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Brussels, 23 november 2001
Euro Coop's Comments to the European Commission's Discussion Document: "Ideas for a Consumer Policy Strategy"
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 4 Central and Eastern European countries. Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.
Euro Coop welcomes the European Commission's Discussion Document: "Ideas for a Consumer Policy Strategy", and strongly supports the European Commission's conclusion that the future framework for a consumer policy needs to take a more strategic approach.
In relation to the areas outlined in the document, Euro Coop has the following comments to make:
1. Creating a real Internal Market for Consumers
It is very important to try to define how this should be done. There has been a development towards a very detailed regulation or standardisation. When it comes to environment issues they are not necessarily in favour of these trends. One example is on organic production where very detailed rules throughout the EU will risk hindering the development of sustainable practices suitable for different climates and countries. Standardisation is tending to: 1) take very long time to develop and 2) to define environmental issues in a very narrow way. The latter is also tending to favour the things as it is today and to put very high scientific requirements on the supposed more environmentally adopted measurements proposed. This is very obvious in terms of i.e. green claims. The aim of the regulation of these was to defeat false claims, but in fact it will also nearly stop the possibility to use environmental claims in marketing. This is not in favour of neither consumers nor a sustainable development.
Euro Coop underlines the importance to develop consumer confidence in cross-border transactions. For instance, there is ongoing work on a code of conduct for electronic commerce for consumer co-operatives adopted by the CCI (Consumer Co-operative International) Executive and supported by Euro Coop.
2. Integration
Euro Coop agrees that consumer interests have to be integrated in all policy areas within the EU. It could be wise to commission all the EU ministers' councils to define how this should be done within their respective area. This has already been done for environmental issues and that could serve as a good example. This is almost proposed under objective 1 in the discussion paper, but there should be a general survey where it is possible for the different directorates to define the consumer policy priorities.
3. Consumer Protection
Euro Coop finds it extremely important that work continues at EU level to protect the consumers against the risk of presence of antibiotics and hormones in food as well as the risk for pesticide residues in food.
Furthermore, we would like there to be a strict control regarding the use and labelling of GMOs so consumers who so wish have the possibility to choose GMO free products. Euro Coop would also like to see that work is done to reduce the amount of authorised foodstuffs in food, in particular, that work is done to regulate and declare flavours.
Euro Coop finds it worrying if a harmonisation of market legislation is done only based on the two general clauses concerning good practices of trade and misleading marketing without any additional special prohibitions against reduction vouchers, compulsory purchase competition etc.
4. Consumer Perspective instead of Consumer Protection
It is also very important to develop a broader definition of consumer interests in which consumer protection is only one part. Probably, the five principles for good governance practices could serve as a starting point.
In line with this, Euro Coop suggests that the expression to be used in the three outlined objectives should be consumer perspective instead of consumer protection. It would seem that this would be especially useful in the agricultural field. Euro Coop is of the opinion that the Common Agricultural Policy (CAP) should be consumer in stead of producer oriented.
Euro Coop agrees that it would be interesting to have a kind of standardised reporting on consumer complaints showing complaints not only on business, but also on education, public services and administration, and political bodies (national and EU level) etc. It will of course also be of crucial interest to measure the consumer confidence and/or satisfaction as well.
Euro Coop underlines the importance of consumer information and education. It is of great importance to develop the use of electronic information systems. We will especially point out that it is, at least theoretically, possible to show every consumer their contribution to the road to a sustainable society on the receipt at every purchase they make.
5. Implementation of Consumer Protection Regulations
In a world with a growing amount of information, Euro Coop believes that it is important that the single consumer is well informed and educated. At the same time, we think that it is vital that professionals dealing with development, production and sale of consumer goods should be knowledgeable about the consequences of their decisions. Therefore Euro Coop urges the European Commission to work for the strengthening of consumer knowledge as an obligatory part of primary and secondary school education. We would also recommend the Commission to work for that topics concerning consumer protection and consumer protection legislation, such as, health related, environmental and ethical ones, become obligatory in higher technical and commercial education.
6. Consumer Representation
Euro Coop also agrees upon the importance to involve consumer representatives in all activities in the EU. We will especially underline that it has to be considered that there are different consumer organisations covering different fields of interest, if a true balance between producer, business and consumer representatives has to be achieved. We also want to stress that consumer co-operatives have a unique position as being owned by the members and engaged in retail business of different consumer goods and services. Therefore, consumer co-operatives have a broad population based membership group and consequently a broad knowledge about consumers' problems. At the same time, consumer co-operatives possess many years of experience in combining ideological policies with entrepreneurship.
Euro Coop would therefore like to underline the importance of consumer co-operatives as representatives for consumers both nationally and at EU level. For that reason, we believe that consumer co-operatives should be included as co-operators and in hearings as far as possible in connection with the formulation of EU's consumer policy.
Contact: Louise Ousted Olsen, Acting Secretary General
Tel.: 02.285.00.76 - Fax: 02.231.07.57 - e-mail : Lousted_Olsen@eurocoop.org
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