However, PostEurop regrets that IMCO proposes disproportionate and unnecessary price assessments and asks for confidential, highly sensitive business data. The national postal operators look to the TRAN committee to reflect these crucial elements in the text.

Article 4(3) and (4) on the provision of terminal rates should be deleted:

• Reporting requirements to national authorities go way beyond the EU’s objective of better market monitoring.
• Highly sensitive commercial information (known as “terminal rates”, which remunerate cross-border parcel delivery between national postal operators) is best protected by not being disseminated.
• This data must remain confidential. National regulatory authorities already oversee the activities of “their” postal operators.

Article 5 – Pan-European yearly affordability assessments are needless and create red tape:

• Given that the Commission expects only 5 to 10 % of parcel prices to be problematic, a general provision to assess cross-border parcel prices is disproportionate.
• It’s customers who regularly check and compare the services and offers of parcel delivery providers.
• The parcel delivery market is fiercely competitive and growing. This development shouldn’t be hindered by unnecessary administrative burden.

Article 6 mandating access to national postal operators’ networks should rightly be deleted, as proposed by the IMCO opinion:

• National postal operators already give third party delivery operators access to their networks, through agreements negotiated on a commercial basis.
• Regulating third-party access would unnecessarily alter these market dynamics. The EU has plenty of tools (competition Law) at its disposal to address inappropriate practices – if indeed they occur at all.

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