Il regolamento europeo è stato prorogato nel 2020 per altri quattro anni: alla luce degli effetti generati dalla pandemia però, appare come una norma inadeguata e da rivedere.
La Consortia Block Exemption Regulations (CBER) – che permette forme di cooperazione tra consorzi marittimi – è stata recentemente rinnovata per altri quattro anni, con la scadenza ora fissata al 25 aprile 2024. Ecco cosa prevede la regolamentazione europea, il perché sia necessario quantomeno rivederla e cosa prevedono le norme dell’Antitrust UE.
L’ANTITRUST E LA DG CONCORRENZA
L’Antitrust è il complesso di norme che l’autorità pubblica pone a tutela della concorrenza, il cui fine è quello di regolamentare e limitare la concentrazione del potere economico nelle mani di una o più aziende, con l’obiettivo generale della salvaguardia dei principi fondamentali del libero mercato.
La politica di concorrenza all’interno dell’Unione Europea è regolamentata dalla Commissione che, insieme alle autorità garanti della concorrenza degli Stati membri, applica direttamente le regole di concorrenza dell’UE ( articoli 101-109 ) garantendo condizioni di parità tra tutte le imprese e contribuendo così ad un miglior funzionamento dei mercati.
L’articolo 101, ad esempio, vieta gli “accordi tra imprese che possono pregiudicare il commercio degli Stati membri”; l’articolo 102 invece proibisce – in quanto incompatibile con il mercato interno – “qualsiasi abuso da parte di una o più imprese di una posizione dominante nel mercato”; l’articolo 105 stabilisce invece la responsabilità della Commissione ad assicurare “l’applicazione dei principi di cui agli articoli 101 e 102. Su richiesta di uno Stato membro o di propria iniziativa e in cooperazione con le autorità competenti degli Stati membri, che prestano la loro assistenza, la Commissione indaga sui casi di sospetta violazione di tali principi”.
Questi articoli delimitano dunque le norme dell’antitrust dell’UE, in maniera tale da garantire un mercato equo e senza soprusi.
All’interno della Commissione, è tuttavia la Direzione Generale della Concorrenza ad occuparsi della diretta applicazione di tali principi in particolar modo dell’articolo 105. Tuttavia l’esercizio dei suoi poteri è rigorosamente limitato:
Essa può intervenire solo se ha prove di un’infrazione alle regole di concorrenza e le sue decisioni sono suscettibili di ricorso alla Corte di giustizia dell’UE.
Alla luce di tali elementi si comprende come la concorrenza d’impresa all’interno dell’Unione Europea sia soggetta a regole di Antitrust, e di come esista una direzione ad occuparsi della loro corretta attuazione seppur con un potere d’azione incredibilmente limitato. Perché allora si è vista necessaria l’adozione della CBER (Consortia Block Exemption Regulations) nel 2009, e la sua successiva proroga fino al 2024?
CBER: COSA PREVEDE E IL RISCHIO SOTTOVALUTATO
La Consortia Block Exemption Regulations era stata applicata dall’UE nel 2009 e successivamente prolungata al 2014, con il termine di fine ultimo previsto per il 25 aprile 2020. Un mese prima del termine però – a marzo 2020 in piena pandemia – la Commissione Europea ha deciso di prorogare di altri quattro anni il regolamento. La normativa prevede la possibilità, sotto determinate condizioni, per i consorzi marittimi di linea di fornire servizi congiunti senza violare le norme antitrust dell’UE che vieta accordi anticoncorrenziali tra imprese. Più specificatamente, la norma offre la possibilità alle compagnie di navigazione di gestire i servizi di trasporto di linea congiunti e di impegnarsi in alcuni tipi di cooperazione operativa che portino a economie di scala e a un migliore utilizzo dello spazio sulle navi. Dato che il diritto europeo sulla concorrenza vieta gli accordi tra società, la normativa può essere applicata solo a determinate condizioni: il regolamento infatti coinvolge gli operatori marittimi di linea con una quota di mercato combinata inferiore al 30% per stipulare accordi di cooperazione per fornire navi comuni servizi di spedizione. Questi accordi, tuttavia, non possono includere la fissazione dei prezzi o condivisione del mercato.
Nel settembre 2018, la Commissione ha avviato una consultazione pubblica con le parti interessate nella filiera del trasporto marittimo: la valutazione finale ha mostrato che, nonostante l’evoluzione del mercato – consolidamento concentrazione, cambiamento tecnologico, aumento delle dimensioni delle navi – la normativa aveva raggiunto il suo scopo, permettendo alla Commissione di “Legiferare meglio” rientrando pienamente nelle condizioni poste in essere dall’articolo 103. La valutazione ha inoltre mostrato che negli ultimi anni entrambi i costi per i vettori e i prezzi per i clienti per unità equivalente a venti piedi (TEU) sono diminuiti del circa il 30% e la qualità del servizio è rimasta stabile. Tuttavia, se gli effetti della CBER sono indubbi se si guarda agli anni passati, il contesto applicato alla pandemia appare ben differente. Pensata appunto per operatori marittimi con una quota combinata del 30% rispetto all’intera filiera, la proroga non ha tenuto conto di diversi fattori: da un lato la presenza di 3 top carrier (Maersk, MSC, Cosco) che da soli detengono il 45,3% della flotta mercantile e che sono a loro volta riorganizzati in 3 principali alleanze globali – 2M, The Alliance, Ocean Alliance – che controllano la quasi totalità del trasporto marittimo di container; dall’altro lato la proroga alla CBER – che era stata nel pre – pandemia un volano per la crescita degli scambi commerciali – non ha tenuto conto che da tempo oramai le tre alleanze e le relative compagnie hanno posto in essere strategie di integrazione verticale, acquisendo attività terminalistiche e logistiche – ferroviarie e stradali – rafforzando la posizione dominante sulla filiera.
Di conseguenza, la struttura del trasporto marittimo si configura come un vero e proprio oligopolio che permette alle compagnie di beneficiare inoltre di una tassazione media più favorevole (7%) rispetto a quella applicata ad esempio agli spedizionieri (27%).
La Consortia Block Exemption Regulations, appare allora oggi una norma da ridiscutere: allo stato attuale delle cose – con l’aumento esponenziale del prezzo dei noli marittimi, lo squilibrio tra la domanda e l’offerta, la carenza voluta di spazi container – si configura come un regolamento inutile. Il principale obbiettivo che l’aveva mantenuta – come specificato da un rapporto di Confindustria – era principalmente quello di rendere più efficiente il trasporto marittimo internazionale e favorire la globalizzazione degli scambi: ma la pandemia prima, e il desiderio di guadagno dei grandi carrier, hanno mostrato le fragilità strutturali di una normativa che ha le potenzialità per erodere progressivamente il libero mercato.
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