PostEurop’s comments related to the ERGP Report on access to the infrastructure for the delivery of parcels (PL I (24) 11)

Ms Merete Clausen
Director for Investment, European
Commission / DG GROW
Avenue des Nerviens 105
BE-1040 Etterbeek
Brussels, 28 November 2024
Ref: EFR,BS/024/26/mm

PostEurop’s comments related to the ERGP Report on access to the infrastructure for the delivery of parcels (PL I (24) 11).

Dear Ms Clausen,

We are writing to you regarding the ERGP Report on access to the infrastructure for the delivery of parcels (PL I (24) 11), published on 25 June 2024. The “evidence” collected in the report is meant to feed into up-coming works of the ERGP regarding a future EU postal regulatory framework. We note that the report does not draw direct conclusions but leaves it to “further analysis … [which] might be appropriate to verify possible amendments” to the Postal Service Directive and/or the cross-border parcel Regulation, if additional powers are needed for the national regulatory authorities on out-of-home (OOH) parcel delivery services. Looked at more closely, however, the presented analysis as well as the line of argument the reports pursues, seem to be biased in favour of the need for more regulatory powers and sector specific regulation with respect to both competition and consumer protection in the parcel delivery sector. In our view, the argument builds upon an artificial view on the market separating OOH services from parcel delivery and completely skips over the question why the application of general competition law or general consumer law would not suffice to address potential problems in case they should materialize. In the following, we would like to share with you our respective comments and observations in more detail.