bpost SA
bpost Group is Belgium’s leading postal operator and a parcel and e-commerce logistics provider in Europe, North-America and Asia.
ID: 448148139186-23
Lobbying Activity
Response to EU Delivery Act
14 Nov 2025
bpost supports the need to revise the directive, based on the following points: 1. Maintaining a relevant universal service : It is important to define at European level what the minimum requirements are (and for whom) in terms of access to basic postal services, taking into account the evolution of communication methods over the last 20 years. 2. Subsidiarity and flexibility: universal service varies according to national circumstances. Member States must be given the freedom to define its terms (scope, frequency, place of distribution, quality of service, etc.). 3. Financing under pressure: declining mail volumes and rising costs are making SU financing uncertain. Greater national flexibility in defining universal service conditions would delay the need for public funding. A reliable compensation framework is needed to ensure accessibility to postal service without placing excessive pressure on operators. 4. Principle of targeted regulation: regulation is only justified in the event of market failure and must apply equally to all players. It is then important to first identify such market failures. Ex-ante or SMP (Significant Market Power) interventions are not justified in a sector where competition law or other transversal regulations are sufficient. Preventive measures for postal regulators to regulate a highly competitive market are no more justified here than in other currently unregulated sectors. This even contradicts the positions taken by the Commission to deregulate certain sectors that are less competitive (e.g., telecoms). 5. No justification for increased regulation of parcels: this market is extremely competitive and dynamic, barriers to entry are low, and interconnection standards exist. There is no evidence that the parcel sector suffers from market failures requiring additional regulation beyond existing cross-cutting regulations (e.g., competition law or consumer protection). 6. No evidence that cross-border deliveries are hindering the development of e-commerce: the assumptions put forward in the call for contributions are not substantiated. The cross-border market is already competitive, which is reflected in competitive prices. 7. Complaint handling: mechanisms already exist. The consumer protection system should be uniform, regardless of the type of shipment or operator, without being limited to universal service. The creation of additional regulation that could lead to double compensation and a disproportionate administrative burden should be avoided. 8. Administrative burden: avoid adding to the regulatory burden. While simplifying certain aspects of the directive is desirable, this should not be accompanied by new obligations (whether actual or potential just in case) whose necessity is far from proven. The European Council's conclusions on competitiveness call for a reduction in administrative burdens, and the postal sector should be no exception. 9. Revision via a regulation: an approach to be handled with caution. A regulation does not guarantee uniform application of the rules within Member States (see the Regulation on cross-border parcels, which is currently interpreted and applied in a very inconsistent manner within Member States), but risks limiting the subsidiarity and flexibility of Member States to adapt the regulation to their national realities, which can vary greatly (e.g., for reasons of usage, volume, or geography).
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