ERGP REPORT 2014 ON THE QUALITY OF SERVICE AND END...

ERGP (14) 24 – report on QoS and end-user satisfaction

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ERGP REPORT 2014 ON THE QUALITY OF

SERVICE AND END-USER SATISFACTION


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Content

Page

0. Executive summary 10

1. Background 14

2. Objectives 15

3. Methodology 16

4. Current situation regarding quality of service and end-user satisfaction 17

4.1. Measurement of quality of service concerning routing times and the

regularity and reliability of services 17

4.1.1. Measurement of quality of service for single piece priority mail in

2013 23

4.1.2. Measurement of loss or substantial delay in 2013 26

4.1.3. Measurement of quality of service for single piece non-priority mail in

2013 27

4.1.4. Measurement of quality of service for bulk mail in 2013 29

4.1.5. Measurement of quality of service for Newspapers/periodicals in 2013 30

4.1.6. Measurement of quality of service for Parcels in 2013 31

4.1.7. Measurement of quality of service for registered mail in 2013 33

4.1.8. Force majeure 35

4.2. Collection and delivery 36

4.2.1. Requirements on the frequency of collection and delivery relating to

the universal service 36

4.2.1.1. Collection 36

4.2.1.2. Delivery 38

4.2.2 Exceptions on collection and delivery because of circumstances or

geographical conditions deemed exceptional 40

4.3. Access points 43

4.3.1. Collection letterboxes 43

4.3.2. Points of contact 46

4.4. Measurement of consumer satisfaction 54

4.5. Surveys regarding customers’ needs 58


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5. Current situation on the assessment of complaint handling procedures

and consumer protection 61

5.1 Scope and competence of NRAs regarding complaint handling 61

5.1.1. Scope 61

5.1.2. Competence 62

5.2 Information provision and access to complaint handling and dispute

resolution 65

5.3 Implementation of Standard EN 14012: 2008 71

5.4 Compensation schemes for individual customers 72

5.5 Collection of data on complaints 78

6. Conclusions on the current practices of the NRAs regarding the quality

of service regulation, complaint handling procedures and consumer

protection

86


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Tables Page

1. Answers of 32 European countries concerning regulatory objective 18

2. Countries which have regulatory objectives for services provided by non-USP/non-

Incumbents 19

3. Answers of 32 European counties concerning measurements of transit time – which

kind of services are measured 20

4. Cross-border information per country 21

5. Targets and results of single piece priority mail (2013) 23

6. Methodology for each country based on the quality of service for single piece priority

mail in 2013 26

7. Regulatory objective for loss or substantial delay regarding single piece priority mail 26

8. Targets and results of single piece non-priority mail 27

9. Methodology for each country based on the quality of service for single piece non-

priority mail in 2013 28

10. Targets and results of bulk mail (question 1.1.2) 29

11. Methodology for each country, based on the quality of service for bulk mail in 2013 30

12. Targets and results of parcels (questions 1.1.2) 31

13. Methodology for each country, based on the quality of service for parcels in 2013 32

14. Targets and results of registered mail 33

15. Methodology for each country, based on the quality of service for registered mail in

2013 34

16. Number of accepted force majeure days/incidents and reasons in 2013 35

17. Internet links with reference to the list with the exceptional circumstances in the

Member States 42

18. Requirements/standards to ensure an adequate number of collection letterboxes 43

19. Collection time displayed on collection letterboxes 45

20. Requirements/standards to ensure an adequate number of points of contact/postal

establishments 46


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21. Entity entitled to check compliance with the requirements on an adequate number of

postal establishments 48

22. Prevention of the closure of postal establishments 49

23. Points of contact per country (distribution in %) 50

24. NRA uses/monitors measurement of consumer satisfaction 54

25. Links to research carried out to measure customer satisfaction 54

26. Surveys regarding customer needs 58

27. Links to research carried out to measure customer needs 58

28. NRA responsible for complaints

29. Procedures in place to resolve the issue complained

63

64

30. Postal service providers obliged to publish information about procedures to complain,

redress schemes and means of dispute resolution 65

31. Postal service providers covered by the obligation to publish information about

procedures to complain, redress schemes and means of dispute resolution 66

32. Regulation of complaint handling procedures 67

33. Scope of the regulation on complaint handling procedures 68

34. Alternative (or out-of-court) dispute resolution (ADR) 69

35. Cover of existing compensation schemes 74

36. Compensation scheme 74

37. Data on the number of complaints 79

38. Complaints received by USP about universal service, 2012-2013 (per country) 81

39. Complaints received by USP about universal service by category, 2012-2013 82

40. Complaints received by NRAs about postal services, 2012-2013 (per country) 83

41. Complaints received by the USP about cross-border services, 2012-2013 (per country) 85


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Figures Page

1. Targets and results (D+1) in 32 European countries in 2013 25

2. Results (D+1) of 2012 and 2013 in 32 European countries 25

3. Number of collections/week relating to the universal service 37

4. Number of deliveries/week relating to the universal service 39

5. Reasons for exceptions regarding collection and delivery 41

6. Requirements/standards to ensure an adequate number of collection letterboxes 43

7. Where are the requirements/standards to ensure an adequate number of collection

letterboxes defined? 44

8. Collection time marked on collection letterboxes 45

9. Percentage change in the number of collection letterboxes per countries from 2008 till

2013 45

10. Requirements/standards to ensure an adequate number of points of contact/postal

establishments 47

11. Entity entitled to check compliance with the requirements on adequate number of

postal establishments 48

12. Is that entity empowered to prevent the closure of postal establishments? 49

13. Percentage by type of points of contact in 2013 51

14. Evolution of the number of points of contact by type in the in the period 2008 – 2013 52

15. Location of post agencies managed by third parties 53

16. Implementation of standard EN 14012: 2008 71

17. Mandatory compensation schemes for individual customers 72

18. Existing compensation schemes for individual customers by type of service failure 73


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19. Mechanisms in place to make customers aware of compensation schemes 77

20. Collection of data on complaints by NRAs 78

21. Complaints received by USP about universal service, 2012-2013 (per country) 80

22. Complaints received by USP about universal service by category, 2012-2013 81

23. Complaints received by NRAs on postal services, 2012-2013 (per country) 83

24. Collection of data on complaints about cross-border services by NRAs 84

25. Data on complaints about cross-border services received by NRAs 84

26. Complaints received by the USP about cross-border services, 2012-2013 (per country) 85


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Terms and abbreviations

CEN – Comité Européen de Normalisation / European Committee for Standardisation

IPC – International Post Corporation

NRA – National Regulatory Authority

US – Universal Service

USP – Universal Service Provider

USO – Universal Service Obligation


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Country codes

AT – Austria BE – Belgium BG – Bulgaria CH – Switzerland

CZ – Czech Republic CY – Cyprus DE – Germany DK – Denmark

EE – Estonia EL – Greece ES – Spain FI – Finland

FR – France FYROM – Former

Yugoslav Republic of

Macedonia1

HR – Croatia

HU – Hungary

IE – Ireland IS – Iceland IT – Italy LT – Lithuania

LU – Luxembourg LV – Latvia MT – Malta NL – the Netherlands

NO – Norway PL – Poland PT – Portugal RO – Romania

RS - Serbia SE – Sweden SI – Slovenia SK – Slovakia

UK – United Kingdom

1 FY is used in tables and figures for the Former Yugoslav Republic of Macedonia.


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0. Executive summary

- Background

Chapter 6 of Postal Directive 97/67/EC, as amended by Directives 2002/39 and 2008/6 (afterwards

referred to as Directive in this report), lays down that the national regulatory authorities (NRAs) shall

ensure compliance with the obligations arising from the Directive, in particular through the follow-up

of quality of service.

The Directive emphasises that the postal reform has brought significant positive developments in the

postal sector, with increased quality of service and focus on meeting consumer needs. Increased

competition allows consumers to take advantage of a wider choice of products and services offered by

postal service providers and allows these products and services to be continually improved in order to

meet consumer demand.

Quality-of-service standards are set and published in relation to the universal service in order to

guarantee a postal service of good quality.

The European Regulators Group for Postal Services (ERGP) will continuously monitor the effects of

postal liberalisation through appropriate indicators and their development over time, as well as through

the assessment of end-user complaint procedures to ensure that transparent, simple and inexpensive

complaint procedures are available to users – particularly in cases involving loss, theft, damage or

non-compliance with service quality standards – and that consumers are protected according to the

provisions of the Directive.

- Objective

The goal of this report is to provide the necessary data to monitor and follow up the quality of service,

the complaint handling and the consumer protection within the context of the regulatory measures

taken in those fields.

- Methodology

32 ERGP members have provided feedback: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech

Republic, Denmark, Estonia, Finland, France, Former Yugoslav Republic of Macedonia, Germany,

Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, The Netherlands, Norway,

Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland and the United

Kingdom.


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- Current situation regarding service quality and end-user satisfaction

The quality of service and the end-user satisfaction have been analysed with a view to the following 5

dimensions:

1° Measurement of the quality of service concerning transit time

2° Collection and delivery

3° Access points

4° Measurement of consumer satisfaction

5° Surveys regarding customers’ needs

1° Measurement of the quality of service concerning routing times and the regularity and

reliability of services

In 32 ERGP members, there are always regulatory objectives for routing times (100% of the

respondents). For queuing time in post offices, there is a regulatory objective in 3 countries (9%). The

regulatory objectives deal with universal services and four countries have established regulatory

objectives for universal services provided by non-USP/non-Incumbent.

In 2013, targets for measuring the transit time of end-to-end priority mail in the domestic postal

market were established in 30 countries. There is a wide range of targets across the ERGP countries

reflecting different national considerations and, as such, comparisons between ERGP countries cannot

be drawn.

The average value of results (D+1) in countries who answered the questionnaire was 87.6% in 2013

(27 countries provided information on the results obtained), which is lower than the previous year

(88.29%). In 21 countries2 the USP achieved the targets, while in 5 countries

3 the USP did not.

In 19 countries, we have quality of service targets and mostly also results for parcels, in 17 countries

we have also quality of service targets and mostly also results for non-priority mail, and in 6 countries

we have targets and mostly also results for bulk mail.

2° Collection and delivery

Regarding the frequency of collection and delivery to be made by the USP, the responses received

from Member States revealed that the Directive has been implemented by all with at least one

collection/delivery for 5 days a week (in some countries the obligations have extended to 6 days per

week).

Exceptions have been granted in many countries regarding frequency of collection and mostly

delivery. Responses revealed that exceptions are mainly related to dispersed population, mountainous

character and islands.

2 AT, BE, CH, CY, CZ, FR, EL, HR, HU, LU, LT, MT, NO, PT, SE, SK, SI, UK 3 BG, DK, EE, PL, RO


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3° Access points

The access point issue is very sensitive and this is reflected by the fact that a vast majority of the

countries consider it necessary to have requirements or standards to ensure an adequate number of

collection letterboxes and points of contact/postal establishments.

There are different types of points of contact at the European level. The most common is the

permanent post office managed by the USP with a full range of services and the permanent post

agency managed by a 3rd party.

4° Measurement of consumer satisfaction

According to the responses, 14 out of 32 NRAs (45%) use or monitor indicators of consumer

satisfaction in their countries, while 18 (55%) do not.

The results from the 2014 questionnaire show that, among the NRAs that use/monitor indicators of

consumer satisfaction, market surveys are used as the main method to identify levels of consumer

satisfaction and this ranges in frequency from adhoc to annual to twice yearly surveys. The number of

satisfaction indicators varies between NRAs depending on the nature of the research being undertaken

and its objectives, the size of the postal market and their capability to conduct research given

individual circumstances and the regulatory framework.

5° Surveys regarding customers´ needs

In terms of surveys regarding consumer needs and market, 14 NRAs (45%) answered that they

conduct such surveys and 17 NRAs (55%) do not. Surveys are mostly carried out annually or on an ad

hoc basis to serve regulatory needs. Usually, the surveys are conducted by an independent body.

Different methodologies are used, including telephone interviews/computer-assisted telephone

interviews (CATIs), standardised questionnaires and face to face interviews.

- Current situation regarding complaint handling and consumer protection

The report examines five key issues in the field of complaint handling and consumer protection,

namely:

a) Scope and competence of NRAs regarding complaint handling

b) Information provision and access to complaint handling and dispute resolution

c) Implementation of Standard EN 14012:2008

d) Compensation schemes for individual customers

e) Collection of data on complaints

1° Scope and competence of NRAs regarding complaint handling

This part is dealing with the legal framework on complaint handling. First of all, it illustrates in some

more detail the respective legal basis as set within the Postal Directives. Secondly, it evaluates the

scope and the competence of the NRAs in handling complaints on postal services, and it looks at the

other organisations a customer4 can address himself to in case of a complaint.

4 “Customer” has a broader meaning so that it can include customer or user

http://www.dict.cc/englisch-deutsch/standardized.html

http://www.dict.cc/englisch-deutsch/questionnaire.html


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According to the answers to the 2014 questionnaire, in 25 (81%) out of the 31 responding countries,

the NRA is generally responsible for dealing with user complaints. In three of these countries (10%),

the NRA only handles complaints with regard to the Universal Service, while in the vast majority

(71%) all postal service issues can be addressed. 5 (16%) NRAs stated that they are not obliged to

handle user complaints.

2° Information provision and access to complaint handling and dispute resolution

This part analyses the information available for users on complaint handling procedures, redress

schemes and means of dispute resolution.

There have not been any major changes in the number of countries obliging the postal service

providers to publish information. In most countries, universal postal service providers are generally

obliged to publish information about complaint handling procedures and redress schemes, which was

mentioned by 27 (85%) and 25 (78%) NRAs respectively. In fewer countries 10 (31%), there is an

obligation covering information on means of dispute resolution.

3° Implementation of Standard EN 14012:2008

This part presents data on the situation regarding the implementation of the CEN Standard EN

14012:2008 (Postal Services - Quality of Service - Complaints handling principles) by postal service

providers.

Almost half the respondent NRAs (45%) indicated that the USP has implemented the CEN standard.

However, concerning other postal service providers active in the universal service area, the standard is

only implemented in 2 (7%) countries and is not implemented in any country for other postal service

providers. The majority of NRAs (55%) indicated that the standard has not been implemented by any

service provider.

4° Compensation schemes for individual customers

In this part, the scope of existing compensation schemes is analysed. In most countries (17 out of 31),

an obligation for a specific compensation scheme exists and covers the USP in almost all of them; this

also extends to other postal service providers. These results show that no significant change occurred

in this field when comparing with the data collected in 2013.

5° Collection of data on complaints

This part looks at the data that NRAs collect and have available on complaints about postal services in

general and about cross-border services in particular.

Almost all respondent NRAs collect data on complaints received by the USP regarding universal

services (28 out of 32). Out of these, 21 indicated to collect data by category and 16 by service. Fewer

NRAs collect data on complaints received by the USP about non-universal services (16 out of 32).


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1. Background

Chapter 6 of Postal Directive 97/67/EC, as amended by Directives 2002/39 and 2008/6 (afterwards

referred to as Directive in this report), lays down that the national regulatory authorities (NRAs) shall

ensure compliance with the obligations arising from the Directive, in particular through the follow-up

of quality of service.

The Directive emphasises that the postal reform has brought significant positive developments in the

postal sector, with increased quality of service and focus on meeting consumer needs. Increased

competition allows consumers to take advantage of a wider choice of products and services offered by

postal service providers and allows these products and services to be continually improved in order to

meet consumer demand.

Quality-of-service standards are established and published in relation to the universal service in order

to guarantee a postal service of good quality. Quality standards have to focus, in particular, on routing

times and on the regularity and reliability of services.

The European Commission established, by the decision of 10 August 20105, the European Regulators

Group for Postal Services (ERGP). The ERGP's tasks shall be:

a) to advise and assist the Commission in consolidating the internal market for postal services;

b) to advise and assist the Commission on any matter related to postal services within its

competence;

c) to advise and assist the Commission as to the development of the internal market for postal

services and as to the consistent application in all Member States of the regulatory framework

for postal services;

d) to consult, in agreement with the Commission, extensively and at an early stage of its expert

work with market participants, consumers and end-users in an open and transparent manner.

The ERGP Plenary approved the ERGP work programme for 2014. This programme includes the

elaboration of a report on QoS indicators, including cross-border QoS results and complaints.

The ERGP will continuously monitor the effects of postal liberalisation through appropriate indicators

such as benchmarking the quality of postal services and their development over time, including end-

user complaint procedures to ensure that consumers are protected according to the provisions of the

Directive.

The goal is to collect the necessary data to monitor quality of service, linked back to regulatory

measures taken in that field. Particular attention will also be given to complaint handling procedures

and analysis of trends.

5 OJ C 217, 11.8.2010, p. 7.


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2. Objectives

The report examines five key issues in the field of quality of service and end-user satisfaction, namely:

a) measurement of quality of service concerning transit time

b) collection and delivery

c) access points

d) measurement of consumer satisfaction

e) surveys regarding customers’ needs

The report also examines five key issues in the field of complaint handling and consumer protection,

namely:

a) scope and competence of NRAs on complaint handling

b) information provision and access to complaint handling and dispute resolution

c) implementation of standard EN 14012

d) compensation schemes for individual customers

e) collection of data on complaints

The goals are to collect the necessary data to monitor quality of service, end-user satisfaction,

complaint handling and consumer protection within the context of the regulatory measures taken in

those fields.

The document aims at:

a) reporting on the core quality of service indicators to monitor market development, evaluating

the results of regulatory measures and the consumer protection measures taken especially in

the field of complaint handling;

b) reporting on the core indicators to monitor complaint handling and consumer protection.

The report looks at the current and past situation (starting point) of data collection and published

indicators regarding quality of service.

Then, it analyses this data and identifies market trends regarding quality of service, e.g. results of mail

transit time, quality of delivery, customer satisfaction and development of the postal network. The

objective is to update this report on an annual basis.

This ERGP report describes the current practices of NRAs concerning quality of service, complaint

handling and consumer protection as well as the current scope, competencies and powers of NRAs.

Also, the provision of information on complaint handling procedures and implementation of the

complaint handling standard EN 14012 is analysed in detail. Moreover, the document makes reference

to compensation schemes in place and collects data regarding complaints.


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3. Methodology

To obtain information regarding quality of service and end-user satisfaction in the broad sense of the

term, including complaint handling and consumer protection, a questionnaire has been issued to

collect information on the current situation.

This report is based on the feedback provided by 32 ERGP members: Austria, Belgium, Bulgaria,

Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Former Yugoslav Republic of

Macedonia, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the

Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden,

Switzerland and the United Kingdom.

The analysis is primarily based on the answers provided to the questionnaires (June 2014), which in

general, reflects the legislation and practice in place at the end of 2013.


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4. Current situation regarding quality of service and end-user satisfaction

The quality of service and the end-user satisfaction have been analysed with a view to the following 5

dimensions:

1° measurement of the quality of service concerning transit time

2° collection and delivery

3° access points

4° measurement of consumer satisfaction

5° surveys regarding customer needs

Of course, other elements could also be used to monitor quality of service and end-user satisfaction,

but in this report the scope has been limited to the dimensions above.

We have also referred to the technical standards developed by CEN (European Committee for

Standardisation) in the field of quality of service, as laid down in Article 20 of the Directive.

4.1 Measurement of quality of service concerning routing times and the regularity and

reliability of services

The legal ground for measuring quality of service was laid down in Directive 97/67/EC (Chapters 6 &

7 and Annex 2). Concerning quality, Article 16 of the Directive 97/67/EC states:

“Member States shall ensure that quality-of-service standards are set and published in relation to

universal service in order to guarantee a postal service of good quality. Quality standards shall

focus, in particular, on routing times and on the regularity and reliability of services.

….

Independent performance monitoring shall be carried out at least once a year by external bodies

having no links with the universal service providers under standardized conditions to be specified in

accordance with the procedure laid down in Article 21 and shall be the subject of reports published

at least once a year.”

Based on the ERGP questionnaire, the table 1 gives details regarding the definition of regulatory

objective for routing time (transit time) and queuing time in post offices.


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Table 1 – Answers of 32 European countries concerning regulatory objective

Routing time

(transit time) Queuing time

in post offices

Austria Yes No

Belgium Yes Yes6

Bulgaria Yes Yes

Croatia Yes No

Cyprus Yes No

Czech Republic Yes No

Denmark Yes No

Estonia Yes No

Finland Yes No

Former Yugoslav Republic of Macedonia Yes No

France Yes No

Germany Yes No

Greece Yes No

Hungary Yes No

Ireland Yes No

Italy Yes No

Latvia Yes No

Lithuania Yes No

Luxembourg Yes No

Malta Yes No

Netherlands Yes No

Norway Yes No

Poland Yes No

Portugal Yes Yes

Romania Yes No

Serbia Yes No

Slovakia Yes No

Slovenia Yes No

Spain Yes Yes7

Sweden Yes No

Switzerland Yes No

United Kingdom Yes No

Total 32 32 4

6 Regulatory objective based on the management contract between bpost and the State. 7 In Spain, measuring the queuing time in post offices is a regulatory commitment although no target is met.


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In 32 ERGP members, there are always regulatory objectives which deal with universal services for

routing times (100% of the respondents). For loss or substantial delay, there is a regulatory objective

in 11 countries (34%) and, for queuing time in post offices, there is a regulatory objective in 4

countries (13%).

In 4 countries (16% - AT, DE8, LU and RO

9) regulatory objectives are established for services

provided by non-USP/non-Incumbents, as shown on table 2.

Even without regulatory objectives set out by the NRA or regulatory framework, the non-

USP/non-incumbents measured and published the quality levels of services effectively offered

according to parameters or common rules set by the NRA. This is the case in 3 of the ERGP countries,

namely DK, RS and UK. For example, in DK, the non-USP/non-incumbents only have to publish the

results and send a statement to the NRA while, in the UK, the non-USP/non-incumbents have to

submit the consumer complaint numbers via Consumer Protection regulatory conditions.

Table 2 – Countries which have regulatory objectives for services provided by non-USP/non-Incumbents

Austria 90% for D+2 delivery of letter items and 85% for D+3

delivery of parcel items

Germany

80% for D+1 and 95% for D+2 delivery of letter items

(including registered mail) and 80% for D+2 delivery

regarding parcel items

Luxembourg 85% and 99% for D+2 and D+5 delivery, respectively,

of items within the scope of the universal service

Romania 80% for D+3 and 95% for D+5

8 German regulatory law does not differentiate the incumbent’s services and those of its competitors, because the US

provided not only the incumbent but also the entirety of postal service providers. 9 For the authorization regime in RO.


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Table 3 below indicates which countries measure transit time and for which kind of services, namely:

- Priority mail

- Non-priority mail

- Bulk mail

- Newspapers and periodicals

- Parcels

- Registered items

Table 3 – Answers of 32 European countries concerning measurements of transit time – which kind of services are

measured

Priority mail Non-priority

mail Bulk mail

Newspapers /

periodicals Parcels Registered items

AT √ - - √ -

BE √ √ - - √ √

BG √ √ - - √ -

CH √ √ - - √ -

CY √ - - - - -

CZ √ - - - - -

DE √ - - - - -

DK √ √ - √ √ -

EE √ - - - - -

EL √ - - - - -

ES √ - - √ -

FI √ √ - - - -

FR √ √ √ √ √ √

FY √ √ - - - -

HR √ √ - - - -

HU √ √ √ - √ √

IE √ - - - - -

IT √ - √ - √ √

LT √ - - - - -

LU √ - √ - - √

LV √ √ - - - -

MT √ - √ - √ √

NL √ - - - - -

NO √ √ - - - -

PL √ √ - - √ -

PT √ √ - √ √ -

RO √ - - - - -

RS √ - - - - -

SE √ - - - - -

SI √ - - - √ √

SK √ √ - - √ √

UK √ √ - - - -

Total 32 32 15 5 3 14 8

Note: AT and ES did not differentiate between priority and non-priority mail. Non-priority mail is not applicable in CY, CZ,

DE, EE, IE, IT, LU, MT, NL. SI doesn’t differentiate on priority and non-priority mail.; the measurement is done for items of

correspondence which includes, if compared to the definition of priority mail/non-priority mail, a broader range of services.


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Priority mail is measured in all ERGP members, considering that AT, ES and SI did not differentiate

between priority and non-priority mail. Parcels are measured in 14 of the 32 (44%) ERGP members,

registered items in 8 of the 32 (25%) ERGP members, bulk mail in 5 of the 32 (16%) ERGP members

and newspapers / periodicals in 3 of the 32 (10%) ERGP members.

In 14 ERGP members, the non-priority mail is effectively measured, given that the following countries

do not have non-priority mail: CY, CZ, DE, EE, IE, IT, LU, MT, NL, which indicates that, 14 of 23

(61%) of the ERGP members measured these services.

Table 14 below gives details about the regulatory objective regarding cross-border services on the

following issue:

- Regulatory objectives related to cross-border services

- Regarding cross-border flows

- Source of such information

Table 4 - Cross-border Information per Country

Regulatory

objectives regarding

cross-border

services

Results regarding

cross-border flows?

Source

Austria Yes Yes USP

Belgium Yes Yes IPC

Bulgaria Yes Yes IPC10

Croatia Yes Yes USP

Cyprus Yes Yes IPC

Czech Republic No Yes USP

Denmark Yes No /

Estonia No Yes USP

Finland Yes No /

Former Yugoslav Republic of

Macedonia Yes Yes USP

11

France Yes Yes IPC

Germany Yes Other12

IPC

Greece Yes Yes IPC

Hungary Yes Yes USP

Ireland Yes Yes IPC

Italy Yes Yes IPC13

10 The information was provided to the CRC by the USP, but the original source was the IPC. 11 The Postal Agency has the total flow of cross-border services of the USP, but does not have the specific information, i.e.

concerning the results, the methodology used and the measurement. 12 Results regarding cross-border flows were delivered by the incumbent until 2012. New arrangements are in progress. 13 The data are generated by IPC, but are communicated to the regulatory authority by the USP.


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Latvia No Yes IPC

Lithuania Yes Yes IPC

Luxembourg Yes Yes IPC

Malta Yes Yes IPC

Netherlands No No /

Norway Yes Yes IPC

Poland No No /

Portugal Yes Yes USP14

Romania Yes Yes IPC15

Serbia Yes Yes USP

Slovakia No No /

Slovenia Yes Yes USP16

Spain Yes Yes IPC

Sweden No No /

Switzerland Yes Yes USP17

United Kingdom Yes Yes USP

Total 25 25 n.a.

25 out of the 32 (78%) ERGP countries have regulatory objectives for cross-border services. In 3

ERGP countries, there are regulatory objectives but the NRA does not obtain the results. But in one of

them, it is temporary, since they are working to solve the issue.

The information source is the USP or IPC. In 10 countries, it is the USP; in 15 countries, it is IPC.

Of all the 32 countries, only Czech Republic, Estonia, Latvia, the Netherlands, Poland, Slovakia and

Sweden answered that there are no regulatory objectives related to cross-border services.

The remaining countries established objectives regarding D+3 and D+5 delivery, except for Malta

(94%) and Belgium (90%), which established additional targets for the incoming cross-border mail

regarding D+1 delivery.

Concerning D+3 delivery, all countries set the target value at 85%, except for France (90%), Portugal

(88%) and Austria (90% for cross-border extra-community priority letter mail items and postal parcel

items).

Czech Republic, Denmark, Estonia, Finland, France, Latvia, the Netherlands, Poland, Slovakia,

Sweden, Switzerland and United Kingdom did not define a target value for cross-border extra-

community priority letter mail items and postal parcel items. Ireland and Serbia have regulatory

objectives related to cross-border services, but did not indicate the target values for 2013.

14 Based on info provided by IPC. 15

The data are generated by IPC, but are communicated to the regulatory authority by the USP 16

Based on info provided by IPC. 17 Idem


23

Concerning D+5 delivery, the countries set the target value at 97%, except Czech Republic, Denmark,

Estonia, Finland, France, Latvia, the Netherlands, Poland, Slovakia, Sweden, Switzerland and the

United Kingdom, which do not define a target value for cross-border extra-community priority letter

mail items and postal parcel items. Ireland and Serbia have regulatory objectives related to cross-

border services, but did not indicate the target values for 2013.

4.1.1. Measurement of quality of service for single piece priority mail in 2013

In 2013, targets for measuring the transit time of end-to-end priority mail in the domestic postal

market were established in 30 countries.

There is a wide range of targets across the ERGP countries reflecting different national considerations

and, as such, comparisons between ERGP countries cannot be drawn.

Table 5 – Targets and results of single piece priority mail (2013)

D+1 D+2 D+3 D+4 D+5

Target Results Target Results Target Results Target Results Target Results

AT 95,00 95,50 98,00 99,50 / 99,90 100,00 100,00 / /

BE 90,00 95,70 97,00 99,24 / / / / / /

BG 80,00 50,70 95,00 75,60 / / / / / /

CH 97,00 97,60 / / / / / / / /

CY 90,00 90,00 n.a. n.a. 97,00 97,00 / n.a. / /

CZ 92,00 93,09 / / / / / / / /

DE 80,00 91,2018

95,00 / / / / / / /

DK 93,00 93,20 / / / / / / / /

EE 90,00 88,70 / / / / / / / /

EL 87,00 90,50 / / 98,00 99,70 / / / /

ES / / / / 93,00 96,56 / / 99,00 99,16

FI 80,00 90,20 / / / / / / / /

FR 85,0019

87,40 / / 99,00 99,30 / / / /

FY / / / / / / / / / /

HR 85,00 85,20 95,00 95,80 / / / / / /

HU 90,00 92,80 / / 97,00 99,60 / / / /

IE 94,00 /20

/ / 99,50 / / / / /

IT 89,00 90,40 / / 98,00 99,20 / / / /

LT 85,00 90,03 / / 97,00 99,56 / / / /

LU n/a 97,06 85,00 99,63 99,00 n.a. n.a. n.a. / /

18 Only the transit times of the incumbent were measured. The target also applies for other service providers. 19 The target must be greater than or equal to 85. 20 Results are not currently available.


24

D+1 D+2 D+3 D+4 D+5


LV 90,00 90,53 / / / / / / / /

MT 94,00 95,16 98,00 98,71 99,00 99,03 / / / /

NL 95,00 95,80 / / / / / / / /

NO 85.00 86.00 / / 97.00 99.40 / / / /

PL 82.00 66.70 90.00 90.80 94.00 96.70 / / / /

PT21

94.50 94.90 87.00 93.30 / / / / / /

RO 85.00 34.00 97.00 71.00 / / / / / /

RS / / / / / / / / / /

SE 85.00 94.90 / / 97.00 99.90 / / / /

SI22

95.00 96.20 99,50 99.60 100.00 99.90 / / / /

SK 93.00 94.65 / / / / / / / /

UK 93.00 93.2 / / / / / / / /

Total 28 27 11 10 14 13 1 1 1 1

Average 89.2 87.6 94.2 92,3 97.5 98.9 100 100 99 99.2

The average value of results (D+1) in countries who answered the questionnaire was 87.61% in 2013

(27 countries provided information on the results obtained), which is lower than the previous year

(88.29%).

Table 5 above shows the countries that established targets for D+1, D+2, D+3 and other higher

delivery, as well as their results. Based on this table, we can notice the following points:

- 11 countries23

established targets for D+2 delivery. Luxembourg (85%), Poland (90%) and

Portugal (87%)24

have the lowest targets, while Malta (98%) and Slovenia (99.5%) have the

highest targets. Bulgaria (difference of 19.4% compared to the target) and Romania

(difference of 26% compared to the target) failed to achieve their targets;

- 14 countries25

established targets for D+3 delivery. France, (99%), Ireland (99.5%),

Luxembourg (99%), Malta (99%) and Slovenia (100%) have the highest targets. Poland (94%)

and Spain (93%) presented relatively low targets compared to other countries, although results

in Spain are above 96%;

- Austria (100%) and Spain (99%) established targets for D+4 and D+5 respectively, and both

have achieved the target.

21 D+1 applies to letters sent between any locations on Portugal’s Mainland and D+2 applies to letters sent from, between or

to any location of the Autonomous Regions of Azores and Madeira. 22 SI doesn’t differentiate on priority and non-priority mail. SI measurement for D+1, D+2 and D+3 is done for items of

correspondence which includes, if compared to the definition of single piece priority mail, a broader range of services. 23 BE, BG, DE, HR, LU, MT, PL, PT, RO, SI. 24 Applies to letters sent from, between or to any location of the Autonomous Regions of Azores and Madeira. 25 CY, EL, ES, FR, HU, IE, IT, LT, LU, MT, NO, PL, SE, SI.


25

Figure 1 shows that in 2013 21 countries26

achieved their targets, while 5 countries27

did not.

Figure 1 – Targets and results (D+1) in 32 European countries in 2013

As figure 2 shows, in 2013, in comparison with 2012, 10 countries improved the quality of time

measurement (D+1), while 14 countries did not. Two countries recorded the same quality of time

measurement and the figures are not available yet in 2 other countries.

Figure 2 – Results (D+1) of 2012 and 2013 in 32 European countries

26 AT, BE, CH, CY, CZ, DE, EL, FI, FR, HR, HU, IT, LT, LV, MT, NO, PT, SE, SI, SK, UK 27 BG, DK, EE, PL, RO

0

10

20

30

40

50

60

70

80

90

100

AT

BE

BG

CH

CY

CZ

DE

DK

EE

EL

ES FI

FR

FY

HR

HU IE IT LT

LU

LV

MT

NL

NO PL

PT

RO

RS

SE SI

SK

UK

Targets Results

0

10

20

30

40

50

60

70

80

90

100

AT

BE

BG

CH

CY

CZ

DE

DK

EE

EL

ES FI

FR

FY

HR

HU IE IT LT

LU

LV

MT

NL

NO PL

PT

RO

RS

SE SI

SK

UK

2013 2012


26

Table 6 below indicates which methodology each country has used for the measurement of single

piece priority mail. All countries have used the European standard EN 1385028

.

Table 6 – Methodology for each country based on the quality of service for single piece priority mail in 2013

Count Country %

EN 13850 25

AT, BE, BG, CH, CZ, DE, DK, EL,

ES, FR, HR, HU, IE, IT, LT, LV, MT,

NL, NO, PL, PT, RO, SE, SI29

, SK.

100

4.1.2. Measurement of loss or substantial delay in 2013

Countries that have regulatory objectives for loss or substantial delay regarding single piece priority

mail, are shown in table 7. Only Portugal claimed to have regulatory objectives for loss or substantial

delay. Portugal has a target for D+10 set at 99.85% for which the USP achieved a result of 99.87%.

Regarding regulatory objectives for loss or substantial delay, about single piece non priority mail, only

Portugal mentioned the existence of objectives. Portugal sets a target for D+15 delivery at 99.86% for

which the result (99.85%) fell short by 0.01 pp.

Regarding regulatory objectives for loss or substantial delay, about registered mail in 2013, only

France mentioned the existence of objectives for these services. France reported that, in 2013, it had an

indicator for loss or substantial delay, but that the target value was not defined.

Table 7 – Regulatory objectives for loss or substantial delay regarding single piece priority mail

D+1 D+2 D+3 D+10

Target Results Target Results Target Results Target Results

PT / / / / / / 99.85 99.87

Total / / / / / / 1 1

Average / / / / / / 99.9

28 EN 13850 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

priority mail and first class mail 29 SI doesn’t differentiate on priority and non-priority mail. The measurement standard EN 13850 is used in SI for items of

correspondence which includes, if compared to the definition of single piece priority mail, a broader range of services.


27

4.1.3. Measurement of quality of service for single piece non-priority mail in 2013

Table 8 below presents the countries which have a regulatory objective for routing time for single

piece non-priority mail.

Table 8 – Targets and results of single piece non-priority mail

D+1 D+2 D+3 D+4 D+5 D+6

Target Results Target Results Target Results Target Results Target Results Target Results

BE / / 95.0030 97.91 / 99.48 / / / / / /

BG / / 80.00 81.00 95.00 90.40 / / / / / /

CH / / / / 97.00 98.80 / / / / / /

DK 95,00 98,60

FI / / 95.00 92.70 98.00 98.90 / / / / / /

FR / / 93.00 92.80 / / / / / / / /

FY 85.00 / 90.00 / 95.00 / / / / / / /

HR / / / / 95.00 95.10 / / / / / /

HU / / / / 85.00 93.40 / / 97.00 99.30 /

LU n.a. 97.06 85.00 99.63 99.00 n.a. n.a. n.a. / / / /

LV / / / / 98.00 99.70 / / / / / /

NO / / / / / / 85.00 93.70 / / 97.00 97.30

PL / / / / 85.00 85.40 / / 97.00 98.40 / /

PT / / / / 96.30 97.60 / / / / / /

RS / / 90.00 98.86 98.60 98.74 / / 99.50 100.00 / /

SI31

95.00 96.20 99.50 99.60 100.00 99.9 / / / / / /

SK / / 93.00 93.42 / / / / / / / /

UK / / / /

98.50

or

90.00

/ / / / / / /

Total 2 2 9 8 14 12 1 1 3 3 1 1

Average 90.0 96.6 91.2 94.5 95.4 96.3 85.0 93.7 97.8 99.2 97.0 97.3

30 Objective for the overall small consumer baskets which consists of 5 key services of single piece (priority, non-priority,

inbound, registered and parcels). 31 SI doesn’t differentiate on priority and non-priority mail. SI measurement for D+1, D+2 and D+3 is done for items of



28

Based on this table we can notice the following points:

- Only the Former Yugoslav Republic of Macedonia (85%) and Slovenia (95%) have target

values regarding D+1 delivery. Slovenia (96.20%) exceeded the target value. Results for the

Former Yugoslav Republic of Macedonia are not yet available and Luxembourg has results

regarding D+1 (97,06%);

- 9 countries32

have targets concerning D+2 delivery. Bulgaria (80%) and Luxembourg (85%)

have considerably lower targets than the other 7 countries especially when compared with

Belgium (95%), Finland (95%) and Slovenia (99.6%). All countries achieved their targets

except for Finland (difference of 2,3% compared to its target) and France (difference of 0,2%

compared to its target). The average result was 94.5%;

- 14 countries have targets concerning D+3 delivery. Hungary and Poland (85%) showed the

lowest target while Luxembourg (99%), Serbia (98.6%), Slovenia (100%) and the United

Kingdom (98.5%) presented the highest ones. Only Bulgaria (difference of 4,6% compared to

its target) failed to achieve their targets.

- Only Norway sets targets for D+4 (85%) and D+6 (97%) which are surpassed by the results,

respectively 93.7% for D+4 and 97.3% for D+6;

- Only Hungary (97%), Poland (97%) and Serbia (99.5%) set targets for D+5 delivery. These

countries achieved and exceeded their targets with results equal to 99.3%, 98.4% and 100%,

respectively.

Table 9 below indicates which methodology each country has used for the measurement of single

piece non-priority mail. Most countries (85%) used the European standard EN 1450833

, but 2 countries

(15%) used the EN 1385034

.

Table 9 – Methodology for each country based on the quality of service for single piece non-priority mail in 2013

Count Country %

EN 13850 2 NO, SI35

15

EN 14508 11 BE, BG, CH, HR, DK, FR, HU, PL,

PT, SK, UK 85

32 BE, BG, FI, FR, FY, LU, RS, SI, SK. 33 EN 14508 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

non-priority mail and second class mail 34 EN 13850 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

priority mail and first class mail 35 SI doesn’t differentiate on priority and non-priority mail. SI measurement for D+1, D+2 and D+3 is done for items of



29

4.1.4. Measurement of quality of service for bulk mail in 2013

Table 10 below presents the countries which have a regulatory objective for routing time for bulk

mail.

Table 10 – Targets and results of bulk mail (question 1.1.2)

D+1 D+2 D+3 D+4 D+5


FR / / / 97,00 / / / / / /

HU 90,0036

/ / / 97,00

37

85,0038

95,00

39 / / 97,00

40 99,50

41

IT / / / / 94,00 94,10 / / 98,00 98,40

LU n.a. 97,06 85,00 99,63 99,00 n.a. n.a. n.a. / /

MT 94,00 94,35 98,00 97,87 99,00 98,28 / / / /

SE 85,00 / / / 97,00 / / / / /

Total 3 2 2 3 5 3 0 0 2 2

Average 89.7 95.7 91.5 98.2 97.2 95.8 n.a. n.a. 97.5 99.0

Based on this table, we can notice the following points:

- Regarding D+1 delivery, only Hungary (for priority bulk items 90%), Malta (94%) and

Sweden (85%) set targets for which Malta is the only one to have results (94.35%);

- Regarding D+2 delivery, only Luxembourg (85%) and Malta (98%) set targets. France has

results regarding D+2 (97%), but did not present the respective target value;

- Regarding D+3 delivery, Hungary (97% for priority bulk mail and 85% for non-priority bulk

mail), Italy (94%), Luxembourg (99%), Malta (99%) and Sweden (97%) established targets.

Only Hungary (95% for non-priority bulk mail), Italy (94.1%) and Malta (98.28%) presented

results;

- None of the countries have targets regarding D+4 delivery;

- Regarding D+5 delivery, only Hungary (97% for non-priority bulk mail) and Italy (98%) fixed

quality targets. Both Hungary (99.5%) and Italy (98.4%) exceeded their targets.

36 Priority. 37 Idem 38 Non-priority. 39 Idem 40 Idem 41 Idem


30

Table 11 below indicates which methodology each country has used for the measurement of bulk mail.

Most countries (75%) used the European standard EN 1453442

but 1 country (25%) used the

EN1385043

together with the EN 1450844

.

Table 11 – Methodology for each country, based on the quality of service for bulk mail in 2013

Count Country %

EN 13850 1 DK 25

EN 14534 3 HU, MT, SE 75

4.1.5. Measurement of quality of service for Newspapers/periodicals in 2013

Portugal established regulatory objectives for routing time for newspapers/periodicals. None of the

countries established regulatory objectives for loss or substantial delay for newspapers/periodicals.

42 EN 14534 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for bulk mail 43 EN 13850 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

priority mail and first class mail 44 EN 14508 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

non-priority mail and second class mail


31

4.1.6. Measurement of quality of service for parcels in 2013

Table 12 below presents the countries which have a regulatory objective for routing time for parcels.

Table 12 – Targets and results of parcels (question 1.1.2)

D+1 D+2 D+3 D+4 D+5 D+6

Target Results Target Results Target Results Target Results Target Results Target Results

AT / / 90,00 94,44 / / / / 100,00 / / /

BE 95,0045 96,1146 95,0047 98,8648 / / / / / / / /

BG 80,00 89,70 95,00 99,50 / / / / / / / /

CH 95,00 97,30 95,00 97,70 / / / / / / / /

DE / / 80,00 / / / / / / / / /

DK 93,00 96,50

ES / / / / 80,00 81,10. / / 95,00 88,90 / /

FR / / 88,00 89,40 / / 98,50 99,10 / / / /

FY / / 70,00 / 75,00 / / / 80,00 / / /

HU / / 85,00 98,60 95,00 99,70 / / / / / /

IT / / / / 94,00 93,80 / / / / / /

LV / / / / / / 98,00 / / / / /

MT 98,00 98,81 99,00 99,61 99,00 99,75 / / / / / /

NO / / / / / / 85,00 88,40 / / 97,00 98,20

PL 80,00 76,80 / / 90,00 97,80 / / / / / /

PT / / / / 92,00 95,50 / / / / / /

RO / / 85,00 / / / 97,00 / / / / /

SI / / 80,00 100,00 95,00 100,00 / / / / / /

SK / / 93,00 99,34 93,00 99,17 / / / / / /

UK 93,00

and/or

91,50

/ / /

98,50

or

90,00

/ / / / / / /

Total 7 6 12 9 10 8 4 2 3 1 1 1

Average 90.6 92.5 87.9 97.5 91.2 95.9 94.6 93.8 91.7 88.9 97.0 98.2

Based on this table, we can notice the following points:

- Regarding D+1 delivery, only Belgium (95%), Bulgaria (80%), Denmark (93%), Malta (98%),

Poland (80%), Switzerland (95%) and the United Kingdom (93% and/or 91.5%) set targets. Of


inbound, registered and parcels). 46 Parcels with delivery standard D+1. 47 Objective for the overall small consumer baskets which consists of 5 key services of single piece (priority, non-priority,

inbound, registered and parcels) 48 Parcels with delivery standard D+2.


32

these countries only Poland failed to achieve the defined target (difference of 3,2% compared

to the target) and United Kingdom did not present the results;

- Regarding D+2 delivery, 12 countries49

stated to have targets. Belgium, Bulgaria, Switzerland

(95%) and Malta (99%) presented the highest targets while the Former Yugoslav Republic of

Macedonia (70%), Germany, Slovenia (80%) and Romania (85%) established the lowest ones.

The average target was 87.92%. The countries that presented their results exceeded their

goals.


established quality targets. Hungary (95%), Italy

(94%), Malta (99%, same as D+2), Slovenia (95%) and the United Kingdom (98.5%)

presented the highest target values while the Former Yugoslav Republic of Macedonia (75%)

and Spain (80%) presented the lowest ones. Only Italy failed to achieve its target (difference

of 0,2% compared to the target). Results are not available for the Former Yugoslav Republic

of Macedonia and the United Kingdom.

- Only France (98.5%), Latvia (98%), Norway (85%) and Romania (97%) have targets

regarding D+4. Only France (99.1%) and Norway (88.4%) presented results.

- Regarding D+5 delivery, only Austria (100%), the Former Yugoslav Republic of Macedonia

(80%) and Spain (95%) have targets. None of the countries presented results except Spain,

which presented results (88,9%) below the target of 95%.

- Regarding D+6 delivery, only Norway (97%) has a target, which was achieved (98.2%).

Table 13 below indicates which methodology each country has used for the measurement of parcels.

Most countries (50%) used the European standard TR 1547251

but 2 countries (25%) used another

standard, 1 country (12,5%) used the standard EN 1385052

and 1 country (12,5%) used the EN13850

together with the EN 1450853

.

Table 13 – Methodology for each country, based on the quality of service for parcels in 2013

Question: For the service for parcels in

2013, please specify the methodology

used for the measurement: Count Country %

EN 13850 1 NO 12,5

TR 15472 4 BE, MT, PL, SI 50,0

EN 13850/EN 14508 1 SK 12,5

Other 2 BG54

, CH 25,0

49 AT, BE, BG, CH, DE, FR, FY, HU, MT, RO, SI, SK. 50 ES, FY, HU, IT, MT, PL, PT, SI, SK, UK. 51 TR 15472 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for parcels by the

use of a track and trace system. 52 EN 13850 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

priority mail and first class mail 53 EN 14508 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

non-priority mail and second class mail 54 Using data from the datestamp.


33

4.1.7. Measurement of quality of service for registered mail in 2013

Table 14 below presents the countries which have a regulatory objective for registered mail.

Table 14 – Targets and results of registered mail

D+1 D+2 D+3 D+4 D+5


AT 98,00 99,50

/ / 99,90 100,00 100,00 / /

BE 95,0055

96,87

DE 80,00 / 95,00 / / / / / / /

FR / / 93,00 95,20 / / / / / /

HU / / / / 85,00 98,30 / / 97,00 99,60

IT / / / / 92,50 93,70 / / 98,00 98,20

LU n.a. 97,06 85,00 99,63 99,00 n.a. n.a. n.a. / /

LV 100,00 / / / / / / / / /

MT 98,00 99,32 99,00 99,89 99,00 99,95 / / / /

RO 85,00 / 97,00 / / / / / / /

SK / / 93,00 99,34 / / / / / /

UK

93,00

and/or

91,50

and

99,00

/ / /

98,50 or

90,00

and

99,00

/ / / / /

Total 7 4 6 4 5 4 1 1 2 2

Average 93.6 98.2 93.7 98.5 94.9 98.0 100 100 97.5 98.9

Based on this table we can notice the following points:

- Regarding D+1 delivery, only Austria (98%), Belgium (95%), Germany (80%), Latvia

(100%), Malta (98%), Romania (85%) and the United Kingdom (93% and/or 91.5% and 99%)

set quality targets which are measured and achieved in Austria (99,5%), Belgium (96.87%)

and Malta (99.32%) . Luxembourg has results regarding D+1 (97,06%), but did not present the

respective target value;


established quality targets. France (93%), Germany

(95%), Luxembourg (85%), Malta (99%), Romania (97%) and Slovakia (93%). Luxembourg

established the lowest target, while Malta established the highest ones. There are no results

available for Germany and Romania. All countries that presented their results surpassed their

targets.

- Regarding D+3 delivery Hungary (85%), Italy (92.5%), Luxembourg (99%), Malta (99%),

and the United Kingdom (98.5% or 90% and 99%) have targets.

- None of the countries have targets regarding D+4 delivery;


inbound, registered and parcels). 56 DE, FR, LU, MT, RO, SK


34

- Regarding D+5 delivery only Hungary (97%) and Italy (98%) defined quality targets, which

both countries exceeded.

Table 15 below indicates which methodology each country has used for the measurement of registered

items. Most countries used the European standard EN 1385057

(43%) or EN 1413758

(29%) but 1

country (14%) used the EN13850 and 1 country used the EN 1450859

.

Table 15 – Methodology for each country, based on the quality of service for registered mail in 2013

Question: For the service for registered

mail in 2013, please specify the

methodology used for the measurement: Count Country %

EN 13850 2 AT, DE 33

TR 15472 1 BE60

17

EN 14508 1 SK 17

EN 14137 2 FR, MT 33

57 EN 13850 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

priority mail and first class mail 58 EN 14137 is a CEN standard for Postal Services – Quality of Services – Measurement of the loss of registered mail and

other types of postal services using track and trace system 59 EN 14508 is a CEN standard for Postal Services – Quality of Services – Measurement of the transit time for single piece

non-priority mail and second class mail 60 Technical report partly used


35

4.1.8. Force majeure

In measuring the transit time some events which has been considers as force majeure, can be excluded

from the measurement based on the standard. In accordance with CEN 13850 in most countries (18

countries61

) the NRA decide on the application of force majeure events on request of the operator.

In 12 countries have been defined the circumstances on which an event can be considered as a force

majeure62

, which may have implications for measurement of the quality of service.

As a result of the questionnaire in 2013, the accepted force majeure days varied between 0 and 15

days (2012: between 0 and 9 days).

In the table below 4 countries stated the number of force majeure days and reasons for those events.

Table 16 – Number of accepted force majeure days/incidents and reasons in 2013

Country Number of days Reasons

BE 7 days, of which 2

regional ones National strike and extreme weather conditions.

EL 15 National strike

PT 8 working days of

force majeure for

priority mail

(Mainland) and 11

working days of

force majeure for

non-priority mail

National strike and national airspace restrictions resulting from bad weather in the

Azores.

SK 1 heavy snow

61 BE, BG, CH, EL, FI, FY, HR, HU, IE, IT, LT, MT, PL, PT, RS, SE, SI, SK (question 1.5.2: Do you, as the NRA, decide

on the application of force majeure events on request of the operator?). 62 BE, BG, CZ, DK, FI, FY, HR, IT, LT, LV, PT, RO (question 1.5.1: Is there a definition of force majeure events in your

country, applicable to the measurement of quality of service).


36

4.2. Collection and delivery

Concerning delivery, in Article 3 of the Directive 97/67/EC, as amended by Directive 2008/6/EC of

the European Parliament and of the council of 20 February 2008, it is said:

“Member States shall take steps to ensure that the universal service is guaranteed not less than five

working days a week, save in circumstances or geographical conditions deemed exceptional, and that

it includes as a minimum:

- one clearance,

- one delivery to the home or premises of every natural or legal person or, by way of derogation,

under conditions at the discretion of the national regulatory authority, one delivery to appropriate

installations.’

Any exception or derogation granted by a national regulatory authority in accordance with this

paragraph must be communicated to the Commission and to all national regulatory authorities.”

4.2.1. Requirements on the frequency of collection and delivery relating to the universal service

4.2.1.1. Collection

Regarding the frequency of collections (see figure 3) to be made by the universal service provider, the

responses received from European countries have revealed that the Directive has been implemented by

all and that, with few exceptions, the rule is at least one collection/day for 5 days a week.

The exceptions are those countries in which the obligation to have the collection carried out by the

universal service provider was extended to 6 days a week. More specifically, the countries that

implemented exceptions (6 days/week) in the frequency of collection relating to the universal service

are:

- Norway, Malta, Germany and France: for all categories (correspondence, parcel and CNP63

);

- The Netherlands: only for “mourning mail” and “medical mail”;

- UK: only for correspondence and parcels;

- Estonia and Belgium: only for CNP64

;

- Bulgaria: where the universal service provider is obliged to ensure, in Sofia, two collections

per day, from Monday to Friday, and one collection per day on Saturdays and Sundays. For

the rest of the country, the universal service provider has to ensure one collection per day,

from Monday to Saturday, in geographical areas served by a sorting centre, and one collection

per day, from Monday to Friday, in geographical areas unserved by a sorting centre.

63 Catalogues, Newspapers, Prints 64 Idem


37

Figure 3 – Number of collections/week relating to the universal service

1 2 3 4 5 6

UK

Switzerland

Sweden

Spain

Slovenia

Slovakia

Serbia

Romania

Portugal

Poland

Norway

Nedherland

Malta

Luxembourg

Lithuania

Latvia

Italy

Ireland

Hungary

Greece

Germany

FYROM

France

Finland

Estonia

Denmark

Czech Republic

Cyprus

Croatia

Bulgaria

Belgium

Austria

Correspondence CNP Parcels


38

4.2.1.2. Delivery

Regarding the frequency of deliveries (figure 4) to be made by the universal service provider, the

responses received from European countries have revealed that the Directive has been implemented by

all and that, with few exceptions, the rule is at least one delivery/day for 5 days a week.

The exceptions are those countries in which the obligation to have the delivery carried out by the

universal service provider was extended to 6 days a week. More specifically, the countries that

implemented exceptions (6 days/week) in the frequency of delivery relating to the universal service

are:

- Norway, Malta, Germany and France: for all categories (correspondence, parcel and CNP);

- The Netherlands: only for “mourning mail” and “medical mail”;

- UK: only for correspondence and parcels;

- Austria, Estonia and Belgium: only for CNP;

- Switzerland: usually 5 days a week, but for priority mail, in reality the delivery rule claims 6

days a week;

- Bulgaria: where the universal service provider is obliged to ensure, in Sofia, two deliveries per

day, from Monday to Friday, and one delivery per day on Saturdays and Sundays. For the rest

of the country, the universal service provider has to ensure one delivery per day, from Monday

to Saturday, in geographical areas served by a sorting centre, and one delivery per day, from

Monday to Friday, in geographical areas unserved by a sorting centre. Another special case is

FYROM, where the universal service provider is obliged to ensure deliveries only for 3

days/week.


39

Figure 4 – Number of deliveries/week relating to the universal service

1 2 3 4 5 6

UK

Switzerland

Sweden

Spain

Slovenia

Slovakia

Serbia

Romania

Portugal

Poland

Norway

Nedherland

Malta

Luxembourg

Lithuania

Latvia

Italy

Ireland

Hungary

Greece

Germany

FYROM

France

Finland

Estonia

Denmark

Czech Republic

Cyprus

Croatia

Bulgaria

Belgium

Austria

Correspondence CNP Parcels


40

4.2.2. Exceptions on collection and delivery because of circumstances or geographical conditions

deemed exceptional.

According to Paragraph 3 of Article 3 of the Directive, there may be exceptions in the frequency of

collection/delivery in circumstances or geographical conditions deemed exceptional. It includes as a

minimum: one clearance/one delivery to the home or premises of every natural or legal person or, by

way of derogation, under conditions at the discretion of the national regulatory authorities, one

delivery to appropriate installations. It should be underlined that the same paragraph states that any

exception or derogation granted by a national regulatory authority must be communicated to the

European Commission and to all the other national regulatory authorities.

Here are the most frequently mentioned reasons for exceptions to USO obligations in the following

countries (listed in the figure 5 on next page):

- mountainous and inaccessible character;

- depopulated areas, dispersed population;

- islands;

- costs65

;

-tradition;

- extreme weather conditions;

- areas where public transport is not regularly provided;

- poor infrastructure (roads, etc.);

- fluctuation in the number of people depending on the season.

65 The postal sector has the features of a scale economy in which the providers reduce the costs incurred by the processing of

a single postal item as the real flow they process is increasing. Where the real flow is low, the processing costs increase and

the operators naturally decide to close their access/contact points deserved by personnel, ensuring most of the times (with the

agreement of the regulatory authorities) the collection and delivery of postal items 2-3 times a week.


41

Figure 5 – Reasons for exceptions regarding collection and delivery

Analysing the responses provided by Member States, we conclude that there are 8 countries in which

the list of settlements and cases deemed to be exceptional have been expressly defined in the

secondary legislation: Bulgaria, Czech Republic, Denmark, Greece, Romania, Slovakia, Spain and

UK. In all these cases, the list is regularly updated and published (with only one exception: Spain,

where the list is not published).

Greece is a special case. There, the responsibility for updating the list is collective. The list of

settlements located in exceptional areas due to special geographical peculiarities is formed by a

3member committee, where one member is from the Ministry of Infrastructure, Transport and

Networks, another member is from the Greek NRA (EETT) and the last one is from the USP. Once

evaluated and approved by the Minister of Infrastructure, Transport and Networks, the proposed

settlements that are excluded from the quality measurements are appended to the USP’s Management

Contract between the USP and the Ministry of Infrastructure, Transport and Networks.

10

8

15

6

3

6

0

2

4

6

8

10

12

14

16

mountainous

character

islands

dispersed

population

costs

tradition

weather

Islands:

1.

Denmark

2. Estonia

3. Finland

4. France

5. Greece

6. Spain

7. Sweden

8. UK

Weather: 1. Denmark, 2. Greece ,

3. Romania, 4. Slovenia 5. Spain, 6. UK

Mountainous

character:

1. Bulgaria

2. Croatia

3. Cyprus

2. France

3. Greece

4. FYROM

5. Romania

6. Serbia

7. Slovakia

8. Slovenia

8. Sweden

9. Switzerland

10. UK

Dispersed

population:

1. Bulgaria

2. Crotia

3. Cyprus

4. Greece

5. Italy

6. FYROM

7. Norway

8. Romania

9. Serbia

10. Slovakia

11. Slovenia

12. Spain

13. Sweden

14. Switzerland

15. UK

Costs: 1. Norway, 2. Romania, 3. Slovakia,

4. Sweden, 5. Switzerland, 6. UK

Tradition: 1. Switzerland, 2. UK, 3. Sweden


42

Denmark is another special case. There, in accordance with the Postal Services Directive and pursuant

to Article 15 of the Danish Postal Service Act of 2010, the Danish National Regulatory Authority (the

National Transport Authority) has stipulated that the permanent inhabitants of a number of small

Danish islands (approximately 7-8 islands) will have to pick up their postal items - letters and parcels -

at a central location on the mainland (typically in the ferry port). The inhabitants receive compensation

from the universal service provider for this derogation of the universal service. As a principle, the limit

is set at 10 permanent inhabitants, but 3-4 small islands with a population below 10 permanent

inhabitants are subject to more individual arrangements, such as the delivery of postal items in a letter

box in the ferry port or the delivery, to the homes of the inhabitants, by the boatman or by one of the

inhabitants (for which he will be compensated). For all other Danish islands with daily boat or ferry

service and with more than 10 permanent inhabitants, postal items are carried to the island on a daily

basis, Monday through Saturday, and delivered to the homes of the inhabitants. The service

requirement for domestic parcels is day-to-day delivery Monday through Friday between all Danish

cities, except for parcels to the Danish island of Bornholm (in the Baltic Sea), where an extra day must

be expected for delivery.

In all states where this list is regularly updated, it is published on the Internet, on the NRA webpage or

on the USP webpage. Table 17 below gives the internet links to the lists of areas deemed to be special

cases in the Member States.

Table 17 – Internet links with reference to the lists of exceptional circumstances in the Member States

EL https://diavgeia.gov.gr/doc/4ΙΗΝ1-Π

http://mapsrv6.terra.gr/eettpostssl/

RO http://www.ancom.org.ro/uploads/links_files/SP_lista_localitatilor_cdt_exceptionale_septembrie_2013.pdf

SK http://www.posta.sk/stranky/informacie-k-otvaracim-hodinam-post

UK for Collections: http://www.royalmailgroup.com/sites/default/files/USO_Collections_Exceptions.pdf

for Deliveries: http://www.royalmailgroup.com/sites/default/files/USO_Delivery_Exceptions.pdf

https://diavgeia.gov.gr/doc/4ΙΗΝ1-Π

http://mapsrv6.terra.gr/eettpostssl/

http://www.ancom.org.ro/uploads/links_files/SP_lista_localitatilor_cdt_exceptionale_septembrie_2013.pdf

http://www.posta.sk/stranky/informacie-k-otvaracim-hodinam-post

http://www.royalmailgroup.com/sites/default/files/USO_Collections_Exceptions.pdf

http://www.royalmailgroup.com/sites/default/files/USO_Delivery_Exceptions.pdf


43

4.3. Access points

Article 2 of Directive 2008/06/EC defines access points as

“physical facilities, including letterboxes 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.”

4.3.1. Collection letterboxes

To this end, the majority of responding countries with 29 NRAs (91%) have set

requirements/standards to ensure that an adequate number of collection letterboxes are provided by the

USP.

Table 18 – Requirements/standards to ensure an adequate number of collection letterboxes

Question Answer Count Country %

Requirements/standards to

ensure an adequate number

of collection letterboxes

YES 29

AT, BE, BG, HR, CY, CZ, DK, EE, FI, FY, DE,

EL, HU, IE, IT, LV, LT, LU, MT, NL, NO, PL,

RS, RO, SK, SI, SE, CH, UK

91

NO 3 FR, ES, PT66

9

Figure 6 – Requirements/standards to ensure an adequate number of collection letterboxes

66 Specific requirements/standards were defined on the 28th of August, 2014, by a decision of the NRA, and came into effect

on October 1st, 2014. No specific requirements were applicable in 2013.

29

3

0

5

10

15

20

25

30

35

Yes No

Yes

No

Yes (AT, BE, BG, HR, CY, CZ, DK, EE, FI, FY, DE, EL, HU, IE, IT, LV, LT, LU, MT, NL, NO, PL, RS, RO, SK, SI, SE, CH, UK)

No (FR, ES, PT)


44

The most often mentioned applicable criteria to ensure an adequate number of collection letterboxes

are the following:

- number of collection letterboxes per locality;

- one collection letterbox per number of inhabitants depending on the type of settlement

(difference is marked between urban and rural areas);

- maximum distance that one has to travel to the collection letterbox;

- maximum (air) distance between neighbouring collection letterboxes.

In addition, there are different combinations of the above criteria. It should be noted that, in many

countries, the requirements differ regarding the criteria that apply to access points and for urban and

rural areas. Almost half of the responding countries have specific metrics for the minimum number of

collection boxes that should be in place in relation to population density and distance. A sole distance

criterium is also widely spread among Member Countries to ensure an adequate availability of

letterboxes since 45 % of the respondents rely on it.

On the other hand, Denmark, Norway and Sweden are examples of a “custom-made” approach, where

the network of letterboxes is not based on predefined criteria, but has to be built upon users’ needs.

As shown in figure 7 below, 58% of the responding countries’ requirements can be found mainly in

legislation.

Figure 7 - Where are the requirements/standards to ensure an adequate number of collection letterboxes defined?

58 %

6 %

32 %

3 %

Legislation

Authorisation/Licence

Regulation/decision issued by the NRA

Other


45

Collection time is marked on the collection letterboxes in 91% of the countries, as shown in table 19

below.

Table 19 – Collection time displayed on collection letterboxes


Is the collection time

marked on the

collection letterboxes?

YES 29

AT, BE, BG, HR, CZ, DK, EE, FI, DE, EL, HU, IT,

LV, LT, LU, MT, NL, NO, PL, RS, SK, SI, SE, RO,

CH, UK, FR, ES, PT

91

NO 3 CY, FY, IE 9

Figure 8 – Collection time marked on collection letterboxes

Information has been collected regarding the evolution in the number of collection letterboxes since

2008 (end of 2008 and end of 2013). The figures below indicate that, although in some countries a

growth is registered or no changes have occurred, in general there is a decrease in collection

letterboxes. This is significant in the cases of Portugal (- 43%) and Latvia (- 42%).

Figure 9 – Percentage change in the number of collection letterboxes per country from 2008 till 201367

67 IE – Figures provided by the USP in its Annual Reports.

29

3

0

10

20

30

40

Nr.

of

Co

untr

ies

YES (AT, BE, BG, HR, CZ, DK, EE, FI, DE,

EL, HU, IT, LV, LT, LU, MT, NL, NO, PL,RS, RO, SK, SI, SE, CH, UK, FR, ES, PT)

NO (CY, MK, IE)

-19 -16

-9

-35

5

-7

-13 -13

-29

-5

1

-5 -5

21

-42

-31

0 0

-5

-13

-37

-43

0

-17

-24

0

-11

-21

-50

-40

-30

-20

-10

0

10

20

30

AT BE BG HR CY CZ DK EE FY FR DE EL HU IE LV LT LU MT NL NO PL PT RO SK SI ES SE CH


46

4.3.2. Points of contact

In article 3, 2 of the Directive 2008/06/EC, it is said about points of contact

“Member States shall take steps to ensure that the density of the points of contact and of the access

points takes account of the needs of users.”

Those points of contact may be managed directly by postal operators (postal establishments), be

managed by third entities (such as retail stores…) or correspond to services directly provided by the

mailman.

Keeping in mind the above-mentioned provision, Member States should ensure that sufficient access

points are established, taking into account users’ needs in order to satisfy the universal service

obligation. It is also important to assure equal treatment of users in urban and rural areas, without

prejudice of geographical conditions.

It is a difficult task to evaluate whether the density of access points corresponds to the necessary

equilibrium between the users’ needs and the cost-efficient provision of the universal service. In some

countries, post offices have an important social function and they are quite often seen as a last

stronghold of the state in the small villages, so that the density of the access points is a particularly

sensitive issue.

Table 20 below shows NRAs in relation to requirements/standards to ensure an adequate number of

points of contact/postal establishments, with 27 NRAs (84%) who confirm requirements/standards are

in place in their countries and 5 NRAs (16%) who do not. The same question concerning the existence

of requirements/standards in respect of an adequate number of collection letterboxes shows that some

countries have requirements for collection letterboxes but do not have requirements concerning the

number of contact/postal establishments, and vice versa.

Table 20 - Requirements/standards to ensure an adequate number of points of contact/postal establishments


Requirements/standards to

ensure an adequate number

of point of contact/postal

establishments

YES 27

AT, BE, BG, HR, CZ, DK, EE, FI, DE, EL,

HU, IT, LV, LT, LU, MT, NL, NO, PL, RS,

RO, SK, SI, SE, CH, UK, FR,

84

NO 5 CY, IE, LU, PT68

, ES 16

68 Specific requirements/standards were defined on the 28th of August, 2014, by a decision of the NRA, and came into effect

on October 1st, 2014. No specific requirements were applicable in 2013.


47

Figure 10 – Requirements/standards to ensure an adequate number of points of contact/postal establishments

The large majority of the countries have confirmed that they have requirements/standards in place.

53% of those countries include their requirements in the legislation. In 21% of the countries,

requirements/standards are contained in regulations/decisions issued by the NRAs. Combinations of

criteria are used in 19% of countries. An example of such combination is Hungary, where criteria can

be found partly in legislation and party in Universal Postal Public Service Contract. Only one country

has set the requirements in Authorisation/Licence. Belgium is listed as an exception, since the criteria

to ensure an adequate number of postal establishments are found in the management contract between

the State and bpost.

Common criteria applied for an adequate number of points of contact/postal establishments are:

- number of postal establishments per locality;

- one postal establishment per number of inhabitants, which could depend on the size of the

settlement. Also, differences between rural and urban areas are not an exception;

- maximum distance that one has to travel to the nearest postal establishment;

- maximum (air) distance between neighbouring postal establishments;

- minimum number of post offices, providing UPS or full range of postal services;

- percentage of population at a certain distance from the postal establishment.

Generally, a combination of criteria is used, which varies between countries and depends on the

geographic and demographic peculiarities.

0

5

10

15

20

25

30

Nr.

of

Co

un

trie

s

YES

NO


48

As shown in table 21 below, NRA is a common authority for checking the compliance with the

requirements on an adequate number of postal establishments on the national territory. In the majority

of cases, the supervision is done by demanding information to the USP or to various local

authorities/organisations (58% of the respondents). The second most common method is obtaining

information by using publicly accessible information (25% of the respondents). In addition, there are

also combinations of the above methods. Though, only 69% of the respondents indicated to have a

system of sanctions in place in the case of non-compliance with the requirements on an adequate

number of postal establishments.

Table 21 - Entity entitled to check compliance with the requirements on an adequate number of postal establishments


Entity entitled to check

compliance with the

requirements on an

adequate number of

postal establishments

NRA 22

AT, BE, BG, CH, HR, CZ, DK, EE, FI, FR,

FY,DE, IT, LV, LT, LU, MT, NL, NO,RO, SK,

SI, SE

85

Ministry 1 RS

4

NRA +

Ministry 3 EL, HU, PL 11

Figure 11 – Entity entitled to check compliance with the requirements on an adequate number of postal

establishments

In most cases of non-compliance with requirements on the number of postal establishments, the

competent authority could resort to fines/penalties (62% of the respondents) or perform a regulatory

action, e.g. administrative or legal sanctions (38% of the respondents). Usually, measures are graded:

first the USP is asked to comply with the requirements and, only after that, a corrective measure is

applied.

22

1

3

0

5

10

15

20

25

Nr.

of

Co

un

trie

s

NRA (AT, BE, BG, CH, HR, CZ, DK, EE,

FI, FR, FY,DE, IT, LV, LT, LU, MT, NL,NO, RO, SK, SI, SE)

Ministry (RS)

NRA + Ministry (EL, HU, PL)


49

Table 22 below shows if the NRAs have the power to prevent closure of postal establishments. Based

on table 22 indicates that almost 60% of the NRAs have these powers and 40% who do not have these

powers.

Table 22 - Prevention of the closure of postal establishments


Is that entity

empowered to prevent

the closure of postal

establishments?

YES 16 AT, BG, HR, CZ, EE, FY, EL, HU

69, IT, LT,

MT, NO, RS, SK, SI, CH 59

NO 11 DE, FI, FR, DE, LV, LU, NL, PO, PT, RO, SE 41

Figure 12 – Is that entity empowered to prevent the closure of postal establishments?

Article 3, 1 of the Directive 2008/06/EC specifies

“Member States shall ensure that users enjoy the right to a universal service involving the permanent

provision of a postal service of specified quality at all points in their territory at affordable prices for

all users.”

Keeping in mind this provision of the Directive, postal points of contact should be accessible for all

users, including disabled persons. Only in Cyprus, Finland, Italy, Luxembourg, Poland, Sweden and

Switzerland, most postal establishments are equipped for disabled persons.

69 The NRA and the Ministry have no right to directly prevent the closure of postal establishments. However, the NRA can

start a procedure if the closure of postal establishments is in breach of law and/or of the Universal Postal Public Service

Contract (UPPSC). In case of serious breach of the UPSC, the NRA can submit an official decision to the Minister

responsible for the postal sector. The Minister can draw the USP’s attention to cease the breach. If it fails, the Minister is

entitled to withdraw the contract.

16

11

0

5

10

15

20

Nr.

of

Co

un

trie

s

YES (AT, BG, HR, CZ, EE, FY, EL, HU,

IT, LT, MT, NO, RS, SK, SI, CH)

NO (DK, FI, FR, DE, LV, LU, NL, PL, PT,

RO, SE)


50

Table 23 below illustrates the percentage of distribution of points of contact in each country in 2013.

Table 23 – Points of contact per country (distribution in %)

Permanent PO full

range of

services

Permanent PO limited

range of

services

Mobile post

offices

Mailman

170 Mailman 271

Seasonal post

office

Permanent PA

managed by 3rd entity

Other

Austria 29.0 71,0

Belgium 50,2 49,8

Bulgaria 54,0 1,0 45,0

Croatia 99,5 0,2 0,3

Cyprus 100,0

Czech

Republic 46,9 0,2 51,1 1,8

Denmark 3,0 58,0 39,0

Estonia

Finland 8,0 60,0 32,0

Former

Yugoslav

Republic of

Macedonia 73,9 22,5 0,7 0,7 2,2

France 57,0 43,0

Germany

Greece 15,0 55,0 15,0 15,0

Hungary 60,0 29,0 11,0

Ireland 4,96 95,04

Italy 100,0

Latvia 94,8 0,2 5,0

Lithuania 81,5 2,3 16,2

Luxembourg 83,6 16,4

Malta 52,3 3,1 44,6

Netherlands

Norway 3,3 53,0 43,7

Poland 60,0 40,0

Portugal 25,3 0,2 74,5

Romania

Serbia 64,7 19,9 15,5

70 Mail man is providing a full range of services offered by postman of the USP 71 Mail man is providing a basic services offered by postman of the USP


51

Slovakia 86,00 11,00 0,3 2,7

Slovenia 89,9 0,7 4,3 5,0

Spain 26,0 7 0,0 6772

Sweden 4,0 33,0 25,0 38,0

Switzerland 47,0 36,0 16,0

Figure 13 – Percentage by type of points of contact in 2013

The most common type of points of contact at the European level remains the access to a permanent

post office with full range of service. This is the case for all respondents. This is followed by

permanent post agency managed by a 3rd

entity, mobile postal office, permanent post office managed

by USP limited range of service and mail man 173

. The level of seasonal post office is so small that the

percentage level did not reach 1%.

Furthermore, information has been collected on the evolution of the number of points of contact of the

Universal Service Provider for the period 2008 – 2013. Most of the countries are experiencing a

decrease in the number of permanent post offices managed by the USP with full range of service, and

an increase of other types of points of contact, especially permanent post agencies managed by a 3rd

entity.

72 ES; others include mailman and mobile post offices 73 Mail man is providing a full range of services offered by postman of the USP

51 %

5 %

6 %

5 %

3 % 0 %

23 %

5 %

Permanent PO managed byUSP full range of service

Permanent PO managed byUSP limited range ofserviceMobile PO

Mail man 1

Mail man 2

Seasonal PO

Permanent PO managed by3rd

Other


52

However, there were also some countries with an increase in the total number of contact points. This

was the case for Cyprus, Former Yugoslav Republic of Macedonia and Malta. Apart from them, only

Spain had an increase in the number of permanent post offices managed by the USP with full range of

service.

The figure 14 below illustrates the evolution by type of points of contact between 2008 and 2013.

Data obtained from the questionnaire show a general decrease of 14% in the total number of contact

points. There was a 7% decrease of permanent postal offices managed by USP with full range of

service, a significant 64% decrease of mobile postal offices, a 45% decrease of mail man 274

and a

20% increase of permanent post offices managed by a 3rd

entity.

Figure 14 – Evolution of the number of points of contact by type in the period 2008 – 2013

Information has also been collected regarding the range of services offered by post agencies managed

by third entities. From collected data, it appears that different countries have different approaches of

the subject. Full range of services is offered by 59% of the respondents, while the other 41% offers

limited or basic range of services.

74 Mail man is providing a basic services offered by postman of the USP

0

10000

20000

30000

40000

50000

60000

PermanentPO

managedby USP full

range ofservice

PermanentPO

managedby USPlimited

range ofservice

Mobile PO Mail man 1 Mail man 2 PermanentPO

managedby 3rd

Other

Nu

mb

er

of

po

ints

of

con

tact

Type of points of contact

2008

2013


53

The figure 15 below illustrates the location of postal agencies managed by third parties.

Figure 15 – Location of post agencies managed by third parties

Postal agencies managed by third entities are mainly located in shops, followed by kiosks and petrol

stations, while the lowest share goes to bars.

13%

17%

44%

6%

19%

Petrol stations

Kiosks

Shops

Bars

Other


54

4.4. Measurement of consumer satisfaction

In 2013, the overall trend of those NRAs monitoring consumer satisfaction remained relatively

consistent. The resources required to undertake monitoring must also be taken account of when

deciding to engage a monitoring programme. It may be exclusive and resource-intensive to do so.

According to the responses to the 2014 questionnaire, 14 (44%) out of the 32 responding NRAs use or

monitor indicators of consumer satisfaction in their country, while 18 (56%) NRAs do not. In 4 (CH,

DK, NO and SI) out of the 18 countries, where the NRA does not use or monitor indicators of

consumer satisfaction, the USP conducts surveys on this issue and publishes the results.

Table 24 - NRA uses/monitors measurement of consumer satisfaction


Do you use/monitor

indicators of consumer

satisfaction in your

country?

Yes 14 BE, CY, FI, EL, IE, LT, LI, MK, MT,

PT, RS, SE, SK, UK

44%

No 18 AT, BG, CH, CZ, DE, DK, EE, ES, FR,

HR, HU, IT, LV, NL, NO, PL, RO, SI 56%

Two NRAs require the USP by legal obligation to have consumer satisfaction measures in place.

The results from the 2014 questionnaire show that, in the NRAs that use/monitor indicators of

consumer satisfaction, market surveys are used as the main method to identify levels of consumer

satisfaction. Those surveys range in frequency from adhoc to annual to twice yearly surveys. The

number of satisfaction indicators varies between NRAs depending on the nature and objectives of the

research being undertaken, the size of the postal market and their capability to conduct research given

individual circumstances and regulatory framework.

Table 25 -Links to research carried out to measure customer satisfaction

Belgium:

BIPT is publishing data on consumer satisfaction annually, as well as the action done and foreseen to

improve consumer satisfaction

http://www.bipt.be/nl/operatoren/post/universele-en-niet-universele-postdiensten/advies-van-de-raad-

van-het-bipt-van-24-december-2013-met-betrekking-tot-het-verbeteringsplan-2012-en-het-actieplan-

2013-naar-aanleiding-van-het-klantentevredenheidsonderzoek-2012?sid=%2FIBPT-CMS%2FIBPT-

documents-AvecDoc%2F%7C21138-nl-document_page-%2F1%2F3%2F11%2F20507%2F

Cyprus:

http://www.ocecpr.org.cy/nqcontent.cfm?a_id=1188&tt=ocecpr&lang=gr

http://www.bipt.be/nl/operatoren/post/universele-en-niet-universele-postdiensten/advies-van-de-raad-van-het-bipt-van-24-december-2013-met-betrekking-tot-het-verbeteringsplan-2012-en-het-actieplan-2013-naar-aanleiding-van-het-klantentevredenheidsonderzoek-2012?sid=%2FIBPT-CMS%2FIBPT-documents-AvecDoc%2F%7C21138-nl-document_page-%2F1%2F3%2F11%2F20507%2F





55

Denmark:

Data on consumer satisfaction published by USP. Only available in Danish.

http://www.postdanmark.dk/da/om%20os/kvalitet/kunder/Sider/Kundetilfredshed.aspx

The Danish USP, Post Denmark, conducts ongoing surveys of customer satisfaction and loyalty.

Below are the results from the recent years (indexed).

Year Private Business

2012 71 70

2011 71 67

2010 69 69

2009 68 66

2008 62 61

Ireland:

http://www.askcomreg.ie/post/market_research.99.LE.asp

Lithuania:

Consumer satisfaction surveys conducted every two years.

http://www.rrt.lt/download/16986/ataskaita%20-%20rrt%20201210(2).ppt

Malta:

http://www.mca.org.mt/consumer/surveys/consumer-perception-survey-households-postal-

services?language=en

http://www.mca.org.mt/consumer/surveys/micro-businesses-perception-survey-postal-


http://www.mca.org.mt/service-providers/surveys/large-bulk-mailers-perception-survey-postal-


Portugal:

ANACOM conducts a survey every 2 years. The survey includes questions concerning satisfaction

with:

- The service as a whole;

- Specific issues concerning postal establishments (information transparency, waiting time, opening

hours, accessibility and location, personal interaction);

- Every individual service (non-priority, priority, parcels, express…);

- Specific issues concerning individual services (delivery times, prices, inviolability);

- Mail delivery.

Quality is measured in a 1 to 10 scale.

http://www.anacom.pt/render.jsp?contentId=1166565&languageId=1.

ECSI – Portugal conducts a customer satisfaction survey and publishes its findings once a year.

http://www.postdanmark.dk/da/om%20os/kvalitet/kunder/Sider/Kundetilfredshed.aspx

http://www.rrt.lt/download/16986/ataskaita%20-%20rrt%20201210(2).ppt

http://www.mca.org.mt/consumer/surveys/consumer-perception-survey-households-postal-services?language=en

http://www.mca.org.mt/consumer/surveys/consumer-perception-survey-households-postal-services?language=en

http://www.mca.org.mt/consumer/surveys/micro-businesses-perception-survey-postal-services?language=en

http://www.mca.org.mt/consumer/surveys/micro-businesses-perception-survey-postal-services?language=en

http://www.mca.org.mt/service-providers/surveys/large-bulk-mailers-perception-survey-postal-services?language=en

http://www.mca.org.mt/service-providers/surveys/large-bulk-mailers-perception-survey-postal-services?language=en

http://www.anacom.pt/render.jsp?contentId=1166565&languageId=1


56

Serbia:

In January 2011, 2012 and 2014, in accordance with the Law on Postal Services and in cooperation

with a specialized marketing company, the NRA, undertook research on the needs of users of

universal postal service – “Researching the Level of Need Fulfilment of Universal Postal Services

Usersˮ. The method chosen for data collection was terrain survey "face to face" (F2F). Annually, the

NRA shall submit a report to the National Assembly about its activities, containing information

about achieved level in realization of the universal postal service, as well as the estimation of the

level of customers’ satisfaction.

http://www.rapus.rs/download/istrazivanje_izvestaj_fizicka_lica2013.pdf

http://www.rapus.rs/download/istrazivanje_izvestaj_pravna_lica2013.pdf

http://www.rapus.rs/o-nama/projektiIstrazivanje-Izvestaj-Fizicka_lica-2011.pdf

Slovakia:

The USP is legally bound to submit annual reports to the NRA on levels of consumer satisfaction

with the universal service, and to report on steps to improve its performance in identified areas. An

overview of the results is available in English at:

http://www.posturad.sk/en/customer-satisfaction

Slovenia:

The Agency conducts the research of user’s satisfaction/habits (general public and business public)

with postal services on an annual basis. It is done with the assistance of an external contractor. The

objective of such research is to establish the level of satisfaction with the quality of postal services,

user’s awareness of the variety of postal services and providers and to provide a range of comparable

data to the public and to the regulator.

http://www.akos-rs.si/raziskave-o-zadovoljstvu-uporabnikov

Sweden:

PTS makes annual telephone surveys of Swedish households’ use of and satisfaction with the postal

establishments.

http://www.pts.se/en-GB/Documents/Reports/Post/2014/The-Swedish-populations-use-of-postal-

services-2014---PTS-ER-20179/

Also, the USP conducts consumer satisfaction surveys and publishes the results.

http://www.posten.se/sv/Documents/PDF/postens%20service_och_kvalitet_2013.pdf http://www.postnord.com/globalassets/global/english/document/reports/annual-reports/2013/postnord-annual-report-2013.pdf (page 54)

http://www.rapus.rs/download/istrazivanje_izvestaj_fizicka_lica2013.pdf

http://www.rapus.rs/download/istrazivanje_izvestaj_pravna_lica2013.pdf

http://www.rapus.rs/o-nama/projekti

http://www.rapus.rs/o-nama/projekti

http://www.posturad.sk/en/customer-satisfaction


http://www.pts.se/en-GB/Documents/Reports/Post/2014/The-Swedish-populations-use-of-postal-services-2014---PTS-ER-20179/


http://www.posten.se/sv/Documents/PDF/postens%20service_och_kvalitet_2013.pdf

http://www.postnord.com/globalassets/global/english/document/reports/annual-reports/2013/postnord-annual-report-2013.pdf

http://www.postnord.com/globalassets/global/english/document/reports/annual-reports/2013/postnord-annual-report-2013.pdf


57

Switzerland:

USP conducts annual consumer satisfaction surveys and publishes the results :

http://www.poste.ch/en/post-startseite/post-konzern/post-publikationen/post-dossiers/post-pv-

poststellennetz/post-poststellennetz-kundenzufriedenheit.htm

United Kingdom:

Annual business and residential customer surveys are conducted by the NRA.

The survey data and accompanying technical report (a document detailing methodology, weighting

mechanisms, etc.) are published.

http://stakeholders.ofcom.org.uk/market-data-research/statistics/

http://www.poste.ch/en/post-startseite/post-konzern/post-publikationen/post-dossiers/post-pv-poststellennetz/post-poststellennetz-kundenzufriedenheit.htm

http://www.poste.ch/en/post-startseite/post-konzern/post-publikationen/post-dossiers/post-pv-poststellennetz/post-poststellennetz-kundenzufriedenheit.htm

http://stakeholders.ofcom.org.uk/market-data-research/statistics/


58

4.5. Surveys regarding customers’ needs

In terms of surveys regarding consumer needs and market, 13 NRAs (43%) answered that they

conduct such surveys, while the other 17 NRAs (57%) do not. This represents a slight increase in the

number of NRAs collecting data from 2013 (12 and 19 respectively in 2012). However, there had been

a decrease of the same amount in the previous year, so that the overall number of NRAs conducting

surveys regarding consumer needs and market remains static.

Table 26 - Surveys regarding customer needs


Do you conduct surveys

regarding customers’

needs or market surveys?

Yes 13 BE, CY, DK, FI, FR, EL, IE, LT, MT,

NL, RS, SE, UK 43%

No 17

AT, BG, CH, CR, DE, EE, ES, HR,

HU, IT, LU, LV, MK, NO, PL, RO,

SK

57%

The surveys are mostly carried out annually or on an ad hoc basis to serve regulatory needs. Usually,

the surveys are conducted by an independent body. Different methodologies are used, including

telephone interviews/computer-assisted telephone interviews (CATIs), standardised questionnaires,

and face-to-face interviews.

With regard to specific indicators as to consumer needs, 5 NRAs (FR, LT, RS, SE, UK) answered that

they had conducted special surveys to better understand the needs of postal users, or included

questions regarding costumers’ needs in a market or consumer satisfaction survey.

8 NRAs provided further details on the results of their respective surveys by way of web links. In

contrast, 4 NRAs answered that they do not conduct surveys regarding consumer needs. Greece and

Portugal conducted research in 2012, with Greece specifically targeting ‘habit and usage’ patterns of

business and private consumers. France and the United Kingdom undertook detailed studies to better

understand the needs of postal users in 2011 and 2013 respectively.

Table 27 -Links to research carried out to measure customer needs

Belgium

Survey regarding customer needs for professionals:

http://www.ibpt.be/nl/operatoren/post/universele-en-niet-universele-postdiensten/mededeling-van-

de-raad-van-het-bipt-met-betrekking-tot-de-enquete-over-de-universele-postdienst-in-belgie-gedrag-

en-wensen-van-de-professionele-gebruikers

Ireland


http://www.dict.cc/englisch-deutsch/standardized.html

http://www.dict.cc/englisch-deutsch/questionnaire.html

http://www.ibpt.be/nl/operatoren/post/universele-en-niet-universele-postdiensten/mededeling-van-de-raad-van-het-bipt-met-betrekking-tot-de-enquete-over-de-universele-postdienst-in-belgie-gedrag-en-wensen-van-de-professionele-gebruikers





59

Lithuania

The NRA does not conduct special surveys on customer needs. Certain questions related to customer

needs are included in the surveys on consumer satisfaction.

http://www.rrt.lt/download/16986/ataskaita%20-%20rrt%20201210(2).ppt Malta

http://www.mca.org.mt/consumer/surveys/consumer-perception-survey-households-postal-


http://www.mca.org.mt/consumer/surveys/micro-businesses-perception-survey-postal-


http://www.mca.org.mt/service-providers/surveys/large-bulk-mailers-perception-survey-postal-


Serbia:

Studies conducted in 2011 to better understand the needs of postal users

http://www.rapus.rs/download/Istrazivanje-Izvestaj-Pravna_lica-2011.pdf


Slovenia

The Agency conducts the research of user’s satisfaction/habits (general public and business public) with postal services on an annual basis. It is done with the assistance of an external contractor. The objective of such research is to establish the level of satisfaction with the quality of postal services, user’s awareness of the variety of postal services / providers and to provide a range of comparable data to the public and to the regulator. Although user’s needs are not specifically targeted they

could be identified through general public and business public responsed and data. Additionally the Agency is conducting also a market survey on an annual basis.


http://www.akos-rs.si/analize-trga-postnih-storitev

Sweden

The Agency conducts the research of user’s satisfaction/habits (general public and business public)

with postal services on an annual basis. It is done with the assistance of an external contractor. The

objective of such research is to establish the level of satisfaction with the quality of postal services,

user’s awareness of the variety of postal services/providers and to provide a range of comparable data

to the public and to the regulator. Although user’s needs are not specifically targeted they could be

identified through general public and business public response and data. Additionally the Agency is

conducting also a market survey on an annual basis

http://www.pts.se/en-GB/Documents/Reports/Post/2014/The-Swedish-populations-use-of-postal-

services-2014---PTS-ER-20179/




http://www.akos-rs.si/analize-trga-postnih-storitev




60

United Kingdom

As part of its statutory duties under the Postal Services Act 2011, Ofcom was required to assess the

extent to which the postal market meets the reasonable needs of users. To understand the needs of

users, Ofcom commissioned extensive deliberative and quantitative research. The findings were

published in March 2013.

http://stakeholders.ofcom.org.uk/consultations/review-of-user-needs/

http://stakeholders.ofcom.org.uk/consultations/review-of-user-needs/


61

5. Current situation on the assessment of complaint handling procedures and consumer

protection

The complaint handling and consumer protection have been analysed with a view to the following 5

dimensions:

1° scope and competence of NRAs regarding complaint handling

2° information provision and access to complaint handling and dispute resolution

3° implementation of standard EN 14012:2008

4° compensation schemes for individual customers

5° collection of data on complaints

5.1. Scope and competence of NRAs regarding complaint handling

This chapter deals with the legal framework on complaint handling. First of all, it illustrates in some

more detail the respective legal basis as set within the Postal Directives. Secondly, it evaluates the

scope and competence of the NRAs in handling complaints about postal services and it looks at the

other organisations to which a customer75

can address himself in case of a complaint.

5.1.1. Scope

This section analyses the legal basis with regard to postal users’ complaints as set out in the Postal

Directive. It recalls the basic principles enshrined within this legal framework. Furthermore, it

elaborates on the respective recitals dealing with the issue of consumer protection/complaint

procedures. Finally, this section refers to two Commission recommendations dealing with principles

which are applicable to bodies responsible in the area of out-of-court settlement consumer disputes.

Article 19, subparagraph 1, of the Postal Directive stipulates that “Member States shall ensure that

transparent, simple and inexpensive procedures are made available by all postal service providers for

dealing with postal users' complaints, particularly in cases involving loss, theft, damage or non-

compliance with service quality standards (including procedures for determining where responsibility

lies in cases where more than one operator is involved), without prejudice to relevant international and

national provisions on compensation schemes”.

Furthermore, Article 19, subparagraph 2, of Directive 2008/6/EC provides that “Member States shall

adopt measures to ensure that the procedures referred to in the first subparagraph enable disputes to be

settled fairly and promptly with provision, where warranted, for a system of reimbursement and/or

compensation. Member States shall also encourage the development of independent out-of-court

schemes for the resolution of disputes between postal service providers and users.”

75 “Customer” has a broader meaning, so that it can include customer or user


62

Finally, it is required to “ensure that users, acting individually or, where permitted by national law,

jointly with organisations representing the interests of users and/or consumers, may bring before the

competent national authority cases where users' complaints to undertakings providing postal services

within the scope of the universal service have not been satisfactorily resolved”. (Article 19 (2)).

Within recital 42 of Directive 2008/6/EC, the following further information is provided with regard to

consumer protection/complaint procedures: “In line with existing rules in other service areas and in

order to increase consumer protection, it is appropriate to extend the application of minimum

principles concerning complaint procedures beyond universal service providers.”

Furthermore, and with regard to the issue of complaint handling procedures, this recital is referring to

two Commission recommendations dealing with principles which are applicable to bodies responsible

in the area of out-of-court settlement consumer disputes. Within these recommendations, various

principles such as independence/impartiality, transparency, effectiveness, fairness and legality are

stated and explained in more detail. They should be observed by the responsible bodies for out-of-

court settlement of disputes. In this context, the recital states that “with a view to increasing the

effectiveness of complaint handling procedures, it is appropriate to encourage the use of out-of-court

settlement procedures as set out in Commission Recommendation 98/257/EC, of 30 March 1998, on

the principles applicable to the bodies responsible for out-of-court settlement of consumer disputes,

and in Commission Recommendation 2001/310/EC, of 4 April 2001, on the principle for out-of-court

bodies involved in the consensual resolution of consumer disputes.”76

5.1.2. Competence

This section analyses the competence of the NRAs in handling complaints about postal services.

Table 28 on next page shows that in 25 (81%) out of the 31 responding countries, the NRA is

generally responsible for dealing with user complaints. In three of these countries (10%), the NRA

only handles complaints with regard to the Universal Service while, in the vast majority (71%), all

postal service issues can be addressed. 5 (16%) NRAs stated that they are not obliged to handle user

complaints.

These results represent a slight decrease in the number of NRAs dealing with complaints in

comparison to 2012, when 26 NRAs were responsible for this issue and only 3 were not.

In the Netherlands, the NRAs is not legally obliged to deal with user complaints, but it does so in case

it assumes that postal law may be alluded.

76 As set out in Commission Recommendation 98/257/EC of 30 March 1998 on the principles applicable to the bodies

responsible for out-of-court settlements of consumer disputes (OJ L 115, 17.4.1998, p. 31) and in Commission

Recommendation 2001/310/EC of 4 April 2001 on the principles for out-of-court bodies involved in the consensual

resolution of consumer disputes (OJ L 109, 19.4.2001, p. 56).


63

Table 28 - NRA responsible for complaints

All postal service

issues

Universal service

issues only Other situations None

Austria x

Belgium x

Bulgaria x

Croatia x

Cyprus x

Czech Republic x

Denmark x

Estonia x

Finland x

FY R. Macedonia x

France x

Germany x

Greece x

Hungary x

Italy x

Latvia x

Lithuania x

Luxembourg x

Malta x

Netherlands x

Norway x

Poland x

Portugal x

Romania x

Serbia x

Slovakia x

Slovenia x

Spain x

Sweden x

Switzerland x

United Kingdom x

Total 22 3 1 5

71% 10% 3% 16%


64

Table 29 below indicates which procedures are in place to resolve complaints according to the services

and the provider.

Table 29 - Procedures in place to resolve the issue complained

Services

provided by the

USP inside the

universal service

area

Services provided

inside the

universal service

area by postal

operators other

than the USP

Services provided

by the USP

outside the

universal service

area

Services provided

outside the

universal service

area by postal

operators other

than the USP

No

Austria X X X X

Bulgaria X X X X

Croatia X X X X

Cyprus X X X X

Czech Republic X X X X

Denmark X X X X

Estonia X X X X

Finland X

FY R. Macedonia X X X X

France X X X X

Germany X X

Greece X X X X

Hungary X X X X

Italy X X X X

Latvia X X X X

Lithuania X X X X

Luxembourg X X X X

Malta X X X X

Netherlands X X X

Portugal X

Serbia X X X

Slovakia X X X X

Slovenia X

Spain X X

Sweden X X X X

Switzerland X X X X

Total 25 22 21 21 1

96% 85% 81% 81% 4%

Except for those NRAs, who stated that they are not responsible for dealing with complaints, only one

(4%) does not have procedures in place to resolve the issue complained. The majority of these NRAs

(21 of the 26 or 81%) use its procedures to handle complaints with regard to all kinds of postal

services - be it inside or outside the scope of the Universal Service - provided by the USP or by any

other postal operator


65

5.2 Information provision and access to complaint handling and dispute resolution

This chapter analyses the information available for users on complaint handling procedures, redress

schemes and means of dispute resolution as well as on the number of complaints received by postal

service providers and the NRAs. It also looks at the existence of regulation on complaint.

Table 30 below indicates of postal service providers are obliged to publish information about

procedures to complain, redress schemes and means of dispute resolution

Table 30 – Postal service providers obliged to publish information about procedures to complain, redress schemes and

means of dispute resolution

Procedures to

complain

Compensation/redress

schemes

Dispute resolution

(e.g. ADR) No

Austria X

Belgium X X

Bulgaria X X

Croatia X X

Cyprus X X

Czech Republic X

Denmark X

Estonia X X X

Finland X

FY R. Macedonia X X X

France X X X (only USP)

Germany X

Greece X X X

Hungary X X

Ireland X X X

Italy X X X

Latvia X X

Lithuania X X

Luxembourg X X

Malta X X

Netherlands X

Norway X X

Poland X X

Portugal X X X

Romania X X

Serbia X X

Slovakia X X

Slovenia X

Spain X X X

Sweden X

Switzerland X X

United Kingdom X X X

Total 27 25 10 5

84% 78% 31% 16%


66

There have not been major changes in the number of countries obliging the postal service providers to

publish information. In most countries, universal postal service providers are generally obliged to

publish information about complaint handling procedures and redress schemes, which was mentioned

by 27 (84%) and 25 (78%) of the NRAs, respectively. In fewer countries 10 (31%), there is an

obligation covering information on means of dispute resolution.

Table 31 below shows of postal service providers are covered by the obligation to publish information

about procedures to complain, redress schemes and means of dispute resolution.

Table 31 – Postal service providers covered by the obligation to publish information about procedures to complain,

redress schemes and means of dispute resolution

USP

Other postal service providers

active in the universal service Other postal service providers

Austria

Belgium X X X

Bulgaria X X X

Croatia X X X

Cyprus X X X

Czech Republic X X X

Denmark

Estonia X X

Finland X


France X X (except for dispute resolution) X (except for dispute resolution)

Germany

Greece X X X

Hungary X X X

Ireland X X X

Italy X X X

Latvia X

Lithuania X X X

Luxembourg X X

Malta X X X

Netherlands

Norway X

Poland X X X

Portugal X X X

Romania X

Serbia X X

Slovakia X X X

Slovenia X X X

Spain X

Sweden

Switzerland X X X


Total 27 17 19

84% 53% 59%


67

In most cases the obligation to publish information also (partially) extends to other postal service

providers. The USP is the only provider obliged to publish any information with regard to the above-

mentioned issues in only 5 countries.

Table 32 below indicates which postal services are subjected to regulation of regulation of complaint

handling procedures.

Table 32 – Regulation of complaint handling procedures

USP

Other postal service

providers active in the

universal service


providers No

Austria X

Belgium X X X

Bulgaria X X X

Croatia X X X

Cyprus X X X

Czech Republic X X X

Denmark X

Estonia X

Finland X


France X X X

Germany X

Greece X X X

Hungary X X X

Ireland X X X

Italy X X X

Latvia X X X

Lithuania X X X

Luxembourg X

Malta X

Netherlands X

Norway X

Poland X X X

Portugal X X X

Romania X X X

Serbia X X

Slovakia X X X

Slovenia X X X

Spain X X X

Sweden X

Switzerland X

United Kingdom X X

Total 25 20 20 7

78% 63% 63% 22%


68

The postal services providers’ complaint handling procedures are regulated in the majority (25

countries, or 78%) of the cases. 7 (22%) out of the 32 responding NRAs stated that a regulation does

not take place. This represents a slight increase in the number of countries having these procedures

being regulated (21 out of 30 in 2012).

The regulation covers the USP in all cases. Other services providers active within the scope of the

universal service and other operators providing services outside the universal service scope are

covered in 20 (63%) cases respectively.

Table 33 below shows the scope of the regulation on complaint handling procedures.

Table 33 – Scope of the regulation on complaint handling procedures

Principles for

complaints

handling

Channels for

lodging

complaints

Deadlines for

answering to

complaints

Access conditions

to dispute

resolution

Other

Austria

Belgium X X

Bulgaria X X X

Croatia X X X X

Cyprus

Czech Republic X

Denmark

Estonia

Finland X

FY R. Macedonia X X X X

France X X X X

Germany

Greece X X X X

Hungary X X X X

Ireland X X X X

Italy X X X X

Latvia X X X X

Lithuania X X

Luxembourg

Malta X

Netherlands

Norway X X X

Poland X X X

Portugal X x

Romania X

Serbia X X X

Slovakia X X

Slovenia X X

Spain X X X X X

Sweden

Switzerland X X X X


Total 21 15 18 11 4

65% 47% 56% 34% 2%


69

The scope of the regulation on complaint handling procedures varies between the countries. In most

cases the principles for complaint handling and the deadlines for answering to complaints are

regulated, in 21 countries (65%) and 18 (56%) respectively. 15 countries (47%) or NRAs answered

that the postal service providers’ channels for lodging complaints are subject to regulation and in 11

countries (34% of cases) the conditions of access to dispute resolution are regulated.

Table 34 below indicates of an Alternative dispute resolution (ADR) exists and which kind.

Table 34 - Alternative (or out-of-court) dispute resolution (ADR)

Yes, Mandatory77 YES, Voluntary78 No

Austria X

Belgium X

Bulgaria X

Croatia X

Cyprus X

Czech Republic X

Denmark X

Estonia X

Finland X

FY R. Macedonia X

France X

Germany X

Greece X

Hungary X

Ireland X

Italy X

Latvia X

Lithuania X

Luxembourg X

Malta X

Netherlands X

Norway X

Poland X

Portugal X X

Romania X

Serbia X

Slovakia X

Slovenia X

Spain X

Sweden X

Switzerland X

United Kingdom X

Total 11 14 8

33% 43% 24%

77 Mandatory: operator is obliged to accept the dispute resolution through ADR 78 Voluntary: operator is not obliged to accept the dispute resolution through ADR


70

Most countries have Alternative Dispute Resolution (ADR). This can be either general or specific to

the postal sector. ADR is voluntary in 14 (43%) countries, whilst it is mandatory in 11 (33%)

countries.


71

5.3. Implementation of Standard EN 14012: 2008

This chapter presents data on the situation regarding the implementation of the CEN Standard EN

14012:2008 (Postal Services - Quality of Service - Complaints handling principles) by postal service

providers.

Figure 16 indicates that almost half the respondent NRAs (45%) indicated that the USP has

implemented the CEN standard. However, concerning other postal service providers active in the

universal service area, the standard is only implemented in 2 countries ( 6%) and is not implemented

in any country for other postal service providers. The majority of NRAs (55%) indicated that the

standard has not been implemented by any service provider.

These results show an increase in the number of countries where the standard has been implemented

by the USP (14 out of 31 against 10 out of 30 from the data collected in 2013). The situation remains

the same in what concerns other postal service providers.

Figure 16 – Implementation of standard EN 14012:2008 79 80

79 NRAs notes:

BE: partly

CH: Only some parts of the EN 14012.

CZ: The USP uses some methods described in this standard, but there is no obligation to use it for any provider.

EL: USP concerning complaints handling is certificated with EN ISO 9001:2008,

www.elta.gr/Portals/0/pdf/Pistopoiitiko2.pdf.

ES: The USP states that compliance with this rule, but this has not been audited by the NRA.

IE: Currently USP measures according to 14012:2003.

HU: Other postal service providers active in the universal service provide “postal services substituting the US” and at present

only the USP is active there, and implemented EN 14012:2008 for business letters belonging to this category.

IR: Currently USP measures according to 14012:2003.

NL: Not in the sense that it is legally required. We have no information on whether the USP or other PSP’s apply this

standard and measure the outcomes.

PT: Although the NRA did not determine the USP to implement EN 14012, the NRA did: (i) determine that the classification

of complaints consider EN 14012; (ii) recommend that future evolution of the complaints handling system to take into

consideration EN 14012.

SE: The standard is used by the USP but it is not implemented as a regulatory measure. 80 Source ERGP (31 NRAs).

14 (45,2%)

2 (6,5%)

17 (54,8%)

0

2

4

6

8

10

12

14

16

18

Yes, by the USP (BE, CH, DK, ES,

FR, HR, HU, LT, MT, PT, SE, SI,SK, UK)

Yes, by other postal service providers

active in the universal service (HU,UK)

No (AT, BG, CY, CZ, EE, FI, FY,

EL, IE, IT, LV, LU, NL, NO, PL,RO, RS)

Nu

mb

er o

f co

un

trie

s

Answers

http://www.elta.gr/Portals/0/pdf/Pistopoiitiko2.pdf


72

5.4. Compensation schemes for individual customers

In this chapter the scope of the existing compensation schemes is analysed.

In most countries (17 out of 31), an obligation for a specific compensation scheme exists and covers

the USP in almost all of them; in most of them (14 out of 31), this also extends to other postal service

providers. These results show that no significant change occurred in this field when compared with the

data collected in 2013.

When asked to explain why there is no obligation on this matter, the countries that were in this

situation (13) mentioned as reasons the following: the scope of liability is covered by general terms

and conditions and civil law (AT); cases which are not solved by the postal law are judged by a court

(CZ); we are in the process of implementing such scheme (CY); the NRA makes sure that the postal

operators publish their compensation conditions (DK); postal service providers are free to set their

own compensation scheme in their standard conditions - for licensed services these conditions have to

be co-ordinated with the NRA (EE); one of several reasons why the NRA has not deemed it necessary

to introduce an obligation for a specific compensation scheme is that the USP's policy is to always

follow the decisions of The National Board for Consumer Disputes (ARN) (SE). Figure 17 - Mandatory compensation schemes for individual customers 81 82 83

81 NRAs notes: DK: The USP however is liable to pay compensation for delays, loss or damage of domestic items covered by

the universal service, provided the delays, loss or damage are due to intentional or negligence attributable to the USP. 82 ERGP (31 NRAs) 83 RO answered “yes”, but did not indicate which service providers are covered.

17 (56,7%)

14 (46,7%) 14 (46,7%) 13 (43,3%)

0

2

4

6

8

10

12

14

16

18

YES, for the USP (BG, EL,

ES, FR, FY, HR, HU, IE, IT,LU, LV, MT, PL, RS, SI, SK,

UK)

YES, for other postal service

providers active in theuniversal service (BG, EL,

ES, FR, FY, HR, HU, IE, IT,

LU, LV, PL, SI, SK)

YES, for other postal service

providers (BG, EL, ES, FR,FY, HR, HU, IE, IT, LV, PL,

RS, SI, SK)

NO (AT, BE, CH, CY, CZ,

DE, DK, EE, LT, NL, NO,PT, SE)

Nu

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Answers


73

Figure 18 below shows if a compensation schemes exist for individual customer and for which type of service failure.

Figure 18 – Existing compensation schemes for individual customers by type of service failure 84

For 22 NRAs, existing compensation schemes cover, for the USP, items lost or substantially delayed

and items damaged. Items arriving late were mentioned as being covered by 14 NRAs. In most of

these countries compensations schemes also cover these types of service failures for other postal

service providers (active or not in the universal service area).

84 NRAs notes:

EE: Item arriving late applies only for express mail.

EL: USP: only registered items are compensated (since only these are tracked). COURIER: all items are compensated (since

all are tracked and traced).

LT: There are no specific requirements for compensation schemes of substantially delayed postal items.

PT: For the USP, existing compensations schemes derive from the regime established by articles 77 to 83 of Decree-Law no.

176/88, of 18 May, which approves the Regulation for Public Postal Service, referring to registered mail, to mail with

declared value and parcels. For other postal services there is no specific legal regime applicable. However the Portuguese

Postal Law no 17/2012, of 26 April (article. 41, paragraph 1 b)) states a principle of adequacy of reimbursement and

compensation systems to be established by postal service providers.

SE: All these categories are at least in some degree covered by existing compensation schemes.

SI: The compensation scheme is covering damage caused during the routing of registered and insured postal items and postal

parcels due to: (1.) loss, damage, theft or robbery; (2.) exceeding the time limit for routing; (3.) unexecuted or incompletely

or incorrectly executed postal services.

SK: (Item lost or substantially delayed covers) Only lost recorded items, only substantially delayed express items.

0 2 4 6 8 10 12 14 16 18 20 22 24

Other

How complaints are treated

Mis-delivery

Mail delivery or collection

Change of adress

Item damaged

Item arriving late

Item lost or substantially delayed

Number of countries

Ty

pes

of

servic

e f

ail

ure

Other postal service providersOther postal service providers active in the universal serviceUniversal service provider


74

Table 35 – Cover of existing compensation schemes85

Universal service provider Other postal service

providers active in US


providers


BG, EE, EL, ES, FR,

FYROM, HR, HU, IE, IT, LT,

LU, LV, MT, NO, PL, PT, RO, RS, SI, SK, UK

BG, EL, ES, FR, FYROM,

HR, HU, IE, IT, LT, LU, LV,

PL, RO, SI, SK

BG, EE, EL, ES, FR, FYROM,

HR, HU, IE, IT, LT, LV, PL,

RS, RO, SI, SK

Item arriving late

BG, FR, FYROM, HR, HU,

IE, IT, LU, NO, PL, PT, RS,

SI, UK

BG, FR, FYROM, HR, HU,

IE, IT, LU, PL, SI


HR, HU, IE, IT, PL, RS, SI

Item damaged

BG, HR, LV, RO, EL, EE, ES,

FYROM, PT, FR, HU, IE, IT, LT, MT, NO, PL, RS, SI, SK,

UK, LU


HR, HU, IE, IT, LT, LU, LV, PL, RO, SI, SK

BG, EE, EL, ES, FR, FYROM,

HR, HU, IE, IT, LT, LV, RO, PL, SK

Change of address - - -

Mail delivery or collection IE, IT, SI IE, IT, SI IE, IT, SI

Mis-delivery ES, IE, IT, LT, PT, RS, SI IE, IT, LT, SI IE, IT, LT, RS, SI

How complaints are treated IE, IT, PL IE, IT, PL IE, IT, PL

Other IE IE IE

NRAs were also asked to indicate how, when and what level of compensation is paid by postal service

providers, having pointed out that all these aspects differ significantly depending on the type of service

failure. Most NRAs indicated that these aspects were determined by law and/or established in general

terms and conditions for the provision of services.

The table 35 below lists some country examples.

Table 36 – Compensation schemes

Country Compensation schemes

DK

Loss or damage is maximal recoverable by the value of the content value, delays are maximal recoverable by shipment

costs. Shipment to and from abroad are covered by the rules of the UPU or the agreements reached by the concerned postal operator.

EL

USP: only registered items are compensated (since only these are tracked). COURIER: all items are compensated (since all are tracked and traced).

For (the above items) the level of compensation is:

1. For a lost, stolen or completely destroyed envelope : from 50-70 € (plus credit the initial postal charge to customer) 2. For a lost, stolen or completely destroyed parcel: from 100-400 € (plus credit the initial postal charge to customer)

3. Categories 1 and 2 that in addition are insured : the above compensation plus the insured amount of money

4. Envelope or parcel partially lost, stolen or destroyed: the compensation amount is equivalent to the value of the lost, stolen or destroyed part provided that the compensation does not exceed the compensation amount of the categories 1 and

2.

5. Category 4. that in addition is insured: the compensation amount is equivalent to the value of the lost, stolen or destroyed part provided that the compensation does not exceed the compensation amount of category 3.

6. Non-delivered postal item: credit the postal charges to consumer 7. Delay in delivery (only applies for courier): 6 € for each day of delay

8. Delay in delivery that exceeds five times the agreed delivery time: 6 € for each day of delay (plus credit the postal

charges to consumer)

FR

Principles and terms of compensation (cases, level of compensation) are provided by national legislation, for example:

1) Loss or damage Ordinary mail: compensation = twice the postage tariff

Registered mail: compensation = 16€

85 Source: ERGP (22 NRAs)


75

Parcels: 23€/kg

2) Delay: compensation = the postage tariff

Postal service providers can provide higher levels of compensation.

FYROM

It depends on the type of item; (a) loss or complete damage:

- For insured postal items, the amount of the marked value;

- for registered postal items and parcels, 15 times the amount paid for the service; b) partial damage or reduction of the item content:

- for insured postal items, the amount of the real value of the damage, but not higher than the marked value;

- for registered postal items and parcels, 10 times the amount paid for the service; c) exceeding the deadline for delivery of:

- priority postal items, 10 times the amount paid for the service;

- non-priority postal items, 5 times the amount paid for the service;

HU

(1) Flat rate compensation: Registered postal item destructed, lost in whole or in part or damaged.

a) destructed or lost in whole, flat rate compensation is fifteen times the fee charged for the service, b) Partially lost or damaged, flat rate compensation proportioned to the entire amount specified in paragraph a) in the same

manner as the damage caused proportioned to the full value of the postal item.

(2) In the event specified under paragraph (1) a), the postal service provider shall also repay the charge paid for the service. (3) Compensation: Insured item destructed, lost in whole or in part or damaged:

a) Destroyed or lost in whole, the compensation is the amount specified in the value guarantee.

b) Partially lost or damaged, the compensation proportioned to the amount specified in the value declaration for insurance in the same manner as the damage caused proportioned to the full value of the postal item.

(4) Flat rate compensation for the delayed delivery of a guaranteed delivery time postal item. The amount of the flat rate

compensation is twice the fee paid for the guaranteed delivery time postal service.

IE

ComReg has recommended that a compensation scheme would apply in respect of any loss, theft, or damage to a postal packet or any failure to provide a postal service of sufficient quality and that compensation will include a refund of the cost

of postage; recompense for the cost of any wrapping or protective material used in the postal packet; and recompense for

any other relevant and reasonable costs incurred.

ComReg has also recommended that postal service providers provide some redress to postal service users who have made a

complaint when the response times and /or maximum handling times are not met. See: ComReg Document 14/06

LT

Where, through the fault of a postal service provider, postal items are lost or damaged, articles (merchandise) are missing or

damaged therein or the articles (merchandise) are damaged, the postal service provider shall pay compensation: 1) for a lost registered postal item as well as for a part of lost or damaged articles (merchandise) contained or all damaged

articles (merchandise) contained therein – twice the amount of posting expenses;

2) for a lost insured postal item – an amount equal to posting expenses plus insured value; 3) for a part of lost or damaged articles (merchandise) in an insured postal item accompanied by a list of articles

(merchandise) – an amount equal to posting expenses and the value of the lost or damaged article (merchandise) indicated in

the list, which in no case shall exceed the insured value of the whole insured postal item.

LU The compensation for loss has to be a multiple of the amount paid as compensation for delay.

MT

COMPENSATION LIMITS

LOCAL

DOMESTIC SERVICES MAXIMUM COMPENSATION LIMIT

Ordinary Items 12 x Stamp Value per Item

Registered Items 30 SDRs* Maximum (approx. €33)

Parcel Items 40 SDRs* per parcel plus 4.5 SDRs per kg*(approx. €45 per parcel,

plus €5 per kg)

FOREIGN

INTERNATIONAL SERVICES MAXIMUM COMPENSATION LIMIT

Ordinary Items N/A

Registered Items 30 SDRs* Maximum (approx. €33)

Ordinary Parcels 40 SDRs* per parcel plus 4.5 SDRs per kg* (approx. €45 per parcel, plus €5 per kg)

* As per Universal Postal Union (UPU) Regulations More information on the Compensation Schemes offered by the USP is available from the following link:

http://www.maltapost.com/committed-to-deliver

NL

Level of compensation is limited by administrative order of 25 March 2009 to an amount of € 50 for registered items and €

1.500 for insured items. Article 29 of the Postal Act states:

1. A Universal Postal Service Provider shall only be liable for damage resulting from the loss of, damage to, or delayed

delivery of domestic Postal Items if the Sender makes use of a manner of conveyance whereby a Postal Item is registered according to rules to be set forth in the general terms and conditions of the Postal Conveyance Company.

2. The liability referred to in paragraph 1 of this article shall not apply if the damage incurred results solely from one or

more of the following circumstances: a. the nature of or a defect in the item conveyed;

http://www.comreg.ie/_fileupload/publications/ComReg1406.pdf

http://www.maltapost.com/committed-to-deliver


76

b. inadequate packaging of the item by a party other than a Universal Postal Service Provider or its subordinates;

c. a cause attributable to the Sender;

d. an act of war or armed conflict; e. seizure on the instructions of an authority competent to order such seizure.

3. Claims may be submitted solely by the Sender. If the damage has been incurred by a party other than the Sender, the

Sender shall be entitled by operation of law to bring the claim on behalf of that other party, either in the Sender’s own name or as the representative of the said party.

4. Amounts may be determined by a general administrative order above which liability within the meaning of paragraph 1

of this article shall not extend, whereby the size of the separate amounts may be determined according, for example, to the type of registration or the nature and value of the Postal Item concerned.

5. A Universal Postal Service Provider shall not be entitled to invoke an exclusion or restriction of its liability ensuing from

the previous paragraphs of this article if the damage incurred is the result of its own act or omission, with such having

occurred either with intent to cause the said damage or due to recklessness and in the knowledge that the said damage would

be likely to result.

6. A Universal Postal Service Provider shall only be liable in respect of the Postal Conveyance from or to areas outside the Netherlands in accordance with the provisions of the Acts of the Universal Postal

Union or other treaties or decisions of international institutions that are binding for the Netherlands.

7. Any stipulation that provides for a departure from this article shall be legally void.

NO

According to the postal regulation there shall be compensation for registered items, for unregistered items. The USP is only obliged to have a compensation scheme if the item is lost etc. due to gross negligence (by the USP). The compensation

amounts are limited.

PL The level of compensation varies according to the type of the service failed. In general, the operators are responsible for

non-performance or improper performance both of universal postal service and of service not being universal postal service.

PT For the USP, please see the regime foreseen by articles 77 to 83 of Decree-Law no. 176/88, of 18 May, which approves the

Regulation for Public Postal Service, available at www.anacom.pt/render.jsp?contentId=980542&languageId=1.

SI

The Postal Service Act requires that the maximum indemnity for:

1. loss, damage, theft or robbery of an insured item shall be the postal item’s stated value;

2. loss or theft of a postal parcel or of a registered postal item shall be the price paid for the executed postal service

multiplied by a factor of 15;

3. theft or damage of a postal parcel or of a registered postal item shall be the price paid for the executed postal service multiplied by a factor of 10;

4. unexecuted, incomplete or incorrectly executed postal service relating to the routing of a registered and insured postal

item or postal parcel shall be the price paid for the executed postal service; 5. exceeding the time limit for routing of a registered and insured postal item and of a postal parcel shall be the price paid

for the executed postal service;

6. loss of a postal item with receipt shall be the price paid for the executed postal service. (3) In cases under points 1, 2 and 3 of the preceding paragraph, the user of postal services shall be entitled to reimbursement

of the price paid for routing of the postal item, excluding the part of the price relating to postal item insurance.

(4) Notwithstanding the provisions of the second paragraph of this article, the highest possible indemnities for cross-border postal items shall be determined in accordance with the provisions of Universal Postal Union acts applicable in Slovenia.

(5) A postal service provider shall on no account be held liable for indirect damage or profits lost.

SK

The sender is entitled to a compensation for damage, for which the postal company is liable according to § 38 of the Postal

Act, to the following extent:

a) twenty times the postal charge for the service “registered” according to the tariff in the case of failure to deliver a

registered item or destruction of its content;

b) the actual damage, up to the double the lowest postal charge according to the tariff per 500 g of the content in the case of

failure to deliver an uninsured parcel, its damage or reduction of its content; c) the actual damage, up to the specified value, in the case of failure to deliver an insured item, its destruction or damage or

reduction of its content;

d) three times the postal charge paid in the case of a postal item with a guaranteed delivery period, which has not been delivered within the delivery period according to the postal terms and conditions.

http://www.anacom.pt/render.jsp?contentId=980542&languageId=1


77

Figure 19 below lists if there is a mechanism in place to make customers aware of compensation

schemes.

Figure 19 – Mechanisms in place to make customers aware of compensation schemes 8687

The majority of NRAs (24 out of 29) indicated that in their countries there are mechanisms in place to

make consumers aware that compensation schemes are available. Only 19 NRAs had answered

positively to this question in 2013.

86 NRAs notes: SE: Especially the website of the USP and NRA. 87 Source: ERGP (29 NRAs)

82,8%

17,2%

0

5

10

15

20

25

30

YES (BG, CZ, EE, EL, ES, FR, FY, HR, HU, IE, IT,

LT, LU, LV, MT, NO, PL, PT, RO, RS, SE, SI, SK,UK)

NO (AT, BE, CH, CY, DK)

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78

5.5. Collection of data on complaints

This chapter looks at the data that NRAs collect and make available on complaints about postal

services in general and, in particular, about cross-border services.

Figure 20 below indicates if the NRAs are collecting data on complaints and from which postal

providers.

Figure 20 – Collection of data on complaints by NRAs88

88 NRAs notes:

PT: The data refer to answered complaints by the USP

HU: This area is called “postal services substituting the US” and at present only the USP is active there with services that are

outside the scope of the USO and are not classified as non-US services.

BG: Data on the number of complaints vary according to cause.

IE: The NRA does not hold data for complaints to the USP, but relies on the information on complaints published by the USP

in its annual report. www.anpost.ie/NR/rdonlyres/98741681-6E66-4387-BAD9-

87994D06442D/0/AnPostAnnualReport2013Commentary.pdf.

28

16

11 10

13

21

10

7 6

7

16

6

3

1

3 4

16

19 20

17

0

2

4

6

8

10

12

14

16

18

20

22

24

26

28

30

Received by universal

service provider aboutUS

Received by universal

service provider aboutnon-US

Received by other postal

service providers activein the US about US


service providers activein the US about non-US


service providers

Nu

mb

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Answers

Yes By category By service No

http://www.anpost.ie/NR/rdonlyres/98741681-6E66-4387-BAD9-87994D06442D/0/AnPostAnnualReport2013Commentary.pdf

http://www.anpost.ie/NR/rdonlyres/98741681-6E66-4387-BAD9-87994D06442D/0/AnPostAnnualReport2013Commentary.pdf


79

Table 37 below shows from which operators and for which services the NRAs are collecting data on

complaints.

Table 37 – Data on the number of complaints89 90

Received by the universal

service provider


service providers active in

US


service providers

About US

Total

AT, BG, CH, CY, CZ, DK,

EL, ES, FI, FR, FYROM, HR, HU, IE, IT, LT, LU,

LV, MT, NO, PL, PT, RO,

RS, SE, SI, SK, UK

BG, DK, EL, FYROM, HU,

IT, LT, LU, PL, SI, UK

By category

CH, CZ, DK, EL, ES, FR,

FYROM, HR, HU, IE, IT,

LT, LV, MT, PL, PT, RS, SE, SI, SK, UK

DK, EL, HU, IT, PL, SI, UK

By service

CH, DK, EL, ES, FR, FYROM, HR, HU, IT, LT,

LV, NO, PT, RS, SI, UK

HU, IT, UK

No BE, DE, EE, NL

BE, CH, CY, CZ, DE, EE,

ES, FR, HR, IE, LV, MT, NL, NO, PT, RO, RS, SE,

SK

About non-US

Total

BG, CY, CZ, EL, FI, HU,

IE, IT, LT, LU, PL, NO, RO, RS, SK, UK

BG, CZ, EL, HU, IT, LT, LU, PL, SI, SK

BG, CY, CZ, DK, EL,

FYROM, HU, IT, LT, PL, RS, SI, SK

By category CZ, EL, HU, IE, IT, LT, PL, RS, SK, UK

CZ, EL, IT, PL, SI, SK CZ, DK, EL, IT, RS, SI, SK

By service EL, IT, LT, NO, RS, UK IT DK, IT, RS

No

BE, CH, DE, DK, EE, ES, FR, FYROM, HR, LV, MT, NL, PT, RS, SE, SI

BE, CH, CY, DE, DK, EE, ES, FR, FYROM, HR, IE, LV, MT, NL, NO, PT, RO, RS, SE, UK

BE, CH, DE, EE, ES, FR,

HR, IE, LU, LV, MT, NL, NO, PT, RO, SE, UK

Almost all respondent NRAs collect data on complaints received by the USP regarding universal

services (28 out of 32). 21 out of these indicated to collect data by category and 16 by service. Fewer

NRAs collect data on complaints received by the USP about non-universal services (16 out of 32).

The majority of NRAs do not collect data on complaints received by other postal service providers

active in the universal area about universal services or non-universal services (19 and 20 out of 32,

respectively). Besides, the majority of NRAs do not collect data on complaints received by other

postal service providers (17 out of 32).

The results this year show a similar situation to the one portrayed in 2013 in what regards the

collection of data on complaints by NRAs.

89

Source: ERGP (32 NRAs). 90

Note: “No” includes situations where other postal service providers active in US are not applicable.


80

Next figure 21 and table 38 show data on complaints received by the USP in 2012 and 2013 per

country and also data on these complaints by category. NRAs numbers on complaints about postal

services are also shown.

Figure 21 – Complaints received by USP on universal service, 2012-2013 (per country) 91

91 NRAs notes:

BG: Number of justified complaints.

CZ: The decrease in number of postal items is due to the fact that the USP sent data about all postal services in the year 2012,

not only about US.

ES: These data include a corresponding admission that is not part of the USO and cannot be identified. The corresponding

distribution part, however, is USO.

FR: Since 2009, the system in place ensures a better accounting of complaints submitted by customers thanks to a systematic

recording. Beside this, the USP systematically provides a compensation when parcels are not delivered within D+2, which

encourages postal users to complain

HU: Actual number of complaints: 23.492 because one complaint could have been classified into more categories by the

USP.

IE: These complaint statistics only relate to written complaints received and do not include complaints received by phone or

email. According to the annual report of An Post “In 2013, there were 514,698 telephone calls made to An Post Customer

Services. Most of these were routine or general enquiries rather than complaints”.

LT: Number of postal items is universal service items of USP. The essential difference between results of 2012 and 2013 is

due to the new Postal Law. According to it, bulk mail services were removed from the scope of the universal postal service.

PT: The values refer to answered complaints.

(a) “Item lost or substantially delayed” includes Item arriving late.

(b) “Change of address” includes redirection complaint.

(c) “Mail delivery includes complaints concerning delivery and mis-delivery.

(d) “Behaviour and competence of postal personnel” is included in “other complaints”.

UK: All complaints data published here:

www.royalmailgroup.com/customers/quality-service/quality-service-reports

0 200000 400000 600000 800000 1000000 1200000 1400000 1600000

United Kingdom

Sweden

Spain

Slovenia

Slovakia

Serbia

Romania

Portugal

Poland

Norway

Malta

Luxembourg

Lithuania

Latvia

Italy

Ireland

Hungary

Greece

France

Denmark

Czech Republic

Croatia

Bulgaria

Austria

Number of complaints

Co

un

trie

s

2013 2012

http://www.royalmailgroup.com/customers/quality-service/quality-service-reports


81

Table 38 - Complaints received by USP about universal service, 2012-2013 (per country)

2012 2013

Austria 176232 194815

Bulgaria 491 996

Croatia 27753 30105

Czech Republic 121988 105638

Denmark 9195 7013

France 1333958 1410665

Greece 9133 10886

Hungary 23918 24133

Ireland 23443 25815

Italy 44202 55025

Latvia 945 777

Lithuania 2659 1760

Luxembourg 2428 2903

Malta 1347 1424

Norway 70601 69665

Poland 175748 133894

Portugal 50196 54 056

Romania 1188 1585

Serbia 3048 1078

Slovakia 23429 22229

Slovenia 1889 1902

Spain 76252 65913

Sweden 75295 71929

United Kingdom 888882 /

Source: ERGP (23 NRAs)

Figure 22 and table 39 below compare the complaints received by USP about universal service by

category for the period 2012-2013.

Figure 22 – Complaints received by USP about universal service by category, 2012-2013

0 100000 200000 300000 400000 500000


Item arriving late

Item damaged

Change of address

Mail delivery or collection

Other complaints


Co

mp

lain

ts c

ate

go

rie

s

2013 2012


82

Table 39 – Complaints received by USP about universal service by category, 2012-201392 93

Item lost or

substantially

delayed

Item arriving

late Item damaged

Change of

address

Mail delivery or

collection Other complaints

2012 2013 2012 2013 2012 2013 2012 2013 2012 2013 2012 2013

Bulgaria 444 979 10 3 9 14 / / / / 34 0

Croatia 22900 22304 288 815 178 1 565 14 40 283 617 4090 4764

Denmark 1331 1055 801 638 7063 5230 0 / 0 / 0 90

Greece 353 73 14 61 11 56 / / / / 8755 60

Hungary 11130 10181 805 731 900 921 512 418 5050 5109 5521 6773

Ireland 18287 20630 351 346 980 1062 919 590 464 117 2297 2910

Latvia 91 93 14 64 103 128 3 18 346 209 388 265

Lithuania 1313 308 63 51 249 199 10 5 463 782 561 415

Malta 73 77 28 10 99 107 254 271 21 27 872 932

Norway 14304 15440 2487 2568 2664 3380 17662 13756 / / 33514 34521

Poland / 96488 / 152 / 1197 / / / / / 35432

Portugal 15114 17537 / / 1071 1236 735 1103 14307 14018 18969 20162

Serbia 3015 1039 8 13 25 26 / / / / 0 0

Slovenia 1437 1494 8 17 64 92 8 16 168 156 204 127

Sweden 44468 47272 4709 4512 5963 6379 / / / / 20155 13766

United

Kingdom 306106 / 35695 / 35543 / 81340 / 69888 / 330242 /

It should be taken into consideration that comparisons between years are not always rigorous because

the source of the data in each year is not exactly the same in some cases. Besides, comparisons

between countries have to bear in mind that the numbers may reflect differences in the legal and

regulatory frameworks, market volumes/structure, etc.

92 Source: ERGP (16 NRAs) 93 Note: Includes NRAs that had figures at least on 4 of the 6 categories selected. Categories were selected based on the

number of complaints and data availability.


83

Figure 23 and table 40 below compare the complaints received by NRAs on postal services for the

period 2012-2013.

Figure 23 – Complaints received by NRAs on postal services, 2012-2013 (per country) 94

Table 40 – Complaints received by NRAs on postal services, 2012-2013 (per country – source 18 countries)

2012 2013

Austria 59 69

Bulgaria 104 127

Cyprus 5 7

Czech Republic 382 164

Estonia 26 61

FYROM 30 20

France 53 71

Germany 1298 1228

Greece 172 203

Hungary 92 87

Italy 412 353

Lithuania 56 82

Malta 16 12

Portugal 9377 8300

Slovakia 38 77

Slovenia 19 32

Spain 182 173

United Kingdom 602 385

94 NRAs notes: CZ: Data from 2012 are only from the USP.

EE: Includes all complaints concerning any postal service (domestic and cross-border). ES: Refers to the universal postal services only.

UK: Ofcom does not have regulatory responsibility for handling and dealing with postal complaints from individual consumers. Ofcom does,

however, respond to complaints referred to it in cases where the postal operator has failed to resolve the complaint or where the complaint may potentially suggest there is a wider or more significant issue that may require regulatory intervention. The above figures represent those

directly received by the NRA from consumers as opposed to the total number of consumer complaints received by the USP as shown in table

6.10.1. In terms of the categories, Ofcom separates postal complaints into 58 categories. The complaint categories ticked above denote the

ones we record.

FYROM: The figures given in 2012 refer to the total number of complaints received by the Postal Agency.

PT: Portugal’s figures on complaints are largely justified by the existing law that states that all service provider must have a “complaints book” on every establishment opened to the public and that they have to, submitted to penalty, send to the NRA all the complaints fulfilled

on the complaints books (over 85% of the complaints received by the NRA are complaints presented through the “complaints book”).

0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000

United Kingdom

Slovenia

Portugal

Lithuania

Hungary

Germany

FYROM

Czech Republic

Bulgaria


Co

un

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s

2013 2012


84

It should be taken into consideration, when analysing the data shown in figure 23 and table 40, that the

numbers on complaints received by NRAs reflect not only the differences in the number of

users/postal items operated, but also in the scope of NRAs’ competences on complaint handling and

the legal framework applicable.

Figures 24 and 25 below show data on complaints about cross-border services collected by NRAs.

Figure 24 – Collection of data on complaints about cross-border services by NRAs (source 28 NRAs)

The majority of NRAs collect data on complaints about cross-border services (18 out of 28), all of

these at least for the USP numbers. Fewer NRAs collect this information with regard to other postal

service providers.

Figure 25 – Data on complaints about cross-border services received by NRAs (source 27 NRAs)

Turning to data on complaints about cross-border services received by the NRAs, there is almost an

even split between NRAs that have this information and NRAs that do not.

64,3%

14,3% 17,9%

35,7%

0

2

4

6

8

10

12

14

16

18

20

YES, by the universal

service provider (BG, CH,CZ, DK, EL, FYROM, HR,

HU, IT, LT, LV, MT, PL,

PT, RS, SE, SI, SK)

YES, by other postal service

providers active in theuniversal service (BG, CZ,

FYROM, IT)

YES, by other postal service

providers (CZ, FYROM, IT,RS, SK)

NO (AT, BE, CY, DE, EE,

FR, IE, NL, NO, RO)

Nu

mb

er o

f co

un

trie

s

Answers

51,9% 48,1%

0

2

4

6

8

10

12

14

16

YES (CH, CY, CZ, EE, EL, ES, FYROM, HR,

HU, IT, LT, LV, MT, PT)

NO (BE, BG, DE, DK, FR, IE, NL, NO, PL, RS,

SE, SI, SK)

Nu

mb

er o

f co

un

trie

s

Answers


85

Figure 26 and table 40 below give figures on the complaints received by USPs about cross-border

services per country. Complaints about cross-border services seem to have grown between 2012 and

2013 in most countries, except for Denmark, Lithuania and Sweden. Nevertheless, it should again be

considered that differences between the figures per country can reflect differences in the markets and

legal frameworks at national level.

Figure 26 – Complaints received by the USP on cross-border services, 2012-2013 (per country) 95

Table 41 – Complaints received by the USP on cross-border services, 2012-2013 (per country – source 16 NRAs)

2012 2013

UN % UN %

Bulgaria 457 53 984 82

Croatia 5416 / 6773 /

Czech Republic / / 109 10,32

Denmark 3721 40,5 2504 35,7

FYROM 1258 27,3 1930 47,7

Greece 8188 90 9596 89

Hungary 4106 17.5 5158 21,4

Italy 23931 12,9 29212 14,5

Latvia 146 15,5 202 26

Lithuania 1616 60,8 595 33,8

Malta 7 0,52 2 0,14

Poland 33210 18,9 / /

Portugal 17398 34,7 22029 40,7

Serbia 12 0,004 12 0,011

Slovakia 9405 17,09 11348 21,9

Slovenia 386 10,22 345 18,13

95 NRAs notes:

CZ: We do not have data from 2012. Regarding other postal providers we do not distinguish whether the complaints concern US or other

services. HU: only US.

PT: The values refer to answered complaints.

0 5000 10000 15000 20000 25000 30000 35000

Sweden

Slovenia

Slovakia

Serbia

Portugal

Poland

Malta

Lithuania

Latvia

Italy

Hungary

Greece

FYROM

Denmark

Czech Republic

Croatia

Bulgaria


Co

un

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s

2013 2012


86

Sweden 25050 24 21331 29

6 Conclusions on the current practices of the NRAs regarding the quality of service

regulation, complaint handling procedures and consumer protection

To ensure compliance with the obligations arising from the Postal Directives, two particular tasks are

usually assigned to national regulatory authorities (NRAs):

- the follow-up of quality of service issues and end-user satisfaction

- the follow-up of complaint handling procedures and consumer protection.

In this report the ERPG has collected core indicators and instruments to monitor the quality of service

and end-user satisfaction, on the one hand, and complaint handling and consumer protection, on the

other hand, linked back to regulatory measures taken in those fields.

The ERPG has also collected data regarding these core indicators and the report analyses the data,

identifies trends on the market and describes the competence and current practices of NRAs.

ERGP REPORT 2014 ON THE QUALITY OF SERVICE AND END...

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