CCPC observations on the European Commission’s Fitness Check of EU consumer law on digital fairness
Submission of the CCPC in response to the European Commission Directorate General for Justice and Consumers’ public consultation on the European Commission’s Fitness Check of EU consumer law on digital fairness.
The Fitness Check (evaluation) aim is to look at the following pieces of EU consumer protection legislation to determine whether they ensure a high level of protection in the digital environment:
- The Unfair Commercial Practices Directive 2005/29/EC
- The Consumer Rights Directive 2011/83/EU
- The Unfair Contract Terms Directive 93/13/EEC
The Fitness Check will examine the adequacy of the existing EU rules in dealing with consumer protection issues such as, but not limited to, consumer vulnerabilities, dark patterns, personalisation practices, influencer marketing, contract cancellations, subscription service contracts, marketing of virtual items (e.g. in video games) and the addictive use of digital products. It will assess whether the existing legal framework would benefit from a targeted strengthening or streamlining, while taking into account and ensuring coherence with recently adopted and forthcoming EU legislation. It will also examine the scope for any burden reduction, cost savings and simplification.
In relation to the public consultation, the CCPC engaged on specific areas of priority and experience such as subscription service contracts, understanding of consumer vulnerability online, subscription traps, cancellation of contracts, influencer marketing and dark patterns.
Attachments
2023.02.20 IE CCPC Submission on Digital Fairness Fitness CheckReturn to Submissions
