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UNI Europa Post & Logistics and its members responded to the targeted consultation on cross-border parcel delivery launched by the European Commission. The aim of the consultation is to gather views on the application of Regulation (EU) 2018/644 on cross border parcel delivery services. The Regulation is aimed at enhancing regulatory oversight and transparency in the parcel delivery sector. The feedback received from stakeholders will feed into a report on the application of the Regulation which will be published by the European Commission.
The Regulation requires parcel delivery operators to report on the number of workers they employ, their employment status and the use of subcontractors. In reporting on the application of these aspects of the Regulation, the perspective of employers’ associations and trade unions will be essential. The Commission therefore encouraged the widest possible participation of these stakeholders in this targeted consultation.
UNI Europa Post & Logistics and its affiliated postal trade unions responded to the targeted consultation with a joint position. On the regulatory aspects, the postal trade unions call for the Regulation to guarantee fair competition in parcel delivery for all operators. Blurred sector boundaries in parcel delivery mean that unscrupulous employers can evade higher-wage collective agreements through outsourcing. The expansion of low-cost and insecure employment models in parcel delivery threatens a race to the bottom in terms of pay and conditions across the whole sector. The rise of precarious employment conditions such as temporary work, subcontracting and bogus self-employment are a central feature of parcel delivery.
Parcel delivery has a price. Free delivery advertisements give the wrong impression and create market distortions with significant pressure on prices. This pressure on prices has immediate consequences on levels of wages, working conditions and create pockets of unfair competition in postal markets that have engaged network third-party access. To support a harmonised regulatory approach in parcel delivery and e-Commerce expansion, the Regulation must uphold the postal mission of services of general economic interest to benefit the citizens and the consumers. To achieve this, all market operators must compete within a regulatory level-playing field that abides by social, labour, and environmental standards and does not engage in a race-to-the-bottom in terms of wages, working conditions and profit-seeking.
UNI Europa Post & Logistics demands the establishment of a minimum regulatory floor for parcel delivery. The overall Quality of Service of the Postal Services Directive must be upheld. The Regulation review must not undermine established national practices whilst defending the provision of the Universal Service Obligation. Market liberalisation needs to be accompanied by social cohesion measures that guarantee decent wages and working conditions for all market players involved in the parcel delivery supply chain.
The adaptation of postal activities and parcel delivery must be enabled in a democratic manner with the full involvement of all stakeholders (workers, citizens, consumers) whilst accounting for the regional and national differences and divergences following postal liberalisation.
In many parts of Europe, notably rural areas, postal services constitute the only means of communication and social inclusion. The Covid-19 pandemic has shown how essential and vital it is to have access to parcel delivery and be able to order online within the single market. Postal services have a crucial role in promoting social and territorial cohesion.
Dimitris Theodorakis (UE Director P&L) says: “Instead of facilitating further blurring of the sector boundaries the new regulatory framework must guarantee good quality parcel delivery services and postal networks whilst ensuring a level-playing field for all market players involved in parcel delivery. The EU Commission must see to enact minimum criteria and stop the race-to-the-bottom in terms of wages and working conditions in parcel delivery. All parcel delivery operators (main contractors) must guarantee joint and several liability throughout their value and supply chains. Subcontracting work that does not offer decent living conditions must be prohibited either through sectoral collective bargaining, a postal licence scheme, or a combination of those to ensure decent working conditions and sustainable jobs in parcel delivery.”
Regulatory fragmentation in parcel delivery has exacerbated negative labour market trends and significantly worsened working conditions. The fragmentation also impedes fair competition in parcel delivery and fuels a race-to-the-bottom in terms of wages and working conditions. ‘Free delivery’ distorts impressions of the actual cost of parcel delivery services.
Oliver Roethig (UE Regional Secretary) said: “In assessing the Regulations’ implementation, the EU Commission should urgently seek measures to provide consumers with full transparency regarding actual delivery costs to allow an informed and responsible consumption.”
Read the submission to the consultation here.