In response to the ERGP Report on Postal Definitions (ERGP PL I (20) 7), which is currently under public consultation, PostEurop would like to take the opportunity to share some reflections on it. We wish to continue the dialogue with the ERGP to discuss further how definitions lead or not to concrete dysfunctions in the functioning of markets, competition and customer satisfaction.

The review of the Postal Services Directive will imply looking at the postal definitions in order to address whether or not they are up-to-date and fit for purpose. In that respect, the ERGP report touches upon interesting questions. What about “self-delivery” of marketplaces and websites, delivery of food or platform intermediary activities related to delivery services. A level playing field presupposes that, where appropriate, regulatory conditions (for instance, authorization, reporting or redress procedure requirements) apply to all players alike, “traditional” as well as “new” players and new business models. Whether the definitions of the Postal Services Directive actually need updating is another question, which deserves further analysis.