Letter

Palun registreerida kiri Deltas.

Dear Madina,

We will have follow-up questions to the information you shared last Friday.

In case the applicant wishes to include international express parcel delivery services in the scope of the request, they will have to provide additional information concerning this segment of the market.

This should include the following:

• * Product market definition (among others, the applicant should clarify whether the international market should be distinguished further into standard and express and explain the reasons for the relevant approach to be followed, taking into consideration Commission’s precedents).  

• * Barriers to market entry for the provision of international express parcel delivery services (if any).

• * Formal requirements to enter the market (if any).

• * Number of operators active in this segment of the market.

• * Names of competitors and their market shares in terms of value and volume (if data are not available, we ask you to provide best estimates for this segment of the market in line with the approach followed under tables 3 to 8, in pp. 25-27 of the exemption request for international standard parcel delivery services).

• * Justification/summary of the reasons why the applicant considers that the the activity relating to the provision of international express parcel delivery services in Estonia is directly exposed to competition.

• * Any other information that might be relevant for the assessment.

We would be grateful if you could share this information by Wednesday, 23 April 2025, close of business. In the absence of a reply by 23 April 2025, the deadline for the adoption of the decision by the Commission will be suspended until the receipt of the information.

We remain at your disposal should you have any questions.

Kind regards,

Christos

Christos Chrysostomou

Legal Officer

European Commission

DG for Internal Market, Industry, Entrepreneurship and SMEs

Directorate E. Single market enforcement

GROW E.2 – Enforcement – Goods, Services to Consumers, Public Procurement, Late Payments

Avenue des Nerviens 105, 06/005

B-1040 Brussels, Belgium

+32229-94228

e-mail: [email protected]

DISCLAIMER

"The views expressed are purely those of the writer and may not in any circumstances be regarded as stating an official position of the European Commission."

Dear, Christos,

Dear Christos,

Thank you for your message clarifying the required procedure for formal communication regarding the exemption request submitted by the Estonian authorities.

We understand and acknowledge that the formal submission of information should come directly from the Estonian authorities to the Commission. In line with this procedure, the Ministry of Finance approves the following response, which was prepared by AS Eesti Post.

We hereby forward this response on behalf of the Ministry of Finance:

“While the application does not expressly include international express parcel delivery services, we consider that market to be open to competition. Thus, it would be appreciated, if it is possible to include it. With regard to Eesti Post – Eesti Post does not have parallel international networks for express and standard parcels, thus its entire activity on the international parcel segment is covered by standard parcels. An express versus standard distinction only carries some relevance on the domestic level.

That said, since Eesti Post is not active in the market (thus its market shares would be 0) and its key competitors, such as DPD and DHL, operate parallel networks for international express parcel delivery and their activities are subject to competition, the market, at least to the extent that it concerns Estonia, is open to competition. This further indicates that from Eesti Post’s perspective, the international express parcel market would be fully open and competitive, should Eesti Post potentially enter this market segment in the future.” 

We trust this provides the necessary information as requested.

Dear Kristo,

Many thanks for your message.

However, since the exemption request has been formally submitted by the Estonian authorities, it is for the latter to submit this information to us bilaterally. Hence, we expect that this information is submitted to us by the Estonian authorities.  

As we have already explained you during the informal procedure, the formal correspondence will be between the Commission and the Estonian authorities. It is up to the Estonian authorities to forward to Eesti Post and Cobalt anything they see fit.

Kind regards,

Christos

Dear Christos,

We are replying on behalf of the Ministry of Finance.

While the application does not expressly include international express parcel delivery services, we consider that market to be open to competition. Thus, it would be appreciated, if it is possible to include it. With regard to Eesti Post – Eesti Post does not have parallel international networks for express and standard parcels, thus its entire activity on the international parcel segment is covered by standard parcels. An express versus standard distinction only carries some relevance on the domestic level.

That said, since Eesti Post is not active in the market (thus its market shares would be 0) and its key competitors, such as DPD and DHL, operate parallel networks for international express parcel delivery and their activities are subject to competition, the market, at least to the extent that it concerns Estonia, is open to competition. This further indicates that from Eesti Post’s perspective, the international express parcel market would be fully open and competitive, should Eesti Post potentially enter this market segment in the future. 

To facilitate smooth correspondence between the Commission and the applicant going forward, we kindly request that the individuals copied on this email be included in all future related correspondence.

Kind regards,

Kristo Pullerits [COBALT]

Dear Madina,

We have a question for clarification pertaining to the exemption request.

Point 38, under section “1.1.2. International parcel services (inbound, outbound)” of the request, provides the following: “the applicant notes that the relevant product market for the purposes of this application should be considered the provision of international standard parcel services in Estonia, which includes the provision of both international standard parcel services using the parcel machine networks as well as the provision of maxi letter services (with an item content of up to 2kg).”

Could you please confirm whether international express parcel delivery services are not covered by the exemption request?

We would be grateful if you could reply by 11 April 2025, close of business. In case of a late reply, the deadline for the adoption of the decision by the Commission will be suspended until the receipt of the information.

Kind regards,

Christos

Christos Chrysostomou

Legal Officer

European Commission

DG for Internal Market, Industry, Entrepreneurship and SMEs

Directorate E. Single market enforcement

GROW E.2 – Enforcement – Goods, Services to Consumers, Public Procurement, Late Payments

Avenue des Nerviens 105, 06/005

B-1040 Brussels, Belgium

+32229-94228

e-mail: [email protected]

DISCLAIMER

"The views expressed are purely those of the writer and may not in any circumstances be regarded as stating an official position of the European Commission."

Dear Madina,

Many thanks for your message and for checking this with us.  

We consider the issue as settled.

We will proceed with the publication of the notice of the receipt of the exemption request in the Official Journal of the European Union. We will inform you when it is done.

Kind regards,

Christos Chrysostomou

Dear Christos Chrysostomou

AS Eesti Post submitted Annex I (attached) to the European Commission on 1 April. Is it required for the Ministry of Finance to submit the document under its own name as well, or may this issue be regarded as settled?

Best regard

Dear Mr Kajak,

Further to our email of 20 March 2025, we would like to remind you that your authorities have not shared yet Annex I with us in order to consider the file as complete.

We look forward to receiving your reply.

Kind regards,

Christos Chrysostomou

Dear Mr Kajak,

Thank you for your message.

We confirm good receipt of the Letter of the Ministry of Finance as well as of the Exemption Request (94 pages).

We note that the exemption request makes reference, in different occasions, to a market report prepared by Effigy Consulting in November 2021 (under Annex I). See for instance point 330 of the exemption request. However, it seems that your authorities have not shared Annex I with us. 

Could you please share the Annex I with us in order to consider the file as complete?

Following the receipt of the document, we will proceed with the publication of the notice of the receipt of the exemption request in the Official Journal of the European Union.

Kind regards,

Christos Chrysostomou

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