PUG Comments on the review of CEN Quality of Service. General Comments. Specific Comments. June, 2009

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1 June, 2009 To: Mr. Ulrich Dammann Chairman TC331 WG1 CEN PUG Comments on the review of CEN Quality of Service CEN TC 331 WG 1 and the European Commission have kindly invited users and other stakeholders to comment on the review of the Quality of Service Standard CEN PUG has consistently supported all initiatives designed to enhance competition, transparency and consumer benefits in the EU postal sector. PUG believes this standard to be extremely important for users and consumers, as it will be a mandatory standard and will serve as a platform for future Quality of Service Standards for the EU postal sector. In recognition of the importance of this matter we have formed a specialised subgroup to provide detailed comments General Comments PUG would like to express its support for CEN s efforts towards the adoption of a new Quality of Service Standard as well as for a future Quality of Service Standard for Bulk and Unaddressed Mail, following some of the principles outlined in the revised version of the CEN Quality of Service. Postal services in the EU will continue to evolve rapidly over the next decade. The level of quality in postal services is gradually improving as a result of competition and the development of new products and services. PUG strongly believes that the liberalization process should encourage regulators and operators to continue efforts towards better management of service quality as well as new products, designed to respond to market demand. Any standard designed to create improvements in the way the service quality is assessed and managed, will therefore have to be future proof, and applicable to all operators in a liberalized market. Furthermore, any standardization in the area of postal services should have the role of further promoting the principles set by the EU Postal Directives. The Postal market of the future has to be a partnership between the postal operators who offer real, high quality services, and the customers, who need to be assured that they are paying the fair price for a value added service. Specific Comments 1. Methodology 1.a. Real mail studies for sample design Following discussions with CEN, PUG was informed that certain requirements, such as using real-mail studies in the first measurement period might have been too costly for some operators. Therefore, the standard could exempt an operator from using real mail studies in the first measurement period.

2 However, the importance of real mail studies in building relevant statistical samples has been widely supported for many years in the EU, and all USP postal operators should now be able to carry out such studies. Therefore, PUG would like to urge CEN to further consider whether this exemption would lead to the expected results of this exercise, despite the relatively small volume of mail this standard is expected to cover. In addition, in our view the 3 years period between real mail studies is too long. Evolution of mail volumes is expected to rapidly change during the next years (notably with shifts in demand linked to e-substitution, or to the economic downturn). 1.b. Determination of the discriminant mail characteristics PUG is pleased to see the draft standard s definition of mail characteristics that may impact quality of service (geographical area, type of payment, type of delivery, formats, etc.). PUG also finds it very useful that the standard requires an audit of the studies in order to determine the discriminant mail characteristics. Many Member States do not have such audit requirements; these will provide reassurance to the user. 1.c. Collection time The methodology used in the standard naturally excludes mail items posted after the last collection time of the day. However, the standard indicates that this collection time is to be taken as stated on the postal letterbox or published at the Post office. Collection time is an important element in the assessment of service quality. Furthermore, this element is of particular importance for users. Therefore, PUG feels that controls by NRAs should be required, as well as the publication of collection times in the report of the NRAs, as a measure of transparency and commitment to improving quality. 2. Definitions 2. a. Postal customers and postal operators 2.b. Natural or legal person buying a postal service from a postal operator Comment: PUG would like to express its concern over the wording used in the draft standard when referring to users. Following discussions with CEN, it was explained to users that the use of a distinct set of definitions would increase precision in the application of the standard. Additionally, it was explained that the total volume covered by the standard, following the introduction of these restrictions and others (such as cost and quantity), would be very small (in the region of 7-9% of total mail volumes). However, in the light of using the reviewed CEN Quality of Service Standard as a platform for additional standards, especially for unaddressed mail and bulk mail, the use of such wording ( postal customers instead of postal users ) could lead to confusion. PUG would like to suggest the use of very clear definitions, through the entire standard, in order to prevent any potential confusion at member state level. 2

3 3. Scope and Measurement 3.a. The objective of the measurement is to estimate the end-to-end transit time QoS given to the customer domestically in each European country and cross-border between the European countries Comment: The Directives set two quite distinct requirements for domestic and cross border delivery and, as the CEN draft goes on to illustrate, operationally both systems are likely to get increasingly complex/complicated once the reserved area is abolished. PUG would like to ask whether the acknowledgement of these two distinct areas of postal services will not require an approach based on two separate standards, one for domestic services and the second for cross-border services. 3.b. This European Standard specifies methods for measuring the end-to-end transit time of domestic and cross-border Single Piece Mail (SPM) (that can also) be used for the measurement of priority mail services Comment: The draft standard uses terms that are not defined in the Directives. PUG believes that it would be very useful for all stakeholders that these are clarified and defined. As we understand it, these categories are the items of correspondence for collection, sortation, transport and delivery as a part of the designated Universal Service Providers (USP) provision of the Universal Postal Service. Would PUG be correct in assuming this is the legal meaning of the above statement? Furthermore, it is not clear why some key functional terms, defined and used in the Directives (and thus firmly rooted in EU law), are not used in this draft Standard, especially as the standard states that 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, and EN is mandatory for measuring the performance levels of single piece priority or first class mail which falls under the universal service. 3.c. Formal definition: Where is the total number of postal items inducted during the period t, and a postal item i fulfils the specification and otherwise if Comment: Following discussions with CEN, PUG believes that it is necessary to have such formulae explained and illustrated, as to allow all users as well as operators to fully comprehend the impact and implications. 3.d. Annual indicators Comment: A result limited to an annual figure is obviously not sufficient from a statistical perspective. For example, Quality of Service statistics often vary depending on the time of the year or season. PUG understands that detailed periodical figures might be perceived by some operators as sensitive data, however, a compromise needs to be reached that would allow users to adapt to seasonally changing Quality of Service levels (e.g. by setting reasonably defined periods such as months). 3.e. National indicators Comment: A result limited to a national average figure does not provide useful information on QoS, especially in large countries. It is essential that the data is provided by regions as well as the totality of the country. PUG is not requesting detailed geographical figures, which would be 3

4 statistically irrelevant and might possibly contain data which might be considered business secrets for Posts. However, QoS results by reasonably defined zones or results based on data on local mail vs. national mail, would allow mailers to adapt to different level of QoS, and would also incentivise Posts to improve their QoS in all regions. However, PUG would like to point that in an ideal context, all postal operators, including alternative carriers, should provide the data for annual and national indicators. That data, aggregated by the NRA for example, will not reveal business secrets. If there is only one USP operating a monopoly on either part or the whole of the relevant mail volume the normal rules of competition should be used to decide whether or not such statistical data could constitute a business secret. 3.f. The draft CEN standard is designed for all types of single piece mail services for addressed mail with defined transit-time service levels offered to the customer without the actual number of potential applications and services being quantified and/or listed 3.g. This European standard relates to the measurement of the SPM services given to private persons or households and businesses that post mail at street letter boxes, over the counter at post offices or have pick-ups at their offices. To cover flows with smaller mail volumes, this European standard includes flexibility areas for adapted implementation. For technical reasons this European standard may not be suitable for the measurement of very small volumes of mail 3.h. This European standard is not applicable for the measurement of end-to-end transit times of bulk mailers services. Comments to sub points f,g,h: PUG believes that it would be extremely useful for users and operators as well if a list of all services of single piece mail was made available by CEN. Such a list would help all stakeholders to clearly comprehend the impact of the reviewed standard. PUG feels that clarification would be beneficial in terms of the exact volumes envisaged to be covered by the standard. For example, the standard uses terms such as very small volumes, which in the opinion of users, should be clearly defined. As a second example, the draft states that items picked up at a business s premises would be included, while at the same time it doesn t offer clear guidance in the case of deliveries to an operator s sorting center. PUG believes that such wording needs to be clearly illustrated, in order to avoid any confusion in implementation. 3.i. This QoS indicator does not measure the postal operators overall performance in a way that provides direct comparison of postal service operators and does not include other service performance indicators Comment: PUG believes that this point is insufficiently clear. When all markets are opened for competition, it is to be expected that the designated USP will remain the dominant end-to-end service provider in nearly all Member States. Therefore, users strongly feel that comparisons between different quality of service performances should be made possible. PUG would like to take this occasion to stress the importance of allowing businesses, users and consumers to compare quality levels. In the current economic climate and in the light of having the European markets fully opened this would constitute a prerequisite for true competition. 4

5 3.j. Priority item, first class item, A-class item: Postal items sent with priority as defined nationally Comment: It is unclear why the term as defined nationally is used in this context. PUG would like to ask CEN whether the use of such wording will not lead to significant variations in the ability to compare the Quality of Service results between the Member States. 3.k. Single piece mail Postal items posted and distributed via a postal service for which a single piece tariff for individual postal items is set in the general terms and conditions of the postal service provider that receives the payment (Note 1: Single piece mail may be inducted using different modes of payment as long as the induction of individual postal items is not restricted; Note 2: Excluded are all postal services that contain further requirements on the induction like, for example, the registration of items, minimum induction volumes, equal contents or a presortation of the inducted mail. PUG strongly believes that CEN should define terms such as pre-sorting, equal contents, and further requirements. Furthermore, PUG would like to express its concern over the wording proposed in NOTE 2. This could lead to the exclusion of USO items from the scope of this standard, such as registered items. PUG feels that prior to the adoption of wording such as in NOTE 2, CEN should investigate (and share this information with the users in the consultation process) the impact of terms such as minimum induction volumes, on the volumes in each of the Member States. Conclusion PUG would like to kindly thank CEN for its efforts and for inviting the users to share their views on this review process. To conclude, PUG would like to signal several potential problems. PUG feels that the use of wording which is alternative to already available terms, defined in the Postal Directives, should be further considered. Furthermore, users believe that the ability to compare the Quality of Service results is essential for the development of competition, new products and better prices for all market players. PUG feels that improvements and certain compromises are needed in the areas of indicators, formulae, definitions and in terms of scope and measurement, which are outlined in the present document. Yours sincerely, Razvan Antemir (On behalf of the Postal Users Group) Postal Users Group Secretariat rantemir@fedma.org ; Link to: Postal Users Group GSM: +32 (0) ; Phone: +32 (0) About The Postal Users Group (PUG): The Postal Users Group (PUG) is an ad hoc platform of major EU postal users and their representative organisations. Since its formation in 1996 PUG has been actively promoting the creation of an Internal Market for postal services. Throughout we have worked closely with DG Internal Market. The PUG membership includes representatives from the major bulk mailing business sectors, such as the International Chamber of Commerce (ICC), the Federation of European Direct and Interactive Marketing (FEDMA), the European E-commerce and Mail Order Traders Association (EMOTA), the European Publishers Council (EPC), the Federation of European Periodical Publishers (FAEP), the European Newspaper Publishers Association (ENPA), the European Directory Publishers Association (EAPD), the Federation des Editeurs EUROPEENS (FEP-FEE) and the European Express Association (EEA). For more information on the PUG activities, high level goals and contact please visit the PUG webpage here 5