The Gazette 1993

MARCH 1993

GAZETTE

Document Exchanges and the EC Green Paper on Postal Services

not automatically sufficient to ensure the survival of DXs as non-reserved services. The AEDE is aware that the scope of reserved services within the monopoly is likely to be defined by reference to certain weight and price limits. This could be immensely serious for DXs. Suppose, for example, that non- reserved services could only carry items weighing more than 500 grammes. Since around 90% of DX mail are letters weighing under 60 grammes, this would eliminate over 90% of all mail sent through the DX system. Any price restrictions would have an equivalent effect. This would force DXs out of business and compel former members to pay significantly higher charges for less efficient services. The other major worry is over the freedom of DX operators to interlink between exchanges. The majority of DX subscribers joining the DX network do so to gain access to a national mail system. Without interlinking there would be a substantial loss of custom, which would in turn force DX operators out of business. The evident concern of members and the activities of the AEDE prior to the publication of the Green Paper have certainly helped bring DXs to the attention of the Commission. Considering that DXs represent a tiny 0.9% of the whole postal market, it is noteworthy that the unique characteristics of efficiency, membership and self-delivery that set the DX service apart from the public and other private mail services have been recognised and noted in the Green Paper. Significantly, the Green Paper recommends that Member States should permit the functioning of document exchanges and in particular should allow document

by *Paul Puxon

In June, 1992 the European Commission published the long- awaited Green Paper on the development of postal services in the single market and embarked on a consultation process with Member States and all interested parties. On 28 September, 1992 the Department then responsible for postal matters, the Department of Tourism Transport and Communications, hosted a conference at Dublin Castle at which interested parties were able to express their views. So what is the Green Paper all about? Essentially, its principal objective is to define the scope of the EC postal monopolies (reserved services) needed to enable post offices (PTTs) to provide a universal service at prices affordable to all and with a satisfactory quality of service. The Green Paper also sets out which services will be subject to open competition between the national postal administration and private operators (non-reserved services). Will the EC permit Document Exchanges (DXs) to carry on operating as they do today? The answer is keenly awaited by the Irish Document Exchange and the Association of European Document Exchanges (AEDE), whose members also include DX operators from the UK, France and Belgium. Formed in 1990, the AEDE is lobbying vigorously to ensure that the DX service for time-sensitive commercial documentation is allowed to continue in its present unique form. At the moment the 1,500 users of the Irish Document Exchange, the majority being lawyers, can send mail to other DX members without any minimum weight restrictions for two thirds of the national postal rate. Ninety nine and a half per cent of this DX mail arrives by the start

Paul Puxon

of business the next working day. Understandably, the DX is popular with its members; there are over 26,000 users in the EC. Before the publication of the Green Paper, the AEDE was anxious to ensure that the DXs could be regarded by the European Commission as non-reserved services. Although, like PTTs, DXs do deliver time-sensitive mail, their modus Fundamentally, DXs are members- only clubs, used by professional business users who regularly correspond with each other. Instead of door-to-door service, DX members have their own mail box at a local exchange where they collect mail delivered to them. At these exchanges they can also self-deliver mail into the boxes of other members sharing the same exchange. Most importantly, members can send mail to other DX members at other exchanges. This is called 'interlinking'. operandi is very different to traditional postal services.

But the AEDE recognises that having a different modus operandi is