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Bundesverband der Deutschen Spirituosen-Industrie und -Importeure e. V.

BSI

Der BSI ist die Interessenvertretung der in Deutschland ansässigen Spirituosenhersteller und Spirituosenimporteure.

Lobbying Activity

Response to Digital Fairness Act

24 Oct 2025

Existing EU regulations - including the UCPD, DSA, GDPR, DMA, and AI Act - already provide broad and effective protection against unfair commercial practices, manipulative interface designs (dark patterns), personalized advertising, influencer marketing, and pricing transparency. The BSI urges the European Commission to focus on robust enforcement and harmonized guidance of current laws, which would build consumer trust and avoid unnecessary regulatory overlap, costs, and market fragmentation. We highlight that dark patterns (misleading design features) are comprehensively covered by the UCPDs technology-neutral framework. Enforcement by courts and authorities proves the sufficiency of current regulation. We recommend targeted guidance and improved consumer and business awareness over new legislation, which risks overregulation and increased compliance costs. Personalized advertising, essential for digital service funding and innovation, is subject to stringent data and privacy regulations. Additional opt-in/opt-out requirements, blanket restrictions, or vague bans risk undermining the availability of free, ad-financed digital content and would harm SMEs competitiveness. The BSI stresses that most consumers value relevant, controlled advertising, and SMEs rely on it for reaching their audiences. Overregulation would weaken market diversity and innovation. We also argue that vulnerable groups (including minors) are already protected within the GDPR and DSA frameworks. Further blanket bans or extensions to categories like emotional vulnerability are seen as disproportionate, impractical, and legally uncertain. Instead, we recommend strengthening enforcement and digital literacy initiatives. On influencer marketing, the BSI notes that transparency and fairness rules already exist and are enforced through national guidance and self-regulatory programs. Additional rigid EU rules would reduce flexibility and risk stifling a dynamic, creator-driven market. The statement points out that misleading pricing practices (drip pricing, unclear discounts) are regulated by the UCPD and the Price Indication Directive. New EU-level rules would add no substantive benefit and could fragment a harmonized regime. Regarding digital contracts (subscriptions, media), BSI finds that current EU consumer laws secure high protection and choice, making further intervention unnecessary and risking media diversity by destabilizing existing funding models. The BSI cautions against simplification measures that could reopen harmonized frameworks or introduce blanket age verification, burden of proof reversals, or lowering the standard for the average consumer. Such changes would impose unreasonable compliance obligations, especially on SMEs, and risk arbitrary enforcement. The priority should be enhancing practical consumer information, digital skills, and enforcement, rather than redefining established legal standards.
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Meeting with Stefan Köhler (Member of the European Parliament)

8 Apr 2025 · Politischer Austausch

Meeting with Andrea Wechsler (Member of the European Parliament)

28 Feb 2025 · EU Consumer Policy

Meeting with Christine Schneider (Member of the European Parliament)

28 Jan 2025 · Alcohol