Country sheet: Poland 713
Country sheet: Poland
1.1 Summary
Market characteristics
The Polish market is characterised by:
(i) The fact that Poland is a large country with an average population density;
(ii) A growing volume of the market, especially in the unaddressed segment;
(iii) The reserved area encloses items of correspondence but also direct mail;
(iv) Comparatively low quality performance of Polish Post.
Regulatory developments
• The main legal act governing postal activity in Poland is the act of 12 June 2003
(Postal Act 2003), which implements Directive 97/67/EC as amended by Directive
2002/39/EC.
• The Postal Act was amended several times. The most significant changes were
introduced by the amendment to the Postal Law of 18 March 2004 and the provisions
on the freedom of economic activity as well as by the Telecommunications Law.
Changes were, for example, made to the reserved area (reducing the weight limit to
50g and the price limit according to the provisions in Directive 2002/39/EC) and the
process for handling complaints.
Market developments
• The Polish market shows a strong development in volume growth, especially in the
unaddressed mail market. Since 2003 the total number of items grew by 94% (mainly
unaddressed mail) and total turnover increased by about 8%. It is interesting to note
that the total number of alternative operators increased very sharply (more than
tenfold). However, the large majority of these operators are active in the local market
and the main operators are mainly active in the segments for unaddressed mail, cross-
border mail, parcel mail and express.
• In the addressed mail market (including addressed direct mail) the market share of
Polish Post is above 99%. The main barrier to competition is the reserved area; the
reduction of the weight limit in 2006 (from 100g to 50g) seems to have had hardly
any effect on the level of competition in the addressed mail market. There are no
indications that this will change fundamentally before full market opening in 2013.
• In the other markets Polish Post faces more competition. In the unaddressed mail
segment, several parties such as I.D. Marketing, Integer, Dystrybucja Polska and Pro
Direct distributed 1.5 billion items in 2007 and have gained a market share of 72%.
Annex II: Main Developments in the Postal Sector (2006-2008) 714
Large international operators like TNT, DHL and UPS are active in parcels, express
and cross-border mail and compete with Polish Post (e.g. the market share of Polish
Post in parcel mail is 53% in volume and 61% in turnover).
• Access to the letterboxes by competitor postal operators seems to be a major problem,
but the regulation concerning the installation of new letterboxes may provide a
solution. Further, the VAT exemption of Polish Post is a (major) barrier to start
addressed mail delivery.
Other issues
• In terms of employment the alternative operators have grown rapidly. In 2003 they
employed 4,700 people and in 2007 nearly 21,250, while the number of Polish Post
employees was more stable in this period (about 100,000).
• Polish Post warns that the universal service is currently not sufficiently protected by
existing fiscal subsidies. In a 2007 press release Polish Post warned that in the future
the abolition of the reserved area may negatively influence the quality of service as
towards regular collection and delivery (less letterboxes, less clearing and delivery
days) and the opening hours of the post offices (shortening of opening hours).
Discussion points
• Although the actual effect is not clear yet, Poland seems to have solved the problems
related to the access of letter boxes by forcing the owners of estates and houses to
install new letter boxes (before August 2008). In the past this was seen as one of the
main barriers for entry of competition.
• Another interesting development in Poland is the strong increase in the number of
alternative operators. Although, these (local) operators mainly focus on unaddressed
mail, cross-border mail, parcel mail and express mail, this indicates that entrepreneurs
are active on the market and make use of the opportunities they have. Despite this
fact, competition in the addressed mail segment is still lagging.
Country sheet: Poland 715
Summary information on market developments:
Postal market segment / aspect Competition (market shares) Main competitors / remarks
Express Competitive UPS, DPD, GLS Poland, DHL,
TNT and Spring
Parcel (main players) NPO (46%) UPS, DPD, GLS Poland, DHL,
TNT and Spring
Unaddressed NPO (28%) I.D. Marketing, Integer,
Dystrybucja Polska and Pro Direct
Cross-border mail NPO (95%) UPS, DPD, GLS Poland and TNT
Express
Addressed mail (market share
CPOs)*
< 1% Only some local initiatives
Population density (inhabitants/km2) 118
Total addressed mail market (items) 1.8 billion items
Addressed mail volume per capita 43.9 (2006)
Status of NPO Since 1997, Polish Post has the
status of a state-owned public
utility
The (legal) preparations
conversion of Polish Post into a
joint stock company (with 100%
state ownership) started in March
2007
Main divisions of NPO Mail, parcel & express, financial
services
Note: * The market share of CPOs refers to the combined market share of CPOs in domestic addressed mail
delivery, excluding newspaper delivery. All figures refer to 2007, unless stated otherwise.
Summary information on the implementation of the Postal Directive:
Aspect Implementation and remarks
Universal service and its
financing
The universal service is in line with the Directives. The universal service should be
provided for domestic and international traffic on the territory of the Republic of
Poland, in a consistent way on comparable conditions and at affordable prices,
maintaining the quality required by law and ensuring emptying the mail boxes and
delivery of the postal items at least on every working day and not less than five
days a week. The universal service provider can obtain a subsidy if there appears
a loss on the universal service.
Reserved area The reserved area covers: (i) domestic mail: the clearance, transport and delivery
of items with correspondence and direct mail up to 50g; (ii) international mail: the
clearance, transport and delivery of items up to 50g; and (iii) domestic and
international mail: postal money orders. Items of correspondence are defined as
‘information recorded on any available material carrier, (…) with the address
inserted by the sender, with the exclusion of books, catalogues and press
magazines.’
Licensing and network
access
Postal activity with respect to the clearance, transport and delivery of postal items
within the universal postal service as well as items for blind persons, requires a
license. For services outside the universal service postal operators do not need a
license, but have to be registered on the basis of a written application. This register
Annex II: Main Developments in the Postal Sector (2006-2008) 716
Aspect Implementation and remarks
is also governed by the NRA. No specific provisions are made in the law
concerning regulated or negotiated upstream or downstream access. Provisions for
transparent and non-discriminatory access are not mentioned in the regulatory
framework. In practice there is no demand for either (yet).
Tariff principles and
transparency of accounts
Ex-ante price regulation of the reserved and USO services has been introduced
since 2008 (article 51 Postal Act 2003). There is no price-cap regulation, but the
prices of universal services should be cost based (article 50 Postal Act 2003).
Polish Post is required to keep an accounting system separately for each service
from the reserved area as well as altogether for non-reserved services (while
making a distinction between universal postal services and services outside the
universal service).
Quality of services A study on transit times between November 2006 and December 2006 showed
that only the requirements for transactional mail for D+3 was met. Polish Post also
did not meet the requirements for direct mail. The (under)performance was
influenced by strikes of mail dispatchers and postmen in November and December
2006.
The national regulatory
authority
Since January 2006, the Office of Electronic Communication (UKE) is the
responsible NRA. Before 2006, the regulatory function was governed by URTiP
(Office of the President of Telecommunications and Post Regulation). At the end of
2006 a total of 28 staff-members were responsible for postal market regulation, 12
people in the head office and 16 people in the regional offices.
1.2 General information
Poland is a rather large country with an average population density (118 inhabitants/km2
compared with the European average of 113 inhabitants/km2). Circa 11% of the 38
million inhabitants live in the five largest cities, of which Warsaw is the largest with 1.6
million inhabitants (see Table 0.1).
Table 0.1 General country information (2007)
Poland
Population (in million) 38.1*
Size of the country (1,000 km2) 323.3 *
Population density (inhabitants/km2) 118.0*
Degree of urbanisation 62.1**
Number (and percentage) of inhabitants 5 largest cities 4.3 million (11%) ***
Sources: * UPU (2006), ** UN (2005), *** World Gazetteer (2008 estimation).
Country sheet: Poland 717
1.3 Regulatory developments
1.3.1 Postal law and regulation
The main legal act governing postal activity in Poland is the act of 12 June 2003 (Postal
Act 2003) which implements Directive 97/67/EC as amended by Directive 2002/39/EC.
The Postal Act 2003 takes into account the Accession Treaty in the scope of transitional
periods negotiated by Poland, which enabled Poland to open up the market slower than in
other EU-countries. The following stages were envisaged:1
• Stage 1: from 1 January 2004 until the date of Poland’s accession to the EU, i.e. 1
May 2004. At the end of this stage the reserved area for the universal service provider
decreased from 500 grams to 350 grams;
• Stage 2: from 1 May 2004 until 31 December 2005. During the EU summit held in
Copenhagen on 12-13 December 2002, Poland was awarded a transitional period
until 31 December 2005 for maintaining the weight limit of 350 grams within the
reserved area;
• Stage 3: from 1 January 2006 until the full opening of the market, initially planned
for 1 January 2009, but postponed until 2013. Currently the weight limit is 50g and
the price limit – at least 2.5 times higher than the public operator’s tariff for the
fastest item in the lowest weight category;
• Stage 4: Fully opened postal market.
The Postal Act was amended several times. The most significant changes were introduced
by the amendment to the Postal law of 18 March 2004 and the provisions on the freedom
of economic activity as well as by the Telecommunications Law. Changes resulting from
the amendment to the Postal law in particular referred to the introduction of:
• a weight limit for postal items with correspondence within the reserved area – 50g
and 2,5 times the ‘standard’ tariff starting from 1 January 2006;
• special tariff options for bulk senders;
• a ban to subsidise universal postal service not comprising reserved services by
revenues from reserved services (excluding cases when this is necessary to maintain
universal service);
• a right to lodge a complaint on a delayed delivery of a letter item by an addressee or a
sender;
• an obligation for the public operator to present information concerning the number of
complaints on a delayed delivery of a letter item to the President of UKE, together
with its postal activity report.
1 UKE (2006), p. 99-100.
Annex II: Main Developments in the Postal Sector (2006-2008) 718
The regulations are (in short) the following:
Table 0.2 Postal law and regulation
Postal law and
regulation
Date of introduction Date of latest
amendment
Remarks
the Act of 12 June 2003 -
Postal Law
24 August 2003 10 October 2007 This act implements the regulations of
the directive 97/67/EC amended by
Directive 2002/39/EC of 10 June 2002
with regard to the further opening to
competition of Community postal
services
Ordinance on the
conditions for the
provision of universal
postal services
22 January 2004 23 July2005
Ordinance on complaints
concerning the universal
postal service in relation
to a recorded item and a
postal money order
11 November 2003 10 May 2005
Ordinance on mail boxes 28 October 2003
Ordinance on letter boxes 28 October 2003 05 May 2004
Ordinance on the method
for cost allocation of the
operator providing
universal postal services
1 January 2004
Law of 30 July 1997 on
the State Enterprise of
Public Utility "Poczta
Polska"
11 October 1997 01 January 2008
The Act of 16 July 2004 -
Telecommunications Law
2 September 2004 20 July 2007 In the field of postal matters this act
sets out the duties of the President of
the Office of Electronic
Communications (Polish NRA – UKE)
in scope of telecommunication and
postal market; settling civil law
disputes between consumers and
postal operators by Permanent
Consumer Arbitration Courts at the
President of UKE (art. 110)
Source: ECORYS questionnaire – NRA and Ministry of Infrastructure.
Country sheet: Poland 719
1.3.2 Universal Service Obligation
Scope of the universal service
The universal service is defined as the postal services consisting of (article 4.25):
• clearance, transport and delivery of:
o letter items weighting up to 2kg, including registered letters and insured letters;
o postal parcels weighting up to 10kg, including insured parcels;
o postal items for the blind persons.
• delivery of postal parcels sent from abroad weighting up to 20kg;
• handling of postal money orders.
The universal service should be provided within domestic and international traffic on the
territory of the Republic of Poland, in a consistent way on comparable conditions and at
affordable prices, maintaining quality required by law and ensuring of emptying the mail
box and delivery of the postal items at least on every working day and no less frequently,
than 5 days a week.
Financing of the universal service
Until now, the reserved area functions as a compensation for the costs of the universal
service, beside some form of state aid (see paragraph 1.5.4). When it appears that the
universal service causes a loss the universal service provider can obtain a subsidy.
Provisions for the blind
Blind persons and organisations of blind persons are exempted from the postage fee for
clearance, transport and delivery (article 30).
Other issues
In a press release Polish Post warned that the abolishment of the reserved area may
negatively influence the quality of service in regarding regular delivery, the emptying of
the letter boxes and the opening hours of the post offices.2
In a ‘Public Consultation on postal services and market opening and the universal postal
service’ (Part 2, 2006) Polish Post expressed the following interesting statements in
reaction to the 21 questions posed in the consultation, mainly related to the universal
service:
• Q2: Universal Service Obligations should not be applied uniformly as the scope of
universal service should depend on economic, geographic and other conditions of the
member states;
• Q4: Calculating the cost of the USO: there should not be any common methodology
for assessing the cost of the US (…) but a way to set the methodology;
• Q10: Role and responsibility of the NRA: we do not see any need for more precise
definitions concerning the independence, the role and responsibility of the NRAs;
• Q15: Cost coverage: each member state should decide whether to apply uniform
tariffs be applicable on its territory or not, especially that prices must be geared to
costs (…). Uniform tariffs not always cover the costs of particular service (…) when
service are provided on extensive and difficult accessible areas;
2 EurActive.com; EU news from 4
th of January 2007.
Annex II: Main Developments in the Postal Sector (2006-2008) 720
• Q17: price control: Price controls should be restricted only to universal service,
irrespective of the fact whether they are provided under conditions of market
dominance or in competitive market.
1.3.3 Reserved area:
Under the Postal Law an exclusive right to provide reserved services has been granted to
Polish Post (Poczta Polska). The reserved area covers (article 47):
• in domestic traffic: the clearance, transport and delivery of items with correspondence
and direct mail up 50g;
• in international traffic: the clearance, transport and delivery of items up to 50g;
• in domestic and international traffic: postal money orders.
Items of correspondence are defined as ‘information recorded on any available material
carrier, (…) with the address inserted by the sender, with the exclusion of books,
catalogues and press magazines’ (article 3).3
The provision of these services by private operators is not in the reserved area if an
operator charges at least 2,5 times more than NPO for the fastest item in the lowest
weight category (currently 50g, priority item).
Table 0.3 Liberalisation of postal services and the reserved area (2008)
Postal product Within reserved area
(Yes, no, partially or unclear)
Remarks
Bulk mail and consolidation Yes
B2B non-bulk mail Yes
Individual item mail Yes
The reserved area encloses items
of correspondence and direct mail
up to 50g
Items of correspondence
Cross-border mail Yes Within reserved area up to 50g
Unaddressed mail No
Parcel mail No
Express mail No
Source: ECORYS questionnaire – NRA and Polish Post.
Plans for next steps
The NRA refers to the fact that Poland is one of the countries that according to the third
Postal Directive may postpone the date of full market opening until 31 December 2012.4
3 Direct mail: postal item containing only advertisement, marketing or promotional materials, being sent on the one time basis
to at least 20 addressees, having identical content, differing only by the identification data of addressees’ non-changing the
content of transferred information, and in particular related to the name, address or other variable data; 4 ECORYS questionnaire – NRA.
Country sheet: Poland 721
1.3.4 NRA
Regulatory functions with regard to postal services are handled by the Office of
Electronic Communications (UKE) since 14 January 2006. Before that date, the
regulatory function was governed by URTiP. UKE’s president issues licenses regarding
postal activity and maintains the register of postal operations. The President of UKE is
also the specialised authority in the area of equipment conformity assessment, including
telecommunications terminal equipment and radio equipment.
On 14 January 2006 a new body of government administration was established – the
President of the Office of Electronic Communications (President of UKE) to take over
from the liquidated Office of the President of Telecommunications and Post Regulation
(URTiP).The President of UKE took over the tasks and powers that had so far rested
within the competence of the President of URTiP as well as certain powers of the
President of the National Broadcasting Council (KRRiT). The activities of the President
of the Office of Electronic Communications are supervised by the minister competent for
communications (currently the Minister of Infrastructure in charge of the communications
sector). The duties of the President of the Office of Electronic Communications have
been set out in: (i) the Act of 16 July 2004 - Telecommunications Law, (ii) the Act of 12
June 2003 - Postal Law, and (iii) the Act of 30 August 2002 on the conformity
assessment system.
The specific duties of the President of the Office of Electronic Communications include:
• intervening in matters related to the functioning of the market for telecommunications
and postal services, the equipment market and the settlement of disputes between
operators;
• cooperation with domestic and international telecommunications and postal
organizations, other competent national authorities, the European Commission and
Community institutions, as well as other NRAs;
• cooperation with the President of the Office for Competition and Consumers
Protection in matters related to the enforcement of the rights of parties using postal
and telecommunications services, and with the National Broadcasting Council.
The President of UKE submits, annually before May 15th, a report to the minister
competent for post and telecommunications, on the basis of information obtained from
the operators, evaluating the functioning of postal services markets, and including the
results of the postal activity inspection.
In addition, the President of UKE publishes in the UKE Bulletin, before May 31st, the
annual report containing the results of examinations of quality of universal postal
services, reached by the operator providing universal postal services within the preceding
year and also the information on number and kinds of submitted complaints and about the
method of their handling, having regard to the separation of them into universal postal
services and services, which are not falling under the scope of universal postal services.
Capacity and organisation
As of 31 December 2006 there were about 564 persons employed in UKE (including 16
local branches), 247 in the head office and 252 in the regional offices. In total 28 staff-
Annex II: Main Developments in the Postal Sector (2006-2008) 722
members are responsible for postal market regulation, 12 persons in the head office and
16 persons in the regional offices. The Postal Market Department situated in the head
office consists of two divisions: (a) the Division of Postal Activity Control, and (b) the
Division of Analyses and Reporting. In addition, there is the Independent Position
(Specialist) for Authorisations and Registration.
Studies
During the period under consideration, some studies were carried out, e.g. concerning the
transit time and the concerning consumers satisfaction. These results will be discussed
later.5
Furthermore, UKE carried out an audit of the alternative postal operators in which 49
operators were controlled. The purpose of the audit was to determine whether these
operators pursued postal activities in compliance with the provisions of the Postal Law
and especially in the reserved area of the Polish Post. The findings were (in short):6
• As the alternative postal operators are acting mostly in the area of the parcel service it
“would therefore appear that the liberalisation of the letter mail market has no impact
on the charge levied by these operators for the delivery of letter items.”;
• One alternative postal operator is organising its postal business (items of
correspondence) on a large scale in the national territory. A comprehensive audit is
planned in 2007 especially in view of assessing the development of its local outlets;
• The audit did find that four operators violated the reserved area of the Polish Post.
Hence the UKE-President issued administrative decisions mandating discontinuance
of postal activities.
Number of complaints and redress procedures in 2006
In 2006, 146 complaints were handled by UKE. Furthermore, 357,429 claims
(complaints) were lodged by consumers for improper performance of postal operators.7
Powers of the NRA
Table 0.4 shows the regulatory powers of the NRA. Article 44 of the Postal Law obliges
the USP to annually submit information related to volumes, postal offices, the number of
mail boxes and the number and kind of submitted complaints and the methods of their
handling. Polish Post is required to keep an accounting system separately for each service
from the reserved area as well as altogether for non-reserved services (with distinction
between universal postal service and services not comprising universal postal service).
5 UKE (2007b), p. 97.
6 UKE (2007b), p. 97.
7 Provisions on procedures: vide the Act of Postal law, art. 48a (plaints) and Chapter 5 (claims); further: the Ordinance of the
Minister of Infrastructure on complaints concerning the universal postal service in relation to a recorded item and a postal
money order of 13/10/2003 (claims).
Country sheet: Poland 723
Table 0.4 Regulatory powers NRA
Powers Yes/No/Unclear Remarks
Require data from USP Yes Financial report
Require accounting system Yes
Require new data studies Yes
Cancel unlawful rates Yes Universal service price-list
Levy Fines Yes
Seek judicial order Yes
Set new rates for USP Yes
Require downstream access No
Require data from non-USPs Yes Control of postal activity
Source: ECORYS questionnaire – NRA and Polish Post.
1.3.5 Licenses
According to the Postal law, postal activities with respect to the clearance, transport and
delivery of postal items with correspondence up to 2kg (excluding the reserved items up
to 50g) performed in the way specified for universal postal service as well as items for
blind persons, requires an license (or authorisation). As a result, the scope of licenses has
been much reduced and starting from 1 January 2006 practically covers only the universal
postal service within the weight range between 50g and 2kg (licenses had earlier been
issued for postal items with correspondence and items for blind persons).8 In other words,
article 6(1) stipulates that in fact within the universal service a license is required.
The provisions of the Act of 6 August 2004 on the freedom of economic activity have
implemented new solutions consisting in the replacement of licenses for conducting
economic activity with an entry to a register on the basis of an undertaking’s declaration
of compliance with the requirements provided for in the law. Regulated activity within
the meaning of the law on the freedom of economic activity, i.e. postal activity not
requiring an authorisation, is now subject to an entry to a register of postal operators (on
the basis of a written application).9 For services outside the universal service postal
operators do not need a license, but have to be registered on the basis of a written
application (article 6.2 Postal Act). This register is also governed by the UKE.
Conditions
Licenses are issued by the UKE after confirmation of the rather general conditions
mentioned in article 10 of the Postal Act. An entrepreneur must for example comply with
(i) the conditions for the maintenance of postal secrecy, (ii) establish transparent and non-
discriminating conditions of handling complaints, and (iii) he must be in possession of the
technical and organisational base matching the size of planned activity.
Table 0.5 shows a summary of these entry regulations.
8 ECORYS questionnaire.
9 ECORYS questionnaire.
Annex II: Main Developments in the Postal Sector (2006-2008) 724
Table 0.5 Entry regulation
Instrument Services allowed under
the license
Conditions for obtaining
the licence
Number of licences
approved (2007)
License Universal services
(Performance of the
postal activity with the
scope of clearance,
transport and delivery
provided within domestic
and international traffic of
postal items: (i) f or the
blind, and (ii) with the
correspondence up to
2000g)
Conditions regarding
postal secrecy, handling
of complaints and having
technical and
organisational base.
6 (including Polish Post)
Register Non-universal services Conditions regarding
postal secrecy and
handling of complaints
159
Total 165 (including Polish
Post)
Source: Postal Act 2003; UKE (2008a), figures as of 31 December 2007.
The number of private operators increased from 30 in 2001 to 164 in 2007 (see Figure
0.1). Most of these operators are active in the express and courier segment. 51% of these
164 private entities can be assessed as ‘local’, 22% is active in whole Poland, 20% is
active in both Poland and abroad, and 7% is only active abroad (only cross-border mail).
None of the five alternative operators with a license is currently providing services within
the universal service.10
Figure 0.1 Number of private operators in the years 1996-2007 (at 31 December)
0
20
40
60
80
100
120
140
160
180
1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Private operators
Source: UKE (2008a), p. 15.
10
ECORYS questionnaire – NRA and Ministry of Infrastructure; UKE (2008b).
Country sheet: Poland 725
1.3.6 Access
No provisions are made in the law concerning regulated or negotiated upstream or
downstream access (see Table 0.6).11
Provisions for transparent and non-discriminatory
access are not mentioned in the regulatory framework as well.12
Private letter (delivery)
boxes have to be accessible for all operators per August 15th, 2008.
Table 0.6 Network access
Upstream/downstream Form of access Regulated?
(Yes, No, Unclear)
Upstream Access to street letter boxes-no
Access to outward sorting centres-
no
Downstream Access to inward sorting centres-no
Access to delivery offices-no
Access to PO boxes-no
Not regulated
Source: ECORYS questionnaire – UKE and Polish Post.
1.3.7 Price regulation
Ex-ante price regulation of the reserved and USO services has been introduced since 2008
(article 51 Postal Act 2003).13
Within the universal service, fees should be established with regard to the costs of their
provision and should be uniform on the entire territory of the country and transparent and
non-discriminatory (article 50). However, the use of uniform tariff does not exclude the
right of operators to use special (negotiated) tariffs, under the condition, that the operator
while setting prices (i) applies towards senders uniform and equal criteria concerning
both prices and conditions related to the contract, and (ii) takes into account the costs of
provision of the service comprising of the full scope of performances related to postal
service of the given, excluding costs avoided in relation to the limitation of activities
performed by the operator (article 50).
It is prohibited to cross-subsidize the non-reserved universal service with the income
from reserved services, unless the subsidy is necessary to provide these universal services
(article 50a).
There is no price-cap regulation, but the prices of the universal service should be cost
based (article 50). The NRA may raise an objection to a new project of price list and as a
result they will not come into force.14
11
ECORYS questionnaire – NRA and Polish Post. 12
ECORYS questionnaire – NRA and Ministry of Infrastructure. 13
ECORYS questionnaire – NRA. 14
ECORYS questionnaire – Ministry of Infrastructure.
Annex II: Main Developments in the Postal Sector (2006-2008) 726
Polish Post (article 52) is required to keep an accounting system separately for each
service from the reserved area as well as altogether for non-reserved services (with a
distinction between universal postal service and services not comprising universal postal
service).
1.3.8 Quality of service
The quality thresholds and performances of Polish Post are shown in Table 0.7. The study
of transit times between November 2006 and December 2006 showed that only the
requirements for transaction mail D+3 was met. Also the requirements for direct mail
were not met. The bad performance was probably the result of strikes by mail dispatchers
and delivery service in November and December 2006 (see also the section on
employment).
Further, a study was carried out concerning the postal outlets, in which one concluded
that they did not “fully comply with the statutory requirements and (…) there was no
improvement to the study in 2002”.
Table 0.7 Quality of service USP
Standard Threshold Performance USP Remarks
Transit time transaction mail
D+1
D+2
D+3
Transit time direct mail
D+5
82%
90%
94%
97%
68%
87%
94,4%
89%
Transit time for cross-border
priority mail
85% Incoming: 85,5%
Outgoing: 84%
Transit time parcels
1st class (D+1)
2nd
class (D+3)
80%
90%
57.8
84.3
The test for parcels was
carried out between 16th of
July and 9th November 2007,
therefore the results provide
no grounds for the
assessment of annual transit
time parameters in 2007
Source: ECORYS questionnaire – NRA and Polish Post; UKE (2007a), UKE (2007e).
Country sheet: Poland 727
1.4 The mail market
1.4.1 Mail market overall
According the NRA and Polish Post the market for postal services in Poland can be
divided into the universal service and postal services outside the universal service area,
including express services.
The next table shows that volumes for, especially, unaddressed mail, parcels and express
and courier services grew very fast during the period 2005-2007. Cross-border mail (both
inbound and outbound) declined. The volume of addressed direct mail increased by 30%
compared to 2005, while the volume of domestic mail above 50g increased threefold.
Turnover patterns are more or less similar.15
Table 0.8 Overall volume and turnover of the postal market 2005-2007
Category Segment 2005 2006 2007 2005 2006 2007
Volume (million items) Turnover (million PLN)
Letter mail Domestic <50g 1,460 1,205 1,420 2,775 2,375 2,495
Domestic >50g 40 205 180 100 470 465
Direct mail
(addressed)
150 165 195 175 205 235
Catalogues - - - - - -
Magazines /
periodicals
- - - - - -
Cross-border
(inbound)
60 60 50 70 70 75
Cross-border
(outbound)
65 70 40 285 490 330
Newspapers - - - - - -
Direct mail
(unaddressed)
1,865 3,290 3,200 135 205 180
Parcel mail Parcels 30 75 80 265 1425 1645
Express and courier
services
Documents,
parcels, letters
3 25 25 90 320 370
Total 3,673 5,095 5,190 3,895 5,560 5,795
Total (in €) 967.9 1,427.3 1531.6
Source: ECORYS questionnaire – UKE (estimations).
Note: The NRA indicates that these figures are estimations due to the fact that their annual postal market
reports are arranged in different categories than given in this table. The figures can differ from the UKE annual
report to some extent because this table includes domestic and cross-border items and the UKE report includes
other services than listed here (e.g. money postal orders).
15
Throughout we use the following exchange rates: € 1,- for 4.023 PLN (2005), 3.8959 (2006) and 3.7837 (2007), based on
Eurostat averages (Euro/ECU exchange rates - Annual data).
Annex II: Main Developments in the Postal Sector (2006-2008) 728
In its postal market assessment of 2007, the NRA found that the total number of postal
items has been increasing between 2005 and 2007 (see tables below). Since 2005 the total
number of items grew by 41%. This growth can largely be attributed to the increase in
unaddressed direct mail transactions. In 2006 and 2007 growth rates for the total market
were 39% and 1.8%, respectively.
Table 0.9 The number of postal items in domestic transactions from 2005 to 2007 for domestic and cross-border items (in
million items)
2005 2006 2007
Addressed items 1,810 1,805 1,990
o/w items of correspondence o/w 1,625 o/w 1,540 o/w 1,690
o/w parcels & express o/w 33 o/w 100 o/w 105
o/w addressed direct mail o/w 150 o/w 165 o/w 195
Unaddressed (direct) mail 1,865 3,290 3,200
Total 3,673 5,095 5190
Source: Source: ECORYS questionnaire – UKE (estimations), UKE (2008a and 2008b).
Note: Addressed items includes items of correspondence, addressed advertising and parcels.
Table 0.10 The revenue generated from the sale of postal services (including direct mail) between 2005 and 2007 for
domestic and cross-border items (in million PLN and €)
2005 2006 2007
Addressed items 3760 5355 5615
Unaddressed (direct) mail 135 205 180
Total (in PLN) 3,895 5,560 5,795
Total (in €) 967.9 1,427.3 1531.6
Source: ECORYS questionnaire – UKE (estimations), UKE (2008a and 2008b); used exchange rates: € 1,- for
4.023 PLN (2005), 3.8959 CZK (2006) and 3.7837 (2007), based on Eurostat averages (Euro/ECU exchange
rates - Annual data).
Note: Addressed items include items of correspondence, addressed advertising and parcels.
In Table 0.11 and Table 0.12 the standard tables are provided, which provide similar data
as the unnumbered tables above (we have no indication why these figures differ). The
addressed mail segments comprises circa 1.8 billion items (circa 35% of the total market)
but generates (probably) more than 70% of all revenues.
Table 0.11 Size of the mail market in turnover (million PLN and million Euro)
Postal product 2005 2006
Bulk mail and consolidation n.a. n.a.
B2B non-bulk mail n.a. n.a.
Individual item mail n.a. n.a.
Addressed mail 3,050 (€ 757.9) 3,050 (€ 782.9)
Cross-border mail 355 (€ 88.2) 560 (€ 143.8)
Unaddressed mail 135 (€ 33.5) 205 (€ 52.6)
Parcel mail 265 (65.9) 1,425 (€ 365.8)
Express mail 90 (€ 22.4) 320 (€ 82.1)
Total 3,895 (967.9) 5,560 (1,427,3)
Country sheet: Poland 729
Source: ECORYS questionnaire – UKE (estimations), UKE (2008a and 2008b).
Note: n.a. is not available.
Annex II: Main Developments in the Postal Sector (2006-2008) 730
Table 0.12 Size of the mail market in physical terms (million items)
Postal product 2005 2006
Bulk mail and consolidation n.a. n.a.
B2B non-bulk mail n.a. n.a.
Individual item mail n.a. n.a.
Addressed mail
o/w transaction mail
o/w direct mail
o/w others
1,650
n/a
o/w 150
n.a.
1,575
na
o/w 165
n.a.
Cross-border mail 125 130
Unaddressed mail 1865 3290
Parcel mail 30 75
Express mail 3 25
Total 3,673 5,095
Source: ECORYS questionnaire – UKE (estimations), UKE (2008a and 2008b).
Note: transaction mail (1st class mail, business mail), direct Mail (addressed 2
nd class mail, advertising mail, bulk
mail), others (magazines, newspapers, addressed catalogues) and unaddressed mail (flyers, brochures,
unaddressed catalogues).
Note: n.a. is not available.
1.4.2 B vs C
The stakeholders could not give an up-to-date estimation of postal streams. Therefore, we
refer to the ECORYS 2005 study for these figures (see Table 0.13 and Table 0.14).
Table 0.13 Postal streams in the market for addressed mail in turnover (million Euro)
Postal stream 2006
B2B n.a.
B2C n.a.
C2B n.a.
C2C n.a.
Source: n.a.
Note: n.a. is not available.
Table 0.14 Postal streams in the market for addressed mail in physical terms (million items)
Postal stream 2004
B2B 10%
B2C 80%
C2B 5%
C2C 5%
Total 1,575 (2006)
Source: ECORYS (2005a).
Country sheet: Poland 731
1.4.3 Market opening
The UKE reports a substantial increase in the number of private operators (from 15 in
1996 up to 164 in 2007). The regulatory authority, however, acknowledges that this
growth can predominantly be felt by business customers in urban areas, because private
operators are active only in cities and targeted mainly at bulk senders.16
This is supported
in the Eurofound report on Poland that states that most private operators have a purely
local character and jointly control approximately 10 percent of the market, mostly with
regard to courier services. As a result, these operators are believed not to constitute
serious competition for PP.17
The NRA states that outside of the reserved area the market is open to competition. They
estimate that the reserved area is circa 25 % of the postal market.18
As shown in the next
table the non-reserved area was 6% of the total market in 2003.
Table 0.15 Division between the reserved and non-reserved area for domestic and cross-border mail (in million items)
2003 2004 2005 2006 2007
Reserved area 1,737 1,931 1,670 1,363 1,489
Non-reserved area 115 190 171 385 505
Total (excluding unaddressed) 1,852 2,121 1,841 1,748 1,994
Source: UKE (2008a and 2008b).
Note: Total includes items of correspondence, addressed advertising and parcels.
The segments for unaddressed mail, parcels and express do not fall under the reserved
area and are free to enter.
1.4.4 Cross-border mail
International traffic (clearance, transport and delivery of items) up to 50g is part of the
reserved area. In volumes, the cross-border mail market encloses circa 65 million items.
Polish Post is (still) the dominant operator, while also TNT, DHL and UPS are active on
the Polish market.
1.4.5 Impact of innovation
Mail substitution
Neither the Ministry nor Polish Post could specify the degree/percentage of substitution
of mail through electronic media (see Table 0.16).19
16
ECORYS questionnaire – NRA. 17
Eurofound (2007). 18
ECORYS questionnaire – NRA. 19
ECORYS questionnaire – NRA and Polish Post.
Annex II: Main Developments in the Postal Sector (2006-2008) 732
Table 0.16 Impact electronic substitution
Postal product % change in total market volume (avg./year)
Bulk mail and consolidation n.a.
B2B non-bulk mail n.a.
Individual item mail n.a.
Cross-border mail n.a.
Unaddressed mail n.a.
Parcel mail n.a.
Express mail n.a.
Source: no figures available.
Note: n.a. is not available.
New services
Polish Post is developing mobile banking service for its customers. Under the new service
the customer will be able to manage his account via mobile phone, make transfers, verify
account balances and make small payments for, for instance, parking. The service will be
launched this year. This is considered as a major competitive strategy by the postal
company to stay active in the postal delivery.20
1.5 Market structure and competition
1.5.1 National postal operator/Universal Service Provider
The current national postal operator is Polish Post, which was established in 1991 by
splitting the Office of Post and Telecommunications into postal and telecommunications
units. Since 1997, Polish Post holds the status of state-owned public utility.
Implementation of the ‘Strategy for Development of Polish Post for 2004-2006’
transformed the operator into a holding company. The current government led by Mr.
Tusk is planning to commercialise the Polish Post and sell (a part of) the stocks,
according to the announcement of the Vice President of the Sejm-Commission for
Infrastructure.21
In the same press release mention is made of the 105.000 employees of
Polish Post demanding a majority of the stocks as preference shares.
The (legal) preparations for the commercialisation of Polish Post started in March 2007.
On 27 March 2007, the Council of Ministers adopted the draft ‘Act on Commercialisation
of the State Enterprise of Public Utility Polish Post’, prepared by the Ministry of
Transport. Polish Post will be converted into a joint stock state treasure enterprise called
‘Polish Post JSC’. The commercialisation will be the first stage of property
transformation of the company.22
The state-owned Polish Post is composed of the following entities:
20
Datamonitor (2008). 21
Infoside (2008). 22
Ministry of Infrastructure (2007).
Country sheet: Poland 733
• Bank Pocztowy S.A;
• Pocztylion-Arka Powszechne Towarzystwo Emerytalne S.A. (a pension fund);
• Pocztowa Agencja Usług Finansowych S.A. (a financial services company);
• Post Media Serwis Sp. z o.o.;
• POSTDATA S.A.;
• Pocztowe Towarzystwo Ubezpieczeń Wzajemnych (a mutual insurance association).
From an organisational perspective, PPUP Poczta Polska consists of the general
directorate, the postal services centre, the licensed services centre, the logistics centre, the
postal network centre, the information technology centre, the infrastructure centre, the
accounting centre, the financial services centre, the security management centre and the
postal order centre. Most if them also have regional branches.23
Postal network
The UKE reports that at the end of 2007 there were 10,235 postal outlets in the area of
Poland. Polish Post holds 8,692 of these outlets (4,624 in villages, the others in cities),
whereas private operators hold the other 1,543 outlets. UKE stresses that outlets of
private operators are mostly (1,505 out of 1,543) located in urban areas and the number of
outlets operated by private operators in rural areas is insignificant.24
This is reflected in
the following table (Table 0.17).
Table 0.17 Postal network of the national postal operator
Polish Post 2007
Number of post offices
- Number of post offices and branch post offices
- Post offices only
8,692
- 5,761
- 2,931
Number of street letter boxes 55,138
Source: UKE (2008a and 2008b); ECORYS questionnaire – NRA.
In 2006, Polish Post realised a total volume of 3.1 billion items. In 2007 they generated a
turnover of PLN 4.6 billion (€ 1.2 billion) and delivered circa 2.9 billion items. Within
the universal service they delivered 1.9 billion items and realised a turnover of PLN 4.2
billion (€ 1.11 billion).25
The market share of Polish Post in the addressed mail segment in 2007 is still very high,
98.8% and 99.5% in the areas of items of correspondence and direct mail, respectively.
The estimated market share of Polish Post in the segment for unaddressed mail is 27.8%
and in parcels 46.1%.26
Degree of vertical and horizontal integration
According to our information, Polish Post has no alliances or partnerships with other
(foreign) postal operators.
23
Eurofound (2007). 24
UKE (2008a). 25
UKE (2008a). 26
UKE (2008a) and (2008b).
Annex II: Main Developments in the Postal Sector (2006-2008) 734
1.5.2 Competitor postal operators
Between 1996 and 2007, the number of private operators has increased more than tenfold
(from 15 to 164). None of these operators, however, has, yet, posed a real challenge to the
position of Polish Post.27
Five of these alternative operators are allowed to provide
services that are part of the universal service (they have an A-license).28
However, in
practice these parties do not offer these services. 29
Information (in English) about these companies is difficult to find.
Integer.pl
Integer.pl, a distribution group, operates InPost. It states to be the first independent postal
operator that performs business activities throughout the country. They claim to be a
market leader in respect of distribution of addressed and non-addressed advertising letters
and to deliver 50 to 70 million leaflets and advertising materials every month, resulting in
a volume of 600-840 million items per year. Their sister organisation Integer courier
delivers parcels in 500 cities in Poland. Integer.pl employs in total circa 7,300 people.
According their website they planned a share issue on the Warsaw Stock Exchange in
2007, but it is not clear whether this has been implemented.30
According to the NRA (see
next table) they delivered in 2006 circa 632 million items and employed circa 131 people.
27
UKE (2007b), p. 101-103. 28
These five are: Kolporter Logistyka, Wava, Indesys Dominik Steinhauf, Działalność Usługowa Jerzy Jaworski and
Dystrybucja Polska; see: http://www.bip.uke.gov.pl/marta/resultRop.vm. 29
UKE (2008a); ECORYS questionnaire – NRA. 30
Website Interger.pl.
Country sheet: Poland 735
Table 0.18 Overview of main competitors on the postal market (2006)
Postal
operator
Market Volume mail
/ Turnover
# of
employees
Service level
(number of
deliveries per
week)
Coverage
I.D. MARKETING Unaddressed mail 763 million items 2,156 n.a. whole country
INTEGER.pl
(InPost)
Unaddressed mail,
direct mail, parcels
632 million items 131
(7,300 for the
group)
n.a. whole country
Dystrybucja
Polska
Unaddressed mail 383 million items 170 n.a. whole country
Pro Direct
(Now: ABC Direct
Contact)
Unaddressed mail 172 million items 541 n.a. whole country
ABC Direct
Contact
Unaddressed mail n.a. n.a. n.a. n.a.
UPS Polska Parcels, express,
cross-border
n.a. n.a. n.a. n.a.
DPD Parcels, express,
cross-border
n.a. n.a. n.a. n.a.
GLS Poland Parcels, express,
cross-border
n.a. n.a. n.a. n.a.
Opek Addressed direct
mail, parcels,
cross-border mail
n.a. n.a. n.a. n.a.
TNT Express
Worldwide (PL)
Parcels, express,
cross-border
n.a. n.a. n.a. n.a.
DHL Express (PL) Cross-border n.a. n.a. n.a. n.a.
Source: ECORYS questionnaire – NRA; NRA (2007b) and UKE (2008a and 2008b), p. 28 (table 8-9).
Note: employment reported in headcount at the end of 2006.
Note: n.a. is not available.
Addressed mail
There are five companies who are allowed to operate within the universal service apart
from PP. However, in practice they do not provide these services. In their 2007 market
assessment, the NRA indicates that nearly all alternative operators are active within the
‘correspondence’ area.. However, this also includes courier services.31
No operator can be
seen as a main competitor for Polish Post, most of them are operating on a local basis.
Parcel and express
Beside the large international operators like UPS, DPD, GLS Poland, DHL, TNT and
Spring, most registered (domestic) postal operators are active in the express market (e.g.
31
UKE (2008a), table 8 and 9 (Ranking the non-public operators). Items of correspondence are defined (article 3-22 Postal
Act 2003) as information on any kind of physical medium including relief print, with the address indicated by the sender on
the item, excluding books, catalogues, newspapers and magazines.
Annex II: Main Developments in the Postal Sector (2006-2008) 736
InPost, Opek). In terms of both volume and turnover UPS, DPD, GLS Poland and TNT
Express are the largest alternative operators for parcel and express services (no individual
figures available).32
The market share of all these alternative operators is 53.9%.
Cross-border mail
As mentioned before, Polish Post is the dominant operator on the market (market share of
circa 95%), while also international operators like TNT, DHL and UPS are active on the
Polish market. Again, in terms of both volume and turnover UPS, DPD, GLS Poland and
TNT Express are the largest alternative operators for cross-border services (no individual
figures available).33
Unaddressed mail
In the unaddressed segment, several operators are active and gained substantial volumes.
Parties like I.D. Marketing, Integer.pl, Dystrybucja Polska and Pro Direct gained a total
volume of 1.9 billion unaddressed items and employ around 3,000 people. Their joined
market share is circa 72%, but this may actually be higher as registration is not
compulsory for this service.34
1.5.3 Competition
The alternative operators delivered in 2007 2.3 billion items (out of 5.1 billion items),
especially unaddressed mail (see next table).
Table 0.19 total volume of the alternative operators (in million € and million items)
Turnover 2007 Volume 2007
Addressed items 1,556.4
(€ 411,3)
79.6
Unaddressed mail 110.1
(€ 29.1)
2,309.3
Total 1,666.5
(€ 440.5)
2,388.9
Source: UKE (2008a and 2008b).
Note: Addressed items includes items correspondence, addressed advertising and parcels. Used exchange
rates: € 1,- for 4.023 PLN (2005), 3.8959 CZK (2006) and 3.7837 (2007), based on Eurostat averages
(Euro/ECU exchange rates - Annual data).
The NRA indicates that the 15 largest alternative operators handle 99.8% (in volume,
97.6% in turnover) of the total volume and turnover (including unaddressed mail).
Without unaddressed mail these figures are respectively 96.2% and 98.5%.35
The incumbent has been facing no real competition in the addressed mail segment
(market share of circa 99-100%) and most probably nothing is going to change until the
32
UKE (2008a), table 9 (Ranking the non-public operators). 33
UKE (2008a), table 9 (Ranking the non-public operators). 34
UKE (2008b). 35
UKE (2008a), table 9 (Ranking the non-public operators).
Country sheet: Poland 737
market is fully liberalised. The most severe competition is observed in the segment of
express services and to a lesser extent in the parcel and unaddressed segments. This is
shown in Table 0.20 and Table 0.21.
Table 0.20 Number of competitors and degree of competition (2005)
Postal product Market share USP Number of competitors Concentration ratio
C3
Bulk mail and consolidation n.a. n.a. n.a.
B2B non-bulk mail n.a. n.a. n.a.
Individual item mail n.a. n.a. n.a.
Items of correspondence
- transactional mail
- direct mail
98.78
99.53%
99.92%
Mainly locals
C1: close to 100%
Cross-border mail n.a. n.a. n.a.
Unaddressed mail n.a. n.a. n.a.
Parcel mail n.a. n.a. n.a.
Express mail 15.6% n.a. n.a.
Total 113 Non-USP registered
Source: ECORYS questionnaire – NRA.
Note : n.a. is not available.
Table 0.21 Number of competitors and degree of competition (2007)
Postal product Market share USP Number of competitors Concentration ratio
C3
Bulk mail and consolidation n.a. n.a. n.a.
B2B non-bulk mail n.a. n.a. n.a.
Individual item mail n.a. n.a. n.a.
Items of correspondence
- addressed direct mail
98.8%*
- 99.5%
75
C1: close to 100%
Cross-border mail 95% 27 (e.g. FedEx, UPS,
DHL Global Mail, TNT
and Spring)
C1: 95%
Unaddressed mail 27.8% 17 (e.g. I.D. Marketing,
Integer, Dystrybucja
Polska and Pro Direct)
C1: 28%
Parcel mail 46.1% 47 C1: 46%
Express mail n.a. n.a. n.a.
Total 164 non-USP registered
(100 of them operated)
Source: ECORYS questionnaire – NRA; UKE (2008a), p. 40 (table 25-28), in volume and UKE (2008b).
Note: * USP’s market share comparing to whole market volumes (USP + all non-USP).
Note: n.a. is not available.
Annex II: Main Developments in the Postal Sector (2006-2008) 738
1.5.4 Competition issues
According to the NRA the fundamental formal barrier to entry is the reserved area (50g),
which limits the entry of new operators in the addressed mail segment. In addition, the
competitors are subject to VAT while the incumbent is relieved from this tax.
Furthermore, the NRA indicates that in general the market is not yet well developed
compared to the leading economies in Europe. There is, for example, no access to
letterboxes and to sorting centres (no consolidators). Competitors have no access to the
address database of the incumbent either.36
State aid
A press release dated 25 April 2007 makes note of the fact that Poland had agreed to
abolish by 30 June 2008 the unlimited state guarantee currently enjoyed by Polish Post.
Under this guarantee the state has responsibility for liabilities entered into by Polish Post
and the fact that the guarantee was unlimited in duration, in amount and covers all
liabilities, allowed Polish Post to obtain finance on more favourable terms, thus giving it
an advantage over its competitors and distorting competition in the single market,
according to the European Commission.37
Access to letterboxes
Nowadays only the postmen of Polish Post have a key to open letterboxes from behind to
deliver the mail. Inhabitants can open the letterboxes from the front side with an
individual key, which can be obtained from Polish Post. The lack of accessibility of
letterboxes can hinder the development of competition.
As a prelude to the liberalisation of the postal market in Poland, owners of estates and
houses are now obliged to install new letterboxes, according to requirements determined
in the Ordinance on letterboxes. These new boxes should be exchanged by August 2008.
The situation for entrants will most likely improve the moment there is access to the
letterboxes; the new letterboxes ensure competitors free access to the last mile. Different
estimations expect about 3.5 up to 6 million new letter boxes. The change of letterboxes
differs from city to city: in Krakow only 15% of the 306,900 letter boxes have been
changed, where as in Kutno 40% of the 21,600 letter boxes have already been changed.38
Polish Post indicates that they do not see other formal obstacles for competition apart
from the temporary ‘keys for the letterboxes’ problem.39
1.5.5 Results of competition.
Some considerations of the NRA40
Between 1996 and 2007, the number of private operators has increased more than tenfold.
None of these operators, however, has posed a real challenge to the position of Polish
36
ECORYS questionnaire – NRA. 37
Commission (2007). 38
ECORYS questionnaire – NRA. 39
ECORYS questionnaire – Polish Post. 40
Based on UKE (2007b), p. 101-103, literally and UKE (2008a).
Country sheet: Poland 739
Post. This growth can be felt predominantly by business customers in urban areas as
private operators are active only in cities and mainly target bulk senders.
The regulatory authority, UKE, reports a stabilisation of market indicators, e.g. the
number of registered operators, the number of services provided by them and the total
volume of postal services. However, UKE still assesses the development of competition
in the Polish postal market positively. In a 2006 audit of alternative postal operators, the
UKE inspected 49 postal operators, whereof 46 operated on a national or local scale,
while 3 had nationwide and international coverage. With respect to results of competition,
its key conclusions were:
• The undertakings operating in Poland and in international service clearly focus on
parcel service;
• Currently, there is one operator in the process of organising its postal business. This
operator intends to offer postal services in the area of items of correspondence in the
entire national territory and establish a nationwide network of local outlets (branches
and customer service offices). Judging by the density of this network, the operator
intends to provide these services on a massive scale. However, it would appear that
the fact that this operator uses special envelopes (weighted with a metal seal),
currently prevents any large-scale activity due to the cost of such envelopes and the
inconvenience of their usage.
Local operators are interested almost exclusively in pursuing postal activities in the area
of the lowest weight category of items of correspondence, i.e. the area set out in the
Postal Law as the area reserved for the public operator, in which other operators may
operate subject to them charging higher prices (being 250% of the PLN 5.00 charged by
the public operator). The local operators inspected want to compete with the public
operator in the reserved area. On some occasions they do it in violation of the provision
cited above or bypass its provisions by using non-standard packaging (weighing about 50
grams). The current potential of the operators inspected points to a relatively small scale
of their activities.
A reason for this persistent lack of competition might be that the government has only
dropped the threshold for the reserved area to 50 grams as of January 2006. The 50 g
threshold has been still binding what effectively prevents competitors from the full
market entry. Moreover, the lack of a level playing field in the Polish postal market might
also provide some explanation.
Observations ECORYS
The Polish market shows a strong development in volume growth, especially in the
unaddressed mail market. Since 2003 the total number of items grew by 94% (mainly
unaddressed mail) and total turnover increased with circa 8%. It is interesting to note that
the total number of alternative operators increased very sharply (more than tenfold).
However, the large majority of these operators are active in the local market and the main
operators are mainly active in the segments for unaddressed mail, cross-border mail,
parcel mail and express.
In 2005 ECORYS concluded that Polish Post dominated the C2C, C2B and B2C
segments due to the density of its network, whereas express and logistic service operators
Annex II: Main Developments in the Postal Sector (2006-2008) 740
concentrate on the B2B segment. It was not expected that competition would take place in
the field of universal services in the near future. However, it was also noted that full
liberalisation of the universal service provision could result in the loss of a large part of
market share in big cities (the competing postal operators were the strongest in the big
cities: 80% of the revenues of the Polish Post originate from 15 cities). These
observations are still mostly valid.
In the addressed mail segment (including addressed direct mail) the market share of
Polish Post is above 99%. The main barrier to competition is the reserved area and the
lowering of the threshold in 2006 (from 100g to 50g) seems to have had hardly any effect
on the level of competition in the addressed mail segment. There are no indications that
this will change fundamentally before full market opening in 2013.
In the market for cross-border mail Polish Post has a market share of 95%.
In the other segments Polish Post faces more competition than in the addressed mail
market. In the unaddressed mail segment, several parties such as I.D. Marketing, Integer,
Dystrybucja Polska and Pro Direct distributed 1.5 billion items in 2007 and have gained a
market share of 72%. Large international operators like TNT, DHL and UPS are active in
parcels and express and compete with Polish Post (e.g. the market share of Polish Post in
parcels is 46% in volume).
Access to the letterboxes by competitor postal operators seems to be a major problem, but
the regulation concerning the installation of new letterboxes may provide a solution.
Further, the VAT exemption for Polish Post is a (major) barrier to start addressed mail
delivery.
1.6 Customer needs
Between 11 and 29 October 2006, the UKE assessed the degree of satisfaction of
customer’s needs.41
In October 2006 a consumers´ satisfaction research (study of satisfaction in regard of
customer needs) was carried out (commissioned by UKE) with regard to the quality of
universal postal service. The investigation differentiated between private customers and
business customers. As the research embraced the scope of universal postal service it
practically referred to the services of Polish Post. The most important results were:
• with respect to private customers, the survey showed that 83% of the customers of
Polish Post were satisfied with services in the area of the universal service, it should
be noted that these customers mostly use its letter service;
• registered letters are sent more rarely than economy letters because of the price;
• customers are rather unhappy about the time it takes to be served and long queues in
Polish Post outlets. For 76 percent of the private customers, Polish Post is also a
41
The sample size of this study is 1,000.
Country sheet: Poland 741
financial intermediary. The waiting time is also a reason for which part of the Poles
opt out of the financial transactions;
• Business customers, on the other hand, were similarly satisfied with all PP’s services
as with competitors’ services, though satisfaction with respect to quality was higher
towards competitive courier services. Business customers were also generally
satisfied with letter services, though some areas were indicated to need improvement
(e.g. returned mail and transit times).
In the overall conclusion the research confirmed a moderate positive level of satisfaction
with services of Polish Post. The parcel services were better assessed than letter services.
In view of respondents, letter mail is rather expensive; some areas of postal activity
features unsatisfactory quality, such as transit time and re-address procedures.42
In another monitor of procedures and the manner of handling complaints, the UKE found
that the highest number of complaints concerned registered mail, whereas the lowest
number of complaints concerned postal items with declared value. Only 5 percent of the
inspected complaints contained damages of postal items, theft, and other reasons (e.g.
breach of confidentiality of correspondence, delayed delivery of postal items).43
42
ECORYS questionnaire – NRA. 43
UKE (2007b), p. 102.
Annex II: Main Developments in the Postal Sector (2006-2008) 742
1.7 Price performance
1.7.1 Tariffs
In Table 0.22 the public tariffs of several postal products are presented. All 2007 prices
increased compared to 2005, the tariff of parcels, for example, with nearly 19%.
Table 0.22 Public tariffs (in PLN)
Postal product Definition 2005 2006 2007
Letter post 1st class USP tariffs for domestic 20g letter of fastest
standard category
2.00
(€ 0.50)
2.00
(€ 0.51)
2.10
(€ 0.56)
Letter post 2nd
class USP tariffs for domestic 20g letter of second
fastest standard category (if applicable)
1.30
(€ 0.32)
1.30
(€ 0.33)
1.35
(€ 0.36)
Letter post cross-
border
USP tariffs for cross-border 20g letter of
fastest standard category
3.45
(€ 0.86)
3.55
(€ 0.91)
3.55
(€ 0.94)
Parcels USP tariffs for a 5 kg domestic parcel (lowest
available public tariff)
8.00
(€ 1.99)
8.50
(€ 2.18)
9.50
(€ 2.51)
Parcels cross-border USP public tariffs for a 5 kg cross-border
parcel (lowest available public tariff)
69.00
(€ 17.15)
71.14
(€ 18.26)
71.14
(€ 18.80)
Registered item USP public tariffs for a registered item (lowest
available public tariff)
3.50
(€ 0.87)
3.50
(0.90)
3.55
(€ 0.94)
Insured item USP public tariffs for an insured item (lowest
available public tariff)
4.50
(€ 1.12)
4.50
(€ 1.16)
4.55
(€ 1.20)
Bulk mail, 20g USP public tariffs for a mailing of 500 items n.a. n.a. n.a.
Bulk mail, 100g USP public tariffs for a mailing of 500 items n.a. n.a. n.a.
Bulk mail, 300g USP public tariffs for a mailing of 500 items n.a. n.a. n.a.
Total
Source: ECORYS questionnaire – NRA.
Note: n.a. is not available.
Table 0.23 Public tariffs (in PPP)
Postal product 2005 2006 2007
Letter post 1st class 0.89 0.89 0.94
Letter post 2nd
class 0.58 0.58 0.60
Letter post cross-border 1.54 1.58 1.59
Parcels 3.56 3.77 4.25
Parcels cross-border 30.75 31.57 31.85
Registered item 1.56 1.55 1.59
Insured item 2.01 2.00 2.04
Bulk mail, 20g
Bulk mail, 100g
Bulk mail, 300g
Total
Source: conversion rate based on Eurostat data.
Country sheet: Poland 743
Evolution of public and special prices for main services
Beside the figures mentioned in the table, there is no information available concerning the
evolution of public and special prices for main services.
Affordability
There is no information available concerning the affordability of postal services or the
price of services relative to the income of low/average-income.
1.8 Employment aspects
1.8.1 Employment
In 2006, nearly 113,000 people (headcount) were employed in the postal sector (see Table
0.24).44
Circa 16% is working for alternative operators. Eurofound reports that
employment at Polish Post has remained largely constant over the past ten years and
estimates that its average employment over a 12-month period was in 96,999 FTE in
1996, 97,702 in 1998, 96,963 in 2002 and 96,110 in 2003. The UKE reported that
employment is still increasing, but at a low pace. Sixty percent of employees are
estimated to be female. 45
Table 0.24 Employment in the sector, in employees and [FTE]
Operator 2005 2006
Polish Post total
Polish Post- civil servant
Polish Post- flexible
94,033
No civil servant status
n.a.
95,016
No civil servant status
n.a.
CPO’s total 14,798 17,964
Total 108,831 112,980
Source: ECORYS questionnaire – NRA and Polish Post.
Note: CPO’s total includes all non-USP employees; data in FTE not available.
Note: n.a. is not available.
In the next table, the development in employment since 2003 is shown. Since 2003 the
total number of employees increased by 15%.
Table 0.25 number of employees (2003-2007)
2003 2004 2005 2006 2007
Polish Post 100,760 100,138 100,049 101,146 100,423
CPO’s 4,702 8,595 14,798 17,964 21,246
Total (excluding unaddressed) 105,462 108,733 114,847 119,110 121,669
Source: UKE (2008a and 2008b).
Note: figures at the end of the year.
44
ECORYS questionnaire – NRA, Polish Post. 45
Eurofound (2007).
Annex II: Main Developments in the Postal Sector (2006-2008) 744
1.8.2 Employment conditions
The Polish law sets the minimum monthly remuneration for full-time work at PLN 889 (€
228,-) in 2006 and at PLN 936 (€ 247,-) in 2007. The average remuneration in the
enterprise sector has been estimated by the Central Statistical Office to be PLN 2,758 (€,-
708) in 2006. With respect to Polish Post, Eurofound reports that average wage was PLN
3.028 (€ 777) as at December 2006. However, 27 percent of all employees (mostly
mailmen) were earning PLN 900 PLN (€ 231,-) per month, which is just above the
minimum wage in 2006.46
There were “wild strikes” between 10th and 27
th November 2006 in different regions.
They started in Gdansk and spread out over the whole country; at the end more than
25,000 of the 50,000 postmen were on strike. The demand of the strikers was (amongst
others) focused on higher salaries, fixed working hours and contract conditions.47
At the
18th of December the Minister of Traffic engaged in the negotiations between Polish Post
and the unions (Solidarnosc).
The private competitor of Polish Post, InPost, which is already present in 71 towns of
Poland, pays their new employees 1,500 PLN (€ 385,-).48
Role of social partners, trade union, sector based collective agreements
There are eight union organisations active within Polish Post.49
Eurofound reports that
unionisation among Polish Post stands at approximately 60%, though despite this
relatively high rate, representation is rather fragmented and individual trade unions
sometimes compete with one another. Due to its dominant position, the collective
agreement in force within Polish Post is said to extend to approximately 90% of the
sector’s employees. No data is available about union membership at the privately-owned
operators. Further, there is no employers’ organisation in the Polish postal sector.50
Wages as proportion of total costs
No information is available concerning the wages as proportion of total costs.
46
Eurofound (2007). 47
The questionnaire of the Gdansk postmen from 13th of November 2006 mentioned: (i) rise of the wages for all postman up
to 2500 PLN respectively 1700 PLN for newcomers; (the average wage is 1,600 PLN and after tax and social fees 1,000
PLN), (ii) fixed labour-contract for newcomers after one year; (iii) postmen do not deliver unaddressed mail (bulk mail); (iv)
working hours are fixed on 8 hours and installation of a punch card; (v) payment of hours of overtime in accordance with the
law of labour; (vi) food and water in the offices, (vii) automatically adoption of the wages at the inflation rate, (viii) no
repressions of participants at protest actions. 48
Wildcat (2007), page 33-35. 49
(i) Inter-Employer Union Organisation of the Solidarity Independent Self-Governing Trade Union (Międzyzakładowa
Organizacja Związkowa Niezależnego Samorządnego Związku Zawodowego ‘Solidarność’); (ii) Free Trade Union of Postal
Employees (Wolny Związek Zawodowy Pracowników Poczty, WZZPP); (iii) Federation of All-Poland Alliance of Trade
Unions of Communications Workers (Federacja OPZZ Pracowników Łączności); (iv) Independent Self-Governing Trade
Union of Poczta Polska Postmen (NSZZ Listonoszy Poczty Polskiej); (v) Forum Nationwide Trade Union (Ogólnokrajowy
Związek Zawodowy Forum, FZZ); (vi) Postal Guard Nationwide Trade Union (Ogólnopolski Związek Zawodowy ‘Straż
Pocztowa’); (vii) Kontra Trade Union (Związek Zawodowy ‘Kontra’); (viii) Inter-Employer Free Trade Union of Poczta Polska
Employees (Międzyzakładowy Wolny Związek Zawodowy Pracowników Poczty Polskiej). 50
Eurofound (2007).
Country sheet: Poland 745
1.8.3 Productivity
No information is available concerning the productivity of Polish Post or the alternative
operators. Given the fact that Polish Post delivers 2.9 billion items (including letter mail,
parcels and express) and has circa 100,000 employees their rough productivity figure is
29,000 items/employee.
1.9 Technological developments and environment
1.9.1 External
There is no information available concerning the external technological developments, for
example, related to the percentage of letter mail in the communications’ market or the
turnover realised by e-commerce.
An interesting example in this respect is the development of mobile banking service for
its customers by Polish Post (mentioned before). The fact that customer will be able to
manage there account via mobile phone, make transfers, verify account balances and
make small payments like parking is an interesting example of the integration of (postal)
financial services and emerging technological development s in the electronic
communication market.
1.9.2 Internal
There is no information available concerning the percentage of letter mail that is
automatically processed.
Polish Post invested in a sorting centre in Lublin of about € 20 million. In this centre it is
planed that 600 employees shall sort 500,000 letter-mail and 20,000 parcels per day. The
centre shall commence in autumn 2009. Actually Polish Post has 10 sorting centres
(Warsaw, Krakow, Wroclaw, Poznan, Szczecin, Gdansk, Lodz, Katowice, Lublin,
Olsztyn).
1.9.3 Environment
There is no information available concerning the postal sector developments in terms of
environmental issues.
1.10 Sources
• European Commission (2007). State aid: Commission takes note of abolition of
unlimited state guarantee for Polish Post Office, press release by the European
Commission, 25 April 2007.
Annex II: Main Developments in the Postal Sector (2006-2008) 746
• Datamonitor (2008). Publication by Datamonitor of 10 March 2008, see
<www.datamonitor.com >.
• ECORYS (2005a). Development of competition in the European postal sector, study
for DG Internal Market, European Commission, July 2005.
• Eurofound (2007). Industrial relations in the postal sector – Poland, study for the
European Foundation for the Improvement of Living and Working Conditions by
Jacek Sroka, November 2007.
• Infoseiten (2008). Polnische Post vor Privatisierung, news item 5 January 2008, see
• < www.infoside -polen/newslog>.
• Ministry of Infrastructure (2007). The Government adopted the draft Act on
Commercialisation of the Polish Post, press release number 51 (138), 27 March 2007.
• Polish Post (2006). Annual report 2005, report by the national postal operator, 2006.
• Polish Post (2007). Annual report 2006, report by the national postal operator, 2007.
• UKE (2006). Annual report 2005, report by the national regulatory authority, 2006.
• UKE (2007a). Transit times for postal items in 2006, report by the national regulatory
authority, January 2007.
• UKE (2007b). Annual report 2006, report by the national regulatory authority, 2007.
• UKE (2007c). The postal market assessment for the year 2006 (in Polish), report by
the national regulatory authority, 2007.
• UKE (2007d). The postal market assessment for the year 2006, English summary of
UKE (2007b) by the national regulatory authority, August 2007.
• UKE (2007e). Transit times for postal parcels, report by the national regulatory
authority, December 2007.
• UKE (2008a). The postal market assessment for the year 2007 (in Polish), report by
the national regulatory authority, May 2008.
• UKE (2008b). The postal market assessment for the year 2006, English summary of
UKE (2007b) by the national regulatory authority, June 2007.
• WIK-Consult (2006). Main developments in the postal sector (2004-2006), study for
DG Internal Market and Services, European Commission, May 2006.
• Wildcat (2007), Wildcat No: 78, winter 2006/2007 p. 33-35.