− The increased integration of consumer policy into other policies: Concrete measures are proposed: consumer liaison officers will be appointed in a number of DGs. We add that each DG should publish each year a report on how consumer policy was integrated into its area.
− A better monitoring of markets: The Strategy proposes to look at the core elements of “safety, satisfaction, price and complaints”. In our opinion, measures of subjective consumer satisfaction are not enough. Consumers can be satisfied with a less than optimal choice simply because they did not know or understand that a better choice was available.
− Work on collective redress: The Strategy foresees that the Commission will consider taking an initiative in this area. We certainly want to see action here. Many consumer problems cannot be resolved only by consumers acting alone – collective action is often necessary too. Arguments for and against US- style class actions are often irrelevant here – we want collective actions that work in European conditions.
− Better regulation for consumer protection: Consumer must have clear legal rights in the digital environment. More and more, our information, education, culture, and entertainment are coming to us in digital form, governed by licenses and not by conventional contracts for the sale of goods or supply of services.
− More generally, the harmonisation of consumer laws must not weaken existing rights or make it more difficult to adapt to changes and new challenges in the market.
− Strengthening of independent consumer organisations: The Strategy promotes training for consumer organisations. We suggest even more attention, as training in itself will not deal with the resource problems faced by many consumer organisations, especially in the new member states.
Jim Murray, BEUC Director, said: “The Strategy is promising in both senses of the word – it gives good reason for hope but hopes must be turned into reality.”
