UNIVERSAL POSTAL UNION POC SB DCG 2004.3–Doc 4a
Postal Operations Council
DATA & CODE DEFINITION GROUP
Washington, 2 September 2004
Country codes, S31 issuer codes and S10 13 character identifiers for postal items
(Agenda item 4a)
Document by IPC
1 Subject References/Paragraphs
CAM issues relating to the use of country codes ?? 1–19
2 Decisions expected
? 20 ? decide on the approach (15-1 or 15-2 or other) to be taken in
respect of East Timor;
? determine, as a result, the need for update of S10; the
directions to be given to CTL-Correios de Timor-Leste and the
desirability of withdrawing S31 codes TP, T25 and TPA; ? decide on the action to be taken in respect of countries and
territories for which the corresponding ISO country code has
not (yet) been allocated as an S31 issuer code; ? determine how, and with what priority, the task of reviewing
other standards for inappropriate use of ‘country’ and
‘country code’ should be undertaken
1. Historically, many UPU standards made use of ISO-3166 country codes as a means of
identifying postal administrations. The tendency towards liberalisation made the use of country
codes for this purpose increasingly problematical. The result was the development of two specific
standards: S31 for the allocation of codes, used in identifiers, to indicate the source of the
identifier concerned and S35 for the general identification of parties to transactions.
2. To ‘grandfather’ previous identification standards, S31 defines both two- and three-
character codes and pre-allocated two-character codes that corresponded with the country codes
of UPU members states to the first / existing / main postal administration of the country
3. This effectively allowed continued use of country code as a means of identifying the ‘traditional’ posts in old standards, whilst opening the way for new standards, using 3-character
codes, to better support liberalisation.
4. The intent was that old standards that refer to ‘country’ should be reviewed to determine
whether they really meant country or actually meant ‘mail service contractor’. Where necessary,
the standards concerned would then be amended.
5. The task of conducting this review was taken on by Finland Post and IPC, with Finland Post agreeing to take the first step. However, this first step was never completed and the
individual responsible for it has now left Finland Post.
6. In the meantime, one of the most affected standards, S10, has been updated. S10 defines (inter-alia) a system of 13 character identifiers which end in ISO country code. This was one of
the prime cases in which country code is really a synonym for ‘issuing post’. However, for
reasons given below, in revising S10, IPC proposed and the DCG agreed to retain the use of
country code in 13 character identifiers.
7. This is leading to a number of problems as described below.
II. Why was S10 not changed; what was done instead? 8. In updating S10, it would have been possible to change the specification of 13 character identifiers such that these ended in a two-character issuer code, instead of in a country code.
This would have had little or no consequences with regard to existing use and users of these
identifiers. However, it would (at least in theory) have opened up the possibility that:
? other organisations with two-character issuer codes (currently only DHL, EuroExpress, IPC,
PNL and the UPU itself) could create and use their own 13 character item identifiers; ? other parties might be encouraged to demand the allocation of two-character issuer codes,
in order that they also would be able to issue S10 13 character item identifiers (rather than
being limited to the use of licence plates, which use 3-character issuer codes). It was
feared that this might delay migration from the use of 13 character identifiers to the use of
licence plates and might ultimately result in code allocation problems, given that there are
only 936 possible 2-character S31 issuer code values;
? the result would be that many 13 character item identifiers would end in a numeric digit
instead of an alphabetic character, whilst others would end in a two letter value that did
not correspond with a valid ISO country code. It was feared that many existing systems
would be unable to cope with this change without significant modification being required. 9. It was also noted that the use of country code does (at least in theory) provide an indication of the geographic origin of an item. This would be lost if issuer codes were used, since
an organisation licensed to operate in several countries would use the same trailing issuer code,
irrespective of the country in which the item originated.1
10. Given these fears, there was reluctance to change the 13 character item identifier specification and it was decided to retain the use of ISO country code in the last two positions.
To address the problem of liberalisation, which could result in multiple organisations in a
country claiming the right to issue 13 character item identifiers, it was proposed, and agreed,
that control over the issue of 13 character item identifiers, in a country, should devolve to the
organisation, if any, to which has been allocated the 2-character S31 issuer code that
corresponds with the ISO country code for the country concerned. The revised S10 specifies that
any other party wishing to issue 13 character item identifiers can do so only with the agreement
of, and under licence from, the ‘owner’ of the relevant S31 issuer code.
1 Actually, this could already be occurring. A European Post with an IMPC in, say, Australia, could use 13 character identifiers ending in its (home) country code, rather than AU, for items originating in Australia, even though this is not
compliant with the standard.
III. So what’s the problem?
11. The S10 changes ensure that there is a clear responsibility for 13 character item identifier allocation and avoid the possibility that two organisations could claim control over their
issuance. However, the CAM has recently been confronted with a number of situations which it
has been unable to fully resolve.
12. The ISO 3166 code for East Timor has been changed from TP to TL. This means that S10 13 character item identifiers for items originating in East Timor should change to end in TL, instead
of TP. But CTL-Correios de Timor-Leste currently has S31 codes TP, T25 and TPA. No-one
currently has S31 2-character code TL. According to a strict interpretation of S10, this means
that no-one (not even CTL-Correios de Timor-Leste) is currently permitted to issue S10 13
character item identifiers in East Timor.
13. In practice, CTL-Correios de Timor-Leste is likely to either (a) continue to issue 13 character item identifiers ending in TP [at least until told not to do so] or (b) assume that it is
permitted to issue 13 character item identifiers ending in TL and commence doing so in practice.
14. Both courses of action would be non-compliant with S10, though it is unlikely that either would lead to short term problems. Problems would arise if ever another organisation applied for,
and was granted, S31 issuer code TL. This new organisation would, under the terms of S10,
immediately acquire the right to control 13 character item identifier issuance in East Timor and
could demand that CTL-Correios de Timor-Leste either desist from using them, or use them only
15. This issue could be resolved in either of two ways:
1. modifying S10 to use 2-character S31 issuer codes instead of country codes; 2. allocating S31 codes TL and T21 (but not necessarily TLA) to CTL-Correios de Timor-Leste. 16. (1) would provide a permanent resolution of the type of issue presented by East Timor, but carries the risks and disadvantages referred to in II (Paragraphs 8 to 10) above. To avoid these, it
might be necessary to temporarily limit 13 character item identifier issuance to the owners of
specific code values (and to indicate this right in the S31 code list), so that the possible problems
associated with the use of codes not in the ISO country code list, or with use of codes ending in
numeric digits, could be evaluated before general issuance rights were granted.
17. (2) would resolve the situation for East Timor, but at the cost of creating a precedent for other cases and without really resolving the general issue.
18. A similar situation previously arose in respect of Serbia and Montenegro (resolved by allocation of codes CS and C28 to Public Enterprise of PTT "Serbia").
19. Problems could also potentially arise in respect of other states in the ISO-3166 country code list for which the S31 Issuer code has not (yet) been allocated.2 The codes corresponding to
these countries and territories have not been allocated on the grounds that they either did not
exist, or the state concerned were not members of the UPU, at the time of creation of S31
revision 3. Currently, any use of 13 character item identifiers ending in these codes would be
non-compliant with standard S10.
2 For example: Åland Islands (AX); Andorra (AD); Anguilla (AI) (under consideration with CAM); Aruba (AW);
Christmas Island (CX); Cocos (Keeling) Islands (CC); Cook Islands (CK); (FK); Faroe Islands (FO); French
Guiana (GF); French Polynesia (PF); Gibraltar (GI); Greenland (GL); Guadeloupe (GP); Liechtenstein (LI);
Martinique (MQ); Mayotte (YT); Micronesia, Federated States of (FM); Montserrat (MS); New Caledonia (NC);
Niue (NU); Norfolk Island (NF); Pitcairn (PN); Puerto Rico (PR); Reunion (RE); Saint Helena (SH); Saint Pierre
and Miquelon (PM); Tokelau (TK); Turks and Caicos Islands (TC); Virgin Islands, British (VG); Virgin Islands,
U.S. (VI); Wallis and Futuna (WF).
IV. Decisions expected of the DCG
20. The DCG is requested to:
? decide on the approach (15-1 or 15-2 or other) to be taken in respect of East Timor;
? in case 15-1 is chosen:
? allocate the task of drafting updates to S10, determining when and how these should
be submitted to the Standards Board;
? determine the need for temporary measures to avoid issuance of 13 character item
identifiers ending in values that might not be supported by operational systems; ? in case 15-2 is chosen:
? decide whether and when CTL-Correios de Timor-Leste should be requested /
required to use TL, rather than TP, in 13 character item identifiers;
? decide whether and when code S31 code values TP, T25 and TPA should be
? decide what if any action is necessary in respect of the countries and territories listed
? determine how, and with what priority, the task of reviewing other standards for
inappropriate use of ‘country’ and ‘country code’ should be undertaken.