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ERGP PL II (19) 35 Report on QoS, and complaint handling

ERGP REPORT ON THE QUALITY OF SERVICE,

CONSUMER PROTECTION AND COMPLAINT

HANDLING 2018 – AN ANALYSIS OF TRENDS

19 December 2019

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

1 Executive Summary ...... 5

1.1 Background ...... 5

1.2 Methodology ...... 5

1.3 Current situation regarding quality of service and end-user satisfaction ...... 5

1.4 Current situation regarding consumer protection and complaint handling ...... 7

2. Background ...... 9

3. Methodology ...... 11

4. Current situation regarding Quality of Service and End-User Satisfaction . 12

4.1. Measurement of quality of service concerning routing times, regularity and reliability of services ...... 12

4.1.1. Measurement of quality of service for single-piece priority mail in 2018 ...... 16

4.1.2. Measurement of quality of service for single-piece non-priority mail in 2018 ...... 20

4.1.3. Measurement of quality of service for registered mail in 2018 ...... 21

4.1.4. Measurement of quality of service for parcels in 2018 ...... 22

4.1.5. Additional information regarding quality of service in 2018 ...... 23

4.2. Collection and delivery ...... 25

4.2.1. Frequency of collections and deliveries ...... 25

4.2.2. Exceptions to collection and delivery due to exceptional geographical conditions …………………………………………………………………………………………………………………………………….26

4.2.3. Obligation to deliver mail to the home or premises of every natural or legal person……………………...... 29

4.3. Access points ...... 31

4.3.1. Collection letterboxes ...... 31

4.3.2. Points of contacts ...... 33

4.4. Monitoring of consumer satisfaction ...... 41

4.5. Surveys regarding ’ needs ...... 42

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

4.6. The impact of E-commerce on the postal field ...... 43

5. Current situation regarding consumer protection and complaint handling procedures ...... 45

5.1. Competence of NRAs on complaint handling ...... 45

5.2. Information provision and access to complaint handling and dispute resolution ...... 47

5.3 Compensation schemes for individual customers ...... 49

5.4. Indicators on complaints ...... 51

5.5. Data on complaints by NRAs ...... 52

5.5.1 Data on complaints by NRAs ...... 52

5.5.2 Complaints received by USPs and NRAs ...... 54

ANNEX 1 – Methodology of each country for the measurement of quality of service of domestic services provided by the USP in 2018 ...... 57

ANNEX 2 – Force majeure and other exceptions which have an impact on the measurement of quality of service ...... 58

2.1. Number of days of measurement impacted by force majeure events in 2018 and reasons…...... 58

2.2. Other exceptions that have an impact on the measurement of the quality of service in 2018 ...... 58

ANNEX 3 – Data regarding quality of service measurement and audit ...... 59

3.1. Information about measurement and audit regarding transit time of single-piece priority mail ...... 59

3.2. Information about measurement and audit regarding transit time of single-piece non- priority mail ...... 60

3.3. Information about measurement and audit regarding transit time of registered mail .... 61

3.4. Information about measurement and audit regarding transit time of single-piece parcels 62

3.5. Information about measurement and audit regarding transit time of cross- mail 63

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

Annex 4 – Countries in which the criteria establishing the exceptional geographical character for frequency are both defined and published ...... 64

Annex 5 – Monitoring of consumer satisfaction ...... 65

Annex 6 – Surveys of customers’ needs and surveys ...... 67

Annex 7 – Obligations to provide information: Countries where postal service providers are obliged to publish information on procedures to complain, compensation schemes and dispute resolution ...... 69

Annex 8 – Compensation schemes for individual customers ...... 70

Annex 9 – Data on complaints ...... 71

9.1. NRAs that collect data on the number of complaints received by postal service providers …………………………………………………………………………………………………………………………………….71

9.2. Complaints received by USPs about universal service per country per 1,000 inhabitants, 2014, 2017, 2018 ...... 72

9.3. Complaints received by NRAs about postal services per country per 10,000 inhabitants, 2014, 2017, 2018 ...... 73

9.4. Complaints received by USPs about cross-border services per country per 1,000 inhabitants, 2014, 2017, 2018 ...... 74

COUNTRY CODES AND NRA ACRONYMS ...... 77

TERMS AND ABBREVIATIONS ...... 78

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

1 Executive Summary

1.1 Background

According to Chapter 6 of the Postal Directive, national regulatory authorities (hereinafter NRAs) shall ensure compliance with the obligations arising from the Directive, in particular through the follow-up of the quality of service. Quality of service standards regarding the universal service (US) are established in order to guarantee a postal service of good quality. These quality standards should in particular focus on routing times, as well as on the regularity and reliability of services. The ERGP continuously monitors the effects of postal liberalisation through appropriate indicators by 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. This 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 consumer protection and complaint handling.

1.2 Methodology

The report is based on the replies received from 32 ERGP members to a questionnaire requesting data for 2018 on quality of service and end-user satisfaction, including consumer protection and complaint handling. For Iceland we have used data of 2017 if available by consequence we have sometimes replies from 33 ERGP members.

1.3 Current situation regarding quality of service and end-user satisfaction

The quality of service and the end-user satisfaction have been analysed taking into consideration the following six dimensions:

1) Measurement of the quality of service concerning routing times and the regularity and reliability of services In 2018, 33 ERGP members have defined regulatory objectives which deal with universal service regarding transit time. Only 9 countries (27%) have regulatory objectives regarding loss or substantial delay and 4 countries (12%) have regulatory objectives regarding queuing time in post offices.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

The majority of the countries have regulatory objectives for priority mail. From the 32 countries, 30 countries (91%) had regulatory objectives for priority mail and 19 for non-priority mail (59%). The average of results (D+1) in countries which provided information on the results (24 countries) was 85.14%, which is a little bit better than in the previous year (84.11% for 27 countries in 2017) and we can notice more stability in quality results since the last 3 years. The Eastern countries had a positive evolution in 2018, unlike the other regions. Amongst the countries which provided their results and targets (24 countries), the universal service provider (USP) achieved the targets regarding D+1 in only 12 countries, while in 12 countries the universal service provider (USP) did not.

2) Collection and delivery Regarding the frequency of collection and delivery to be carried out by the USP, the responses received revealed that the Directive has been implemented by all ERGP members which have established at least one collection/delivery for 5 days a week (in some countries the obligations have been extended to 6 days per week). Nonetheless, many countries have granted exceptions regarding frequency of collection and in particular delivery. Responses revealed that these exceptions for delivery are mainly related to mountain areas, population density, insularity, poor infrastructure, low traffic volumes, cost of service and extreme weather conditions. In certain countries, due to high costs involved in providing access to the universal service, especially in depopulated areas and isolated geographic areas, exceptions are implemented regarding the delivery of mail to the home or premises of recipients. The most common criteria for those exception regarding home delivery are geographical conditions, health and safety concerns, population density and areas with lack of street names. The majority of answers revealed that the delivery service in these situations is directed to local post offices, cluster boxes, curbside letterboxes or, in other cases, to town halls, public authority’s offices, individual arrangements, etc.

3) Access points The access points are defined in postal directive1 as the physical facilities of the postal network, where postal items may be deposited, to be processed by the postal providers. Two key components of the postal access points are analysed, namely collection letterboxes and points of contact.

The access point is rather a very sensitive issue and this is reflected by the fact that a vast majority of the countries deem it necessary to have requirements or standards to ensure an adequate number of collection letterboxes and points of contact/postal establishments. The analysis shows that the most common type of contact or postal establishments based on respondents is permanent post offices managed by USP (more than then 90% of respondent), followed by permanent post agencies managed by 3rd entity postal establishments (87%).

1 Article 2of the Directive 2008/06/EC

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

4) Measurement of consumer satisfaction According to the responses to the questionnaire, almost 55% of the NRAs monitor indicators of consumer satisfaction in their country and almost all of these NRAs publish the respective results. The results from the questionnaire show that 39% of the USPs in Europe conduct studies regarding the level of consumer satisfaction but these results are not so often published.

5) Surveys regarding consumers´ needs and market surveys In terms of measuring consumers’ needs and market surveys, 56% of the NRAs indicated that they conduct such surveys, and most of them publishing the results. Only 33% of NRAs indicated that the USP conducts surveys regarding customers’ needs, but the large majority of respondent NRAs (55%) do not have information regarding this issue from their USP.

6) E-commerce aspects Also, the Regulation 2018/644 of the European Parliament and of the Council on cross-border parcel delivery services was adopted in April 2018 with the scope to encourage the development of e- commerce and European cross-border e-commerce specific. E-commerce is nowadays considered as the new growth engine for parcels growth which can compensate the decline in traditional mail business. In this section we focus on NRA activities in this area.

1.4 Current situation regarding consumer protection and complaint handling The report examines five key issues in the field of consumer protection and complaint handling, namely:

1) Competence of NRAs regarding complaint handling In the large majority of countries (79%), NRAs have this competence, most of which covering complaints about all postal services. In almost all of the countries where NRAs are responsible for dealing with users’ complaints, the NRAs have procedures in place to resolve those complaints.

2) Information provision and access to complaint handling and dispute resolution In 2018, the majority of countries had obligations in place for postal service providers to publish information regarding complaint procedures, compensation schemes and dispute resolution (usually on the providers’ website, access points, general terms and conditions), covering the USP but also other postal service providers. For the last three years the number of countries where alternative (or out-of-) dispute resolution mechanisms are available to consumers has been increasing from 22 (67%) in 2014 to 28 (85%) in 2018.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

3) Compensation schemes for individual customers Regarding the scope of existing compensation schemes, most countries (24 out of 32 or 72%) have an obligation for a specific compensation scheme which concerns mostly the USP. This compensation schemes have been extended to other postal service providers in 15 countries.

4) Indicators on complaints On the measurement and publication of complaints handling indicators by the USP, analysing existing obligations and their scope. In the majority of countries (79%), USPs are obliged to measure and/or publish indicators on the complaints they receive. This obligation is normally set by the postal , but in some cases is derived from licence conditions or NRAs decisions or procedures.

5) Data on complaints by NRAs Here we look at the data NRAs are collecting on the number of complaints about postal services in general and also about cross-border services. Most NRAs mentioned items lost, damaged or substantially delayed as the main reasons for cross-border complaints in 2018. The vast majority of NRAs (87%) collect and publish data on complaints received by the USP regarding universal services.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

2. 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 NRAs shall ensure compliance with the obligations arising from the Directive, in particular through the follow-up of the quality of service. The Directive emphasises that the postal reform has brought significant positive developments in the postal sector, increasing both quality of service and focus on meeting consumer needs. Increased 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 regarding the universal service are established and published 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 ERGP continuously monitors 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 in accordance with the provisions of the Directive. The objective is to collect the necessary data to monitor quality of service, end-user satisfaction, consumer protection and complaint handling 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 consumer protection and complaint handling. The report looks at the current and past situation of data collection and publishes indicators regarding quality of service, consumer protection and complaint handling. It then analyses this data and identifies market trends regarding quality of service, quality of delivery, satisfaction and development of the postal network, as well as consumer protection and complaints handling and e-commerce aspects. The report has been published yearly since 2011 and the objective is to update this report on an annual basis. This ERGP report describes the current NRAs’ practices concerning quality of service, consumer protection and complaint handling as well as the current scope, competencies and powers of NRAs. The report examines six key issues in the field of quality of service and end-user satisfaction, namely: 1. measurement of quality of service concerning transit time, regularity and reliability of services; 2. collection and delivery; 3. access points; 4. measurement of consumer satisfaction; 5. surveys regarding customers’ needs.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

6. E-commerce aspects

The report also examines five key issues in the field of consumer protection and complaint handling, namely: 1. competence of NRAs on complaints handling; 2. information provision, access to complaint handling and dispute resolution; 3. compensation schemes for individual customers; 4. indicators on complaints 5. data on complaints by NRAs

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

3. Methodology

In order to gather information regarding quality of service and end-user satisfaction in the broad sense of the term, including information regarding complaint handling and consumer protection, a questionnaire was submitted in May 2019 to ERGP members and observer NRAs in order to collect information on the situation of 2018 (except stated otherwise in the report). We received replies from the 32 ERGP members on 2018 data, which are the following: Austria, , Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, , the Republic of North Macedonia (MK), , Greece, Hungary, Ireland, , Latvia, Lithuania, Luxembourg, Malta, Norway, Poland, Portugal, Romania, , Slovakia, Slovenia, , Sweden, , the and the . For Iceland we have used data of 2017 if available. This report is primarily based on the answers provided to the questionnaire, which overall, reflects the legislation and practice in place at the end of 2018. The data used in the report is already collected by NRAs and is publicly available data2 , which means that NRAs did not collect data specifically for the purpose of this ERGP exercise. For some indicators, we used data already included in previous ERGP reports (based on the NRAs’ responses to the ERGP questionnaires, ranging from 2008 to 2018). With the objective of identifying geographical trends and to present the information in a more appealing way, for some indicators a cluster analysis was made using the following clusters3 : - Western countries: AT, BE, DE, DK, FI, FR, IE, LU, NL, SE, UK; - Southern countries: CY, EL, ES, IT, MT, PT; - Eastern countries: BG, CZ, EE, HR, HU, LT, LV, PL, RO, SI, SK; - Countries outside the (EU): CH, FY, IS, NO, RS.

2 Only public data was included in the report, confidential figures are not presented individually. 3 Classification also used in some of the postal studies commissioned by the European Commission.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

4. Current situation regarding Quality of Service and End-User Satisfaction

The quality of service and the end-user satisfaction have been analysed based on the following dimensions:

4.1 measurement of the quality of service concerning transit time and the regularity and reliability of services;

4.2 collection and delivery;

4.3 access points;

4.4 measurement of consumer satisfaction;

4.5 surveys regarding customers’ needs;

4.6 E-commerce aspects.

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 above-mentioned dimensions.

4.1. Measurement of quality of service concerning routing times, regularity and reliability of services In accordance with the Postal Directive 97/67/EC (especially Chapters 6 and 7 and Annex 2), one of the main tasks of the NRAs is to monitor quality of service in order to guarantee a postal service of good quality. Quality of service standards have to be set and published in relation to the universal service in order to guarantee a postal service of good quality and have to focus, in particular, on transit times and on the regularity and reliability of services. The figure below provides details regarding the definition of regulatory objectives for transit time, loss or substantial delay and queuing time in post offices. Regarding the quality of service, all the 33 countries define regulatory objectives, which deal with universal service regarding transit time. Only 9 countries (27%) have regulatory objectives regarding loss or substantial delay, which is more than in 2017 (7 countries). Of those 9 countries, 4 have regulatory objectives but rather no measurement obligation for loss or substantial delay. Moreover, 4 countries (12%) have regulatory objectives regarding queuing time in post offices, which is the more than in 2017 (3 countries). Of those 4 countries, 1 have regulatory objectives but rather no measurement obligation for queuing time in post offices.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

Figure 1 – Regulatory objectives in 2018

100% 1

90%

80%

70% 24 60% 28 N/A 50% 33 No 40% Yes 30%

20% 9 10% 4 0% Routing Time (transit time) Loss or Substantial Delay Queuing time in Post Offices (reliability)

The majority of the countries have regulatory objectives for priority mail. According to the Figure 2, in 2018, 30 countries (91%) had regulatory objectives for priority mail and 19 for non-priority mail (58%). Amongst the 33 countries, 21 countries (64%) had regulatory objectives for parcels, 13 countries (39%) for registered items, 5 countries (15%) for bulk mail and 2 countries (6%) for newspapers/periodicals and for bulk parcel.

Figure 2 – Regulatory objectives for transit time in 2018 – which kind of service has a regulatory objective Non-priority Registered News-paper Single piece Priority mail Bulk mail Bulk parcel mail item / periodical parcel AT ✓ ✓ ✓ BE ✓ ✓ ✓ ✓ BG ✓ ✓ ✓ CH ✓ ✓ ✓ CY ✓ CZ ✓ DE ✓ ✓ ✓ ✓ DK ✓ ✓ EE ✓ EL ✓ ES ✓ ✓ FI ✓

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

Non-priority Registered News-paper Single piece Priority mail Bulk mail Bulk parcel mail item / periodical parcel FR ✓ ✓ ✓ ✓ HR ✓ ✓ HU ✓ ✓ ✓ ✓ ✓ IE ✓ ✓ ✓ IS ✓ ✓ IT ✓ ✓ ✓ ✓ ✓ LT ✓ ✓ ✓ ✓ LU ✓ ✓ ✓ ✓ LV ✓ ✓ ✓ MT ✓ ✓ ✓ ✓ ✓ ✓ NL ✓ NO ✓ ✓ PL ✓ ✓ ✓ PT ✓ ✓ ✓ ✓ ✓ RO ✓ RS ✓ ✓ ✓ SE ✓ SI ✓ ✓ SK ✓ ✓ ✓ ✓ MK ✓ ✓ UK ✓ ✓ ✓ ✓ Total 33 30 19 13 5 2 21 2

The figure below details if countries have set regulatory objectives for cross-border services and if they had the corresponding results of quality of service.

Figure 3 – Cross-border information per country for 2018

Regulatory objectives regarding Results regarding

cross-border services cross-border flows? AT Yes Yes BE4 Yes Yes BG Yes Yes CH No Yes CY Yes Yes CZ No Yes

4 BE: Inbound mail should be treated on an equal basis with priority letters.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

DE Yes No DK No No EE No No EL Yes Yes ES Yes Yes FI Yes No FR No Yes HR Yes Yes HU Yes Yes IE Yes No IS Yes Yes IT Yes Yes LT Yes Yes LU Yes Yes LV No Yes MK Yes No MT Yes Yes NL No No NO Yes Yes PL No No PT Yes Yes RO Yes Yes RS Yes Yes SE No No SI Yes Yes SK No No UK Yes Yes Total of “yes” 23 23

In 2018, 23 countries set regulatory objectives for cross-border services. Amongst the countries that established targets, 4 indicate that it doesn’t have the corresponding results. 23 countries indicated they have the results regarding quality of service for cross-border flows and consequently, 4 of these countries did not set regulatory objectives for cross-border services. According to the figure below, 20 countries established an objective regarding inbound D+3 and 21 countries established an objective regarding outbound D+3, 19 countries had an objective regarding D+5 delivery. 16 countries (50%) presented the results of transit time for cross-border flows in 2018.

Figure 4 – Targets and results of cross-border mail in 2018

D+3 D+5 Target Result Target Result Inbound Outbound Inbound Outbound Inbound Outbound Inbound Outbound AT 85,00% not yet 97,00% not yet BG 85,00% 36,50% 97,00% 72,40% CY 85,00% 37,30% 33,80% 97,00% 74,90% 72,10% CZ na na DE 85,00% na 97,00% na DK na na na na

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

D+3 D+5 Target Result Target Result Inbound Outbound Inbound Outbound Inbound Outbound Inbound Outbound EE na na na na EL 85,00% 72,80% 58,20% 97,00% 92,80% 89,40% ES 85;00% 97,00% FR 81,60% 85,30% 96,10% 95,90% HR 85,00% 71,50% 97,00% 93,50% HU 85,00% 63,40% 71,60% 97,00% 90,90% 89,50% IE 85,00% na 97,00% na IS 90,00% 75,00% 97,00% 95,00% IT 85,00% 74,60% 97,00% 90,40% LT 85,00% 97,00% LU 85,00% 81,10% 97,00% 86,80% LV na na MK 85,00% na 93,00% na MT 85,00% 47,00% 97,00% 75,00% NL na na na na NO 85,00% 48,20% 97,00% 80,70% PL na na na na PT 88,00% 80,50% 97,00% 96,00% RO 85,00% 40,00% 97,00% 80,00% RS 85,00% 40,61% 97,00% 80,81% SE na na na na SI 85,00% 77,70% 82,60% 97,00% 94,40% 95,30% SK na na na na UK na 85,00% 86,6% 85,20% na na Total 20 21 15 16 19 15 15 Average 85,42 85,40% 61,85% 63,23% 96,79% 86,65% 86,95% Notes: In RS the target and the result in D+5 in referring only to European countries. CY and SI present disaggregation of the results in inbound and outbound. LU does not yet have the results. In HU the cross-border service is regarding registered international letter mail. The UK considered the USO single piece International mail to EU states (only outbound) for D+3. The quality of service metrics are set on the financial year basis from April to March. In this sense, the inbound result is referring to 2018-2019 and the outbound result is referring to 2017-2018.

4.1.1. Measurement of quality of service for single-piece priority mail in 2018

In 2018, 30 countries set targets for measuring the transit time of end-to-end priority mail in the domestic postal market. 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 figure below shows the countries which established targets from D+1 to D+5 delivery regarding single-piece priority mail and their results for 2018, according to which: - 25 countries set a target for D+1 delivery, of which 14 countries at 90% or more. Switzerland still had the highest target (97%);

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

- 24 countries provided their results for 2018 for D+1 Delivery and the average value was 85,14%, which is higher than the previous year (84,11%); - 15 countries set a target for D+2 delivery, ranging from 85% (LU, NO, RO, RS) to 99.50% (SI); - 12 countries established a target for D+3 delivery; - Only 5 countries set targets for D+4 (AT, FR, IT, NO, RO); - Only ES set a target for D+5 and only RS measured the result for D+5. - DK, FI and MK doesn´t measure single-piece priority mail and hasn´t defined target values.

Figure 5 – Targets and results of single-piece priority mail in 2018

D+1 D+2 D+3 D+4 D+5 Target Result Target Result Target Result Target Result Target Result AT 95,00% not yet 98,00% not yet 100,00% not yet BE 93,00% 91,20% 97,00% 96,5% BG 80,00% 49,00% 95,00% 73,00% CH 97,00% 97,40% CY 90,00% 89,32% 97,00% 99,78% CZ 92,00% 92,92% DE 80,00% 88,30% 95,00% 98,30% EE 90,00% 76,00% EL 87,0% 74,70% 98,0% 95,0% ES 93,00% not yet 99,00% not yet FR 85,00% 84,60% 96,60% 99,0% 99,50% HR 85,00% 85,60% 95,00% 95,50% HU 85,00% 87,70% 97,00% 99,20% IE 94,00% 89,00% 99,50% 99,00% IS 85,00% 84,00% 97,00% 99,00% IT 80,00% 85,90% 98,00% 98,90% LT 85,00% 85,00% 97,00% 98,00% LU 85,00% 96,8% 99,00% 99,00% LV 90,00% 94,40% MT 95,00% 95,11% 98,00% 99,40% 99,00% 99,75% NL 95,00% 95,00% NO 85,00% 89,90% 97,00% 99,10% PL 82,00% 57,10% 90,00% 84,70% 94,00% 93,80% PT 94,50% 92,30% 87,00% 86,00% RO 85,00% 57,10% 97,00% 86,05% RS 80,00% 67,16% 85,00% 91,42% 90,00% 96,78% 99,17% SE 95,00% 98,58% SI 95,00% 95,70% 99,50% 99,70% 100,00% 99,95% SK 94,00% 94,39% 99,00% 99,47% UK 93,00% 91,50% Total 25 24 15 15 12 11 5 4 1 1 Average 88,86% 85,14% 92,57% 90,86% 97,71% 98,11% 98,20% 95,89% 99,00% 99,17% Note: In BE the target of D+1 (93,00%) is set by law and 95,00% is set by management contract and of D+2 (97,00%) is set by law. DK and FI doesn´t measure single-piece priority mail and hasn´t defined target values. In PT, the measurement of D+1 applies to letters sent between any location of Portugal Mainland and the measurement of D+2 applies to letters sent from, between or to any location of Autonomous Regions of Azores and Madeira. In RS 2018 measurement is based on Ordinance (2018) only for two-month period as preparing for full implementation of (EN 13850) during 2019. So, the targets for 2018 does not exist, but we apply targets for 2019 in this report. In UK the quality of service metrics are set on the financial year basis from April to March. In this sense, the result is referring to 2018-2019.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

The figure below shows that, in 2018, 12 of the 24 countries which provided their targets and results regarding D+1 delivery achieved their target, while 12 countries did not. Amongst the countries which provided their results for 2017 and 2018 (D+1), 10 recorded progress (or stability) in their transit time quality while 14 recorded a decrease.

Figure 6 – Targets (2018) and results (2016, 2017 and 2018) regarding D+1 delivery of single-piece priority mail

100

80

60

40

20

0 BE DE FR IE NL UK CY EL IT MT PT BG CZ EE HR HU LT LV SI SK PL CH IS RS Western Southern Eastern Outside EU 2016 2017 2018 Target 2018

Note: Data considering the 24 countries that provided data since 2016 (western: BE, DE, FR, IE, NL, UK; southern: CY, EL, IT, MT, PT; eastern: BG, CZ, EE, HR, HU, LT, LV, SI, SK, PL; outside EU: CH, IS, RS). For Iceland was considered in 2018 the value of 2017.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

The figure below shows that as far as quality of service regarding priority mail (D+1) between 2009 and 2018 is concerned. Better results are observed between 2012 and 2014. The Eastern countries had a positive evolution in 2018, unlike the other regions.

Figure 7 – Evolution of the average value of quality of service of single-piece priority mail regarding D+1 delivery (2018) 95

90

85 Western Southern 80 Eastern Outside EU 75 European average

70

65 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Note: Data considering the 24 countries that provided data since 2014 and until 2018 (western: BE, DE, FR, IE, NL, UK; southern: CY, EL, IT, MT, PT; eastern: BG, CZ, EE, HR, HU, LT, LV, SI, SK, PL; outside EU: CH, IS, RS). Regarding the measurement methodology, in 2018, 26 countries used the European standard EN 138505 for the measurement of single-piece priority mail transit time6. When measuring the transit time, some events – which have been considered as force majeure regarding the European standard EN 13850 –, with potential impacts on quality of service can be excluded from the measurement. In 13 countries7, the NRA decides on the application of force majeure events on request by the operator. In 2018, the number of days of force majeure accepted by the NRAs varied between zero and 78 days, whereas, in 2017, it ranged between zero and 3 days. Only 59 indicated that there are other exceptions made for quality measurements regarding letters and parcels, which can impact the quality of service measurement10.

5 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. 6 See annex 1. 7 BE, BG, CH, DK, EL, ES, HR, IT, MT, PT, RS, SI, SK. 8 See annex 2.1. 9 EE, EL, NL, PL, RO. 10 See annex 2.2.

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

4.1.2. Measurement of quality of service for single-piece non-priority mail in 2018

18 countries have regulatory objectives for non-priority mail. Regarding the methodology of measurement of quality of service for single-piece non-priority mail, 11 countries used the European standard EN 1450811 while 5 countries used the EN 1385012. The figure below presents the countries which had a regulatory objective for routing time of single- piece non-priority mail in 2018. Based on this table, one can conclude that, in 2018, 12 countries had a target regarding D+3, whereas 7 countries had a target regarding D+2 delivery and 5 countries had a target regarding D+4, and 4 countries had a target regarding D+5.

Figure 8 – Targets and results of single-piece non-priority mail in 2018

D+1 D+2 D+3 D+4 D+5 D+6 Target Result Target Result Target Result Target Result Target Result Target Result BE 95,00% 93,40% 97,00% 96,50% BG 80,00% 80,5% 95,00% 91,6% CH 97,00 98,90% DK 95,00% 95,40% FI 50,00% 99,50% 97,00% 99,70% FR 94,00% 94,80% 98,60% 99,00% 99.40% HR 95,00% 95,60% HU 85,00% 85,20% 97,00% 97,80% IS 85,00% 98,00% IT 90,00% 88,00% 98,00% 96,70% LT 85,00% 90,00% 97,00% 99,00% LU 85,00% 96,8% 99,00% 99,0% LV 98,00% 99,60% MK 85,00% 63,20% 90,00% 72,08% 95,00% 77,85% 85,10% PL 85,00% 74,80% 97,00% 94,30% PT 96,30% 96,40% SK 94,00% 94,21% 99,00% 99,66% UK 98,50% 98,60% Total 1 1 7 7 12 13 5 6 4 4 1 1 Average 85,00% 63,20% 89,00% 88,83% 93,82% 93,11% 87,00% 95,11% 96,50% 96,80% 98,00% 96,70% Note: BE: Common target defined by the Management Contract. In UK the quality of service metrics are set on the financial year basis from April to March. In this sense, the result is referring to 2018-2019.

In 2018, SK increased its target regarding D+2 delivery from 93,00% to 94,00%. NO has no longer targets of single-piece non-priority mail. On the other hand, from 2018 FI and MK have set targets for this service.

11 BE, BG, CH, DK, HR, HU, IT, PL, PT, SK, UK. 12 FI, FR, IS, LT, LU.

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Amongst the countries which provided their results for 2017 and 2018, 413 recorded a progress in their results while 614 showed a decrease, and 315 countries showed stability. PL improved the results for D+3 and decreased the value for D+5 and SK improved the results for D+2 and decreased the value for D+4. The average value of the results regarding D+3 was about 93,11%, which is lower than in the previous year (94,29%).

4.1.3. Measurement of quality of service for registered mail in 2018

The figure below presents the countries which had a regulatory objective for registered mail in 2018. Based on this table, it can be concluded that: - 6 countries set a quality target regarding D+1 delivery (BE, DE, LT, MT, PT; UK) from 80% (DE) to 99% (UK); - Regarding D+2 delivery, 5 countries set quality targets (DE, FR, LU, MT, SK) from 85% (LU) to 99% (MT); - 4 countries set targets for D+3, 3 countries for D+4 and 1 country for D+5 and for D+6.

Figure 9 – Targets and results of registered mail in 2018

D+1 D+2 D+3 D+4 D+5 D+6 Target Result Target Result Target Result Target Result Target Result Target Result BE 95,00% 87,30% DE 80,00% 88,30% 95,00% 98,30% FR 95,00% 94,60% 99,0% 99,20% HU 85,00% 95,40% 97,00% 99,20% IT 90,00% 95,00% 98,00% 97,90% LT 85,00% 69,00% 97,00% 91,00% LU 85,00% 96,8% 99,00% 99,0% MT 98,00% 99,29% 99,00% 99,83% 99,00% 99,90% PT 91,00% 93,70% SK 94,00% 95,43% 99,00% 99,73% UK 99,00% 98,20% Total 6 7 5 5 4 4 3 3 1 1 1 1 Average 91,33% 89,28% 93,60% 96,99% 95,00% 96,33% 96,00% 97,98% 97,00% 99,20% 98,00% 97,90% Note: BE: Common target defined by the Management Contract. SK: For the average of the results was considered priority for D+1 and non-priority for D+3. LT: The result values corresponds to the priority speed. The non-priority result values are 90,0% for D+1 and 96,0% for D+3. UK: The quality of service metrics are set on the financial year basis from April to March. In this sense, the result is referring to 2018-2019.

13 DK, HR, HU, PT, SK. 14 BE, CH, BG, FR, IT, LT. 15 IS, LV, UK.

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In comparison with the 2017 results of quality, amongst the 816 countries which provided their results, 417 countries showed a decrease, 218 countries recorded progress, 119 country showed stability, and 120 country had improvement in D+2 and deterioration in D+4.

4.1.4. Measurement of quality of service for parcels in 2018

For the measurement of transit time of parcels, countries use different methodologies. According to their answers, 4 countries used the European standard TR 15472, 5 countries used the Standard EN 13850, duly adapted and 4 countries used another methodology. The figure below presents the countries which had a regulatory objective for transit time for single- piece parcels in 2018. Based on this table, the conclusions are the following: - For D+1 delivery, 7 countries set targets, from 80,00% for the lowest (BG, PL) to 98,00% for the highest (MT). The results achieved has an average of 82,34%; - Regarding D+2 delivery, 10 countries set targets. MT (99,00%) presented the highest target, while DE, RS and SI (80,00%) had the lowest one; - Concerning D+3 delivery, 8 countries set targets, 80,00% being the lowest (E) and 99% the highest (MT); - Some countries have targets but no results as in DE, ES, RS and SK. - SK increased its D+2 target from 93,00% in 2017 to 94,00% in 2018. In 2018, 921 out of the 1522 countries which provided their targets and results for parcels achieved their targets, 523 recorded progress (or stability) in their transit time quality regarding the previous year while 724 recorded a decline.

Figure 10 – Targets and results of single-piece parcels in 2018

D+1 D+2 D+3 D+4 D+5 D+6 Target Result Target Result Target Result Target Result Target Result Target Result AT 90,00% not yet 100,0% not yet BE 95,00% 83,5% BG 80,00% 41,50% 95,00% 79,40% CH 95,00% 97,20% 95,00% 97,70% DE 80,00% na

16 BE, DE, FR, IT, MT, PT, SK, UK. 17 BE, DE, FR, IT. 18 MT, PT. 19 UK. 20 SK. 21 CH, HU, IT, LT, LV, MT; NO, PT; SI. 22 BE, BG, DK, FR, HU, IT, LT, LV, MT, NO, PL, PT, SI, UK. 23 HU, IT, MT, NO, .UK. 24 BE, DK, FR, LT, PL, PT, SI.

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D+1 D+2 D+3 D+4 D+5 D+6 Target Result Target Result Target Result Target Result Target Result Target Result DK 93,00% 92,60% ES 80,00% not yet 95,00% not yet FR 91,00% 90,30% 98,50% 99,20% HU 85,00% 99,20% 95,00% 99,80% IT 90,00% 95,10% LT 97,00% 99,00% LV 98,00% 98,00% MT 98,00% 99,45% 99,00% 99,83% 99,00% 99,85% NO 85,00% 95,10% 97,00% 98,10% PL 80,00% 71,70% 90,00% 97,80% PT 92,00% 94,80% RS 80,00% 90,00% 95,00% na SI 80,00% 99,40% 95,00% 99,80% SK 94,00% na 99,00% na UK 93,00% 91,50% 98,50% 98,40% Total 7 7 10 6 8 6 6 5 3 0 1 1 Average 90,57% 82,50% 88,90% 94,31% 92,44% 98,41% 94,58% 97,28% 96,67% na 97,00% 98,10% Note: BE: Common target defined by the Management Contract. SK didn’t measure this service in 2018. In 2018 DE and MT had regulatory objectives for transit time for bulk parcels, presenting its results. Both presented the same values, both for the objectives and the results, that they had presented to the single-piece parcel service. In UK the quality of service metrics are set on the financial year basis from April to March. In this sense, the result is referring to 2018-2019.

4.1.5. Additional information regarding quality of service in 2018 In addition to the measurement of transit time of the main postal services above (letters and parcels), some countries also used other types of indicators to monitor quality of service, such as the measurement of loss or substantial delay. Some countries also monitor transit time of bulk mail, newspapers and periodicals. Regarding loss or substantial delay, 6 countries had regulatory objectives in 2018 (see figure below). SI only measured loss or substantial delay of priority mail, registered item and single-piece parcels and CH do the same for priority mail, non-priority mail and single-piece parcels.

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Figure 11 – Regulatory objectives for loss or substantial delay in 2018

Non- Registered News-paper Single piece Priority mail priority Bulk mail Bulk parcel item / periodical parcel mail HU ✓ ✓ ✓ LV ✓ ✓ ✓ MT ✓ ✓ ✓ NO ✓ ✓ ✓ ✓ PT ✓ ✓ UK ✓ ✓ ✓ ✓ Total 14 5 3 3 2 2 4 0

Regarding the methodology of measure the transit time of bulk mail, HU, IE, IT, MT and LU set regulatory objectives. FR, HU, IT, MT and LU measured this service, of which FR, HU and MT used the European standard EN 14534 and LU used EN 13850. IE and IT hasn’t indicated any methodology. Regarding newspapers and periodicals, only MT and PT set regulatory objectives. DK and FR measured transit time for newspapers and periodicals but without regulatory objectives. DK used the European standard EN 14508 to measure the transit time for newspapers and periodicals and FR and PT used the European standard EN 14534. MT hasn’t indicated any methodology. Regarding non-compliance and corrective measures, 17 countries has framework of corrective measures in case of non-compliance with the quality of service target and 10 have had recent cases or decisions regarding non-compliance and corrective measures. Regarding the measurement of single-piece priority mail, single-piece non-priority mail, registered mail, single-piece parcel and cross-border mail, it is important to note that in the majority of countries it is the operator who pays the measurement (above 67%) and more than 57% of countries indicate that the measurement is audited. The measurement of single-piece priority mail, registered mail, single-piece parcel and cross-border mail was ordered by USP in more than 68% of the countries, and in the case of single-piece non-priority mail is balanced between NRA (50%) and USP (44%). The responsible for ensuring the audit of single-piece priority mail, single-piece non-priority mail, registered mail, single-piece parcel is mainly the NRA, and in the case of cross-border mail, “others” is mentioned, which must be because International Post Corporation (IPC) is measuring this service at European level.

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4.2. Collection and delivery

Regarding collection and delivery, we have detected three key elements. Of course, the most important is the parameter on frequency of collection and especially deliveries. Secondly, we will explore the current exceptions to collection and delivery due to exceptional conditions. Thirdly, we will also look at the derogation of delivery to the home.

4.2.1. Frequency of collections and deliveries

Regarding the frequency of collections and deliveries made by the universal service provider (USP), with few exceptions, the rule is at least one collection and delivery per day for 5 days a week. The exceptions are those countries in which the obligation to carry out the collection and delivery by the USP was extended to 6 days a week. More specifically, the countries that have at least one collection and delivery per day for six days a week are Bulgaria (at least two collection and delivery per day, only in Sofia), Germany, France, Malta, Serbia (only for collection: 1 or 2 collections per 5 or 6 day a week), Switzerland (only for delivery: 6 days only for subscribed newspapers) and the United Kingdom (only for correspondence). It should be noted that in most of the cases the extension from 5 to 6 days a week takes place only regarding the of correspondence and newspapers. The split information, specifically on collection and delivery, is shown in the next two figures.

Figure 12 – Frequency of collection in Europe in 2018

1 Collection / day / 5 days a week, namely Austria, Belgium, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, Greece, Hungary, Ireland, Iceland, Italy, Lithuania, Latvia, Luxembourg, The Netherlands, Norway, Poland, Portugal, Romania, Sweden, Slovenia, Slovakia, Spain and the UK.

1/2 Collections / day / 6 days a week, namely Germany, France, Malta, the UK (6 days for correspondence) 25 Combination of 5 and 6 collection days a week, namely Bulgaria (6 days for Sofia) and Serbia.

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Figure 13 – Frequency of delivery in Europe in 2018

1 Delivery / day / 5 days a week, namely Austria, Belgium, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, Greece, Hungary, Ireland, Iceland, Italy, Lithuania, Latvia, Luxembourg, The Netherlands, Norway, Poland, Portugal, Romania, Sweden, Slovenia, Slovakia, Spain, and the UK.

1/2 Delivery / day / 6 days a week, namely Germany, France, Malta, the UK (6 days for correspondence)

Combination of 5 and 6 delivery days a week, namely Bulgaria (6 days for Sofia). An exceptional case is Switzerland (6 days

only for subscribed newspapers delivery).

4.2.2. Exceptions to collection and delivery due to exceptional geographical conditions

According to Paragraph 3 of Article 3 of the Directive25, there may be exceptions in the frequency of collection/delivery in circumstances or geographical conditions deemed exceptional, which includes

25 Article 3.3. “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.

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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. The directive underlines in the same paragraph that any exception or derogation granted by a national regulatory authority must be communicated to the European Commission, as well as to all the other NRAs.

The reasons for the exceptions of USO obligations as pointed out by respondents are:

− mountain areas: ▪ for collection (Bulgaria, France, Greece, Iceland, Italy, Macedonia, Norway, Romania, Serbia and Sweden); ▪ for delivery (Bulgaria, Croatia, France, Greece, Iceland, Italy, Macedonia, Norway, Romania, Serbia, Sweden, Switzerland and Slovakia). − population density: ▪ for collection (Bulgaria, Iceland, Italy, Macedonia, Norway, Romania, Serbia and Sweden); ▪ for delivery (Bulgaria, Croatia, Iceland, Italy, Macedonia, Norway, Romania, Serbia, Slovakia, Sweden and Switzerland). − low traffic volumes: ▪ for collection (Denmark, Italy, Macedonia, Romania and Serbia); ▪ for delivery (Italy, Macedonia, Romania and Serbia). − costs of service: ▪ for collection (Iceland, Norway and Romania); ▪ for delivery (Iceland, Norway, Romania and Slovakia). − poor infrastructure26: ▪ for collection (Bulgaria, Macedonia, Norway, Romania, Serbia and UK); ▪ for delivery (Bulgaria, Macedonia, Norway, Romania, Serbia, Switzerland and UK). − insularity: ▪ for collection (Denmark, Estonia, Finland, France, Greece, Iceland, Norway, Sweden and UK); ▪ for delivery (Denmark, Estonia, Finland, France, Greece, Iceland, Norway, Sweden and UK). − extreme weather conditions: ▪ for collection (Greece, Romania and Serbia); ▪ for delivery (Greece, Romania and Serbia).

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.” 26 Depends on local circumstances, e.g. lack of roads.

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Figure 14 – Reasons for exceptions regarding collection in 2018

12

10 10 8 9 8 6 4 4 5

2 3 3

0 Mountainous Insularity Population Low traffic Poor Cost of service Extreme areas density volumes infrastructure weather

Figure 15 – Reasons for exceptions regarding delivery in 2018

14

12 12

10 11

8 9

6 7

4 4 4 2 3

0 Mountainous Population Insularity Low traffic Poor Cost of service Extreme areas density volumes infrastructure weather

Only in 9 countries, the criteria establishing exceptional cases or locations where exceptions are applicable for collection are both defined and published (Bulgaria, Denmark, Estonia, Greece, Iceland, Ireland, Italy, Romania and UK), and in other 10 countries, for deliveries (Bulgaria, Estonia, Greece, Iceland, Ireland, Italy, Romania, Slovakia, Switzerland and UK).

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4.2.3. Obligation to deliver mail to the home or premises of every natural or legal person

Besides the obligation to ensure collection and delivery frequencies, in the execution of the universal service there may be special cases where delivery of postal items to the recipient's home is not possible for various reasons. The regulators from 17 Member States (Austria, Czech Republic, Denmark, Finland, Germany, Greece, Hungary, Iceland, Luxembourg, Netherlands, Norway, Romania, Serbia, Slovakia, Slovenia, Sweden and UK) have identified some exceptional cases where universal service providers are allowed to execute delivery under special conditions. The exceptional cases reported are: − Special geographical conditions, in 13 Member States (CH, CZ, DK, EL, ES, HU, IS, NO, RO, RS, SE, SK and UK); − Health and safety concerns, in 13 cases (AT, CH, CZ, EL, ES, FI, HU, NO, RO, SE, SI, SK and UK); − Population density, in 12 Member States (AT, CH, DK, EL, ES, HU, IS, NO, RO, RS, SE and SK); − Areas with improper toponymy (lack of streets names), in just 4 cases (EL, ES, NO and RO).

Figure 16 – Exceptions in terms of home delivery in 2018

4 12 Population density: AT, CH, DK, EL, ES, HU, IS, NO, RO, RS, SE, SK

Geographical conditions: CH, CZ, DK, EL, ES, HU, IS, NO, RO, RS, SE, SI, 13 SK, UK

Health and safety concerns: AT, CH, CZ, EL, ES, FI, HU, NO, RO, SE, SI, SK, UK

13 Areas with lack of street names: EL, ES, NO, RO

12 regulators (AT, CZ, DE, EL, ES, FI, HU, LU, NL, RO, SI and UK) have identified other exceptional situations that they have defined separately (e.g. delivery of postal item with declared value higher than 150 000 CZK, in Czech; disproportionate difficulty, in Hungary; poor infrastructure, in Romania; limited access, in Slovenia; difficult access in a round trip of 15 minutes, in UK). In 12 Member States there are special criteria for defining the exceptional cases for home delivery (AT, CH, CZ, DK, EL, HU, IS, RO, RS, SK, SI and UK): The answers revealed that the delivery service in these situations is directed to local post offices (14 countries: AT, CH, CZ, DE, EL, IS, LU, NO, RO, RS, SE, SI, SK and UK), cluster boxes (13 countries: AT, CH, EL, HU, IS, LU, NO, RO, RS, SE, SI, SK and UK), curb-side letterboxes (9 countries: CH, CZ, EL, LU,

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NO, RO, RS, SE and UK) or, in other cases, to town-halls, public authority’s offices, individual arrangements, private addresses, local USP delivery offices, letterboxes on the main land, return to the sender, places determined by mutual agreement between user and USP, etc. Regarding the number of where the delivery service is not assured at their address, just 8 NRAs submitted estimated percentages (Austria – 2%, the Czech Republic – approximately 0.002%, Iceland – 1%, Norway – 0.40%, Slovakia – 0.6%, Slovenia – 0.03%, Spain – 0,16%, Switzerland – 0.09% the UK – <1%), assuming that in the case of all other respondents these data are not available. 7 NRAs indicated that in their countries criteria for defining exceptions in terms of mail delivering to the home or premises of the recipient are published either on the regulator's website or on the universal service provider's website: Austria, Greece, Iceland, Slovakia, Slovenia, Switzerland and UK. The large majority of NRAs answered that such criteria are not published in their countries. Regarding the need to have a common set of criteria for determining the exceptional circumstances to the delivery of mail at the home or premises, only 2 regulators answered positive (Romania and Serbia). The rest of NRAs answered that we do not need common criteria at European level, or they did not have an opinion on this.

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4.3. Access points

The access points are defined in postal directive27 as the physical facilities of the postal network, where postal items may be deposited, to be processed by the postal providers. In the sections below two key components of the postal access points are analysed, namely: - Collection letterboxes - Points of contact.

4.3.1. Collection letterboxes

Requirements and standards to ensure that an adequate number of collection letterboxes are provided by the USP have been set by the majority of countries (more than 94%). Exceptions are France and Spain where those requirements and standards have not imposed in regulation.

Figure 17 – Requirements/standards to ensure an adequate number of collection letterboxes

35 AT, BG, BE,CH, CY, CZ, DE, DK, EE, EL, FI, 30 HR, HU, IE, IT, LT, LV, LU, MK, MT, NL, 30 NO, PL, PT, RO, RS, SE, SK, SI, UK

25

20

15

10 ES, FR 5 2 0 YES NO The most commonly listed criteria to ensure an adequate number of collection letterboxes are the following: • one collection letterbox per number of inhabitants depending on the type of settlement (difference is marked between urban and rural areas) (BG, EL, IT, LV, PT, RO, SK, SI); • maximum distance between letterboxes and postal user and number of inhabitants per letter box (CY, CZ, HU, NL, RS);

27 Article 2of the Directive 2008/06/EC

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• maximum distance between letterboxes. (DE, FI, HR); • number of letter boxes shall always 'meet the demands of the users' (DK, LU, PL); • number of collection letterboxes per community / locality (BE, CH, MK, PT). • maximum distance between letter box and postal user (AT, IE, EE, LT, MT, UK)

In addition, these requirements may also be combined, so the countries are clustered according to the prevalent type of criteria. In 25% of countries the criteria are given by the number of inhabitants, but there is also a difference in requirements concerning rural and urban areas. Maximum distance between letter box and postal user is criteria for almost 20% of countries. Denmark and Luxembourg are examples of a “custom-made” approach, where the network of letterboxes is not based on predefined criteria but has to be built according to users’ needs, or local demand in case of Poland. Poland’s addition criteria refer to the percentage of mail boxes installed in a manner and location facilitating the use by a disabled person in a wheelchair that has to be more than 95%. In more than 61% of the respondent countries’ requirements can be found mainly in legislation. In almost 30% of countries those requirements are set in regulation or decisions issued by the NRA. In Lithuania these requests are granted with authorization. In Denmark requirements for setting letterboxes are in both legislation and authorisation. In Slovenia and Romania requirements for setting letterboxes are in both legislation and regulation. Figure below shows in which legal act are the requirements or standards of ensuring an adequate number of collection letterboxes defined. Figure 18 - Type of legal act that regulates the criteria for setting letterboxes

20 19 AT, BE, CH, CY, CZ, DE, DK, EE, EL, 18 FI, HR, HU, LT, LU, NL, SI, PL, RS, RO 16

14 BG, IE, IT, MK, MT, NO, 12 SK, PT, UK 10 9 8 6 LV 4 2 1 0 Legislation Authorization Regulation

Information on the collection time is marked on the collection letterboxes in 90 % of the respondents. Denmark and Ireland are countries where this information is not marked on letterboxes. In Norway, in practice, some of letterboxes are marked but there is no legal obligation to mark collection time.

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4.3.2. Points of contacts

In European legislation28, it is defined that each member is obliged to ensure that density of contact and access points meet the needs of users. In practice, these contact points are organized by postal operators (postal establishments), by third parties (agencies or stores) or by providing services directly by the mailman. Taking into account the legal requirements, it is often necessary to manage to ensure equal treatment for customers in urban and rural areas. The density of postal access points is a particularly sensitive issue in many countries, especially in remote rural areas. It is therefore very difficult to find a balance between the actual needs of the users and the cost-effectiveness of provision of the universal service. A total of 30 countries have confirmed that they have defined requirements regarding contact points in place in order to ensure that an adequate (minimum) number of postal establishments are provided by the USP. Requirements for adequate number of postal establishments are not enforced by law in Denmark and Spain.

Figure 19 – Requirements or standards to ensure an adequate number of points of contact/postal establishments

AT, BG, BE, CH,CY, CZ, DE, EE, EL, FI, FR, HR, HU, IE, IT, LT, 35 LU, LV, MK, MT, NL, NO, PL, PT, RO, RS, SE, SK, SI, UK 30 30

25

20

15

10 DK, ES

5 2 0 YES NO

28 In Article 3, 2 of Directive 2008/06/EC: “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”.

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There are very different practices in the 30 countries which have a legally requirements for ensuring adequate number of postal establishments and standards for setting those facilities. The most common criteria to ensure an adequate number of points of contact/postal establishments are: - number of postal establishments per locality/ municipality (EE, EL, FI, PT, MT, NO);

- one postal establishment per number of inhabitants, which could depend on the size of the settlement and there are differences between rural and urban areas (BG, LV, PT, RO, RS);

- maximum distance that one has to travel to the nearest postal establishment (LT, IT, PT);

- minimum number of post offices, providing UPS or full range of postal services (AT, PT, NL);

- the density of post offices and access points corresponds to the needs of users (CY, LU);

- combination of criteria per number of inhabitant and maximum distance especially in rural area (CZ, DE, HR, MK, PL, RS, SK);

- percentage of population at a certain distance from the postal establishments (BE, CH, FR, HU, NL, SI, PT, UK).

Number of postal establishments on whole territory is also additional criteria to several above- mentioned countries (AT, BE, CZ, RS, FR, HR). Generally, in majority of countries a combination of criteria is used, which varies from country to country and depends on geographical and demographic specifics. In more than 64% of respondent requirements, standards or obligations on ensuring an adequate number of points of contact are set up in legislation, in more than 22% they are in regulation or decisions issued by the NRA. Only in Latvia authorization or in license is only act. There are few cases as: - Romania and Slovakia who beside legislation those requirements set up also in regulation, or - Chez Republic who beside legislation those requirements defined also in authorization. In Switzerland, accessibility requirements will no longer be defined at national level, but at cantonal level, in order to place greater weight on the equal treatment of regions.

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Figure 20 - Requirements on ensuring an adequate number of points of contact (postal establishments provided by the Universal Service Provider)

25 AT, BG ,BE,CH, CZ, DE, EE, EL, FI, FR, HR, HU, LT, LU, NL, PL, RO, RS, SI, UK 20 20

15 IE, IT, MK, MT, NO, PT, SK

10 7

5 LV 1 0 Legislation Authorisation Regulation

So far, from the 31 countries that response, in 3 countries (DK, PL, SE) there isn’t entity in power to check compliance with the requirements on ensuring an adequate number of points of contact (postal establishments provided by the Universal Service Provider) As shown in the figure below in the majority of European states, the NRA is the authority responsible for ensuring compliance with the requirements regarding an adequate number of postal establishments on the national territory. The exceptions are Hungary and Republic of Serbia where both the competent Ministry and NRA are in charge, while in United Kingdom the competent is Ministry. Also, in Switzerland independent body approved by NRA is entitled to check compliance with the requirements regarding an adequate number of points of contact.

Figure 21- Entity entitled to check compliance with the requirements regarding an adequate number of points of contact/postal establishments

30 AT, BG, BE, CY,CZ, DE, EE, EL, FI, FR, HR, IE, IT, LT, LU, LV, MK, MT, NL, NO, PT, RO, SK, SI 24 25

20

15 CH, HU, RS, UK 10 DK, PL, SE 4 5 3

0 NRA Other None

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On the question how compliance testing was performed the most frequently, response is based on USP report (more than 60%) or based on publicly accessible information or checking user complaints (20% of the respondents). A number of countries (8% of the responses) have listed criteria that represent the combinations of the methods mentioned above, and 12% of countries refer to some other criteria. In Austria, NRA checks whether legal requirements concerning coverage are fulfilled based on economic and geographical information (from both USP and publicly available), using a geographical information . In Switzerland, applied „routing method“ measures the typical time of the whole population (by addresses) including the time of public or on foot to the next post office or post agencies (by GPS and all public connections transports). Result for 2018 of the measurement: For 94.5% of the population in Switzerland is a post office or agency available within 20 minutes. Additionally, in Croatia NRA has a possibility to carry out monitoring through the inspection in order to determine the facts and gives orders to set up to fulfill requirements according the law. In Ireland, these data are checked by monitoring quality of service. In the majority of cases (more than 60% of respondents), the competent authority has supervisory measures and the power to impose fines and sanction in case of non-compliance with requirements regarding an adequate number of points of contact. Other countries have indicated other reasons, between them most common is imposing collective measures or for example opening additional offices in Estonia and UK. Usually, measures are gradual: first the USP is asked to comply with the requirements and, only after that, a corrective measure is applied. In more than half of respondents there is competent entity (NRA) who has a power to prevent closure of postal establishment. In particular, Cyprus and UK stated that they didn’t have a practical case so far. For example, Norway NRA is not empowered to prevent closure of postal establishments as such, but the NRA is empowered to impose correctional measures in order to secure that the USP offer at least one postal establishment per municipality. The similar practice is in Luxembourg, where NRA is not entitled to impose a permanent closure or to prevent the closure of postal establishments. The temporary bans up to 1 year to carry out certain postal activities are an administrative sanction which may be imposed by the Luxemburg NRA.

Figure 22- Power to prevent the closure of points of contact/postal establishments

16 14 AT, BG, BE, CZ, EE, EL, HR, IT, LT, 14 LV, MT, RS, SK, SI 12 11 CH, DE, FR, HU, IE, LU, NL,NO, 10 PL, PT, RO 8 6

4 CY, UK 2 2 0 Yes No Other

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The analysis shows that the most common type of contact or postal establishments based on respondents is permanent post offices managed by USP (more than then 90% of respondent), followed by permanent post agencies managed by 3rd entity postal establishments (87%).

Figure 23- Types of points of contact/postal establishments of the USP

Type Number Countries

Permanent post offices 28 AT, BG, BE, CH, CY, CZ, DE, EE, EL, ES, FI, FR, HR, HU, IE, IT, managed by the USP LU, LV, MK, MT, NO, PL, PT, RO, RS, SE, SK, SI

Mobile and seasonal post 17 AT, DE, ES, FI, HR, HU, IT, LT, LV, MK, MT, PL, PT, RO, SK, SI, offices UK

Mail man managed by the 23 AT, BG, CH, CZ, DE, EE, EL, ES, HU, IT, LT, LU, LV, MK, NO, USP PL, PT, RO, RS, SE, SK, SI,UK

Permanent post agencies, 27 AT, BE, CH,CY , CZ, DE, DK, EE, EL, FI, FR, HU, IE, LT, LU, LV, managed by 3rd entity MK, MT, NL, NO, PL, PT, RS, SE, SK, SI, UK

Figure 24- Types of points of contact/postal establishments

30 28 27

25 23

20 17

15

10

5

0 Permanent post Mobile and seasonal Mail man managed Permanent post offices managed by post offices by the USP agencies, managed the USP by 3rd entity

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Figure 25- Types of points of contact/postal establishments of the USP per country

Types of points Number Country All types of points 9 AT. DE, HU, LV, MK, PL, PT, SK, SI

-Permanent post offices managed by the USP 3 ES, IT, RO

-Mobile and seasonal post offices

-Mail man managed by the USP

-Permanent post offices managed by the USP 2 FI, MT

-Mobile and seasonal post offices

-Permanent post agencies, managed by 3rd entity

-Permanent post offices managed by the USP 6 CZ, EE, LU, NO, RS, SE

-Mail man managed by the USP

-Permanent post agencies, managed by 3rd entity

-Permanent post offices managed by the USP 4 BE, CY, FR, IE -Permanent post agencies, managed by 3rd entity

In Bulgaria there is combination of permanent post offices and mail man managed by the USP. In Croatia, permanent post offices, mobile and seasonal post offices managed by the USP are the types of contacts for consumers of postal services. Specific situation is Netherlands where no longer exist Post offices in the traditional sense. The service point is a term used instead of postal office. These service points are partly managed by the USP and (for the larger part) by 3rd parties, mainly in shops (book shops or office supplies and such). Nevertheless, in permanent post office in majority of respondents there is full range of service. In mobile and seasonal post offices is mainly limited range of services as in case of mail man managed by the USP. The situation varies in cases where postal agency is managed by third parties, where have find different answers (from full-service to limited scope of services). Additionally, in Portugal, for population residing more than 10 000 meters away from the nearest postal establishment, postmen shall also perform itinerant customer service operations, which specifically include sale of stamps and prepaid envelopes, acceptance of non-registered mail, acceptance of non-registered and registered mail and home payment of postal orders. In Poland mail men are playing a complementary role to the services offered by the post offices. They offer a limited range of services and only sporadically potential customers use their services. Post agencies managed by third –party entities are commonly located in shops ( retailing). The 13 respondents stated that the postal agencies are organized in other way, the most common answers are: municipal offices, town halls, supermarkets, tourist info points, pharmacies, bookstores but even in own homes of the employees (RO).

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Figure 26- Types of post agencies managed by third-party entities

Number of Location Countries Country

Petrol kiosks 11 AT, CH, CY, DE, DK, LU, LV, NO, RS, SE, SI

Kiosk 14 AT, BE, CH, CY, DE, DK, FI, LU, LV, NO, RS, SE, SI, UK

Shops (food retailing) 23 AT, BE, CH, CY, CZ, DE, DK, EE, EL, FI, FR, IE, LU, LV, MK, NL, NO, PL, RS, SE, SI, SK,UK

Bars 4 AT, CH, EL, SI

Other 13 CY, CZ, DK, FR, MT, NL. PL, PT, RO, RS, SI, SK, UK

Figure 27 -Types of permanent post agencies, managed by 3rd entity

25 23

20

14 15 13 11 10

5 4

0 Petrol kiosks Kiosk Shops (food Bars Other retailing)

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ERGP PL II (19) 35 Report on QoS, consumer protection and complaint handling

The figures below illustrate the location of post agencies managed by third-party entities for 25 countries, which shows that they are mainly located all over the country (urban and rural area).

Figure 28-Location of permanent post agencies, managed by 3rd entity

20 AT, CH, CY, DE, DK, EL, FI, FR, HU, IE, 19 LU, LV, NL, NO, PT, RS, SE, SI,UK 18 16 14 12 10

8 CZ, ES, MK, SK 6 MT, PL 4 4 2 2 0 Urban Rural Urban and rural

Figure 29 -Percentage per location of permanent post agencies, managed by 3rd entity

8%

16% Urban Rural Urban and rural 76%

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4.4. Monitoring of consumer satisfaction

According to the responses to the 2018 questionnaire, almost 55% of the NRAs respondents are monitoring indicators of consumer satisfaction in their country and almost all of these publish the respective results.

The figure below highlights the overall situation regarding the monitoring of consumer satisfaction in Europe, in 2018.

Figure 30 – Monitoring of consumer satisfaction conducted by NRAs and USPs in 2018

BE, CY, CZ, EL, FI, HU, IE, LV, LT, MT, MK, PL, AT, CZ, DE, EE, HR, HU, IE, IS, LU, PT, RO, SE, SI, SK, UK MT, MK, NL, PL, PT, RO, SE, UK 20 18 18 17 16 15 15 14 13 12 10 8 BE, CZ, EL, FI, IE, LT, MT, MK, CH, CY, FR, IT, RS PL, PT, RO, SE, SI, SK, UK 6 3 5 4 2 BG, FI, LV 0 NRA USP Yes No Publish No info

Note:

The Serbian NRA hasn’t monitored consumer satisfaction in 2018th but they research this periodically, every 2- to 3 years. Annex 9 contains more information on how NRAs monitor consumer satisfaction and links where the published surveys can be found.

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Surveys regarding customers’ needs In terms of surveys regarding customers’ needs 18 NRAs indicated that they conduct such surveys and 16 of them publishing the results. The regularity of these surveys varies a lot and they are mostly carried out on an ad hoc basis to serve regulatory needs. Only 11 NRAs indicated that the USP conducts surveys regarding customers’ needs, but the large majority of respondent NRAs (18) do not have information regarding this issue. The figure below highlights the overall situation regarding the monitoring of customers’ needs in Europe, in 2018.

Figure 31 – Surveys on customers’ needs conducted by NRAs and USPs in 2018

AT, BG, DE, DK, EE, FR, HR, HU, IE, BE, CY, CZ, EL, FI, HU, IE, IS, LT, LV, MT, MK, NL, PL, PT, RO, SE, SK, UK MT, NL, PL, PT, RO, SE, SI, UK 20 18 18 18 16 16 15 AT, BG, CH, DE, DK, BE, CY, CZ, ES, IS, IT, 14 EE, ES, FR, HR, IT, LU, LU, LT, NO, RS, SI 12 MK, NO, RS, SK 11 10 BE, CY, CZ, EL, IE, IS, 8 CH, EL, FI, LV LT, LV, MT, NL, PL, PT, 6 RO, SE, SI, UK 4 4 3 2 CY, IS, RS 0 NRA USP

Yes No Publish No info

Note: The Serbian NRA hasn’t monitored consumer needs in 2018th but they research this periodically, every 2 or 3 years. Annex 10 contains data on how NRAs conduct these surveys and links where the information published can be found, even many of these links lead to documents written only in the language of the Member State concerned.

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4.5. The impact of E-commerce on the postal field In the past few years the volumes of postal mail traffic have been constantly regressing. On this background, the parcel post volumes increased in the same time with the development of the e- commerce domain. Given the close interaction between internet and postal services through the e-commerce it should be mentioned that the European Commission defines as a European priority the development of the digital (DSM). The DSM emphasizes the need to ensure the free movement of people, services and , and also to bring businesses into the online environment, under fair conditions of competition, the European strategy for DSMs development being based on 3 main pillars: access, environment and . Considering all this, in the Commission’s political guidelines it is mentioned as a priority the development of the Digital Services Act that will upgrade the Union's liability and safety rules for digital platforms, services and products. Also from the regulatory perspective, have to be mentioned the Regulation 2018/644 of the European Parliament and of the Council on cross-border parcel delivery services with the scope to encourage the development of e-commerce, this Act coming to meet the needed development both for e-commerce businesses and for postal services, with emphasis on international intra-community services considering that it seems that cross-border e-commerce is still lagging behind compared to national e-commerce. Taking in account the above mentioned, the ERGP integrated for the second consecutive year in the questionnaire on quality of services and complaints a distinct part related to the impact of e- commerce on the postal field. The received responses revealed the following conclusions: The vast majority of regulators in the Member States have no attributions in terms of regulation and monitoring of e-commerce field, do not have accurate data on the development of e-commerce and they did not make specific studies on the impact of e-commerce on the postal services sector. The only two exceptions regarding the regulatory and monitoring attributions in the field of electronic commerce are the NRAs from Cyprus and Malta. In most European countries, the bodies that have powers in terms of regulating and monitoring e-commerce are the ministries of communications. However, in most cases, it seems that the most consistent data regarding electronic commerce are held by consumer protection and various associations of the e-traders. In these conditions, one of the conclusions drawn from the received answers is that in the vast majority of cases, the NRAs do not monitor the e-commerce postal flows. The authorities in Bulgaria (CRC) and Slovenia (APEK) have begun to develop a way of monitoring the e-commerce postal flows through the annual statistical exercise but have not yet reached conclusive results in this regard.

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Before 2018, just few NRAs have carried out surveys on e-commerce field on their own or through participation with a third party. For example: - Belgium29: In order to get a clear insight into the situation of e-commerce in Belgium, BIPT has hired a third party for mapping out the possible obstacles to the growth of e-commerce as regards parcel delivery. The study identified some obstacles to the growth of e-commerce and also offers some recommendations to boost e-commerce in Belgium. - France30: ARCEP developed together with a third party the Study on the cross-border parcels generated by the e-commerce. The study was published in June 2017. - Greece31: A study on e-commerce was completed during 2015 regarding the parcel’s delivery services. A special case is Romania: Starting with 2016, ANCOM has decided to build a tool for monitoring the impact of e-commerce on the postal field. Thus, in 2017 a first study was conducted in this regard, the methodology and results obtained not being made public. However, the study became annual and in 2018 was published on the authority's website. From a methodological point of view, the study carried out by ANCOM comprised over 99% of market in terms of volume and revenues, and generated relevant conclusions regarding the quality of the parcel services and the impact of e- commerce on the Romanian postal market during 2017. A very important fact to mention is that in connection with the necessity of implementing a common method of monitoring the impact of electronic commerce on the postal services markets in Europe, 14 NRAs answered positively, 10 NRAs answered negatively, and 9 NRAs had no opinion yet. Considering a possible common methodology for monitoring the impact of e-commerce on the postal fields in the European states, there were proposed for several potentially necessary indicators: the traffic volumes generated by the e-commerce, the revenues collected from the processing postal items generated by e-commerce, types of services and postal items generated by e-commerce, complaints and types of users. Almost all the NRAs that have expressed the desire to implement a common monitoring methodology considered that all the proposed indicators are suitable to be integrated into it. As a conclusion all the NRAs are interested in monitoring the impact of e-commerce on the postal field but developing a common European methodology is still premature, so we suggest that ERGP continue to report on national NRA activities in this field.

29 http://www.bipt.be/en/operators/postal/universal-and-non-universal-postal-services/communication-by- the-bipt-council-of-18-may-2017-regarding-the-results-of-the-study-on-the-belgian-market-for-parcel- delivery-in-the-context-of-e-commerce-activities . 30 https://www.arcep.fr/fileadmin/cru-1557996259/uploads/tx_gspublication/etude-colis-transfrontiere- juin2017.pdf 31 http://www.eett.gr/opencms/export/sites/default/EETT

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5. Current situation regarding consumer protection and complaint handling procedures

The complaint handling and consumer protection questionnaire results have been analysed from the following five perspectives: 5.1 competence of NRAs on complaint handling; 5.2 information provision and access to complaint handling and dispute resolution; 5.3 compensation schemes for individual customers; 5.4 indicators on complaints; 5.5 data on complaints by NRAs.

5.1. Competence of NRAs on complaint handling This subchapter evaluates the scope and competence of the NRAs in handling users’ complaints about postal services. In recent years, the situation in this respect remains stable and there are no changes. The number of NRAs declaring to be responsible for dealing with users’ complaints remains over the last three years at the same level - 26 of them are engaged in the complaint procedures. In the large majority of countries (79%) NRAs have this competence, most of which covering complaints about all postal services. Only in few cases we have to do with other situations, e.g. ComReg in Ireland has regulatory remit to accept, for resolution, complaints which remain unresolved after due completion of all the procedures of a postal service provider’s own complaints and redress code of practice. Consumers must have exhausted the complaints procedures of the postal service provider before ComReg can accept such complaints. Sometimes the competences of the NRAs in this field are not clear - in the Netherlands there is no explicit legal basis for dealing with complaints from users. If the NRA considers it pertinent to performing its tasks (supervision of compliance with the provisions of the Postal Act 2009, the Competition Act and relevant consumer legislation) it may address these issues. In Luxembourg the NRAs intervene only in cases involving loss, , damage or non-compliance with service quality standards. It should be pointed out that the powers of NRAs on complaint handling are split. Although in most countries they are dealing with users’ complaints, there is still a significant number of countries (21%), where complaint handling is out of their competence. While the role of those NRAs is regulation of the postal sector, they are unable to investigate and resolve individual complaints about postal services. In some cases, such as in Serbia, the competent ministry is responsible for resolving the complaints, instead of the NRA.

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All the countries where NRAs are responsible for dealing with users’ complaints have procedures in place to resolve the complaints. The chart below illustrates the situation regarding the competence and respective scope of the NRAs in complaint handling in 2018.

Figure 32 – NRAs dealing with users’ complaints in 2018

AT, BG, CH, All postal CY, CZ, DE, services DK, EE, EL, 22 FR, FY, HR, HU, IS, IT, NO 7 YES 26 LT, LV, MT, PT, RO, SI, SK

Only US 1 FI BE, ES, Other situations 3 NO, PL, IE, LU, NL RS, SE, UK

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5.2. Information provision and access to complaint handling and dispute resolution This subchapter analyses the information available to users on complaint handling procedures, redress schemes and means of dispute resolution, also looking at the existence of regulation regarding complaints handling and alternative dispute resolution schemes. The graph below indicates that in 2018 the majority of countries had obligations in place for postal service providers to publish information regarding procedures to complain, compensation schemes and dispute resolution, splitting this duty relatively equally between the USPs, the other postal service providers active in the universal services area (OPSP.US) and other postal services providers (OPSP). Usually this obligation was implemented with the use of the provider’s website access points, as well as general terms and conditions), Compared to previous years, there was a significant improvement in 2018 with regard to the information obligation of all procedures, especially in relation to dispute resolution, regardless of the type of operator – whether it was USP, OPSP.US or OPSP.

Figure 33 – Obligations to provide information about complaints handling in 2018

30 27 26

25 23 22 21 21 21 20 19 17

15

10

5 3

0 Procedures to complain Compensation / redress Dispute resolution No obligation schemes USP OPSP.US OPSP

Note: The list of countries where postal service providers are obliged to provide information is available in the appendices (annex 10). In respect to the regulation of complaints handling procedures, the situation is stable in the last few years. Most NRAs (75%) indicated establishment of such regulations (BE, BG, CZ, DK, EL, ES, FR, MK, HR, HU, IE, IS, IT, LT, LU, LV, MT, NO, PL, PT, RO, RS, SI, SK, UK), almost the same number as in 2017. Usually the existing complaints handling procedures include all postal service providers. It should be pointed out that in 8 countries (AT, CH, CY, DE, EE, FI, NL, SE) this area has been outside the scope of regulation. In some countries, regulation of complaint handling procedures is limited. As in Norway, only principles for providers' complaint handling /procedures are given in the regulations. However, the providers shall, according to the regulations, give the NRA information about the specific content in their complaint handling procedures (including any changes), and the NRA can impose changes in the complaint procedures.

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In general, among the complaints handling procedures mostly the principles, channels for lodging complaints and deadlines are regulated. The scope of application of alternative (or out-of-court) dispute resolution mechanisms (ADR) has been at the very similar level in the last three years. In 2018 ADR was available in 27 countries, to cover almost entire territory of Europe. Only a small group of countries is getting out of these statistics - in DK, HR, IS, RO and RS dispute resolution mechanisms were still not available for the consumers. Participation in out-of-court resolution of consumer disputes is usually voluntary and the consent must be expressed by both parties to the dispute. In very few cases (six countries) the ADR mechanism is mandatory. It is worth to notice that e.g. in the UK ADR is compulsory for the USP (Royal Mail) only, not for other providers. In out-of-court resolution of consumer disputes different legal solutions are used. For example, in Malta the customer may file a claim before the Consumer Claims Tribunal. that is empowered to determine disputes between the customer and the trader. In Poland the President of the NRA is the entity authorized to conduct proceedings in this respect. Figure 34 – Alternative (or out-of-court) dispute resolution in 2018

BE, LV, MK, Mandatory 7 MT, NO, PT, UK Voluntary 21

NO 5 YES 28 AT, BG, CH, CY, CZ, DE, EE, El, ES, FI, FR, HU, IE, IT, LT, LU, DK, HR, IS, NL, PL, SE, RO, RS SI, SK

Referring to the issue of the standards it is worth noting that the CEN standard EN 14012 on complaints handling principles relates to both domestic and international postal services. It also provides guidelines for compensation procedures and damage compensation. The situation has not changed significantly compared to previous years. Most countries (18) apply the standard EN 14012 (BE, CH, CY, FR, HR, HU, IS, LT, MT, NL, NO, PL, PT, RS, SE, SI, SK, UK), in some cases partly or on voluntary basis (Switzerland and Norway). Usually the standard is implemented by the USPs. There is no information about the implementation of EN 14012 by other postal service providers, apart from the Netherlands (USP, OPSP.US and OPSP).

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5.3 Compensation schemes for individual customers This subchapter looks into the existing compensation schemes for individual customers, with a focus on their framework, scope and disclosure. There are no major changes compared to the previous year. Compensation schemes are mostly used on an obligatory basis. The obligation for a specific compensation scheme to be applicable to individual consumers is broadly evenly spread out between all postal operators (USP, OPSP.US, OPSP), although the USPs are the operators that are the most active in this area (62.5% countries). In five countries (DK, IS, MT, PT, UK) – only the USP is involved in compensation schemes what means that other operators are not able to meet the expectations of their customers. This puts the customers in a difficult situation. The main reason of failure to apply an obligation for a specific compensation scheme to individual consumers was lack of appropriate provisions in postal law. Compensation schemes are often determined by the postal operators and included in the contract for the provision of services. The compensation is also subject to civil law.

Figure 35 – Mandatory compensation schemes for individual customers in 2018

BG, DK, EL, ES, FR, HR, HU, IE, IS, IT, LU, LV, MK, MT, PL, PT, RO, USP 20 RS, SK, UK

BG, DE, EL, ES, FR, HR, HU, IE, IT, NO 9 OPSP.US YES 24 LT, LU, LV, MK, 19 NO, PL, RO, RS, SI, SK

OPSP AT, BE, CH, 15 BG, EL, ES, FR, CY, CZ, EE, FI, MK, HR, HU, IE, NL, SE IT, LU, LV, PL, RO, RS, SK

The situation in respect of types of service failures covered by existing compensation schemes was very similar to that in the previous reference period. The figure below shows that in the majority of countries (65.6%) the compensation covers first of all items damaged and items lost or substantially delayed. These types of schemes are mainly ensured by the USPs. The competitors (OPSP.US and OPSP) slightly give way to the USPs in this respect. This may suggest that the competitors of the USPs attach increasing importance to the issue of complaint handling. Compensation schemes for items arriving late are also quite well established. Other types of service failure are represented to a lesser extent, regardless of the type of provider.

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Figure 36 – Coverage of existing compensation schemes for individual customers per type of service failure in 2018

20 Item lost or substantially delayed 18 14 20 item damaged 16 12 14 Item arriving late 13 11 6 Misdelivery 4 2 4 How complaints are treated 2 2 3 Mail delivery or collection 3 3 3 Other 2 2 2 Change of address 0 0

0 5 10 15 20 25

USP OPSP.US OPSP

Note: The list of countries per postal service provider and type of service failure covered is available in the appendices (annex 11).

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5.4. Indicators on complaints This chapter deals with the subject of measurement and publication of complaint handling indicators by the USP, along with analysis of existing obligations and their scope. In general, there are no substantial changes compared with the previous year. In most countries (79%), USPs are obliged to measure and/or publish indicators on the complaints they receive. Sometimes, for example in Austria, there is no obligation to publish, but obligation to inform the NRA about the number of complaints received. This obligation is usually set out by primary or secondary postal law. Occasionally it is derived from licence conditions, NRAs decisions or procedures based on the standard EN 14012. In most cases the existing obligations include both the measurement and publication of the indicators. A standard set of the indicators consists of the number of complaints received and the number of resolved/unresolved complaints. It is often a part of a report on postal activities submitted to the NRA. Such elements as average response times and the number of complaints which lead to a compensation were less common. There is still a relatively high percentage of countries (21%), where there is no obligation to measure and/or publish complaint handling indicators by the USP. It seems that customers should have access to this type of information as the lack of knowledge in this area puts them at a disadvantage.

Figure 37 – Obligation to measure and publish indicators on complaints in 2018

To measure and publish CZ, EE, EL, 19 FI, FR, HR, NO 7 YES 26 IT, LT, LV, MK, MT, PL, PT, RO, RS, SE, SI, SK, UK Only to measure 7 BE, DE, DK, HU, IS, LU, AT, BG, CH, NL CY, ES, IE, NO

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5.5. Data on complaints by NRAs This subchapter focuses on the data collected by NRAs on the number of complaints concerning postal services, particularly cross-border services.

5.5.1 Data on complaints by NRAs

As shown in the figure below, the situation regarding the collection of data by NRAs on complaints received by postal service providers remains similar to what has been observed in the last few years. The majority of NRAs (88%) collect data on the number of complaints received by the USP about universal services, mostly in total numbers and by category. However, it should be pointed out that some NRAs, for instance CTU (Czech Republic), do not distinguish between universal services and non-universal services provided by postal service providers other than the USP, as they collect this data together. In addition, the number of complaints received by OPSP operating in Serbia, which is collected by RATEL, refers only to express services. Despite the differences in data collection, it is possible to conclude that the trend in recent years has not changed, thus fewer NRAs collect data on complaints regarding universal services provided by OPSP.US and complaints regarding non-universal services.

Figure 38 – Collection of data by NRAs on the number of complaints in 2018

30 27

25

20 19

15 14 12 11 9 9 10 8 7 6 5 5 4 4 4 5 3

0 USP OPSP.US USP OPSP.US OPSP Universal services Non-Universal services Do not collect

Total Category Service

Note: The list of countries where NRAs collect data on complaints and from which postal service providers is available in the appendices (annex 9.1).

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The measurement of complaints can be made resorting to the number of complaints received by postal service providers – especially the USP, which in some countries is obliged to publish indicators on the complaints received – and/or to the ones directly addressed to the NRAs responsible for handling users’ complaints.

Taking a closer look at cross-border services, the chart below illustrates the collection of data by NRAs regarding the number of complaints received by postal service providers and NRAs in 2018. In 2018, the majority of NRAs that collected data specifically regarding this matter have done so based on the number of complaints received by USPs. It appears that the number of complaints received by NRAs has decreased comparing with 2017. It should be noted that when it comes to the number of complaints received by USPs, the data collected by CRC (Bulgaria) and TELEOFF (Slovakia) refer only to justified complaints, i.e. the complaints in which the USP recognised the failure. Also, the data collected by ANACOM (Portugal) refer to complaints answered by the USP and regarding universal services only. The collection of data by NRAs on the number of complaints received by OPSP.US and OPSP does not differ much from the situation verified in 2017 and in recent years. The most complained issues regarding cross-border services mentioned by NRAs are related to the quality of delivery, such as items lost, damaged or substantially delayed.

Figure 39 – Collection of data by NRAs on the number of complaints about cross-border services in 2018

BG, CH, CZ, DK, HR, IT, LV, MK, PT, RO, RS, SE, SK 14

12 13

10 CZ, EE, EL, HR, LV, PT, SK 8 CZ, MK, RO, RS, SK 6 7 BG, CZ, RO 4 5

2 3

0 USP OPSP.US OPSP NRA

Complaints on postal services collected by NRAs

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5.5.2 Complaints received by USPs and NRAs

The charts presented in this subchapter illustrate data on the number of complaints received by USPs and NRAs in 2014, 2017 and 2018 per country and per number of inhabitants in each country32. Once again, complaints regarding cross-border services are detailed. The following figure shows the complaints received by USPs about universal services per country per 1,000 inhabitants. In 2018 the complaints rate ranged from 20.15 (France) to 0.03 (Cyprus). Overall, the number of complaints has increased since 2014, as does the population of each country, except for rare exceptions. Nevertheless, the same trend cannot be concluded when comparing the data from 2017 and 2018, whereas the complaints rate is steady or has decreased in some cases. Looking at the geographic clusters, the overall complaints rate remains higher in western countries and lower in eastern and southern countries.

Figure 40 – Complaints received by USPs about universal services per country per 1,000 inhabitants, 2014, 2017, 2018

30

25

21,49 20,15

20

16,91

15,86

13,78

13,26 12,86

15 12,84

12,49

11,99

10,98

10,71

10,69

10,16

9,76

9,68

8,66

8,50

8,39 8,24

10 7,86

7,80

7,74

7,56

7,20

6,99

6,25

5,61

5,59

5,36

5,30

4,84

4,50

3,90

3,60 3,60

3,22 2,85

5 2,85

2,74

2,62

2,32

2,30

2,26

2,21

2,00

1,73 1,73

1,66

1,53

1,40

1,38

1,32

1,31

1,26 1,26

1,24

1,20

1,18

1,15

1,04

0,90

0,70 0,70

0,57

0,54

0,43

0,39 0,39

0,14

0,09

0,08 0,08 0,03 0 DK FR IE LU SE UK CY EL ES IT MT PT BG CZ HR HU LT LV PL RO SI SK MK NO RS Western Southern Eastern Outside EU

2014 2017 2018

Note: The number of complaints received by USPs and the population per country are available in the appendices (annex 9.2).

It is important to reinforce that establishing a comparison between countries would be misleading and inaccurate, as there are significant differences not only in data collection methods, but also in the national regulatory frameworks and practices. The definition of complaint itself may vary, as well as the applicable rules and procedures. For instance, in Portugal the number of complaints is

32 The information on the population of each country that was used is available at https://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tps00001&plugin=1.

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strongly influenced by the existence of a legally established “complaints book”, which is available in every postal service providers’ establishments and online. There are also countries where consumers must address their complaints to the service provider before complaining before the NRA. With regard to data collection methods, there are countries that do not distinguish the type of provider or service, others that collect only justified complaints or complaints answered by the provider. The reference period for which statistical results are collected may also vary. Therefore, the data provided by NRAs is directly related to the circumstances of each country. Considering this premise, the next figure shows the complaints received by NRAs about universal services per country per 10,000 inhabitants. In 2018 the complaints rate ranged from 5.21 (Cyprus) to 0.01 (France). It is also shown there is mostly an increasing trend since 2014, despite the decreasing scenario occurred in some countries. The same applies to the comparison between 2017 and 2018.

Figure 41 – Complaints received by NRAs about postal services per country per 10,000 inhabitants, 2014, 2017, 2018

6 5,21 5

4

3 2,56

2,39 1,97

2

1,12

0,80

0,67 0,58

1 0,51

0,45

0,41

0,40

0,38

0,37 0,37

0,36 0,36

0,35

0,33

0,32 0,32

0,28

0,27

0,26 0,26 0,26

0,25 0,25

0,24

0,23

0,22

0,20

0,19 0,19

0,17

0,16 0,16 0,16 0,16

0,15

0,14

0,12

0,11

0,09 0,09

0,06

0,05 0,05 0,05

0,04 0,04

0,03 0,03

0,02

0,01 0,01 0,01 0 DK FR LU SE CY EL IT MT PT BG CZ EE HR HU LT LV RO SK MK Southern Eastern Outside EU 2014 2017 2018

Note: The number of complaints received by NRAs and the population per country are available in the appendices (annex 9.3).

The following figure presents the number of complaints received by USPs about cross-border services per country per 1,000 inhabitants. Although the number of complaints has generally increased in most countries since 2014, the upward trend is not as expressive as the one observed in the previous charts. Overall, there are no significant changes between the number of complaints received by USPs about cross-border services in 2017 and 2018. As verified in 2017, there is still a significant spread between countries – the complaints rate ranged from 4.19 (Portugal) to 0.04 (Latvia and Serbia).

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Figure 42 – Complaints received by USPs about cross-border services per country per 1,000

inhabitants, 2014, 2017, 2018 4,21 4,5 4,19 4,0

3,5 2,93

3,0 2,93 2,65

2,5 2,08

2,0 1,77 1,50

1,5 1,35

1,15

1,10 0,82

1,0 0,75

0,66

0,48

0,46

0,42

0,39

0,37

0,36 0,35

0,5 0,20

0,11

0,10

0,09

0,09

0,08

0,06

0,04

0,04 0,04

0,02 0,01 0,0 BG CZ DK HR IT LV MK PT RO RS SE SK

2014 2017 2018

Note: The number of complaints received by USPs and the population per country are available in the appendices (annex 9.4).

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ANNEX 1 – Methodology of each country for the measurement of quality of service of domestic services provided by the USP in 2018

Services Standards Count Country %

AT, BE, BG, CH, CY, CZ, DE, EL, ES, FR, Single-piece EN 13850 26 HR, HU, IE, IS, IT, LT, LU, MT, NL, NO, PL, 79% priority mail PT, RO, SI, SK, UK

Other 1 RS 3%

EN 13850 5 FI, FR, IS, LT, LU 15%

Single-piece non- BE, BG, CH, DK, HR, HU, IT, PL, PT, SK, priority mail EN 14508 11 33% UK

Other 0 na 0% EN 14534 3 FR, HU, MT 9% Bulk mail EN 13850 1 LU 3% EN 13850 6 AT, BG, ES, NO, PT33, UK34 18% TR 15472 4 BE, MT, PL, SI 14% Parcels Other 4 CH, FR35, HU, RS36 14%

EN 13850 3 LT, LU, PT37 9% EN 14508 1 SK 3% Registered mail EN 14137 1 MT 3% 38 Other 2 FR , HU 6%

Methodology AT, BG, CY, EL, ES, FR, HR, IS, IT, LU, MT, based on EN 15 45% Cross border RO, SI, PT, UK mail39 13850 Other 1 RS 3%

Methodology AT, BG, CY, EL, FR, HR, IS, IT, LU, MT, based on EN 14 42% Cross border RO, SI, PT, UK mail40 13850 Other 1 RS 3%

33 Measurement principles and rules set out in Standard EN 13850:2012, duly adapted, apply to the calculation of this indicator. 34 For D+1 parcels 35 Methodology based on a track and trace system. 36 Internal methodology of NRA 37 Measurement principles and rules set out in Standard EN 13850:2012, duly adapted, apply to the calculation of this indicator. 38 Methodology based on a track and trace system. 39 If the UNEX-Study Intern Post Corporation (IPC) system was mentioned, then the use of standard EN 13850 was considered, because they used this standard in 2018. 40 If the UNEX-Study Intern Post Corporation (IPC)system was mentioned, then the use of standard EN 13850 was considered, because they used this standard in 2018.

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ANNEX 2 – Force majeure and other exceptions which have an impact on the measurement of quality of service

2.1. Number of days of measurement impacted by force majeure events in 2018 and reasons

Number of days Geographical area Number of days Country accepted by the Reasons affected denied by the NRA NRA

Adverse weather 3 Regional 0 CH conditions 2 types (weather EL 3 National conditions in Winter and 19 general strikes) Weather conditions on PT 7 National Azores and Madeira 0 Islands Shutdown of main postal center because of security reasons SI 1 Regional (medical carantena 0 because of white powder with suspicion of bio weapon).

2.2. Other exceptions that have an impact on the measurement of the quality of service in 2018

Country Description

National holidays and public holidays; in case of an island which does not have a regular ferry, boat or flight connection which allows delivery of a postal item with the prescribed frequency. On holidays there is EE no collection or delivery, in case of island the collection and delivery are done with the frequency of connection. National (Official) or local/regional holidays are normally deducted during the calculation of quality EL measurements on any given time period. There is a 3-week period in December where quality of service measurement only applies to letters NL handed over to the USP at postal establishments (Christmas period). 1) force majeure; 2) reasons on the part of the sender or addressee, not caused by the postal operator's fault; 3) contravention by the sender or addressee of the Act or rules and regulations for the provision of postal services or universal services; PL 4) properties of a sent item. In addition, the designated operator is liable for non-performance or inadequate performance of universal services, unless non-performance or inadequate performance results from the strike of that operator's employees held in accordance with the applicable provisions. Nevertheless, there were neither force majeure events nor strikes last year. All localities located under exceptional geographical conditions are exempted from performing quality RO measurements. 792 localities in the mountain area, Danube Delta etc.

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ANNEX 3 – Data regarding quality of service measurement and audit

3.1. Information about measurement and audit regarding transit time of single-piece priority mail Who commissions or Who pays for the Is the measurement Who is responsible for orders the measurement? audited? ensuring the audit measurement? AT USP USP Yes NRA BE NRA USP Yes NRA BG NRA NRA No -

CH NRA USP Yes Other CY41 USP USP Yes USP CZ USP NRA Yes NRA DE USP USP Yes USP EE USP USP No - EL NRA NRA Yes NRA ES USP USP Yes NRA FR USP USP Yes NRA and/or USP HR USP USP Yes NRA HU USP USP Yes USP IE NRA - Yes - IS NRA USP Yes Other IT NRA USP Yes USP LT USP USP No - LU USP USP Yes Other LV USP USP Yes USP MT USP USP Yes NRA NL USP USP Yes USP NO USP USP Yes USP PL NRA NRA Yes NRA PT USP USP Yes NRA RO USP USP No USP RS NRA USP Yes NRA SE USP USP Yes USP SI USP USP Yes NRA SK USP USP Yes NRA UK USP USP Yes NRA Total of yes - - 26 - Note: considering countries for which single-piece priority mail is applicable and that have a measurement.

41 The NRA makes sure both the measurements and the audits are done in accordance with the standard EN 13850.

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3.2. Information about measurement and audit regarding transit time of single-piece non-priority mail

Who commissions or Who pays for the Is the measurement Who is responsible for orders the measurement? audited? ensuring the audit measurement? BE USP USP Yes NRA BG NRA NRA No -

CH NRA USP Yes Other DK NRA USP No - FI NRA USP Yes USP FR USP USP Yes NRA and/or USP HR - USP Yes NRA IS NRA USP Yes Other IT NRA USP Yes NRA LT USP USP No - LU USP USP Yes Other LV NRA NRA No NRA PL NRA NRA Yes NRA PT USP USP Yes NRA SK USP USP Yes NRA UK USP USP Yes NRA Total of yes - - 12 -

Note: considering countries for which single-piece non-priority mail is applicable and that have a measurement.

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3.3. Information about measurement and audit regarding transit time of registered mail

Who commissions or Who pays for the Is the measurement Who is responsible for orders the measurement? audited? ensuring the audit measurement?

BE USP - - NRA DE USP USP Yes USP FR USP USP Yes NRA and/or USP IT NRA USP Yes USP LT USP USP No - LU USP USP Yes Other MT USP USP No - PT USP USP Yes NRA SK USP USP Yes NRA UK USP USP Yes NRA Total of yes - - 7 -

Note: considering countries for which registered mail is applicable and that have a measurement

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3.4. Information about measurement and audit regarding transit time of single-piece parcels

Who commissions or Who pays for the Is the measurement Who is responsible for orders the measurement? audited? ensuring the audit measurement?

AT USP USP Yes NRA BE USP USP Yes NRA BG NRA NRA No - CH NRA USP Yes USP DK USP USP No - ES USP USP Yes NRA FR USP USP Yes Other42 HU USP USP Yes USP IT NRA USP Yes USP LT USP - No - LV USP NRA No NRA MT USP USP No - NO USP USP Yes USP PT USP USP Yes NRA RO NRA - - - RS NRA - No - SI USP USP Yes NRA UK USP NRA Yes NRA Total of yes - - 11 - Note: considering countries for which registered mail is applicable and that have a measurement

42 The last audit was commissioned by the NRA

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3.5. Information about measurement and audit regarding transit time of cross-border mail

Who commissions or Who pays for the Is the measurement Who is responsible for orders the measurement? audited? ensuring the audit measurement?

AT USP USP Yes NRA BE Other Other Yes Other USP takes part each year BG in the UNEX USP Yes Other measurement CY USP USP Yes USP EL Other Other Yes Other FR USP USP No - HR USP USP No NRA HU USP USP Yes USP IS NRA USP Yes Other IT Other USP Yes Other LU USP USP Yes Other MT USP USP - - PT USP Other Yes NRA RO USP USP Yes Other RS - - No - SI USP USP No - Total of yes - - 11 -

Note: considering countries that have a measurement

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Annex 4 – Countries in which the criteria establishing the exceptional geographical character for frequency are both defined and published

BG http://www.crc.bg/files/_bg/Spisak_notification_EC.xls DK Published on collection boxes EE http://www.riigieataja.ee./en/eli/5200 EL Published in local post offices Published in the Official Gazette: FYROM http://www.ap.mk/resource/legislativa/Pravilnik_kriteriumi_pristap_2015.pdf IS https://www.pfs.is/library/Skrar/akv.-og-urskurdir/akvardanir-PFS/Akv_PFS_nr.34_2015_.pdf IE https://www.comreg.ie/csv/downloads/ComReg14135.pdf http://www.agcom.it/documents/10179/2209608/Delibera+395-15-CONS/a9012437-c38c- IT 4baa-8fd8-257472caba41?version=1.2 RO www.ancom.org.ro/uploads/links_files/SP_Lista_localitati_exceptionale_ianuarie_2016.pdf SK http://www.posta.sk/stranky/informacie-k-otvaracim-hodinam-post UK Published on the USP website

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Annex 5 – Monitoring of consumer satisfaction

Country Surveys (periods and methodologies)

BE The BIPT performs a consumer satisfaction study every three years. In 2018 PWC performed this verification. BIPT has published the entire PWC-report (40 pages) including all recommendations formulated by PWC: https://www.bipt.be/public/files/fr/22490/Communication_Controle_Enquete_Satisfaction_Clientele_bpost.pdf All these surveys are published on a three-yearly basis. The last published one can be read on the following link: https://www.bipt.be/fr/operateurs/postal/services-postaux-universels-et-non-universels/communication-du- conseil-de-libpt-du-20-avril-2018-concernant-la-realisation-d-un-controle-de-lenquete-de-satisfaction-de-la- clientele-de-bpost

CZ The NRA monitors number of complaints to the postal services annually and publish them in the annual report. Also, the USP is obliged to publish the number of complaints on US divided to specified categories.

EL

FI Conducted yearly by the NRA. The last published data can be read on the following link: https://www.traficom.fi/fi/ajankohtaista/suomalaisten-tyytyvaisyys-viestintapalveluihin-sailyi-ennallaan

HU Consultancy , survey, every 3 – 5 years.

IE Monitored in the course of Postal Market Surveys conducted by the NRA. The last published data can be read on the following link: https://www.comreg.ie/industry/postal-regulation/postal-framework/postal-research/

LT Every two years the NRA conducts surveys on consumer needs/ satisfaction regarding postal services, availability of services. The last published data can be read on the following link: https://www.rrt.lt/wp-content/uploads/2018/07/Pašto-paslaugos-kokybės-ir-kainos-prieinamumo-apklausa- 2018.pdf

LV Studies are made on order.

MT By means of surveys carried out by the MCA every three years and by analysing complaints received. The last published data can be read on the following links: http://mca.org.mt/articles/overview-households-perception- postal-services https://mca.org.mt/articles/2017-mca-business-perception-survey-postal-services

PL The President of UKE conducts every 4 years a survey on demand for the universal service - in this sense we regularly monitor the indicators of consumer satisfaction. At the end of 2016 we ordered conducting a survey on customer’s needs that contained a part regarding consumer satisfaction. A similar survey was conducted in 2014, prior to appointing the designated operator. https://archiwum.uke.gov.pl/zapotrzebowanie-polakow-na-uslugi-pocztowe-22729

PT ANACOM collects consumer satisfaction indicators by type of service (priority, non-priority, parcels, express) and concerning also additional features (waiting time, location and number of postal establishments, accessibility for people with special needs, etc.). There indicators are collected through a survey carried out every two years by an external company (commissioned by ANACOM). The latest results (field - November 2016) are available at the following link: https://www.anacom.pt/render.jsp?contentId=1404532&languageId=1.

RO The number of complaints made by users is considered to be an indicator for user’s satisfaction. ANCOM are monitoring this indicator since many years ago and also are making studies regarding the user’s needs regularly. The last study had been made in 2015. The number of user’s complaints is published yearly in the statistic annual report.

RS NRA- every 2 or 3 years, conduct external independent surveys on customers' needs in cooperation with specialized companies. Till 2017 NRA had conduct four researches (2010. 2011. 2013. 2015.) on the needs of users of universal postal service, entitled „Researching the Level of Need Fulfilment of Universal Postal Services - Usersˮ. The survey covers issues relevant to the functioning of the postal market and the role of the main participants, in

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particular customers. The last published data can be read on the following link: https://www.ratel.rs/cyr/page/cyr-studije-iz-oblasti-postanskih-usluga

SE Study every 2nd or 3rd year by external investigation company on behalf of NRA. The last published data can be read on the following link: https://www.pts.se/globalassets/startpage/dokument/icke-legala- dokument/rapporter/2019/post/befolknings-anvandning-av-posttjanster-2019-pts-er-2019_9.pdf

SI NRA has ordered on annual basis research on consumer satisfaction regarding postal services. The last published data can be read on the following link: http://www.akos-rs.si/raziskave-o-zadovoljstvu-uporabnikov

SK The NRA does not monitor consumer satisfaction, but the NRA imposes this obligation to the USP. Consumer satisfaction is measured by an independent body (research) yearly. Indicators (e.g.): adequacy of the fees, accessibility of the post office, opening hours, handling complaints, behaviour of employees, simplicity of the products, queuing time. http://www.teleoff.gov.sk/index.php?ID=8841

UK Annual tracker research surveys and further research as required. Last user needs research published March 2019. The last published data can be read on the following link: https://www.ofcom.org.uk/postal-services/information- for-the-postal-/monitoring_reports

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Annex 6 – Surveys of customers’ needs and market surveys

Country Surveys (periods and methodologies)

BE Consumer needs will be measured on a three-yearly basis, comprising both quantitative and qualitative research. Both residential as professional users are in the scope of the research. https://www.bipt.be/nl/operatoren/post/universele-en-niet-universele-postdiensten/mededeling-van-de-raad-van-het-bipt-van-3- april-2019-met-betrekking-tot-de-controle-van-het-6de-beheerscontract-tussen-de-staat-en-bpost https://www.bipt.be/nl/operatoren/post/universele-en-niet-universele-postdiensten/mededeling-van-de-raad-van-het-bipt-van-20- december-2017-betreffende-de-controle-van-de-aanbieders-van-postdiensten-uitgevoerd-door-het-bipt-in-2017

CH

CY OCECPR conducts surveys regarding customer needs, as well as market surveys but there is no specific frequency. Below presented is the latest survey conducted in 2011 http://www.ocecpr.org.cy/sites/default/files/ps_report_presentationconsumers_gr_05-03-2012_pt.ppt

CZ The NRA made a first survey in the year 2016 for the review of the need to impose the obligation to ensure the US. In the year 2018 made the NRA market research related to waiting times at the post offices, delivery to the apartment, not only to the address, of demand related to the increase of the US . Outcomes of this research are not public. The last published data on this can be read to the following link, only in the Czech and only the results from the survey from the year 2016: https://www.ctu.cz/sites/default/files/obsah/ctu/vyzva-k-uplatneni-pripominek-k-zameru-ulozit-jako-povinnost-poskytovat- zajistovat-jednotlive/obrazky/prezkumpodless37odst.4zakonaopostovnichsluzbach.pdf

EL

FI Market survey of using parcel lockers. Not published data.

HU NRA in every 3-5 years. Survey

IE We have monitored this in the course of our Postal Market Surveys. https://www.comreg.ie/industry/postal-regulation/postal-framework/postal-research/

IS Last survey was conducted in April 2012. The last published data on this can be read to the following link: https://www.stjornarradid.is/media/innanrikisraduneyti-media/media/frettir-2013/2012-05-09_IRR_postmal_Maskinuskyrsla.pdf

LT Every two years, an independent consumer survey is commissioned. The last published data can be read to the following link: https://www.rrt.lt/wp-content/uploads/2018/07/Pašto-paslaugos-kokybės-ir-kainos-prieinamumo-apklausa-2018.pdf

LV The NRA indicated that such survey is included in the annual report, but they did not provide a link for accessing the data.

MT By means of surveys carried out by the MCA every three years. The last published data can be read to the following link: https://mca.org.mt/articles/2017-mca-business-perception-survey-postal-services

NL Article 33 of the Postal Act 2009 stipulates that the NRA systematically collects, analyses and processes information and data relating to the operation of the national market for postal services. ACM submits an annual report (Marktmonitor Post) on its findings to the Minister of Economic Affairs. The last published data can be read to the following link: https://www.acm.nl/nl/publicaties/post-en- pakkettenmonitor-2017

PL We are obliged to regularly (every 4 years) conduct surveys on demand regarding the universal service. As mentioned before at the end of 2016, we ordered a survey on customers (individual and institutional) needs. A similar survey was conducted in 2014, prior to appointing the designated operator. https://archiwum.uke.gov.pl/zapotrzebowanie-polakow-na-uslugi-pocztowe-22729

PT ANACOM commissioned two studies in 2017 (conducted by an external company): (1) Study on users' needs on the access to postal establishments and other access points, whose purpose is to identify and assess the needs of users of postal services in relation to accessibility to postal establishments and other access points in Portugal, including the opening hours of postal establishments; (2) Study on the needs of consumers of postal services, whose purpose is to identify and assess the needs of residential end-users in the

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postal sector in Portugal, in particular as regards possible shortcomings in the provision of postal services useful to consumers or in identifying elements of the postal service that may no longer be valued by consumers. The first study referred in 6.1.1 is available at the following link: https://www.anacom.pt/render.jsp?contentId=1413422 (available in English) and the second study referred in 6.1.1 is available at the following link: https://www.anacom.pt/render.jsp?contentId=1413406&languageId=1 (available only in the Portuguese version).

RO Any time needed. The last published data can be read following the next link: https://statistica.ancom.org.ro:8000/sscpds/public/alldocuments/marketstudy

RS The NRA conducts every 2 or 3 years external independent surveys on customers' needs in cooperation with specialized marketing companies. Until 2016, we conducted four studies (2010, 2011, 2013, 2015) on the needs of users of universal postal service, entitled „Researching the Level of Need Fulfilment of Universal Postal Services Usersˮ. The survey covers issues relevant to the functioning of the postal market and the role of the main actors, in particular customers. https://www.ratel.rs/cyr/page/cyr-studije-iz-oblasti-postanskih-usluga

SE Specific questions addressed in specific studies. The last published data can be read following the next links: https://www.pts.se/globalassets/startpage/dokument/icke-legala-dokument/rapporter/2018/post/bilaga_pts-er-2018- 19_undersokningsrapport.pdf https://www.pts.se/globalassets/startpage/dokument/icke-legala-dokument/rapporter/2018/post/behov-av-fysiska-brevtjanster- pa-en-digitaliserad-marknad-pts-er-2018-19.pdf

SI Part of survey of users’ satisfaction. The last published data can be read following the next link: http://www.akos-rs.si/raziskave-o-zadovoljstvu-uporabnikov

UK OFCOM may from time to time review the extent to which the universal service reflects the reasonable needs of the users of postal services provided in the UK. The review may consider whether the requirements of the universal service could be altered so as better to reflect consumer needs. The minister for the relevant government department also has the power to request Ofcom to conduct such a review. The OFCOMs first, and most recent, review of user needs, in 2013, can be found following the next link: https://www.ofcom.org.uk/__data/assets/pdf_file/0022/58432/statement1.pdf

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Annex 7 – Obligations to provide information: Countries where postal service providers are obliged to publish information on procedures to complain, compensation schemes and dispute resolution

Other Postal Service Universal Service Providers active in Other Postal Service Provider the Universal Service Providers area BE, BG, CH, CY, CZ, EE, BE, BG, CY, CZ, DK, EL, BE, BG, CH, CY43, CZ, EL, ES, FI, FR, HR, HU, ES, FI, FR, HR, HU, IE, EL, ES, FR, FY, HU, IE, Procedures to complain IE, IS, IT, LT, LU, LV, IS, IT, LT, LU, LV, MK, IT, LV, MT, NO, PL, PT, MK, MT, NO, PL, PT, MT, PL, PT, RO, RS, SE. RO, SI, SK, UK RO, RS, SE, SI, SK, UK SI, SK, UK

BG, CY, EE, EL, ES, FR, BG, CY, EL, Es, FR, HR, BG, CY, DK, EL, ES, FR, FY, HR, HU, IE, IS, IT, HU, IE, IS, IT, LT, LU, Compensation schemes HU, IE, IT, LV, MK, MT, LT, LV, MT, NO, PL, PT, MK, MT, PL, PT, RO, NO, PL, PT, RO, SI, SK RO, RS, SI, SK RS, SI, SK

BE, BG, CH, CY, CZ, DE, BE, BG, CY, CZ, DE, EL, BE, BG, CH, CY, CZ, DE, EE, EL, ES, FR, HU, IE, ES, FR, HU, IE, IS, IT, Dispute resolution EL, ES, FR, HU, IE, IT, IS, IT, LT, LU, LV, MK, LT, LU, LV, MK, PT, SI, LV, MK, NO, PT, SI, SK NO, PT, SI, SK, UK SK No obligation AT, NL

43 The OPSP in Cyprus has a licence to operate, but unitl today has not proceeded in offering any services.

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Annex 8 – Compensation schemes for individual customers

Countries that have compensation schemes for individual customers Other Postal Service Universal Service Providers active in Other Postal Service Provider the Universal Service Providers area

BG, CY, DK, EL, ES, FR, BG, CY, EE, EL, ES, FR, BG, EL, ES, FR, FY, HR, FY, HR, HU, IE, IS, IT, FY, HR, HU, IE, IT, LT, Item lost or substantially delayed HU, IE, IT, LU, LV, PL, LU, LV, MT, PL, PT, RO, LU, LV, NO, PL, RO, RS, RO, RS, SK RS, SK, UK SI, SK

BG, CY, EL, FR, FY, HR, BG, CY, EL, FR, FY, HR, BG, EL, FR, FY, HR, IE, Item arriving late HU, IE, IT, LU, PL, PT, HU, IE, IT, LU, PL, RS, IT, LU, PL, RS, SK RS, SK, UK SI, SK

BG, CY, DK, EL, ES, FR, BG, CY, EE, EL, ES, FR, BG, EL, ES, FR, FY, HR, FY, HR, HU, IE, IS, IT, Item damaged FY, HR, HU, IE, IT, LT, HU, IE, IT, LU, LV, RO, LU, LV, MT, PL, PT, RO, LU, LV, NO, RO, SI, SK SK RS, SK, UK

Change of address IE, UK

Mail delivery or collection CY, IE, IT, UK CY, IE, IT, LT IE, IT

Misdelivery DK, ES, IE, IT, PT, UK ES, IE, IT, LT, SI ES, IE, IT

How complaints are treated CY, DK, IE, IT, UK CY, IE, IT IE, IT

Other BG, SK, UK BG, SK BG, SK

No existing schemes AT, BE, CH, CZ, NL, SE

No information -

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Annex 9 – Data on complaints

9.1. NRAs that collect data on the number of complaints received by postal service providers

Other Postal Service Other Postal Service Universal Service Provider Providers active in the Providers Universal Service area Yes Yes Yes

AT, BG, CH, CY, CZ, DK, EL,

ES, FI, FR, HR, HU, IE, IT, LT, BG, CZ, EL, IT, LU, MK, PL, Total LU, LV, MK, MT, NO, PL, PT, RO, SK

RO, RS, SE, SI, SK, UK

CH, CZ, DK, EL, ES, FR, HR, Category IE, IT, LT, LV, MK, MT, NO, CZ, EL, IT, MK, PL

PL, PT, RS, SE, SI, UK AboutServices Universal CH, DK, EL, ES, FR, IT, LT, LV, Service IT, MK, PL MK, PL, PT, RS

BG, CH, CZ, EL, HU, IT, LT, BG, CZ, HU, IT, MK, NO, PL, BG, CY, CZ, EL, IT, HU, LT, Total

LV, MK, PL, RO, RS, SI, SK RO MK, PL, RO, RS, SK

CZ, EL, IT, LT, LV, MK, PL, RS, Category CZ, IT, MK, NO, PL CZ, EL, IT, MK, PL, RS

SI

Universal Services Universal

- About Non Service EL, IT, LT, LV, MK, PL, RS IT, MK, NO, PL IT, MK, PL, RS

Do not collect BE, DE, EE, NL

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9.2. Complaints received by USPs about universal service per country per 1,000 inhabitants, 2014, 2017, 2018

2014 2017 2018

USP Per 1,000 USP Per 1,000 USP Per 1,000 Population Population Population complaints inhab. complaints inhab. complaints inhab. AT 205,572 8,506,889 24.17 ------BG 685 7,245,677 0.09 8,789 7,101,859 1.24 12,228 7,050,034 1.73 CY 65 858,000 0.08 - - - 28 864,236 0.03 CZ 115,419 10,512,419 10.98 126,876 10,578,820 11.99 146,196 10,610,055 13.78 DK 16,011 5,627,235 2.85 13,350 5,748,769 2.32 18,595 5,781,190 3.22 EE 374 1,315,819 0.28 ------EL 12,618 10,926,807 1.15 18,646 10,768,193 1.73 13,533 10,741,165 1.26 ES 77,103 46,512,199 1.66 167,332 46,527,039 3.60 182,117 46,658,447 3.90 FI ------3,329 5,513,130 0.60 FR 873,834 65,889,148 13.26 1,435,712 66,804,121 21.49 1,348,463 66,926,166 20.15 HR 30,574 4,246,809 7.20 40,530 4,154,213 9.76 33,848 4,105,493 8.24 HU 21,854 9,877,365 2.21 22,180 9,797,561 2.26 35,241 9,778,371 3.60 IE44 22,290 4,605,501 4.84 25,628 4,784,383 5.36 30,214 4,830,392 6.25 IS - - - 5,696 338,349 16.83 - - - IT 85,230 60,782,668 1.40 76,293 60,589,445 1.26 79,324 60,483,973 1.31 LT 2,050 2,943,472 0.70 3,762 2,847,904 1.32 3,325 2,808,901 1.18 LU 4,321 549,680 7.86 6,326 590,667 10.71 6,436 602,005 10.69 LV 779 2,001,468 0.39 768 1,950,116 0.39 828 1,934,379 0.43 MK 4,752 2,065,769 2.30 2,166 2,073,702 1.04 1,443 2,075,301 0.70 MT 1,116 425,384 2.62 1,261 460,297 2.74 1,355 475,701 2.85 NO 63,811 5,107,970 12.49 67,601 5,258,317 12.86 67,991 5,295,619 12.84 PL 171,240 38,017,856 4.50 201,433 37,972,964 5.30 213,236 37,976,687 5.61 PT45 58,276 10,427,301 5.59 87,140 10,309,573 8.39 89,076 10,291,027 8.66 RO46 10,851 19,947,311 0.54 30,000 19,644,350 1.53 39,000 19,530,631 2.00 RS 4,095 7,146,759 0.57 535 7,040,272 0.08 981 7,001,444 0.14 SE 67,398 9,644,864 6.99 77,922 9,995,153 7.80 78,370 10,120,242 7.74 SI 1,865 2,061,085 0.90 2,847 2,065,895 1.38 2,482 2,066,880 1.20 SK 46,046 5,415,949 8.50 55,242 5,435,343 10.16 52,716 5,443,120 9.68 UK 486,336 64,351,203 7.56 1,044,522 65,844,142 15.86 1,120,559 66,273,576 16.91

44 Written complaints received by the USP and published in its annual report. 45 The values refer to complaints answered by the USP. 46 Complaints regarding universal services and non universal services.

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9.3. Complaints received by NRAs about postal services per country per 10,000 inhabitants, 2014, 2017, 2018

2014 2017 2018

NRA Per 10,000 NRA Per 10,000 NRA Per 10,000 Population Population Population complaints inhab. complaints inhab. complaints inhab.

AT 94 8,506,889 0.11 ------BG 117 7,245,677 0.16 227 7,101,859 0.32 406 7,050,034 0.58 CY 8 858,000 0.09 204 854,802 2.39 450 864,236 5.21 CZ 272 10,512,419 0.26 365 10,578,820 0.35 541 10,610,055 0.51 DK 205 5,627,235 0.36 150 5,748,769 0.26 130 5,781,190 0.22 EE 53 1,315,819 0.40 37 1,315,635 0.28 30 1,319,133 0.23 EL 168 10,926,807 0.15 291 10,768,193 0.27 264 10,741,165 0.25 ES 200 46,512,199 0.04 234 46,527,039 0.05 - - - FR 42 65,889,148 0.01 47 66,804,121 0.01 46 66,926,166 0.01 HR 58 4,246,809 0.14 72 4,154,213 0.17 134 4,105,493 0.33 HU 249 9,877,365 0.25 363 9,797,561 0.37 252 9,778,371 0.26 IS 14 325,671 0.43 27 338,349 0.80 - - - IT 115 60,782,668 0.02 159 60,589,445 0.03 221 60,483,973 0,04 LT 58 2,943,472 0.20 55 2,847,904 0.19 45 2,808,901 0.16 LU 2 549,680 0.04 22 590,667 0.37 23 602,005 0.38 LV 25 2,001,468 0.12 37 1,950,116 0.19 22 1,934,379 0.11 MK 11 2,065,769 0.05 19 2,073,702 0.09 34 2,075,301 0.16 MT 10 425,384 0.24 19 460,297 0.41 38 475,701 0.80 PT 331 10,427,301 0.32 465 10,309,573 0.45 1,152 10,291,027 1.12 RO 92 19,947,311 0.05 717 19,644,350 0.36 307 19,530,631 0.16 SE 650 9,644,864 0.67 2,554 9,995,153 2.56 1,996 10,120,242 1.97 SK 32 5,415,949 0.06 25 5,435,343 0.05 16 5,443,120 0.03

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9.4. Complaints received by USPs about cross-border services per country per 1,000 inhabitants, 2014, 2017, 2018

2014 2017 2018

Per Per Per USP USP USP Population 1,000 Population 1,000 Population 1,000 complaints complaints complaints inhab. inhab. inhab. BG47 675 7,245,677 0.09 7,815 7,101,859 1.10 8,134 7,050,034 1.15 CZ 148 10,512,419 0.01 218 10,578,820 0.02 859 10,610,055 0.08 DK - - - 4,284 5,748,769 0.75 5,490 5,781,190 0.09 HR 7,518 4,246,809 1.77 12,165 4,154,213 2.93 12,031 4,105,493 2.93 HU 6,759 9,877,365 0.68 8,021 9,797,561 0.82 11,649 9,778,371 1.19 IT48 21,779 60,782,668 0.36 21,016 60,589,445 0.35 23,440 60,483,973 0.39 LV 197 2,001,468 0.10 119 1,950,116 0.06 76 1,934,379 0.04 MK - - - 221 2,073,702 0.11 406 2,075,301 0.20 PT49 27,673 10,427,301 2.65 43,389 10,309,573 4.21 43,162 10,291,027 4.19 RO 9,287 19,947,311 0.46 13,000 19,644,350 0.66 16,000 19,530,631 0.82 RS - - - 277 7,040,272 0.04 306 7,001,444 0.04 SE 20,062 9,644,864 2.08 15,022 9,995,153 1.50 13,692 10,120,242 1.35 SK50 2,622 5,415,949 0.48 2,007 5,435,343 0.37 2,261 5,443,120 0.42

47 Number of justified complaints. 48 Complaints received by the USP related to priority mail, registered mail, insured mail and the parcel of the universal services. 49 The values refer to complaints answered by the USP about universal services only. 50 Only justified complaints, when the USP recognised the failure.

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TABLE OF FIGURES

Figure 1 Regulatory objectives in 2018 P 13 Regulatory objectives for transit time in 2018 – which kind of service Figure 2 P 13-14 has a regulatory objective Figure 3 Cross-border information per country for 2018 P 14-15 Figure 4 Targets and results of cross-border mail in 2018 P 15-16 Figure 5 Targets and results of single-piece priority mail in 2018 P 17 Targets (2018) and results (2016, 2017 and 2018) regarding D+1 Figure 6 P 18 delivery of single-piece priority mail Evolution of the average value of quality of service of single-piece Figure 7 P 19 priority mail regarding D+1 delivery (2018)

Figure 8 Targets and results of single-piece non-priority mail in 2018 P 20

Figure 9 Targets and results of registered mail in 2018 P 21 Figure 10 Targets and results of single-piece parcels in 2018 P 22-23 Figure 11 Regulatory objectives for loss or substantial delay in 2018 P 24 Figure 12 Frequency of collection in Europe in 2018 P 25 Figure 13 Frequency of delivery in Europe in 2018 P 26 Figure 14 Reasons for exceptions regarding collection in 2018 P 28 Figure 15 Reasons for exceptions regarding delivery in 2018 P 28 Figure 16 Exceptions in terms of home delivery in 2018 P 29 Requirements/standards to ensure an adequate number of collection Figure 17 P 31 letterboxes Figure 18 Type of legal act that regulates the criteria for setting letterboxes P 32 Requirements/standards to ensure an adequate number of postal Figure 19 P 33 establishments Requirements on ensuring an adequate number of points of contact Figure 20 P 35 (postal establishments provided by the Universal Service Provider) Entity entitled to check compliance with the requirements regarding Figure 21 P 35 an adequate number of points of contact/postal establishments Power to prevent the closure of points of contact/postal Figure 22 P 36 establishments Figure 23 Types of points of contact/postal establishments of the USP P 37 Figure 24 Types of points of contact/postal establishments P 37

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Types of points of contact/postal establishments of the USP per Figure 25 P 38 country Figure 26 Types of post agencies managed by third-party entities P 39 Figure 27 Types of permanent post agencies, managed by 3rd entity P 39 Figure 28 Location of permanent post agencies, managed by 3rd entity P 40 Percentage per location of permanent post agencies, managed by 3rd Figure 29 P 40 entity Monitoring of consumer satisfaction conducted by NRAs and USPs in Figure 30 P 41 2018 Figure 31 Surveys on customers’ needs conducted by NRAs and USPs in 2018 P 42 Figure 32 NRAs dealing with users’ complaints in 2018 P 46 Figure 33 Obligations to provide information about complaints handling in 2018 P 47 Figure 34 Alternative (or out-of-court) dispute resolution in 2018 P 48 Figure 35 Mandatory compensation schemes for individual customers in 2018 P 49 Coverage of existing compensation schemes for individual customers Figure 36 P 50 per type of service failure in 2018 Figure 37 Obligation to measure and publish indicators on complaints in 2018 P 51 Figure 38 Collection of data by NRAs on the number of complaints in 2018 P 52 Collection of data by NRAs on the number of complaints about cross- Figure 39 P 53 border services in 2018 Complaints received by USPs about universal services per country per Figure 40 P 54 1,000 inhabitants, 2014, 2017, 2018 Complaints received by NRAs about postal services per country per Figure 41 P 55 10,000 inhabitants, 2014, 2017, 2018 Complaints received by USPs about cross-border services per country Figure 42 P 56 per 1,000 inhabitants, 2014, 2017, 2018

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COUNTRY CODES AND NRA ACRONYMS

Country Acronym NRA Austria AT RTR Belgium BE BIPT Bulgaria BG CRC Croatia HR HAKOM Cyprus CY OCECPR Czech Republic CZ CTU Denmark DK FSTYR Estonia EE ECA France FR Arcep Germany DE BNetzA Greece EL EETT Hungary HU NMHH Ireland IE COMREG Italy IT Agcom Latvia LV SPRK Lithuania LT RRT Luxembourg LU ILR Malta MT MCA Netherlands NL ACM Norway NO Nkom Poland PL UKE Portugal PT ANACOM Romania RO ANCOM Republic of Moldova MD ANRCETI Republic of Serbia RS RATEL Slovakia SK RU Slovenia SI AKOS Spain ES CNMC Sweden SE PTS United Kingdom UK Ofcom

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TERMS AND ABBREVIATIONS

CEN – Comité Européen de Normalisation / European Committee for Standardisation

IPC – International Post Corporation

NA – Not available

NRA – National Regulatory Authority

OPSP.US – Other Postal Service Providers active in the Universal Service area

OPSP – Other Postal Service Providers

US – Universal Service

USP – Universal Service Provider

USO – Universal Service Obligation

X - Not applicable

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