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Targeted revision of EU consumer law directives

Consumers, Employment and social affairs, Justice and fundamental rights

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Public consultation

ID: 1428

Lobbying Activity

40 responses

Consultation response

Bureau Européen des Unions de Consommateurs, 18 Jun 2018

BEUC welcomes the Commission proposal on representative actions. It is crucial to strengthen private enforcement and to give consumers a realistic chance to obtain redress in case of mass damages. This new instrument could make a real change in areas where mass consumer harm typically occurs. BEUC…

Consultation response

Bureau Européen des Unions de Consommateurs, 27 Jul 2017

BEUC, The European Consumer Organisation, would like to highlight the following (for details and other issues, see our Position attached) -RIGHT TO REMEDIES: We support an EU wide standard for individual rights and remedies of consumers, without lowering the level of protection that already…

Consultation response

Confederation of Swedish Enterprise, 14 Jun 2018

The Confederation of Swedish Enterprise ("Svenskt Näringsliv") is Sweden's largest and most influential business federation representing 49 member organizations and over 60.000 member companies with over 1.6 million employees. It represents almost all sectors of business with the exception of the…

Consultation response

Insurance Europe, 21 Jun 2018

Please find attached Insurance Europe's key messages and concerns on the proposal for representative actions.

Consultation response

Wirtschaftskammer Österreich, 13 Jun 2018

Please find attached the Statement of the Austrian Federal Economic Chamber.

Consultation response

Wirtschaftskammer Österreich, 25 Jul 2017

The Austrian Federal Economic Chamber (Wirtschaftskammer Österreich – WKÖ) would like to submit - by no means exhaustive – the following remarks:  We consider the IIA as too narrow insofar, as it does not consider the bureaucratic burdens and financial risks the CRD causes especially with…

Airlines for Europe urges exclusion from new collective redress rules

Airlines for Europe, 21 Jun 2018

A4E demands the complete exclusion of air transport from the proposed directive. They argue existing aviation regulations already provide sufficient tools for passenger compensation.
Avoiding these rules would prevent mass litigation and protect airlines from profit-driven companies.
Third-party claims firms lose the opportunity to profit from mass consumer compensation.

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 20 Jun 2018

The German Insurance Industry welcomes the possibility to give feedback to the proposal for a Directive on representative actions for the protection of the collective interests of consumers. Most member states have only recently introduced procedures to close gaps in legal protection regarding…

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 20 Jun 2018

The German insurance industry expressly welcomes the intended improvements of consumer protection under the proposed Directive. However, we do not agree with the Directive’s underlying assumption of insufficient enforcement and limited consumer redress possibilities. There is no lack of consumer…

Ryanair urges EU to exclude aviation from collective redress

Ryanair Holdings, 21 Jun 2018

Ryanair argues that aviation should be excluded from the directive because current passenger rights laws are already sufficient. They claim adding new legal paths would confuse consumers and undermine existing systems.
Exclusion prevents the financial burden of mass lawsuits and protects current individual claim processes.
Claim management companies would lose the ability to profit from organizing mass consumer legal actions.

Consultation response

Bitkom e.V., 21 Jun 2018

Bitkom would like to thank the EU Commission for the opportunity to comment on the recent Proposal of the New Deal for Consumers and would like to give feedback in detail in the attached position paper.

Consultation response

The Danish Chamber of Commerce, 12 Jul 2017

At the Confederation of Danish Enterprise we are very pleased, that the IIA take the experience and burdens that traders meet into account. This is important to strike a balance that in the end - will yield the best results for both consumers and traders. We have the following remarks: - We…

Consultation response

GSMA Europe, 20 Jun 2018

The GSMA and ETNO welcome the objective to improve law enforcement and strengthening consumer protection across the EU, irrespective of the location of size of an undertaking. This also requires Member States to provide sufficient resources, which is unfortunately not addressed in this proposal.…

Consultation response

GSMA Europe, 18 Jun 2018

The GSMA and ETNO welcome the objectives of the proposals on “A New Deal for Consumers”, which aim at updating consumer protection standards and improving enforcement. To effectively reach these, objectives several crucial adjustments are required, addressing only clearly identified problems in a…

Consultation response

AIM - European Brands Association, 21 Jun 2018

Since early 2017, our sector actively collaborated with the European Commission to address the issue of alleged “dual quality” of food products. This resulted in what was presented by the Joint Research Centre in April, namely the methodology and the testing initiative that is currently ongoing. …

Consultation response

International Air Transport Association, 20 Jun 2018

see attached file "IATA feedback on collective redress"

Consultation response

HOTREC, Hotels, Restaurants & Cafés in Europe, 20 Jun 2018

The fast evolving digitalisation of the economy and the transformation of consumption patterns make necessary some adjustments to the current EU consumer framework. This is particularly true in the tourism sector (the 3rd socio-economic activity in Europe) which is being radically transformed by…

UniCredit warns against high minimum fines for consumer law violations

UniCredit, 21 Jun 2018

UniCredit argues for deleting the 4% turnover floor for fines and establishing a clear maximum cap. They also suggest that consumers should not have a minimum right to unilaterally terminate contracts for unfair practices.
A cap would prevent the bank from facing massive fines for minor procedural errors.
EU citizens might find it harder to cancel contracts with banks using unfair terms.

UniCredit Urges Stronger Safeguards in EU Consumer Representative Actions

UniCredit, 21 Jun 2018

UniCredit requests narrowing the directive's scope to laws specifically granting consumer rights. They advocate for mandatory admissibility checks and the "loser pays" principle to deter unfounded claims. They also prefer "opt-in" systems to ensure claimants represent affected consumers.
Stricter rules would reduce the risk of speculative lawsuits and protect the bank's reputation.
Individuals and consumer groups would face higher barriers and financial risks when pursuing collective redress.

Consultation response

eu travel tech, 27 Jul 2017

ETTSA generally supports the direction taken by the European Commission as outlined in the Inception Impact Assessment of the targeted revision of EU consumer law directives. ETTSA welcomes the fact that B2B relations are not covered by the present initiative. We also welcome the removal of any…

Consultation response

European Coalition for Corporate Justice, 21 Jun 2018

ECCJ welcomes the opportunity to give feedback to this legislative proposal to advance the availability of collective redress to victims of corporate malpractice. However given the previous acknowledgment by EU institutions of the value of a horizontal collective redress for all fundamental rights…

Consultation response

Handelsverband Deutschland, 21 Jun 2018

Zum Thema Verbandsklagen: Da keine tatsächlichen Behinderungen des europäischen Binnenmarktes durch nicht vereinheitlichte nationale Rechtsdurchsetzungsregeln im Bereich des kollektiven Rechtsschutzes nachgewiesen werden kann, kann der Richtlinienentwurf auch nicht auf die Binnenmarktkompetenz…

Consultation response

Handelsverband Deutschland, 21 Jun 2018

Obwohl die Europäische Kommission zu dem Schluss kam, dass das EU-Verbraucherrecht weiterhin zweckdienlich ist, wurden nun weitreichende Änderungen vorgeschlagen, die teilweise weit in die nationale Souverä-nität eingreifen und deutliche Systembrüche verursachen. Es kann also keineswegs von…

Consultation response

Video Games Europe, 20 Jun 2018

ISFE welcomes the Commission’s initiative to achieve a more coherent interpretation, implementation and enforcement of EU Consumer Law. Our detailed feedback can be found in the attached ISFE position paper.

Consultation response

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 28 Jul 2017

Independent Retail Europe welcomes the Commission’s review of the consumer acquis. For both consumers and businesses, the rules need to be simple, understandable, straightforward and strictly proportional to the consumer protection objectives to be achieved. If businesses struggle to interpret the…

Consultation response

Ecommerce Europe, 21 Jun 2018

Ecommerce Europe overall agrees with the Commission on the fact that EU Consumer Law is generally already fit for purpose and need only some targeted adjustments. Some amendments proposed in the New Deal for Consumers are likely to foster online sales in the European Union by removing current…

Consultation response

European Federation of Investors and Financial Services Users, 7 May 2018

BETTER FINANCE welcomes and supports this proposal setting a minimum EU-wide framework for collective redress mechanisms across Member States which will be available for financial services users. Like for other sectors, there is indeed a clear need for collective redress scheme for financial…

Consultation response

Council of Bars and Law Societies of Europe, 29 May 2018

Please see our feedback in the attached paper

Consultation response

World Federation of Advertisers, 20 Jul 2017

The World Federation of Advertisers (WFA) is the voice of marketers worldwide, representing 90% of global marketing communications spend – roughly €900 billion per annum – through a unique, global network of the world’s biggest markets and biggest brand owners. WFA champions responsible marketing…

Consultation response

Seldia - The European Direct Selling Association, 15 Jun 2018

Our feedback is provided in detail in the Seldia position paper attached.

Consultation response

European Mortgage Federation - European Covered Bond Council, 24 May 2018

The EMF-ECBC is pleased to share its comments on the Commission proposal for a Directive on representative actions for the protection of collective interests of consumers. We have, in the past, expressed reservations about EU intervention in the area of consumer collective redress, and, most…

AIRE opposes including air passenger rights in collective lawsuits

Airlines International Representation in Europe, 21 Jun 2018

AIRE urges excluding air passenger rights regulation from the scope of this directive. They request clear definitions for mass harm to avoid confusing and clashing procedures.
This exclusion avoids unfounded liabilities that could lead to higher air fares.
Consumers lose a path to collective compensation for flight cancellations or delays.

Consultation response

Federation of European National Collection Associations, 21 Jun 2018

1. FENCA FENCA, the Federation of European National Collection Associations, represents the interests of European credit servicers and credit purchasers, coordinating with the institutions of the European Union, stakeholders in the European financial services industry, consumer groups and the…

Consultation response

Verein für Konsumenteninformation, 21 Jun 2018

VKI welcomes the Commission proposal on the modernisation and better enforcement of EU consumer law but several aspects need to be improved to ensure a high level of consumer protection. - Right of withdrawal: It is troubling that the Commission decided to deteriorate the best-known consumer right…

Consultation response

Verein für Konsumenteninformation, 21 Jun 2018

VKI welcomes the Commission proposal on representative actions. It is crucial to strengthen private enforcement and to give consumers a realistic chance to obtain redress in case of mass damages (see also https://vki.at/pk-gruppenklage-ak-vki) This new instrument could make a real change in areas…

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 21 Jun 2018

DECO welcomes the Commission proposal on the modernisation and better enforcement of EU consumer law but several aspects need to be improved to ensure a high level of consumer protection. - Right of withdrawal: It is troubling that the Commission decided to deteriorate the best-known consumer…

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 21 Jun 2018

DECO welcomes the Commission proposal on representative actions. It is crucial to strengthen private enforcement and to give consumers a realistic chance to obtain redress in case of mass damages. This new instrument could make a real change in areas where mass consumer harm typically occurs.DECO…

Consultation response

National Energy Ombudsmen Network, 20 Jun 2018

NEON, the European network of independent, not-for-profit consumer dispute-resolution services and ombudsmen active in the energy sector, welcomes the opportunity to comment on the Commission proposal to amend the consumer protection directives under the New Deal for Consumers. As entities in…

Consultation response

Federation of European Movers Associations, 18 Jul 2017

FEDEMAC is pleased that the EC is looking at revising EU consumer law especially in regards to online-platforms. Those have changed greatly the way business is done, facilitating business between consumers and businesses. However, they have also created much unfair practices between businesses and…

Consultation response

National Energy Ombudsmen Network, 3 Jul 2017

A Targeted revision of EU consumer law directives is very timely and should go beyond the scope of the previous directives. Unfortunately, what is clearly missing here is a straight reference to out-of-court dispute resolution mechanisms, in particular with an ADR entity (2013 directive) or with…