Positionspapier Position Paper on the New Deal for Consumers Proposal
The European Commission published its proposals for the “New Deal for Consumers” on 11th April 2018. Bitkom welcomes harmonisation and unification of enforcement of consumer law in the EU. However, we would also like to voice some concerns regarding the provisions of the proposal, especially to ensure proportionality and coherence with other regulatory instruments. In summary, our main concerns regard the definition of qualified entities that are entitled to bring collective actions and redress claims, the missing harmonization regarding a requirement for a consumers mandate to bring a collective action and a danger of third party funding for a commercial interests of such party.