Verbraucherzentrale Bundesverband (vzbv)

Summary of the position paper: Consumers are an integral part of the telecommunications market without them, there would be little need for the connectivity sector. With this in mind, the Federation of German Consumer Organisations (vzbv) calls on the European Institutions to put end user interests at the centre of the legislative proposal.

vzbv would like to thank the European Commission for the opportunity to comment on the initiative. However, vzbv regrets the short consultation period and the absence of any further opportunity for public input on what is likely to be a farreaching legislative proposal, which aims to create a new regulatory basis for a future proof digital infrastructure in the European Union.

The unregulated use of environmental advertising claims, so-called green claims, poses problems for consumers: they cannot rely on environmental claims and labels to reliably certify environmentally friendly production. Green claims without substantiation - meaning claims without scientific foundation of the accuracy of the claims - thus prevent a change to sustainable consumption patterns.

Private enforcement is an important cornerstone in the enforcement of existing rules. In order to enable civil society organisations to conduct proceedings through private enforcement, they should have access to the DPP registry.

Filed in German · English published by the European Commission

(1) Dark patterns and manipulation of consumers: Risk of circumvention of DMA obligations: The proposal does not refer to the gatekeepers’ use of so-called “dark patterns”. Dark patterns surreptitiously influence consumers’ behaviour by manipulative interface de-signs that exploit consumers’ behavioural biases .

EX ANTE REGULATORY INSTRUMENT FOR LARGE ONLINE PLATFORMS Feedback of the Federation of German Consumer Organisations (vzbv) on the Digital Services Act package “Ex ante regulatory instrument for large online platforms with significant network effects acting as gate -keepers in the European Union’s internal market” June 29, 2020 Impressum Verbraucherzentrale Bundesverband e.V.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The comments on the support period convincingly implement the legal requirements from the consumer’s point of view. The chapter sets out precisely how to ensure the protection of users throughout the product life cycle and, in our view, does not require adaptations.

Filed in German · English published by the European Commission

The CO2 fleet limit legislation has been a success, as it has helped to limit CO2 emissions from passenger car traffic and promote the ramp-up of e-mobility. However, this journey is not yet over, and it is imperative that we adhere to the existing CO2 limits.

Consumer confidence in digitalisation and thus in the openness to use new innovative technologies and services is essential for the wider and desired digital transformation of society. The European Commission’s Digital Fitness Check offers the opportunity to close identified protection gaps in European digital legislation that are relevant to consumers, with the aim of further enhancing consumer trust and thus…

Filed in German · English published by the European Commission

Today, in addition to traditional media services, video-sharing platforms, influencers and, increasingly, AI-generated content are shaping the media landscape. These developments not only change the way media is used, but also pose new challenges to the existing legal framework: unclear rules, lack of transparency and manipulative advertising practices create real risks for consumers in their daily lives.

Filed in German · English published by the European Commission

Ladies and gentlemen, the Verbraucherzentrale Bundesverband e.V., welcomes the fact that the European Commission has put forward a proposal for a regulation to improve the enforcement of passengers’ rights and offers an opportunity to comment on it in the context of a public consultation. The detailed assessment of the proposal for a Regulation can be found in the attached document. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

Ladies and gentlemen, the Verbraucherzentrale Bundesverband e.V., welcomes the fact that the European Commission has put forward a proposal for a regulation to improve the rights of multimodal travellers and offers an opportunity to comment on it through a public consultation. The detailed assessment of the proposal for a Regulation can be found in the attached document. Yours sincerely, [name removed]

Filed in German · English published by the European Commission

1. Ensure consumer protection: The harmonisation of the various EU rules on passenger rights and obligations is welcome in principle. A patchwork of different rules, sometimes contradictory, does not create confidence among travellers and makes travel more complicated.

Filed in German · English published by the European Commission

If the EU wishes to deepen the single market and strengthen Europes competitiveness, it must also strengthen the economic capacity of private households to act. For consumers are not merely objects of legal protection, but sustain the European economy on a daily basis through their consumption, contractual, mobility and financial decisions.

The Federation of German Consumer Organizations (vzbv) considers the lack of availability of through tickets to be a major problem for travelers. The obligation to offer through tickets is necessary for both international travel and domestic long-distance travel. A detailed statement can be found in the attached PDF.

The Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband - vzbv) welcomes the European Commissions initiative to make it easier to purchase tickets for rail travel and multimodal journeys.

The Verbraucherzentrale Bundesverband (vzbv) is critical of the European Commission’s proposal to amend Article 30(5) GDPR. In the view of the Vzbv, documentation of processing activities is far more than a bureaucratic obligation: It is a key component of effective data protection and lived accountability. It allows companies to identify and minimise risks in a contextual and dynamic manner.

Filed in German · English published by the European Commission

vzbv is disappointed that the Commission has not shown the necessary will in this proposal to really effectively promote ADR as a solution to consumer disputes. The proposal misses the opportunity to create a basis for fundamental change and falls short of the needs of consumers.