Brussels, 23 March 2005

1. General Comments on a future EU Consumer Strategy

Firstly, EURO COOP welcomes the proposal of the Commission to develop simultaneously a new Strategy and Legal Base. This move should ensure greater consistency between policy-making and resources.

As part of the work of developing a new Strategy and Legal Base, EURO COOP believes that the Commission should fully analyse the effects of the previous Strategy and Legal Base, including seeking the views of consumer organisations.

EURO COOP also believes that if the new Strategy and Legal Base are to respond to the needs of all consumers, then the views of the widest possible range of consumer organisations should be sought.

EURO COOP sets-out below four overriding themes for the future Strategy and Legal Base.

1.1 Empowerment

The new Strategy should set improvement of consumer confidence as a top priority. Confident consumers are empowered consumers. Empowered consumers will be prepared to take advantage of the increased choice in goods and services resulting from an ever-enlarging and liberalised Internal Market. Moreover, empowered consumers will stimulate competition between suppliers of goods and services, thus helping the EU to achieve its Lisbon objective of becoming the most competitive market in the world by 2010. The objective of empowering consumers is therefore a "win-win" situation for consumers and businesses alike.

Key elements in empowering consumers include:

1.1.1 Consumer Education and Consumer Information
Both consumer education and consumer information are necessary in ever-increasingly complex and competitive markets: firstly, consumers must be educated in order to be able to analyse and understand information received from competing suppliers; secondly, consumers must have easy access to objective, honest, and scientifically-sound information (e.g., labels) in order to then help them make informed, appropriate choices.

1.1.2 Enforcement
There is general agreement that the consumer policy acquis is already well-developed, and that resources should now be deployed to ensure enforcement of existing measures, rather than seeking to create new legislation. Many new and important measures have been developed under the previous strategy1; EURO COOP therefore agrees that in the context of an EU of 25 Member States, the new Consumer Strategy should focus on consolidating measures already adopted under the previous Strategy and ensuring they are properly implemented - and be seen to be implemented.

1.1.3 Redress
EURO COOP believes that the third element in empowering consumers is reassuring them that in cases of dispute with businesses, they can have access to quick, easy and inexpensive redress procedures. While fully supporting the normal legal redress process, EURO COOP finds that ADR (Alternative Dispute Resolution systems) are often better suited to the average consumer complaint; EURO COOP therefore believes that ADR should be further developed as a means to ensuring effective consumer redress. In addition, businesses which deliberately mislead or defraud consumers should face sufficiently dissuasive sanctions in order to discourage such behaviour. Such sanctions would have an improved deterrent effect if they were well-advertised.

1.2 Integration

EURO COOP has always called for, and consistently worked towards, the integration of the views of consumers into other EU policy areas, including enterprise, environment, food and nutrition, services, etc. EURO COOP believes that the new Strategy should ensure that the views of consumers are heard in the elaboration of all policies and legislation that affect them. Indeed, in an increasingly liberalised Internal Market, and more globalised world economy generally, there is a stronger need than ever for the views of consumers to be heard, and particularly the views of vulnerable groups of consumers.

Importantly, the new Legal Base should ensure that the proper resources are available to allow consumer organisations to represent the consumer view across all relevant policy areas.

1.3 Evidence

EURO COOP believes that future consumer policy initiatives must be evidenced-based. The EU must be able justify its consumer policy actions, and provide proper impact assessments in order to ensure that proposals are balanced, taking into account not only the views of consumers, but also other stakeholders. To this end, the new Strategy must continue to work towards the development of a knowledge base about consumers, while the Legal Base must ensure that the proper resources are available to facilitate this work. These two objectives should help ensure that resources are devoted to measures that will have the greatest positive impact on the greatest number of consumers.

1.4 Diversity

The 2004 European Consumer Assembly found that many different types of consumer organisations exist at local, regional, national and EU-level for a range of different reasons including history, politics and culture. If future EU consumer policy strategy is to respond to the needs of all consumers in an EU of 27 (or more) Member States, then the new Strategy and Legal Base must recognise this diversity and involve the widest possible range of consumer organisations in the policy-making and legislative process.

EURO COOP regrets however that one of the effects of the current Legal Base2 is to reduce this diversity of consumer organisations at EU-level by virtue of the stricter definition of "European Consumer Organisation", whereby de facto only those european consumer organisations which meet the strict criteria for financial support from DG SanCo3 are eligible to be full members of the European Consumer Consultative Group, and therefore other EU-level consumer forums. EURO COOP believes that this anomaly should be corrected in the new Strategy and Legal Base.

Indeed, EURO COOP recalls that in its Report on the current Legal Base (2004-07), the European Parliament called for the eligibility criteria for financial contributions to european consumer organisations not to preclude the participation in the ECCG organisations whose main objective is to protect the interests of consumer and uphold their rights at EU-level. The European Economic and Social Committee made a similar call in its opinion on the Legal Base.

2. Specific Priorities for a future Consumer Strategy

In the context of an increasingly liberalised Internal Market and globalised economy, there is a greater need that ever to ensure that the views of consumers are heard, and in particular those of vulnerable groups of consumers.

EURO COOP set-outs below four priority areas of action for a future EU Consumer Strategy. They correspond to the areas where EURO COOP and its member organisations actively represent the views of consumers, namely: food and nutrition policy, environment policy, consumer policy and CSR.

2.1 Measures to ensure food safety and food quality for consumers

• Food labelling, including nutrition and health claims, food fortification, nutrition labelling, GMMOs (food and feed) and GMOs4 , flavourings, processing aids, etc.
• Diet and health, including obesity
• Emerging technologies, including nanotechnology, etc.
• Food traceability
• Emerging risks such as mycotoxins, allergies, etc.
• Animal welfare

2.2 Measures to improve consumer confidence in other goods and services

• Services of general interest
• Unfair commercial practices
• Advertising
• Financial services, including overindebtedness

2.3 Measures to ensure a safe environment for consumers

• EU Thematic strategies, including pesticides, natural resources, waste, soil
• Sustainable development
• Eco-labelling
• Ecology

2.4 Measures to maximise the potential of consumers to be drivers of CSR

• Enhancing consumer awareness and understanding of CSR generally, including developing and promoting the concept of responsible "consumer-citizens"
• Improving the role of consumers in the development and implementation of CSR practices
• Education and information about consumer-related CSR "best practices", such as Fair and Ethical Trade.

Dónal WALSHE
Secretary General.

1. Consumer Policy Strategy 2002-06
2. Decision of the European Parliament and of the Council establishing a general framework for financing Community actions in support of consumer policy for the years 2004-07
3. European Commission Directorate-General Health and Consumer Protection.
4. E.g., riboflavin.