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UNI Europa Post & Logistics supports the EU Commission efforts to foster affordable, high-quality, cross-border delivery services. Essential changes will help build consumer trust in online sales, building e-commerce and increasing parcel volumes.

Key obstacles outlined in the Commission communication include: high prices, inefficiencies in the market, and various obstacles to cross-border online commerce. Those obstacles include a lack of transparency, excessive cost of small shipments and lack of inter-operability between different operators. Significant investment will be necessary to realize a single market in X-border e-commerce. This includes significant investment in IT systems to further inter-operability by operators, as well as operational flexibility.

The Commission document “A Digital Single Market Strategy for Europe” does not consider working conditions and other employment aspects. While UNI Europa Post & Logistics supports efforts to create a single digital market adapted to the needs of e-retailers and customers, planned changes must not come at the expense of social, employment and/or environment standards.

The change necessary to realize the single market will have a significant impact on working conditions. Trade unions should be involved in negotiating changes in working time, salary and training for new technological applications. The sectoral social dialogue committee must be consulted to provide the Commission with its input.

UNI Europa Post & Logistics would like to highlight four areas of concern for inclusion in the public consultation:
Employment

• Competition in cross-border delivery services should not be a means to deteriorate pay and working conditions in the sector
• In its Opinion on parcel delivery, the EESC highlighted the need to define a minimum European Regulatory framework with the obligation to guarantee fair working conditions; transparency regarding the conditions and pricing of the service; continuing vocational training of staff as well as enacting the shared responsibility of operators along the entire online supply chain; and the guarantee of access to a universal service at an affordable cost
• UNI Europa P&L echoes the call of the European Parliament for member states to closely monitor outsourcing arrangements and working conditions in cross-border parcel services and to ensure workers in the sector receive adequate training
• The Commission must consider employment and social concerns, via consultation of existing Social Dialogue Committees, before further measures are taken. A self-regulatory regime by the industry is insufficient to address potential social impacts.

Social dimensions and regulatory framework

• Any assessment of cross-border parcel markets, including a review of price transparency and regulatory matters, is incomplete without inclusion of the same as part of the forthcoming Implementation Review of the Postal Services Directive
• UNI Europa P&L favors increased transparency and harmonized accounting methods as a means to ensure operators comply with existing terms of collective agreements and minimum wage legislation
• UNI Europa P&L favors increased transparency of pay structure as a means to wage dumping, unfair and unequal treatment of contractors and to guarantee a living wage for workers in parcel delivery
• Subcontracting, self-employment and short-term or part-time working models should be limited and should guarantee a living wage
• Such social dimensions should be included in the regulatory framework and overseen by the National Regulatory Authorities. Compliance by firms to the regulatory framework should be obligatory to ensure fair competition based on service quality and innovation.

Environment

• Further interoperability between operators will have a positive effect on carbon emissions
• Transparent information regarding environmental effects of operators should be available to consumers
• Social partners should be consulted in ways to adopt new technologies and procedures to mitigate environmental damage

Customer satisfaction

• Customers should be able to choose service provider on both sides of a cross-border purchase
• Information provided to consumers should include: actual cost of delivery (not listed price), service quality standards, time-definite delivery, track and trace, speed, returns options, environmental impact, etc.
• UNI Europa P&L recommends introduction of a social certificate for parcel operators indicating social standards and fair play are met
• “Free delivery” and similar terms distort impressions of actual cost of delivery service. Commission should seek measures to provide consumers transparency regarding actual costs to allow informed, responsible consumption

To conclude, UNI Europa further encourages the Commission to involve the European Social Dialogue framework as a means to consult the relevant social partners regarding proposals for the cross-border parcel initiative. Self-regulation and/or industry-led exercises and consultations are not sufficient to gather the necessary views, nor to ensure adherence to stated standards.

Annexed are the replies to the Consultation and the adopted position by the UNI Europa Post & Logistics Committee meeting on this Consultation.