Consumer Choice Center Europe
CCC Europe
CCC Europe is a non-partisan, independent consumer advocacy organization founded in 2024.
ID: 634783053106-61
Lobbying Activity
Response to Digital Fairness Act
13 Oct 2025
On behalf of the Consumer Choice Center Europe, we thank you for the opportunity to provide feedback on the Digital Fairness Act. As a consumer organisation advocating for evidence-based policy, we submit the following condensed remarks (please see our PDF enclosed). 1) BUILD ON EXISTING LAW, PRIORITIZE ENFORCEMENT. EU consumers are already among the most protected in the world online and offline. Existing instruments (such as the UCPD, GDPR, ePrivacy, DSA, DMA, AVMSD, CRD and others), already target deception, manipulation, and misuse of personal data. Proper, consistent enforcement and clearer guidance would address most concerns without adding another overlapping layer that increases complexity for consumers, businesses, and public administrations. 2) TACKLE FRAGMENTATION FIRST, PURSUE TARGETED FIXES. The Commission itself points to legal uncertainty, gaps, weak enforcement, and Member-State fragmentation. These should be addressed before creating new legislation. As with the GDPR (targeted improvements without full reopening), the DFAs goals should be pursued via harmonised application and precise amendments rather than a broad new act. 3) UPHOLD BETTER REGULATION PRINCIPLES. The EUs Better Regulation principles (including proportionality and one-in, one-out) argue for streamlining, not stacking rules. A DFA that does not repeal or rationalize overlaps would contradict these commitments and raise unnecessary costs. 4) ASSESS NEGATIVE ECONOMIC AND CONSUMER IMPACT (WITH NUMBERS). The call for evidence cites at least 7.9 billion/year in consumer harm from online problems. The future impact assessment should also quantify the value of personalization and model downside scenarios of stricter rules on ads, social-media design, etc. Surveys showing concern about data use should be balanced with evidence that 7 in 10 Europeans prefer relevant ads, and with SME perspectives that are often missing. 5) POTENTIAL NEGATIVE EFFECTS: a) SMEs & small markets. E-commerce was a lifeline during COVID-19, and personalized ads remain a pragmatic, affordable way to reach customers and compete with larger rivals. If personalization is effectively curtailed, costs will rise and reach will fall. b) SMEs: At least 75% of SMEs say they would struggle to find customers without personalized advertising. c) Pass-through costs. Vague concepts (e.g., harmful practices, addictive designs) would raise compliance burdens likely passed to consumers. d) Macroeconomic effect: Personalised advertising drives at least 100 billion in additional EU sales, contributes 25 billion to GDP, and supports about 600,000 European jobs. 6) TRANSATLANTIC CONSIDERATIONS. The EU-US Framework for an Agreement on Reciprocal, Fair and Balanced Trade commits both parties to reduce non-tariff barriers and address unjustified digital trade barriers. A DFA that materially affects US-based providers could strain relations; focusing first on enforcement of existing EU rules would mitigate this risk. 7) CONSULTATION DESIGN. Because consultation results feed into the impact assessment, methodology must be neutral. The current framing appears to steer toward more regulation: no action choices lack space to explain reasoning; key terms (dark patterns, addictive design) are undefined; closed option sets prime intervention. Biased instruments distort evidence and under-represent Europes diversity of views. We recommend an additional, short, methodologically balanced consultation to ensure a credible evidence base.
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