95 / 462
GAZETTE
MARCH 1993
Document Exchanges and the EC
Green Paper on Postal Services
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
operandi is very different to
traditional postal services.
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'.
But the AEDE recognises that
having a different modus operandi is
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