FAS Sent Comments on Draft Federal Law “On Postal Service”
OREANDA-NEWS. September 24, 2010. The official web-site of the Russian Ministry of Communications published information about the Ministry drafting the Federal Law “On Postal Service”. FAS Russia, which is a co-executor of the project, has repeatedly stated its position on different aspects of performance and development of the market of postal service, reported the press-centre of FAS Russia.
The present state of the economy sets radically new requirements to the performance of the market of postal services. To meet today’s needs of society, postal services should be provided to physical persons and legal entities on the basis of different principles. There should be well-established interactions between service providers, which at the moment is practically non-existent.
For instance, due to incomplete legal framework regulating activities in the field of postal services, alternative providers of postal services exercising some operations for shipping parcels, written correspondence (accepting, processing, and sorting mail) who then use the federal postal services, pay to the federal organization of postal services according to the tariffs set for exercising the whole technological process, which forces alternative operators to fix prices for its customers higher than the prices of the “Russian Post” Federal State Unitary Enterprise.
In view of a monopolistic position of the “Russian Post” Federal State Unitary Enterprise in many segments of the market for postal services and a legal ban for private providers to render certain services (for example, cash-on-delivery consignment), the market is distorted and it infringes the interests of consumers of postal services. For instance, organizations involved in distance selling cannot use services of any providers of postal services other than the “Russian Post” Federal State Unitary Enterprise.
Entering into effect the new version of the Rules for providing postal services (1st May 2005) caused depletion of non-expensive postal services. For example, following the changes to acceptable content of small parcels, mail items that earlier could be sent as a small parcel now must be sent as a parcel, the cost of which is considerably higher (two- or threefold).
It should be concluded that development of the market of postal services depends on improvement of the market regulation and its legislative framework.
Having considered the draft Law, FAS Russia forwarded its comments to the Russian Ministry of Communications. If taken into account when editing the draft Law, these proposals would create conditions for liberalizing the market of postal services and its efficient and dynamic development.
In particular, FAS Russia proposes to additionally consider a possibility of either liquidating a statutory monopoly for some types of postal services or changing the conditions for licensing postal series.
FAS Russia also finds it unacceptable to have a monopoly on the most important segment of the postal services market – providing universal postal services, and believes it is necessary to create conditions for developing competition in this market by allowing providers that meet the requirements, approved by the Government of the Russian Federation, to render universal postal services.
To facilitate fair competition, FAS Russia would recommend incorporating in the draft Law the standards similar to those used in the European Union, where according to the Postal Directive providers must render universal services by providing access to customers or intermediaries in acceptable outlets, in accordance with the needs of those customers. Access conditions (if the latter are specially offered) must be transparent and should be published accordingly and do not contain discriminatory conditions.
FAS Russia also criticized the proposed definition of international postal communications, which gives exclusive rights for international postal exchange to the only appointed operator– the “Russian Post” Federal State Unitary Enterprise, although it is not required by the Universal Postal Union.
In the FAS Russia’s opinion, granting exclusive rights for international postal communications to appointed operators would unreasonably limit the number of potential sellers on the market in question, restrict competition and can infringe the interests of the customers using the services of international postal communications because it would limit their choice of economic entities providing such services.
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