Will Rigid Stacked Order Pricing Under Delivery-Specific Law Trigger a Four-Way Lose? Experts Urge Return to Market Flexibility

Since the official implementation of the delivery-specific law, public attention has largely focused on minimum compensation guarantees for delivery workers. However, as operational details of the new system emerge, the law's rigid requirements regarding 'stacked order pricing' are increasingly revealing troubling policy side effects. Feng Chang-Kuo, co-managing partner at Chung & Partners Law Firm and supervisor at DEAT Taiwan Digital Platform Economy Association, recently submitted an op-ed to Storm Media, warning that the current law imposes overly inflexible billing standards for stacked orders, creating a highly skewed 'duplicate salary payment' problem. If the government does not promptly re-evaluate these rules, he cautioned, it could trigger a collapse resulting in a four-way lose scenario affecting platforms, delivery riders, merchants, and consumers.

Feng conducted calculations based on existing regulations: if a delivery rider accepts three consecutive route-efficient orders delivered at 20, 25, and 30 minutes respectively, their legally mandated minimum compensation would be approximately NT$82, NT$102.5, and NT$123—exceeding NT$300 in just half an hour. This compensation structure, far surpassing typical基层 workers’ earnings, stems from a fundamental disregard for core logistics optimization principles. He emphasized that 'concurrent orders' do not occur spontaneously; they are the result of sophisticated technology developed through hundreds of millions of dollars invested annually by platforms to build real-time traffic big data models and millisecond-level algorithms that precisely calculate route overlap between orders. This 'efficiency dividend' is essentially a form of technology rent. Mandating full freight payment for concurrent orders—and even duplicating compensation for already-paid travel time and distance—effectively erases the value of technological innovation and deprives other market participants of their right to share in these benefits.

From an economic perspective, the core labor cost for delivery riders lies in physical movement, which concurrent orders significantly reduce. Moreover, when stacked orders lead to delays, cold meals, or refund risks, the financial and customer satisfaction burdens fall almost entirely on platforms, merchants, and consumers. Feng analyzed that if platforms cancel stacked orders to avoid duplicate payments and instead dispatch three separate riders for each order, it would lengthen matching wait times, drastically increase per-order shipping fees, eliminate previously offered free delivery and trip bonuses, and generate unnecessary carbon emissions and traffic congestion.

International experience has already shown that when laws forcibly distort market mechanisms, platforms are forced to reduce stacked orders or pass costs onto users. Ultimately, this leads to a sharp decline in riders’ hourly order volume, causing total hourly wages to stagnate or even decrease. Consumers abandon orders due to high costs, damaging the survival of merchants reliant on delivery services. In his op-ed, Feng urges that, given the law already ensures no order pays below NT$45 and guarantees an hourly wage at least 1.25 times the minimum wage, the government must strike a balance between protecting delivery workers’ rights and respecting market mechanisms. It should moderately relax pricing flexibility for stacked orders, or else risk exhausting the once-thriving delivery market under rigid legal provisions.