GSMA和Connect Europe对《数字公平法案》影响评估证据呼吁的回应

Digital Fairness Act Response toCall for Evidence for an Impact Assessment Introduction As well-established providers of connectivity solutions in Europe,Connect Europe and the GSMAagree with the European Commission(EC)that consumersplaya key roleincontributing to themarket economy as co-drivers for a competitive single market along with providers ofconnectivity services. We also support the Commission’spushfor a Digital Single Marketthroughsimplified and harmonised rulesfor businessesto eliminatefragmentation. Europe can boast of its strong consumer protection rules which are world-class. This does notmean that the current framework cannot be improved, because in order to sustain this position,the applicable consumer protection frameworks also need to evolve.WeurgetheECto be boldinreviewingcurrent rules,whileat the same timeexercisingrestraintinproposing a plethora ofnewones.The current frameworkcould already cover a broad range of the mentioned issues, butoften lacksenforcement. If the Commissions comes to the conclusion that new rules are neededhorizontally, it should also be ensuredthat any new rules are also enforceable given the resourcesthat will eventually be neededfor every new administrative procedure. Even though our response to the Call for Evidence and the associated questionnaire on the DigitalFairness Actmainlyfocuses on topics that are close to the nature of our businesses, such assimplification and harmonisation, we also provide responses to adjacent issues, as we believetheserequire further clarification. Moreover, theDigital Fairness Act(DFA)shouldbuild up onthe 2025-2030 Consumer Agenda.Tothis end,we advocateforthe Agendatoreinforce the conditions that allow consumers to makeinformed choices, drive demand for high-quality and sustainable services, and supportinnovation.Acore ambitionoftheECshould beto drive simplification and harmonisation acrossall legislative fileswith the aim ofimproving thecompetitiveness and financial robustness of allEuropean businesses,while maintaining a fair and reasonable level of consumer protection. Simplify current rules We strongly support reducing and simplifying the information obligations under the ConsumerRights Directive(CRD).Currently, consumers receive too much information during onlinepurchases—long texts, legal language, and technical details that they rarely read or understand.This is similar to the situation with cookie banners, where the volume of notices ends up beingcounterproductive. A better approach would be to limit the information to what is necessary anduseful for consumer decisions.Today,the way information is presented to consumers, especiallyin areas like billing, can often be overly complex and difficult to navigate. This is often a result offragmented and overlapping regulatory requirements. Addressing this challenge through greaterregulatory harmonisation would help simplify communication,enhance consumerunderstanding, and support more informed decision-making. Need for harmonisation The EU aims for a Digital Single Market, but the reality is that EU consumer protection legislationprovides ampleroom for Member States to divert, introduce additional/gold-platingmeasures.European businesses need conditions that enables them to operate seamlessly across bordersand the core ambition for theECshould be to drive simplification and harmonisation across alllegislative files, including the DFA, to facilitate an increased competitiveness and financialrobustness of all European businesseswhile maintaining a fair and reasonable level of consumerprotection already regarded as being best in class. From sector-specific to horizontal rules Even though not directly covered bythe DFA,it is also worth looking into any sector-specific rulesthat comes on top of the alreadyextensive legal framework on consumer protection.Forexample,telecommunications operators have to comply with horizontal consumer rules,inaddition tosector-specificconsumer rules.This, however, leads to unnecessary duplication andincreases the burden for companies without adding any additional benefit for consumers. Mostof the sector-specific rules, such as the EECC,should therefore be removed.More specifically,thoserules lead to detailed management throughout the entire lifecycle of service provision: fromthe initial interaction with consumers, going to the provision of the service, to the end of thecontract. Each step is currently regulated.Ifthere is a gap between the sector specific consumerprotection rulesand horizontal consumer law, the horizontal consumer law will applyin addition. To reduce thisdisproportional burden, we support the application ofhorizontal consumer rulesin contractual matters. In this vein, increasing obligations does not necessarily result in betterregulation. Thus, simplified regulations for European telecommunications operators, combinedwith strong horizontal and harmonised protections for European citizens, are particularlyimportant atthis tim