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A comparative study of free and reduced cost postal services for blind and partially sighted people in the European Union

November 2003


Contents



1. Introduction to the European Blind Union and the survey on postal services

The European Blind Union (EBU) is a non-governmental and non profit-making European organisation founded in 1984. EBU currently has 44 member countries, each represented by a national delegation. EBU aims to protect and promote the interests of the significant number of 7.4 million blind and partially sighted people in Europe. The number of people with sight problems in Europe is likely to increase even further. It is a known fact that the population is ageing, and that a lot of people develop sight problems when they become elderly.

The detailed work of the European Blind Union is carried out by Standing Commissions and by Expert Working Groups, whose areas of activity reflect the major interests of EBU. One of these EBU Working Groups, namely the working group on Access to Information, organised this study on free and reduced cost postal services for blind and partially sighted people in the European Union.

The Working Group would like to thank the following organisations for their input into this study :

    - Osterreichischer Blinden- und Sehbehindertenverband Bundesgeschaftsstelle (Austria)

    - Belgische Confederatie voor Blinden en Slechtzienden - Confédération Belge pour la Promotion des Aveugles et Malvoyants (Belgium)

    - SONS - Czech Blind United (Czech Republic)

    - Dansk Blindesamfund (Denmark)

    - Nakovammaisten Keskusliitto RY (Finland)

    - Comité National pour la Promotion Sociale des Aveugles (France)

    - Deutscher Blinden- und Sehbehindertenverband DBSV (Germany)

    - Panhellenic Association of the Blind (Greece)

    - National Council for the Blind of Ireland

    - Unione Italiana Ciechi (Italy)

    - Federatie Slechtzienden- en Blindenbelang (Netherlands)

    - ACAPO (Portugal)

    - Organizacion Naciónal de Ciegos De Espana (ONCE)

    - Synskadades Riksforbund, SRF (Sweden)

    - Royal National Institute of the Blind, RNIB (United Kingdom)

Finally, the working group would like to thank Nolan Quigley and Leen Petre at RNIB's European Campaigns Unit for processing the survey results and producing this report.

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2. The EBU position on postal services

The European Blind Union Access to Information Working Group members agreed that the following principles should be recognised in relation to postal services for blind and partially sighted people :

2.1. Postal services for blind and partially sighted people should be available from all service providers in the market, not just from one national universal service provider.

Blind and partially sighted people are more reliant than the average user on the post for home shopping etc., so any impact on postal services has a disproportionate effect on them. For example, many blind and partially sighted people rely largely on the postal service to access information and obtain essential equipment which is not readily available from high street shops.

This is why freepost schemes for blind and partially sighted people should be available from all service providers in the market, and freepost schemes need to be recognised and protected as a service of general interest.

Postal services providers currently have a universal service obligation to deliver and collect post everywhere. With increasing privatisation, there is concern that some private operators will cherry pick lucrative routes and ignore the rest leading to the old national universal service provider (Royal Mail, de Post, etc…) having to deal with the least profitable delivery routes.


2.2. Postal services for blind and partially sighted people should be reliable, secure and have a guaranteed priority delivery speed.

Quality is as important, if not more so, to blind people as to sighted people. Services need to be reliable and secure, and information has to be made available in alternative formats (braille, large print, spoken word audio, computer disk - 1) allowing blind and partially sighted people to access information and services. Speed of delivery is particularly important because blind and partially sighted people have often already had information delayed while it is made available in alternative formats such as braille or tape. For the same reason freepost items should be guaranteed for next day delivery to minimise the risk of delays of items which may have a direct impact on the quality of blind people's lives.


(1) For a full explanation of the need for and production of information in alternative formats, see : European Blind Union (2003). Access to information, Making your information accessible for customers with sight problems

2.3. Postal services for blind and partially sighted people should be physically accessible, i.e. service providers need to maintain a number of collection points and special collection and delivery arrangements in rural areas.

Given that mobility is a significant problem for many blind and partially sighted people, it is important that the number of collection points for postal services is maintained. In addition blind and partially sighted people highly value the option in rural areas to have bulky and heavy letters and packages collected. This service should be safeguarded.

Any changes likely to affect collection or delivery arrangements should take into account the particular needs of blind and partially sighted people. In particular, market liberalisation should not lead to a reduction in the existing network of post offices in our local communities, as these offices are a crucial point of contact and access point in providing a universal service to blind and partially sighted people.

The closure of urban and rural Post Offices is a real problem for blind and partially sighted people and we support their promotion and development rather than their disappearance.


2.4. Postal services for blind and partially sighted people should be free of charge (or freepost).

The issue of the affordability of postal services is particularly relevant to blind and partially sighted people. Firstly, special format copies of documents and books (for example braille copies) are heavier than their print equivalent and would make many items prohibitively expensive to post, yet they can often only be obtained by mail-order. Secondly, the majority of blind and partially sighted people live on lower incomes than non-disabled people, with a smaller percentage than average in employment. Combined with overall higher living costs (due to reliance on specialist equipment and mobility problems), this means that charging for their postal services would have a disproportionate and discriminatory effect on blind and partially sighted people. Their reliance on affordable postal services is particularly great.

In conclusion, postal services for blind and partially sighted people should be provided free of charge. Without the freepost scheme they would be denied access to information and services which are essential for their ability to live independent lives. Similarly, the ability of their organisations to provide them with essential services would be jeopardised.


2.5. No distinction should be made between postal items and items of correspondence for or from a blind or partially sighted person or their organisations. All of these should be carried without charge. The same should apply to all special aids or equipment for blind and partially sighted people. A realistic weight allowance should be applied.

Any new legislation or regulation should avoid any reduction in the service currently provided to blind and partially sighted people on the grounds of lack of profitability.

Given the considerable weight of some braille copies the weight limit of 7 kg as set in the Universal Postal Convention should be applied. Article 7.4 of the 1994 text of the Universal Postal Convention also states that "literature for the blind shall be exempt from all postal charges, with the exception of air surcharges". This Convention binds governments, and as they should ensure that it is applied in their countries by postal operators and that postal operators do not charge for sending items for and from blind and partially sighted people and their organisations.

As concerns the range of items to be covered by freepost, it is essential that the distinction between postal items (e.g. newspapers and goods) on the one hand and items of correspondence on the other hand should not be applied to freepost for blind and partially sighted people. It is precisely because braille and tape versions of "postal items" (newspapers, magazines and books) are not readily available that blind and partially sighted people rely on postal services to get access to them. The same applies to specialised equipment or aids which are only available by post.

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3. The European Directives that apply in this sector and the problems arising from liberalisation.

3.1. The 1997 Directive

The first Directive that established a regulatory framework for the postal sector area is Directive 97/67/EC of 15 December 1997 on "common rules for the development of the internal market of Community postal services and the improvement of quality of service". This text included measures to guarantee a universal service and set maximum limits for the postal services which Member States were allowed to reserve to their universal service provider(s).

3.2. The 2002 Directive

The 1997 Directive was recently amended by Directive 2002/39/EC of 10 June 2002 "amending Directive 97/67/EC with regard to the further opening to competition of Community postal services". Directive 2002/39/EC aimed at further opening up postal services to competition in the European Union. The main objectives of this Directive were a further controlled liberalisation of the postal market and a durable guarantee of the provision of universal service.

In most countries in the Europe Union, the state is obliged to deliver mail to all citizens and the state also owns the concession to deliver mail in the country. In many European countries it is also stated in the law that the state is obliged to supply free postal services for blind and partially sighted people. Normally the state chooses to hand over both the concession and the obligation to a company (in the past this was usually a government owned company). The reason being that the concession would compensate for the cost the company incurs when fulfilling the obligation to deliver mail to all citizens e.g. people living in areas hard to reach and postal services for blind and partially sighted users.

With these Directives the European Union has regulated this practice of allocating the concession. The company holding the concession is in the Directives known as the "universal service provider". The Directives provide a timetable for a gradual and controlled opening of the market for letters to competition, which should allow all universal service providers sufficient time to modernise and restructure to ensure their long-term viability under the new market conditions. The Directives provide a step-by-step approach to further market opening also opening outgoing cross-border mail fully to competition. At the same time, the Directives set weight limits for the services which may be reserved to the "universal service providers": 100 grams in 2003 and 50 grams in 2006.

Article 7, 1 of Directive 2002/39/EC states: "To the extent necessary to ensure the maintenance of universal service, Member States may continue to reserve services to universal service provider(s). Those services shall be limited to the clearance, sorting, transport and delivery of items of domestic correspondence and incoming cross-border correspondence, whether by accelerated delivery or not, within both of the following weight and price limits. The weight limit shall be 100 grams from 1 January 2003 and 50 grams from 1 January 2006..... "

Free postal service is exempt from these weight limits as follows, "In the case of free postal service for blind and partially sighted persons, exceptions to the weight and price restrictions may be permitted."


3.3. How can liberalisation impact on freepost schemes ?

The introduction of the aforementioned EU rules and any further liberalisation could cause problems for the freepost services that exist, because freepost is closely linked to the universal service concept.

If we check the EBU position on postal services, it becomes clear that the basic principles it sets out could be seriously undermined by further liberalisation of postal services.

Firstly, there will need to be a strong provision requiring all service providers in the market to provide postal services for blind and partially sighted people. If free competition means that the universal service provider is left to deal only with letters of less than 50 grams and therefore restructures its operations to handle only this type of mail items, then that service provider will have problems handling freepost items that are heavier. A Braille letter, for example, will normally weigh more than 50 grams.

Secondly, there will need to be assurances that services will be reliable, accessible, secure and have a guaranteed priority delivery speed. Increased competition should not imply that the handling of freepost items receive less attention and care than the handling of profit-making items.

Thirdly, there will need to be provisions to ensure that freepost services are accessible and free of charge. Postal companies that are being asked to deliver a free postal service will expect compensation. At the moment, receiving the national concession is the compensation for the universal service provider, but as markets for items above 50 grams are opened up to competition, service providers are likely to demand a new form of compensation. This issue will need to be resolved as it will become a pressing question with further liberalisation.

Finally, many freepost services for blind and partially sighted people in Europe need to be broadened so that they can fully cover all postal items as well as items of correspondence sent or received by blind or partially sighted people or their organisations (with a realistic weight limit). Even though some governments are interested in broadening the freepost system to reflect the changing ways in which blind and partially sighted people communicate in society, the difficulties of maintaining freepost schemes in a liberalised market could put the brakes on such developments.

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4. The 2003 European Blind Union study of free and reduced cost postal services

The EBU Access to Information Working Group organised a survey of members of the EBU Liaison Commission in the first half of 2003 in order to study the existence and extent of free and reduced cost postal services for blind and partially sighted people throughout Europe. (A similar survey was conducted in 1999, when the liberalisation of postal services was at a more embryonic stage.)

Responses were received from every current EU Member State except for Luxembourg. The Czech Republic also completed the survey, and as it is a future EU member its input has been included in the results. So in total, EBU organisations from 15 countries have contributed to the results, namely : Finland, Sweden, Denmark, Germany, Austria, Czech Republic, Netherlands, Belgium, France, United Kingdom, Ireland, Italy, Greece, Spain and Portugal.

The 2003 study asked each country's EBU organisation what articles are covered by the freepost scheme in their country, whether reduced rates are used instead of or in addition to freepost, on what legal basis the freepost system operates, who is qualified to send and receive freepost articles, the financial costs and benefits of the scheme and how it is funded. In addition, it also asked organisations representing blind and partially sighted people about the progress towards postal liberalisation in their respective country and whether they were worried about the future of the freepost system for the blind.

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5. The 2003 European Blind Union survey results

This section will look at what postal items and items of correspondence are covered by free-of-charge schemes or reduced charging in the different countries represented in the survey as well as other aspects such as who is eligible for the scheme, what the legal basis is, how it is funded etc.

For each of these issues, we will identify any patterns that occur across Europe.

5.1. What items are covered by freepost schemes ?

This section discussed a range of alternative formats frequently used by blind and partially sighted people who can not read standard print. For a detailed explanation on these formats, see the European Blind Union guidelines in this area.

Braille
Braille is a method of reading by touch using a system of raised dots. There are dot combinations which correspond to letters of the alphabet, punctuation and common letter groups. Almost any information can be put into braille - from bus timetables to music. The numbers of blind and partially sighted people able to read braille is small but for these people it is a crucial medium. This is reflected in the prominence that braille receives in the freepost systems for blind and partially sighted people that operate throughout Europe. All EU countries operate a freepost system for Braille items of mail, mostly without limits on who can send braille to whom. Only 4 countries surveyed imposed restrictions as to the sender or recipient, namely Belgium, Greece and the Netherlands, where the correspondence has to be between a blind organisation and a blind person or vice-versa.

Large Print
Large Print is defined by the European Blind Union as print in a font size larger than 'standard', i.e. a minimum of 16 point. For some blind and partially sighted people up to 20 point text may be required. As the majority of printed information is nowadays generated by word processors, it has become possible to print off copies in the size requested and to better meet individual's needs. Consequently, sending large print by the postal systems throughout Europe has become even more important than before.

Only 3 countries extend freepost to large print, even though this is such a vital resource for partially sighted people. They are Spain, Portugal and the United Kingdom. Sometimes reservations are expressed about the possibility of operating large print freepost schemes without opening the system up to abuses. However, the postal authorities in these three countries clearly feel that they can operate a satisfactory system.

Large Print is defined by the European Blind Union as print in a font size larger than 'standard', i.e. a minimum of 16 point. For some blind and partially sighted people up to 20 point text may be required. As the majority of printed information is nowadays generated by word processors, it has become possible to print off copies in the size requested and to better meet individual's needs. Consequently, sending large print by the postal systems throughout Europe has become even more important than before.

Only 3 countries extend freepost to large print, even though this is such a vital resource for partially sighted people. They are Spain, Portugal and the United Kingdom. Sometimes reservations are expressed about the possibility of operating large print freepost schemes without opening the system up to abuses. However, the postal authorities in these three countries clearly feel that they can operate a satisfactory system.

Audio-tape
Audio tape and other audio file formats are a very effective means of communication. They are preferred by many blind and partially sighted people, e.g. people who have recently lost their sight and have not mastered the use of braille or those with diabetes who have lost the sensitivity of their fingertips.

All of the countries allow freepost for audio tape items of mail. This is a clear recognition of the importance of this information format and a marked improvement. Previously the 1999 Survey showed that Finland and Spain did not offer this service.

Countries do apply varying degrees of restrictions, for example, France, Netherlands and Germany, require that correspondence must again be between an organisation and an individual. (i.e. not between individuals themselves). In Austria, the freepost of audio-tapes is only allowed when it concerns correspondence between organisations and their members. In Belgium, it is only permitted between special libraries or production centres and their members.

Computer Diskettes and CD-ROMs
Computer disks (or increasingly CD-ROMs) may be the preferred format of blind and partially sighted people with access to computers. Blind and Partially sighted computer users can access the information that is displayed on their computer screen by using speech synthesisers, braille keyboards, large print displays and other innovations. Computer use has increased the number of ways in which blind and partially sighted people access information. The above mentioned software and hardware solutions allow blind and partially sighted people to access any information created in an open text format, such as word-processing files.

The importance of computer files as a means of communication is clearly recognised by freepost schemes as 10 of the 15 countries allow computer diskettes and CD-ROMs to be sent by freepost. However, various restrictions apply. Austria, Belgium, Germany, and the Netherlands all require the correspondence to either come from or go to an institution, thereby preventing communication via these media between blind and partially sighted individuals. Both Portugal and the Netherlands stress that diskettes and CD-ROMs can only contain audio material, which means that many very useful open text files are not covered by the scheme. Denmark, Finland, Sweden, France and the Belgium do not allow computer disks and CD-ROMs to be sent at all but there is progress, firstly in France where the Fédération d'Aveugles de France (FAF) have negotiated temporary agreements to send CD-ROMs free of charge with their local post office. Progress is also apparent in Denmark where a new pilot scheme sends diskettes free of charge between blind and partially sighted people and from public institutions and private organisations to blind and partially sighted people. Negotiations are also ongoing in Denmark to allow CD-roms to be sent free of charge.

There has been considerable improvement since 1999 when both the UK and Portugal placed restrictions which they have since abandoned, such as only allowing diskettes to be sent free of charge between organisations and individuals. Greece, one of the countries where diskettes and cd-roms still can not be sent by freepost highlights this discrepancy as being one that blind and partially sighted people would most like remedied.

Special equipment for blind and partially sighted people
Designers have invented a range of special equipment for blind and partially sighted people to enable them to be as independent as possible in their daily life. Examples of this equipment are braille writing frames, talking watches and clocks, walking sticks adapted for blind people, tactile maps, talking calculators etc…

Denmark, Ireland and the United Kingdom, allow freepost for specially adapted equipment for visually impaired people. Denmark restricts these items to those which are communication related, such as braille embossing machines.

The UK and Ireland appear to have schemes that are of most benefit to blind and partially sighted people by allowing all kinds of aids for blind and partially sighted people to be sent. The Irish freepost scheme even allows items as big as computers to be sent free of charge. In the UK, the scheme covers articles such as harnesses for guide dogs, specially adapted games, talking watches and other aids.

In addition, The French Federation is currently negotiating an extension of freepost to CDs, DVDs and audio-described videocassettes.


5.2. Reduced Rate Postage Options

Only three out of the fifteen countries that participated in the survey, namely Denmark, Ireland and the Netherlands operate limited reduced rate post schemes for some items, mostly to cover international mail. In Denmark, parcels or letters weighing more than 7 kg can be sent as first class post domestically and as second class internationally at reduced rates. In the Netherlands and Ireland, international mail for blind and partially sighted people can be sent at reduced rates.


5.3. Weight Limits

Denmark, the Czech Republic, Ireland, the UK, Sweden, Finland, Greece and Portugal, impose a maximum weight restriction of 7 kg for freepost items for blind and partially sighted people. The UK allows only 1kg of freepost if sent elsewhere in the EU.

In France, on the other hand, the 7 kg limit applies to international mail, with 5 kg as a maximum domestically. Austria imposes a maximum weight of 5 kg for parcels. Italy sets a maximum of 1 kg for audio tapes, CD-ROMs and computer disks and 5 kg for braille books. Germany imposes a maximum freepost weight of just 1 kg. Spain's maximum is 4 kg.


5.4. Dimension Limits

Of the 15 countries, all except the UK, Belgium, Czech Republic, France, Italy and Portugal and Sweden have some kind of maximum dimension for freepost package. This is most complicated in Denmark which has different maximum dimensions for the Faroe Islands and Greenland. Greece, Netherlands and Denmark also have minimum dimensions.


5.5. Special Wording on Packaging

All 15 countries require some special wording or symbols to appear on freepost mail for blind and partially sighted people. In Greece there is a special stamp that people can get from either the post office or the Association. A variant of the word "cecogramme" is used in 6 countries. In Germany and Italy, a different wording is used for audio or braille material.


5.6. Who can use the scheme ?

The criteria used to qualify to send post through the freepost scheme vary from Belgium and Spain where no registration at all appears to be necessary for either the person or the organisation to countries where the blind person must be registered (Austria, Czech Republic, Germany, UK). In Greece only members of the visually impaired association can use freepost.

In most countries the organisations that wish to qualify need to register with or be recognised by the State. In Denmark, the organisation must be a service provider.

In Finland, the freepost system applies to private individuals. A different system is operated for libraries and organisations of blind and partially sighted people : they benefit instead from an indirect system of reduced postal charges as their postal costs are reimbursed after they have been incurred.


5.7. The Legal Basis for Freepost

Most countries set out the details of the national freepost scheme in their post office contracts with government or customers. 4 countries use some form of legislation to define the freepost system, they are Italy, Denmark, Spain and the UK.


5.8. The Funding of the Freepost Scheme

Funding for the freepost scheme is provided by the State in Sweden, Belgium, Spain and the Czech Republic. The Post Office funds the scheme in Italy, the UK, Germany, Finland, the Netherlands, Greece and Portugal. In France, the post office pays and is then reimbursed by the State. In Ireland, NCBI (The National Council of the Blind of Ireland) is responsible for the production of the labels, the rest is paid by the Post Office.

It is important to note that the incentive for the post office as "universal service provider" to fund the scheme as it does in a number of countries, is most likely the fact that they are the holder of the national concession. Once the market is opened up and more companies enter the field, other incentives will need to be put in place to ensure that freepost schemes continue to be operated.

It is also necessary to ensure that the existing compensation schemes in the form of government subsidies or other funding are allowed to continue to exist in a further liberalised European postal service market.


5.9. The importance and cost-benefit balance of freepost services

EBU members provide services and products that rely upon the use of freepost systems, e.g. they provide blind and partially sighted people with equipment that helps them increase their independence and mobility, books, magazines and newspapers in braille or on tape. Any discontinuation of freepost services would have serious implications for the continuation of these services and this was confirmed in the survey responses.

All organisations agreed that the freepost system is important. When asked to explain why they consider freepost important, organisations mentioned the following elements :

    - The right to information of blind and partially sighted people was referred to in various ways, e.g. one organisation quoted "the principle of equal access to information without a financial penalty pursuant to article 5 of the UN standard rules" (1), another organisation referred to "the right of visually impaired people to access information".

    (1) Standard Rules on the Equalization of Opportunities for persons with Disabilities, adopted by the United Nations General Assembly, forty-eighth session, resolution 48/96, annex, of 20 December 1993

    - The importance of freepost for library services received particular mention. One organisation said that, "freepost is the lifeblood of national library services". The National Library for the Blind in the UK estimates that it would not be able to bear the annual cost of approximately Pounds 2.9m (Euros 4.1m) to pay for the sending and return of its books in braille format.

    - The importance of freepost for the social inclusion of blind and partially sighted people was referred to. Organisations emphasised the "social aspect of such communications" and that "low income visually impaired people would be excluded from much current information they receive and send."

    - The importance for service provision to blind and partially sighted people was highlighted, and one organisation said: "it would pose a big problem to service providers too, many of whom are charities and rely on freepost to provide as many services as possible to blind and partially sighted people."
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6. The future of freepost schemes

The survey looked at the concerns of European Blind Union Members relating to the future of freepost schemes and possible improvements. These elements are analysed in this section.

6.1. How to overcome some practical problems relating to the operation of freepost schemes

Ten EBU members highlighted examples of problems with the freepost schemes in their countries.

The problems relate to the following aspects :

    - The need to increase the timeliness and quality of the service :
    In many countries, there is suspicion or proof that freepost for blind or partially sighted people is slower than regular post, for example, in France they believe freepost is treated as second class post despite the government reimbursing the post office for first class post. Sweden has noticed a decline in service in certain post offices since rationalisation programmes were instigated. In Portugal freepost can only be sent from post offices and can not be put in normal post-boxes in the street. This poses problems for blind and partially sighted people who can not easily get to a post office.

    - The need for a neutral naming of the service :
    In Ireland, it was felt the term, "articles for the blind" was offensive and restrictive.

    - The importance of preventing fraud and misuse of the service :
    In several countries ( e.g. France, Portugal and The Netherlands) freepost mail must not be sealed to prevent misuse and to allow checks to be made on the contents and it was suggested that this system works quite well.

    - The lack of clarity about the scheme and the lack of publicity given to the scheme :
    Partially sighted people's rights under the freepost schemes are not always clear. Many EBU members believe that the system is not well-enough publicised especially with regard to partially sighted people. Most respondents agreed that the scheme should be better advertised.

    - The need to abolish the exclusion of certain items :
    Most EBU members suggested extending the range of items which can be sent freepost, for example to include large print, disks, CD-ROMs and so on.

    - The need to abolish the exclusion of certain potential beneficiaries :
    Most EBU members suggested extending the range of organisations and individuals who would qualify to use the scheme.


6.2. The combination of the most advanced different national features would lead to a very progressive model.

In the following exercise we have combined the most progressive features that can be found in any of the 15 different systems that operate in the 15 countries that participated in the survey. This results in a theoretical model of a freepost scheme with a strong basis in reality as the various aspects are operated with demonstrable success in at least one of the 15 countries.

This theoretical model would look as follows :

    - Freepost for braille, large print, audio tapes, computer disks and CD-roms available to (1) anyone sending items to a blind or partially sighted individual and (2) any individual blind or partially sighted person sending out items

    - Freepost of any equipment (including specially adapted equipment) to any blind or partially sighted person without minimum and maximum weight requirements

    - Any items to be sent by freepost are to be clearly identified by a special stamp, sticker, wording or symbol on the exterior of the article

6.3. The assessment of the impact of liberalisation legislation on freepost schemes by European Blind Union members

As specified in EU legislation, all EU countries are moving towards liberalisation but at differing speeds. Significant changes have already taken place in Denmark, Sweden and Germany. Changes are planned or have begun in Ireland, Finland, the Netherlands, Spain, and the UK. France, Portugal, Italy, Austria, Greece and Belgium all anticipate changes to varying degrees but do not know what form they will take. Sweden is the most liberalised and interestingly it is in Sweden, where the respondent to the Survey claimed that customer service had deteriorated since the liberalisation or "rationalisation" process was put in place.

40 % of the respondents to the survey (6 out of the 15 countries) expressed concern about the future of freepost for blind and partially sighted people. Belgium was undecided and the UK and Germany believed that although there was a danger, the future of freepost could be easily assured. Italy was alone in believing that there was absolutely no prospect of losing the freepost provision.

National Organisations are clearly not all convinced that the current commitments given about universal service preservation by the EU Directives, governments and the post offices alike will be maintained in the future.

This is why any future proposals for further market liberalisation need to re-affirm the provision of freepost services for blind and partially sighted people and their exemption from regular weight restrictions.

Proposals for further liberalisation of postal services also need to address the issues raised in section 3.3. of this study : there will need to be a strong provision requiring all service providers in the market to provide postal services for blind and partially sighted people; there will need to be assurances that services will be reliable, secure and have a guaranteed first class delivery speed ; there will need to be provisions to ensure that freepost services are physically accessible and free of charge (whilst ensuring compensation for the operating companies). Finally, many freepost services in Europe need to be broadened before they can cover all postal items (with realistic weight limits) as well as items of correspondence sent or received by a blind or partially sighted person.

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7. Summary and conclusion

The European Blind Union has agreed some basic principles that should govern postal services for blind and partially sighted people. They are: that all service providers in the market should provide postal services for blind and partially sighted people; that the services should be reliable, secure and have a guaranteed priority delivery speed; that the services should be physically accessible, that they should be free of charge; and that they should cover postal items and items of correspondence as well as assistive or adapted equipment for blind and partially sighted people with a realistic weight allowance.

The European move to liberalise the postal services market, unless conducted with carefully crafted guarantees for blind and partially sighted people, could seriously undermine these principles.

The survey conducted by the European Blind Union of 15 Countries in Europe (14 European Union Countries and the Czech Republic) shows that the vast majority of countries operates a system of freepost for braille without restrictions as concerns the sender or recipient.

The study revealed differences in provision across the EU. For example, an Irish blind person can send a braille embosser, a German blind citizen could only send a package of 1kg. These results raise the question as to whether it would not be beneficial for individual EU member states and the European Institutions to consider the EBU principles when making decisions about freepost schemes.

Some common features of the schemes were identified. All countries allow freepost for audio items with varying degrees of restrictions. A large majority of the countries allow computer diskettes and CD-ROMs to be sent by freepost with varying restrictions. Some of the countries surveyed have extended the freepost to cover large print items. Some countries allow freepost for specially adapted equipment or for all assistive equipment that benefits blind and partially sighted people.

In terms of weight limits, most countries apply a reasonable weight limit of 7 kg for freepost. About half of the countries have a maximum dimension restriction for freepost packages.

All 15 countries that participated require some special wording or symbol to appear on freepost for blind and partially sighted people. A third of countries require some form of registration of the blind or partially sighted individual before they can benefit from the freepost scheme, and most require that the organisations wishing to benefit should register.

When it comes to the practicalities of operating freepost schemes, some interesting features emerged from the EBU study that should be taken into account in any proposals for further liberalisation of postal services: most countries set out the details of their national freepost scheme in their post office contracts; some use legislation to define the freepost scheme; in a third of the countries the scheme is directly funded by the government, whilst for most of the respondents the post office funds the scheme.

The cost-benefit analysis of freepost services highlights that all EBU respondents agree that freepost schemes are highly important to in practice deliver the right to information for blind and partially sighted people and in particular access to library services. It is also recognised that freepost schemes contribute to promoting social inclusion and ensuring that vital services reach blind and partially sighted customers.

When looking at the future of freepost schemes across Europe, most of the participating EBU members identified problems that needed addressing such as timeliness and quality, the naming of the service, combating fraud and misuse, a lack of clarity and publicity, exclusion of certain items and exclusion of potential beneficiaries.

The study also demonstrated that the combination of the most advanced different national features would lead to a very progressive model. Such a model is not unrealistic, since there are examples of countries that operate each element of the model. There are clear lessons to be learned for countries operating a rather more minimalist system.

EBU members who participated in the study raised their concerns about further liberalisation and there are a number of issues that will need to be addressed in any moves toward further liberalisation.

The provision of a free postal service for blind and partially sighted people and the exceptions to the weight restrictions that come with it, should be recognised in any future proposals for further liberalisation of the postal service in Europe. This would ensure that the EBU principles on postal services for blind and partially sighted people are safeguarded in the process.

To conclude, this EBU study clearly demonstrates that the freepost system is valued throughout the EU by organisations of blind and partially sighted people and that it must be protected and maintained in the future.


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