voluntary associations, and revenue authorities. These five regulators are the most common and the leading ones among several agencies who commit themselves in regulating freight forwarding business. Where there is no recognition of freight forwarders, many transport and customs related agencies are involved in the industry without a clear leading institution. With the absence of a leading institution or the lack of laws for freight forwarding business, self-regulators or voluntary associations sometime take a lead to unify and regulate the industry. Whether governments or voluntary associations or not, a regulator ideally should be politically strong entity to coordinate agencies and the entity with good technical capabilities and adequate human and financial resources.

# _Ministry of Transport as a regulator_

Ministries of transport (or transport related agencies) are the most common regulator for the freight forwarding business but with different recognition to freight forwarding. Some countries, particularly high logistics service performers in the Logistics Performance Index 2014, have established the clear definition of freight forwarding, and ministries of transport established unique regulations for their business (i.e. Netherlands, USA, Japan). On the other hand, ministries of transport consider that freight forwarding is the extended service of trucking business in the countries where ministries do not recognize the freight forwarding as unique business. Therefore, there are neither often clear regulations oriented to freight forwarding, nor unique licensing system in place for freight forwarders. Trucking service regulations are more for domestic operators; as a results, they often do not mention foreign operators, who are rather considered as foreign investors. Ministries of transport in emerging countries such as Brazil and Thailand employ the term multimodal transporter for the freight forwarding concept with implication of additional services provided by trucking companies.

Ministries of transport often have a double licensing system at national and sub-national levels. For instance in Sudan, trucking companies need to register first at a state level for a business license. In addition to this, they need to complete the registration at the national level with the ministry of transport for vehicle registration and inspection. The ministry of transport, who develops a strategic plan for the transport policies, considers itself as a regulator and supervisor of the transport businesses while freight forwarders on the ground consider a state traffic authority as a regulator for their business. The layer of licensing regulations sometimes causes unclear understanding on an actual regulator and may distort the roles of regulators in place. Besides, licensing procedure at national and regional levels can sometime be simply duplication. The logistics assessment study on Greece (World Bank, 2013)<sup>17</sup> points out that some municipalities issue truckers licenses; consequently, operators have to follow identical and parallel procedures to obtain the licenses: one from a local authority and the other from a department of transport at the ministry.

An example on clear division of tasks is found in Japan. In principle, freight forwarding business permits should be issued by the minister of transport, and the same ministry is responsible for supervising their business licenses and orders to the registered operators on remedies for freight / fees. Once operators become operational, a director at prefecture’s level is responsible for the small matters, such as supervising

> 17 Greek Logistics – Unlocking Growth Potential through Regulatory Reform and Complementary Measures

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