entry.122 
There may be a base to argue that increased transparency on access and procedural rules 
in this regard might have the potential to constitute a  non-invasive and pro-competition 
instrument.  

The  Directive  currently  does  not  provide  national  regulatory  authorities  with  tools 
allowing them to set terms for access to the network thereby providing for the possibility 
to introduce ex ante competition. The Directive also does not provide them with the tools 
to  handle  dispute  resolution  for  situations  when  commercial  negotiations  break  down 
between  access  seekers  and  the  universal  service  provider.  To  the  extent  national 
regulators  have  such  tools  (i.e.,  in  Germany  and  the  Netherlands),  this  depends  on 
national  postal  legislation  and  on  the  type  of  responsibility  granted  to  each  regulatory 
authority at domestic level.  

In  its  Opinion  on  the  review  of  the  regulatory  framework  for  postal  services,  the 
European Group of Regulators for Postal Services is strongly advocating that a continued 
focus  on  promoting  competition  in  the  letter  mail  market  is  relevant  and  that  national 
regulatory  authorities  should  have  the  powers  to  intervene  ex-ante  in  case  of  actual  or 
potential  competition  problems.  This  entails  sufficient  powers  to  define,  monitor  and 
analyse markets and, in particular, the competence to impose regulatory obligations such 
as  access  to  the  network  and  its  components.  In  a  2020  Report  on  the  suitability  of 
regulatory  tools  to  promote  competition,  the  European  Group  of  Regulators  for  Postal 
Services  also  analysed  29  different  regulatory  tools  used  to  promote  competition  in 
various different industries and sectors (including the postal sector) to see what national 
postal  regulators  thought  could  be  effective  for  promoting  competition.  The  Report 
concluded  that  most  of  the  known  and  common  regulatory  tools  such  as  access 
obligation,  price  regulation,  non-discrimination  and  transparency  are  still  perceived  as 

121  It appears that in this case the access conditions were so favourable that they did not stimulate end-to-

end competition. 

122  Postal  and  electronic  communications  regulators  are  also  of  the  opinion  that  experiences  in  the 

telecommunications sector cannot be simply transposed to the postal sector.    

37 

 
 
                                                      
suitable and effective tools to promote competition in the postal sector, even considering 
the transitioning postal market.123  

At the same time it should be recognised that in a period characterised by digitisation and 
declining letter mail volumes, it is becoming more difficult for smaller rivals to enter on 
a  sustainable  basis124.  Universal  service  providers  have  a  long  term  experience,  may 
enjoy  market  power,  well-structured  (adaptable)  networks  and  are  often  equipped  with 
higher bargaining power and in certain circumstances the ability to set strategic prices for 
non-universal services. Very few competing operators can maintain a market presence in 
this situation.  

Regarding  access  to  international  postal  networks,  a  recent  report  of  the  European 
Regulators Group for Postal Services  125 on interconnection models and access illustrate 
that in a cross-border context there seems to exist a plurality of options available to postal 
operators to access international postal networks (e.g., direct access, bilateral/multilateral 
agreements  etc.).  This  suggests  that  the  current  provisions  of  the  Directive  do  not 
constitute a barrier to cross-border competition even though it does not actively promote 
competition. 

In  response  to  the  Commission’s  public  consultation,  the  vast  majority  of  regulators 
along  with  the  majority  of  associations  representing  non-universal  service  postal 
operators stated that there is no or insufficient competition in the single piece letter mail 
segment. In contrast, around half of the universal service providers that responded to the 
public  consultation  are  of  the  opinion  that  there  is  significant  competition  in  the  single 
piece letter mail segment.  

Q3:   Has the Directive led to an expected level of harmonised regulation 

of postal services across the European Union? 

The  Directive  is  based  on  minimum  harmonisation  and  is  principle-based  rather  than 
relying  on  fully  harmonising  rules.  Differences  in  domestic  implementation  were  thus 
inevitable  and  expected.  The  transposition  and  application  of  the  Directive  since  2008 
have  shown  that  these  divergences  have  not  had  a  major  disruptive  effect  on  the 
effectiveness of the Directive. While there is a question whether current definitions have 
been  effective  considering  market  changes,  there  is  no  clear  evidence  that  any  lack  of 
clarity  or  that  inconsistencies  among  Member  States  have  caused  any  relevant  internal 
market  problems.  National  regulatory  authorities  have  contributed  to  better  and  more 

123  European Regulators Group for Postal Services (20) 25, Report on the suitability of regulatory tools to 

promote competition. 

124  According  to  an  analysis  undertaken  by  the  Swedish  postal  regulator  Post-  och  Telestyrelsen  there  is 
evidence  that  even  in  times  of  growing  letter  segments  competing  postal  operators  have  struggled  to 
survive (NB the postal market was fully liberalised in Sweden already in 1993) Post- och Telestyrelsen 
(2008), Service and Competition, p. 16: “Since 1993, the growth in large parts of the bulk mail segment 
has  been  characterised  by  tough  competition  between  Posten  AB  and,  in  particular,  CityMail.  This 
competition  is  largely  the  result  of  pricing  and  PTS  views  it  as  possible  that  competition  has  led  to 
price  levels  that  occasionally  result  in  negative  operating  margins  for  operators.  For  example,  2004 
was the first year ever when CityMail showed a positive full year result”. 

125  European  Regulators  Group  for Postal  Services  PL  II  (20) 28,  Report on  interconnection  models  and 

access to international postal network. 

38 

 
 
                                                      
coherent oversight of the postal services markets. It appears that the benefits of greater 
harmonization in the implementation of technical standards has not been fully reached. 

Definitions 

Definitions  contribute  to  harmonised  concepts.  The  main  definitions  remain  unchanged 
since  the  adoption  of  the  1997  Directive.  A  recent  report  of  the  European  Regulators 
Group for Postal Services126 questions if some of the definitions are still effective in the 
context of a changing postal market127. 

The Directive – contrary to the Parcel Regulation128 – does not contain any upper weight 
limit that allows distinguishing postal items from items falling under the freight transport 
and  logistics  sector.  This  lack  of  an  upper  weight  limit  has  resulted  in  divergent 
delimitations  of  the  sector  and  in  this  regard  not  to  a  harmonised  and  effective  sector 
definition  (in  particular  vis-a-vis  the  logistics  sector).  The  European  Regulators  Group 
for  Postal  Services  has  indicated  it  is  desirable  to  have  a  clear-cut  criterion  separating 
these two sectors. However, while this may be seen as not fully consistent with the Parcel 
Regulation,  it  has  not  resulted  in  problems  from  the  perspective  of  postal  service 
providers and stakeholders129.  

Also  as  regards  other  definitions  such  as,  for  example,  “postal  item,”  “item  of 
correspondence,”  “registered  item,”  “insured  item,”  “cross-border  mail,”  “universal 
service provider,” “terminal dues,” “sender” and “user”) no stakeholders in the public 
consultation  have  indicated  that  the  definitions  have  not  been  effective  and  successful. 
There is no clear evidence that any lack of clarity has caused any relevant internal market 
problems or barriers to entry for postal service providers. The absence of a weight limit 
in particular seem to have provided Member States with desired flexibility in determining 
the scope of their own postal services regulation. 

Harmonising technical standards 

The  Directive  entrusts  the  European  Committee  for  Standardisation  with  the  task  of 
drawing up technical standards to be applied in the postal sector based on standardisation 
requests  made  by  the  Commission.  Harmonising  certain  technical  standards  such  as 
standards  on  addressing  or  size  of  letter  boxes  were  clearly  needed  to  ensure 
interoperability and facilitate cross-border traffic mail130. 

126  European Regulators Group for Postal Services (20) 7, Report on postal definitions. 
127  This  concerns  particularly  the:  (a)  delimitation  of  the  postal  sector  with  the  transport/logistics  sector 
(i.e.,  the  possible  need  to  establish  a  upper  weight  limit  on  the  lines  of  the  31,5  kilograms  limit 
introduced  into  the  definition  of  Regulation  (EU)  2018/644;  (b)  possible  improvements  in  relation  to 
self-provision, and (c) possible improvements in relation to food delivery (postal item).  

128  The  Regulation considers only  items not exceeding 31,5kg as a parcel,  since items heavier cannot be 
handled  by  a  single  average  individual  without  mechanical  aid  and  this  activity  is  part  of  the  freight 
transport and logistics sector. 

129  The European Regulators Group for Postal Services further reported that in some Member States local 
food  delivery  operators  are  subject  to  postal  regulation.  Such  open  ends  may  result  in  some  postal 
regulators  being  in  change  of  a  larger  group  of  market  players.  See  European  Regulators  Group  for 
Postal Services (20) 7, p. 20. However, postal service providers and stakeholders that responded to the 
Commission’s public consultation did not raise any problems in this regard.     

130  WIK (2021), p. 306. 

39 

 
 
                                                      
Only  the  standards  regarding  the  measurement  of  cross-border  mail  quality  and 
complaints  handling  are  mandatory  standards.  All  the  other  standards  have  been  of  a 
voluntary nature. The compulsory standard defining the measurement system for cross-
border  mail  was  fundamental  to  ensure  a  proper  and  comparable  measurement  of  the 
obligation to  respect  quality standards (in terms  of transit time) for the  fastest  standard 
category of letters as required by the Directive. 

The application of the two mandatory standards has been uneven. The standard for transit 
time  is  applied  in  all  EU  Member  States  but  four,  while  the  standard  on  complain 
handling principles in 14 Member States.  There is no follow-up, sanctions or any other 
consequences for Member States not using them. 

Even  if  there  is  no  robust  monitoring  and  information  on  the  effective  implementation 
and application of the voluntary standards by providers, their application varies between 
Member  States.  According  to  a  WIK  survey,  universal  service  providers  in  some 
countries  only  apply  the  two  mandatory  standards  and  do  not  apply  any  voluntary 
standards. Others apply them very selectively. The reasons for this non application can be 
diverse: it could be due to preference for routines and procedures that have proved more 
adapted to particular national circumstances, the lack of relevance of some standards for 
some  operators  or  the  preference  given  by  postal  operators  from  small  countries  to 
standards developed by the Universal Postal Union, which they may consider more well-
known or more easily accessible. Finally the lack of follow-up and overview of the extent 
to which Member States apply these standards and of sanctions or other consequences of 
not using mandatory standards does not provide any incentive for a wider use.  

The  objective  and  the  benefits  of  greater  harmonization  in  the  implementation  of 
technical standards has therefore not been fully reached. A greater use of standards could 
facilitate  the  sorting,  transporting  and  delivery  of  international  postal  items.  The  postal 
operators interviewed by WIK as part of their study confirmed that the standards that are 
applied  create  great  benefits  for  them131.  Consequently  while  certain  doubts  may  be 
raised  as  regards  the  use  of  voluntary  standards  which  may  negatively  impact  their 
effectiveness, this is an area that would merit further consideration 

National Regulatory Authorities 

As  required  by  the  2008  Directive,  all  Member  States  have  established  regulatory 
authorities legally separate and operationally independent of the postal operators. 

In nearly all cases these national regulatory authorities are responsible for postal services 
and  for  telecommunications.  Consequently  these  national  regulatory  authorities  are 
subject  to  the  European  Electronic  Communications  Code  where  strong  independence 
provisions  are  applicable.  Alignment  for  all  regulators  with  such  independence 
provisions  appears  to  be  an  effective  way  to  ensure  that,  in  the  exercise  of  its  tasks,  a 
national  regulatory  authority  is  protected  against  external  intervention  or  political 
pressure liable to jeopardise its independent assessment of matters coming before it. 

131  WIK (2021), p.306. For a comprehensive list of the standards published by the European Committee for 

Standardization TC 331 see WIK (2021), p. 346ff. 

40 

 
 
                                                      
The  2008  amendment  to  the  Directive  also  ensured  that  the  national  regulatory 
authorities  have  better  access  to  information  (including  financial)  from  postal  service 
providers and put in place appropriate monitoring procedures to ensure compliance with 
the  obligations  arising  from  the  Directive.  This  was  expected  to  also  help  national 
regulatory authorities in the transition to competition. As evidenced by the core indicator 
reports  that  the  European  Regulators  Group  for  Postal  Services  issues  every  year,  it 
seems that, compared to the baseline, national regulatory authorities have received more 
and  better  information  to  perform  their  tasks  and  that  the  regulatory  oversight  has 
significantly expanded and improved. However, given the insufficient requirement in the 
relevant  provision  of  the  Directive,  national  regulatory  authorities  largely  lack  tools  to 
obtain information regarding terminal dues.  

As more and more cross-border issues have become integral part of regulatory activity, 
the  European  Regulators  Group  for  Postal  Service132  has  been  playing  an  increasingly 
important  role in  the provision  of expertise  to the national  regulators  and the European 
Commission.  Close  cooperation  of  national  regulatory  authorities  has  become  more 
relevant in a fully open and e-commerce determined postal and parcel market.   

Information shared with regulators  

The  2008  amendment  introduced  a  requirement  for  postal  service  providers  to  supply 
financial information, statistics and information on the provision of the universal service 
to  the national  regulatory  authorities. This  was to ensure  conformity with the Directive 
and  to  be  able  to  effectively  monitor  the  postal  services  market.  National  regulatory 
authorities  have  interpreted  the  provision  referring  to  monitoring  in  different  ways. 
Hence, the collection of statistics and market data is not uniform. Prior to the adoption of 
the Regulation on cross-border parcel delivery services133, data on the parcel and express 
segment  of  the  postal  services  market  was  far  less  comprehensive  and  reliable  than 
information with regard the letter mail market.  

Research  by  the  European  Regulators  Group  for  Postal  Services  confirms  that  the  data 
collection competences  of national  regulatory  authorities is  different  and  in  some cases 
limited.134 

5.2  Efficiency 

Q1:   Do  benefits  associated  with  the  application  of  the  Directive 

outweigh the costs? 

The provisions on quality and price control in the Directive bring clear benefits, though 
the measurable effects of some of those provisions seem to have been declining in recent 
years. Notably, the benefits related to quality seem to have decreased, while the broader 
societal benefits of universal service provision could be assumed to be less pronounced 

132  Commission Decision of 10 August 2010, Official Journal of the EU C 217/7 of 11.8.2010. 
133  Regulation 2018/644 of 18 April 2018 
134  WIK (2021), p.312. For example, the national regulatory authorities in France and Portugal may collect 
data  from  other  operators  than  the  universal  service  provider,  only  if  these  are  authorised  postal 
operators. The Danish regulator has no competence to collect data on non-universal services. 

41 

 
 
                                                      
than  around  2008,  due  to  changed  user  needs  and  communication  needs  because  of 
digitisation 

The trend seems to be that some of the costs (price for users, net cost compensation for 
the State) have been increasing over the last 5 to 10 years. The costs for administration 
are still modest, however, and the affordability of prices has not been questioned. 

The  main  costs  associated  with  the  Directive  encompass  the  costs  of  providing  the 
universal  service  (which  can  entail  offering  services  that  are  not  profitable  for  the 
universal  service  provider),  the  operational  costs  for  operators  to  comply  with  the 
Directive’s  provisions  on  prices,  quality  and  administrative  costs  for  both  national 
authorities and operators in following and monitoring its provisions.  

The benefits for users are related to the possibility for businesses and public institutions 
to  keep  communication  channel  to  citizens  and  other  businesses/public  institutions,  the 
provision  of  affordable  postal  services  and  the  accessibility  of  postal  services  for  all 
users,  including  vulnerable  groups.  Universal  service  providers  are  also  expected  to 
enjoy benefits as the universal service provision means a broad network and profitability 
potential (e.g., presence throughout the Member State territory increases brand value and 
brings  demand  complementarities).  The  benefits  for  society  as  a  whole  emerges  from 
greater  social  cohesion  with  a  basic  service  available  to  all,  irrespective  of  economic 
resources or digital skills, the maintenance of comparable living conditions in rural and 
urban areas (territorial cohesion). 

Costs for the State 

The State may finance the net cost of the universal service obligation, or certain costs for 
the provision of selected postal services, under the State aid rules for services of general 
economic interest.  

State aid compensation for the universal service obligation may only be paid by the State 
when the universal service obligations entail a net cost and represent an unfair financial 
burden.  It  is  one  of  the  financing  mechanisms  that  can  be  used  under  the  Directive, 
besides the compensation fund, to compensate the universal service provider from losses 
incurred  for  the  provision  of  the  universal  service  obligation.  More  than  one  third  of 
Member  States135  did  not  undertake  any  net  cost  calculation,  and  consequently  no 
compensation for the universal service was paid. 

The net cost is calculated as the difference between the net cost (or profit) of a designated 
universal service provider subject to an obligation to provide the universal service as per 
the Directive and the net cost (or profit) of the same operator without this obligation. It 
therefore only relates to the additional costs created by the provision of universal service. 
It  compares  the  universal  service  provider’s  result  in  a  situation  with  universal  service 
obligation to a hypothetical, counter-factual situation where the operator is not obliged to 
provide  universal  services.  However,  the  existence  of  net  cost  of  the  universal  service 
obligation does not exclude overall profitability of the universal service provider.  

135 WIK (2021), p. 191-192, table 27 

42 

 
 
                                                      
The  calculation  of  the  net  costs  by  the  Member  States  which  use  it136  vary  greatly, 
depending on the counterfactual scenario chosen by the universal service provider. 

Although  the  evidence  base  is  limited  there  are  some  indications  that  net  costs  remain 
important  in  some  countries  and  have  even  sometimes  increased.  In  2008  to  2010, 
estimates of the net cost were reported from nine Member States.137 For the period 2010 
to 2013, such calculations were reported from 12 Member States.138 Also, the number of 
State aid cases to compensate the net cost have increased since 2008. Between 2000 and 
2008 there were only a few cases (Poland, Spain and the United Kingdom), as shown in 
the Commission’s overview of State aid cases.  

The WIK (2013) study concluded that the estimated net cost of universal service in the 
EU-12139 Member States appears to be around 5 percent or less of the universal service 
cost,  while  the  cost  in  the  Member  States  that  joined  the  EU  after  2004  is,  at  least  in 
some cases, far more substantial (30 to 70 percent).140 The same study also found that the 
net  cost  is  increasing  over  time.  The  main  reason  is  the  generally  lower  letter  volumes 
per  capita  in  the  Member  States  that  joined  after  2004141,  which  implies  less  revenue, 
high costs for the universal service network, and leads to higher net costs142.  

The guidance for the calculation of the net cost of the universal service set out in Annex I 
of  the  Directive  has  been  used  for  the  calculation  of  the  financial  contribution  to  the 
universal  service  provider  in  the  12  Member  States  that  calculate  the  net  cost.  The 
guidance  involves  developing  a  counterfactual  scenario  in  order  to  compare  the  costs 
incurred  by  an  operator  with  a  universal  service  obligation  with  one  without  a  public 
mission. WIK finds that developing a completely hypothetical scenario specific to each 
country  and  its  universal  service  provider  is  difficult143.  Five  of  the  eight  national 
regulatory  authorities  that  responded  to  the  Commission’s  public  consultation  on  this 
matter argued that the net cost calculation methodology was useful, while the three other 
ones said it was not. Some say it is appropriate and reliable, some find it cumbersome. 

The  table  below  summarises  the  available  estimates  of  the  net  costs  from  different 
sources and based on different measurements methods.  

136  WIK (2021), p. 191-193. 
137  Copenhagen Economics (2010), p 130. 
138  WIK (2013), Main Developments in the Postal Sector (2010-2013), p. 153. 
139 In this document, EU-12 refers to all Member States of the European Union between 1 November 1993 

and 31 December 1994 and aggregated data referring to any interval of that period. 

140  Idem, p. 152. 
141 Letter mail volume per capita, 2017 : EU-MemberStates-in1997=127, EU-MemberStates-after2004=78, 

EU-MemberStates-after2007= 32,  

142 WIK (2013) p. 152. 
143  WIK (2021), p.213 

43 

 
 
                                                      
Table 5 Calculated net cost / compensation for SGEI provision 

Member 
State 

Net cost calculation 
published? /  
Last available year 

Net cost for universal 
service obligation,  
in percentage of total 
universal service revenues 

Previous estimate of net cost of 
universal service obligation in 
percentage of universal service 
cost 

Bulgaria 

Czech Rep. 

Denmark 

Estonia 

Greece 

2016 

2016 

2016 

2018 

2015 

Spain 

2010 

2018 

2015 

2016 

2016 

2017 

2013 

2015 

2016 

2016 

Croatia 

Ireland 

Italy 

Lithuania 

Latvia 

Poland 

Romania 

Slovenia 

Slovakia 

Belgium 

Hungary 

Malta 

United 
Kingdom 

25-30 percent 

39.6 percent (2012) 

15-25 percent (2016) 

n.a. 

7 percent (2007), 1.5 percent 
(2008) 

5-15 percent (2016) 

30 percent 

10-15 percent 

10-20 percent (reference 
year unclear) 

n.a. 

n.a. 

10-15 percent (2013) 

5-15 percent 

n.a. 

- 

n.a. 

5-10 percent 

5-10 percent 

1.3 percent (2008),  

5.2 percent (2009) 

12 percent (2009) 

17.2 percent (2012) 

0 percent (2009) 

39 percent (2009) 

6.7 percent (2012) 

0 percent (2009) 

3.8 percent (2009) 

69 percent (2009) 

5 percent (2008) 

Sources:  Based  on  Copenhagen  Economics  (2018),  national  regulator  decisions  and  annual  reports;  EC 

state aid decisions, USP annual reports and WIK (2013), p. 153. 

For Bulgaria, the Czech Republic, Estonia, France, Ireland, Italy, Lithuania, Poland and 
Slovakia the calculated net cost per capita ranges from below EUR 1 to almost EUR 6.144  

Net cost compensation involves State aid and must be notified to and evaluated by the 
Commission  under  the  rules  in  the  Framework  for  State  aid  to  Services  of  General 
Economic  Interest145  if  the  amounts  at  stake  exceed  EUR  15  million  per  year.  If  these 

144  WIK (2021), p. 195. 
145  Commission Decision 20 December 2011 on the application of Article 106(2) TFEU on State aid in the 
form  of  public  service  compensation  granted  to  certain  undertakings  entrusted  with  the  operation  of 
SGEI,  OJ  L  7,  11.1.2012,  p.  3-10,  and  Communication  from  the  Commission  —  European  Union 
framework for State aid in the form of public service compensation (2011), OJ C 8, 11.1.2012, p. 15–
22.  

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
amounts  remain  below  EUR  15  million  per  year,  no  notification  is  necessary  if  the 
conditions  of  the  Services  of  General  Economic  Interest  decision  are  fulfilled.  Postal 
universal  services  is  one  example  of  a  service  of  general  economic  interest,  but  postal 
offices  can  also  perform  other  such  services  for  which  they  may  receive  State  aid. 
Examples include financial and administrative processing of traffic fines (Belgium), or a 
savings account available for all (France).146 Less than half (42 percent) of the State aid 
compensation to the postal sector concern universal service obligations, with large parts 
of the compensation also relating to newspaper distribution (25 percent) and “territorial 
presence” (rules for postal network density) (19 percent).   

The main issue in State aid control of universal service compensation is to ensure that the 
calculation of the net cost by Member States and universal service providers is reliable 
and  not  unduly  inflated,  to  avoid  the  risk  of  overcompensation  and  cross-subsidisation 
(use  of  State  aid  for  activities  outside  the  universal  service  area).  The  Commission 
verifies  that  the  net  cost  calculation  provides  a  correct  estimate  of  the  true  economic 
burden  of  the  universal  service  obligation,  by  focusing  on  the  decisions  that  would  be 
made in the absence of the universal service obligation. Since 2008, the Commission has 
approved  State  aid  for  universal  service  provision  (based  on  net  cost  calculations 
according  to  the  Directive)  in  Poland  (2006  to  11),  (2013  to  15),  Greece  (2015  to  19), 
Italy  (2009 to  11, 2016 to  19, 2020 to  24), Spain  (2011 to  20), Denmark  (2017 to  19), 
and the Czech Republic (2013 to 17, 2018 to 22). The amounts can be up to EUR 6 per 
capita  (see  below),  given  that  net  cost  may  be  5  to  10  percent  of  universal  service 
revenues,  even  though  the  aid  usually  covers  only  a  part  of  the  net  cost.  The  State  aid 
cases with the largest total amounts were in Italy and Spain, presented in the box below. 

Examples of State aid measures 

The  universal  service  providers  of  Italy  and  Spain  are  the  two  most  long-running 
beneficiaries of State aid for universal service net costs.   

In the case of Spain, the aid granted amounted to around EUR 1.4 billion over 2000 to 
2011, and around  EUR  1.2 Billion over 2011 to  2019. This  means that the aid  amount 
per  year  remained  practically  unchanged  in  nominal  terms,  and  the  average  annual  aid 
was roughly EUR 2.5 to 2.8 per capita.147 The purpose of the aid is compensation for the 
costs  related  to  universal  service  obligations  such  as  network  density  and  delivery 
frequency.  

The  Italian  universal  service  provider  received  compensation  for  universal  service 
obligations from the State amounting to on average around EUR 365 million per year for 
the  period  2009-11,  a  maximum  of  EUR  335  million  per  year  for  2012-15  period, 
maximum  EUR  262  million  per  year  for  2016  to  19,  and  has  been  granted  maximum 
EUR 262 million per year for 2020 to 2024. This means an average annual aid of roughly 
EUR  4.4  to  6  per  capita.  The  purpose  of  the  Italian  aid  is  to  preserve  the  universal 

146  This involves special features not provided by all banks (Aide d’État SA.41147 (2017/NN) – France). 
147  It may be noted that the Commission has also issued a negative decision concerning parts of Spanish 

State aid, whereby some of the aid granted for 2004-10 was recovered.   

45 

 
 
                                                      
service,  since  the  counterfactual  calculations  showed  that,  for  some  years,  it  would  be 
profitable to discontinue (not only reduce) such services.148  

Hence, the aid amounts for these major recipients have not increased. Since the aid does 
usually  not  cover  the  entire  net  cost,  however,  this  cannot  be  seen  as  an  indication  of 
falling net costs. The trend also seems to be an increased number of State aid cases for 
universal  service  provision  in  recent  years.149  Most  costs  are  incurred  by  universal 
service providers, both for the universal service provision and for the other provisions 
of  the  Directive.  In  some  cases,  these  costs  are  financed  by  the  State  and  hence  the 
taxpayers, or possibly by users (through the prices they pay). 

Operational costs for the universal service provider 

Operational  costs150  arise  mainly  from  the  Directive’s  requirements  to  comply  with  a 
certain  quality  of  service,  such  as  transit  time  for  postal  items.  This  includes  notably 
investments in sorting machines as well as the whole terminal structure with centers and 
platforms  for  the  delivery  process  (though  a  definite  causality  between  all  such 
investments and the provisions of the Directive can of course not be established). 

Investments for quality improvement: Germany 

As  an  illustration  of  the  dimensions  of  investment  required  for  quality  improvement, 
investments made by Deutsche Post to completely reorganize its mail network, including 
substantial investments in sorting centres and the letter mail processing network may serve 
as  an  illustration.  Investments  during  the  1990s  (largely  before  1997)  to  achieve  this 
objective amounted to between 7 and 11.5 percent of annual revenues. Around 80 percent 
of the revenues emanated from letter mail at the time. These investments are obviously not 
directly linked with the Directive, but they show the magnitude of investments needed for 
substantial quality improvements at a major postal operator. As a comparison, in 2018 the 
Deutsche  Post  investments  in  the  mail  segment  had  decreased  to  4.3  percent  of  annual 
revenues.  The  quality  requirements  of  the  Directive  could  be  expected  to  influence  the 
need to invest in quality, but such major investment decisions also depend heavily on the 
competitive situation as well as on the internal assessment and strategy of operators.151 As 
a result, the quality of service improved from 75 percent of letters delivered within one day 
(D+1) (in 1992) to 95 percent delivered at D+1 (in 1998). 

Investments for quality improvement: France 

Another  example  is  a  letter  mail  quality  project  that  the  French  La  Poste  launched  in 

148  State Aid SA.43243 (2015/N) – Italy, recitals 85-86. 
149  EU 

Competition) 
https://ec.europa.eu/competition/state_aid/register/ 

Commission 

(DG 

database 

on 

State 

aid 

cases. 

150  In this context,  “operational costs”  means costs (incl.  e.g. investment costs) related to the Directive’s 

provisions, other than the net costs for universal service provision.   

151  WIK (2021) p. 233. 

46 

 
 
 
 
 
                                                      
2004,  aimed  at  modernising  the  mail  processes,  and  improving  quality  of  service.  La 
Poste  earmarked  EUR  3.4  billion  for  the  entire  duration  of  the  project.  At  the  end  of 
2009,  the  modernization  program  covered  70  percent  of  French  mail  operations:  18 
automated  mail  handling  platforms  were  opened  in  2009.  By  the  end  of  2011,  41  new 
generation platforms were implemented, covering 90 percent of French operations. As a 
result, the delivery quality (D+1) increased from 66 percent before 2004 to more than 87 
percent in 2011.152 While a causal link cannot be made between this type of investments 
in quality improvement and the quality provisions of the Directive, it is an indication of 
the type of investments that may be needed to provide a quality performance in line with 
the Directive’s requirements.153 

If, in the absence of the Directive, quality had been much lower, then the investments to 
improve quality would have constituted an important cost of the Directive. The need for 
this  type  of  investments  does  not  seem  to  have  been  as  high  in  the  last  5  to  10  years, 
however,  as  structural  letter  volume  decline  (and  thereby  less  actual  and  potential 
competition  in  this  part  of  the  market)154  means  declining  need  for  investments  to 
comply  with  the  Directive.155  Concerning  personnel  costs,  because  universal  service 
providers  have  to  provide  a  certain  network  density  and  delivery  frequency  they  will 
incur  costs  that  they  would  not  have  in  the  absence  of  universal  service  obligation156 
Staff costs are likely to be a considerable part of this. However, all such costs would be 
included in the net cost calculations.  

All universal service providers also incur administrative costs. Such costs relate notably 
to  reporting  on  the  performance  of  universal  service  provision,  maintaining  separate 
accounts for universal and non-universal services, applying for authorisations to provide 
universal  postal  services,  and  reporting  to  national  regulatory  authorities  (in  some 
Member States), and requesting approval for tariff increases subject to price regulation. 
On the basis of estimates made by the universal service operators in Ireland and the UK, 
the  administrative  costs  of  complying  with  the  domestic  regulation  costs  have  been 
estimated at less than 0.4 percent of their turnover of universal services. This should be 
interpreted with great caution as these two countries may not be representative for all the 
Member  States  and  the  national  regulation  goes  beyond  the  requirements  of  the 
Directive.  This  estimate  therefore  provide  for  an  upper  limit  for  estimating  the 
administrative costs of the Directive.157  

152  WIK (2013), p.220 to 221. 
153  The  background  to  this  type  of  investment  could  of  course  also  be  the  need  to  face  (potential) 
competition  caused  by  market  opening.  In  that  case,  too,  the  investments  could  be  seen  as  possibly 
caused by the Directive’s provisions. 

154  With continued declining quality of service, however, the Directive’s provisions on quality of service 
could  mean  that  new  investments  are  needed,  irrespective  of  the  market  situation  in  terms  of 
competition. 

155  Copenhagen Economics (2018), p. 34. 
156  Delivery staff make up 44 percent of total employment of EU universal service providers (Copenhagen 

Economics, 2018). 

157  WIK (2021), p. 197. Based on estimates made for Ireland and the UK. Please see Annex 3 for details. 

47 

 
 
 
 
                                                      
Costs for other postal operators 

Postal  operators  that  are  not  universal  service  providers  also  face  administrative  costs 
related  to  universal  service  provision.  Such  costs  are  related  notably  to  authorisation 
procedures (where applicable), reporting obligations for data collection, and complaints 
procedures.  It  concerns  all  companies  that  are  classified  as  postal  operators.  As  a 
percentage of turnover for universal services or services within the scope of the universal 
service  obligation,  they  are  5  to  10  times  lower  than  for  universal  service  providers. 
These costs are estimated at 0.01 to 0.05 percent of the relevant turnover.158    

In very few Member States non-universal service postal operators also have to contribute 
to  financing  the  net  cost  of  universal  service  provision  by  contributing  fees  for 
compensation  funds.  The  postal  operators  that  meet  certain  size  criteria  usually 
contribute a  certain  percentage of their  relevant  turnover  (i.e., turnover in the universal 
service area and/or inter-changeable services), or a fee per postal item.159 In addition to 
the cost for postal operators, compensation funds often bring administrative costs for the 
regulatory authorities and they have a negative effect on the competitive situation of the 
competing operators. In Italy, a dispute as to which operators would have to contribute to 
the  fund,  was  settled  by  the  Court  of Justice  of  the  EU160,  but  in  the  end  the  fund  was 
never activated.  

The  general  principle  of  sharing  the  contribution  among  all  providers,  including  the 
universal  service  provider,  according  to  their  market  share  within  the  scope  of  the 
universal  service  (or  interchangeable  services161),  must  by  definition  –  given  the  high 
market share of the universal service providers in that part of the market  – result in the 
universal  service  provider  bearing  the  by  large  biggest  share  of  the  contribution  to  the 
compensation fund. 

The limited experience with  compensation funds which has only been activated in  four 
Member States162  raises doubts as to  whether the mechanism as such is  a cost-efficient 
way of financing the net costs of the universal service. The administrative costs to set up 
the fund, fixing the level of contributions, and collecting the fees can be relatively high in 
comparison with rather limited, received revenues. Also, the paid fee is an additional cost 
that  will  eventually  be  transferred  to  the  customer,  making  the  services  of  contributing 
service  providers  more  expensive.  Finally,  a  compensation  fund  has  low  incentives  to 
improve the efficiency of the universal service provider. Evidence is too limited to assess 

158  WIK (2021), p.198. 
159  In Estonia, the  fees per item  amounted to  EUR 0.08 per item of correspondence (ordinary letter) and 
EUR 0.40 for registered and insured letters in 2018. (WIK (2021), p.210. In Poland, the fees amount to 
max. 2 percent of the revenues from the provision of universal services (and interchangeable services) 
(State aid SA.38869 (2014/N) – Poland). In Greece, the basic contribution for the other postal operators 
is 0.5 percent of their turnover in the universal service (which can increase to max. 10% if the operator 
is mainly active in certain major urban areas). (State aid SA.35608 (2014/C) (ex 2014/N) – Greece) 
160  See Court of Justice of the EU (2018), Decision of 31 May 2018, joint cases C-259/16 and C-260/16 
(CONFETRA, AICAI and others v. Autorità per le Garanzie nelle Comunicazioni and Ministero dello 
Sviluppo Economico). 

161  See  Recital  27  of  Directive  2008/6/EC  and  the  detailed  explanation  of  the  concept  in  Copenhagen 
Economics (2015), Study on the interchangeability of Universal Service Obligation and non-Universal 
Service Obligation services. 

162  Only Denmark, Estonia, Poland and Slovakia have actually activated such a fund. WIK (2021), p.210. 

48 

 
 
                                                      
the impact of such compensation mechanisms on the efficiency of the universal service 
providers  even  more  so  since  efficiency  promotion  is  a  process  over  several  years. 
However, universal service providers in those countries where a compensation fund was 
activated  did  not  show  a  high  level  of  profitability,  as  evidenced  in  Table  7163,  was 
negative or near zero.  

Costs for users 

As  shown  in  section  3.3,  price  for  postal  users  have  increased  in  most  Member  States 
between 2008 and 2019 notwithstanding price regulation. Without the Directive, as letter 
quantities  decline,  a  company  operating  under  normal  market  conditions  would  likely 
withdraw  from  the  unprofitable  parts  of  the  market  that  show  consistently  declining 
demand.  This  is  not  an  option  for  the  universal  service  providers.  In  this  context,  the 
price increase could be seen as a way for operators of making users contribute to share 
the  costs  of  financing  the  universal  service.  As  shown  in  section  3.3  and  in  Annex  1, 
section 1.4, parcel prices have not increased as much as letter prices, essentially because 
of  the  increase  in  parcel  volumes.  The  stress  on  the  universal  service,  and  thereby  the 
cost  for  users,  relates  largely  to  the  decreasing  letter  volume.  The  universal  service 
providers  usually  have  separate  networks  (as  concerns  sorting,  distribution  etc.)  for 
parcel and letters.  

Costs for national regulators 

National postal regulators are facing significant administrative costs directly related to 
the Directive. These costs concern resources  that  regulators spend on verifying that the 
provisions of the Directive are followed. The total such regulatory budget is estimated at 
around EUR 45 million, which means that the amount per capita is marginal, and lower 
than  the  administrative  costs  for  universal  service  providers.  The  main  categories  of 
administrative costs are shown in the table below.  

Table 6 Total budgets of regulators for postal regulation (figures from 2017 or 2018) 

Regulatory aspect 

Total EU-28164 
(EUR million) 

Percent share 

Total regulatory budget 

Ensuring  /  monitoring  universal  service  provision 
and financing  

Quality requirements  

Complaint procedures 

Price regulation 

Administering authorisations & market opening  

Harmonising technical standards 

Source: WIK (2021), p.166. 

45.2 

17.2 

4.5 

9.0 

6.8 

6.8 

0.9 

38 percent 

10 percent 

20 percent 

15 percent 

15 percent 

2 percent 

163  The  Danish  universal  service  provider  showed  negative  profitability  in  2012,  2016  and  2017,  the 
Estonian universal service  provider showed low positive  profitability  for these  years (sometimes  near 
zero). In addition, the Polish universal service provider showed negative profitability in 2016. 

164  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period between  1 

July 2013 and 31 January 2020 and aggregated data referring to any interval of that period.  

49 

 
 
 
                                                      
Benefits for stakeholders and society 

The concrete benefits of universal service provisions for postal users emanate from the 
guaranteed access to a postal network (universal service provision), as well as from the 
Directive’s provisions on pricing, quality and complaint handling. Other postal operators 
benefit from open markets and removal of obstacles to competition. 

People depending more on postal services than others in the EU would include: 
  98 million people living in remote and rural areas; 

  62 million people who have never used the Internet; 

  74 million disabled people; 

  105 million people over 65 years old165. 

Some of these groups may however overlap. For instance the elderly and the people who 
have  never  used  the  internet  or  the  people  who  live  in  remote  and  rural  areas  with  all 
other groups. The magnitude of these overlaps is however impossible to calculate 

According to WIK (2021), which included a survey, 79 percent of respondents still use 
mainly/mostly letters or at least for some specific purposes.166  

The Commission’s public consultation showed that 83 percent of EU citizens found that 
the  objective  of  providing  universal  service  to  all  citizens  across  the  territory  had  been 
completely or partially met. For all categories of respondents, 77 percent agreed that the 
Directive  has  completely  or  partially  met  this  objective.  According  to  the  WIK  (2021) 
survey,  82  percent  of  the  operators  and  89  percent  of  the  regulators  found  that  the 
Directive has effectively ensured universal services.167 

Another  important  benefit  of  the  Directive  comes  from  the  nationwide  accessibility  of 
universal postal services. This is normally more relevant in sparsely populated areas, as 
postal services tend to be more costly for the operator per item in such regions (due to the 
fact that there are fewer items that share the delivery costs). Moreover, a “digital divide” 
between rural households (82 percent have internet access) and urban households is still 
evident (90 percent have internet access).168 

In  2013,  22.5  percent  of  the  EU  population  lived  in  predominantly  rural  areas.169  This 
decreases  to  18.6  percent  of  the  EU  population  in  2019.  Given  this  decrease  in  rural 
population,  it  can  be  assumed  that  the  societal  benefits  of  postal  services  diminishes, 
since the rural regions are mostly concerned by the universal service obligation.  

The age of the population is also a factor in analysing the importance of universal postal 
service  provision.  Older  generations  usually  have  lower  digital  communication  skills 
than  younger  generations170  (indicating  a  higher  need  for  postal  services),  though  the 
difference is decreasing. A 2016 survey from Sweden confirms that the need for next-day 

165  WIK (2021), pp.118-134.  
166  WIK (2021) p. 94. 
167  WIK (2021) p. 189. 
168  Eurostat, WIK (2021), p. 50 and p.122. 
169  Eurostat, CAP Context indicators, 2014 update. 
170  Eurostat, WIK (2021), p. 127. 

50 

 
 
                                                      
delivery  services  is  higher  for  the  elderly  and  residents  of  areas  with  poorer 
accessibility171. The very old may also have special needs. Both these factors increase the 
benefits  of  universal  postal  service  provision.  Older  people  (aged  65  years  or  more) 
account for 20 percent of the EU28 population, with the share of the very old (80 years or 
more) standing at  5.7  percent of the total  population.172  With  an ageing population,  the 
benefit  of  universal  service  has  likely  increased  as  the  special  needs  (e.g.,  potentially 
impaired  vision,  mobility  issues)  that  can  be  served  through  universal  postal  services 
increase.  

The overall importance of the Directive in ensuring social cohesion is shown in the role 
it  plays  for  societal  inclusion  of  postal  users.  Both  national  regulatory  authorities  (86 
percent) and postal operators (68 percent) agree that the Directive has a positive impact 
on societal inclusion of postal users.173 

Requirements  on  quality  of  service  (i.e.,  transit  time  for  delivery  of  letter  mail)  are 
crucial  for  building  consumer  trust  in  the  reliability  of  postal  services.  External  bodies 
monitor and verify whether the quality requirements of the Directive are respected. While 
the  significant  progress  in  quality  until  2008  has  benefitted  EU  citizens  and  societal 
functions as well as businesses, benefits have clearly diminished. Only 20 to 22 percent 
of  all  the  regulators  and  operators  who  replied  to  the  WIK  survey  fully  agree  that  the 
Directive  has  improved  the  quality  of  domestic  or  cross-border  services  in  their 
countries174.  This  may  be  seen  as  indications  of  quite  unclear  benefits  from  the 
Directive’s quality provisions.  

Price  regulation  brings  benefits  to  users  by  limiting  price  increases  to  the  extent 
determined by the principles of cost orientation and affordability.  

Practical benefits can still be seen: price caps are applied in ten Member States (Belgium, 
Croatia,  Estonia,  France,  Germany,  Hungary,  Lithuania,  Netherlands,  Portugal  and 
Sweden).175 The price caps are geared to inflation, normally the Consumer Price Index. 
In a few cases, the price cap is set a few percentage points above the change Consumer 
Price  Index,  but  there  are  also  examples  where  it  is  set  below  the  Consumer  Price 
Index.176It  does  therefore  not  seem  to  be  the  case  that  price  caps  are  set  at  such  high 
levels that they become irrelevant, so they have led to benefits for users.  

Some  of  the  benefits  of  price  regulation  can  also  be  seen  by  comparing  actual  price 
development  with  a  hypothetical  situation  without  price  regulation.  There  is  some 
indication  when  comparing  the  situation  before  and  after  EU  membership  for  the 
Member States that joined the EU in 2004 and after, nominal price increases were more 

171 WIK (2021), p.112. 
172  Eurostat  Data 

explorer,  Population 

statistics:  Structure 

indicators, 

update 

3.7.2020. 

http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=demo_pjanind  

173  WIK (2021) p. 204. 
174  WIK (2021), p.227 
175  See Copenhagen Economics (2018). A report by the European Regulators Group for Postal Services in 
2014 indicated that Denmark and Poland also applied price caps. The price cap applied in the United 
Kingdom  is  a  safeguard  cap  to  ensure  affordability  and  is  applied  without  an  efficiency  factor.  See 
European Regulators Group for Postal Services (14) 22.  
176  European Regulators Group for Postal Services (14) 22. 

51 

 
 
                                                      
pronounced in the period before 2007 than after that date.177 For the Member States that 
joined in 2004, average letter prices increased by 8.3 percent annually between 1998 and 
2004,  and  by  5.6  percent  annually  between  2004  and  2009.178  This  would  point  to 
benefits  of  the  Directive  for  users,  but  could  also  be  related  to  general  price  increases 
prior  to  joining  the  EU.  As  an  international  comparison,  e.g.,  Australia  split  postal 
service  into  “priority”  and  “regular”  (lower  service  levels)  in  2016,  which  led  to  a 
dramatic price increase (considerably steeper than the price increases in the EU) for what 
was called “priority” service. Volumes have continued to decline after 2016, and prices 
increased further in 2020. Letter prices in the U.S. have grown less than in the EU since 
2008, as the U.S. price regulation does not allow the U.S. universal service provider to 
increase prices beyond the general inflation rate. In the EU the average price for priority 
letters  has  increased  more  than  the  consumer  price  index,  especially  after  2015  when 
some  Member  states  decided  to  transfer  the  higher  cost  of  next  day  delivery  to  the 
customer, but kept the non-priority letter price increase more moderate. 

Figure 4 Price developments within the EU, Australia and the US 

Source: WIK (2021) p.258, “EU Member States 1997 average” refers to the average price development in 
EU Member States that had joined the EU by 1997. 

If  high  prices  could  be  shown  to  correlate  with  high  quality,  the  benefits  of  improving 
one  of  these  factors  could  be  assumed  to  compensate  for  the  deterioration  of  the  other 
factor. Comparing the fastest actual transit time and the price for the fastest small letter in 
each  Member  States  shows,  however,  that  there  is  no  correlation.179  It  seems  that  high 
quality does not necessarily come together with high prices.  

177  WIK (2021) p. 24 and p. 258.  
178  Data provided by WIK with the 2021 study. Letter prices, 20g, domestic (converted to Euro using 2019 

exchange rates). 
179  WIK (2021) p. 235. 

52 

050100150200250300350200820092010201120122013201420152016201720182019Price development (index)AUEU averageEU MS 1997 averageUS 
 
 
                                                      
As  illustrated  by  a  2020  WIK  survey  of  postal  stakeholders,180  86  percent  of  national 
regulatory  authorities  but  only  55  percent  of  universal  service  providers  agreed 
completely  or  partly  that  the  Directive  has  limited  price  increases  and  price 
discrimination. 

Finally,  the  Directive  also  brings  benefits  for  universal  service  providers.  As  seen  in 
Table 6 below, there is considerable variation in their overall letter/parcel  profitability, 
but  most  of  them  show  a  positive  result.181  Profitability,  and  thereby  the  benefit  of  the 
Directive for universal  service providers, is  not constant  over time though.182 The table 
below shows profitability for universal service providers for letters/parcels. It is clear that 
the picture is varied, with some universal providers showing clear profitability, whereas 
others  are  unprofitable.  The  role  as  universal  service  provider  brings  extra  revenues 
directly  related  to  the  additional  offices  and  network.  It  also  means  other  extra 
(intangible) revenues related to being a universal service provider, including brand value 
and  demand  complementarities,  demand  effects  due  to  the  VAT  exemption,  as  well  as 
network  advantages  and  enhanced  advertising  effect.  Some  of  them  also  show 
profitability thanks to activities outside the parcel/letter segment. 

Table  7  Profitability  of  universal  service  providers  (EBIT  margin  (Earnings  before  interest  and 
taxes), letter and parcel segment) 

Member State 

2008 

2012 

2016 

2017 

Austria 

Belgium 

Germany 

Denmark 

Greece 

Spain 

Finland 

France 

Ireland 

Italy 

Luxembourg 

Netherlands 

16.9 percent 

17.3 percent 

18.2 percent 

18.7 percent 

11.9 percent (all 
revenue segments) 

22.84 percent 

25.2 percent 

21.8 percent 

15.1 percent 

7.5 percent 

8.5 percent 

8.3 percent 

6.9 percent 

-0.2 percent 

-6.5 percent 

-7.5 percent 

1.7 percent 

3.6 percent 

2.5 percent 

-4.2 percent 

3.8 percent 

-0.4 percent 

-3.1 percent 

-5.3 percent 

9.4 percent 

6.3 percent 

4.4 percent 

4.2 percent 

4.3 percent (all 
revenue segments) 

3.7 percent (all 
revenue segments) 

6.0 percent 

5.1 percent 

5.3 percent 

-12.7 percent 

-5.9 percent 

-4.0 percent 

-1.0  percent 

8.9 percent 

-11.4 percent 

-14.2 percent 

14.7 percent 

9.2 percent 

4.0 percent 

14.9 percent 

3.7 percent 

9.6 percent 

8.1 percent 

180  WIK (2021) p. 255. 
181  For more details on profitability, please see Annex 4.I, section 1.5. 
182  Some  studies indicate  falling  profitability. For instance, according to Copenhagen Economics (2019), 
Postal services  in  the EU, p. 26 to 27,  the overall profitability of  universal service  providers actually 
decreased by some 7 percent over 2014 to 2017. 

53 

 
 
 
                                                      
Portugal 

Sweden 

Cyprus 

Czech rep. 

Estonia 

Hungary 

Lithuania 

Latvia 

Malta 

Bulgaria 

Croatia 

8.5 percent 

10.6 percent 

5.8 percent 

5.2 percent 

3.9 percent (2013) 

14.9 percent 

4,6 percent (all 
revenue segments) 

22.6 percent 

0.0 percent 

16.4 percent 

14.5 percent 

1.8 percent 

1.5 percent 

1.1 percent 

0.6 percent 

4,4 percent 

1.4 percent 

0.7 percent 

4.0 percent 

-2,1 percent 

2.0 percent 

0.2 percent 

-19.1 percent 

0.5 percent 

1.5 percent 

3.0 percent 

7.3 percent 

8.5 percent 

4.5 percent 

3.4 percent 

14.1 percent 

9.8 percent 

10.5 percent 

7.9 percent 

2.7 percent 

-8.7 percent 

-5.1 percent 

-12.4 percent 

-0.7 percent 

8.0 percent 

9.7 percent 

Source: WIK (2020), p. 192-93, and data provided by WIK in connection with this study. 

As a rough comparison with some major express operators:  

  The operating margin (EBIT) of Federal Express has fluctuated between 5 percent and 
7 percent between 2010 and 2013, to reach 8-10 percent in 2013-15, and fall to around 
4 percent - 6 percent in most of 2016-2020.183 

  For United Parcel Service, the corresponding figures were 8-11 percent in 2010-2012, 

below 3 percent in 2012-13, and 9-12 percent in 2014-2020.184 

  The  Express  Division  of  DHL  has  shown  EBIT  margins  of  around  9-12  percent  in 

2013-2018.185 

Comparing costs and benefits 

For  the  State,  in  Member  States  that  pay  net  cost  compensation  for  universal  service 
provision, the cost per capita can be an additional EUR 2 to 6 in the highest cases. While 
the net cost compensation can vary significantly, with some extreme cases, the costs per 
capita for ensuring universal service provision, incurred by the regulatory authorities, can 
be estimated at below EUR 0.1 per capita annually. This should be put in relation to the 
benefits which include improved social cohesion as the universal service enables general 
access  to  affordable  communication  services.  The  universal  service  also  creates  or 
maintains comparable living conditions in rural and urban areas (territorial cohesion) and 
enables reliable communication among citizens, businesses, and public institutions.  

By adding the estimated total administrative cost for universal service providers and 
the  estimated  total  cost  for  national  regulatory  authorities,  the  costs  per  capita  for 
ensuring  universal  service  provision  can  be  estimated  at  below  EUR  0.20  per  year  in 

183  https://www.macrotrends.net/stocks/charts/FDX/fedex/operating-margin 
184  https://www.macrotrends.net/stocks/charts/UPS/ups/operating-margin 
185  DPDHL Annual reports. 

54 

 
 
 
 
 
                                                      
many Member States.186 The costs relating to quality requirements are rather low while 
the  benefits  of  improved  quality  are  important  for  society  as  a  whole,  and  the  quality 
standards contribute to creating transparency. Compared to the situation in 2008, benefits 
to postal users (results on actual quality in terms of delivery time, as shown in section 5.1 
above)  have  been  going  down,  while  costs  are  about  the  same  as  earlier,  meaning  a 
decrease in efficiency.  

Table 8 summarizes the costs and benefits of universal service provision and regulation 
per economic actor or group in society, and estimates where possible the costs. 

Table 8 The costs and benefits of universal service provision and regulation 

Regulatory 
authorities/ Member 
States 

Universal service 
providers 

Other operators 

Costs 

Benefits 

  Administrative costs of regulatory 

 

Social/ territorial cohesion  

authorities  (e.g., controls regarding 
price, quality and market opening) 
[Less than EUR 0.1 per capita annually] 
Finance for universal service net costs 
(State aid) [Up to EUR 2-6 per capita 
annually] 

 

  Operational costs for compliance with 

 

the Directive’s provisions 

  Administrative costs (e.g. reporting, 
maintaining separate accounts, 
authorisations/licenses) [Estimated at 
EUR 0.20 per capita maximum] 

  Administrative costs  
 

Contribution to compensation fund 
(where applicable) 

Intangible benefits (e.g., 
brand value, demand 
complementarities, network 
advantages, enhanced 
advertising effect).   

 

Potential access to network of 
universal service provider 

Consumers and 
citizens 

 

Price paid for universal service 
products 

  Access to affordable 

communication services 

Q2:   Is  there  scope  for  a  more  cost-efficient  application  of  any 
provisions of the Directive, including for simplification and burden 
reduction? 

For  certain  universal  service  obligations,  such  as  the  delivery  frequency  and  delivery 
times, the Directive provides only limited flexibility, to address the growing decrease in 
interest for fast delivery of letter mail. The provision on the compensation fund does not 
seem to be cost-efficient, because the received fees are not sufficient to cover the entire 
net cost and it entails administrative burden. The fund does not encourage the universal 
service provider to improve its efficiency.  Complaint procedures in the Directive do not 
sufficiently  take  in  account  the  information  needs  of  recipients  which  is  especially 

186  Please see annex 3 for details. 

55 

 
 
 
 
 
 
 
                                                      
important  for  parcel  delivery.  Without  substantial  additional  costs,  the  publication 
requirements  on  complaints  may  become  more  effective  by  providing  more  useful 
detailed information. 

Scope of minimum universal service: delivery frequency requirements  

Because  of  the  declining  demand  for  letter  mail  and  the  reduced  need  for  fast  delivery 
service  levels  by  recipients  and  senders,  the  current  mandatory  delivery  frequency 
threshold  of five days  per week may not  be cost-efficient. For some Member States an 
imbalance may emerge between the cost of a daily delivery frequency and the benefits, 
even if for some operators, it seems  important  to maintain it to  keep a reasonably high 
level of mail volume.  

The  Directive  allows  Member  States  to  derogate  from  the  minimum  frequency  of  five 
days  per  week.  This  is  cost  effective  as  it  aims  to  reduce  high  delivery  costs  when 
circumstances  or  geographical  conditions  are  deemed  exceptional187.  Until  now  most 
Member  States  have  used  the  derogation  in  a  measured  way  and  mostly  to  deal  with 
exceptional  situations  (although  some  have  gone  considerably  further).  This  can  be 
derived by the fact that the derogation only affect a small part of their population, in most 
cases less than 1 percent188189. 

However,  in  Member  States  where  all  actors  in  society  have  widely  adopted  digital 
communication and senders and users no longer need regular daily delivery of letters as 
they did before, the requirement of a minimum five days per week delivery may become 
too costly in proportion to the users benefits. The derogation is not in principle designed 
to solve this cost benefit imbalance. Its purpose was never to deal with this massive shift 
in  user  behaviour  nor  with  the  increasing  financial  burden  when  unit  costs  increase 
because of substantial lower letter mail volumes.  

The evaluation finds that the requirement of a minimum five days per week delivery may 
no longer  be cost  efficient.  A  relaxation would not  affect  the increasing  need for faster 
parcel delivery, as Member States have in a many cases separate networks for parcel and 
letters. 

Quality of service: transit times for domestic and cross-border services 

The flexibility Member States have in setting domestic transit times can be considered as 
cost efficient because it allows Member States to adjust  transit time (speed of delivery) 
and standards to the appropriate service level needed by  postal users. There is however 
limited flexibility for cross-border delivery times as these are contained in the Directive 
itself.  

In the last five years, some Member States used the flexibility for domestic transit times 
provided in the Directive, because a large part of the society primarily use digital means 

187  For example delivery too mountainous and island regions where delivery costs are much higher 
188  Copenhagen Economics (2018), page 193, Figure 84.  
189  Italy is the exception where the derogation covers 25 percent of the Italian population. Regulatory and 
legislative changes in 2014 and 2015 allowed Poste Italiane to implement an XY delivery model in the 
most rural areas of the country, where mail is delivered on Mondays, Wednesdays and Fridays during 
the first week and on Tuesdays and Thursdays in the second. The precise overall cost is not published. 

56 

 
 
                                                      
for a wide range of communication needs. This shift has been further accelerated when 
authorities encouraged or imposed digital communication exchange between citizens and 
public  authorities.  To  mitigate  the  rising  unit  costs  when  letter  volumes  decline 
substantially, these Member States have implemented slower transit times than D+1 for 
the fastest letter product (Denmark D+5, Finland D+4, Sweden D+2). The decision was 
motivated  by  the  fact  that  a  fast  service  at  D+1  covers  more  than  what  is  needed  by 
different  user  groups  (e.g.,  certain  private  recipients  and  senders  in  rural/urban  areas, 
small  and  medium  enterprises,  larger  senders  such  as  banks,  telecoms,  government 
institutions and e-retailers).  

While it is cost efficient for authorities to adapt their national legal framework to slower 
domestic delivery it creates a conflict with the D+3 target that the Directive requires for 
cross-border  delivery.  Cross-border  delivery  of  universal  letter  mail  requires  two 
operators  working  together,  implying  that  a  slower  delivery  by  the  operator  in  the 
country  of  the  recipient  prolongs  the  total  cross-border  transit  time  from  sender  to 
recipient.190  

For cross-border (i.e., intra community) mail, quality standards on routing times and the 
regularity and reliability of services are set by the Parliament and the Council. They can 
only be changed through a regulatory procedure with scrutiny. 

Financing of the universal service: compensation fund 

The compensation fund where providers of postal services have to pay a fee per item or a 
share of their turnover is an option to finance the net cost of the universal service. Even if 
it is legally allowed in 18 Member States, only four Member States have established and 
activated  such  funds  (but  not  always  systematically  in  all  years)191.  From  a  cost 
efficiency  perspective  the  compensation  fund  method  has  certain  limitations  that  may 
explain  why  it  is  not  widely  adopted.  First,  the  fee  contributions  received  from  other 
providers do not appear sufficient to cover the entire net cost, especially when this cost is 
growing in  a declining  market  and the universal service provider has a  strong  position. 
State  aid  funding  is  then  needed  in  addition.  Secondly,  there  is  some  evidence  that  the 
administrative cost of the sharing mechanism may be relatively high in proportion to the 
contribution fees192 and that organising this contribution from other operators means an 
additional layer of administrative burden for both regulators and operators. Not only the 
criteria  to  determine  which  postal  operators  have  to  contribute  to  the  fund  must  be 
established  and  verified  by  both  regulators  and  operators,  but  also  the  mechanisms  for 
collection and transfer of the contributions (often a fee per relevant postal item) must be 
established. Thirdly, sharing the burden among postal operators sets low incentives for a 

190  The operator in the origin Member State that collects, sorts, and dispatches in the home country, and the 
operator in the destination country that sorts per post code and delivers to the addressee. This split in 
activities implies that the operator in the origin Member is dependent on the other operator for its cross 
border transit time performance. When certain Member States relax domestic transit time for the fastest 
service category the delivery performance of the operator in the origin country will also slow down.  

191  WIK (2019), p. 60. 
192  WIK (2021), page 210: Although the final ruling of the CJEU confirmed express operators would need 
to  contribute  to  the  compensation  fund,  AGCOM  did  not  find  it  appropriate  to  activate  the 
compensation fund. This decision took into account the changes in frequency of delivery in rural areas, 
leading to substantial cost reductions for Poste Italiane, and the high administrative cost for establishing 
the fund.192 

57 

 
 
                                                      
universal service provider to improve its efficiency and deters market entrance.193 Other 
operators  have  to  pay  a  higher  fee,  the  higher  the  relevant  market  share  they  have 
achieved, which deters their market position. This would in the longer run have negative 
effects on the competition in the postal sector.   

The evaluation concludes that the compensation fund is not very cost efficient, because 
benefits do not outweigh the cost.  

Complaints 

Whereas  universal  service  providers  in  17  Member  States  did  measure  and  publish 
indicators on complaints in 2018, in five Member States there was only a requirement to 
measure (not publish), and in six Member States there was no such requirement at all.194 
Accountability and transparency promote a more efficient and reliable dispute resolution 
and  enable  the  wider  public  and  stakeholders  to  monitor  how  qualitative  the  universal 
service  has  been  provided  to  the  users.  As  there  is  quite  a  variety  in  reporting  on 
complaints the provisions of the Directive on this matter could be more explicit so that 
there is a more uniform approach in all Member States.  

The mandatory complaint handling standard EN 14012, which requires that a maximum 
time for response to the complainant shall be defined (but does not recommend the time 
scale), is not applied in all Member States.195 The standard also provides guidelines for 
compensation procedures and damage compensation. The standard is only applied by 14 
Member  States.196  If  Member  States  were  urged  to  oblige  their  universal  service 
providers  to  apply  standard  EN  14012,  this  would  contribute  to  reinforcing  consumer 
confidence in the postal sector and to correctly addressing their claims.  

The  Directive  provides  that  complaints  be  available  to  “users”  (which  are  according  to 
the definition “senders and addressees”), but in many Member States the receiver (who in 
the case of e-commerce, has  a contractual relationship with the provider, not the  postal 
operator) does not have a real option to launch a complaint. This is particularly relevant 
in  case  of  parcel  deliveries  where  the  receiver  may  suffer  from  damages  to  the  parcel 
received.  The  benefit  to  users  would  increase  if  the  rights  of  the  recipients  were  more 
explicitly  taken  into  account.  This  seems  to  be  supported  by  the  public  consultation 
where of the 28 consumer respondents that filed a complaint 16197 were not satisfied with 
the handling of complaints by universal service providers and postal operators. The main 
reasons given are the very long time for processing complaints, or the fact that the postal 
operator do not provide any reply to the complaint. 

193  WIK (2021), page 211: A universal service provider with inefficient postal operations and low level of 
commercial  success  has  a  much  higher  risk  of  facing  problems  to  sustainably  finance  the  universal 
service obligation. Sharing the burden among other operators with greater commercial success, such as 
express operators, may be understandable from the view of the national treasury, but sets low incentives 
for the universal service provider for improving its efficiency. More importantly, it negatively affects 
the competitive situation of competitors that have to contribute to the fund. 

194  European Regulators Group for Postal Services PL II (19) 35, p. 51. 
195  European Regulators Group for Postal Services (2019) PL II (19) 35 and WIK (2021) p. 303. 
196  WIK (2021), page 303, Application of technical standard for complaint procedures EN 14012 
197  How satisfied were you with the way in which your complaint was handled? EU citizens replied: I was 

not satisfied (14 citizens) and I was slightly dissatisfied (two citizens). 

58 

 
 
                                                      
5.3  Coherence 

Q1:  To  what  extent  is  the  Directive  internally  coherent  as  well  as 
coherent  with  the  Regulation  on  cross-border  parcel  delivery 
services? 

The  Directive  is  internally  coherent.  Stakeholders  did  not  express  themselves  on  the 
Directive’s internal coherence. Possible frictions between the principles of affordability 
and cost orientation for tariffs should be further assessed. 

The provisions of the Directive are consistent with each other and their articulation help 
ensure  the  achievements  of  the  Directive  main  objectives.  Their  interaction  is  already 
explained in the intervention logic. In particular, the articles on the scope and features of 
the universal service are clearly interlinked and consistent with each other. The scope of 
the  universal  service  and  its  evolution  in  response  to  technical,  economic  and  social 
environmental  developments  and  the  needs  of  users  are  to  be  considered  together.  The 
provisions on the financing, accounting and the guidance on calculating the net cost are 
complementary  to  each  other  to  ensure  there  is  no  cross-subsidisation.  The  only 
exception regarding full consistency concerns the principles underpinning the Directive’s 
rules on tariffs. The Directive requires prices of postal services to  comply with the two 
principles of affordability and cost orientation. The principle of affordability requires that 
letter mail tariffs are affordable to all users. The principle of cost-orientation requires that 
tariffs are geared to the costs of an efficient universal service provider. Cost-orientation 
in this sense is in principle the “cost of efficiency" defined as long run incremental costs 
including common costs and a profit-mark-up.  

Compared  to  2008,  the  unit  cost  for  letter  mail  has  increased  significantly  and  in  such 
circumstances the cost orientation principle can be a driver for higher prices and not for 
limiting  them.  At  first  sight  this  might  create  a  conflict  between  the  principles  of 
affordability  and  cost  orientation  as  the  national  regulatory  authority  should  aim  at 
limiting  price  increases  for  postal  users.  However,  as  illustrated  in  Section  5.1  Q1,  in 
reality even with cost based tariffs, prices are still at level where they do not conflict with 
the affordability goal. 

The Parcel Regulation builds on and complements, insofar cross-border parcel delivery 
services  are  concerned,  the  rules  set  out  in  the  Directive  in  relation  to  regulatory 
oversight,  transparency  and  assessment  of  tariffs.  The  Parcel  Regulation  in  particular 
increases  the  transparency  of  single-piece  tariffs  for  certain  items  and  provides  for  an 
assessment procedure to identify tariffs that are “unreasonably high.” In that assessment 
the  Parcel  Regulation  refers  to  the  principles  of  affordability  and  cost-orientation  as 
established in the Directive. The Regulation builds in general on the definitions from the 
Directive, and its provisions foresee that the national regulatory authorities established by 
the Directive undertake an assessment of certain universal service parcels.  

59 

 
 
Q2:  To  what  extent  is  the  Directive  coherent  and  complementary  with 
legislation  and  horizontal  policy  as  well  as 

other  EU-level 
international postal policy?  

The Directive is generally coherent and complementary with other legislative initiatives 
impacting on the postal sector, in the field of VAT, customs, services, road transport and 
consumer  rights.  With  regard  to  its  consistency  with  the  main  policy  objectives  at  EU 
level, certain features of the universal service obligations such as the delivery frequency 
might  interlink  with  the  EU  Green  Deal  objectives.  In  addition,  certain  features  of  the 
Directive such as improving cross border delivery might interlink with EU objectives in 
digital  markets.  As  the  postal  sector  is  labour-intensive,  actions  on  employment  and 
working  conditions  developed  under  the  European  Pillar  of Social  Rights  may  have  an 
impact on the functioning of postal market legislation. 

Several EU level instruments touch upon different aspects covered by the Directive or are 
potentially relevant for the provision of postal services. A few stakeholders in replies to 
open  questions  and  position  papers  have  mentioned  the  importance  of  regulatory 
coherence between the Directive and some of these, in particular with  Regulation (EU) 
2018/644; from these few interventions, it cannot be concluded that it would be required 
to  include  specific  non-postal  aspects  in  sectoral  legislation.  Most  of  them  entered  into 
force  after  2008  and  usefully  complemented  the  application  of  the  Directive.  This  is 
particularly  the  case  of  the  Services  Directive198,  Road  Transport,  Consumer  Rights199 
and standardisation. In the case of the VAT-Directive200 that allows to exempt universal 
postal  services  from  VAT  there  is  to  the  extent  that  this  constitutes  a  special  right  a 
limited discrepancy to the Directive that has abolished all special rights201.  

In addition the Directive should also be assessed for its coherence and complementarity 
with broader policy objectives for the EU. 

Green Deal 

Environmental  protection  is  listed  among  the  essential  requirements  that  may  induce  a 
Member State to impose specific conditions on the supply of postal services. A majority 
of  postal  providers  in  the  EU  have  undertaken  measures  to  limit  the  negative 
environmental impacts of postal service provision. However the environmental footprint 
of  mail  and  parcel  delivery  linked  to  the  collection,  sorting,  transport  and  delivery  and 
the  universal  service  obligations  to  deliver  certain  services  at  certain  frequencies  and 
speed, could cause potential tensions with the objective of the EU Green Deal objectives 
to  reduce  greenhouse  gas  emissions  by  at  least  55  percent  by  2030202  and  to  become 

198  Directive  2006/123/EC  of  the  European  Parliament  and  of  the  Council  of  12  December  2006  on 

services in the internal market (“Services Directive”). 

199  Consumer Rights Directive, ADR and ODR. 
200  VAT exemption under Article 132 (1a) of the Directive on a common system of VAT (recast Directive 

2006/112/EC). 

201 For more details see Annex 5. 
202  Regulation  No  561/2006  as  amended  by  Regulation  No  165/2014  as  interpreted  by  the  Court  in  C-

374/18 (UPS ./. Deutsche Post). 

202  PostEurop has informed in their position paper that the aim of universal service providers is to reduce 

carbon emissions for letter and parcel by 20 percent by 2025, from a 2013 baseline year. 

60 

 
 
                                                      
climate-neutral  by  2050.  Maintaining  a  high  delivery  frequency  in  a  sector  with  steep 
letter  volume  decline  would  increase  the  environmental  footprint  per  letter.  Only  20 
percent of the respondents to the public consultation considered that the Directive was in 
line with environmental regulations, though 76 percent considered that the postal sector 
has contributed to the fight against climate change.203 

Digital Single Market 

Ending  unjustified  cross-border  ecommerce  barriers,  improving  cross-border  parcel 
delivery services, protection of online customer rights and promoting cross border access 
to  online  content  are  cornerstones  of  the  Digital  Single  Market  Strategy.  A  new 
regulatory  framework  on  geoblocking  entered  into  force  on  3  December  2018204.  This 
framework  tackles  discrimination  against  consumers  and,  in  limited  cases,  against 
businesses, based on their nationality, place of residence or establishment when they buy 
goods or services online. The Report by the Commission on the first short-term review of 
the  Geoblocking  Regulation  of  30  November  2020205  concluded  that  the  potential 
discriminatory effects of certain traders’ practices such as deliberately limiting delivery 
options  for  certain  products  or  websites  in  countries  otherwise  served  by  the  trader 
without any objective justification not directly addressed by the Geoblocking Regulation 
may  still  be  subject  to  case-by-case  scrutiny;  consequently  further  guidance  may  be 
needed.  

Digitisation  has  resulted  in  an  increasing  number  of  online  platforms  that  facilitate  the 
delivery  process  for  their  users  and  provide  tailored  made  delivery  management 
solutions.206  While  a  gateway  position  of  online  platforms  enables  them  to  organise 
millions of users, it may also open up for the possibility for unilateral trading practices 
that might be harmful in certain circumstances. To address these concerns, the Platform 
to Business Regulation207 was adopted on 20 June 2019. This Regulation aims at taking 
action against unfair contracts and trading practices in the platform-to-business relations. 
The Commission’s proposed Digital Market Act also aims at tackling unfair practices of 
gatekeepers.208  

It will be important to explore whether synergies can be made from further aligning EU 
postal  and  delivery  priorities  and  objectives  with  those  of  the  digital  single  market 

203 2020 Public consultation on the evaluation of the Postal Services Directive. See summary in Annex 2.  
204  On  30  November  2020,  a  Report  was  published  by  the  Commission,  where  it  appeared  that  the  first 
months of implementation by national enforcement and assistance bodies showed that, when it comes 
to disputes and problems, consumers have often greater expectations about the rights and obligations at 
stake. These expectations were especially high for the denial of cross-border delivery, or the absence of 
delivery  options  for  certain  countries,  especially  by  multinational  traders.  Obligations  in  these  areas 
were not provided for in the Geoblocking Regulation. 

205  Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee and the Committee and the Committee of the Region on the first 
short-term review of the Geo-blocking Regulation, COM(2020) 766 final of 30.11.2020. 

206  See for example: https://www.parcelhub.co.uk/.  
207  Regulation  (EU)  2019/1150  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on 
promoting  fairness  and  transparency  for  business  users  of  online  intermediation  services  (Text  with 
EEA relevance), OJ L 186, 11.7.2019, p. 57–79 

208  See 

for 

further  details:  https://ec.europa.eu/info/strategy/priorities-2019-2024/europe-fit-digital-

age/digital-markets-act-ensuring-fair-and-open-digital-markets_en.  

61 

 
 
                                                      
especially in the area of cross-border e-commerce, or whether one framework may create 
tension with the other.  

65  percent  of  the  business  respondents  to  the  public  consultation  considered  that  the 
Directive  were  largely  or  partly  in  line  with  the  Digital  Single  Market  Strategy  and  its 
subsequent policies, while only 11 percent of the responding consumers and 30 percent 
of the public authorities agreed.  

Competition rules 

Ensuring  the  sustainability  of  the  universal  service,  and  thus  the  compensation  of  the 
possible net cost associated with it, commonly involves State aid in accordance with the 
Framework for State aid on Services of General Economic Interest209. The Directive and 
the State aid  framework  are complementary  and ensure that universal  service providers 
are not overcompensated by the State or that any such State aid distorts competition. 

Social and territorial cohesion 

The  Directive  with  its  ubiquitous  universal  service  obligation  contributes  to  one  of  the 
objectives of the social and territorial cohesion policy by enhancing access to and use and 
quality of postal services. It should particularly be noted that maintaining uniform tariffs 
for certain postal items is explicitly motivated by regional and social cohesion210. 

Employment 

The 2008 amendment to the Directive introduced211 general non-economic reasons which 
can  cause  a  Member  State  to  impose  conditions  on  the  provision  of  the  universal 
service212.  This  provision  is  as  such  coherent  with  EU  labour  law,  while  respecting 
national law and collective agreements by social partners. The Directive does not affect 
labour law related to legal or contractual provisions on employment conditions, working 
conditions, including health and safety at work and the relationship between employers 
and  workers,  which  Member  States  apply  in  accordance  with  national  law  and  in 
conformity  with  EU  law.213  As  the  postal  sector  is  labour-intensive,  actions  on 
employment  and  working  conditions  developed  under  the  European  Pillar  of  Social 
Rights214 may have an impact on the functioning of postal market legislation.215 

209  Commission of Decision 20 December 2011 on the application of Article 106(2) TFEU on State aid in 
the form of public service compensation granted to certain undertakings entrusted with the operation of 
Services  of  General  Economic  Interest,  OJ  L  7,  11.1.2012,  p.  3-10,  and  Communication  from  the 
Commission  — European Union framework  for State aid in the  form of public service  compensation 
(2011), OJ C 8, 11.1.2012, p. 15–22.  
210  See recital 38 of Directive 2008/6/EC. 
211  One of the reasons is the respect for the terms and conditions of employment, social security schemes, 
laid down by law, regulation or administrative provision and/or by collective agreement negotiated by 
national social partners, in accordance with Community and national law. 

212  Moreover,  in  Article  9(2),  where  necessary,  Member  States  may  reflect  working  conditions  in  their 
authorisation procedures in line with national legislation. As Section 5.3.Q2 focuses on coherence with 
EU legislation, this particular provision, which has to be in line with national law, is not highlighted in 
the text. 

213  The 2008 amendment to the Directive, recital 53. 
214  https://ec.europa.eu/info/european-pillar-social-rights-0/european-pillar-social-rights-20-principles_en 
215  The European Pillar of Social Rights Action Plan adopted by the Commission on 4 March 2021, sets 

out concrete initiatives and headline targets for the EU to be achieved by 2030. 

62 

 
 
                                                      
Universal Postal Union and International Agreements 

The Universal Postal Union sets terminal dues, i.e., the remuneration between universal 
service operators for the delivery of cross-border letter mail and inward land rates for the 
delivery  of  cross-border  parcels.  In  the  past  the  very  low  terminal  dues  have  raised 
substantive  concerns  regarding  the  respect  of  the  cost-orientation  principle  of  the 
Directive.  This is because they did not reflect the actual cost of cross-border delivery for 
the  final  delivering  universal  service  operator.  This  also  impacted  negatively  on  EU  e-
commerce providers as the low terminal dues that EU universal service operators charge 
their counterparts in developing countries did not cover the costs for the provision of the 
last  mile  delivery.  In  September  2019  the  Universal  Postal  Union  Convention  was 
modified and terminal dues will now (till 2025) be based on so-called self-declared rates 
(that are linked to 70 percent of domestic single piece tariffs). This largely resolves the 
inconsistency  of  the  Universal  Postal  Union  Convention  with  the  cost  orientation 
principle  of  the  Directive.  Furthermore,  most  of  the  European  Union  Free  Trade 
Agreements  contain  provisions  on  postal  and  courier  services.  Amongst  other,  they 
prevent  discriminatory  practices  at  the  border  and  require  an  independent  regulatory 
authority. No coherence issue arises, as Free Trade Agreements provisions are based on 
the same principles as the Directive. 

Import VAT and customs issues 

Another element that could be considered as potentially incoherent with the rules of the 
Directive  will  eventually  be  eliminated  by  1  July  2021216.  This  concerns  the  so-called 
small consignment importation exemption, which exempts from the import VAT goods 
with a value up-to EUR 22217. These items, usually contained in letters or packets, also 
benefit from simplified customs procedures (use of UPU forms CN 22 and CN 23 instead 
of a formal customs declaration).  

Besides, for goods in postal consignments, such simplification applies up-to an intrinsic 
value  of  EUR  150  per  consignment.  This  simplified  procedure  will  be  abolished  in 
parallel.  From  1  July  2021,  the  abolition  of  the  “small  consignment  importation 
exemption”  and  the  extension  of  the  use  of  standard  customs  declarations  also  to 

216  Due to the practical difficulties created by the measures taken to contain the coronavirus pandemic, the 
application  of  the  VAT  e-commerce  package  was  postponed  to  1  July  2021:  Council  Decision  (EU) 
2020/1109 of 20 July 2020 amending Directives (EU) 2017/2455 and (EU) 2019/1995 as regards the 
dates of transposition and application in response to the COVID-19 pandemic (OJ L 244, 29.7.2020, p. 
3–5);  Council  Regulation  (EU)  2020/1108  of  20  July  2020  amending  Regulation  (EU)  2017/2454  as 
regards the dates of application in response to the COVID‐19 pandemic (OJ L 244, 29.7.2020, p. 1–2); 
Council Implementing Regulation (EU) 2020/1112 of 20 July 2020 amending Implementing Regulation 
(EU) 2019/2026 as regards the dates of application in response to the COVID-19 pandemic (OJ L 244, 
29.7.2020,  p.  9–10);  Commission  Implementing  Regulation  (EU)  2020/1318  of  22  September  2020 
amending  Implementing  Regulations  (EU)  2020/21  and  (EU)  No  2020/194  as  regards  the  dates  of 
application in response to the COVID‐19 pandemic (OJ L 309, 23.9.2020, p. 4–6). 

217  This  elimination  is  also  addressing  the  problem  of  fraud  caused  by  a  previously  misused  VAT 
exemption for goods valued at under EUR 22 coming from outside the EU which can distort the market 
and create unfair competition. High value goods were often mislabelled in small packages as having a 
value under the threshold of EUR 22 in order to avoid the payment of import VAT and customs duty 
and to benefit from a simpler customs treatment. Such VAT losses are creating a gap of EUR 7 billion 
annually in the revenues of EU Member States. 

63 

 
 
                                                      
universal service providers will ensure full coherence with the Directive that requires the 
abolition of special and exclusive rights. 

However, the  subsequent obligation to complete a customs declaration may result in the 
universal  service  providers  charging  fees  for  acting  as  a  customs  representative  for 
consignments which so far were delivered without any supplementary charges. In some 
Member  States  consumers  are  not  informed  individually  about  their  right  to  clear  the 
postal consignment on their own and, in addition, fees charged by the  universal service 
providers amount to EUR 15 to 24 for consignments with values below EUR 150 without 
assessing their proportionality to  the service rendered. These practices  may raise issues 
from a consumer perspective and could possibly constitute an infringement of TFEU and 
customs law.  

5.4  Relevance 

Q1:   How  well  do  the  original  objectives,  scope  and  definitions  of  the 
Directive  still  correspond  to  the  needs  of  EU  postal  users  in  the 
current technical, economic and social conditions?  

Even if users needs’ have changed, continuing to regulate a minimal scope of universal 
service  continues  to  be  relevant,  albeit  the  products  included  and  related  features  and 
quality  requirements  might  need  to  differ  between  Member  States.  Promoting  a  well-
functioning and competitive  internal market  remains a valid and relevant  objective for 
postal users, undertakings and employees alike, both for the present and the foreseeable 
future. 

The  needs  of  those  who  use  postal  services  have  changed  to  some  extent  since  the 
universal service obligations were designed in 1997.218 Postal users today generally want 
to maintain the quality of service and other features they are used to, even though many 
could accept reductions in quality for a corresponding reduction in price. Recent surveys 
by national regulators show that it is still important for users in some Member States to 
send and receive postal items and this will in all likelihood remain so for the next five to 
ten years. For instance,  69 percent of the Belgian private persons would feel closed off 
from  the  outside  world  if  they  could  not  send  or  receive  any  mail  anymore.  In  case  of 
people  over  65  this  share  is  84%.  Vulnerable  users,  with  limited  mobility  or  a  visual 
impairment, who are not online-oriented, remain greatly dependent on postal services219 
Delivery of e-commerce parcels, medical supplies, cards, election and court documents is 
important today and will remain so in the future. 

218  The  assessment  of  current  and  future  users’  needs  was  based  on  WIK  (2021),  which  undertook  a 
comprehensive literature review and an online stakeholder survey answered by 419 postal stakeholders 
(331 business  senders,  their  associations,  and  consumer  associations,  44  regulators  and  44  operators, 
including 28 universal service providers). For more details, consult section 1.3 of Annex 4. 

219  WIK (2021), p.106 and 134, based on surveys in Belgium in 2017, Sweden in 2016 and 2018, Portugal 

in 2017, the Slovak Republic  in 2015, and the United Kingdom in 2012. 

64 

 
 
                                                      
Objective  1:  Guarantee  the  sustainable  provision  of  affordable  and  high  quality 
universal service to all users throughout the EU 

While overall individuals use letter mail less frequently than before, large senders such as 
public utility companies, financial institutions and public administration organisations, as 
well as small and medium sized enterprises still very much rely on letter mail for certain 
transactions  and  administrative  purposes.  Vulnerable  users  such  as  those  with  low 
income, lack of digital skills220, residence in remote and rural areas, and reduced mobility 
or disabilities, are also more likely than others to remain dependent on postal services. 

The  substantial  gap  between  urban  and  rural  broadband  penetration  rates  has  not 
decreased  between  2010  and  2019.  The  share  of  rural  households  that  subscribe  to 
broadband  varies  widely,  from  over  90  percent  in  Luxembourg  and  the  Netherlands  to 
less  than  50  percent  in  Bulgaria  and  Finland221.  The  specific  geographical  and  social 
circumstances  also  vary.  In  Member  States  such  as  Estonia,  Ireland,  Slovenia  and 
Romania more than half the population reside in rural areas.  

As  evidenced  by  a  recent  study  by  Citizens  Advice222,  letter  mail  continues  to  play  an 
important role for individual recipients, as missing letters can cause missing health-care 
services  benefits,  housing  and  employment  opportunities,  as  well  as  incurring  financial 
losses and debt. Over 40 percent of the persons who do not receive their letter mail have 
experienced  financial  losses  because  of  missed  letters.  On  average,  this  amounts  to 
around EUR 950 per person.223  

The WIK online survey shows that being connected to the postal infrastructure and able 
to send and receive postal items remains of particular importance for private and business 
users224.  Just  5  percent  of  the  respondents  to  the  Commission’s  public  consultation 
questioned  the  continued  relevance  of  the  universal  service  objective  of  the  Directive. 
However,  65  percent  of  the  respondents  believe  the  Directive  requires  adjustments, 
mostly companies – over 80 percent – and consumers – over 60 percent, while ten out of 
13 national regulators believe it is still necessary but requires significant changes.   

Based  on  available  evidence,  the  objective  of  setting  a  minimum  level  of  affordable 
today’s 
postal  universal  service  for 
circumstances.   

therefore  remains  relevant 

letter  mail 

in 

As  the  parcel  delivery  segment  functions  well  and  new  operators,  as  well  as  new 
technologies, continue to emerge, there appears to be no risk of market failure in terms of 
parcel  delivery,  more  specifically  what  concerns  e-commerce  delivery,  business  users 
and bulk parcels. The necessity of regulatory intervention can therefore be questioned225 

220  According to WIK (2021), p.126, 12 percent of EU citizens still lack the necessary digital skills to use 
the  internet  at  all  and  25  percent  of  those  who  use  it  report  low  levels  of  digital  skills,  which  could 
prevent them from replacing letters with digital solutions 

221  Digital Economy and Society Index (DESI) 2020, Thematic chapters, p.27. 
222  Citizens Advice (2020), Millions without Mail. 
223  Idem, p.21. 
224  WIK (2021), pp.134-6. 
225  As discussed in Section 6.1, most businesses selling online in the EU today can choose from at least ten 
parcel  delivery  operators.  E-commerce  shoppers  across  the  EU,  including  in  rural  areas,  often  have 

65 

 
 
                                                      
 
at  least  in  what  concerns  keeping  bulk  parcel  delivery  services  in  the  scope  of  the 
universal service.  

Conversely, it appears that providing for the possibility to keep single-piece parcels (the 
type of parcels sent by consumers) in the scope of the universal service in order to ensure 
a minimum level of affordable universal  single-parcel delivery service for all continues 
to be relevant, at least in certain Member States or regions.  

In sum, the extent of regulatory intervention in relation to the universal service will have 
to be further considered. This could include assessing possible changes in the definition 
and  application  of  a  minimal  set  of  basic  universal  services  to  all,  at  quality  levels 
tailored to the specific needs of every Member State/region.    

Table 9 Relevance of the universal service features and quality requirements, present and 
future 

Relevance of the universal service features and quality requirements from a users’ perspective 

                       Product 

Letters 

Parcels 

Feature 

Delivery across the 
entire territory of the 
country 

Accessibility of postal 
office/point of contact 

Delivery to the door 

Daily (weekdays, 5 
days/week) collection 
and delivery 

Speed of delivery 

Present 
relevance 

High 

Average, 
users report 
satisfaction with 
density, albeit 
varied 

High,  

for both private 
users and SME’s 

Important for 
business users 

More important 
for business 
users than 
consumers 

Future relevance 

Average 
– to be assessed with 
development of 
electronic alternatives 

Average, mainly for 
non-postal services 
and low-mobility 
users 

High, but relevance to 
be assessed with 
usage of mail 

Decreasing for 
consumers, likely to 
remain important for 
business users 

Decreasing for 
consumers, likely to 
remain the same for 
business users 

Present 
relevance 

High 

High 

High 

Future relevance 

Increasing 
along with the 
use of e-
commerce  

Increasing,  
need for longer 
hours and 
flexibility 

Increasing,  
demand for more 
flexibility and 
alternate 
solutions 

Increasing 

Increasing 

High,  
users prefer 
greater certainty 
of delivery times  

Increasing,  
demand for more 
flexibility and 
predictability in 
the delivery time 
(day and time of 
day) 

access  to  the  same  delivery  options  and  largely  pay  the  same  for  deliveries  of  goods  bought  online. 
Copenhagen Economics (2020), Principles of EU postal regulation and implications for  the future, p.7 

66 

 
 
 
 
 
 
 
 
                                                                                                                                                              
Affordable prices  

High 

Likely to stay the 
same 

Increasing  

High,  
for both 
consumers and 
business senders 

Source: WIK (2021), European Regulators Group for Postal Services226, 2020 public consultation 

Objective 2: Establish a well-functioning and competitive Internal Market 

The  level  of  concentration  in  letter  mail  markets  is  increasing  in  some  Member  States. 
The  most  notable  competitors  in  recent  years  have  either  exited  the  market  (e.g.,  in 
Belgium and Poland) or have been acquired by  the incumbent  (e.g., in  the Netherlands 
and  in  Italy).  The  recent  evolution  in  the  Netherlands  is  particularly  interesting  in  that 
respect.  Initially,  the  incumbent  PostNL’s  intention  to  acquire  its  largest  competitor  in 
the letter market (Sandd) was blocked by the Netherlands Authority for Consumers and 
Markets  on  the  grounds  that  it  would  re-establish  a  de  facto  mail  monopoly  in  the 
Netherlands.  This  decision  was  nevertheless  overruled  by  the  Dutch  Ministry  of 
Economic  Affairs  and  Climate  Policy  which  argued  that  the  acquisition  would  “ensure 
that  mail  delivery  remains  affordable,  available  and  reliable  in  a  sharply  shrinking 
market”227. This led to the de facto re-monopolization of the Dutch letter market228.  

In  its  2019  manifesto,  the  trade  association  of  European  public  postal  operators, 
PostEurop,  argue  that  the  relevance  of  the  current  objective  of  a  competitive  internal 
market  for  postal  services  should  be  reassessed  in  the  current  context  of  shrinking 
demand  for  letter  mail  and  significantly  changed  users’  needs,  and  be  balanced  against 
the objective of ensuring the sustainability of the universal service229. Universal service 
providers are concerned that cherry picking by competing operators would make it even 
more difficult to sustain the universal service which is already constrained by declines in 
letter  mail  volumes.  Based  on  available  information,  it  cannot  be  evidenced  that  such 
cherry picking practices have so far materialised  in  practice. Available, though limited, 
evidence suggests that in Member States where there has been some competition this has 
helped  stimulate  demand  and  supply  and  enabled  the  letter  mail  market  to  expand,  for 
instance  in  Germany  (2008)  and  the  United  Kingdom  (2006).  This  also  provided 
incentives for universal service providers to become more efficient and thus contributed 
to guaranteeing the universal service230.  

Importantly,  available  evidence  suggests  that  where  access  to  the  incumbent’s  network 
was  granted  under  transparent  and  non-discriminatory  conditions  to  different  types  of 
operators  and  consolidators,  postal  users  (especially  businesses)  have  benefited  from 
lower prices231. Ensuring the possibility and threat of competitive market entry therefore 
seems  to  provide  incentives  for  universal  service  providers  to  become  more  efficient, 

226  European  Regulators  Group  for  Postal  Services  (16)  36,  Report  on  Universal  Services  in  light  of 

changing postal end users´ needs. 

227  https://www.rijksoverheid.nl/actueel/nieuws/2019/09/27/onder-strenge-voorwaarden-vergunning-voor-

overname-sandd-door-postnl 

228  WIK (2021), p.36. 
229  PostEurop,  2019,  Delivering  a  Sustainable  European  Post,  the  manifesto  of  the  European  Postal 

industry setting out its priorities and goals for the new regulatory term, p.7.  

230  WIK (2021), p.280. 
231  Idem, p.285. 

67 

 
 
                                                      
offer  good  quality  at  lower  prices,  address  users’  concerns,  innovate  and  develop  new 
services.  

The  European  Regulators’  Group  for  Postal  Services  considers  that  promoting 
competition  in  letter  mail  markets  remains  a  valid  and  important  objective  to  pursue, 
especially  in  Member  States  and  markets  where  volumes  of  letter  mail  are  still  or  are 
likely to remain significant such as, for instance, bulk mail from large business senders 
and  public  administrations.  They  argue  that  the  focus  of  EU  regulation  in  this  field 
should  shift  from  protecting  the  postal  users  through  the  provision  of  the  universal 
service to ensuring the proper functioning of the postal markets, namely sufficient actual 
or potential competition232. 65 percent of the respondents to the open public consultation 
consider that the objective of ensuring competition in the postal markets is still relevant: 
over 90 percent of all responding regulators, 79 percent of all responding consumers, 55 
percent of the trade unions and 22 percent of the universal service providers.    

Based  on  available  evidence,  safeguarding  a  well-functioning  and  competitive  single 
market therefore remains a valid and relevant objective for postal users, undertakings and 
employees alike, both for the present and the foreseeable future. 

Objective 3: Having a general set of harmonised principles for the regulation of postal 
services  

The purpose of  establishing harmonized principles for the postal  services sector was to 
create a similarity of competitive conditions for postal operators across the EU, in order 
to facilitate the establishment of postal service providers and competition and to ensure 
that  postal  users  across  the  EU  enjoy  the  same  level  of  postal  services.  As  the  postal 
markets continue to be very diverse and evolve differently and because in many Member 
States the universal service providers are still controlled by the State, establishing a set of 
harmonised  and  unbiased  principles  at  EU-level  for  the  regulation  of  the  postal  sector 
remains more relevant than ever.  

Postal  services  is  a  network  industry  where  interconnection  and  interoperability  is 
essential.  Especially  the  harmonisation  of  the  technical  standards  related  to  the 
interconnection  of  parcel  networks  has  grown  in  relevance  along  with  the  increased 
demand  for  cross-border  parcels.  Lacking  or  divergent  standards  could  impact  on  the 
effective  and  efficient  cross-border  circulation  of  parcels  and  could  make  the 
comparability  of  the  operational  data  from  different  Member  States  very  complex  and 
costly.  

Q2:   How  relevant  are  the  provisions  of  the  Directive  for  achieving  its 
main  objectives  (i.e.,  related  to  universal  service,  internal  market 
and harmonised principles)?  

Some of the provisions  of the  Directive, particularly  on the scope  and features of the 
universal  service,  the  quality  parameters  thereof  or  provisions  related  to  market  entry 

232  European Regulators Group for Postal Services PL I (19) 12 Opinion on the review of the regulatory 

framework, p.7. 

68 

 
 
                                                      
may not be relevant in their current form. 

Definitions 

The  European  Regulators  Group  for  Postal  Services  have  indicated  that  certain 
definitions (such  as  those of  “postal  services”, “postal  provider”, “postal item”, “postal 
network” and “postal user”) are outdated and in need of adjustment due to technological 
and market evolutions. This was supported by a considerable number of Member States 
during  the  consultation  of  the  Postal  Directive  Committee.  During  the  public 
consultation,  the  postal  operators  favoured  preserving  the  current  definitions,  while  the 
majority  of  regulators  favoured  some  revision,  especially  for  the  concepts  of  “postal 
service” and of “postal provider”. Because most definitions date back to 1997, structural 
and  technological  changes  in  the  postal  sector  puts  into  question  their  relevance  and 
appropriateness.   

Universal Service product/service scope, features and quality 

The assessment shows that the current provisions on product/service scope and features 
and the quality of the universal service may not all be relevant in current circumstances 
to better achieve the objective of ensuring a universal service to all and may have to be 
reconsidered to  align with  users’ needs and expectations.  In this context,  reviewing the 
level  of  flexibility  needed  for  Member  States  to  adapt  to  domestic  circumstances 
therefore seems appropriate.  

Regarding the various features of the universal service, the relevance of the provision on 
ensuring  the  density  of  access  points  seems  to  be  confirmed  by  the  high  percentage  of 
users  that  see  a  dense  network  of  postal  outlets  as  indispensable  in  the  future.  WIK 
survey  respondents  from  Belgium,  Italy,  Hungary,  Portugal  and  Romania  rated  higher 
than  average  the  importance  of  maintaining  the  density  of  postal  outlets  over  the  next 
five  to  ten  years.  In  Austria,  France,  Germany,  the  Netherlands,  Poland  and  Spain,  the 
importance  of  keeping  the  current  density  of  postal  outlets  in  future  is  rated  below  the 
average  of  all  respondents233.  It  however  appears  that  individuals  are  willing  to  accept 
alternative  delivery  locations  for  parcels  in  addition  to  home  delivery,  and  are 
increasingly  interested  in  more  flexibility  and  alternative  options  for  the  delivery  of 
parcels (e.g., Poland, Portugal and Romania)234.  

Five-day  delivery  and  collection  for  letter  mail  has  decreased  in  importance  for  postal 
users235.  For  example,  postal  users  in  Belgium,  Ireland,  the  Netherlands  and  Sweden 
consider  reliable  and  predictable  delivery  services  (e.g.,  day-definite  delivery)  more 
important than overnight delivery or delivery on five days per week236. WIK users’ needs 
study  concludes  that  users  appear  ready  to  accept  reductions  in  delivery  frequency  in 
return  for  price  stability237.  Business  users,  especially  large  mailers  surveyed,  for 
instance,  in  Belgium,  Ireland  and  the  Netherlands,  are  more  reluctant  than  individuals 

233  WIK (2021), p.113. 
234  Idem, p.115. 
235  For example, Denmark, Estonia and the Netherlands; see WIK (2021), p. 215. 
236  WIK (2021), p.112. 
237  Idem, p.151. 

69 

 
 
                                                      
and  small  and  medium-sized  enterprises  to  accept  reductions  of  the  delivery  frequency 
for letters238.  

The importance of quality of services (transit time) for letter mail is changing. It remains 
very  important  for  transaction  mail,  office  mail  and  business-to-consumers/businesses 
parcels239, which account for the vast majority of the total postal service. Conversely, for 
individual  postal  users  transit  time  is  no  longer  the  dominant  parameter/factor  for 
determining quality of service. Volumes for priority letters in three large postal markets 
(France, Sweden and the United Kingdom) have decreased much stronger than for non-
priority mail240. In addition, users seem to value having a choice between a service with 
next day delivery and a cheaper postal product with longer transit times, as indicated by 
national  surveys  in  a  range  of  very  different  postal  markets  such  as  Belgium,  France, 
Ireland,  the  Netherlands  and  Romania241.  Adjustments  to  ensure  reliability  may  be  of 
greater relevance to this user group.   

Complaint handling 

Along  with  the  growth  in  e-commerce  the  number  of  user  complaints  has  been 
increasing,  especially  in  relation  to  e-commerce  shipments242.  As  more  providers  are 
involved in the cross-border parcel delivery process, users, and in particular receivers of 
parcels,  should  have  access  to  efficient  complaint  handling  mechanisms243.  The 
mandatory standard that lays down in detail the approach for the resolution of complaints 
is  only  used  by  the  universal  service  providers  in  half  of  the  Member  States.  The 
application  of  the  standard  should  make  the  complaint  resolution  procedure  more 
effective,  increase  user  satisfaction  and  confidence  to  use  postal  services.  Some  of  the 
non-mandatory provisions of the Directive, such as the one on compensation schemes for 
loss or damage and the one for out-of-court resolution schemes would most likely have a 
broader  impact  if  used  by  all  Member  States.  It  can  be  concluded  that  while  the 
provisions related to  complaint handling remain very relevant,  in  the current  form they 
are  not  sufficiently  specific,  do  not  ensure  consistency  in  application  and  could  be 
simpler.   

Tariff regulation 

Tariff regulation aims at identifying price levels that do not impose a significant burden 
on  consumers  (affordability)  while  ensuring  the  sustainability  of  the  universal  service 
obligation (cost-orientation). The assessment has demonstrated that the principles of cost 
orientation and affordability are not defined, which makes their application inconsistent. 
Also, their interplay may become contradictory in the future. The current provisions are 
also not relevant for the effective application of the cost-orientation principle on terminal 
dues.  

238  Idem, p. 109. 
239  Idem, p.110. 
240  Idem, p.237. 
241  WIK (2021), p. 238. 
242  Copenhagen Economics (2018), p.66 
243  According to WIK (2021), p.303, the mandatory standard on complaint handling principles (EN 14012- 
Postal  services  –  Quality  of  service  –  Complaints  handling  principles)  is  being  applied  in  only  14 
Member States. 

70 

 
 
                                                      
Competition 

The evaluation suggests that current provisions to enable market access under transparent 
and non-discriminatory conditions may not be relevant in their current form. In response 
to  the  public  consultation,  a  European  association  representing  non-universal  service 
operators, Free & Fair Post, called for more concrete provisions regarding market access 
and a stronger role for national regulators to ensure a proper enforcement of the existing 
provisions, such as the access provisions, the tariff principles and the fair designation of 
the universal service provider.  

The assessment has shown that procurement procedures have hardly been used to date for 
ensuring  universal  service  provision  although  in  principle  public  procurement  can 
encourage competition. Despite the fact that letter mail volume is declining it cannot be 
excluded  that  public  procurement  could  still  be  a  relevant  means  to  encourage 
competition,  especially  in  Member  States  and  for  market  segment  where  letter  mail  is 
still important.  This would have to be further assessed. 

Based  on  the  very  limited  evidence  available,  it  appears  that  the  guidance  for  the 
calculation of the net  cost  of the universal  service remains relevant  but  that  it could  be 
simplified.  

The  provision  granting  Member  States  the  possibility  to  finance  the  universal  service 
integrally  from  the  State  budget  has  been  the  option  favoured  by  over  70  percent  of 
universal  service  providers,  67  percent  of  trade  unions  and  52  percent  of  consumers  in 
the  public  consultation.  Only  27  percent  of  national  regulators  share  this  opinion. 
National  regulators  rather  favour  a  combination  of  contribution  by  the  State  and 
contributions by consumers and competing postal operators. As explained in section 5.2, 
other  options,  such  as  a  compensation  fund,  appear  to  have  become  a  less  efficient 
compensation mechanism and therefore less relevant in the present form.  

Harmonising technical standards 

The  rapid  increase  in  cross-border  parcel  deliveries  requires  full  inter-operability  of 
parcel  delivery  services  through  common  rules  for  the  management  of  the  increasing 
volumes of data generated in the process. The provision on common technical standards 
therefore remains relevant. 

Independent national regulatory authorities 

The  actions  of  the  independent  national  regulators  are  instrumental  for  ensuring  the 
application and enforcement of the Directive and for monitoring the postal sector. They 
moreover act on issues  where the Directive leaves room of manoeuvre for  the Member 
States. The relevance of national regulators will remain high going forward as they will 
continue  to  ensure  an  as  consistent  as  possible  application  and  enforcement  of  the 
Directive in  a changing  market  context.  Even more so if  additional responsibilities and 
powers are granted as a result of a future revision of the Directive. 

71 

 
 
Q3:   In the context of the new developments in the postal markets, are 
there  other  relevant  objectives  for  regulatory  intervention  at 
European level in the field of postal services?  

Stakeholders have not singled out other relevant objectives for regulatory intervention at 
EU level specific to the postal sector.  

The European Regulators Group for Postal Services244 argues in an opinion published in 
2019 that in view of the fundamental changes in society and the market, the postal sector 
needs a completely new regulatory framework, a so-called “greenfield approach” rather 
than  only  a  small,  targeted  revision  of  the  Directive.  The  regulators  question  the 
proportionality of the universal service, and recommend that it should be provided only 
in case of manifest market failure. This is echoed by a study commissioned by an express 
operator,  which  concludes  that  future  postal  regulation  must  “start  from  the  current 
situation,  considering  all  changes  in  the  market  and  regulatory  context  since  its  last 
revision and, in particular, any market failures that still exist and might warrant continued 
or revised regulation”245. 

The Member States represented in the Postal Directive Committee (an equal proportion 
of  Ministries  and  regulators  in  charge  of  postal  services)  were  split  on  the  issue  of  a 
“greenfield approach” but unanimously supported the relevance of the universal service. 
They also indicated a number of other issues that would have to be considered, but not 
necessarily  addressed  within  the  postal  framework:  digitalisation,  environmental 
footprint, consistency with the Green Deal and employment conditions in the sector.  

Many  stakeholders,  especially  consumers,  e-retailers,  and  social  partners  highlight  that 
environmental  sustainability  and  carbon  emissions  reduction  are  relevant  objectives  for 
the postal  sector. While postal  operators, and several  Member States represented in  the 
Postal  Directive  Committee,  recognize  that  environment  and  climate  change  are 
important policy objectives for the postal sector, they argue that horizontal legislation is 
already in place at EU level and sector-specific regulation is therefore not justified.  

5.5  EU Added Value 

Q1:   Would  the  benefits  delivered  by  the  Directive  have  been  achieved 

in the absence of EU-level intervention? 

In addition to safeguarding the postal universal service for all EU citizens, the Directive 
has made at least two significant contributions to the postal sector that are not likely to 
have happened in its absence: the opening of the postal markets and the improvement of 
postal service quality. 

244  European Regulators Group for Postal Services PL I (19) 12. 
245  Copenhagen Economics (2020), p.8. 

72 

 
 
 
                                                      
By  2008  the  EU  postal  markets  were  slowly  progressing  towards  market  opening  and 
competition246 with only a few Member States having opened their postal services market 
more than what was required by the 1997 and 2002 Directives. In the absence of the 2008 
Directive,  it  is  far  from  certain  that  the  EU  would  have  achieved  the  current  level  of 
market opening in letter mail in all Member States.247  

The Directive has also secured the continuation of the universal service provision across 
the EU after the opening of the market. Even if some form of postal universal service was 
available  in  all  Member  States  at  the  time  of  the  adoption  of  the  1997  Directive,  the 
combination of the opening of the market combined with the drop in volume could have 
led  to  the  interruption  or  decrease  in  the  universal  service  because  of  competitive 
pressures  or  profitability  constraints.  Servicing  less  profitable  areas,  such  as  rural,  less 
populated  regions  or  servicing  vulnerable  users  could  have  been  reconsidered  or  could 
have been provided at higher, possibly discriminatory prices. Alternatively, the universal 
service  may  have  been  kept  in  place  in  many  Member  States,  but  compensated  by 
granting  the  universal  service  provider  monopoly  rights  on  some  parts  of  the  market, 
during the period preceding the 1997 Directive. 

Regarding  the  quality  of  postal  services,  the  Directive  had  the  most  obvious  positive 
impact on the level of cross-border quality standards for universal postal services. While 
a Member State may require postal operators in its own country to comply with quality 
standards,  it  has  no  competence  to  impose  standards  abroad,  to  incentivize  foreign 
operators  or  sanction  them  in  case  of  under-performance.  Although  it  is  possible  that 
several  EU  operators  would  have  agreed  bilaterally  on  quality  standards,  it  is  doubtful 
that  EU-wide  quality  standards  for  cross-border  postal  services  would  have  been 
established  and  respected  on  a  voluntary  basis.  Action  at  the  EU  level  has  thus  been 
necessary to improve and ensure more consistency of quality of cross-border mail across 
the Union.248  

Intervention  at  EU  level  was  also  instrumental  in  securing  high  quality  in  domestic 
universal  postal  services as cross-border quality  requirements have had a positive spill-
over  effect  on  overall  quality-levels.  The  majority  of  respondents  to  the  Commission’s 
public  consultation  believes  the  Directive  was  successful  in  achieving  its  objectives 
regarding improving the quality of service, integrally or partially. This is particularly true 
for  the  postal  operators  which  almost  unanimously  take  the  view  that  better  quality  of 
domestic  and  cross-border  services  has  been  achieved  by  the  Directive.  Almost  all 
regulators are of the same opinion. Consumers, are more critical, with 45 percent and 29 
percent  respectively  thinking  that  better  quality  for  domestic  and  cross-border  services 
has not been achieved. Consumers were, however, poorly represented in the consultation.  

246  Prior to the adoption of the first Directive postal services markets were, with only few exceptions, not 
liberalised.  Sweden  and  Finland  had  completely  opened  their  postal  services  sector  to  competition 
already in the first half of the 1990ies but only a few other Member States had opened their letter mail 
market (Germany, Denmark, Spain and the United Kingdom). 

247  Especially since, absent the Directive, it is not certain that any EU level legislation would be in place.  

The 1997 Directive was set to expire in 2008. 

248  WIK (2021), pp.241-242. 

73 

 
 
                                                      
Complaints  relating  to  cross-border  services  would  have  been  more  difficult  to  address 
without the Directive, since  postal users are not  always  able to determine which postal 
operator is responsible for what went wrong.  

Q2:   What  would  be  the  most  likely  consequences  of  withdrawing  the 

Directive? 

During the consultation of the Postal Directive Committee, national regulatory authorities 
confirmed that they still consider it necessary to keep a certain level of postal universal 
service.  The  COVID-19  pandemic  has  contributed  to  an  increased  necessity  to  ensure 
universal  service  coverage.  During  the  crisis,  several  Member  States  used  the  postal 
network  to  deliver  protective  equipment  or  information  across  the  national  territory, 
some universal service providers also extended their services to delivery of medicine and 
checking on elderly persons living in rural areas. Even if the Directive were withdrawn, 
many Member States would most likely keep in place the postal universal service. What 
is  less  certain  is  whether  the  same  level  of  quality  would  still  be  ensured  and  whether, 
under  pressure  to  finance  the  universal  service,  Member  States  may  not  reintroduce 
reserved areas or other advantages for the universal service provider, thus reversing the 
opening of the market.  

In  the  absence  of  common  European  requirements,  the  level  of  ambition  could  vary 
widely  among  Member  States  in  what  concerns  the  products  included  in  the  scope 
(weight-limits  for  parcels,  bulk  mail,  direct  mail,  newspapers),  the  quality  required 
(network density, frequency and speed of delivery) and the level of affordability ensured. 
The  lack  of  a  harmonised  EU-level  framework  would  therefore  prove  detrimental  as 
fragmentation  would  increase  with  time,  interoperability  might  suffer,  especially 
concerning  cross-border  parcel  delivery.  In  the  absence  of  common  definitions  and 
mandatory  measurement  standards,  the  oversight  of  the  EU  postal  sector  would  also 
become difficult.  

Moreover, a withdrawal of the Directive would also eliminate rules that are intended to 
ensure  the  level  playing  field  and  protect  the  non-universal  service  providers.  For 
example,  the  accounting  provisions  are  intended  to  prevent  cross-subsidies  from  the 
universal  service  to  competitive  services.  Furthermore,  the  Directive  explicitly  ensures 
that  the  financing  of  the  universal  service  net  cost,  if  any,  is  made,  in  case  a 
compensation  fund  is  set  up,  only  from  undertakings  that  provide  services  within  the 
universal service scope. Equally in the absence of any rules on access and special tariffs 
it is possible that such issues would only be addressed via ex-post competition cases. As 
COVID-19  has  shown  the  essential  nature  of  postal  services,  it  would  not  seem 
opportune to take away  the basis for regulatory  oversight, particularly in the context of 
rapidly  changing  cross-border  postal  market  with  new  players  that  are  gaining  market 
dominance in some Member States. 

74 

 
 
 
6.  CONCLUSIONS 

The  evaluation  has  examined  whether  the  Directive  has  achieved  its  objectives  as 
intended and whether it is still fit for purpose, namely apt to respond to the needs of EU 
citizens  and  businesses.  The  assessment  focused  on  the  Directive’s  key  elements:  the 
universal service obligation (including its scope) the designation of the universal service 
providers, the financing of the universal service, the quality of services and the regulation 
of tariffs. The assessment also evaluated the effect of the Directive on market opening of 
national postal markets.   

The  evaluation  builds  on  a  number  of  studies.  The  WIK  study  on  postal  users’  needs, 
which  is  an  important  source  of  information  underpinning  this  evaluation  builds  on 
information  collection  and  review,  desk  research  and  stakeholder  interaction  and  is 
chiefly  based  on  qualitative  analysis.  Further  consultation  activities  carried  out  by  the 
Commission with different stakeholders have been used to gather additional evidence and 
to  cross-check  information  from  different  sources.  However,  the  Commission’s 
consultations  and  other  surveys  were  based  on  a  limited  number  of  responses.  This  is 
particularly  the  case  for  the  public  consultation.  The  level  of  quantification  in  the 
analysis is also substantially constrained by the availability of relevant data. This affects 
especially the efficiency section and the establishment of a causality link between market 
developments and the Directive. It also affects the robustness of some of the conclusions 
drawn  in  the  analysis  especially  when  it  comes  to  user  needs  and  user  satisfaction  for 
which evidence at EU level remains sometimes weak.  

Based on the assessment  and  available evidence  presented in  the previous sections and 
annexes  to  this  Staff  Working  Document,  this  section  presents  the  conclusions  on  the 
evaluation of the Directive. Although it is beyond the scope of this evaluation to provide 
any policy conclusions or propose follow-up actions to take, this section also highlights 
the  lessons  learned  regarding  the  main  areas  with  potential  to  improve  the  EU’s  postal 
services policy for the future.  

6.1  Conclusions on the fitness of the Directive  

The  Directive  pursues  three  principal  objectives:  (i)  guaranteeing  the  provision  of 
affordable,  high-quality  universal  postal  service  to  all  users;  (ii)  establishing  a  well-
functioning  and  competitive  internal  market  for  postal  services;  and  (iii)  establishing 
harmonising principles for the regulation of postal services. Based on available evidence, 
this evaluation shows that not all of the expectations set out in 2008 were met and that 
the  Directive  has  only  partly  delivered  on  its  objectives.  The  requirements  of  the 
Directive are overall coherent, relevant, and have brought EU value added. Nonetheless, 
a  number  of  issues  relating  to  changes  in  users’  needs  and  to  the  design  of  certain 
provisions limit the effectiveness and efficiency of the Directive. Changing users’ needs 
(also  stemming  from  new  opportunities  brought  by  innovation  and  developments  of 
technology)  also  call  into  question  whether  certain  specific  provisions  of  the  Directive 
are still relevant. Specifically:  

  Effectiveness:  The Directive has broadly been effective in ensuring the provision of a 
universal  postal  service,  in  particular  with  regard  to  the  frequency  and  timeliness  of 
delivery,  to  all  citizens  and  businesses  across  the  EU.  Digitisation  in  the  form  of  e-

75 

 
 
government  and  increased  use  of  digital  communication  means,  however,  has  led  to 
diminishing demand for letter mail, which in turn has increased the costs of universal 
service  provision.  To  address  this  phenomenon,  11  Member  States  have  relied  on 
derogations  allowed  by  the  Directive  and  reduced  the  scope  of  the  universal  service 
obligation, notably by narrowing the relevant letter mail products and services subject 
to  universal  service  as  well  as  reducing  the  frequency  of  delivery  of  postal  items. 
These derogations appear to increasingly become broader in scope. Derogations were 
not  intended  for  a  generalized  application.  This  suggests  that  requirements  in  the 
Directive  may  not  be  fully  aligned  with  current  market  expectations.  The  quality 
(transit  time)  of  universal  services  has  gone  down  and  price  for  letter  mail  has 
increased  as  a  result  of  increases  in  costs  for  universal  service  providers.  From  this 
perspective, the Directive has not fulfilled the expectations set in 2008 when the last 
amendment to the Directive was adopted. Available evidence on the application of the 
Directive’s tariff provisions suggests, however, that the Directive’s principles of cost-
orientation,  sustainability  and  affordability  have  likely  contributed  to  avoiding  even 
steeper price increases. That said, the evaluation highlights that Member States apply 
and  interpret  these  principles  very  differently  (and  sometimes  do  not  apply  all  of 
them)  and  that  the  interplay  between  the  principles  of  cost-orientation  and 
affordability requires further consideration. The assessment also indicates that national 
regulatory  authorities  may  not  have  the  required  tools  to  verify  if  and  how  these 
principles are respected.   

Available evidence suggests that the Directive has  been only marginally  effective in 
contributing  to  the  achievement  of  an  internal  market  and  stimulating  effective 
competition  (neither  within  Member  States  nor  among  Member  States)  in  the  letter 
mail segment and has not met the expectations underlying the 2008 amendment of the 
Directive.  The  main  reasons  seem  to  include  high  entry  costs  and  the  need  for 
substantial  economies  of  scale  and  scope  while  the  market  experienced  diminishing 
volumes.  However,  the  absence  of  harmonised  measures  for  access  to  the  postal 
network (i.e., tools allowing national regulatory authorities to set terms for access to 
the network thereby providing for the possibility to introduce ex ante competition) as 
well  as  the  absence  of  procedural  access  rules  (e.g.,  dispute  resolution  powers  of 
national  regulatory  authorities  for  situations  when  commercial  negotiations  break 
down  between  access  seekers  and  the  universal  service  provider)  may  also  have 
contributed to the low uptake of competition in the letter mail segment. With regard to 
the  parcel  delivery  segment,  competition  existed  already  before  the  adoption  of  the 
Directive. However, the inclusion of a limited number of parcel items in the universal 
service obligation has contributed to ensuring delivery to all users. 

Finally,  while  the  assessment  of  the  transposition  and  application  of  the  Directive 
show  that  there  are  divergences  among  Member  States  with  regard  to  the  level  of 
harmonisation of postal services, these divergences do not seem to have had a major 
disruptive effect on the effectiveness of the Directive and expectations motivating the 
decision to maintain minimum harmonisation in the 2008 amendment have from this 
perspective been met. The assessment suggests, however, that there is an insufficient 
use of technical standards, even when they are mandatory. 

  Efficiency:    The  assessment  suggests  that  the  Directive  is  not  fully  efficient.  The 
universal  postal  service  obligation  continues  to  protect  a  fundamental  means  of 

76 

 
 
communication and economic participation (including social and territorial cohesion) 
throughout  the  EU.  However,  in  light  of  the  available,  sometimes  limited  evidence, 
changes  in  users’  needs  suggest  that  benefits  of  the  Directive’s  quality  of  services 
requirements  have  been  declining  in  recent  years.  The  same  applies  to  the  broader 
benefits  to  society  of  universal  service  provision.  In  parallel,  some  of  the  costs  of 
providing universal  service have been increasing  over the last five to  ten  years. The 
assessment also has identified a number of provisions of the Directive, which appear 
to  generate  unnecessary  cost  and  burden  for  universal  service  providers  and  postal 
users  and  therefore  reduce  the  Directive’s  efficiency.  This  concerns  in  particular 
complaint handling and certain aspects related to the financing of the universal service 
obligation. 

  Coherence:  The  Directive  is  fully  internally  coherent  and  also  coherent  with  the 
Regulation  for  cross-border  parcels.  It  is  also  broadly  coherent  and  complementary 
with  other  relevant  EU-level  legislation  and  horizontal  policies  as  well  as  with 
international  postal  policy.  The  postal  sector  has  an  environmental  impact,  for 
instance through the frequency of delivery, and hence interlinks with the Green Deal 
objectives.  There  are  also  links  between  the  EU  postal  and  delivery  priorities  and 
objectives and those of the digital single market, especially in the area of cross-border 
e-commerce.  As  the  postal  sector  is  labour-intensive,  actions  on  employment  and 
working conditions developed under the European Pillar of Social Rights may have an 
impact on the functioning of postal market legislation. 

  Relevance:  Overall,  the  objectives  of  the  Directive  appear  to  be  appropriate  and 
relevant.  Even  though  the  postal  services  market  and  users’  needs  have  undergone 
significant changes, the principal objectives of the Directive seem to remain relevant. 
The  assessment  suggests  that  because  of  changing  users’  needs  and  market 
developments, however, certain provisions in the Directive may no longer be required 
(or not required in the current form) for achieving those objectives. This concerns in 
particular the scope and features of the universal service and the quality parameters of 
such services, as well as provisions to enable market entry and competition.  

  EU value added: Overall, the Directive has had added value because it has ensured a 
universal  postal  service  for  all  citizens  across  the  EU.  It  has  enhanced  the 
independence  of  national  regulatory  authorities  and  enabled  them  to  play  a  more 
prominent role in the oversight of the postal services sector. 

In  sum,  the  Directive  and  its  objectives  remain  important  for  the  EU.  But  there  are 
shortcomings  and  certain  provisions  seem  not  to  fully  match  current  expectations  of 
postal users and operators, and generate unnecessary costs and burden. 

6.2  Lessons learned  

The  following  points  summarise  the  lessons  learned  from  this  evaluation  in  terms  of 
main  areas  where  there  is  scope  for  improvement  in  EU  postal  services  policy.  These 
need  to  be  understood  within  the  above  overall  conclusion  that  the  Directive  has  only 
partly  delivered  on  its  objectives  and  that  there  are  some  shortcomings.  An  important 
lesson  for  future  work  is  the  need  for  further  consideration  of  how  to  ensure 
completeness  in  data  and  information  collection  in  a  more  comprehensive  way.  As 

77 

 
 
explained  above,  this  evaluation  does  not  put  forward  proposals  for  action,  but  takes 
stock of experiences gained. 

The universal service  

  The letter mail and parcel delivery segments have evolved very differently. While the 
relative  importance  of  letter  mail  in  certain  Member  States  should  not  be 
underestimated,  letter  mail  volumes  are  overall  significantly  diminishing  and 
competition  in  the  letter  mail  segment  is  very  low.  Conversely,  demand  for  parcel 
delivery is  continuously  increasing and the segment is characterized by the presence 
of a large number of actors (sometimes with new business models) that compete with 
each  other  (especially  for  e-commerce  delivery).  These  differences  have  been 
accentuated  during  the  COVID-19  pandemic.  User  needs  in  terms  of  the  universal 
service  and  corresponding  consequences  for  universal  service  providers  also  differ 
greatly  among  Member  States  and  will  continue  to  develop  in  different  ways  and  at 
different pace. 

  An important number of Member States are adjusting the universal service obligation 
to fit domestic needs in terms of scope of products and services offered, frequency of 
delivery  and  collection  and  there  seems  to  be  a  tendency  for  these  derogations  to 
become  very  broad  and  cover  a  large  part  of  the  population.  Derogations,  however, 
were intended for exceptional circumstances and exceptional geographical needs and 
not for a generalized application. Too many, and especially too extensive, derogations 
could further increase fragmentation, which in turn could make cross-border services 
more  costly.  Ultimately,  the  impact  of  parts  of  the  Directive  could  become 
significantly reduced. 

  Given  this  situation  there  may  be  a  case  for  reassessing  the  products,  services  and 
related features that need to be included in the universal service obligation, including 
the level of flexibility needed for Member States, and how they should be regulated.  
  More specifically the assessment could include the following: whether the inclusion of 
parcel  delivery  in  the  minimum  requirements  of  the  universal  service  obligation  is 
always optimal; the importance of five-day delivery for letter mail for users appears to 
be decreasing and the importance of transit time for letter mail has also decreased and 
for  non-business  postal  users  it  may  no  longer  be  the  dominant  parameter/factor  for 
determining quality of services. There is a question whether these parameters should 
be adjusted and/or other parameters should be added. 

  Better  calibrated  provisions  could  lead  to  better  and  more  consistent  regulatory 

outcomes in the future. 

Enabling market access and effective competition 

  Developments in the parcel delivery segment stand in stark contrast to developments 
in  the  letter  mail  segment.  As  opposed  to  letter  mail  where  the  statutory  monopoly 
was abolished with the 2008 amendment, there was never such a monopoly for parcel 
delivery. In most Member States the high level of competition in the parcel delivery 
segment  has  led  to  innovative  improvements  to  delivery  services.  Demand  is 
continuously  increasing  mainly  because  of  e-commerce,  and  frequency  and  options 
for delivery of parcel have not been reduced but rather evolved and increased. 

78 

 
 
  The evaluation shows that there is very little competition in the letter mail segment in 
all Member States. This seems to partly be due to market conditions, but there may be 
a case for reviewing access and price transparency provisions. This may be of special 
importance  in  Member  States  or  in  market  segments  where  volume  decline  is  less 
prominent.  Available  evidence  suggests  that  competition  where  it  has  occurred  has 
provided  incentives  for  universal  service  providers  to  become  more  efficient,  offer 
good  quality  at  lower  prices,  address  users’  concerns,  innovate  and  develop  new 
services. This needs further analysis and assessment. 

More consistency and greater harmonisation 

  The  Directive  requires  that  Member  States  ensure  that  the  tariffs  for  the  universal 
service  are  in  line  with  the  principles  of  cost  orientation,  affordability  and 
transparency. The assessment suggests that their application have been entirely left to 
the discretion of Member States since they are not defined in the Directive. This may 
reduce clarity, legal certainty and transparency around the use of these principles. 
  This  can have  a particular impact  in  relation  to  universal  service provider’s bilateral 
and  multilateral  agreements  for  the  delivery  of  cross-border  mail.  Virtually  none  of 
the  national  regulatory  authorities  has  any  instruments  to  verify  if  and  how  these 
principles are respected by the price postal providers in different Member States when 
charging  one  another  for  the  delivery  of  cross-border  postal  items.  This  may  have 
negative  effects  on  the  market,  including  the  e-commerce  sector.  As  the  volumes  of 
cross-border  e-commerce  deliveries  continue  to  rise  this  may  become  increasingly 
relevant.   

  The  assessment  suggests  that  a  review  of  the  principles  of  cost-orientation  and 
affordability principles along with the tools of national regulatory authorities to ensure 
the transparency of their use may increase the effectiveness of the Directive.   

  The  assessment  shows  that  insufficient  use  is  made  of  mandatory  and  voluntary 
technical  standards.  Even  where  technical  standards  stem  from  requirements  in  the 
Directive, their use is not coordinated and most often also not mandatory (even when 
a  standard  is  mandatory  it  is  not  always  used).  This  means  that  universal  service 
providers sometimes use different technical standards or possibly no standards at all. 
This  reduces  clarity  and  legal  certainty  and  may  lead  to  unnecessary  costs  and 
interoperability  issues.  Therefore,  there  may  be  a  case  for  assessing  the  use  of 
standards by postal operators. 

Simplification and burden reduction 

  Although  it  seems  that  the  complaint  procedures  required  by  the  Directive  do  not 
impose  or  constitute  a  significant  burden  for  universal  service  providers,  the 
assessment  suggests  that  its  benefits  to  postal  users  are  limited.  There  seems  to  be 
insufficient transparency provided on complaints, a lack of a harmonised approach to 
complaint handling and in some cases a limited availability of complaint procedures. 
This does not promote consumer confidence in postal services.  

  The examples provided suggest that the use of the complaint-handling standard is sub-
optimal which may erode consumer confidence. In the case of parcel deliveries, where 
the  complaint  procedure  is  not  mandatory,  the  receiver  may  suffer  from  damages  to 
the  parcel  received.  The  assessment  suggests  that  widening  the  complaint  handling 

79 

 
 
standards would enhance benefits for postal users and make procedures simpler, more 
efficient without substantial additional costs. 

  The  results  of  the  evaluation  suggest  that  there  may  also  be  scope  to  improve  the 
provisions on the financing of the costs of the universal service. This concerns mainly 
the provisions relating to the compensation fund, which is one option that can be used 
to fund the universal service. Such fund operates in a way that all providers of postal 
services (the universal service providers and any other postal services providers) in a 
given Member State have to contribute to finance the net cost of the universal service 
provision.  The  net  costs  of  universal  service  provision  can  be  substantial.  If  the 
universal service provider had to bear such costs on its own, it would put that provider 
in disadvantaged position vis-à-vis any competitors. The evaluation indicates that the 
current provision on the compensation fund is not a widely applied option and that the 
contribution  to  the  fund  from  alternative  postal  service  providers  is  often  small 
relative  to  the  universal  service  provider.  This  suggests  that  in  its  current  form  the 
provision on the compensation fund is not working in an optimal manner to fund the 
universal service. 

80 

 
 
 
7.  ANNEX 1: PROCEDURAL INFORMATION 

Lead DG 

  Lead DG: Directorate General Internal Market, Industry, Entrepreneurship and SMEs 

(DG GROW);  

  DeCIDE planning: PLAN/2019/5774;  
  Commission Work Programme 2020 (Adjusted Work Programme)  –  Annex II, Refit 

Initiative Nr.29.249  

Organisation and timing 

The evaluation was initially announced in the 2020 Commission Work Programme. In its 
adjusted  Work  Programme  adopted  in  May  2020,  the  Commission  indicated  that  the 
evaluation would not be finalised in 2020 but at a later stage.  The evaluation Roadmap 
was  published  on  2  March  2020  and  set  out  the  context,  purpose  and  scope  of  the 
evaluation  exercise.  22  stakeholders  provided  feedback  on  the  Roadmap,  most  of  them 
favourable to the proposed design of and way forward of the evaluation. 

A  public  consultation  was  launched  on  13  July  2020  and  concluded  on  9  November 
2020,  based  on  a  questionnaire  translated  into  all  EU  languages.  119  responses  were 
received  from  a  broad  range  of  stakeholders  including  users  of  postal  services,  postal 
operators,  social  partners,  representing  postal  employers  and  employees,  as  well  as 
national regulatory authorities. More details about the public consultations and about the 
other consultations that took place within the context of this evaluation can be found  in 
Annex 2.  

The  Inter-Service  Steering  Group  met  for  the  first  time  on  2  March  2020  and  gathered 
representatives  from  the  Secretariat  General,  the  Legal  Service,  Directorate  General 
Economic  and  Financial  Affairs,  Directorate  General  Competition,  Directorate  General 
Employment,  Directorate  General  Taxation  and  Customs  Union,  Directorate  General 
Justice  and  Consumers,  Directorate  General  Trade  and  the  Joint  Research  Centre.  The 
Inter-Service  Steering  Group  was  consulted  on  the  Roadmap  and  on  the  Consultation 
Strategy  and  was  informed of the summary  report  of the open public consultation. The 
Inter-Service  Steering  Group  met  five  times  to  discuss  the  consultation  strategy,  the 
questionnaire  for  the  public  consultation  and  various  drafts  of  the  evaluation.  It  was 
consulted  on  2  March  2020,  1  July  2020,  12  November  2020,  18  December  2020  (in 
writing) and 28 January 2021.  

Consultation of the Regulatory Scrutiny Board (if applicable) 

An upstream meeting with the Regulatory Scrutiny Board took place on 6 October 2020. 
The  Regulatory  Scrutiny  Board  received  the  draft  version  of  the  Staff  Working 
Document on 17 February 2021.  

249  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee  and  the  Committee  of  the  Regions  Adjusted  Commission  Work 
Programme 2020,COM(2020) 440 final, Brussels, 27.5.2020. 

 
 
 
                                                      
Following  the  hearing  which  took  place  on  17  March  2021,  the  Regulatory  Scrutiny 
Board  issued  a  positive  opinion  on  the  Evaluation.  In  its  opinion,  the  Board 
recommended  the  report  to  include  a  clear  overview  of  what  was  expected  to  happen 
between  the  2008  revision  of  the  Postal  Services  Directive  and  the  present,  more 
evidence on the needs and degree of satisfaction of users of postal services and on how 
the  Directive  and  changes  in  demand  affected  network  economies  and  costs  of  service 
providers  and  further  analysis  of  the  reasons  behind  the  limited  improvement  in 
competition. 

For  more  details  on  how  the  Staff  Working  Document  was  developed  to  include  the 
Regulatory Scrutiny Board recommendations, see the table below. 

Table 10 Revisions to the SWD following the RSB recommendations 

RSB recommendations 
(1) The report provides relevant information 
on the outcomes of the Directive. However, 
the  report  should  better  explain  what  was 
expected to happen between 2008 and now. 
It  should  describe  the  points  of  comparison 
more  clearly.  This  would  help  to  assess  the 
extent  to  which  the  outcomes  are  related  to 
shortcomings  in  the  Directive  itself,  to  its 
implementation or to external factors.  

(2) The  report  seems  to  assume  that  certain 
changes  in  the  quality  of  postal  services, 
such  as  the  reduction  of  the  scope  of  the 
universal service or its frequency, are always 
a  response  to  changing  consumer  needs. 
Based  on  additional  evidence  (e.g.  national 
surveys  on  consumers’  perceptions),  the 
report  should  consider  whether  they  have 
resulted  in  lower  consumer  satisfaction.  It 
should  present  a  more  differentiated  picture 
of  the  developments  affecting  user  needs 
and  satisfaction,  for  example  by  referring 
and 
separately 

individual 

users 

to 

Revisions 
To better explain the outcome of the Directive a 
number of clarifications have been made. A table 
explaining  the  evolution  of  the  main  provisions 
of  the  Directive  has  been  added  in  Section  2.2 
before  the  intervention  logic,  which  has  been 
simplified.  To  have  a  more  solid  base  for 
assessing what was expected to happen between 
2008  and  now,  a  new  table  listing  the  expected 
outcomes in relation to main provisions has been 
included in the baseline section. The information 
is  based  on  the  2006  impact  assessment  for  the 
2008  revision  of  the  Directive.  In  addition, 
further clarifications on the points of comparison 
in the baseline have been added. The assessment 
in Section 5.1 now also covers to what extent the 
expectations  that  motivated  the  2008  revision 
have been met or not. More specifically, we have 
also  clarified  that  the  Directive  has  achieved  its 
third  objective 
i.e.,  setting  harmonised 
principles for the regulation of postal services. 

- 

Revised Sections: 2.2, 2.3 and 5.1. 
The evaluation has been revised to better explain 
how changing user needs of various postal users 
(business  and  bulk  mailers,  individual  users, 
consolidators, receivers) are the starting point for 
adjustments  of  the  universal  service.  Further 
study  results  relevant  to  the  adjustments  have 
been  added  to  especially  Sections  5.1  and  5.4. 
References  in  the  entire  evaluation  report  to 
stakeholder views have been revised to provide a 
more  differentiated  picture  to  the  extent  such 
information has been available.  

It  should  be  borne  in  mind  that  user  needs  are 
different  from  Member  State  to  Member  State 

82 

 
 
businesses.   

that 

(3)  The  report  is  quite  clear  that  the 
in 
Directive  has  not  been  effective 
stimulating  effective  competition 
the 
in 
letter  mail  segment.  It  should  analyse  more 
in depth the reasons behind this, in particular 
given 
the  main 
this  was  one  of 
objectives.  The  report  should  discuss  the 
extent  to  which  the  limited  progress  in 
competition  is  due  to  deficiencies  in  the 
Directive, to limitations in the instruments or 
empowerment  of  national  regulators,  or  to 
other  factors.  It  should  analyse  to  what 
extent  scale  and  network  economies  of 
incumbents limit entry. It should expand on 
how the Directive has led to specialisation in 
the  market  for  postal  services.  The  report 
should  discuss  whether  cross-subsidisation, 
which  is  prohibited  in  the  Directive,  is  no 
longer a problem. It should also elaborate on 
the  possible  reasons  why  Member  States 
have  not  used  public  procurement 
to 
designate universal service providers.  

(4)  The 
report  could  provide  more 
information on the role of the compensation 
funds  in  preserving  the  provision  of  the 
universal service.  

(5) The report should elaborate more on the 
(e.g. 
views  of  different 
the 
regulators, 
functioning  of 
its 
continued relevance. 

users) 
the  Directive  and 

stakeholders 
on 

operators, 

and among various user groups. In particular the 
needs  of  vulnerable  users  need  to  be  paid 
attention to. References to studies to support the 
analysis  in  as  far  as  such  studies  are  available 
have been added in Section 5.1. 

Section  5.1,  Q2,  has  been  revised  to  provide  a 
broader picture of why the competition objective 
has  not  been  achieved  and  that  this fell short  of 
the  expectations  underpinning  the  2008  revision 
of  the  Directive.  It  goes  into  more  depth  about 
specialisation  in  the  market  for  postal  services 
and  on  the  role  of  regulators  and  whether  they 
are  sufficiently  equipped  to  ensure  effective 
market  entry  and  competition  in  the  letter  mail 
segment.   

tools 

Section  5.1  Q1  addresses  the  issue  of  cross-
subsidisation  and  what 
the  Directive 
provides  regulators  with  in  order  to  detect  and 
prevent  illegitimate  cross-subsidisation.  In  this 
Section  (the  sub-point  on  designation)  the  point 
on  lack  of  use  of  public  procurement  has  been 
further elaborated on but there are limitations to 
how far this could be done as a lack of evidence 
prevents the evaluation from concluding on why 
public procurement is not used more extensively.  

More  detailed  information  related  to  the  impact 
of  the  compensation  fund,  the  legal  conditions 
for  its  use,  its  costs  and  benefits,  have  been 
added to Section 5.2 (Q1) under the point “Costs 
for  other  postal  operators”  and  (Q2)  under 
service: 
“Financing 
compensation fund”. 

universal 

the 

of 

The  evaluation  also  elaborates  more  on  the 
aspect  that  the  universal  service  provider  that 
benefits from a compensation fund will have low 
incentives to improve its efficiency. 

Where relevant, the evaluation report as a whole 
has  been  revised  to  give  a  better  and  more 
differentiated view of stakeholder positions.  See 
in  particular  Sections  5.1,  5.2  and  5.4.    The 
additional  information  is  mainly  based  on  the 
WIK online survey, national surveys carried out 
by 
and 
information  extracted  from  the  Commission’s 
public consultation.  

authorities 

regulatory 

national 

(6)  The  report  should  include  additional  Where relevant, the evaluation report as a whole 

83 

 
 
evidence  to  support  its  conclusions.  Where 
relevant,  it  should  acknowledge  that  the 
evidence  base  remains  weak  and  avoid 
drawing strong conclusions. 

has  been  revised  to  include  more  detailed  and 
updated  evidence,  where  it  has  been  available, 
and efforts have gone in to better explaining and 
justifying  the  conclusions  made,  in  particular  in 
Sections  5.1  and  5.4.    Section  4  on  method  has 
been revised to be clearer about how weaknesses 
regarding  evidence  affects  the  robustness  of 
certain  conclusions  and  that  a  lesson  for  the 
future  is  to  see  how  the  information  gap  can  be 
better  overcome.    The  conclusions  in  Section  6 
are  also  more  explicit  when  referring  to  the 
impact  that  the  weakness  of  the  evidence  base 
has  on  the  conclusions  drawn  in  the  evaluation 
assessment. 

Evidence, sources and quality 

The evidence collection for this evaluation is based on the following main sources: 

  External support studies commissioned by DG GROW: 

o  Study  on  User  Needs  in  the  Postal  Sector  carried  out  by  WIK  Consult  (WIK 
(2021)),  covering  different  timespan  for  different  issues.  The  study  looks  at  the 
changing  societal  and  user  needs  related  to  postal  services,  and  included  a 
systematic  review  of  64  user  needs  surveys  in  16  Member  States.  It  also 
incorporated the results of a dedicated online stakeholder survey that collected 418 
responses,  of  which  44  from  regulators,  44  from  operators,  and  331  from  postal 
users.  The  evidence  base  underpinning  the  study  builds  mainly  on  qualitative 
research,  information  collection  and  review,  desk  research  and  stakeholder 
interaction and did  not  include any quantitative modelling. The study was carried 
out  under  close  guidance  of  DG  GROW  and  fed  into  the  preparation  of  the 
evaluation Staff Working Document; 

o  Study on International Postal Services, Remuneration and Regulation (2011-2020) 
carried out  by WIK Consult  (WIK (2020)) focused on how the  global  system for 
terminal  dues  (fees  that  postal  operators  charge  each  other  for  delivery  of 
international  letters)  were  likely  to  affect  the  market  for  international  postal 
services. 

o  Study  on  the  Development  of  cross-border  e-commerce  through  parcel  delivery 
(2013-2017)  carried  out  by  WIK  Consult  (WIK  (2019))  explored  trends  in  the 
supply  of  and  demand  for  delivery  solutions  in  the  context  of  cross-border  e-
commerce.  It  particularly  emphasised the needs  of e-retailers  and consumers, and 
included regulatory aspects as well as employment and environment related topics.  
o  Study  on  the  Main  Developments  in  the  Postal  Sector  2013-2016  carried  out  by 
Copenhagen  Economics  (Copenhagen  Economics  (2018)),  which 
included 
extensive data collection based on literature review and stakeholder consultation by 
means of surveys and interviews. 

  The stakeholder contributions to the open public consultation on the evaluation of the 

Directive; 

  The opinions of the Member States represented in the Postal Directive Committee; 

84 

 
 
 
 
  The  technical  inputs  and  opinions  of  the  European  Regulators  Group  for  Postal 

Services, in particular: 
o  European Regulators Group for Postal Services PL II (20) 23 Report on postal core 

indicators; 

o  European  Regulators  Group  for  Postal  Services  (20)  22,  Report  on  quality  of 

service, consumer protection and complaint handling; 

o  European  Regulators  Group  for  Postal  Services  II  (20)  26  Report  on  the 

consequences of COVID-19 on the postal sector; 

o  European  Regulators  Group  for  Postal  Services  PL  II  (20)  28  Report  on 

interconnection models and access to international postal networks; 

o  European Regulators Group for Postal Services (20) 7, PL II (20) 30 Report on the 

outcome of the public consultation Report postal definitions; 

o  European Regulators Group for Postal Services PL I (19) 12 Opinion on the review 

of the regulatory framework;  

o  European Regulators Group for Postal Services (19) 10 Report on the development 
of  postal  networks  and  access  practices  regarding  infrastructure  related  to  the 
parcel market; 

o  European  Regulators  Group  for  Postal  Services  PL  II  (19)  37  Report  on  core 

indicators; 

o  European  Regulators  Group  for  Postal  Services  (19)  35  Report  on  the  quality  of 
service, consumer protection and complaint handling 2018: An analysis of trends; 

o  European  Regulators  Group 

(17)  38,  Report  on 
recommendations and best practices in regulation for access to the postal network 
of the incumbent operator (in terms of competition, prices and quality of service); 
o  European Regulators Group for Postal Services (14) 22, Report on tariff regulation 

for  Postal  Services 

in a context of declining volumes; 

o  European  Regulators  Group  for  Postal  Services  (15)  32,  BoR  (15)  214,  Joint 
Opinion  of  the  Body  of  European  Regulators  for  Electronic  Communications 
(BEREC) and the European Regulators Group for Postal Services (ERGP) on price 
transparency and regulatory oversight of cross-border parcels delivery, taking into 
account possible regulatory insights from the electronic communications sector; 
o  European Regulators Group for Postal Services (13) 38 Rev. 1, Report on end-to-

end competition and access in European postal markets; 

o  European  Regulators  Group  for  Postal  Services  (13)  33,  Report  on  Market 

indicators; 

o  European  Regulators  Group  for  Postal  Services  (11)  19,  Report  on  the  quality  of 

service and end-user satisfaction; 

  Joint contributions from the Social Partners representing employers and employees at 
the Social Dialogue Committee for the postal sector adopted on 6 December 2019250, 
and on 13 November 2020251; 

  Statistical  data,  as  resulting  from  the  Commission’s  postal  statistics  database  (2014-
2018), the Universal Postal Union statistical data base (2008-2018), Eurostat and the 
national regulators’ statistical reports; 

  The  study  on  Postal  services  in  the  EU  commissioned  by  the  European  Parliament 

(TRAN Committee) in 2019; 

250  https://www.uni-europa.org/wp-

content/uploads/2019/12/JointStatement_PostalDirectiveReview_PostSDC_20191206.pdf 

251  http://www.postsocialdialog.eu/Home 

85 

 
 
                                                      
In addition to the sources listed above, the following European Commission application 
reports on the implementation of the Directive, impact assessment and other documents 
were considered in the preparation of the evaluation: 

  Report from the Commission to the European Parliament, the Council, the European 
Economic and Social Committee and the Committee of the Regions on the first short-
term review of the Geo-blocking Regulation, COM(2020) 766 final; 

  Commission Staff Working Document, accompanying the Report from the Commission 
to  the  European  Parliament  and  the  Council  on  the  Application  of  the  Postal 
Directive COM(2015) 568 final, SWD (2015) 207 final;  

  Impact  Assessment.  Commission  Staff  Working  Document,  accompanying  the 
proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  amending 
Directive  97/67/EC,  concerning  the  accomplishment  of  the  internal  market  of 
Community postal services, COM(2006) 594 final, SEC(2006) 1292; 

  Commission Staff Working Document, accompanying the Report from the Commission 
to  the  European  Parliament  and  the  Council  on  the  Application  of  the  Postal 
Directive, COM(2006) 595 final, SEC(2006) 1293; 

  Commission Staff Working Document, accompanying the Report from the Commission 
to  the  European  Parliament  and  the  Council  on  the  Application  of  the  Postal 
Directive COM(2008) 844 final, SEC(2008) 3076; 

  The  Impact  on  Universal  Service  of  the  Full  Market  Accomplishment  of  the  Postal 
Internal  Market  in  2009,  Final  Report  May  2006,  Study  commissioned  by  the 
European  Commission,  Internal  Market  and  Services  Directorate  General,  DG 
MARKT/2005/03/E; 

  Green Paper on the Development of the Single Market for Postal Services, COM(91) 

476 final; 

  Digital Economy and Society Index (DESI) 2020, Thematic chapters. 

Other relevant sources quoted in the evaluation Staff Working Document, ranging from 
academic papers to industry figures and estimates, are listed in annex 6 – Bibliography. 

The quality of the evidence is mixed. Some studies, in particular WIK(2021), are based 
on  comprehensive  information  collection,  review,  desk  research  and  stakeholder 
interaction,  mainly  using  qualitative  analysis.  Additional  consultation  activities  with 
stakeholders  have  been  used  to  gather  further  relevant  evidence  and  to  cross-check 
information  from  different  sources.  The  quality  of  evidence  is  however  affected  by  the 
relatively limited number of responses to the consultation activities. This is particularly 
the case for the Commission’s public consultation on the evaluation of the Directive. The 
level of quantification in the evaluation analysis also suffers from the limited availability 
of  relevant  quantitative  data  (e.g.  confidential  business  data)  and  from  a  lack  of  fully 
comparable  indicators  to  cover  the  entire  timespan  of  the  evaluation.  This  affects 
especially the efficiency section and the establishment of a causality link between postal 
market developments and the Directive.  

86 

 
 
 
 
8.  ANNEX 2: STAKEHOLDER CONSULTATION 

1.  The consultation strategy 

1.1  Objectives 

The Commission carried out a number of consultation activities to inform the evaluation 
of the Postal Services Directive (“the Directive”)252. 

To ensure transparency and involve stakeholders, the process followed the standards and 
methods  set  out  in  the  Better  Regulation  guidelines.  The  various  consultations  have 
followed  the  drafting  of  the  roadmap,  which  was  published  on  the  Better  Regulation 
website253 and was open for public feedback between 02 March and 15 April 2020254. 

1.2  Stakeholders consulted 

The main stakeholders targeted by the consultation were:   

  Users  of  postal  services,  including  citizens  and  businesses.  These  stakeholders 
may  encounter different  issues in  their  capacity  as  receivers and senders.  Postal 
services  are  of  particular  interest  for  e-retailers  (especially  Small  and  Medium 
Sized Enterprises), who use them to deliver their products to their customers;  
  Postal operators, that can be further segmented into Universal Service Providers 
(for  instance    incumbents,  former  monopolies,  national  posts)  and  other  postal 
operators (such as express and courier service providers); 
  Social partners representing postal employers and employees; 
  National Regulatory Authorities; 
  Member States. 

1.3 Consultation activities 

The  Commission  has  planned  several  consultation  activities  in  order  to  build  a  solid 
evidence base for the evaluation of the Directive.  

These consultation activities include:  

a)  Consultations of Member States  in the context of meetings with the Postal Services 

Directive Committee; 

b)  Consultations of National Regulatory Authorities in the context of meetings with the 

European Regulators Group for Postal Services (ERGP); 

c)  Consultation of social partners in the context of the Social Dialogue  Committee for 

the Postal Sector; 

252 Directive 97/67/EC of the European Parliament and of the Council of 15 December 1997 with regard to 
the full accomplishment of the internal market of Community postal services as amended by Directive 
2002/39/EC and Directive 2008/6/EC. 

253 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/11965-Report-on-the-

Application-and-Evaluation-of-the-Postal-Services-Directive 

254  The  feedback  received  is  available  here:  https://ec.europa.eu/info/law/better-regulation/have-your-

say/initiatives/11965-Report-on-the-Application-and-Evaluation-of-the-Postal-Services-
Directive/feedback?p_id=7575514 

87 

 
 
                                                      
d)  Consultations with postal operators, users’ associations, regulators, trade unions and 

representatives of the Member States in a number of public workshops; 

e)  An open public consultation. 

Table 11 Timing of consultation activities 

Date 

Actions 

January 2019 

Stakeholder workshop on User needs in the postal sector 

June 2019 

June 2019 

June 2019 

June 2019 

Postal Services Directive Committee meeting – update of MS positions on the review 
of the Directive 

ERGP Plenary meeting 

Stakeholder workshop on User needs in the postal sector 

Social  Dialogue  Committee  for  the  Postal  Sector  –  formal  request  for  input  to  the 
review of the Directive 

September 2019 

Stakeholder workshop on User needs in the postal sector, and 
Stakeholder workshop on International postal services, remuneration and regulation 

September 2019 

ERGP Stakeholder Forum 

November 2019 

ERGP Plenary meeting 

December 2019  

Postal  Services  Directive  Committee  meeting  –  targeted  consultation  on  the 
evaluation of the Directive 

December 2019 

Social Dialogue Committee for the Postal Sector – plenary meeting 

March - April 2020 

Publication of the Evaluation Roadmap and request for feedback 

June 2020 

June 2020 

July 2020 

July-November 
2020 

Postal  Services  Directive  Committee  meeting  –  targeted  consultation  on  the 
evaluation of the Directive 

ERGP Plenary meeting 

Completion of the study on User needs in the postal sector255  

Open public consultation on the evaluation of the Directive 

September 2020 

Stakeholder workshop on International postal services, remuneration and regulation 

November 2020 

ERGP Plenary meeting 

November 2020 

Social Dialogue Committee for the Postal Sector – plenary meeting 

November 2020 

December 2020 

Completion  of  the  study  on  International  postal  services,  remuneration  and 
regulation256  

Postal  Services  Directive  Committee  meeting  –  targeted  consultation  on  the 
evaluation of the Directive 

255https://op.europa.eu/en/publication-detail/-/publication/339db611-eb31-11ea-b3c6-
01aa75ed71a1/language-en/format-PDF/source-193430876 
256https://op.europa.eu/en/publication-detail/-/publication/946318c8-604e-11eb-8146-

01aa75ed71a1/language-en/format-PDF/source-189430505 

88 

 
 
 
                                                      
2. 

Synopsis of consultation activities 

2.1  Consultations of Member States   

The  European  Commission  used  the  meetings  of  the  Postal  Services  Directive 
Committee to consult Member States on the evaluation of the Directive. These meetings 
indicated  that  there  is  consensus  among  Member  States  that  the  provisions  of  the 
Directive played an important role in achieving its objectives, even though the opening of 
postal markets did not necessarily bring concrete results in all Member States. Member 
States believe that the issues addressed by the Directive are still relevant and justify the 
continuation of action at EU level, but at the same time demand more flexibility to allow 
adapting  the  universal  service  provision  to  market  developments  and  national 
specificities, in particular for what concerns delivery frequency but also quality of service 
requirements,  the  scope  of  the  universal  service  obligation  and  the  way  the  net  cost  is 
calculated. There is also support for a clarification of some of the definitions included in 
the Directive. 

2.2 Consultations of National Regulatory Authorities 

The  European  Commission  used  the  meetings  of  the  European  Regulators  Group  for 
Postal Services (ERGP) to consult National Regulatory Authorities on the evaluation of 
the  Directive.  The  list  of  meetings  held  and  documents  adopted  by  the  ERGP  are 
published on: https://ec.europa.eu/growth/sectors/postal-services/ergp_en. 

The ERGP believes that in  light  of the changes  that affected the postal  sector in  recent 
years,  the  Directive  is  not  fit  for  purpose  anymore.  ERGP  proposes  to  base  a  future 
regulatory  framework  on  a  thorough  consideration  and  analysis  of  all  relevant,  current 
and future developments in society and the sector (“greenfield approach”). In particular, 
The  ERGP  recommended  to  reorient  the  focus  of  the  regulatory  framework  from  the 
universal service provision to a proper functioning of the postal market and competition 
The  universal  service  should  be  defined  at  European  level  but  Member  States  and 
national regulatory authorities should have sufficient flexibility to adapt their application 
of  universal  service  according  to  specific  national  circumstances  and  developments. 
NRAs should have powers on market monitoring, (collection of information covering all 
the  players  in  the  market),  enforcement  and  application  of  sanctions,  consumer 
protection,  regulatory  powers  and  regulatory  tools,  including  the  interdependence  with 
adjacent  markets  (e.g.  platformisation)  and  ensure  and  strengthen  an  independent 
performance  of  their  tasks.  Furthermore,  the  institutional  framework  for  ensuring 
cooperation between national regulatory authorities should be strengthened. 

2.3 Consultation of European social partners in the context of the Sectoral 
Social Dialogue Committee for the Postal Sector 

Social partners submitted a joint contribution257 for the Directive’s review in December 
2019, stressing the need to maintain the focus on the universal service and its sustainable 
provision,  as  postal  services  play  a  crucial  role  in  territorial  and  social  cohesion.  In  a 
second contribution258 issued in November 2020, social partners highlighted further key 

257 https://ec.europa.eu/social/main.jsp?catId=521&langId=en&agreementId=5613 
258 https://ec.europa.eu/social/main.jsp?catId=521&langId=en&agreementId=5693 

89 

 
 
                                                      
issues, in particular flexibility, which would allow each Member State to better structure 
the  obligations  of  its  universal  service  provider  to  fit  domestic  circumstances  ensuring 
that  universal  postal  services  remain  financially  sustainable.  Social  partners  also 
emphasised  that  all  postal  sector  workers  should  enjoy  fair  working  conditions,  the 
importance  of  the  EU  Green  Deal,  and  their  willingness  to  contribute  to  the  EU  Green 
recovery. 

2.4 Public Workshops 

Five  workshops  were  organised  by  the  Commission  in  2019-2020,  in  cooperation  with 
the  consultants  to  which  the  studies  relevant  for  the  evaluation  were  entrusted. 
Hypotheses  related  to  the  functioning  of  the  Directive,  specific  questions  and  the 
preliminary conclusions of the studies were discussed.  

A  high  number  of  participants  agreed  that  the  concept  of  universal  postal  service  has 
worked  well,  but  that  adaptations  may  be  needed.  As  user  needs  change  and  differ 
between Member States, there seemed to be broad agreement that there is no “one-size 
fits  all”  universal  service  obligation.  Participants  had  different  opinions  concerning  the 
level of flexibility and reform needed. For instance several universal service providers, as 
well as their association PostEurop, warned against a “greenfield approach” involving a 
drastically new framework.  

Some consumer groups recalled the importance of letter post service for vulnerable users 
and  for  groups  with  special  needs,  and  the  alternative  of  faster  or  slower  delivery  was 
appreciated by many users. Several participants agreed that the group of vulnerable users 
is likely to decrease, but that there will always be some special needs for postal service. 
Digitization means that some users (e.g.  enterprises) find letters less relevant  and more 
costly,  but  discussions  showed  that  the  picture  varies  considerably  between  Member 
States.      

2.5 Open Public Consultation  

2.5.1  Introduction 

On  13  July  2020,  the  Directorate  General  for  the  Internal  Market,  Industry, 
Entrepreneurship  and  SMEs  (DG  GROW)  launched  a  public  consultation  in  23  EU 
official languages entitled "Public Consultation on the Evaluation of the Postal Services 
Directive". The consultation lasted 17 weeks and closed on 9 November 2020.  

The consultation  was designed to  gather the views of all interested stakeholders on the 
following: 

  universal postal services - common requirements; 
  affordability/tariff regulation of universal postal services; 
  quality of service, including complaints; 
  designation/safeguarding universal postal services; 
  access and level playing field; 
  independent regulators; 
  general authorisation, licensing; 
  harmonised technical standards; 
  impact of the COVID-19 crisis; 

90 

 
 
  overall role and effects of the directive. 

2.5.2  Overview of respondents 

DG  GROW  received  119  responses  to  the  public  consultation.  Out  of  these  responses, 
consumers  submitted  45.  Contributions  also  came  from  28  companies/business 
organisations. Out of these contributions, 18 came from universal service providers of the 
different  Member  States,  3  from  non-universal  service  providers  and  7  from  business 
senders (e-commerce market places, online sellers, utility companies, banks, etc.). Out of 
the 20 business associations that responded to the consultation, 6 represent non-universal 
service providers, 6 represent business senders associations and 1 represents the universal 
service  providers  (the  remaining  7  are  a  mix  of  associations  representing  different 
sectors). 14 public authorities responded to the consultation, with 11 replies coming from 
postal  services  regulators,  1  from  an  association  of  postal  services  regulators  and  2 
coming from ministries of Member States. 9 responses were submitted by trade unions, 2 
by  consumer  organisations  and  1  by  an  NGO.  See  Figure  5  for  a  breakdown  by 
respondent type. 

Figure 5 Respondents by Stakeholder Group 

Replies  originated  in  23  Member  States  (all  except  Bulgaria,  Lithuania,  Romania  and 
Slovenia) and from Norway.  Most of the respondents are located in Poland (26 percent), 
Belgium  (13  percent),  Germany  (11  percent),  Italy  (6  percent)  and  France  (5  percent).  
See Figure 6 for a breakdown by country of origin. 

91 

 
 
 
Figure 6 Respondents by country of origin 

2.5.3  Summary of responses 

Universal postal services – Common requirements  

Over the last 2 years a vast majority of consumers (in most of the cases over 70 percent) 
have used personal correspondence services (letters, cards, items), have sent or received 
government documents and made use of e-commerce parcels and returns services. With 
the  exception  of  consumers  living  in  rural  areas  (a  total  of  4  individuals  identified 
themselves as living in such areas), the majority of consumers have not used (and have 
declared they do not need) the delivery of periodicals and advertising mail. The replies of 
a majority of business senders are in line with those of the consumers. Business senders 
also declared that they used mail to send bills, invoices or receipts. The majority of both 
stakeholder  groups  stated  that  for  correspondence  with  the  judiciary  and  public 
authorities, they are obliged to send or receive letters.  

The majority of consumers believe that the most important features of the postal service 
are delivery to the door, delivery across the entire territory of the country and transparent 
and  non-discriminatory  prices.  The  majority  of  business  senders  share  these  views,  
except for delivery to the door, which is not as important to them. They instead indicate 
that daily collection and delivery is one of the most important features. The majority of 
regulators  share  the  views  of  consumers  while  postal  service  providers  mentioned 
delivery to the door, delivery across the entire territory of the country and daily collection 
and delivery as the most important features.  

The majority of all stakeholders stated that all postal services and features are important 
for all vulnerable groups identified in the questionnaire (people living in rural and remote 
areas,  elderly  people,  people  with  disabilities  and  people  with  low  digital  skills).  For 
people  living  in  rural  and  remote  areas,  receiving  parcels,  delivery  to  the  door,  a  letter 
box or alternative collection or delivery point sufficiently close to home, delivery across 
the  entire  territory,  speed  of  delivery  and  affordable  prices  are  particularly  important. 

92 

 
 
 
Elderly  people  stated  that  the  most  important  features  are  sending  and  receiving  letters 
and affordable prices. 

Almost all universal service providers, as well as the majority of postal service regulators 
and trade unions believe that the postal sector in their member state has addressed well or 
very  well  the  needs  of  vulnerable  groups  of  people.  People  living  in  rural  and  remote 
areas  and  elderly  people  are  however  more  critical  on  whether  the  postal  sector  has 
addressed their needs.  

The vast majority of consumers are satisfied with the current frequency of delivery and 
collection of postal items in their respective Member State. For very few of them, a 3 or 
4-day delivery per week would be sufficient, while others would prefer a 6-day delivery 
which  would  include  Saturday.  Business  senders  state  that  they  would  like  to  see  an 
increase  in  the  frequency  of  delivery  and  collection,  but  their  comments  related  almost 
exclusively on collection and delivery of parcels. 

A  majority  of  respondents  in  all  stakeholder  groups  stated  that  the  provision  of  basic 
postal  services  kept  up,  at  least  to  some  extent,  with  technological  and  market 
developments, societal development and the needs of users. Some respondents mentioned 
that  postal  services  should  invest  more  into  CO2  neutral  vehicles  to  ensure  a  carbon 
neutral  delivery,  that  more  parcel  boxes  should  be  deployed  and  that  they  should  be 
accessible to  all postal  operators, and that the online sale of stamps  that can be printed 
from home should be developed.  

Affordability and tariff regulation of universal postal services  

Out  of  the  stakeholders  that  expressed  an  opinion  on  affordability,  the  vast  majority 
stated  that  in  the  last  10  years  they  did  not  refrain  from  using  basic  domestic  or  intra-
EEA  letter  mail  service  because  of  the  amount  charged  for  these  services.  A  slight 
majority stated that the amount charged was also not influencing the decision on whether 
or not to use express domestic and intra-EEA letter mail services and basic domestic and 
intra-EEA parcel  services.  Conversely, a slight  majority stated that the amount charged 
for express domestic and intra-EEA parcel services have prevented them from using such 
services. 

Around  half  of  all  stakeholders  believe  that  the  obligation  to  provide  universal  postal 
services  across  the  entire  EU  has  affected  the  level  of  prices  of  most  universal  service 
products over the past 10 years. For most of them the impact was significant in the case 
of domestic and intra-EEA letters.  

Over  80  percent  of  all  stakeholders  that  replied  to  that  question  consider  the  pricing 
information  for  postal  services  accessible,  i.e.  they  know  where  to  find  it.  Similar 
percentages apply to consumers and business senders.  

Slightly more than half of the national regulators who replied believe prices of universal 
postal services are cost-oriented and slightly more think they are non-discriminatory.  All 
universal service providers and the association representing them believe that prices are 
cost-oriented and non-discriminatory. 

Regarding the wholesale tariffs for cross-border  postal  services within the EU, the vast 
majority  of  universal  service  providers  indicate  that  wholesale  tariffs  are  cost-oriented, 

93 

 
 
based  on  the  quality  of  service,  transparent,  non-discriminatory  and  influenced  by  the 
universal service obligation. The replies of the regulators are less conclusive on whether 
they are cost-oriented, based on the quality of service, non-discriminatory or influenced 
by the universal service obligation, but most indicate they are not transparent.  

Over  80  percent  of  universal  service  providers  believe  the  principles  underpinning  the 
establishment  of  prices  of  universal  postal  services  should  not  be  defined  in  EU  law, 
while 57 percent of consumers, 90 percent of national regulators and the majority of trade 
unions believe they should be defined in EU law.  

Most of the regulators (77 percent), universal service providers (65 percent) and almost 
all (90 percent) of the representatives of trade unions believe that tariff regulation helps 
to  make universal  postal  services  affordable, although most think only to some extent.. 
Many  of  the  comments  provided  mention  that  affordability  is  relative  and  not  defined 
clearly by the Directive and some point out that tariff regulation can create competitive 
disadvantages for the universal service provider.  

Regarding  the  balance  between  cost-orientation  and  affordability,  the  opinions  of  those 
who replied are split evenly between those who think there is balance between the two 
and  those  who  said  that  there  is  too  much  emphasis  either  on  affordability  or  on  cost 
orientation.  Universal  service  providers  incline  slightly  towards  the  fact  that  a  right 
balance  has  been  achieved,  while  most  regulators  believe  too  much  emphasis  to  be  on 
cost-orientation. In the comments, some indicate that affordability of letters is maintained 
primarily due to low usage.  

46 percent of all stakeholders that responded to the consultation believe universal service 
cost  should  be  financed  from  the  State  budget.  This  was  notably  the  case  for  over  70 
percent  of  universal  service  providers,  67  percent  of  trade  unions  and  52  percent  of 
consumers, while only 27 percent of regulators share this opinion. Regulators suggested a 
combination of contributions from the State, consumers and competing postal operators 
should finance the universal service.   

Quality of service and complaints  

A majority  of  consumers that responded to  the  consultation  are partly  or fully satisfied 
with the access to the postal network in terms of number of letterboxes and post offices. 
Most consumers are however slightly or very dissatisfied with the reliability of delivery 
(items  delivered),  regularity  (items  delivered  on  time)  and  delivery  and  collection 
location (number of alternative solutions), while no clear opinion on delivery speed was 
expressed. The majority of consumers living in rural areas responded that they are at least 
partially satisfied with all the features mentioned above. The majority of business senders 
answered in a similar way to all consumers. 

When comparing these features to 10 years ago, the majority of consumers believe that 
the  access  to  the  postal  network  in  terms  of  number  of  letter  boxes  and  post  offices  is 
now  worse  or  significantly  worse.  Delivery  speed,  reliability  and  regularity  of  delivery 
has not changed, while delivery and collection location is better nowadays. These views 
are shared by consumers living in rural areas, except for the access to the postal network, 
where the situation is considered not to have changed. The majority of business senders 

94 

 
 
answered in  a similar way  except  for collection location where they believe it is  worse 
(but only a very limited number of business senders replied to the consultation). 

Almost all consumers that replied are aware that it is possible to lodge a complaint when 
they  encounter a problem  with  the service (such as non-compliance  with  the quality  of 
service standards, damage, loss or theft) and more than half have lodged a complaint with 
the postal service provider. The majority thinks that the complaint handling procedure of 
the  provider  was  not  at  all  or  only  to  some  extent  easy  to  find  and  simple  to  file,  and 
almost  all  of  the  ones  who  replied  stated  that  it  is  very  much  free  of  charge  or 
inexpensive but many stated that the procedure was not at all effective in addressing the 
matter  and  not  at  all  fast.  Only  two  business  senders  stated  that  they  ever  lodged  a 
complaint and associations of business senders stated that they never lodged a complaint. 

Among  the  consumers  that  lodged  a  complaint  about  lost/damaged  goods,  only  20 
percent reported that they were reimbursed. 

Only 10 consumers reported that they ever complained about a cross-border delivery and 
6 of them replied that it was easy to establish which postal operator was responsible.  

When  asked  how  satisfied  they  are  with  the  way  in  which  universal  service 
provides/postal operators handle complaints, the majority of consumers that responded to 
that question stated that they are not satisfied. The main reasons given were the very long 
time  for  processing  complaints,  or  the  fact  that  the  postal  operator  did  not  provide  any 
reply to the complaint. 

Designation and safeguarding universal postal services  

The vast majority of questions under this section were addressed to a limited number of 
stakeholders,  in  particular  to  postal  service  providers/associations  of  postal  service 
providers, and/or public authorities. 

The associations representing non-universal service providers are the most critical when 
asked how the financial compensation mechanism put in place to safeguard the provision 
of  the  universal  postal  services  has  evolved  over  the  past  10  years.  67  percent  of  them 
stated  that  the  compensation  mechanism  evolved  negatively  in  terms  of  transparency, 
non-discrimination,  proportionality  and  application  of  objective  and  verifiable  criteria. 
The vast majority of universal service providers are split between saying it has evolved 
positively  and  it  has  not  evolved  at  all.  Over  half  of  regulators  that  responded  to  the 
consultation  reported  a  positive  evolution  of  the  financial  compensation  mechanism  in 
terms of the four mentioned features. 

The  majority  of  regulators  believe  that  in  determining  the  eligible  amount  of 
compensation,  the  net  avoided  cost  methodology  is  appropriate,  reliable,  but  also 
cumbersome. The majority also stated that the net-cost calculation guidance provided by 
the directive has been useful and that the separate accounts kept by the universal service 
provider  in  their  Member  State  observe  the  principles  for  allocation  of  common  costs 
established by the directive, and that in the majority of cases this has been verified by an 
independent external body. Among the regulators that stated that the net-cost calculation 
guidance provided by the directive has not been useful, some added that the wide margin 
of  discretion  that  the  methodology  allows  (e.g.  in  the  definition  of  the  counterfactual 
scenario)  has  led  to  countless  disputes  between  the  regulator  and  the  universal  service 

95 

 
 
provider,  that  the  calculation  of  the  net  cost  using  the  guidance  is  very  complicated, 
while  a  clearer  and  more  objective  methodology  would  be  required  for  regulators,  and 
that the intangible costs are very hard to take into account. 

It is not possible to draw conclusions on the aspects regarding the selection procedure for 
a universal service provider, as almost all postal  service providers stated that there was 
no  selection  procedure  in  their  country  or  they  did  not  provide  a  response  to  that 
question. 

Access and level playing field 

The vast majority of universal service providers, non-universal service providers as well 
as  the  association  representing  universal  service  providers  and  regulators  believe  it  is 
easier to  enter the postal market  today  compared to  10  years ago. The vast  majority of 
associations  representing  non-universal  service  providers  stated  that  it  is not  easier  and 
the reasons given were the investment levels required, the fact that they cannot compete 
with the prices of the universal service provider and because of economies of scale and 
scope. 

Around  55  percent  of  consumers  responded  that  they  are  aware  of  providers  of  postal 
services aside from the traditional one in their country for what concerns the sending of 
domestic  and  international  letters,  while  38  percent  replied  that  they  are  not.  For 
domestic and international parcels, the figures change to over 80 percent for awareness 
and less than 10 percent for non-awareness of alternative providers. 

On  the  issue  of  whether  the  Directive  has  contributed  to  effective  competition  in  the 
postal markets in Member States, the vast majority (over 80 percent) of regulators stated 
that there is no or insufficient competition in the one-piece letter market, while over 60 
percent  are  of  the  view  that  there  is  some  competition  for  the  bulk  letter  market.  The 
picture  is  completely  different  regarding  the  parcel  market,  where  over  45  percent  of 
regulators believe there is significant competition in the one-piece parcel market and over 
70 percent believe there is significant competition in the bulk parcel market.  

In contrast to the regulators, around 50 percent of universal service providers are of the 
opinion  that  there  is  some  competition  in  the  one-piece  letter  market  and  significant 
competition  in  the  bulk  letter  market.  Similar  to  the  regulators,  almost  all  universal 
service  providers  agree  that  there  is  significant  competition  in  both  the  one-piece  and 
bulk  parcel  markets.  The association representing the universal  service providers stated 
that  competition  is  significant  in  all  four  market  segments.  This  is  to  be  contrasted 
against  the  views  of  the  majority  of  the  associations  representing  the  non-universal 
service providers, which are of the view that there is no or insufficient competition in the 
one-piece letter market and some competition in the remaining three segments.  

When analysing the replies to the question on how competition has evolved over the last 
10 years in these 4 markets, all regulators stated that competition was stationary or has 
decreased in the one-piece letter market and over 80 percent believe that it was stationary 
or  had  increased  in  the  bulk  letter  market.  Again,  results  are  quite  different  for  what 
concerns the parcel market, where the vast majority of regulators stated that competition 
in the last 10 years has increased or significantly increased in both the one-piece and bulk 
parcel markets. 

96 

 
 
Over  50  percent  of  universal  service  providers  believe  that  competition  has  remained 
stationary  in  the  one-piece  letter  market,  60  percent  that  it  increased  or  significantly 
increased in the bulk letter market, 95 percent that it increased or significantly increased 
in the one-piece parcel market and there is unanimity that it significantly increased in the 
bulk  parcel  market.  The  association  representing  the  universal  service  providers  stated 
that  competition  increased  significantly  in  all  four  segments,  while  the  majority  of 
associations  representing  non-universal  service  providers  stated  that  competition 
decreased  in  the  one-piece  letter  market,  increased  or  remained  stationary  in  the  bulk 
letter  market,  decreased  or  remained  stationary  in  the  one-piece  parcel  market  and 
increased in the bulk parcel market.  

The  majority  of  regulators  believe  that  the  following  measures  under  the  directive  – 
definition  of  the  universal  service,  territorial  coverage  required,  quality  requirements, 
designation of a universal service provider, universal service financing mechanism, tariff 
regulation of universal services, – had no impact on competition in the postal market of 
their  respective  countries,  while  the  accounting  separation  obligation  for  designated 
universal  service  provider,  the  enforcement  policy  of  the  regulator,  wholesale  tariff 
regulation of cross-border universal postal services and access regulation had a positive 
impact and the VAT exemption had a negative impact. The majority of universal service 
providers stated that  all these measures had no impact  on competition.  The majority of 
associations representing the non-universal service providers stated that the definition of 
the  universal  service,  territorial  coverage  required,  designation  of  a  universal  service 
provider, universal service financing mechanism and VAT exemption negatively affected 
competition. Accounting separation obligation for designated universal service provider 
and  enforcement  policy  of  the  regulator  had  a  positive  effect  on  competition,  while 
quality requirements, tariff regulation of universal services, wholesale tariff regulation of 
cross-border universal postal services and access regulation had no impact.  

For  what  concerns  the  access  conditions  implemented  in  their  Member  State  for  the 
postal network and elements of infrastructure (postal network, postcode system, address 
database, post office boxes, delivery boxes, information on change of address, redirection 
service, return to  sender service),  almost  all the universal  service providers replied that 
they  are  transparent,  non-discriminatory  and  proportional.  Extremely  few  associations 
representing non-universal service providers replied to that question and one stated that 
access conditions are discriminatory. 

Independent regulators 

Concerning  the  independence  of  regulators,  the  vast  majority  (76  percent)  of  postal 
operators believe the national regulatory authorities in charge with ensuring compliance 
with the Directive are fully independent, while the majority (50 percent) of associations 
representing  non-universal  service  providers  stated  that  they  are  only  partially 
independent. 43 percent of postal operators have not perceived any change in the level of 
independence over the past 10 years. 

General authorisation and licensing  

Around  80  percent  of  universal  service  providers  and  the  majority  of  non-universal 
service providers and their associations state that definitions used to determine the scope 

97 

 
 
of  the  Directive,  such  as  “postal  services”,  “postal  item”,  “postal  service  provider”, 
“universal  service”  and  “user/sender”  have  had  no  impact  on  their  activity.  A  few 
universal  service providers stated that as  long  as the objectives of the Directive remain 
unchanged  so  should  the  definitions.  One  universal  service  provider  stated  that  the 
definitions  largely  remain  fit  for  purpose  and  are  sufficient  to  provide  clarity  to  postal 
service providers in the conduct of their business. However, the application of definitions 
is  not  uniform  across  all  Member  States  and  this  can  lead  to  unequal  regulatory  and 
market conditions. At the same time, around 70 percent of regulators responded that all 
definitions  except  the  one  on  “universal  service”  have  a  negative  impact  on  their 
activities.  In particular, they state that the definitions of “postal  service”  and of “postal 
provider” are not clear and do not reflect the developments in the postal market since the 
adoption of the Directive. 

Over 70 percent of universal service providers and the majority of non-universal service 
providers  stated  that  the  different  authorisation  systems  in  the  Member  States  have  not 
been  an  obstacle  for  the  establishment  and  provision  of  cross-border  postal  services. 
Some of them mentioned that different extraterritorial office of exchange policies could 
in theory constitute an obstacle for cross-border provision of postal services. 

It  is  not  possible  to  draw  a  conclusion  from  the  responses  of  the  universal  service 
providers  and  the  regulators  regarding  the  extent  to  which  the  opening  of  the  postal 
market  has  affected  operational  costs  and  prices  of  services  over  the  last  10  years,  as 
responses are evenly scattered among the response “increased somewhat” and “decreased 
somewhat”. 

The main three aspects that generate the largest costs for universal service providers are 
the provision of the postal universal service (100 percent of respondents), implementing 
the quality requirements (72 percent) and data collection and reporting (56 percent). For 
non-universal  service  providers  the  largest  costs  are  licencing,  authorisations  (67 
percent), data collection, and reporting (44 percent). 

Harmonised technical standards 

Among universal service providers, 88 percent responded that postal technical standards 
have kept  pace with  developments  in  technology and the evolution  of users’ needs and 
over  50  percent  of  regulators  are  of  the  same  view.  A  number  of  associations 
representing non-universal providers, however, disagree with that statement. As concerns 
the actual use of postal technical standards, most universal service providers report that 
they use both  CEN standards and UPU standards, with a higher percentage using UPU 
standards  “to  a  large  extent”  (71  percent,  versus  57  percent  for  CEN  standards).  Some 
also  reported  using  “other  standards”,  which  generally  refers  to  some  use  of  ISO 
standards. 

When  asked  which  areas  of  standardisation  have  the  most  impact  on  their  operations, 
“quality of service” (e.g. transit time measurement, complaints handling) was ranked as 
the most important by 72 percent of universal service providers. The other areas ranked 
in  terms  of  importance  for  universal  service  providers  were  standards  for  “processing” 
(e.g. automatic identification of items), which was ranked as the second most important 
by  over  60  percent  of  respondents,  “delivery”  (e.g.  technical  features  of  parcel  boxes, 
apertures of private letter boxes), which was ranked as the third most important area by 

98 

 
 
55 percent of respondents, and “digital services” (e.g. secured electronic postal services), 
which was ranked as the fourth most important area by 44 percent of the respondents.  

As  mentioned  above,  most  operators  use  standards  to  some  extent.  In  the  cases  where 
they  do  not  use  certain  standards,  a  number  of  reasons  were  given  by  the  universal 
service  providers.  The  most  relevant  ones  are  that  implementation  would  be  too  costly 
(55 percent), that some standards are not suited to needs (39 percent), and that others do 
not  use  the  standards  (33  percent).  Associations  of  non-universal  service  providers 
reported that standards are not suited to their needs and that they are outdated. 

Almost  all  universal  service  providers  (95  percent)  and  the  few  non-universal  service 
providers  that  responded  stated  that  none  of  the  optional  standards  should  be  made 
mandatory.  A  number  of  regulators  believe  that  they  should  be  made  mandatory  and 
mentioned  the  ones  on  the  measurement  of  transit  times  for  parcels  and  on 
interoperability  and  exchange  of  electronic  data  between  providers,  online  shops, 
consumers and other authorities (e.g. customs). 

Finally, the public consultation indicated that standardisation has had  a positive  impact 
on  the  provision  of  cross-border  postal  services.  65  percent  of  the  respondents  that 
replied to that question agreed that standards have had a positive or very positive impact 
on this aspect of EU postal services. 

Impact of the COVID-19 crisis 

The  majority  of  consumers  (including  those  living  in  rural  areas)  and  business  senders 
state that because of the COVID-19 crisis, the timely delivery and frequency of delivery 
for both letter mail and parcels has decreased while there was no impact on the cost  of 
delivery for both services. Some trade unions reported an increase in the cost of delivery 
for both letter mail and parcels. A majority of universal service providers and regulators 
responded that the punctuality of delivery of letter mail and parcels decreased, there was 
no  impact  on  the  frequency  of  delivery  and  that  cost  for  the  delivery  of  both  services 
increased.  

Almost  all  universal  service  providers  and  the  vast  majority  of  regulators  state  that  the 
COVID-19 crisis had a negative effect on the demand and use of all types of letter mail. 
Consumer  responses  are  less  clear-cut  as  they  are  divided  between  those  that  consider 
COVID-19  had  a  negative  effect  and  those  who  believe  it  did  not  have  any  effect  on 
demand and use of letter mail. The majority of all these stakeholders agree that COVID-
19 had a positive effect on the demand and use of parcel delivery services.   

When  asked  about  the  effect  of  the  COVID-19  pandemic  on  the  current  trends  in  the 
postal market, there is consensus among the majority of all stakeholders that the decline 
in letter mail volumes due to electronic communications, the decline in advertising mail, 
the growth in domestic and cross-border e-commerce related parcels will accelerate.  

Almost  all  universal  service  providers,  the  association  representing  them  and  over  70 
percent of  regulators believe that the provisions  of the  Directive have been sufficiently 
flexible  to  allow  the  postal  sector  to  adjust  in  response  to  the  COVID-19  pandemic. 
Some  of  them  stated  that  the  provisions  could  enable  a  quick  and  effective  response 
during the lockdown in Member States in order to ensure the provision of the universal 
postal service and securing the health of both postal staff and customers. 

99 

 
 
Overall role and effects of the Directive  

When asked whether some of the objectives of the Directive have been achieved and are 
still relevant, respondents replied: 

Table 12 Were the objectives of the Directive achieved? Are they still relevant? 

ACHIEVED 

RELEVANT 

Yes, 
completely 

Yes, 
partially  

Not at 
all 

I do not 
know 

Yes 

No 

Universal  service  to  all 
citizens 
the 
territory 

across 

47 percent 

30 
percent 

6 
percent 

17 
percent 

87 
percent 

5 
percent 

I do not 
know 

8 percent 

Better 
quality 
domestic services 

of 

22 percent 

33 
percent 

24 
percent 

21 
percent 

71 
percent 

20 
percent 

9 percent 

Better  quality  of  cross-
border services 

20 percent 

32 
percent 

19 
percent 

29 
percent 

67 
percent 

19 
percent 

14 
percent 

Affordable  prices 
services  

for 

27 percent 

29 
percent 

25 
percent 

19 
percent 

74 
percent 

17 
percent 

9 percent 

Transparent  and  non-
discriminatory prices 

27 percent 

19 
percent 

33 
percent 

21 
percent 

79 
percent 

14 
percent 

7 percent 

Competition 
postal markets 

in 

the 

26 percent 

34 
percent 

22 
percent 

18 
percent 

64 
percent 

25 
percent 

11 
percent 

More  than  half  (55  percent)  of  the  respondents  indicate  not  being  aware  of  any 
unintended  negative  effects,  due  to  the  directive,  or  finding  the  effects  just  positive.  A 
number  of  respondents  (39  percent)  however  think  that  the  directive  has  led  to 
unintended  negative  effects,  for  example,  in  terms  of  not  meeting  its  objectives  on 
improved  competition  in  the  letter  market  and  enhanced  quality  of  service.  Some 
stakeholders  also  call  for  more  flexibility  on  delivery  frequency,  while  others  find  the 
directive obsolete. 

The majority of regulators believe that the opening of the postal market to new providers 
has  only  in  part  contributed  to  maintaining  sustainable  and  quality  employment  within 
universal  service  providers  and  facilitating  the  creation  of  new  jobs  in  alternative 
providers, while there is no clear opinion on whether it has contributed to expanding the 
overall  size  of  the  postal  market.  The  almost  totality  of  universal  service  providers 
believe that market opening has not at all or just in part contributed to expanding the size 
of  the  market  and  maintaining  sustainable  and  quality  employment  within  their 
organisations  and  believe  that  it  has  in  part  contributed  to  the  creation  of  jobs  in 
alternative  providers.  Half  of  the  associations  representing  non-universal  service 
providers share the view on the creation of new jobs.  

More than half of the trade unions that replied find that the opening of the postal market 
to  new  providers  has  not  contributed  effectively  at  all  to  maintaining  sustainable  and 
quality employment within universal providers or to facilitating the creation of new jobs 

100 

 
 
 
 
in  alternative  providers.  They  mention  the  increase  in  part-time  work  and  precarious 
working conditions as negative consequences.  

Close to 70 percent of universal service providers, as well as the association representing 
them  consider  that  the  directive  provides  the  necessary  level  of  flexibility  to  meet  the 
their  Member  State.  Some  associations 
particular  circumstances  and  needs 
representing  non-universal  service  providers  believe  that  the  directive  is  not  flexible 
enough. The majority of regulators believe the same and a number of them mention the 
lack of flexibility in the 5-days collection and delivery provision.  

in 

The majority of universal service providers and the few non-universal service providers 
and associations representing them that responded stated that they have not come across 
additional requirements in the national postal legislation that have dissuaded them from 
operating in another country. 

Many respondents believe that the measures set out by the Directive are in line, or at least 
partly in line, with other EU policies, for example with customs regulations (30 percent), 
competition  framework  (36  percent),  consumer  rights  framework  (42  percent),  or 
regional cohesion policies (33 percent). Fewer among the respondents think the measures 
are  in  line,  or  partly  in  line,  with  The  Digital  Single  Market  Strategy  and  subsequent 
policies  (29  percent),  taxation  policies  (26  percent),  trade  policies  and  agreements  (23 
percent), labour and social policies (22 percent), environmental regulations (20 percent), 
or with transport policies (19 percent). 

Many  of  the  respondents  assess  that  the  postal  sector  developed  to  some  extent  (35 
percent) or even to  great extent (28 percent) in an environmentally sustainable manner, 
while others think that it has not developed at all in such a manner (23 percent). Slightly 
fewer believe that the postal sector has contributed to some extent (31 percent) or to great 
extent (15 percent) to the fight against climate change, but almost as many (29 percent) 
say it has not contributed at all. Those who were the most critical mentioned an increase 
in traffic, the lack of provisions on the use of rail and electric transport for shipments and 
delivery of items. 

When  asked  if,  in  light  of  changes  in  users’  needs  and  in  the  market  context,  the 
Directive is still fit for purpose, respondents replied: 

Figure 7 Is the Directive still fit for purpose? 

101 

 
 
 
 
9.  ANNEX 3: METHODS AND INFORMATION SOURCES 

WIK  (2021)  User  Needs  in  the  Postal  Sector  and  Evaluation  of  the  Regulatory 
Framework  

Part of the background information and analysis for the evaluation comes from the WIK 
study on “User Needs in the Postal Sector and Evaluation of the Regulatory Framework”, 
done for the Commission (WIK (2021)). The study was approved in August 2020. 

The study provides: 

  an  overview  of  the  development  of  user  needs  in  the  postal  sector,  focusing  on  an 

analysis of the need for universal service obligations; 

  an evaluation of the Postal Services Directive. 

This  is  an  exploratory  study  about  user  needs  in  the  postal  sector.  It  was  initiated  and 
largely finalized before the establishment of the evaluation inter-service steering group. 
The  initial  focus  of  the  study  was  on  future  user  needs,  and  the  evaluation  aspects 
became increasingly emphasized as the work progressed.  

The  study  evaluates  different  specific  elements  of  the  regulatory  framework  for  postal 
services, organised in seven groups of major topics, following the logic of the Directive. 
Each of these seven groups covered relevant provision in the Directive and were analysed 
in accordance with the five criteria of the Commission’s Better Regulation Guidelines. 

For market  overview and background data,  WIK relies on published data referred to  in 
previous  studies  or  from  Eurostat,  European  Regulators  Group  for  Postal  services, 
operators’  annual  reports  and  similar  sources.  The  study  also  relies  on  WIK’s  own 
surveys, undertaken for this purpose, to show the views, needs and expectations of policy 
makers, operators and stakeholders. As the WIK online survey was answered by a larger 
number of  respondents  than that of the EC,  it was  used with  priority  when stakeholder 
views  were  necessary  for  the  analysis.  WIK  made  an  effort  to  collect  adequate  and 
relevant  data.  For  some  aspects,  notably  the  cost-benefit  analysis  (and  in  particular  the 
part  on  benefits),  there  is  however  a  lack  of  data  covering  several  Member  States  and 
longer time periods. This has obvious implications on the robustness of the results. The 
consultant addresses this by drawing lessons from studies concerning individual Member 
States or case studies. 

The key findings are summed up in  each section, with a clear connection to the results 
and  analysis  in  the  preceding  text.  As  concerns  the  evaluation  part  of  the  study,  the 
findings are more elaborated for some criteria and for the more encompassing provisions 
(notably on “ensuring universal service”).  

While conclusions are anchored in the findings and overall analysis, the evidence base as 
such  is  not  always  solid  in  terms  of  quantifications  (due  to  limited  data  availability). 
Rather than on solid data, much of the evidence base comes from the surveys conducted 
by WIK. There is not always a clear distinction between findings and conclusions. In the 
evaluation section, the conclusions sum up the results for each of the five criteria, and the 
findings  provide  an  overall  view.  The  conclusions  are  non-biased  as  they  are  based  on 
overall  results  and  no  particular  perspective  (e.g.,  from  a  stakeholder  group  or  special 
interest) is given undue weight.   

102 

 
 
 
Cost-benefit analysis 

As  pointed  out  in  section  4  of  the  Staff  Working  Document,  there  are  usually  no 
quantifications (or estimates of monetary values) available as concerns societal benefits. 
The explanations of the cost-benefit analysis in this section takes that into account, and 
also gives background on the analysis done in the efficiency analysis (section 5.2 of the 
Staff  Working  Document).  This  section  is  based  on  input  from  WIK  (2021)  discussed 
above. 

The  efficiency  section  of  the  Staff  Working  Document  discusses  costs  and  benefits  for 
some  of  the  key  provisions  of  the  Directive.  The  table  below  provides  an  overview  of 
costs and benefits analysed in that section. 

Table 13 Costs and benefits of universal service provision and regulation 

Universal service regulation  
(including scope of the universal service obligation, ensuring and financing universal service) 

Compensated  net  cost  of  the  universal  service  obligation  /  price  for  providing 
selected universal services fixed in procurement procedures in order to maintain 
specific services or service levels 

Operational costs for compliance with the Directive’s provisions 

Costs 

Administrative  costs  for  universal  service  providers,  for  non-universal  service 
providers, and for regulators induced by the application of the Directive. 

Postal users’ benefits from universal service regulation 

Social cohesion  

Enabling  reliable  communication  among  citizens,  businesses,  and  public 
institutions 

Benefits 

Enabling access to printed newspapers 

Enabling postal vote 

Create/maintain  comparable 
(territorial cohesion) 

living  conditions 

in  rural  and  urban  areas 

Enabling access to affordable communication services 

Net cost of the operator ensuring the universal service obligation 

The relevant costs come from: 

  having to invest in and maintain additional post offices; 

  having to keep additional network and distribution capacity several days per week in 

all regions, with more use of staff and vehicles; 

  having to keep prices below a profit-maximizing level. 

The obligation to provide the services that the operator could otherwise avoid also brings 
some income flows, so in the net cost calculation, the costs mentioned above are put in 
relation to the benefits the operator gets from universal service provision, such as: 

103 

 
 
  
 
  extra revenues directly related to the additional offices and network, 

  other  extra  (intangible)  revenues  related  to  being  a  universal  service  provider.  Such 
revenues  and  advantages  may  be  of  significant  importance  for  the  universal  service 
provider. They include the following: 

o  brand value and demand complementarities; 

o  economies of scale and scope;   

o  demand effects due to the VAT exemption; 

o  network advantages and enhanced advertising effect; 

o  improved customer acquisition due to uniform price. 

Administrative costs 

The  Directive  induces  general,  administrative  costs  related  to  e.g.  controls  regarding 
price, quality and market opening, such as: 

  costs incurred by regulatory authorities; 

  costs incurred by universal service providers and other operators that have to comply 

with the rules that are set out in the Directive; 

Estimating the administrative costs of regulatory authorities for each of the regulatory 
aspects  is  done  by  investigating  the  postal  budget  of  national  regulatory  authorities, 
where  available  (and  estimate  it  for  a  few  countries  where  postal  budgets  are  not 
published).259  The  share  of  national  regulatory  authorities’  budgets  used  for  regulatory 
activities  related  to  the  Directive  are  subsequently  estimated,  checked/verified  with  the 
members of the European Regulators Group for Postal Services and, finally, the estimate 
is adjusted.  

 Table 14 Total budgets of regulators for postal regulation (figures from 2017 or 2018) 

Regulatory aspect 

Total regulatory budget 

Ensuring  /  monitoring  universal  service  provision  and 
financing  

Quality requirements  

Complaint procedures 

Price regulation 

Administering authorisations & market opening  

Harmonising technical standards 

Source: WIK (2021), p. 166. 

Total EU-28260 
(EUR million) 

Percent share 

45.2 

17.2 

4.5 

9.0 

6.8 

6.8 

0.9 

38 percent 

10 percent 

20 percent 

15 percent 

15 percent 

2 percent 

259 WIK (2021), p. 165-166 
260  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period between  1 

July 2013 and 31 January 2020 and aggregated data referring to any interval of that period. 

104 

 
 
 
 
                                                      
As  shown  in  Table  14  above,  around  38  percent  of  the  national  regulatory  authorities’ 
budget  is  used  for  ensuring  and  monitoring  the  universal  service  provision,  equalling 
approximately  EUR  17.2  million.  This  means  that  EU  national  regulatory  authorities’ 
budgets  amounted to  approximately EUR 0.04 per capita for ensuring universal service 
provision.  The  costs  for  national  regulatory  authorities  for  measuring  and  monitoring 
quality  of  service  include  not  only  administrative  costs  for  reviews,  but  also  costs  of 
regulators  having  to  bear  the  costs  of  quality  measurements.  Price  regulation  induces 
administrative costs for national regulatory authorities amounting to approximately EUR 
6.8  million  in  all  EU  Member  States  combined,  corresponding  to  approximately  EUR 
0.01 per capita on average. 

For  market  opening  the  costs  of  the  national  regulatory  authorities  relate  to  market 
monitoring,  verifying  and  regulating  downstream  access  as  well  as  access  to  postal 
infrastructure elements,  managing  authorisation  procedures, and controlling  compliance 
with the relevant conditions. Such costs are about the same level as administrative costs 
for price regulation meaning that the costs per capita are very low. 

All universal service providers also incur administrative costs as they have to comply 
with the Directive. Such costs relate notably to reporting on the performance of universal 
service provision, maintaining separate accounts for universal and non-universal services, 
applying for authorisations to provide universal postal services, calculating net cost (for 
those that do such calculation) and reporting to national regulatory authorities (in some 
Member States), and requesting approval for tariff increases subject to price regulation 

Only two universal service providers have undertaken the effort to produce cost figures 
for costs of regulation, namely An Post (Ireland) and Royal Mail (United Kingdom). To 
estimate the administrative costs of universal service providers, we use information about 
An Post and Royal Mail as examples, see Table 15 below. 

Table 15 Costs of regulation (universal service providers) 

Country 

Operator 

Year 

Cost (million 
EUR) 

percent of turnover of 
universal services 

EUR per 
capita 

Ireland 

An Post 

2016 

United 
Kingdom 

Royal 
Mail 

2016/201
7 

1.8 

8.7 

0.4 percent 

0.1 percent 

0.38 

0.13 

Source:  ComReg  (2017),  Submissions  in  response  to  consultation  on  Draft  Postal  Strategy  Statement, 

p. 16, as reported by WIK, p. 197. 

Using the relationship between universal service provider costs of regulation provided by 
Royal Mail and An Post on the one hand and the national regulatory authority budgets in 
these  countries  on  the  other  hand,  it  is  possible  to  estimate  the  administrative  costs  of 
other  Member  State  universal  service  providers  stemming  from  postal  regulation.  The 
administrative costs range from below EUR 1 Mio for small Member States to over EUR 
12  Million  for  the  German  universal  service  provider.261  The  total  administrative  cost 

261  WIK estimates (WIK (2021), p. 198) 

105 

 
 
                                                      
amounts to an estimated EUR 75 million in 2018 for the EU28 Member States. It is not 
possible to separate these costs depending on which part of the Directive they relate to. 
Hence,  while  small  in  relation  to  the  turnover  of  universal  services,  compared  to  the 
budgets  of  the  regulatory  authorities,  the  costs  of  universal  service  providers  are  thus 
quite considerable. 

For  universal  service  providers,  the  administrative  costs  of  measuring  quality  (transit 
time  for  postal  items)  as  required  by  the  Directive  vary  substantially  depending  on  the 
scope of universal services reviewed and the letter mail volumes of the relevant universal 
service  provider.  The  cost  of  such  measurements  are  borne  by  the  universal  service 
provider  in  most  Member  States.262  Based  on  discussions  and  interviews  with  various 
universal  service providers, WIK  estimate the  costs for quality measurements borne by 
universal service providers to be very low (less than 0.01 percent of the total cost of their 
mail business).263 The cost is typically below EUR 1 million for large operators per year, 
and even less for smaller operators.  

By adding the estimated total administrative cost for universal service providers and the 
estimated total cost for national regulatory authorities, the costs per capita for ensuring 
universal  service  provision  can  be  estimated  at  below  EUR  0.20  per  year  in  many 
Member States. In addition, while the net cost compensation can vary significantly, with 
some  extreme  cases,  the  State  aid  costs  per  capita  for  ensuring  universal  service 
provision can be estimated at below EUR 1 per year in many Member States. 

Table 16 EU-28264 costs for compliance with the Directive per capita 

Administrative cost 
of universal service 
per 
providers 
capita 

Regulator  budget 
per capita 

Net  cost  /  other 
compensation  per 
capita 

up to EUR 0.15  

EUR 0.04  

EUR 0-6.40 

Provision 

Ensuring  universal 
service provision 

Quality 
requirements 

Less than EUR 0.15 

EUR 0.01 

Price regulation 

Less than EUR 0.15 

EUR 0.01  

Competition,marke
t access 

Less than EUR 0.15 

EUR 0.01 

- 

- 

- 

Societal benefits of universal postal services 

It is not possible to quantify the societal benefits of universal postal services. Universal 
postal  services  means  there  is  a  means  of  communication  and  economic  participation 
throughout the EU, though digital communication is increasingly changing that picture. 

262  Cost borne by operator in 21 Member states, by the regulator in four Member States (no information for 
Denmark and Finland). See European Regulators Group for Postal Services (2019), Report on Quality 
of service, consumer protection and complaint handling, p. 59. 

263  WIK (2021) p. 234. 
264  In this document, EU-28 refers to all Member States of the European Union in the period between 1 

July 2013 and 31 January 2020 and aggregated data referring to any interval of that period. 

106 

 
 
 
                                                      
The magnitude of such benefits are analysed based notably on user surveys. Attempts at 
modelling or estimating data on the monetary value of universal postal services and how 
they  contribute to  improving communication and economic participation  have  not  been 
made, also not at Member State level.  

Table 17 Stakeholders benefitting from universal service provision 

Stakeholders 

Examples of main benefits 

Consumers 

Small and 
medium-sized 
businesses (SMEs) 

Non-profit 
organisations 

  Ensure businesses and public institutions have 
communication channel to citizens and other 
businesses/public institutions 

  Enable economic activity 
  Reliable and affordable postal services 
  Accessibility of postal services for all users, 

including vulnerable groups 

s
r
e
s
u

l

a
t
s
o
P

Senders 
using 
universal 
service 
products 

Receivers 

Society as a whole 

  Social cohesion (basic service available to all, 
irrespective of economic resources or digital 
skills) 

  Create/maintain comparable living conditions in 
rural and urban areas (territorial cohesion) 

107 

 
 
 
 
 
10.  ANNEX 4: ANALYSIS OF THE APPLICATION OF THE POSTAL SERVICES DIRECTIVE, IN 
VIEW OF THE SIXTH APPLICATION REPORT TO THE EUROPEAN PARLIAMENT AND THE 
COUNCIL 

1.  THE MARKET (OVERVIEW OF THE POSTAL SECTOR IN EUROPE) 

1.1 Volumes 

Letter post  

Letter  postal  volumes  in  the  EU  were  stable  or  increasing  until  2008  when  the  global 
financial  crisis  accelerated  substantial  change.  The  impact  of  the  following  economic 
recession led to a decrease in letter post, and volumes never recovered to the levels before the 
crisis. In 2017 in the EU, the number of letter post mail amounted to 59 billion items265, 34 
billion  items  less  than  in  2008,  when  the  third  Postal  Service  Directive  was  adopted. 
Germany, France, and the United Kingdom account for two third of total letter post volumes. 

In  the  period  2008-2017  there  has  been  an  average  yearly  decline  of  -4,9  percent  in  the 
European  Union  (EU28).  This  decline  is  widespread  and  occurring  in  almost  all  member 
states. For most of the countries where data is available this declining trend continues in 2018 
and 2019. Before, in the period 1998 until 2007, volumes increased by 0.52% on average. 

The  contraction  of  the  economy  due  to  Covid-19  crisis,  where  letter  mail  volumes  are 
estimated  to  have  dropped  in  the  range  of  –12  percent  and  –26  percent266  accelerates  the 
structural letter post volume decline. 

Figure 8 Letter mail volumes, 2008-2019 

Source: Based on raw data of WIK (2021), the Commission added data for years 2018 and 2019 when available 
from public sources. 

The  historically  strong  correlation  between  the  level  of  economy  activity  and  letter  post 
volumes per  capita still  holds to  a certain  extent. The Member States  with  a high GDP per 

265 EC calculations based on raw data of WIK (2021) 
266 Copenhagen Economics (2020), results of 8 universal service providers in the EU 

108 

 
 
 
                                                      
capita  still  have  the  highest  letter  post  volumes  per  capita.  The  EU  average  was  about  97 
items per capita. 

Figure 9 Letter mail per capita, 2018 

Source: EC postal statistics 

Ninety-three percent of letter post mail is sent domestically, and inbound and outbound letter 
post represent respectively only 4 percent and 3 percent of the total. There is some divergence 
across  countries  for  the  share  of  inbound  letter  post  where  in  a  few  Eastern  European 
countries (Czech Republic and the Baltic states), Luxembourg and in all the island countries 
(Cyprus, Ireland, Iceland and Malta) it reach higher levels of at least 10 percent of total mail.  

Parcel delivery services 

Online shopping took-off in the early 2000s, when the internet became more widely available 
to  the  public.  Since  then  e-commerce  drives  the  growth  of  parcel  and  express  delivery 
services. Especially in the last years there is an acceleration in the parcel volume growth.  

Globally,  the  average  growth  in  parcel  volumes  in  the  second  quarter  of  2020,  during  the 
COVID-19 lockdown, was 43 percent267. The trend has continued throughout the rest of the 
year.268  At  the  same  time,  international  mail  fell  by  27  percent,  especially  flows  from 
China.269 Before the pandemic, global online sales were predicted to roughly double between 
2019  and  2024,  but  recent  trends  suggest  the  COVID-19  crisis  will  push  this  timeline 
forward270  and  a  stronger  growth  of  intra-EU  parcel  traffic  than  of  incoming  international 
traffic  is  likely.  Findings  from  a  recent  representative  survey271  confirm  that  51%  of 
consumers  bought  more  from  domestic  e-retailers  and  33%  bought  more  from  foreign  e-

267  IPC (2020), p. 9. 
268  22  European  national  regulators  reported  on  increased  parcel  volumes  in  August  (compared  with  15 

reporting in April), European Regulators Group for Postal Services II (20) 26. 

269  IPC (2020). 
270  Ibid. 
271 https://www.ipc.be/shopper (February 2021) 

109 

 
 
 
                                                      
retailers  due  to  COVID-19  and  that  China’s  share  of  cross-border  e-commerce  purchases 
decreased for the first time in 2020. 

Figure 10 Growth rate parcels, domestic and international service -dispatch, EU 27 

Source : UPU postal statistics, EU27 aggregate, designated operators, exclude express and incoming parcels 

Statistics on the total size of the market of parcel and express delivery services, capturing the 
volumes of all the providers are not available for the entire period 2008-2018. UPU statistics 
for  EU27  for  the  period  2008-2018272  show  that  parcel  volumes  from  designated  operators 
(excluding  incoming  and  express  items)  increased  annually  by  9  percent.  There  are 
indications  that  some  challenges  related  to  cross-border  e-commerce  delivery  may  still 
remain as concerns consumer experiences.273 

Parcel volumes, including volumes of other parcel operators and express items, are estimated 
to  have  reached  around  9  billion  items  in  the  EU28  by  2018274.  Germany,  France,  and  the 
United Kingdom account for two third of total parcel volumes.  

Postal recipients of high GDP per capita countries on average tend to receive more parcels. In 
2018, the EU average was 12 parcels per year. 

272 UPU postal statistics, EU27 aggregate, designated operators, exclude express and incoming parcels 
273 Report on the first short-term review of the Geo-blocking Regulation, COM (2020), 766 final.    
274 EC postal statistics, domestic and outbound 

110 

 
 
 
                                                      
Figure 11 Parcels per capita, domestic and inbound, 2018 

Source: EC postal statistics 

In contrast with letter post the share of international parcel delivery services is higher, with 
incoming  (inbound)  and  outgoing  (outbound)  parcels  representing  respectively  10  percent 
and 11 percent of total volumes in the EU.  

Figure 12 Parcel volumes, EU28, 2018 

Source: EC postal statistics 

Growing  parcel  volumes  have  not  compensated  yet  the  letter  volume  decline  in  terms  of 
number  of  items.  In  2018,  the  share  of  parcels  represents  only  14.5  percent  of  all  postal 
items275. Bulgaria is the only EU country where more parcels than letters are sent. 

1.2 Main drivers of change in the postal sector 

Economic  activity  was  historically  the  main  driver  of  letter  volumes276.  There  is  some 
evidence  that  the  strength  of  the  relationship  weakens  when  digitalisation  of  a  country’s 

275 Based on raw data, EC postal statistics 
276 WIK (2013), pp 194-200. 

111 

 
 
 
 
                                                      
economy intensifies strongly, and notably when government and businesses actively oblige or 
incentivize  the  population  to  use  digital  communication  tools.  This  is  a  major  example  of 
how the postal industry has been affected by exogenous structural phenomena in recent years. 
In  the  last  5  years,  large  postal  senders  such  as  government  and  businesses  have  been  an 
important  driving  force  for  the  replacement  of  postal  products  by  digital  solutions.  They 
increasingly replace paper-based communication with office and transactional mail.  

In  many  areas,  but  certainly  not  all,  paper-based  communication  has  been  replaced  by 
electronic  communication.  There  are  several  drivers  of  developments  in  the  postal  market, 
involving  competitive  pressure  from  other  sectors,  notably  digitisation  of  business 
communication,  of  private  users’  communication,  and  use  of  e-government  services. 
Evolving technical solutions, such as use of hybrid mail also play a role, as does the general 
internet access.  

Compared  with  2007,  the  share  of  online  shoppers  in  the  EU  population  has  more  than 
doubled  from  27  percent277.  In  2019,  60  percent  of  people  has  shopped  online,  a  further 
increase  of  11  percentage  points  since  2015.  The  European  B2C  e-commerce  market  is 
estimated to have increased from EUR 307 billion in 2013 to EUR 636 billion in 2019. This 
means an average annual growth of 13 percent.278   

Business communication as a driver 

In  the  recent  years,  digitisation  has  significantly  changed  the  way  companies  communicate 
with their customers, suppliers, partners and government. Still, the share of companies using 
e-commerce  and  e-invoicing  is  still  relatively  low  compared  to  the  use  of  electronic 
communication of private users. In 2018 on average 21 percent of companies (with more than 
10 employees) in the EU-28279, received their orders electronically, which in turn relates to 
17  percent  of  their  total  turnover.  Compared  to  2014,  this  means  marginal  increases  of 
2 percentage points in the share of companies and 3 percentage points in turnover. 

Enterprises  are  part  of  supply  chains  with  other  suppliers,  distributors  and  large  customers. 
They have connected their business processes and related systems, such as stock keeping. A 
specific  aspect  of  linking  enterprise  processes  electronically  with  their  suppliers  and 
customers  relates  to  online  purchases.  On  average,  27  percent  of  enterprises  purchase  their 
materials  and  components  from  suppliers  online  in  2018  versus  23  percent  in  2014.280  The 
development  of  online  purchasing  depends  largely  on  how  online  marketplaces  for  B2B 
develop  in  the  years  to  come.  Today,  the  impact  of  B2B  online  market  places  still  seems 
limited.  This  might  be  due  to  less  transparency  in  business  markets  and  complex  supply 
chains.  

At European level, public administrations have been modernised and there has been a strong 
push towards e-invoicing with the Directive on electronic invoicing in 2014.281 The push for 

277 Eurostat, ICT indicators 
278 Estimate from Ecommerce Europe, as quoted by WIK (2020), p. 47. 
279  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period  between  1  July 
2013 and 31 January 2020 and aggregated data referring to any interval of that period.  
280 Eurostat, as quoted by WIK (2021) p. 58-59. 
281 Directive 2014/55/EU 

112 

 
 
                                                      
e-government is increasing the replacement of letter products for businesses, especially when 
it  comes  to  government  e-procurement  and  related  e-invoicing.  It  should  be  noted,  though, 
that  the  replacement  of  traditional  mail  between  companies  could  also  be  slowed  down  in 
certain  sectors  due  to  legal  requirements  or  the  legal  character  of  mail  exchange.  For 
example,  the  judicial  sector  or  regarding  certain  activities  where  legal  accountability  is  an 
important  factor  and  a  paper  trail  or  secured  archive  is  of  utmost  importance.  E-invoicing 
may be the form of business digitisation that has the most direct effect on postal operators. 
From  the  figure  below,  it  is  clear  that  on  average  at  least  25 percent  of  EU  enterprises  are 
able  to  generate  their  invoices  electronically.  There  are  large  differences  among  Member 
States, however. The Nordic countries are forerunners, with more than half of the enterprises 
sending e-invoices but overall it may be concluded that invoices are still an area where most 
enterprises prefer to send letters and where there is a large potential for replacement of letters 
by digital solutions in the future. 

Figure 13 Percentage of enterprises sending e-invoices suitable for automated processing (2018) 

Source:  Eurostat, quoted in WIK (2021), p. 57.  

Note:   Ø measures the average for EU-28282 plus NO. 

The  pace  of  digitisation  and  replacement  of  B2X  letters  differs  between  Member  States, 
between sectors and between large companies and SMEs. Attractive price strategies of postal 
operators,  in  an  attempt  to  maintain  certain  mail  volumes,  can  be  effective  if  aimed  at 
enterprises  shifting  towards  electronic  variants,  as  the  implementation  costs  and  related 
personal efforts can be significant. However, this will most likely only delay replacement of 

282  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period  between  1  July 

2013 and 31 January 2020 and aggregated data referring to any interval of that period.  

113 

0102030405060708090FISIDKNOITSEESLTPTFREENLBEIEATROMTDELUPLSKCZBGHRUKCYHUELLVØ% of enterprises sending e-invoices 
 
 
 
                                                      
letters as costs  are only  one factor.  Faster  response on demand  and supply  fluctuations  and 
increased  data  collection  of  their  information  flows  are  other  factors  which  drive  the 
integration  of  systems  in  between  enterprises  and  with  their  partners  in  the  supply  chain. 
Once  competitors  in  the  market  have  gone  this way  and  as  a  result  strengthen  their  market 
position,  it  will  only  be  a  matter  of  time  for  other  competitors  to  follow  which  will  then 
further increase the rhythm of letter replacement. 

Private communication as a driver 

Internet access crossed a boundary in 2007, when a majority (55 percent) of households in the 
EU-28283 had internet access. This proportion continued to increase, passing three quarters in 
2012  and  four  fifths  in  2014284.  By  2019,  the  share  of  EU-27285  households  with  internet 
access had risen to 92 percent, some 29 percentage points higher than in 2008286, and ninety 
percent of households had broadband. 

In 2019, more than three quarters (77 percent) of individuals in the EU-27 actually accessed 
the  internet  on  a  daily  basis  with  a  further  7  percent  using  it  at  least  once  a  week  (but  not 
daily).  In 2009 only 46  percent  used internet  on a daily basis.287 Connecting to  the internet 
became easier with  more people using portable  computers or handheld  devices, and mobile 
phone  networks  or  wireless  connections  to  connect  in  another  location  than  home  or  work 
place. In 2013, 39 percent of the population in the EU-27 used a mobile device to connect to 
the  internet,  while  by  2019  this  share  had  risen  to  73  percent.  There  has  generally  been  an 
increase in the proportion of individuals that use the internet to send and receive e-mails in 
Europe  from  2014  to  2018.  On  average,  73 percent  of  all  individuals  in  the  EU-28288, 
Norway, Iceland, and Switzerland used the internet to send and receive e-mails in 2018. 

Another  platform  that  increasingly  more  people  use  to  communicate  are  the  various  social 
networks. The figure below illustrates the share of individuals for a number of countries that 
use the internet to participate in social networks between 2014 and 2018. The participation in 
social networks has increased from 2014 to 2018 in all countries, as shown in Figure 14 below.  

283  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period  between  1  July 

2013 and 31 January 2020 and aggregated data referring to any interval of that period. 

284 

https://ec.europa.eu/eurostat/statistics-explained/index.php/Digital_economy_and_society_statistics_-

_households_and_individuals#Internet_access 

285 In this document, EU-27 refers to all Member States of the European Union between January 2007 and 30 

June 2013 and aggregated data referring to any interval of that period. 

286 Eurostat ICT survey 
287 http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=isoc_bdek_di&lang=en 
288  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period  between  1  July 

2013 and 31 January 2020 and aggregated data referring to any interval of that period. 

114 

 
 
                                                      
Figure 14 Individuals’ internet use to participate in social networks, 2014-2018 

Source:  Eurostat, quoted in WIK (2021), p. 64.  

Note:   Ø measures the average for EU-28289 plus IS, NO and CH. Most recent data for CH is 2017. 

The  group  of  individuals  who  use  the  internet  for  social  communication  today  includes  the 
vast majority of the population in almost all Member States. E-mail, social networks, and the 
use  of  multiple  internet  access  devices  have  reached  all  age  groups.  Consumer  letters  and 
cards have seen the most dramatic decline in volume over the past years and this trend will 
continue  as  the  age  groups  of  55-64 years  and  over  go  on  to  adopt  fixed-line  and  mobile 
internet applications. The group of people who never used the internet is declining and will 
become even more marginal over time, however, considerable variations between age groups 
and Member States will probably remain for the next 5-10 years. 

Government as a driver (e-government services) 

The possibility to interact with public authorities over the internet is slowly beginning to gain 
traction. There has been an increase of individuals interacting with public authorities online 
over the period of a year between 2014 and 2018 for most of the sample countries, with an 
overall increase from 53 percent to 58 percent of individuals. 

289  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period  between  1  July 

2013 and 31 January 2020 and aggregated data referring to any interval of that period. 

115 

0102030405060708090100ISNODKBESEUKMTCYFINLHULUEELVROIESKPTESLTCZHRATCHDEELBGPLSIITFRØ% of individuals20142018 
 
 
                                                      
Figure 15 Individuals’ internet use to interact with public authorities in the last 12 months, 2014-2018 

Source:  Eurostat, quoted in WIK (2021), p. 67.  

Note:   Ø measures the average for EU-28290 plus IS, NO and CH. Most recent data for CH is 2017. 

Few Member States have already managed to introduce e-government solutions in almost all 
public  service  areas.  It  may  be  concluded291  that  countries  with  strong  e-government 
initiatives  have  lost  more  letters  per  capita  than  those  countries  where  digitization  is 
relatively  lower.  For  instance,  in  Denmark  the  government  launched  an  e-government 
strategy in  2011, declaring that  by 2015 80 percent of the communication between citizens 
and public authorities should be digital. Consequently the Danish letter volumes dropped by 
61 percent in 2011-2017.292  

The vast majority is only halfway or made even less progress. It can therefore  be assumed 
that  in  most  Member  States  the  replacement  of  Gov2X  letters  by  digital  solutions  has  only 
just  started  and  will  proceed  even  more  quickly  with  the  full  implementation  of  the  “E-
Government Action Plan” and the Single Digital  Gateway by 2023 with its principles One-
Stop-Shop, Once-Only, and Digital-by-Default. Especially businesses will profit enormously 
from e-government solutions and this development can have spill-over effects towards B2B 
digital  communication.  Government  could  also  play  a  role  through  roll-out  of  new 
infrastructures  (5G  mobile  network)  and  obligations  of  public  authorities  to  use  e-
procurement platforms might accelerate the development. 

290  In  this  document,  EU-28  refers  to  all  Member  States  of  the  European  Union  in  the  period  between  1  July 

2013 and 31 January 2020 and aggregated data referring to any interval of that period. 

291 WIK (2021), p. 25. 
292 Calculations based on raw data WIK (2021). 

116 

0102030405060708090100DKISNOSEFINLEECHFRATLVLUUKDEESBESIIEHUCZSKLTELMTCYPTHRPLITBGROØ% of individuals20142018 
 
 
 
                                                      
Technical development as a driver - hybrid mail 

Hybrid mail is an electronic-based postal service where the sender posts the original message 
electronically  and  a  hybrid  mail  service  provider  then  processes  the  message  either  via  a 
(secure)  electronic  mail  system  or  (depending  on  the  recipients  preferences  and  technical 
possibilities)  into  a  letter-post  item  for  physical  delivery.293  Technical  progress  in  IT 
software,  interfaces  and  print  technology,  as  well  as  the  growing  ambition  of  companies  to 
digitise internal processes, have had an impact on supply and demand for hybrid mail.  

Hybrid mail solutions potentially facilitate the transition process from paper-based to digital 
communications. The solutions could also help with narrowing the “digital divide” between 
people that do not use the internet and people using digital devices for communicating with 
government  authorities.  Today,  hybrid  mail  customers  are  usually  small  and  medium-sized 
enterprises and local public authorities but also large senders, e.g. insurance companies, who 
outsource  outgoing  mail.  Hybrid  mail  offers  new  business  opportunities  for  IT  solutions 
providers,  printing  businesses  and  postal  service  providers.  However,  awareness  of  and 
demand for hybrid mail solutions still seems to be rather low. 

Figure 16 Use of hybrid mail solutions in future (respondents using hybrid mail, in per cent) 

Source: WIK (2021), p. 46.  

Businesses  are  in  principle  ready  for  digitisation  and  replacement  of  letters.  However,  for 
some  crucial  purposes  like  invoicing  the  overall  majority  still  uses  traditional  letters. 
Digitisation  of  B2B  communication  has  not  yet  reached  its  peak.  Roll-out  of  new 
infrastructures  (5G  mobile  network)  and  obligations  of  public  authorities  to  use  e-
procurement platforms might accelerate the development. There are also factors which slow 
down  the  replacement  of  letters  by  digital  solutions.  Reasons  for  letter  mail  still  being 
preferred in businesses compared to private communication are, for example, availability and 
affordability of broadband, qualification of personnel, IT budgets, and also legal requirements 

293  Defined  in  CEN/TS 16326:2013,  Postal  Services  -  Hybrid  Mail  -  Functional  Specification  for  postal 

registered electronic mail. 

117 

0102030405060708090100Business or businessassociationPublic institution orpublic authorityAllShare of respondents (in %) less than todayto the same extent as todaymore than today 
 
 
                                                      
and  security  or  archiving  issues.  The  trend  towards  digitisation  and  replacement  of  B2X 
letters  advances  at  a  different  pace  in  the  Member  States,  in  different  sectors  and  in  large 
companies  versus  SMEs,  however,  it  will  not  come  to  a  halt  in  future.  Policy  makers  and 
operators can expect continuous volume decline in this segment. 

1.3 Changing User Needs 

The  societal  need  to  ensure  bidirectional  communication  and  broadcast  information  is 
increasingly  being  fulfilled  by  internet  and  digital  services.  Broadband  coverage  has 
overtaken  the  role  that  postal  networks  used  to  play  in  the  past  for  ensuring  the  economic, 
territorial  and  social  cohesion  of  the  European  Union.  The  fact  that  the  7th  Report  on 
Economic,  Social  and  Territorial  Cohesion  (2017)  does  not  mention  postal  services  at  any 
point294 testifies to this.  

As  the  role  of  the  postal  service  in  society  is  changing,  postal  operators,  regulators  and 
governments have been undertaking in the last years studies and surveys of the postal users in 
their  countries.  The  Commission  contracted  an  extensive  in  depth  review  of  this  body  of 
research that summarized the main trends of the users’ behaviour and preferences. Even if the 
Directive  does  not  differentiate  between  individual  consumers  and  business  users  of  postal 
services,  most  surveys  address  these  two  groups  separately  and  identify  particularities  for 
each regarding the purposes of using postal services, the alternatives for letter post, and the 
rationale behind the choice for different means of communication.  

The decline in letters and increase in parcels already manifest in the last decade (see section 
1.1  of  Annex  4)  corresponds  to  the  behaviour  trends  evidenced  by  most  consumer  surveys 
reviewed: people, and especially younger people, send less letters and cards and receive more 
parcels than older generations used to. This is a reliable indication that this trend is likely to 
continue  into  the  future295.  However,  experts  do  not  agree  on  whether  letters  will  ever 
completely disappear under the pressure of digital alternatives296.  

Digital solutions replace private letters more than business letters. Consumers/private citizens 
increasingly  use  the  postal  product  of  letters  only  for  special  occasions,  for  ceremonial 
purposes,  to  send  congratulation  or  invitation  cards.  Business  users,  especially  the  less 
digitized small and medium enterprises, still use letter mail for administrative purposes and 
marketing, but rely increasingly on digital solutions and 32 percent expect to do so more in 
the future. Public administrations progressively digitalise their interactions with constituents, 
but  the  efforts  are  very  different  between  Member  States.  The  one  group  for  which  letters 
seem to maintain their importance is that of blind and partially sighted citizens, who rely on 
mail for the transfer and distribution of Braille publications297.  

The results of the WIK online survey (see Figure 17) indicate that the majority of stakeholders 
in  the  postal  sector  in  Europe,  i.e.  regulators,  operators  and  postal  users,  expect  significant 
volume declines for all postal segments, except parcels (fulfilment). More than 60 percent of 
respondents expect declining volumes of correspondence (i.e. transactional mail, office mail 

294 WIK (2021), p.139 
295 WIK (2021), pp.93 
296 WIK (2021), pp.106 
297 WIK (2021), p.93-94 

118 

 
 
                                                      
and social mail) and more than 30 percent expect significant volume declines of more than 20 
percent during the next ten years. Direct mail will also decrease, but at a slower pace. Even 
the  fact  that  an  increasing  number  of  small  e-commerce  goods  will  ship  as  letter-mail  will 
only slow down the overall letter volume decline, not stop or reverse it298. 

Figure 17 Stakeholders’ expectations of letter volume development over the next 10 years 

Source:  WIK Stakeholder online survey 2019, WIK (2021) 

Question: In your opinion, how much do you expect postal volumes for each of the following mail categories  to change in 
the future (in 5-10 years)? 

The trend of digital solutions gradually replacing letters as a means of communication is clear 
and  looks  irreversible,  but  its  speed  is  not  steady  or  completely  predictable  and  it  does  not 

298 WIK (2021), pp.83-85 

119 

15%13%49%50%13%35%33%14%68%74%20%51%58%18%59%63%31%8%5%43%33%39%23%30%49%40%25%21%27%41%37%28%31%29%24%3%3%29%18%11%28%10%10%17%8%5%24%8%26%10%18%28%18%14%25%25%8%22%22%5%20%8%13%61%74%1%11%7%7%8%0%20%40%60%80%100%Postal usersOperatorsRegulatorsPostal usersOperatorsRegulatorsPostal usersOperatorsRegulatorsPostal usersOperatorsRegulatorsPostal usersOperatorsRegulatorsPostal usersOperatorsRegulatorsFulfilmentPeriodicals &NewspapersDirect mailSocial mailOffice mailTransactionalmailShare of respondentsstrong decline (>20%)slight decline (<20%)no changeslight increase (<20%)strong increase (>20%) 
 
 
 
                                                      
evolve at the same pace in all Member States. However, with Denmark, The Netherlands and 
Estonia leading the way both in adoption of digital solutions at country level and decline in 
letter  use,  there  seems  to  exist  a  weak  but  plausible  correlation  between  the  availability  of 
broadband internet and digital skills and the decline in letter usage. Nevertheless, letter mail 
still represents a substantial part of the postal business in many Member States, even though 
the share varies substantially between France where letters still represent 78 percent of postal 
volumes and Bulgaria where they represent only 4 percent299. 

Network coverage, delivery to the door 

A  number  of  national  surveys  indicate  that  private  citizens  seem  to  appreciate  the  fact  that 
they are virtually connected by a nation-wide postal network that covers their entire country 
and having the possibility to send letters or parcels to any point in this territory. They rely on 
the role of the postal network in ensuring social cohesion. 

The  presence  of  a  postal  outlet  in  the  vicinity  and  a  dense  network  of  postal  outlets  is 
regarded  by  a  majority  of  respondents  to  the  WIK  online  survey  as  indispensable  in  the 
future,  for  postal  or  other,  financial  or  community  services.  Qualitative  research  indicates 
plausibly  that  the  accessibility  of  postal  outlets  is  especially  important  for  people  with 
reduced  mobility  and  people  living  in  remote  areas.  Access  to  at  least  one  default  e-
commerce return option, collection points for parcels and for registered items are mentioned 
as crucial for these user groups300. 

Regarding the role of the postal outlets, some postal user surveys show that in Germany and 
the Czech Republic they are mostly used for postal services and increasingly less for financial 
services,  unlike  in  Malta  where  they  are  still  used  for  the  payment  of  bills.  Basic  financial 
services  are  offered  in  postal  outlets  as  part  of  a  public  service  obligation  in  the  Czech 
Republic, France and many Eastern Member States.  In some countries, like Sweden, postal 
outlets are the standard delivery location for parcels or the standard fall-back solution if the 
universal  service  provider  fails  to  deliver  at  the  first  attempt.  They  are  often  used  to  buy 
stamps  and  to  send  registered  letters  and  parcels  (including  ecommerce  returns)  and  in 
Portugal they are important for citizen’s daily life in rural areas. 

Despite  the  continuous  tendency  to  decrease  the  density  of  the  postal  network,  the  WIK 
(2021)  study  shows  that  consumers  seem  usually  satisfied  with  the  number  and  density  of 
postal  outlets  as  well  as  with  services  provided.  It  is  however  not  clear  if  the  consumers 
surveyed  had  recently  been  exposed  to  the  shutting  down  of  postal  outlets.  Surveys  from 
some  Member  States  indicate  that  consumers  request  a  higher  density  (Poland)  and  longer 
opening hours (Portugal, Romania) to improve the accessibility of postal outlets in the early 
morning,  evening  and  at  weekends,  so  that  the  increasing  number  of  e-commerce  delivery 
can be collected or returned.  

The European postal regulators report that postal users generally disagree with any proposals 
to  reduce accessibility,  especially in  the  case of  delivery to  the doorstep  (home delivery)301 

299 EC postal statistics  
300 WIK (2021), p.114 
301 European Regulators Group for Postal Services (16) 36, p. 28. 

120 

 
 
                                                      
and  they  prefer  the  delivery  mode  they  are  used  to.  Numerous  surveys  indicate  that  both 
private  users  and  SME’s  prefer  ‘delivery  to  the  door’  (letters  and  letter-box  sized  small 
packages are delivered to the letter box of each household/business) over ‘community letter 
boxes’  (centrally  situated  letter  boxes  where  individuals  and  businesses  can  collect  their 
postal items) and, when asked, they refuse to give up one for the other.  

The  exact  method  of  parcel  delivery  varies  greatly  among  Member  States:  from  the 
predominance of delivery at the doorstep to pick-up from a parcel locker or from the nearest 
postal  outlet.  Surveys  indicate  that  in  some  countries  consumers  are  willing  to  accept 
alternative  delivery  locations  for  parcels  additional  to  home  delivery  (Denmark,  Germany, 
Malta). Which type of delivery location is preferred also depends on availability (e.g. parcel 
lockers  are  not  available  in  all  countries  and  usually  situated  in  densely  populated,  urban 
regions) and age of the user (younger people are more willing to use parcel lockers instead of 
postal outlets). E-retailers and business/private consumers welcome how parcel carriers build 
up alternative pick-up and drop-off points for more convenient online-shopping302. 

Frequency of collection and delivery 

Respondents to a dedicated survey considered daily delivery (5 days/week, as mandated per 
the  Directive)  more  important  in  the  case  of  transactional  mail,  office  mail  and  all  parcels 
(B2X,  C2X,  e-commerce  returns  and  e-commerce  goods),  than  in  the  case  of  direct  mail, 
consumer letters and cards, newspapers, and “other” postal items303. 

Surveys  from  six  Member  States  show  that  a  majority  of  consumers  would  accept  four 
delivery  days  (or  less)  and  only  two  surveys  found  a  majority  of  the  local  private  users 
reluctant to accept a reduction of the frequency of delivery. Business users, on the other hand, 
both  receivers  and  senders,  seem  more  reluctant  to  accept  reductions  of  the  delivery 
frequency for letters304.  

Speed of delivery 

The results of a dedicated survey suggest that respondents value speed of delivery as slightly 
more  important  than  the  daily  delivery  of  postal  items.  It  is  possible,  however,  that  the 
consumers failed to see the correlation between frequency of delivery and speed of delivery. 
The speed of delivery is rated as being more important for transaction mail, office mail and 
parcels than for consumer letters, cards or newspapers305.  

The  results  of  the  literature  review  show  that  in  many  countries  (Belgium,  France,  Ireland, 
the Netherlands and Romania) a slower delivery standard appears acceptable for both private 
and business users, but both user groups would only accept a slower delivery standard if there 
is a choice between next-day delivery for urgent postal items and slower delivery service for 
less urgent items. Also, users expect to benefit from lower postal tariffs if they accept slower 
delivery. 

302 WIK (2021), p.108 
303 WIK (2021), p.108 
304 WIK (2021), p.109 
305 WIK (2021), p.110 

121 

 
 
                                                      
It appears that the need for next-day delivery services also correlates with the access to digital 
infrastructure and solutions. For example, Danish citizens without internet access prefer next-
day  delivery  while  those  with  internet  access  are  open  for  slower  delivery  standards.  In 
Sweden, overnight delivery is of greater importance for the elderly and respondents in areas 
with poorer accessibility306. 

There  are  countries  (Belgium,  Ireland,  the  Netherlands,  and  Sweden)  where  postal  users 
favour  reliably  predictable  delivery  services  (e.g.  day-definite  delivery)  over  overnight 
delivery or delivery on five days per week. The postal users of Poland value delivery on time, 
especially in the case of parcels. 

The literature review indicates an increasing need of postal users, in their role as recipients of 
e-commerce parcels, for more flexibility and predictability in the delivery time (day and time 
of day). This requires more flexibility in the delivery days (e.g. deliveries on Saturdays and 
Sundays),  as  well  as  in  the  delivery  time.  In  this  context,  individual  users  wish  to  have  a 
delivery  in  the  late  afternoon  or  in  the  evening  of  registered  items  and  bulkier  parcels  that 
both  usually  need  a  personal  handover.  Business  users  (with  constantly  manned  offices) 
usually prefer delivery in the morning. 

Vulnerable users 

The WIK study307 has identified five groups that are, in the context of progressing digitisation 
and e-substitution, more likely than others to be dependent on postal services. These groups 
combine characteristics like low income, lack of digital skills, residence in remote and rural 
areas, and reduced mobility or disabilities. The low-income group was estimated to more than 
23  percent  of  the  EU  population  in  2016,  unevenly  distributed  between  Member  States. 
Persons with reduced mobility, who can either be elderly (105 million people over 65 years), 
or  have  a  disability  (74  million),  may  face  particular  difficulties  reaching  the  nearest  post 
office  if  the  density  of  postal  outlets  were  reduced.  This  also  applies  to  the  inhabitants  of 
rural  or  remote  areas  (97  million  in  2017,  19  percent  of  all  EU  population),  who  represent 
more than half of the population of Estonia, Ireland, Slovenia and Romania. Although rapidly 
decreasing, 12 percent of EU citizens still lack the necessary digital skills to use the internet 
at  all  and  25  percent  of  those  who  use  it  report  low  levels  of  digital  skills,  which  could 
prevent them from replacing letters with digital solutions308. Visually impaired persons rely 
heavily on letters and currently receive Braille documents free of charge.  

1.4 Prices 

Letters 

Between  1998  and  2019  real  prices309  of  the  most  commonly  used  letter  mail  product,  a 
single piece priority letter 20g, increased annually on average by 2.7 percent in the European 
Union. 

306 WIK (2021), p.111 
307 WIK (2021), pp.118-134 
308  Wik Consult (2020), User Needs and Evaluation of the Regulatory Framework, p.126. 
309 Prices corrected for inflation 

122 

 
 
                                                      
Figure 18 Real price for priority domestic letter 20g: CAGR 1998-2019 

Source: Based on raw data of WIK (2021) 

In the first years after the adoption of the Directive, end of the nineties until the third revision 
of  the  Directive,  prices  corrected  for  inflation  in  the  Member  States  increased  slightly  by 
0,48%  on  average  per  year,  but  this  changed  after  the  financial  crisis  in  2008  when  price 
increases  started  to  accelerate.  This  sharper  increase  coincides  with  accelerated  letter  mail 
volume decline and the modus shift from physical letters to digital communication310.  

Figure 19 Public tariff for domestic priority letter 20g (real prices, Euro)  

Source: Based on raw data of WIK (2021) 

Price information of universal bulk mail (for larger senders) is not always published, although 
the  Directive  requires  transparency  and  non-discrimination  when  it  is  in  the  scope  of  the 

310 Exception for EU Member States that joined after 2007 (Romania, Bulgaria, Croatia) 

123 

 
 
 
 
                                                      
USO.  Bulk  mail  is  for  a  large  part  in  the  hands  of  large  mailers  such  as  banks,  utility 
companies,  and  public  authorities.  As  the  bulk  senders  hold  some  purchasing  power,  it  is 
reasonable to conclude that the price increase in this segment will have been more moderate 
than for single piece letters.  

There  is  no  accurate  data  on  the  price  elasticity,  but  it  is  expected  that  letter  prices  will 
become more elastic as the digitisation of the economy intensifies. 

Parcels 

Between  2014-2019  prices  for  a  standard  2  kg  parcel  show  a  moderate  price  growth.  The 
domestic  nominal  price  of  a  standard  2kg  universal  parcel  on  average  increased  by  1,0 
percent  annually,  and  the  nominal  price  of  the  cheapest  and  most  expensive  cross-border 
destination by  respectively 2.6  percent and 0.3  percent.  In 2019 a standard domestic parcel 
2kg in the European Union costs on average EUR 5.5, compared to a much higher price311 for 
the cheapest and for the most expensive cross-border destination.  

Figure 20 Parcel prices in EUR, 2 kg, domestic and intra-EEA, 2019 

311 EUR 17.3 for the cheapest and EUR 25.7 for the most expensive cross-border destination in the EEA 

124 

 
 
 
  
                                                      
Source: EU postal statistics 

More  recent  information  from  the  web  tool  on  cross-border  parcel  prices312  covering  the 
prices  for  1400  of  parcel  and  express  services  from  more  than  378  operators  shows  a 
marginal increase overall for parcels, and for certain operators a small price decrease between 
2019 and 2020. 

Between  the  Member  States  there  is  also  a  large  price  difference  for  cross-border  parcels. 
When  the  price  to  send  a  universal  cross-border    parcel  is  identified  as  high  compared  to 
prices  of  other  Member  States  the  postal  regulatory  authority  is  required  under  the 
‘Regulation  on  cross-border  parcel  delivery’  to  perform  a  price  assessment,  where  it 
examines cost elements and assesses if cross-border prices are not too high. 

The price of sending an international parcel can depend on what zone the destination country 
is  in.  For  cross-border  parcels  several  universal  service  providers  countries  adopt  uniform 
prices  (Germany,  Denmark,  Italy,  Sweden).  The  majority  have  only  two  or  three  different 
prices  depending  on  the  destination  country.  There  are  a  few  countries  (Estonia,  Latvia, 
Lithuania, Latvia, Malta and Romania, which apply almost for every destination a different 
price.  

Figure 21 Number of geographical zones applied for the pricing of intra-EEA standard 2kg parcel, 2018 

Source: EC postal statistics 

312 https://ec.europa.eu/growth/sectors/postal-services/parcel-delivery/public-tariffs-cross-border_en 

125 

 
 
 
                                                      
 
1.5 Competition, operators, ownership, performance, profitability 

When volumes decline, nearly all senders in a market mail less, rather than some senders stop 
using  mail  and  others  keeping  their  volumes  stable.  Receivers  also  receive  less  mail  while 
delivery staff has to make its rounds to every street, as it is rare that there is no mail for all 
inhabitants in a specific street. Operators therefore have to keep the same network to meet the 
needs of both senders and receivers, albeit with reduced general volumes. This makes it more 
difficult  to  realise  economies  of  scale  which  is  a  necessity  for  a  postal  business  to  be 
profitable. 

Before the Postal Services Directive was  introduced, postal  operations were mainly manual 
processes  with  a  low  level  of  mechanical,  not  to  mention  automated,  sorting.  The  apparent 
lack of efficient operations translated into loss-making mail  activities of postal  operators in 
the 1990s. At that time, postal operators were organized as State administrations rather than 
commercially oriented companies. According to the EC Green Paper, ten out of twelve postal 
administrations had loss-making mail services in 1988.313 

According  to  the  available  data  submitted  by  the  European  Regulators  Group  for  Postal 
Services,  in  2019  the  number  of  active  postal  service  providers  in  the  EU,  which  includes 
smaller  parcel  delivery  operators  and  individual  subcontractors,  amounted  to  18364  across 
the  EU,  down  from  20127  in  2014.  These  include  small  parcel  delivery  operators  and 
individual subcontractors. 

Most  of  the  alternative  postal  operators  are  active  only  on  the  parcel  and  express  markets. 
Many are growing thanks to the dynamic competitive market. The universal service providers 
have  much  lower  market  shares  in  the  parcel  segment  than  in  the  letter  segment,  with  an 
average around 28 percent for the period 2014 to 2018314. The dynamics of the letter segment 
is very different.  

End-to-end competition occurs where letters are collected, processed and delivered directly to 
the recipient in direct  competition with the incumbent operator without the necessity to  use 
the incumbent's network. Some end-to-end competition in relation to letter mail developed in 
the Member States that opened up their reserved area early, before the date mandated by the 
Directive in 2011/2013, such as Germany, Spain, the Netherlands, and Sweden and in several 
Member  States  where  express  and  courier  operators  were  able  to  offer  better  quality  letter 
products than the incumbent, such as in Croatia, Poland and Romania.315 

Furthermore,  access  competition,  whereby  alternative  operators  collect  postal  items  from 
senders  and  insert  it  in  the  universal  service  provider’s  network  for  delivery,  has  been 
established in various forms by national regulations in 18 Member States. Access competition 
is  the only  form  of competition  in the letter  mail  markets  of France and  Slovenia, while in 

313 The only profitable mail services were offered by postal administrations in the Netherlands and the United 
Kingdom.  See  EC  (1992),  Green  Paper  on  the  Development  of  the  Single  Market  for  Postal  Services, 
p. 115. 

314 European Regulators Group for Postal Services PL II (19) 37. 
315 WIK (2021), p.35. 

126 

 
 
                                                      
Germany,  the  Netherlands,  Spain  and,  to  some  extent,  in  Belgium  there  is  both  access 
competition and end-to-end competition.316 

Timing  seems  to  play  a  role  for  the  development  of  competition:  where  markets  were 
liberalised  in  a  period  of  increasing  mail  volumes,  competitors  were  attracted  more  easily. 
With the exception of Finland, competitors in early opened markets had managed to achieve 
competitive market shares above 5 percent (end-to-end and/or access competition)317. Today, 
in  a  period  characterised  by  digitalisation  and  declining  letter  volumes,  the  economics  of 
letter services have changed: realising economies of scale has become harder for competitors.  

Universal service provider profitability on postal services 

In  the  recent  past,  the  vast  majority  of  universal  service  providers  has  managed  to  be 
profitable  in  their  mail  operations.  With  few  exceptions,  universal  service  providers  report 
positive EBIT (Earnings before interest and taxes) margins up to 5 percent, some even higher 
than  10  percent  (e.g.  Belgium,  the  Netherlands,  Portugal,  Cyprus).  There  was  only  one 
universal service provider (Bulgaria Post) that reported negative EBIT margins between 2013 
and  2016,  and  a  few  others  were  unprofitable  in  one  or  two  years  during  that  period. 
Although some universal service providers have asked for, and received, additional funding 
for  the  provision  of  universal  services,  the  primary  source  of  funding  stems  from  postal 
revenues. Only six universal service providers (from Bulgaria, Denmark, Spain, Ireland, Italy 
and Poland) had a negative EBIT margin (profitability) in their mail and parcel business318 in 
2016. So overall, universal service providers in the Member States have generally managed 
to operate profitably throughout the EU, even though the negative trend in letter volumes has 
negatively affected their profitability over time. 

316 See European Regulators Group for Postal Services (2014), Report on end-to-end competition and access in 
European postal markets, p. 4 for an overview; and Copenhagen Economics (2018), Main Developments in 
the Postal Sector (2013-2016) for more recent market shares in those Member States. 

317  See  European  Regulators  Group  for  Postal  Services  13  (38)  Rev.1,  Report  on  end-to-end  competition  and 
access  in  European  postal  markets,  p. 4  for  an  overview,  and  Copenhagen  Economics  (2018)  for  more 
recent market shares in those countries. 

318  WIK  (2021).  Based  on  segment  reporting  of  the  universal  service  providers.  In  the  case  where  universal 
service providers do not publish segment reporting, the profitability relates to the overall EBIT margin. This 
is reasonable as universal service providers without segment reporting usually do not have much business 
outside postal markets. 

127 

 
 
 
 
 
 
 
                                                      
Figure 22 Average universal service provider profitability in mail operations, by country group 

In  fully  competitive  markets,  inefficient  providers  would  normally  be  forced  to  leave  the 
market. In practice, postal markets do not always follow this logic. For competitors, survival 
is  not  (only)  a  question  of  efficiency.  They  face  market  dominant  operators  which  usually 
have much higher bargaining power, and may have sufficient financial means to set strategic 
prices (for non-universal services). In the long run, very few competitors appear able to cope 
with this double strain. 

Universal service provider profitability, all activities 

Across  the  Member  States  operating  results  of  universal  service  providers  increased  on 
average by 353% in the first period after liberalisation (1997 until 2007). This improvement 
is widespread and can be observed in 24 out of 28 Member States. 

In  the  second  period  from  2007  until  2018,  although  the  operating  income  increased  on 
average by 2%, profits decreased or turned into losses in more than half of the countries (16 
out  of  28).  The  universal  service  providers  of  Germany  and  United  Kingdom,  with  strong 
positions in the parcel market, improved their operating profits. In fast digitalising countries 
(Denmark,  Finland,  the  Netherlands,  Sweden)  the  fast  decline  in  letter  mail  volumes  is 
weighing on the operating result, and caused a deterioration by 71% up to 159%. 

128 

-10%-05%00%05%10%15%20%USP profitability letter post segmentAllEU MS 1997EU MS 2004EU MS after 2007EEA countries, CH 
 
 
 
 
 
 
 
 
 
3 

8 

9 

2 

3 

3 

4 

61% 

-52% 

562 

615 

-8 

1718% 

-131% 

-50 

-79 

-107 

57% 

-159% 

8 

0 

44 

24 

-23 

1 

5 

-859% 

156% 

134% 

-95% 

Table  18  Operating  profit/loss  of  universal  service  providers,  all  activities,  in  mio  Special  Drawing 
Rights319 

7
9
9
1

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

% 
diff. 
1997-
2007 
or * 

% 
diff. 
2007-
2018 
or* 

159 

-7 

-1 

91 

-16 

-2 

-2 

-6 

5 

-30 

-22 

-63 

0 

-16 

5 

16 

17 

1 

7 

7 

-2 

86 

217 

-4 

14 

9 

40 

76 

86 

107 

151 

152 

133 

134 

151 

168 

172 

165 

69 

170 

170 

176 

-5% 

17% 

-31 

-34 

63 

91 

367 

388 

404 

322 

108% 

253% 

4 

4 

5 

5 

2 

-2 

10 

-2 

-22 

-5 

-5 

-13 

-27 

20 

6 

9 

7 

7 

5 

23 

14 

24 

6 

9 

8 

7 

4 

25 

25 

19 

1 

4 

6 

7 

-3 

5 

3 

12 

-4 

-1 

0 

9 

7 

4 

9 

4 

6 

-8 

-7 

-7 

-8 

-8 

-1 

541% 

-117% 

14 

19 

14 

18 

13 

55% 

195% 

115 

146 

177 

214 

174 

125 

180 

177 

93 

90 

58 

35 

21 

0 

-8 

41 

0 

0 

1 

2 

2 

2 

2 

-1 

-2 

1 

1 

6 

1 

3 

46 

56 

43 

63 

83 

111 

78 

95 

62 

43 

33 

-5 

34 

3 

9 

2 

5 

-276 

-470 

-82 

-147 

97 

-28 

120 

459 

623 

831  1197 

800 

696 

676 

564 

700 

689 

603 

686 

766 

843 

743 

533% 

-38% 

-14 

-1448 

1790 

1867 

2529 

2936 

3099 

3390 

1987 

-512 

212 

1582 

2052 

427 

806 

791 

12 

2724 

3116 

2592 

14726% 

30% 

-74 

-45 

1 

5 

6 

46 

18 

13 

6 

4 

6 

-2 

-38 

6 

HU 

-13 

-8 

-27 

-14 

-23 

11 

15 

22 

21 

20 

27 

19 

11 

-8 

-14 

-22 

-39 

-5 

-13 

-36 

2 

13 

13 

27 

28 

5 

5 

6 

7 

2 

2 

-5 

4 

1 

108% 

-92% 

-7 

60 

59 

57 

47 

12 

-2 

253% 

-110% 

-15 

-10 

5 

4 

438% 

-85% 

-993 

-651 

-323 

122 

205 

372 

587 

682 

1045 

1474 

1115 

1123 

1252 

1181 

816 

821 

319 

483 

489 

650 

638 

248% 

-57% 

3 

0 

4 

0 

5 

1 

4 

1 

2 

2 

-1 

1 

0 

0 

-1 

-12 

-20 

-24 

-15 

17 

10 

1 

0 

0 

1 

0 

0 

3 

3 

2 

-1 

-2 

7 

0 

1 

7 

2 

-16 

-4 

-8 

-17 

-3 

1 

0 

5 

0 

3 

3 

4 

1 

1 

2 

1 

2 

2 

2 

4 

-676% 

110% 

241% 

455% 

159% 

3 

3 

3 

2 

2 

3 

3 

3 

3 

26% 

70% 

440 

437 

460 

399 

548 

620 

697 

759 

620 

703 

549 

548 

400 

498 

307 

250 

362 

339 

268 

227 

211 

152 

25% 

-72% 

-12 

-14 

-8 

-2 

-44 

-31 

-26 

13 

-7 

11 

0 

9 

-8 

26 

1 

-24 

-26 

-16 

-14 

5 

-8 

3 

6 

0 

2 

3 

4 

3 

8 

1 

9 

7 

33 

28 

58 

32 

21 

-42 

-44 

3 

19 

9 

4 

6 

-1 

-13 

-9 

273% 

-343% 

-47 

45 

41 

19 

37 

45 

37 

39 

45 

44 

78 

114 

87 

71 

39 

32 

2573% 

-15% 

-2 

-1 

7 

6 

-26 

-37 

-12 

-7 

10 

14 

14 

10 

6 

-8 

-5 

-1 

8 

17 

24 

18 

19 

15 

17 

8 

5 

2 

-4 

6 

7 

4 

5 

7 

5 

4 

6 

9 

-3 

5 

8 

5 

6 

239 

-54% 

58% 

228% 

-127% 

176% 

-73% 

277% 

198% 

113 

66 

168 

157 

8 

85 

125 

58 

66 

51 

73 

58 

43 

48 

49% 

-71% 

-45 

-32 

-119 

-143 

15 

119 

123 

166 

168 

151 

80 

73 

5 

3 

-3 

6 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

141 

-112 

-486 

-375 

-1317 

-804 

85 

376 

428 

205 

304 

417 

222 

458 

348 

344 

802 

313 

653 

655 

499 

46% 

143% 

EU28  

253 

-1157 

-735 

-2150 

1434 

2156 

4287 

5860 

6379 

6648 

6247 

2958 

3140 

4551 

5000 

2900 

3456 

3567 

2505 

6157 

6680 

5125 

S. avg  
353% 

S. avg  
2% 

Source: UPU statistics,*closest years available to this period 

319  The  table  is  expressed  in  SDR,  the  rate  of  exchange  applied  to  convert  the  financial  data.  To  allow 
comparison  of  data  between  countries,  all  financial  information  in  the  UPU  statistics  are  presented  in 
Special Drawing Rights (SDR), the unit of account of the International Monetary Fund. 

129 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                      
Figure 23 Sources of operating revenues, average for years 2016, 2017 and 2018 

Source: Universal Postal Union statistics, 22 EU Member States 

Universal service provider ownership 

The majority of universal service providers remain publicly owned at least in part: PostNL, 
Malta Post and CTT Correios (Portugal) are the only wholly privately owned operators. The 
proportion  of  government  ownership  has  however  diminished  since  2008  with  several 
governments  selling  a  partial  stake  or  more  in  their  national  operator.  Furthermore,  in  all 
Member  States  except  Cyprus  the  universal  service  provider  is  organised  as  a  corporation 
under normal corporate law or related governance arrangements for state-owned enterprises. 
Cyprus Post is a ministerial (government) department. 

On the EU market, there are several international parcel operators owned by national postal 
operators: the French-based DPD network is owned by La Poste, GLS is an offspring of UK’s 
Royal Mail, and DHL’s European parcel network is part of the Deutsche Post group. 

Competition 

The majority of Member States has not seen the development of substantial competition until 
today. As shown in the table below, market shares of universal service providers in the vast 
majority of the Member States have remained at very high levels. According to the European 
Regulators  Group  for  Postal  Services,  the  universal  service  providers  generally  maintain  a 
high market share, in terms of volumes, for letters (in 2019 it was about 89 percent percent). 
The  universal  service  provider  market  shares  (in  terms  of  volumes)  regarding  parcels  are 
generally lower (around 28 percent percent).320 

Table 19 Shares of universal service providers on the domestic letter market 

1998 

2005 

2012 

2018 

Sources 

AT 

BE 

98% 

98% 

100% 

100% 

99% 

99% 

99%  WIK estimate 

99%  WIK estimate 

320 European Regulators Group for Postal Services PL II (19) 37. 

130 

 
 
 
 
                                                      
DE 

DK 

EL 

ES 

FI 

FR 

IE 

99% 

99% 

99% 

92% 

99% 

99% 

89% 

99% 

99% 

92% 

84% 

BNetzA, Marktbeobachtung, BNetzA Jahreberichte 

99%  WIK estimate 

75% 

EETT, Market Review / 2018 ERGP 

CNSP, Market report  

100% 

100% 

100% 

100% 

FICORA, Postal Statistics. 2018: ERGP 

100% 

99% 

99% 

99%  WIK estimate  

100% 

100% 

100% 

100% 

ERGP 

IT 

99% 

88% 

LU 

100% 

100% 

100% 

92% 

NL 

100% 

91% 

81% 

76% 

WIK  estimate  based  on  AGCOM,  Relazione  annuale 
and Poste Italiane Investor Presentations, 1998 based 
on Ecorys (2005) 

calculated based on DG GROW Postal statistics. 2018: 
ERGP 

calculated based on PostNL AR and Market Studies by 
the ACM 

PT 

SE 

98% 

98% 

calculated  based  on  DG  GROW  -  Postal  statistics. 
2018: ERGP 

95% 

92% 

87% 

calculated based on PTS, Svensk postmarknad  

UK 

100% 

100% 

100% 

100% 

calculated  based  on  Ofcom,  Market  Reports,  Royal 
Mail,  Regulatory  Accounts  &  DG  GROW  -  Postal 
Statistics. 2018: ERGP 

CY 

CZ 

EE 

100% 

100% 

100% 

100% 

ERGP 

98% 

98% 

98% 

94% 

calculated based on DG GROW Postal statistics 

69% 

70% 

calculated based on DG GROW Postal statistics. 2018: 
ERGP 

HU 

100% 

100% 

100% 

99% 

calculated based on DG GROW Postal statistics. 2018: 
ERGP 

LT 

LV 

98%  Universal Service Provider reports 

91% 

95% 

calculated based on DG GROW Postal statistics. 2018: 
ERGP 

MT 

99% 

99% 

99% 

97% 

calculated  based  on  DG  GROW  -  Postal  statistics. 
2018: ERGP 

PL 

SI 

SK 

99% 

99% 

87% 

98% 

calculated based on UKE, Reports on the state of the 
postal market. 2018: ERGP 

93% 

calculated based on DG GROW Postal Statistics  

96% 

ERGP 

BG 

100% 

100% 

100% 

82% 

2018: ERGP; 
2012: calculated based on DG GROW Postal Statistics; 
WIK estimate 

HR 

67% 

89% 

calculated based on DG GROW Postal statistics. 2018: 
ERGP 

131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RO 

98% 

98% 

79% 

61% 

calculated based on NRA, Postal Statistics, 2018: ERGP 

Source: WIK (2021) 

Although there are a large numbers of competing postal  operators active in  European letter 
markets, they are mostly very small and operate on a local level. There are a few countries 
where  their  numbers  amounts  to  several  hundred  although  market  shares  of  the  universal 
service providers are high, such  as  Belgium (700), Germany  (600),  Greece (>500), or  Italy 
(>3000).321  

As shown in the figure below, some countries, even if not having a very significant number 
of active providers, have a significant number of providers with more than 1 percent market 
share (e.g. Cyprus, with 20 providers and 10 with more than 1 percent market share). 

Figure 24 Number of postal service providers with more than 1 percent of the postal market in 2019 

Source: ERGP PL II (19) 37 Report on Core indicators of the postal sector 

There  have  been  some  changes  in  the  number  of  operators  with  more  than  1  percent  of 
market share in the period 2015-2019, but in the more recent period (2018-2019), in most of 
the countries who provide data there has been no major change, neither in terms of volumes 
nor in revenues. 

The European Regulators Group for Postal Services’ analysis on the level of concentration in 
the  market  shows  very  high  concentration  rates.  The  Herfindahl-Hirschman-Index  is  above 
7 000 in terms of volume on average for all countries analysed by ERGP, and above 4 000 in 
terms  of  revenues  (based  on  2018  data).322  The  index  can  take  values  up  to  10 000,  values 
above  2 000  indicate  a  strong  market  concentration.  Country-specific  values  are  also  very 
high, with lowest values in Romania (3 300), Greece (4 500) and Estonia (4 700) in terms of 
volume.  Highest  values  for  the  index  can  be  found  in  France  (9 700),  Malta  (9 000)  and 
Belgium (8 700). 

321 European Regulators Group for Postal Services PL II (19) 37, p. 33. 
322   Ibid, p. 34. 

132 

 
 
 
 
                                                      
End-to-end  competition  has  developed  mainly  in  those  Member  States  that  opened  their 
markets  earlier  than  others:  Germany,  Spain,  Netherlands,  and  Sweden.  In  several  Eastern 
European Member States, there is competition from courier services that deliver letters, e.g. 
in  Bulgaria, Croatia, Slovakia, Poland, Romania. Access  competition,  i.e. competition  from 
operators  that  collect  postal  items  from  senders  and  hand  it  over  to  the  universal  service 
provider for delivery may exist as the only form of competition or in addition to end-to-end-
competition. Examples for countries with access competition only are France, Slovenia, and 
the UK.323 In the Netherlands, Spain and Germany, and also to some extent in Belgium, there 
is access competition in addition to end-to-end. 

In  parcel  markets,  competition  is  much  higher  than  in  letter  markets,  as  there  was  never  a 
reserved area for parcels. However, there are differences in the development of competition, 
depending  on  customer  segment.  Competition  for  business  customer  services  had  already 
developed before the Postal Services Directive  was introduced.  In the wake of e-commerce 
growth,  operators  from  the  B2B-segment  entered  into  B2C  service  segments.  There  are  of 
course significant  national  differences in  the competitive landscape.  In  countries with  well-
developed  parcel  markets  like  the  Netherlands,  Sweden,  Germany,  and  Belgium,  the 
universal service providers still have quite high levels of market shares but are far from being 
market dominant. In many Eastern and Southern European Member States, universal service 
providers  are  not  very  successful  in  parcel  delivery.  Parcel  markets  with  intensive 
competition can be found in Belgium, the Netherlands, Germany, the United Kingdom, and 
Austria.324 

Competitors 

Even  in  times  of  growing  letter  markets,  competing  postal  operators  have  struggled  to 
survive.325 In declining markets, becoming profitable is even harder when competitors have 
to fight against the market-dominant operators at the same time.  

There are many examples of competitors that have not been able to remain profitable in the 
long term – or would have never been able to survive in the market without financial backing 
by their owners. For instance, CityMail in Sweden, which started letter delivery operations in 
1993  but  was  only  profitable  for  the  first  time  in  2004.  Due  to  financial  problems,  the 
company was bought by Post Norway and renamed Bring CityMail. CityMail was then sold 
to a German investor (Cimase Capital Consult GmbH).326 Whistl in the UK, PIN in Germany, 
and  Sandd  in  the  Netherlands  are  other  examples.  Financial  problems  faced  by  these 
competitors  have  been  the  combined  effect  of  volume  declines  and  difficulties  in  winning 
market shares against a dominant operator.  

323   WIK (2013) and Copenhagen Economics (2018). In UK, the only end-to-end competitor Whistl stopped its 

delivery activities in 2015. Today, Whistl is active in access services. 

324 See WIK (2019). 
325 See e.g. the history of CityMail in Sweden. CityMail started letter delivery operations in Sweden in 1993 but 
was only profitable for the first time in 2004. See PTS (2008). Due to financial problems, the company was 
bought by Post Norway and renamed to Bring CityMail. CityMail was recently sold to a German investor 
(Cimase Capital Consult GmbH). See CityMail (2019), Hållbarhetsredovisning. 

326 See CityMail (2019), Hållbarhetsredovisning. 

133 

 
 
                                                      
In letter services, several national postal operators face competition on their domestic markets 
while  acting  as  competitors  in  letter  delivery  abroad.  Examples  are  PostNL  (PostCon  in 
Germany, Nexive in Italy), Deutsche Post (Selektmail in the Netherlands, Unipost in Spain) 
or  Post  Norway  (Bring  CityMail  in  Sweden).  For  national  universal  service  providers, 
expanding their activities abroad might have been an effort to compensate for revenues lost to 
competition  in  their  home  markets.  As  the  incumbent  operators  are  normally  have  both 
financial resources and knowledge on letter operations, it would be easier for them to become 
active  in  other  countries  than  for  new  market  entrants  without  roots  in  the  postal  sector. 
However, most EU incumbents have divested their foreign mail operations in recent years. 

While the universal service providers try to diversify their business activities, other operators 
exit  the  market.  In  Poland,  for  example,  there  are  several  major  competitors  active  in  the 
letter  segment.  In 2015,  Polish  Post’s  biggest  competitor  InPost  acquired  Polska  Grupa 
Pocztowa (PGP), the second-largest competitor, and reached an agreement with Polish Post 
that Polish Post delivers InPost’s letters in rural areas. In 2016, however, InPost announced 
plans  to  resign  their  letter  business  and  limited  their  activity  to  the  delivery  of  registered 
e-commerce letters  (small packets).327  In February  2019, PostNL announced the acquisition 
of the largest competitor Sandd which had a revenue share of 10-15 per cent in the business 
segment in 2016. Although the acquisition will yield a re-monopolization of the letter market 
in the Netherlands, it had strong political support as the acquisition was seen as an option to 
safeguard  the  universal  postal  service.  At  first,  the  Dutch  competition  and  regulation 
authority, ACM, blocked the deal on the grounds that it would re-establish a mail monopoly 
in the Netherlands but the Ministry of Economic Affairs and Climate Policy overturned the 
regulatory  veto  on  the  acquisition.328  In  some  of  the  countries,  there  is  limited  end-to-end 
competition in the letter segment and competitors even gain market share. However, even in 
these  countries  the  incumbent’s  market  shares  still  remain  well  above  80 per cent  and 
competition remains limited as the incumbents maintain dominant positions.  

The market for parcel  and express services is characterised by the presence of international 
integrators  like  UPS,  FedEx,  and  DHL  which  operate  globally.  In  the  case  of  express 
integrators,  these  networks  existed  already  before  the  Postal  Services  Directive  was 
introduced.  The  intensifying  international  activities  of  parcel  operators  are  driven  by  e-
commerce and cross-border trade, not by the Postal Services Directive. 

Revenues  

In 2018 the letter post sector accounted for a total of EUR 33 billion in revenues compared to 
EUR 36 billion in 2016. Germany, France and United Kingdom together generate two thirds 
of this revenue.  

327   Parkiet (2015), InPost przejmuje PGP, published 2.1.2015,  

https://www.parkiet.com/Spolki/301029983-InPost-przejmuje-PGP.html;  Post&Parcel  (2015),  Polish  Post 
29.4.2015, 
to 
grants 
https://postandparcel.info/64752/news/polish-post-grants-rivals-inpost-access-to-rural-mailboxes/; 
InPost 
(2016), Integer.pl Group results inQ2 2016, p. 12. 

mailboxes, 

published 

InPost 

access 

rivals 

rural 

328  See  CEP-Research,  1 October  2019,  PostNL  wins  government  approval  for  EUR130  million  Sandd 
acquisition;  PostNL  (2019),  PostNL  and  Sandd  to  form  one  strong  national  postal  network  for  the 
Netherlands,  published  25 February  2019,  https://www.postnl.nl/en/about-postnl/press-news/press-
releases/2019/postnl-and-sandd-to-form-one-strong-national-postal-network-for-the-netherlands.html.  

134 

 
 
                                                      
 
On average revenues declined only by 3.3 percent annually in the period 2016-2018, whereas 
the  decline  in  volumes  was  more  substantial.  An  effective  strategy  for  postal  operators  has 
been to compensate revenue loss from volume decline by increasing the price for letters.  

The  parcel  delivery  segment  has  seen  increasing  revenues  because  volumes  have  been 
increasing.  Postal  providers  in  the  EU  generated  EUR  50  billion  in  revenues  from  parcel 
delivery services in 2018.  This represents an average 60 percent of total postal revenues in 
the EU28329. In fourteen Member States parcel delivery services contributed to more than 50 
percent of their postal revenues. 

 Figure 25 Share of turnover from letters and parcels, 2018 

Source: EC postal statistics 

The share of universal service parcels in total turnover of parcels is on average 17 percent in 
the European Union, but the percentages vary significantly between the Member States.  

1.6 Employment  

In the past decade, employment in the postal sector has been influenced by two main market 
developments: letter volumes decline and parcel volumes growth.330 The postal sector is very 
labour-intensive  and  with  rising  labour  costs  across  Europe  significant  restructuring 
(including  job  losses  but  also  job  creation)  has  taken  place  in  several  Member  States. 
According to the latest available data by Eurostat, the total employment related to activities 
falling  under  the  universal  service  obligation  has  been  decreasing  since  2011,  while  the 
number  of  persons  employed  for  other  postal  and  courier  activities  has  been  increasing,  in 
particular  since  2014.331  The  Eurostat  data  suggests  that  the  total  number  of  persons 
employed in other postal and courier activities is almost equal to the total number of persons 
employed for postal universal service activities (see figure 26).  The job  creation for parcel 
activities  at  other  operators  seems  to  compensate  for  the  job  losses  at  universal  service 
providers. 

329   Data for Romania, Latvia are not available 
330 Copenhagen Economics (2018), p. 29. 
331 Eurostat (2021), annual detailed enterprise statistics for services 

135 

 
 
 
 
 
 
                                                      
Figure 26 Persons employed in postal and courier activities  

Source: Eurostat (2021), annual detailed enterprise statistics for services 

Developments  in  technology, user needs, postal  business  models and increased  competition 
in  the  parcel  segment  have  also  had  an  impact  on  working  conditions.  The  main  trends  in 
postal sector employment are:332 

- 

Increasing pressure on reducing expensive employment contracts at universal service 
providers, e.g. civil servants, which have been decreasing;  

-  Growing  use  of  new  employment  patterns,  especially  at  non-universal  service 
providers, such as on-call work, temporary agency work, outsourcing, sub-contracted 
workers, and self-employment; 

-  More performance-related pay, e.g. pay based on the number of delivered mail items 

and parcels per day;  

-  Some  Member  States  are  also  experiencing  recruitment  problems  because  of 
demographic  changes  (aging  societies),  lack  of  qualified  drivers  and  lack  of 
attractiveness of the sector.333 

In  countries  where  postal  services  employ  a  high  share  of  civil  servants,  universal  service 
providers  and  governments  have  been  searching  for  solutions  to  meet  two  sometimes 
conflicting  objectives:  ensuring  legacy  social  rights  and  obligations  to  civil  servants  and, 
providing universal service providers a level playing field in the dynamic postal and delivery 
market.  Given  these  inherently  conflicting  objectives,  legal  and  dispute  actions  on  state 
compensation have occasionally arisen.334 

332 Copenhagen Economics (2018), p. 144-145. 
333 WIK (2019), p. 309. 
334 Copenhagen Economics (2018), p.147-148. For instance, Germany’s state aid to Deutsche Post for legacy 
civil servants’ pensions was first deemed illegal, but finally approved by the European Union General Court in 
2016, 

136 

 
 
 
 
                                                      
Subcontracting is a common practice especially in parcel delivery to respond to the need for 
flexibility.335  A  key  challenge  for  carriers  consists  of  dealing  with  peak  demand  in  e-
commerce deliveries, which require more flexible employment arrangements, often based on 
minimum  national  wages  and  working  standards.  This  has  resulted  in  a  two-tiered  labour 
market consisting, in one part, of company or sectoral collective labour agreements and the 
other  part  of  non-standard  contractual  arrangements.336  In  some  cases  concerns  have  been 
raised related to precarious forms of employment in subcontracting chains.337 Problems may 
occur  if  subcontracting  cascades  are  formed  leading  to  unclear  responsibilities  between  the 
parties involved.338 Labour regulations on subcontracting differ substantially among Member 
States,  while  sometimes  also  lacking  in  transparency.339  The  Directive  is  however  without 
prejudice  to  the  competence  of  Member  States  to  regulate  employment  conditions  in  the 
postal services sector, in accordance with national and EU law.340  

1.7 Environment  

Due to growing e-commerce and parcel volumes, in parallel with increasing expectations of 
online  shoppers,  managing  negative  environmental  impacts  has  become  more  important  in 
the past decade. In the 2008-2020 period, a majority of universal service providers in the EU 
undertook  measures  to  limit  the  negative  environmental  impacts  of  postal  service 
provision.341  Most  universal  service  providers  set  up  environmental  quantitative  targets  in 
road  transport,  which  remains  the  most  important  mode  of  transport  throughout  Europe, 
especially  in  domestic  postal  services.342  Some  of  the  universal  service  providers  also  set 
sustainability requirements on their sub-contracted and outsourced activities, for example in 
procurement  procedures.343 A majority of universal service providers were  members of one 
or  several  industry  networks  established  to  share  knowledge  and  improve  environmental 
performance  among  postal  operators,  such  as  the  Sustainability  Measurement  and 
Management  System  (SMMS)  by  International  Post  Corporation  (IPC)  and  the  Greenhouse 
Gas  Reduction  Programme,  initiated  by  PostEurop.344  Key  drivers  behind  universal  service 
providers’  green  initiatives  were  cost  benefits,  corporate  image,  competitive  differentiation 
and compliance with environmental regulation set out by national and local authorities. Non-
universal  service  providers345  have  also  acted  to  reduce  the  environmental  effects  of  parcel 
delivery, especially in last-mile deliveries, by improving fuel and network efficiency, and by 
introducing  alternative  vehicles  and  fuels.  Major  carriers  set  themselves  quantitative  goals, 
focusing on a decrease of CO2 emissions and an increase of environmental friendly delivery 
vehicles.346  

335 WIK (2019), p. 33. 
336 WIK (2019), p. 33. 
337 Eurofound, 2018, and WIK (2019), p. 323-324. 
338 WIK (2019), p.324 and p.336. 
339 WIK (2019), p. 33. 
340 Postal Services Directive 2008/6/EC, Recital 53. 
341 Copenhagen Economics (2010); Copenhagen Economics (2018), and IPC 2019 Sustainability Report. 
342 Copenhagen Economics (2010); Copenhagen Economics (2018). 
343 Copenhagen Economics (2018). 
344 Copenhagen Economics (2018); IPC; PostEurop. 
345 These include courier, express and parcel services providers. 
346 WIK (2019), p.349. 

137 

 
 
                                                      
The  2019  Postal  Sector  Sustainability  Report347  by  the  International  Post  Corporation 
concludes  that  carbon  efficiency  of  letter  mail  delivery  has  decreased  over  the  last  seven 
years, albeit unevenly, while the CO2 efficiency for parcels has increased. Given the fact that 
most of the reporting operators are EU universal service providers, this may be related to the 
compulsory  minimum  delivery  frequency  of  5  days  a  week,  which,  with  fewer  letter  mail 
items to deliver, may result in inefficiencies, both in terms of cost and CO2 emissions. This is 
a preliminary assumption that may need further research.  

2.  APPLICATION OF THE DIRECTIVE 

2.1 Transposition of the Directive 

Member  States  have  transposed  the  Directive  using  different  approaches  and  assuming 
different  positions  on  the  two  major  axes  illustrated  in  the  chart  below,  that  of 
competitiveness and that of universal services.  

Figure 27 National approaches to implementing the Postal Services Directive 

Source: WIK (2021)  

For  example,  some  Member  States  ensure  universal  service  provision  using  a  “controlled 
market  approach”  which  is  characterised  by  both  close  monitoring  of  the  universal  service 
and  strong  control  of  competitive  entry.  Typically  these  Member  States  did  not  open  their 
letter markets before the deadlines in the Directive. Individual licensing are more common or 
required for a wider range of universal services than in other approaches. Another approach is 
the  “controlled  entry  approach”.  It  is  characterised  by  intensive  control  of  new  entrants  in 
letter markets while at the same time replying on market forces for ensuring universal service 
provision.  Relying on market  forces means there is  no designated operator for ensuring the 
universal service. Instead, universal service is provided by all postal operators that are active 

347  https://www.ipc.be/news-portal/sustainability/2020/11/25/09/45/ipc-publishes-first-online-sustainability-

report 

138 

 
 
 
                                                      
within  the  scope  of  universal  services  which  is  quite  broad.  Quality  of  service  targets  are 
defined  for  selected  universal  services  only.  A  third  approach  is  the  so-called  “controlled 
universal service” and is characterised by rather strict controls of universal service but a light-
handed  approach  at  controlling  competitors.  Finally  there  is  a  “liberal  approach”  where 
instead  of  regulating  universal  service  provision  the  obligations  of  the  universal  service 
provider arise from its significant market power.  This approach leaves some flexibility to the 
universal  service  provider  to  set  prices  but  at  the  same  time  sets  a  network  access 
obligation.348 

2.2 The Universal Service 

The  universal  service  is  one  of  the  key  elements  of  the  regulatory  framework.  All  users  – 
senders and addressees alike – must be able to enjoy the right of reliable and affordable postal 
services at all points of the territory of EU Member States. Article 3 is based on a minimum 
harmonisation  principle.  Consequently,  Member  States  must  ensure  a  universal  service  that 
provides for the collection, sorting, transport, and distribution at least five working days per 
week  of  (i)  postal  items  weighing  up  to  2  kilograms  and  (ii)  postal  packages  up  to  10 
kilograms,349 as well as services for registered items and insured items in both categories. The 
universal service covers both national and cross-border services (Article 3, paragraph 7).  

A  number  of  postal  services  are  not  part  of  the  universal  service,  even  where  they  are 
provided by the universal service provider. These services are notably express services, but 
they may also be the delivery of newspapers/periodicals. There are substantial differences in 
the  scope  of  universal  services  among  Member  States,  particularly  as  regards  bulk  letters, 
bulk parcels and other items.  

2.2.1  Scope 

The scope of the universal service remains varied in Member States. Single piece letters and 
parcel services are ensured in all Member States, a number of Member States have chosen to 
include bulk mail in the universal service. 

Table 20 Scope of universal services 2018 

Scope of universal services 

Number  Member States 

Single piece letters only 

Bulk letters 

Newspapers and periodicals 

13 

15 

18 

DE, DK, EE, FI, HR, LT, LU, NL, NO, PL, RO, SI, UK 

AT, BE, CY, EL, ES, FR, HU, IE, IS, IT, LV, MT, PT, SE, SK 

AT, BE, BG, CH, CY, DE, DK, EL, FR, IS, IT, LU, LV, MT, NO, PT, 
RO, SI 

No information for LI. In CH, CZ, BG, bulk mail services are not defined.  
Source:  based on ERGP (2018), Report on core indicators for monitoring the European postal market, 18 (45) and ERGP 

(2017), Report on core indicators for monitoring the European postal market, 17 (36)  

There  is  a  tendency  to  reduce  services  provided  as  universal  services  and  since  2014  the 
following  Member  States  have  excluded  bulk  mail  from  the  scope  of  the  universal  service: 

348  WIK (2021), p.175-6 
349  National  Regulatory  Authorities  may  increase  the  weight  limit  of  universal  service  coverage  for  postal 

parcels to any weight not exceeding 20kg.  

139 

 
 
                                                      
EL, HR, LV, LU, RO and SI. Furthermore, a number of frequently used postal services are 
not  part  of  the  universal  service,  even  where  they  are  provided  by  the  universal  service 
provider.  Such  services  include  for  example  value-added  services  that  are  in  particular 
provided  for  business  senders  (e.g.  small  e-commerce  goods  for  e-retailers)  like  track  and 
trace or delivery within a specified time window (e.g. bulk services with different levels of 
pre-sorting). Non-universal service features have been added to some universal services: This 
concerns for instance universal service parcels which in 19 Member States350 include tracking 
while this is not required by the Directive (and national legislation). 

2.2.2  Designation 

Member States must ensure the provision of the universal service by using one or more of the 
following three mechanisms: market forces; the designation of one or more undertakings to 
provide different elements of the universal service or to cover different parts of the territory; 
or  the  public  procurement  of  universal  services  (Article  4,  paragraph  2).  They  are  to 
determine the "most efficient and appropriate" mechanism while respecting in particular "the 
principles  of  objectivity,  transparency,  non-discrimination  and  proportionality",  thereby 
guaranteeing the continuity of the universal service.  

Despite more options given by Directive 2008/6/EC all Member States still designate a single 
universal  service  provider,  with  the  exception  of  Germany351,  which  in  principle  relies  on 
market forces for the provision of the universal service. The universal service provider is in 
all cases the historical public postal operator or its corporate successor. 

2.2.3  Financing the Universal Service Obligation (and Sustainability) 

The  mechanisms  for  ensuring  universal  service  provision  are  connected  to  the  financing 
options  allowed  by  the  Postal  Services  Directive.  Since  the  2008  amendment,  reserving 
services  for  a  designated  operator  as  a  financing  mechanism  is  no  longer  permitted.  After 
2008, Member States need to analyse if the obligation to provide universal service entails a 
net  cost  and is  an unfair financial burden on the  universal  service provider as  laid down in 
Article 7(3).  In  that  case,  Member  States  may  rely  on  State  funding  and/or  a  sharing 
mechanism (compensation fund). 

While  procuring  universal  services  is  a  mechanism  to  ensure  that  universal  service  is 
provided,  it  is  also  a  financing  mechanism.  From  an  economic  perspective,  Member  States 
may  apply  procurement  procedures  to  increase  competition  for  a  market  if  the  level  of 
competition  within  a  market  is  low  or  competition  does  not  exist.  The  other  options  for 
financing  may  apply  if  the  universal  service  entails  a  net  cost.  In  that  case,  Member  States 
may  choose  to  compensate  the  universal  service  provider  directly  from  public  funds. 
Alternatively, the net cost may also be shared among market players and/or users, according 
to Article 4 (3b). 

The majority (18) of Member States have legally authorised compensation funds for sharing 
the net cost of the universal service obligation among several providers, but only four have in 

350 WIK (2019), p. 54.  
351 Even in Germany Deutsche Post has an obligation if she wants to not provide anymore universal services in a 
part of the territory or for parts of the service to inform the national regulatory authority in advance. After a 
procurement procedure direct designation is possible. 

140 

 
 
                                                      
fact established and activated a fund: Denmark, Estonia, Poland, and Slovakia.352 Typically, 
providers  of  postal  services  within  the  scope  of  universal  service,  including  the  universal 
service provider, have to contribute to a compensation fund, e.g. as a fee per item or a share 
of  their  turnover.  In  Estonia,  the  fees  per  item  amounted  to  EUR 0.08  per  item  of 
correspondence  (ordinary  letter)  and  EUR 0.40  for  registered  and  insured  letters  in  2018. 
There  was  an  option  to  introduce  a  charge  for  parcels  but  it  was  not  applied  in  2018.353  In 
Estonia  as  well  as  in  other  Member  States,  the  universal  service  provider  as  the  market-
dominant  provider  of  postal  services  has  to  bear  the  majority  of  contributions  to  the  fund 
from which it is compensated. 

Additionally,  there  have  been  disputes  on  the  criteria  to  determine  which  postal  operators 
have to contribute to the fund. In Italy, a conflict on this question between express operators 
and  an  Italian  association  of  transport  and  logistic  operators  (Confetra)  and  the  postal 
regulatory  authority,  AGCOM  (supported  by  Poste  Italiane  and  the  Ministry  of  Economic 
Affairs),  went  through  national  courts  before  the  case  was  brought  before  the    Court  of 
Justice of the European  Union.354 Although the final  ruling of the  Court confirmed express 
operators  would  need  to  contribute  to  the  compensation  fund  (in  as  far  as  their  services 
display  sufficient  inter-changeability  with  universal  services),  AGCOM  did  not  find  it 
appropriate to activate the compensation fund. This decision took into account the changes in 
frequency of delivery in rural areas, leading to substantial cost reductions for Poste Italiane, 
and the high administrative cost for establishing the fund.355  

WIK  (2021)  signalled  an  economic  argument  against  compensation  funds  as  a  means  to 
finance  the  universal  service  obligation.  When  there  is  a  net  cost  of  the  universal  service 
obligation,  this  is  often  driven  by  volume  declines,  but  the  efficiency  and  commercial 
flexibility of the  universal  service provider  also  play a role.  Its  ability to develop  a market, 
offer value-added postal services which may not be substituted as easily as bills and invoices, 
and  be  successful  in  e-commerce  delivery  are  also  important  factors.  A  universal  service 
provider with inefficient postal operations and low level of commercial success has a much 
higher  risk  of  facing  problems  to  sustainably  finance  the  USO.  Sharing  the  burden  among 
other  operators  with  greater  commercial  success,  such  as  express  operators,  may  be 
understandable  from  the  view  of  the  national  treasury,  but  sets  low  incentives  for  the 
universal  service  provider  for  improving  its  efficiency.  More  importantly,  it  negatively 
affects  the  competitive  situation  of  competitors  that  have  to  contribute  to  the  fund.  The 
impact  of  compensation  funds  on  competition,  however,  depends  on  the  design  of  the 
contribution  mechanism.  Where  the  universal  service  provider  as  the  market-dominant 
operator  has  to  bear  the  major  share  of  the  contribution,  a  compensation  fund  would  be  a 
complicated mechanism to transfer financial charges from one pocket of a universal service 
provider to another. Where competitors have to bear major shares of the contributions, it is a 
mechanism to choke off or at least negatively affect competition. 

352 WIK (2019), p. 60. 
353 Estonian  Competition  Authority (2018), Overview of the  Estonian postal  market and  future developments, 

presentation at WIK Königswinter Postal Seminar, 6 February 2018. 

354  Court  of  Justice  of  the  European  Union  (2018),  Decision  of  31 May 2018,  joint  cases  C-259/16  and 

C-260/16. 

355 AGCOM (2016), Delibera N. 166/16/CONS, Allegato B; AGCOM (2017), Delibera 298/17/Cons 

141 

 
 
                                                      
Financing from public funds or by establishing a compensation fund is only permissible if a 
net  cost  of the universal service obligation has been determined  and additionally  represents 
an unfair financial burden on the universal service provider. The methodology for calculation 
of the net cost has been established in Annex I of the Directive since 2008. Annex I provides 
guidance on the calculation methodology but does not go into details. Thus, Member States 
have  to  adapt  the  guiding  principles  of  Annex  I  to  their  national  situation  and  develop  a 
calculation methodology that is consistent with Annex I. 

2.2.4  Access to postal services 

Article  3(2)  of  the  Postal  Services  Directive  established  the  universal  access  to  the  postal 
network: ‘Member States shall take steps to ensure that the density of the post offices and of 
the access points356 takes account of the needs of users’. This gave flexibility to the Member 
States to define more detailed requirements regarding the density and structure of the postal 
network.  The  majority  of  Member  States  use  this  flexibility  today  and  require  that  their 
universal service providers maintain a certain number of postal access points per number of 
inhabitants or other criteria357.   

Postal Network 

As  recently  as  2019,  the  situation  of  the  postal  offices  operated  by  the  universal  service 
provider  still  varied  significantly  across  member  States.  Cyprus  stood  out  with  12.65  post 
offices for every ten thousand inhabitants. Belgium and the Netherlands had the least dense 
postal network with 1.19 and 1.89 post offices for every ten thousand inhabitants in 2019.358 
Between  2013  and  2016  the  density  of  the  postal  office  network  declined  in  23  of  the  32 
countries  surveyed  by  Copenhagen  Economics.  Of  these  23  countries,  France  was  the  only 
country that experienced a decline in density because the population was growing faster than 
new post offices were being open. In the remaining 22 countries, the reduced density of the 
post  office  was  caused  by  closure  of  post  offices359.  On  the  other  hand,  between  2014  and 
2018, some countries reported an increase in their postal networks: Denmark by 14.1 percent, 
Sweden by 13.5 percent and Malta by 12.7 percent360 and the latest ERGP report indicates an 
overall  increase  of  16.2  percent  between  2015  and  2019  in  the  total  number  of  postal 
establishments  owned  by  universal  service  providers  and  other  operators.  In  the  countries 
surveyed by the European Regulators Group for Postal Services361 the postal outlets owned 
by the universal service providers decreased by -3.4 percent from 2015 to 2019 while those of 
other postal operators increased by 44.3 percent362. 

356 Access points – physical facilities, including letter boxes provided for the public either on the public highway 
or  at  the  premises  of  the  postal  service  provider(s),  where  postal  items  may  be  deposited  with  the  postal 
network by senders; 

357 European Regulators Group for Postal Services PL II (19) 35, pp.32-33 
358 European Regulators Group for Postal Services PL II (20) 23, p.66 
359 Copenhagen Economics (2018), p.196 
360 European Regulators Group for Postal Services PL II (19) 37, p.63 
361  Austria,  Belgium,  Bulgaria,  Croatia,  Cyprus,  the  Czech  Republic,  Denmark,  Estonia,  Finland,  France, 
Germany,  Greece,  Hungary,  Ireland,  Iceland,  Italy,  Luxembourg,  Lithuania,  Latvia,  North  Macedonia, 
Malta, Norway, the Netherlands, Poland, Portugal, Romania, Serbia, Sweden, Slovenia, Slovakia, Spain and 
Switzerland 

362 European Regulators Group for Postal Services PL II (20) 23, p.60 

142 

 
 
                                                      
An  interesting  development  is  that  most  universal  service  providers  are  outsourcing  the 
operation of points of contact in order to lower their operating costs. In 2016, only universal 
service  providers  in  Spain,  Cyprus,  Croatia,  Italy,  Romania,  Bulgaria,  and  Lithuania  were 
operating the totality of the postal outlets in their country. In Norway, Finland and Sweden, 
the universal service provider operated only two, three and four percent of all postal outlets 
respectively. The remaining 98 percent of postal outlets were operated by others on behalf of 
the universal service provider. Other providers operated at least half of the postal outlets for 
the  universal  service  provider  in  Austria,  Belgium,  Estonia,  Finland,  Germany,  Norway, 
Portugal and Sweden363.  

Letter boxes 

Between 2015  and 2019 the number of letter boxes decreased by an overall  -4.4 percent in 
the  countries  surveyed  by  the  European  Regulators  Group  for  Postal  Services.  In  2019,  the 
universal  service  providers  owned  97.2  percent  of  the  total  of  over  half  a  million  letter 
boxes364. The number of letter boxes varied greatly from country to country, with France and 
the  United  Kingdom  accounting  for  65  percent  of  the  total  number  of  letterboxes  in  the 
examined countries in 2018. There were slight increases in Portugal (1.9 percent), Latvia (0.4 
percent)  and  Ireland  (0.3  percent),  while  the  most  important  decreases  were  reported  by 
Poland  (-45.6  percent),  Estonia  (-33.6  percent),  Slovenia  (-28  percent)  and  Slovakia  (-16.1 
percent)365. 

Parcel lockers 

Following  the  development  of  the  e-commerce  and  the  increasing  importance  of  parcel 
delivery,  the  postal  operators  added  parcel  lockers366  to  the  composition  of  their  networks. 
The  European  Regulators  Group  for  Postal  Services  has  started  to  collect  data  and  report 
about parcel lockers in 2016. Not all states were able to provide data about parcel lockers, but 
the  countries  that  reported  have  had  a  significant  increase  in  parcel  lockers  for  both  the 
universal service providers and other operators. Significant advances in 2019 were noted for 
the  non-universal  service  providers  of  Germany  (6.516  percent),  Spain  (389  percent)  and 
Romania  (296  percent).  The  greatest  number  of  parcel  lockers  newly  installed  by  the 
universal  service  provider  was  reported  by  the  Netherlands  with  an  increase  of  83  percent 
from 63 to 115 in 2019. The numbers differ significantly between reporting countries367. 

2.2.5  Frequency of collections and deliveries 

Article  3(3)  of  the  Postal  Services  Directive  set  the  minimum  frequency  of  collections  and 
deliveries  of  postal  items  within  the  scope  of  the  universal  service  to  five  working  days  a 
week, save in circumstances or geographical conditions deemed exceptional. Delivery has to 
be to the home or premises of every citizen or business. Exemptions are only possible when 
approved by the national regulatory authority. 

363 Copenhagen Economics (2018), pp.197-198 
364 European Regulators Group for Postal Services PL II (20) 23, p.67 
365 European Regulators Group for Postal Services PL II (19) 37, pp.70-72 
366 automated installations where people can receive or send parcels or other postal items 
367 European Regulators Group for Postal Services PL II (20) 23, pp.71-72 

143 

 
 
                                                      
According to WIK (2021)368, before 1997, delivery was done once a day every day, for both 
letters and parcels and only six states had exceptions from the rule to deliver at the door. The 
Postal Services Directive merely encoded in legislation what was common practice in EU15 
before its adoption. Unsurprisingly, all Member States complied and some even exceeded the 
requirements  of  the  Directive,  ensuring  at  least  one  collection  and  delivery  per  day  for  six 
days  a  week369.  Yet,  the  Member  States  exceeding  the  requirements  diminished  over  time, 
from eleven Member States requiring six-day a week collection and delivery in 2004 to only 
three that exceeded the minimum required frequency and had a six-day collection/delivery in 
2019  (i.e.,  France,  Germany  and  Malta),  plus  Bulgaria  with  at  least  two  collections  and 
deliveries per day, but this concerns only the capital370.  

Regarding delivery to the door, in 2019, the regulatory bodies of 11 Member States (Austria, 
the Czech Republic, Denmark, Germany, Hungary, Luxembourg, the Netherlands, Romania, 
Slovakia,  Slovenia  and  Sweden)  had  identified  exceptional  circumstances  allowing  the 
universal  service  providers  to  perform  delivery  under  special  conditions371.  This  coincided 
with the increasing installation of parcel lockers in retail outlets, which have been adopted as 
an alternative to home delivery of parcels. 

The  increasing  size  of  exceptions  in  terms  of  population  concerned  and  the  diminishing 
number  of  days  for  collection  and  delivery  came  in  response  to  a  series  of  developments, 
including  changing  user  needs,  digitisation  and  declining  mail  volumes372.  As  volumes 
decreased, it has become more expensive for operators to deliver letters, pushing up the cost 
of  the  universal  service  obligation.  Some  Member  States  started  to  contemplate  or  even 
adopted measures challenging the provisions of the Directive, taking  into account Article 5, 
paragraph  1  fifth,  indent,  which  states  that  the  universal  service  obligation  shall  "evolve  in 
response to the technical, economic and social environment and to the needs of users".  

Denmark  was  the  first  country  to  reduce  the  frequency  of  delivery  obligation  for  universal 
services  below  the  5  working  days  a  week.  It  was  followed  by  Italy,  which  introduced  an 
alternate day delivery model for rural areas (inhabited by 23,2 percent of the population). The 
universal  service  provider  of  the  Netherlands  delivers  letters  from  Tuesday  to  Saturday.  In 
Finland,  an  amendment  of  the  Postal  Service  Act  now  allows  a  reduction  to  three  delivery 
days per week in urban areas if the area in question has an early-morning delivery network 
for newspapers.373.  

These  exemptions  from  the  frequency  of  delivery  obligation  were  granted  to  the  universal 
service providers by either the government or the regulator in order to mitigate the impact of 
declining  volumes.  However,  WIK  (2021)  notes  that  it  is  not  clear  whether  such  a  flexible 
interpretation of the Postal Services Directive will be upheld by courts in the future. In 2018, 
a complaint from Italian municipalities was brought to the Court of Justice of the European 
Union, but it was withdrawn before the Court made a final decision on the matter. As long as 

368 WIK (2021), p.155 
369  Report  from  the  Commission  to  the  Council  and  the  European  Parliament  on  the  application  of  the  Postal 

Directive (Directive 97/67/EC as amended by Directive 2002/39/EC), SEC(2005) 388, p.12 

370 European Regulators Group for Postal Services PL II (20) 22, p.26 
371 European Regulators Group for Postal Services PL II (20) 22, p.31 
372 WIK (2021), p.186 
373 WIK (2021), p.155 

144 

 
 
                                                      
there  is  no  decision  of  the  Court  of  Justice  of  the  European  Union  on  the  flexibility  of 
universal  service  features,  such  as  five-day  delivery  and  national  transit  time  requirements, 
there will remain a risk that national deviations from the Postal Services Directive could be 
declared as non-compliant at some point in the future’374.  

2.2.6 

 Quality of service: reliability, regularity, routing times 

The  title  of  the  Postal  Services  Directive  focuses  on  improving  the  quality  of  the  postal 
service,  along  with  the  development  of  the  internal  market  of  postal  services.  The  1993 
Guidelines375  declared  the  service  quality  as  ‘inadequate’,  as  well  as  varying  considerably 
from  one  Member  State  to  another.  This  was  the  first  of  the  ‘operational  problems’  of  the 
sector that required intervention. Therefore,  increasing and levelling the performance of the 
different Member States’ universal service providers was a chief motive for the adoption of a 
common policy for postal services. 

The quality of the domestic mail differed considerably from one Member State to another, in 
some countries 90 percent of letters arrived the day after posting, while in others the figure 
was as low as 15 or 16 percent. This was seen as ‘a real barrier to trade’ for those sectors that 
were  particularly  dependent  on  the  postal  services,  like  magazine  and  newspaper  services, 
financial  services,  mail  order  and  advertising.  For  cross-border  mail,  the  average  delivery 
time  was  four  days,  compared  with  between  one  and  a  half  and  two  working  days  for 
domestic mail. The generally stated aim of a timeframe of three-day for the delivery of cross-
border  mail  was  in  fact  achieved  in  only  40  percent  of  cases.  This  difference  in  service 
quality  emphasized  borders  and  thus  disrupted  the  single  market,  giving  local  firms  an 
advantage over competitors from other Member States376. 

The  Postal  Services  Directive,  by  its  Article  16,  required  quality  of  service  standards 
focussing on routing times, regularity and reliability to be set and published in relation to the 
universal service. Performance according to these standards was to be subject to independent 
monitoring.  Article  18  and  Annex  II  set  out  targets  for  the  intra-Community  cross  border 
letter mail services: 85% D+3. i.e. 85 percent of the intra-EU cross-border letters were to be 
delivered  within  three  working  days  after  the  date  of  deposit  and  97%  D+5,  i.e.  to  be 
delivered within five working days after deposit. For domestic post, Member States had the 
flexibility to  determine their own standards, provided that they  were compatible with  those 
for intra-Community cross-border services set by the Directive.  

Following the adoption of the Directive, the then 15 Member States reset their performance 
targets  for  domestic  mail,  some  dropping  from  100  percent  to  more  realistic  values  (Spain 
and  Luxembourg)  and  six  of  them  raising  to  more  ambitious  levels.  At  present,  all  EEA 
Member States have defined transit time targets for priority mail, and even if they still present 
some variations, the average targets have been on a similar level since 2006 (between 80-95 
percent),  with  the  exception  of  the  most  recent  Member  States  (Bulgaria,  Croatia, 
Romania)377. Spain and Luxembourg do not have transit time targets for D+1, their targets for 
single-piece  priority  mail  referring  to  D+3  (Spain)  and  D+2  (Luxembourg).  Taking  full 
advantage  of  the  flexibility  offered  by  the  Directive,  17  Member  States  have  defined 

374 WIK (2021), p.186 
375 COM(93) 247 final, pp.5-6 
376 COM(93) 247 final, pp.5-6 
377 WIK (2021), pp.26-27 

145 

 
 
                                                      
regulatory targets  for other mail  categories like  non-priority letters, 13  for registered items, 
six for bulk mail and two for newspapers378.  

Table 21 EEA Transit time objectives for domestic single-piece priority letter mail 

D+1 

80 percent 

>80 percent up to 85 percent 

>85 percent up to 90 percent 

>90 percent up to 95 percent 

>95 percent 

Number of countries 

3 

7 

4 

12 

1 

Note: 
Source:   ERGP (2019), Report on quality of service, consumer protection and complaint handling 2018, PL II (19) 35 

DK, ES, LU, SE have not defined D+1 targets within the scope of universal service. No information: LI 

In addition to the transit-time performance objectives, nine of the countries surveyed by the 
European  Regulators  Group  for  Postal  Services  had  regulatory  objectives  regarding  loss  or 
substantial  delay  in  2018  (two  more  than  in  2017).  Four  of  these  nine  countries  have 
regulatory  objectives,  but  no  measurement  obligation,  for  loss  or  substantial  delay.  Four 
countries  have  regulatory  objectives  regarding  queuing  time  in  post  offices  (up  by  one 
compared  to  2017).  One  of  these  countries  has  regulatory  objectives  but  no  measurement 
obligation for queuing time in post offices. Six states had regulatory objectives regarding loss 
or substantial delay. Only Malta and Portugal set regulatory objectives regarding the delivery 
time of newspapers and periodicals, whereas Denmark and France measured transit time for 
newspapers and periodicals without having regulatory objectives379.  

Domestic mail 

the  obligation 

these  performance 

targets,  combined  with 

to  monitor, 
Establishing 
independently  measure  and  publish  the  actual  performance,  has  greatly  improved  domestic 
transit  time  performance  after  the  adoption  of  the  Directive380.  Although  departing  from 
considerable differences, performance became more comparable and improved, most notably 
in the Member States that joined in 2004. The trend was still positive between 2010 and 2013 
for  the  overall  domestic  transit  time  performance.  At  that  time  targets  were  exceeded  for 
priority  letters  in  most  Member  States  and  for  non-priority  mail  in  virtually  all  Member 
States381.  It  was  from  2014  that  the  trend  was  reversed  and  the  transit  time  performance 
started to decrease in most of the countries, driven by the fall in volumes and need to ensure 
financial  sustainability.  Since  2013,  the  number  of  universal  service  providers  that  achieve 
their targets in the fastest standard category diminishes constantly (see Table 22).  

378 WIK (2021), p.229 
379 European Regulators Group for Postal Services PL II (19) 35, pp.23-24 
380 WIK (2021), p.229 
381 COM(2015) 568 final, SWD(2015) 207 final, p.78 

146 

 
 
 
                                                      
Table 22 Number of universal service providers that achieved domestic transit time targets (FSC) 

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

8 

6 

9 

7 

11  14  15  16  18  21  17  18  20  19  19  20  21  25  23  20  16  17  16 

6 

7 

6 

6 

9 

11  10  10  11  11  10  12  11  14  12  9 

7 

9 

8 

2 

2 

4 

5 

5 

5 

4 

5 

5 

4 

5 

5 

6 

4 

7 

7 

7 

7 

5 

5 

6 

na  na  na  na  na  na  na  2 

0 

1 

1 

1 

1 

1 

0 

1 

1 

1 

1 

1 

1 

na  na  na  2 

3 

3 

3 

3 

2 

3 

3 

2 

2 

3 

3 

3 

3 

3 

3 

2 

1 

All 

EU  MS 
1997 

EU  MS 
2004 

EU  MS 
after 
2007 

LI, IS, NO, 
CH 

Source:  ERGP core indicators, annual reports of national regulators, WIK research 

As letter post volumes decline, the average operational costs increases for the exploitation of 
the postal  network and for maintaining quality standards such as transit time performances. 
Despite this challenge, transit time performance of D+1 domestic priority letters delivered on 
time remained quite stable between 2015-2018 in most countries. Universal service providers 
in the EU had transit time performance at around 85 per cent on average. Thirteen countries 
reached performance shares of  at  least  90 percent, seven above or equal to  85 percent,  and 
five have performance varying between 49 percent and 76 percent.  

Figure 28 Percentage of domestic priority letters delivered next day 

Source: EC postal statistics, Spain applying D+3 for priority letters and Denmark D+5  

In contrast, the international transit performance of D+3 has deteriorated in the period under 
review (see Figure 29 below).  

Cross-border mail 

With  as  little  as  30-40  percent  of  cross-border  mail  delivered  in  D+3  in  some  cases,  the 
quality  of  cross-border  delivery  in  the  1990s  was  indeed  low,  as  the  1992  Green  Paper 
rightfully  pointed  out.  After  the  Postal  Services  Directive  set  minimal  standards  for  the 
number of letters to be delivered in three and five days, cross-border mail quality of service 

147 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
boosted until it reached a peak in 2008 with nearly 95 per cent of all intra-Community cross-
border items delivered on the third day after posting (See  below).  

The steady decline that followed coincided with a more abrupt fall in volumes caused by the 
financial  crisis  and  the  increasing  pressure  on  operators  to  cut  costs.  Reductions  in  the 
delivery  frequency  also  played  a  role  in  lower  transit  time  performance  since  the  financial 
crisis. As a consequence, in 2013, 92.5 percent of cross-border items were delivered within 
three working days, but only 82.3 percent in 2016 and 77.5 percent in 2019. This is not only 
the lowest performance since the start of measurement in 1997, but also well below the target 
of 85 percent specified by the Postal Services Directive382.  

Figure 29 D+3 performance development 1997-2019 for international mail 

Period of volume growth 
Period of volume growth 

Volcanic 
Volcanic 
eruption in IS 
eruption in IS 

Period of volume declines 
Period of volume declines 

Source:  based on WIK (2021), Copenhagen Economics (2018); IPC, UNEX CEN module 2019 results 

These  percentages  are  average  and,  as  the  chart  below  shows,  in  2018  there  were  still 
universal service providers who upheld the standard (Denmark, Hungary, Malta, Slovakia,). 
Nevertheless,  there  were  more  who  had  fallen  below  the  standard  and  the  trend  continues 
downward. 

382 WIK (2021), p.31 

148 

 
 
  
 
                                                      
Figure 30 Transit time performance D+3 

Source: EC postal statistics 

2.2.7  Affordability – price regulation 

The Directive leaves the interpretation of affordability at the discretion of Member States, as 
it does the other tariff principles established by Article12: cost-orientation, transparency and 
non-discrimination. Most Member States have included the tariff principles in their national 
postal legislation and all apply some form of price control383 in order to ensure compliance.  
However,  as  shown  in  Table  23  below,  the  interpretation  of  the  principles  is  varied.  For 
instance, only five Member States have defined affordability and 16 cost orentation.  

Table 23 Implementation of pricing principles, 2018 

Countries 

# of MS 

Affordability defined? 

BE, BG, DE, IT, UK 

Cost orientation 

Affordability 

Cost orientation defined at all? 

BE, BG, CY, CZ, FR, HU, IE, IT, LT, MT, NL, PT, RO, 
SI, SK 

Cost orientation not defined? / NA 

AT, DE, DK, EE, EL, FI, HR, LV, LU, PL, SE, UK 

Transparency defined? 

BE, BG, CZ, DE, EE, EL, FI, FR, HR, HU, IE, IT, LV, LT, 
MT, PL, PT, RO, ES, SI, UK 

Transparency 

5 

15 

12 

21 

Transparency: publish at website 

CZ, EE, EL, FI, FR, HR, IE, IT, LV, LT, MT, RO, SI, UK 

14 

Transparency: publish tariffs and general discounts 

BE, NO, ES 

Transparency:  publish  tariffs  and  general  discounts 
to relevant users only 

Transparency: publish tariffs to NRA 

BG 

DE 

383 COM(2015)0568 final, p.17 

3 

1 

1 

149 

 
 
 
 
                                                      
Transparency: publish without formal requirements  HU, PL, PT 

Transparency: NA 

AT, CY, DK, LU, NL, SK, SE 

3 

7 

Non-discrimination 

Non-discrimination defined at all? 

BG, CZ, DE, EE, EL, FR, HR, HU, IE, IT, LV, LT, MT, 
PL, PT, RO, ES, SK, SI, SE, UK 

21 

Source:  WIK (2021), Copenhagen Economics (2018) 

The exact mechanisms for price control vary as well, ranging from ex-ante price approval by 
regulators and ex-ante price cap regulation to performing affordability tests. Similarly, tests 
for cost-orientation vary with respect to the type of accounting information delivered by the 
universal service provider (financial versus regulatory accounts) and the level at which cost-
orientation is tested (individual product level versus basket of services level). Some countries 
do not employ formalised tests for cost orientation384.  

Table 24 Method of price regulation 

Method of price regulation 

Ex-post 

Price-cap 

Ex-ante 

No price regulation 

Price 
dominant 

cap 

where 

Country 

Basic letter 
post 

Bulk 
letters 

Direct mail 

Periodicals 

Non-
priority 
letter post 

Parcel post 

Bulk 
parcels 

Other 

Other 

Other 

Other 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

384 Copenhagen Economics (2018), p.207 

150 

 
 
  
  
 
 
 
  
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
                                                      
MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

Other 

Other 

Source: Copenhagen Economics (2018) 

The principle of cost orientation for universal service tariffs set in place by the Directive in 
Article 12 was established initially in the context of imminent liberalisation in order to limit 
price  increases  to  the  level  indicated  by  costs,  rather  than  the  amount  enabled  by  market 
power.  Lately  however,  as  a  consequence  of  volume  declines,  average  costs  per  unit  are 
increasing and are driving prices beyond the scope of inflation, as it is evident from the chart 
below. This effect is more evident in the European countries with higher mail volumes (EU 
MS  1997  in  the  chart  below)  than  the  entire  European  Union  and  the  tendency  is  also 
manifest in non-EU countries, as well, for instance Australia and the United States.  

Figure 31 Price developments within the EU, Australia and the USA 

Source:  WIK (2021) Australia Post price lists, universal service providers’ price lists, WIK research 

Where  national  regulators  directly  review  and  verify  cost  orientation  (e.g.  Belgium),  price 
increases have in principle been restricted to cost increases. In the ten Member States where 
regulators  apply  price  caps  to  limit  price  increases  (Belgium,  Croatia,  Estonia,  France, 
Germany, Hungary, Lithuania, Netherlands, Portugal, Sweden), price cap formulas include an 
efficiency  factor.  The  existence  of  this  factor  is  aimed  at  ensuring  that  efficiency  gains  are 

151 

050100150200250300350200820092010201120122013201420152016201720182019Price development (index)AUEU averageEU MS 1997 averageUS 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
achieved.    As  the  efficiency  factor  limits  (it  is  in  principle  a  negative  factor)  the  scope  for 
price  increases,  operators  that  manage  to  enhance  their  efficiency  beyond  the  scope  of  the 
efficiency factor may retain these efficiency gains. Regulators from the countries with some 
of the highest volume declines tend to relax the national price control mechanisms in order to 
keep  the  provision  of  services  sustainable.  In  the  last  years,  this  has  affected  even  the 
requirements  for  the  scope  of  the  universal  service  –  e.g.  frequency  of  delivery  (Denmark, 
Iceland  and  the  Netherlands)  and/or  the  transit  times  (Finland  and  Sweden).  However,  the 
reductions in the quality requirements were not sufficient for the universal service providers 
to  keep  costs  under  control  and  the  prices  in  these  countries  have  increased  as  well,  as 
indicated in the chart below. 

Figure 32 Developments of public tariffs in selected countries (20g letter, fastest standard category) 

Source: WIK (2021) Universal Service Providers price lists 

For the case of Sweden, this is documented by the national regulator’s statement in its annual 
market survey. The Swedish price cap would allow an increase of 0.19 SEK (~EUR0.02) for 
2019, which is regarded as insufficient by PostNord Sweden to cover average unit costs, even 
though  priority  and  non-priority  letter  services  in  Sweden  have  been  merged  to  a  D+2 
service385. 

Since postal prices have been quite low in many Member States for a long time, the need to 
define and verify affordability was not urgent, even in the absence of effective competition in 
the  letter  markets.  However,  in  some  countries,  price  increases  have  been  substantial:  the 
current price for a domestic priority letter stamp in Italy is EUR 2.80, and DKK 29/EUR 3.88 
in Denmark. The average consumer might not be heavily affected by such price increases, not 
even  in  Italy  and  Denmark,  as  average  consumers  send  a  very  low  number  of  letters. 
However, there are user  groups for  which strong price increases  can be a problem, such  as 
those without alternatives to letters, e.g. without internet access or with low digital skills. The 
number  of  users  for  whom  strong  price  increases  for  letters  are  a  problem  will  vary 
substantially between Member States but affordability can be a potential problem for certain 

385 WIK (2021), pp.266-8 

152 

00.511.522.533.54SENLISFIDKPrices in €201320162019 
 
 
                                                      
user  groups.  In  this  context,  the  implicit  conflict  between  affordability  and  cost  orientation 
will both become more relevant and evident386.  

2.3 Protection of users - complaints resolution 

Complaint resolution protection before the Directive was not measured or reported publicly, 
it  was  at  the  latitude  of  the  operators.  The  1992  Green  paper  notes  that  ‘how  readily  are 
enquiries  or  complaints  answered’  is  part  of  the  quality  of  service  and  deplores  the  lack  of 
common ‘standards for dealing with complaints387’ to ensure measurability. It also states that 
‘regulatory bodies must ensure that there are clear procedures laid down for the resolution of 
disputes’. 

The Postal Services Directive bridges this gap by its Article 19 which requires Member States 
to ensure that a transparent, simple and inexpensive procedure for dealing with complaints is 
made  available  by  all  postal  operators,  not  only  the  universal  service  providers.  Where 
warranted,  a  system  of  reimbursement  and/or  compensation  is  also  required.  Where  not 
satisfied by the provider, the Directive mandates that users be able to bring cases in front of 
the competent authority, independently or together with consumer protection organisations or 
other organisations representing user interests. This was initially applicable only to universal 
service  providers  and  then  it  was  extended  to  all  postal  service  providers  by  the  third 
Directive (2008/6/EC). 

The  universal  service  provider,  and  where  appropriate  other  operators  providing  services 
within  the  scope  of  the  universal  service  area,  are  required  to  publish  the  number  of 
complaints  they  receive  and  how  they  have  been  dealt  with.  Independent  out-of-court 
schemes for dispute resolution are not an obligation, but are mentioned and encouraged.  

In the application of these, all Member States have extended user protection obligation to all 
postal operators, and almost all Member States have appointed a competent national authority 
to review users’ complaints that have not been satisfactorily resolved by the universal service 
provider. This is frequently the postal regulator and sometimes an Ombudsman or dedicated 
consumer  body.  All  Member  States  ensure  that  providers  of  postal  services  have  a 
transparent,  simple  and  inexpensive  procedure  for  dealing  with  complaints  from  users,  and 
most universal service providers have a system of compensation388. 

In 21 countries universal service providers are obliged to measure and in 15 to also publish 
indicators on the complaints they receive (see Table 25 below). In eight countries there is no 
obligation to publish, but in some cases, like in Austria, there is the obligation to inform the 
NRA  about  the  number  of  complaints  received.  below).  In  eight  countries  there  is  no 
obligation to publish, but in some cases, like in Austria, there is the obligation to inform the 
NRA about the number of complaints received.  

386 WIK (2021), p.269 
387 COM(91) 476 final, pp.186, 216 
388 COM(2015) 568 final, SWD(2015) 207 final, p.79 

153 

 
 
 
 
 
                                                      
Table 25 Universal service providers’ complaint procedures  

Applied in  
(# of countries) 

Applied in 

Universal Service Providers obliged to 
measure complaints 

Universal Service Providers obliged to 
publish complaint statistics 

Universal Service Providers not obliged 

Compensation schemes 

21 

15 

8 

16 

BG, CH, CY, CZ, EE, ES, EL, FI, FR, HR, IT, LT, LV, MT, 
PL, PT, RO, SE, SI, SK, UK 

CZ, EE, EL, FR, HR, IT, LV, MT, PL, PT, RO, SE, SI, SK, 
UK 

BE, DE, DK, HU, IS, HU, NL, NO 

BG, CY, EL, FR, HR, HU, IE, IS, IT, LV, MT, PL, PT, RO, 
SK, UK 

No information for AT, IE, LI 

Note: 
Source:  ERGP (2018), Report on Quality of Service, consumer protection and complaint handling, (18) 44 
Complaint procedures are approved by regulators in only 18 out of 32 countries surveyed by 
the  European  Regulators  Group  for  Postal  Services  in  2018.  Postal  users  in  nearly  all 
countries have the option to have the regulator review the operator’s decision if a complaint 
was  not  solved  satisfactorily  from  a  user’s  perspective.  The  option  to  appeal  to  courts  is 
ensured in at least 30 countries.  

Only  half  of  universal  service  providers  are  obliged  to  offer  compensation  schemes,  and 
regulators  in  some  countries  lack  sufficient  enforcement  tools  to  deal  with  shortcomings  in 
quality performance (e.g. Germany)389. 

The  European  Regulators  Group  for  Postal  Services,  as  well  as  the  WIK  2021  study,  point 
out a structural flaw in the Directive in this respect, namely that it refers to postal users rather 
than customers. A customer is understood as the one paying for a service, i.e. the sender, not 
the receiver. Because of this receiver rights are structurally neglected by many operators, and 
often receivers do not have the option to complain at all390. 

Between  2013  and  2016  an  increase  in  user  complaints  was  experienced,    especially  in 
Eastern  European  countries,  primarily    Bulgaria  and  Poland.  Complains  related  to  both 
universal service and non-universal service products. The main driver behind the increase in 
user complaints was considered to be the rapid growth of e-commerce parcel volumes391. 

Between  2017  and  2019,  the  data  collected  by  the  European  Regulators  Group  for  Postal 
Services392  did  not  confirm  a  common  EU  trend  regarding  complaints.  The  number  of 
complaints  received  by  the  universal  service  providers  about  universal  services  ranged  in 
2019  from  14.46  per  one  thousand  inhabitants  in  France  to  0.35  in  Cyprus.  The  European 
Regulators  Group  for  Postal  Services  analysed  geographic  clusters  and  concluded  that  the 
overall  complaints  rate  remains  higher  in  Western  countries  and  lower  in  Eastern  and 
Southern countries. 

389 WIK (2021), pp.244-246 
390 WIK (2021), p.244 
391 Copenhagen Economics (2018), p. 66. 
392 European Regulators Group for Postal Services (2020) PL II (20) 22, pp.57-59 

154 

 
 
 
                                                      
Figure 33 Complaints received by universal service providers per 1,000 inhabitants, 2017-2019 

Source:  ERGP (2020) PL II (20) 22, Report on quality of service, consumer protection and complaint handling  

In what concerns the number of complaints received by regulators, as indicated in Figure 34 
below, the  rate per ten thousand inhabitants  ranged from 1.58 in  Sweden to  0.00 in  France 
and no consistent trend could be discerned from the data reported by the regulators.   

Figure 34 Complaints received by regulators per 10,000 inhabitants, 2017-2019 

Source:  ERGP (2020) PL II (20) 22, Report on quality of service, consumer protection and complaint handling 

The complaints lodged with the universal service providers (see Figure 35 below) regarding 
cross-border services referred mainly to items lost, damaged or substantially delayed.  

155 

 
 
 
 
Figure 35 Complaints received by universal service providers about cross-border services, 2017-2019 

Source:  ERGP (2020) PL II (20) 22, Report on quality of service, consumer protection and complaint handling 

However, as shown above, there are significant differences among Member States regarding 
the  definition  of  complaints,  the  data  collection  methods  and  the  national  regulatory 
frameworks and practices.  

2.4 Level Playing Field and Competition  

Article  11a  of  the  Postal  Services  Directive,  requires  Member  States  to  give  all  postal 
operators  access  to  “elements  of  postal  infrastructure”  —  facilities  and  information 
resources used in providing postal services  — whenever necessary to protect the interest of 
users and/or to promote effective competition. 

This  provision  would  require  that  non-discriminatory  access  conditions  were  provided  to 
elements  of  postal  infrastructure  such  as  postcodes,  address  database,  public  letter-post 
collection boxes, post office boxes, parcel lockers, letter delivery boxes, and redirection and 
return services.  It has been found that in the majority of Member States access to  universal 
service provider’s post codes, address database, and post office boxes is given to competitor 
operators.393 

Table 26 Access to postal infrastructure 

Infra-structure 
element 

Post 
codes 

Address 
database 

Public 
letter-post 
collection 
boxes 

Post 
office 
boxes 

Parcel 
lockers 

Letter 
deli-very 
boxes 

Redirect
ion  and 
return 
service 

84% 

57% 

18% 

64% 

5% 

57% 

48% 

Member States 
with non-
discriminatory 
access 
conditions 

393 Copenhagen Economics (2018), p. 89. 

156 

 
 
 
                                                      
 
(percent)  

Source: Copenhagen Economics (2018) Main Developments in the Postal Sector 2013-2016, p. 90. 

Operators  generally  do  not  cooperate  in  building  or  sharing  infrastructure.  In  a  few  cases, 
however, operators have engaged in cooperation initiatives to develop and/or share part of the 
postal infrastructure. Apart from the traditional third-party downstream access arrangements, 
new infrastructure sharing models include the following examples:  

  Sharing  of  parcel  lockers  among  the  universal  service  provider  and  other  postal 

operators (BE, LU).  

  Sharing of delivery network by non-universal service provider postal operators (IT).  

 Overall, the new initiatives revolve mostly around the delivery of parcels. 

Access to downstream services describes  a service whereby the incumbent postal operator 
gives access to other postal service providers and postal users to its network at selected points 
of  the  postal  supply  chain  and  then  delivers  the  access  mail  fed  into  its  network.  From  a 
postal regulatory point of view, access regulation aims at promoting efficiency and effective 
competition and, thereby, conferring benefits on the users of postal services. 

Downstream  access  regulation  has  strong  impact  on  the  pricing  of  the  universal  service 
provider. For instance, if the access price is set below the bulk mail price, then bulk mailers 
(e.g.  business  mail  senders)  find  it  less  expensive  to  either  become  access  seekers  or  send 
mail via intermediaries that use access product, compared to buying the postal operator’s bulk 
mail  products.  Thus,  the  postal  operator  will  be  limited  in  its  ability  to  price  its  bulk  mail 
product.  On  the  other  hand,  setting  the  access  price  higher  than  the  bulk  mail  price  can 
amount to a margin squeeze, forcing access seekers or intermediaries to limit what they can 
charge. Either way, access price regulation affects prices bulk mailers pay for delivery. 

Once access has been mandated by the national regulator or requested by a competitor, both 
the universal service provider and the regulator may face a host of challenges concerning the 
design of the access  regime. These challenges  can be grouped into  three  types  of questions 
that need to be answered when designing an access regime, namely: scope of access, access 
price, and point of access.  

First,  in  terms  of scope of access:  should access be mandated to  universal  service products 
only  or  also  to  non-universal  service  products?  While,  in  some  cases,  national  postal  laws 
limit access to universal service products, the question of whether to include only a subset of 
these  products  (or  other  products)  still  arises.  In  other  cases,  the  postal  law  does  not 
determine  a  clear  product  scope  of  access.  Among  20  countries  where  universal  service 
providers are obliged to provide access to their postal network, in ten countries such access 
concerns  only  universal  postal  services,  in  two  countries  it  concerns  non-universal  postal 
services and in remaining eight countries – both universal and non-universal postal services, 
as shown in the table below.  

Table 27 Product scope 

 Product scope 

Member States 

Obligatory access to the postal network 

Belgium,  Bulgaria,  Croatia,  Cyprus,  Czech  Rep., 

157 

 
 
 
Germany,  Estonia,  Spain,  Greece,  Hungary, 
Ireland, 
Netherlands, 
Lithuania,  Malta, 
Portugal, Romania, Slovenia, UK 

Obligatory  network  access  to  universal  postal 
services 

Belgium,  Croatia,  Cyprus,  Germany,  Estonia, 
Spain, Greece, Hungary, Slovenia 

Obligatory  network  access  to  non  –  universal 
postal services 

Lithuania, Netherlands 

Obligatory  network  access  to  universal  and 
non-universal postal services 

Bulgaria,  Czech  Rep.,  Ireland,  Malta,  Portugal, 
Romania 

Source: Copenhagen Economics (2018) Main Developments in the Postal Sector 2013-2016, p. 94. 

Second, access points: at which point in the delivery chain should access take place, i.e. at 
which  point  the  access  seeker  should  drop  off  its  mail  in  order  for  it  to  be  fed  into  the 
delivery network? Traditionally, point of entry for access mail have usually been the inward 
and  outward  mail  centre.  From  the  economic  point  of  view,  any  access  points  further 
downstream  than  the  inward  sorting  centre  are  likely  both  operationally  inefficient  and 
incompatible with the cost-orientation requirement for access prices. Access that is provided 
further downstream, for instance at distribution offices, may lead to a duplication of resources 
and  therefore  to  an  increase  in  costs.  In  the  situation  when  access  points  create  additional 
costs for the universal service provider, any access prices charged would have to reflect these 
additional  costs.  This  creates  a  tension  between  the  cost  orientation  requirement  and  the 
requirement for access  prices to  be lower than the standard end-to-end service price. These 
elements have been at the basis of the German and Italian NRAs’ conclusion not to set out 
access to local distribution centres. 

2.5 Interoperability for the Postal Sector/Standardisation 

The European Committee for Standardisation (CEN) is entrusted with drawing up technical 
standards applicable in the postal sector on the basis of standardisation requests adopted by 
the Commission. Such work should take account  of the harmonisation  measures adopted at 
international level and in particular those decided upon within the Universal Postal Union. 

CEN’s method of operation is based on a network of national standardization bodies and is 
geared  towards  involving  all  parties  concerned,  including  SMEs  and  societal  stakeholders. 
European  standards  for  postal  services  are  developed  by  the  CEN  technical  committee  331 
(CEN/TC 331). CEN/TC 331 consists of experts with  different  backgrounds and from  both 
different  countries  and  organizations.  When  the  experts  in  CEN/TC  331  draft  standards, 
members of the national standardization committees (via the national standardization bodies) 
comment  on  the  standards  during  the  several  voting  phases  during  the  development  of 
standards. This is the system and process that is common for developing European standards 
and hence a broad group of parties is connected.  

The  Commission  has  issued  four  standardisation  requests  concerning  postal  services.  The 
first request M/240394 to CEN was issued in March 1996 to work on the first set of European 
standards for postal services and equipment. Based on the progress achieved within this first 

394 M/240, Mandate to CEN for standardisation in the field of postal services and equipment, 15.3.1996. 

158 

 
 
                                                      
request and to extend the work programme with new subjects for standardisation, the second 
request M/312395 to CEN was issued in May 2001. The third standardisation request M/428396 
was  issued  in  October  2008  asking  CEN  to  establish  tools  for  measurement  of  quality  of 
postal services and for facilitating interoperability between actors in the postal value chain. In 
addition, it asked CEN to undertake a periodical review of standards elaborated on the basis 
of previous request and to study feasibility of new standards in the area of quality of service. 
The fourth standardisation request M/548397 was issued in August 2016.    

Standardisation request 2016-2020 

Previous standardisation requests for postal services focused largely on letter post. With the 
growing importance of e-commerce, a shift is taking place to include not only letters, but also 
parcel  delivery,  as  expressed  in  this  standardisation  request.  This  shift  in  approach  is  still 
valid  and  relevant,  given  recent,  continued  trends  in  the  postal  markets  (increasing  parcel 
volumes and decreasing letter volumes). 

The  latest  request  was  launched  as  there  was  considered  to  be  a  need  for  progress  in  the 
interconnection of postal networks. Encouraging technical standardisation is seen as required 
to address this need, and such standardisation is considered to be in the interests of users. In 
general,  technical  standardisation  is  also  seen  as  indispensable  for  the  promotion  of 
interoperability  between  national  networks  and  for  an  efficient  European  Union  universal 
service. For the single market, interconnection of postal networks and interoperability is still 
of  high  importance,  and  the  project  (standardisation  deliverables)  has  been  targeted  at  this 
need.     

The  objective  of  the  request  was  notably  to  promote  quality  of  service,  European 
interoperability  of  mail-delivery  operations  and  thereby  to  contribute  to  promoting  the 
creation  of  a  Digital  Single  Market  for  the  European  Union.  The  objective  was  also  to  be 
compliant to security and customs clearance requirements for electronic advanced data in line 
with  international  standards  adopted  by  the  World  Customs  Organisation  (WCO)  and 
Universal Postal Union. 

Use of standards 

Since  2002,  CEN  has  developed  and  published  43 standards  of  which  two  are  mandatory: 
EN 13850  on  measurement  of  transit  time  of  end-to-end  services  for  single-piece  priority 
mail  and  first  class  mail,  and  EN 14012  on  principles  of  complaint  handling.  These  two 
mandatory standards stand out as they are a direct result of the Directive’s requirements.  

However,  some  designated  postal  operators  do  not  apply  these  standards.  According  to 
research by the European Regulators Group for Postal Services, EN 13850 is not applied in 
Denmark, Estonia, Latvia and Sweden. In the case of Denmark, standard EN 14508 is applied 
for measurement of non-priority mail. For the others, it is unclear which quality standards for 
measurement of transit time performance are applied.  

395  M/312,  Standardisation  mandate  to  CEN  for  standardisation  in  the  field  of  postal  services  and  equipment, 

4.5.2001. 

396  M/428,  Standardisation  mandate  to  CEN  for  standardisation  in  the  field  of  postal  services  and  equipment, 

9.10.2008. 

397 Standardisation mandate to CEN for standardisation in the field of postal services and equipment, 1.8.2016.  

159 

 
 
 
                                                      
Table 28 Application of the mandatory standards for transit time measurement 

Standard applied for measurement of 

Applied in (# of MS) 

EN 13850 

Single-piece priority mail 

Single-piece non-priority mail 

Registered mail 

Bulk mail 

EN 14508 

Single-piece non-priority mail 

Registered mail 

EN 14534 

Bulk mail 

TR 15472 

Parcels 

23 

4 

3 

1 

10 

1 

3 

4 

Source:  ERGP  (2019),  Report  on  Quality  of  Service,  consumer  protection  and  complaint  handling,  (19) 35, 

p. 57 

The application of voluntary standards also varies between Member States. Universal service 
providers  in  some  countries  only  apply  the  two  mandatory  standards.  There  are  no  data 
available  on  the  number  of  operators  that  apply  voluntary  standards.  Universal  service 
providers apply voluntary standards very selectively. Universal service providers from small 
countries  are  less  likely  to  apply  voluntary  standards  developed  by  CEN  and  rely  on  UPU 
standards only.398 

2.6 Data Collection 

Article 22a was introduced in the Third Postal Services Directive to ensure the availability of 
reliable and up-to-date postal statistics. Member States are therefore required to  ensure that 
postal service providers supply financial information and information on the provision of the 
universal service, in particular to National Regulatory Authorities where such information is 
required to ensure conformity with the Directive or for clearly defined statistical purposes. 

Eurostat (which was the main information point for postal statistical information) decided in 
2013  to  terminate  data  collection  on  postal  services399.  From  2014  the  Commission 
Directorate-General  for  the  Internal  Market,  Industry,  Entrepreneurship  and  SMEs  has 
assumed the role of compiling statistics at the European level. The Commission statistics are 
collected  in  collaboration  with  National  Regulatory  Authorities,  who  receive  the  data  only 
after universal service providers publish their accounts. Data is then validated and complied 
at the EU level.   

Overall, Article 22a has been implemented with respect to data for ensuring compliance with 
the  Directive.  Research  by  the  ERGP400  indicates  however  that  the  data  collection 

398 WIK (2021) p. 302. 
399  Eurostat 
postal 

data 

refer 

up 

to 

reference 

year 

2011, 

and 

are 

available 

at: 

http://ec.europa.eu/eurostat/web/postal-services/data/database 

400 European Regulators Group for Postal Services (18) 45  

160 

 
 
 
                                                      
competence of National Regulatory Authorities is restricted in some cases. For example, the 
National Regulatory Authorities in France and Portugal may collect data from other operators 
than  the  Universal  Service  Provider,  only  if  these  are  licensed  operators.  The  Danish 
regulator has no competence to collect data on non-universal services401. Collection of market 
data is not uniform and it is not necessarily considered an aim of regulation or a key duty by 
National  Regulatory  Authorities  in  all  Member  States.  Member  States  have  interpreted 
Article  22a(1)(b)  in  different  ways.  In  practice,  although  all  Member  States  collect  some 
statistics from their Universal Service Providers there is a strong focus on services within the 
scope  of  the  universal  service  obligation.  Until  recently,  data  on  the  parcel  and  express 
segment of the postal market was far less comprehensive and reliable than information on the 
letter market because most National Regulatory Authorities had not systematically collected 
data on domestic and cross-border parcel  and  express  services outside the universal  service 
obligation. With the adoption of the Regulation on cross-border parcel delivery services402 in 
2018,  parcel  delivery  service  providers  are  now  obliged  under  article  4  to  provide  the 
National  Regulatory  Authority  of  the  Member  State  in  which  they  are  established  with  a 
number  of  information,  such  as  annual  turnover,  number  of  persons  working  for  them, 
items.
number  of  parcels  handled  or  price 

set  of  pre-defined 

for  a 

lists 

401 WIK (2021), p.312 
402 Regulation 2018/644 of 18 April 2018 

161 

 
 
                                                      
11.  ANNEX 5: COHERENCE 

Table 29 Coherence and complementarity between the Directive and other key pieces of legislation403 

EU legislation 

Regulation (EU) 2018/644 of the European 
Parliament  and  of  the  Council  of  18  April 
2018  on  cross-border  parcel  delivery 
services 

[regulation on cross-border parcel delivery 
services] 

OJ L 112, 2.5.2018, p. 19-28 

Directive  2014/24/EU  of  the  European 
Parliament  and  of 
the  Council  of 
26 February  2014  on  procurement  on 
repealing 
procurement 
public 
Directive 2004/18/EC  

and 

[Procurement Directive] 

OJ L 94, 28.3.2014, p. 65 - 242–374 

Relevant 
provisions in the 
Directive 

Article 2, 3, 12, 22, 22a 

Interactions 

Potential 
gaps, synergies 

inconsistencies, 

The Regulation builds on the Directive (e.g., 
it uses the definitions of the Directive, relates 
to  single  piece  parcel  that  are  part  of  the 
into 
universal  service  obligation, 
account 
the 
Directive)  and  complements  it  insofar  as 
cross-border  parcel  delivery  services  are 
concerned. 

takes 
the  pricing  principles  of 

The  Regulation  and  the  Directive  are 
complementary.  While 
the  Directive 
does  not  focus  on  regulatory  oversight 
of  parcel  delivery  service  providers  it 
establishes common rules governing the 
provision  of  postal  services  and  the 
universal  service  within  the  Union.  No 
discrepancies  were  found  between  the 
Regulation and the Directive. 

Article 2, 4,  

The  Procurement  Directive  establishes  rules 
for  the  procurement  procedure  inter  alia  for 
universal postal services.  

The  Directive  explicitly  refers  (Recital 
26) to the different procedures under the 
public  procurement  Directive,  which 
should be used for the designation of the 
universal  service  providers.  The  two 
pieces  of  legislation  complement  each 
other  in  this  respect.  No  discrepancies 
were found between the two Directives. 

Directive  2006/123/EC  of  the  European 
Parliament  and  of  the  Council  of  12 

Article 6, 9, 19, 22 

In principle, postal services are subject to the 
the  Services  Directive, 
provisions  of 

The  provisions  of  the  Directive  prevail 
over the corresponding provisions of the 

403 This Annex provides a comprehensive overview including acts not covered in the Staff Working Document. 

162 

 
 
 
 
                                                      
December 2006 on services in the internal 
market 

[Services Directive] 

OJ L 376, 27.12.2006, p. 36–68 

of 
Council  Directive 
28 November 2006 on the common system 
of value added tax 

2006/112/EC 

Article 7 

[VAT Directive] 

OJ L 347, 11.12.2006, 

See  also:  Case  C  357/07  TNT  Post  v. 
Commissioners for Her Majesty’s Revenue 
and  Customs,  EU:C:2009:248,  paras  37-
39 

Council  Directive  (EU)  2017/2455  of  5 
December  2017 
amending  Directive 
2006/112/EC  and  Directive  2009/132/EC 
as 
tax 
regards  certain  value  added 
obligations  for  supplies  of  services  and 
distance sales of goods 

[VAT  Directive  for  supplies  of  services 
and distance sales of goods] 

OJ L 348, 29.12.2017, p. 7–22 

However,  the  real  impact  of  the  Services 
Directive is limited as  one  key element of it 
(the "freedom to provide services principle") 
does  not  apply  to  postal  services  -    postal 
services,  because  of  their  permanent  nature 
are  in  general  subject  to  establishment. 
Furthermore,  as  far  as  aspects  are  directly 
regulated  by  the  Postal  Services  Directive, 
the  relevant  provisions  take  precedence  (see 
the  2008 
in  particular 
amendment to the Directive and Article 3 of 
the Services Directive). 

recital  58  of 

information 

Services  Directive.  This  concerns  in 
particular 
requirements 
(Article  6),  authorisation  procedures 
complaint  procedures 
(Article  9), 
(Article 
contact 
the 
19) 
point/national 
authorities 
(Article  22).  No  discrepancies  were 
found  between  the  two  Directives.  For 
those  aspects  not  regulated  by 
the 
Directive  the  Service  Directive  would 
apply complementary. 

and 
regulatory 

The  VAT  Directive  exempts  the  supply  at 
face value of postage stamps valid for use for 
postal 
respective 
territory,  fiscal  stamps  and  other  similar 
stamps. 

services  within 

their 

The  Directive  abolishes  in  principle  all 
special  and  exclusive  rights.  In  as  far 
the VAT exemption can be considered a 
special  right  there  is  certain,  albeit 
limited inconsistency. .. 

The  Directive  abolishes  all  exclusive  and 
special  rights  for  the  establishment  and 
provision of postal services. 

Article 7 

The  Directive  aims  at  removing  the  VAT 
exemption  for  small  goods  entering  the  EU 
from  third  countries.  This  new  Directive 
would ensure a level playing field with intra-
EU  postal  deliveries  and  impact  on  the 
volume  of  postal  items  from  third  countries.  
.  

The  removal  of  the  exemption  together 
with  the  shift  to  more  cost-orientated 
terminal  dues  has  a  potential  positive 
effect  on 
the 
universal  service  as  volumes  from third 
countries  are  likely  to  be  reduced  and 
remaining volumes are provided at more 
and more cost-orientated rates.  

the  sustainability  of 

163 

 
 
 
 
 
Article 19 

Article 19 

Article 19 

Directive  2011/83/EU  of  the  European 
the  Council  of 
Parliament  and  of 
25 October  2011  on  consumer  rights, 
amending  Council  Directive  93/13/EEC 
and Directive 1999/44/EC of the European 
the  Council  and 
Parliament  and  of 
repealing  Council  Directive  85/577/EEC 
and  Directive  97/7/EC  of  the  European 
Parliament and of the Council  

[Consumer Rights Directive] 

OJ L 304, 22.11.2011, p. 64–88 

Directive  2013/11/EU  of  the  European 
Parliament  and  of  the  Council  of  21 May 
2013  on  alternative  dispute  resolution  for 
amending 
consumer 
and 
Regulation 
Directive 
on 
consumer ADR) 

disputes 
(EC)  No 2006/2004 
(Directive 

2009/22/EC 

and 

[Alternative Dispute Resolution Directive] 

OJ L 165, 18.6.2013, p. 63–79 

(EU)  No 524/2013  of 

the 
Regulation 
European Parliament and of the Council of 
21 May  2013  on  online  dispute  resolution 
for  consumer  disputes  and  amending 
and 
Regulation 
Directive  2009/22/EC 
(Regulation  on 
consumer ODR) 

(EC)  No 2006/2004 

[Online Dispute Resolution Directive] 

OJ L 165, 18.6.2013, p. 1–12 

The  Consumer  Rights  Directive  contains 
rules for consumer contracts, this also applies 
to  contracts  between  consumers  and  postal 
service  providers.  However, 
in  case  of 
distance  sales  consumers  have  in  general  a 
contract with the trader and no contract with 
the  postal  service  provider.  The  obligations 
on  the  information  contained  in  the  contract 
(Article 5) are more detailed that the general 
information  requirements  under  Article  6  of 
the Directive. 

The  Directive  on  consumer  alternative 
dispute  resolution  contains  concrete  rules 
regarding the Alternative Dispute Resolution 
entities  and  Alternative  Dispute  Resolution 
procedures.  Member  States  have  to  make 
them available to postal consumers.  

The  Online  Dispute  Resolution  Regulation 
complements  the  Directive  on  consumer 
Alternative Dispute Resolution. It provides a 
European  Online  Dispute  Resolution 
independent, 
platform 
impartial,  transparent,  effective, fast and fair 
out-of-court  resolution  of  disputes  between 
consumers 
traders  online.  Postal 
consumers  have  the  right  to  use  it  for 
alternative dispute resolution procedures. 

facilitating 

and 

the 

information  on 

The Consumer Rights Directive requires 
more  detailed 
the 
contracts than the Directive.  It therefore 
provides for a more detailed application 
of  Article  6  of 
to 
consumers  while  remaining  coherent 
with  it.  No  discrepancies  were  found 
between the two Directives. 

the  Directive 

postal 

between 

The Directive only encourages Member 
States  to  develop  independent  out-of-
court  schemes  for  the  resolution  of 
service 
disputes 
the 
providers  and  users.  However, 
Alternative 
Resolution 
Dispute 
Directive  obliges  Member  States  to  set 
up alternative dispute resolution entities 
and procedures for consumers only, and 
not  for  the  other  categories  of  users  as 
defined in the Directive 

The  Directive  does  not  contain  a 
specific digital platform for out-of-court 
dispute  resolution  (see  point  above). 
The  Online  Dispute  Resolution 
is  specific  and  provides 
Regulation 
consumers  with  an  online  platform  for 
dispute  resolution.  No  discrepancies 
were found between the two Directives. 

164 

 
 
providers. 

interlink  between 

The 
the  Geoblocking 
Regulation  and  the  Directive  relates  to  the 
self-arrangement of pick-up of items (goods) 
that  have  been  bought  in  another  Member 
State.  This  can  be  done  by  using  postal 
service 
The  Geoblocking 
Regulation  does  not  impose  any  obligation 
on traders to deliver goods across borders. It 
is  up  to  the  trader  to  decide  whether  to 
deliver to another country or not.  However if 
a customer wishes to buy a good on a foreign 
website, the customer is entitled to order the 
product and collect it at the trader's premises 
or organise  delivery himself to his home(the 
customer  may  have  recourse  to  cross-border 
parcel delivery services).- 

The  Regulation  establishes  requirements  for 
access  for  persons  with  disabilities  and  the 
elderly. 
establishes 
requirements for ubiquitous access. 

Directive 

The 

The  Directive  provides  a  universal 
postal  service  that  contains  also  cross-
border  services;  users  may  rely  on  this 
in  order  to  receive  items  from  other 
Member States. Therefore, the Directive 
facilitates  the  relevant  provision  of  the 
Geoblocking  Regulation.  However,  it 
should  be  noted  that  the  Directive  does 
not  contain  an  obligation  for  postal 
service providers to provide for pick-up 
services  of  items  (goods)  bought  and 
provided in another Member State. 

The  Regulation  and  the  Directive  are 
coherent. 

Article 3 

Article 3 

and 

Regulation (EU) 2018/302 of the European 
Parliament  and  of  the  Council  of  28 
February  2018  on  addressing  unjustified 
forms 
geo-blocking 
of 
discrimination 
customers' 
based 
nationality,  place  of  residence  or  place  of 
establishment  within  the  internal  market 
and  amending  Regulations 
(EC)  No 
2006/2004  and 
(EU)  2017/2394  and 
Directive 2009/22/EC  

other 
on 

[Geoblocking Regulation] 

OJ L 60I , 2.3.2018, p. 1–15 

REGULATION  (EU)  No  1303/2013  OF 
THE  EUROPEAN  PARLIAMENT  AND 
OF THE COUNCIL of 17 December 2013 
laying  down  common  provisions  on  the 
European Regional Development Fund, the 
European Social Fund, the Cohesion Fund, 
the  European  Agricultural  Fund  for  Rural 
Development  and  the  European  Maritime 
laying  down 
and  Fisheries  Fund  and 
general  provisions  on 
the  European 
Regional Development Fund, the European 
Social  Fund,  the  Cohesion  Fund  and  the 
European Maritime and Fisheries Fund and 
repealing  Council  Regulation  (EC)  No 
1083/2006 

[Regulation on Regional Development] 

Regulation  (EC)  No  561/2006  of 

the  Article 3 

The  Regulation  contains  certain  exemptions 
from  drive  and  resting  times  for  universal 

The  universal  service  obligation  of  the 
is  eased  by  exempting 
Directive 

165 

 
 
 
and 

amending 

European Parliament and of the Council of 
15  March  2006  on  the  harmonisation  of 
certain  social  legislation  relating  to  road 
transport 
Council 
Regulations  (EEC)  No  3821/85  and  (EC) 
No  2135/98 
repealing  Council 
Regulation (EEC) No 3820/85 (OJ 2006 L 
102, p. 1), as amended by Regulation (EU) 
No  165/2014  of  the  European  Parliament 
and of the Council of 4 February 2014 (OJ 
2014  L  60,  p.  1) 
(‘Regulation  No 
561/2006’). 

and 

service  providers  in  order  to  support  the 
provision of universal services. 

universal  services  from  resting  times. 
The  Court  (Joined  Cases  C  203/18  and 
C  374/18)  has  provided  a  judgement 
limiting 
that 
exclusively  provide  universal  services, 
and  avoiding 
thus  a  special  right. 
Consequently,  the  Directive  and  the 
Regulation are fully consistent. 

to  vehicles 

the  use 

[Road Transport Regulation] 

166 

 
 
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169