EUROPEAN COMMISSION Brussels, 7.11.2019 SWD(2019) 382 final COMMISSION STAFF WORKING DOCUMENT Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the mid-term evaluation of the Consumer Programme 2014-2020

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Table of contents 1.Introduction 1.1.Purpose of the evaluation 1.2.Scope of the evaluation 2.Background to the intervention 2.1.Policy context 2.2.Description of the intervention and its objectives 2.3.Baseline and points of comparison 3.Implementation / state of Play 3.1.Programme management 3.2.Status of implementation 4.Methodology 4.1.Short description of methodology 4.2.Limitations and robustness of findings 5. Analysis and answers to the evaluation questions 5.1Effectiveness 5.2 Efficiency 5.3Relevance

5.4Coherence 5.5EU added value, complementarity, sustainability 5.6Simplification and burden reduction 6.Conclusions Glossary Term or acronym Meaning or definition ADR Alternative Dispute Resolution BEUC Bureau Européen des Unions de Consommateurs CHAFEA Consumers, Health, Agriculture and Food Executive Agency CPC Consumer Protection Cooperation DG COMP Directorate-General Competition DG DIGIT Directorate-General Informatics DG ESTAT Directorate-General Eurostat - European statistics DG FISMA Directorate-General Financial Stability, Financial Services and Capital Markets Union DG GROW Directorate-General Internal Market, Industry, Entrepreneurship and SMEs DG JRC Directorate-General Joint Research Centre DG JUST Directorate-General Justice and Consumers DG SANTE Directorate-General Health and Food Safety DG TAXUD Directorate-General Taxation and Customs Union ECCG European Consumer Consultative Group EEA European Economic Area EFTA European Free Trade Association GDP Gross Domestic Product MFF Multiannual Financial Framework ODR Online Dispute Resolution NGOs Non-governmental organizations RAPEX Rapid Alert System for dangerous non-food products REFIT The Commission's Regulatory Fitness and Performance programme SMEs Small and medium-sized enterprises TFEU Treaty on the Functioning of the European Union 1.Introduction

1.1.Purpose of the evaluation The present evaluation covers the mid-term evaluation of the Consumer Programme 2014-2020. The legal act establishing the Consumer Programme contains a legal obligation to perform an evaluation . The Consumer Programme 2014-2020 builds on and continues the actions funded under the Consumer Programme 2007-2013. The most successful elements of the previous Programme have been maintained in the new Programme. The results of the mid-term evaluation fed into the design of the post-2020 Multi-annual Financial Framework. The purpose of the mid-term evaluation of the Consumer Programme 2014-2020 is to review the achievement of the objectives of all the measures (at the level of outputs, results and impacts, the latter to the extent possible), the state of play regarding the implementation of the eligible actions set out in Article 4 and the specific actions referred to in Annex I of the Regulation, the allocation of funds to the beneficiaries, the efficiency of the use of resources and the programme's European added value, taking into consideration developments in the area of consumer protection and other consumer-relevant EU policies, with a view to a decision on the renewal, modification or suspension of the actions. The evaluation addresses the scope for simplification, the programme's internal and external coherence including possible synergies/complementarities with other EU programmes, the continued relevance of all objectives, as well as the contribution of the measures to the Union priorities of smart, sustainable and inclusive growth. The longer-term impacts and the sustainability of effects of the programme have been evaluated to the extent feasible given that the programme is still being implemented with a view to feeding into a decision on a possible renewal, modification or suspension of a subsequent programme in terms of scope, nature and cost. 1.2.Scope of the evaluation The evaluation reviews the state of play regarding the implementation of all the measures and their effects at the level of outputs, results and impacts and of the eligible actions set out in Article 4 and the specific actions referred to in Annex I of the Regulation. The evaluation considers the implementation of the Programme in all EU Member States (taking account of the date of accession), as well as in Norway and Iceland. The evaluation period is the period covered from 2014 until 2017. While some of the actions committed at the end of the period are also included in the evaluation for budgetary purposes, they are not taken into the consideration for the evaluation questions. This evaluation covers some aspects related to the management of actions carried out by the Consumers, Health, Agriculture and Food Executive Agency, (hereafter referred as "CHAFEA"). Such management of actions have only been taken into account to the extent that they may be relevant for the evaluation of the financial programme as defined by the evaluation questions, in particular with regards to the efficiency and effectiveness, and scope for simplification aspects. 2.Background to the intervention 2.1.Policy context Article 169 of the Treaty on the Functioning of the European Union requires the EU to contribute to protecting the health, safety and economic interests of consumers through actions in the field of consumer protection and also to take consumer protection requirements into account in defining and implementing other Union policies and activities. This can be achieved as a part of the efforts to build a proper functioning internal market in which both consumers and business benefit equally. In addition, the EU may adopt measures to support, supplement and monitor the policy pursued at national level to promote consumers' rights to information, education and to organise themselves. With consumer spending accounting for 56% of the EU GDP, consumers can play a crucial role in achieving the EU goals of stimulating economic growth, employment and competition. The overarching objective of consumer policy is therefore to empower Europe's 500 million consumers by providing them with the tools necessary for their active participation in the market, by making products and services markets work for them, by facilitating the exercise of their power of choice and ensuring that their rights are properly enforced. Against this background, the EU has put in place over the past 60 years a set of consumer rights and policies that aim to achieve this objective, either through horizontal instruments or sector-specific legislation. Recent efforts to keep this framework up-to-date and fit to address evolving markets include the review of the Consumer Protection Cooperation Regulation as well as the REFIT/Fitness Check of Consumer and Marketing Law, which led to the adoption in April 2018 of the New Deal for Consumers . To implement its consumer policies, the European Commission set out its strategic vision for an EU consumer policy during the reference period of the evaluation in the Consumer Policy Strategy for the years 2007 – 2013 and later in the European Consumer Agenda adopted in 2012. Under the current Commission, the Juncker Commission's Priorities provide a framework for the EU consumer policy, in particular the following priorities: (1) “A Connected Digital Single Market”; (2) “A Deeper and Fairer Internal Market with a Strengthened Industrial Base” and (3)"A Resilient Energy Union with a Forward-Looking Climate Change Policy". These documents lay down the policy priorities to support consumers' interests. For the period covered by this evaluation, the practical realisation of these priorities was underpinned by funding from the EU budget granted through the multi-annual Consumer Programme 2014-2020. 2.2.Description of the intervention and its objectives

The Consumer Programme 2014-2020 with an amount of EUR 188.8 million for the years 2014-2020 was established by Regulation (EU) No 254/2014 of the European Parliament and of the Council of 26 February 2014 . It was adopted to support the implementation of the policy priorities set out in the European Consumer Agenda - Boosting Confidence and Growth. This programme aims to help citizens fully enjoy their consumer rights and actively participate in the Single Market, thus supporting growth, innovation and meeting the objectives of Europe 2020. In particular, actions funded under the Programme seek to address issues linked to globalisation, digitalisation, the growing level of complexity of decisions that consumers have to make, the need to move towards more sustainable patterns of consumption, population ageing, social exclusion and the issue of vulnerable consumers. The programme builds on the actions funded under the previous programme covering the period 2007-2013. It ensures a smooth transition and a continuation of the multiannual measures while taking into account the mid-term evaluation of the previous programme’s successes and areas requiring more attention. By and large the actions to be financed under the Consumer Programme 2014-2020 show a large degree of continuity with the previous programme. They have however been re-organised under four key objectives (as opposed to two broader objectives focusing on consumer protection and effective application of consumer protection rules under the previous programme) with a view to reflect the main priorities of the 2012 Consumer Agenda and notably a stronger focus on access to redress and enforcement, as follows: 1.Objective I — Safety: to consolidate and enhance product safety through effective market surveillance throughout the Union. 2.Objective II — Consumer information and education, and support to consumer organisations: to improve consumers’ education, information and awareness of their rights, to develop the evidence base for consumer policy and to provide support to consumer organisations, including taking into account the specific needs of vulnerable consumers. 3.Objective III — Rights and redress: to develop and reinforce consumer rights in particular through smart regulatory action and improving access to simple, efficient, expedient and low-cost redress including alternative dispute resolution. 4.Objective IV — Enforcement: to support enforcement of consumer rights by strengthening cooperation between national enforcement bodies and by supporting consumers with advice. Only two actions of the Consumer Programme 2007-2013 do not feature in the Consumer Programme 2014-2020, namely the financial contribution to ANEC, which represents consumer interests in standardisation, and was transferred to Regulation (EU) No. 2015/2012 at the end of the 2007-2013 Consumer Programme and is now under the administration of DG GROW and the Financial contributions for the development of integrated European Master Degree courses in consumer issues which were intended to provide initial support for the selected academic consortia and were explicitly non-renewable grants. The implementation of the 2014-2020 Consumer Programme also takes account of the guidance provided by the following Juncker Commission priorities: a deeper and fairer internal market, a connected digital single market, and a more resilient Energy Union. Furthermore, the Programme supports the consumer-relevant policy contribution to Sustainable Consumption/Circular Economy initiatives planned in 2017, in particular in the context of the EU Circular Economy Action Plan. The intervention logic underpinning the Consumer Programme 2014-2020 can be found hereafter. Figure 1: Consumer Programme 2014-2020 – Intervention logic The programme aims to achieve the above described objectives by providing financial support to actions that support and complement Member States’ policy. For instance, while the enforcement of consumer rights is the prerogative of national authorities, the programme contributes to enhance the effectiveness of national enforcement by facilitating the cooperation between enforcement authorities in Member States. 2.3.Baseline and points of comparison As clarified in the previous section, even though the Consumer Programme 2007-2013 was organised around two broad objectives as opposed to the four more targeted objectives of the current programme, both programmes aim at addressing similar challenges in a continuous way. As such, the baseline for the Consumer Programme 2014-2020 is the situation at the end of the Consumer Programme 2007-2013: - As regard Objective I - product safety: whilst product safety was not a self-standing objective under the previous programme, both the mid-term evaluation of the Consumer Programme 2007-2013 and the impact assessment of the Consumer Programme 2014-2020 highlighted the continued existence of problems in the area of product safety. Product safety became a stand-alone objective of the Consumer Programme 2014-2020 notably with a view to address differences in the enforcement of product safety legislation between Member States as well as their difficulties in working together in the absence of a clear pan-European enforcement framework and against the background of the increasing globalisation of production chains and the rise of e-commerce.

- As regard Objective II - Consumer information, education and support to consumer organisations: while actions covered by this objective under the current programme were spread across the two general objectives of the Consumer Programme 2007-2013, both the mid-term evaluation of the latter programme and the impact assessment of the Consumer Programme 2014-2020 concluded that problems continued to exist in the area of consumer information, education and support to consumer organisations, justifying the need to keep the focus on these areas. The impact assessment of the current Programme also noted that consumer markets monitoring was still relatively underdeveloped, in particular with respect to the understanding of ‘actual’ consumer behaviour and decision-making processes . Uneven capacity between consumer organisations in different Member States was also noted as a problem in the impact assessment for the current Programme. also in addition it reported that less than half of EU consumers (44%) felt ‘confident, knowledgeable, and protected’ as consumers ; a situation confirmed by the 2013 Consumer Scoreboard and a 2011 Consumer Empowerment Survey . The consumer information and education tools funded under the previous Consumer Programme were also considered to be inadequate . - As regard Objective III – Rights and redress: The mid-term evaluation of the Consumer Programme 2007-2013 and the impact assessment for the current Consumer Programme identified a number of continuing problems related to consumer rights and redress. Both noted that consumer rights were still inadequately protected, especially in a cross-border context, with the result that consumers feel less confident shopping cross-border than domestically. The impact assessment for the current Programme noted that consumer awareness about means of redress was insufficient, and that vulnerable consumers (especially the less educated and the elderly) were particularly reluctant to seek redress, even though they are no less likely than the general population to experience problems. The mid-term evaluation of the Consumer Programme 2007-2013 concluded that additional steps had been taken between 2011 and 2013 to address these problems, i.e. the development of the Online Dispute Resolution (ODR) platform and the funding of a study on consumer vulnerability, but that the problems identified above remained relevant at the start of the Consumer Programme 2014-2020 justifying the need to keep the focus on these areas. - As regard Objective IV – enforcement: The mid-term evaluation of the Consumer Programme 2007-2013 and the impact assessment for the current Programme concluded that problems continued to exist in the area of enforcement of consumer rights, particularly in a cross-border context, justifying the need to keep on focusing on enforcement. The mid-term evaluation notably highlighted that such problems of poor enforcement resulted in EU consumers being less effectively protected when shopping cross-border than domestically, especially with respect to online sales. The ECC-Net was also not considered to be reaching its full potential in cross-border enforcement, principally due to low awareness among consumers . 3.Implementation / state of Play 3.1.Programme management The programme identifies priorities and for each priority the type of actions that are eligible for funding . These actions are listed in the respective legal act establishing the programme, notably in the annex. The programme has been implemented by means of annual work programmes adopted by the Commission with the assistance of an advisory Committee formed by representatives from Member States . Each annual work programme sets out the actions to be undertaken in a given year, including the allocation of financial resources, as well as the selection and award criteria and criteria for the percentage of EU financial contributions. The actions have been implemented mainly by calls for tender and calls for proposals. The beneficiaries of the financial support are public bodies and private non-profit-making bodies in the Member States, including officials responsible for enforcing consumer protection legislation (e.g. exchanges of officials), or European consumer organisations, higher education institutions, students or teachers. The Programme is monitored through a series of indicators set out in Annex II of the legal act establishing it. Since 2008 an important part of the multi-annual programmes is implemented by an executive agency established in Luxembourg, currently referred to as the "Consumers, Health, Agriculture and Food Executive Agency (CHAFEA)" . For each annual work programme, the Agency and Directorate-general for Justice and Consumers jointly agree what actions will be implemented by the agency. 3.2.Status of implementation The implementation of the Consumer Programme 2014 – 2020 is ongoing: most of the related performance indicators expected for 2014, 2015 and 2016 have been achieved. The 2014, 2015 and 2016 annual work programmes, with a budget of EUR 21.9 million, EUR 22.5 million and EUR 23.7 million respectively, were executed, with a final rate of implementation of 98,3%, 99% and 99,52% respectively. The implementation of the work programmes proceeded as planned except that the absorption of the budget by the Member States was lower than expected and the unused budget has been channelled to awareness raising campaigns. Please find here below the main results in terms of implementation activities per objective. Further information is included in the section on the effectiveness criterion. Objective I In the table below, both indicators for the evaluation period 2014-2017 for Objective I are presented. The percentage of RAPEX notifications entailing at least one reaction by other Member States amounted on average to 43% in the 2014-2017 period (46% in 2017), thereby in the last year almost reaching the target set for 2020. The ratio of the number of reactions to the number of serious risk notifications already reached the envisaged target, with an average of 1.58 in the 2014-2017 period (1.66 in 2017). Table 1: Indicators defined in the Regulation for Objective I Rapid Alert System for dangerous non-food products (RAPEX) Indicators provided in Regulation According to Article 3(1)(a) the objective will be measured in particular through the activity and effectiveness of the EU rapid alert system for dangerous consumer products (RAPEX). As specified in Annex II of the Regulation, relevant indicators are: Indicator: Baseline (2010) provided in Regulation Target in Regulation

(by 2020) Interim status % of RAPEX notifications entailing at least one reaction (by other Member States) 43% (843 notifications) Increase of 10% by 2020 [47.5%] 46% (2017)j) Ratio number of reactions/number of notifications (serious risks)* 1.07 Increase of 15% by 2020 [1.23] 1.66 (2017)h) The table below shows that interviewees assessed activities under the previous Programme on average with 3.8, and activities under the current Programme with 3.9, a stable assessment with a slight positive trend. In both Programs, largely the same activities were funded (except the E-Enforcement Academy, and the databases on cosmetics, which were only funded under the current Programme). Table 2: Overview of progress made during evaluation period (stakeholder assessment of activities - Objective I) Indicator Baseline

(annual average

2011-13) Evaluation period (annual average 2014-17) Progress made Effectiveness of activities funded under Objective I

(on a scale of 1 to 5) Largely effective

(3.8) a) Largely effective

(3.9) O / +

(slight positive trend) Benefits achieved

(on a scale of 1 to 5) Moderately achieved

(3.1) a) Moderately

achieved

(3.3) O / +

(slight positive trend)

++ = significant progress made; + = progress made; O = stable; – = negative trend.

Notes: Averages calculated on basis of the available annual data.

a) Baseline value for whole Programme period CP 2007-2013 ) Regarding the positive assessment by stakeholders per activities under Objective I, Training for enforcement officials received the highest average rating in terms of effectiveness (4.2) , followed by Networking and events (4.0), then in descending order the joint actions, exchange of officials, the EU database on cosmetics, and RAPEX (3,8), see below. Figure 1: To what extent have these activities been effective in consolidating and enhancing product safety through market surveillance in the European Union? CP 2014-2020. Average assessments on a scale of 1 (Not at all effective) to 5 (Very effective) Source: Civic Consulting, stakeholder interviews, question 3. N=22, 55, 45, 26, 15, 70 (in the order of activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment because they did not participate in or use the output of the listed activities. As well positive is the perception of the benefits that most of these activities have achieved in the Member States with better information on unsafe products for enforcement authorities achieving the highest average score (of 4.0), followed by better trained enforcement officials (3.7), better cooperation with enforcement authorities (3.6), better information for consumers (3.5), improved market surveillance and enforcement (3.4) and better information for businesses (3.4), see table below. Figure 2: Please assess to what extent these activities have achieved the following benefits in your country – CP 2014-2020. Source: Civic Consulting, stakeholder interviews, question 4. N=63, 45, 53, 71, 64, 47, 36, 53, 28 (in the order of activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment because they did not participate in or use the output of the listed activities. Objective 2 The only target set for Objective II on consumer information and education that concerns the European Consumer Complaints Registration System-ECCRS has been achieved, and even surpassed. The indicator, i.e. the number of complaint bodies and number of countries submitting complaint data to the complaint database increased from 37 complaint bodies representing 13 countries in 2014 to 73 complaint bodies representing 20 countries in 2015. Table 3: Indicators provided in Annex II of the Regulation (Objective II) ECCRS and related support measures Indicators provided in Regulation Indicator: Baseline (2012) provided in Regulation: Target in Regulation

(by 2020): Interim status: (2015)g) Number of complaint bodies and number of countries submitting complaints to the ECCRS 33 complaint bodies from 7 countries 70 complaint bodies from 20 countries 73 complaint bodies from 20 countries Interviewees considered the activities funded under Objective II of the current Programme on average to be largely effective, as was already the case for the previous Programme. A slight downward trend is noted, but mostly due to the ECCRS, which is the only new activity under Objective II of the current Programme, and assessed lowest. This is illustrated in the figure below: Table 4: Overview of progress made during evaluation period (stakeholder assessment of activities - Objective II) Indicator Baseline

(annual average

2007-13)a) Evaluation period (annual average 2014-17) Progress made Effectiveness of activities funded under Objective II

(on a scale of 1 to 5) Largely effective

(3.8) Largely effective

(3.7) – / O (slight negative trend) Benefits achieved

(on a scale of 1 to 5) Moderately achieved

(3.2) Moderately

achieved

(3.2) O ++ = significant progress made; + = progress made; O = stable; – = negative trend.

Notes: Averages calculated on basis of the available annual data.

a)Assessment concerns the whole Programme period 2007-2013 The activities that were considered to be the most effective in reaching Objective II were Support to EU-level consumer organisations (BEUC) (average rating of 4.2), Networking and events (4.0), the Consumer Champion Programme (3.9) and Consumer scoreboards/market studies (both 3.8). As mentioned above, the ECCRS has received the lowest average assessment (2.9) by stakeholders in terms of its effectiveness (i.e. slightly less than "moderately effective"), and second lowest (3.0) in terms of benefits achieved. Figure 3: To what extent have these activities been effective in improving consumer education/information, developing the evidence base for consumer policy and providing support to consumer organisations? CP 2014-2020. Average assessments on a scale of 1 (Not at all effective) to 5 (Very effective)

Source: Civic Consulting, stakeholder interviews, question 6. N=51, 83, 36, 77, 76, 53, 39, 34 (in the order of activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment because they did not participate in or use the output of the listed activities. In terms of benefits, Improved representation of consumer interests at EU level and Better information on consumer markets and problems across the EU to benchmark the situation in my country with the situation in other Member States were rated, on average, with the highest level of achievement (3.6 and 3.5). Improved capacity of national consumer organisations was ranked the lowest in terms of level of achievement (particularly among consumer organisations) with an average assessment of 2.8. These benefit ratings tally with assessments made regarding effectiveness – notably the high average rating for support to BEUC is reflected in the high average rating of improved representation of consumer interest at the EU level, see Figure below: Figure 4: Please assess to what extent these activities have achieved the following benefits in your country – CP 2014-2020. Average assessments on a scale of 1 (Not at all achieved) to 5 (Fully achieved) Source: Civic Consulting, stakeholder interviews, question 7. N=81, 93, 94, 78, 53, 77, 65. (in the order of activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment because they did not participate in or use the output of the listed activities. Objective III As shown by the table below, the target set in the Regulation regarding the number of complaints registered on the ODR platform could be reached, despite the limited period of time that the platform has been operational (since 2016): Table 5: Indicators provided in Annex II of the Regulation - ODR Platform Indicators provided in Regulation Indicator: Baseline (2010) provided in Regulation: Target in Regulation

(by 2020): Interim status: Number of cases dealt with by a Union-wide online dispute resolution (ODR) system 17 500 (complaints received by ECCs related to e-commerce transactions) 100 000 55 002 (2017) Table 6: Indicators provided in Annex II of the Regulation – consumer action in response to a problem Indicators provided in Regulation Indicator: Baseline (2010) provided in Regulation: Target in Regulation

(by 2020): Interim status: % of consumers who took action in response to a problem encountered in the past 12 months 83% 90% 69% (2016) Despite the introduction of ADR mechanism and ODR platform, the percentage of consumers taking action (i.e. complaining) in response to a problem encountered has actually declined from the baseline level of 83% in 2010 to 69% in 2016. Unresolved cases referred by ECCs to ADR bodies in 2016constituted 18%, as shown in the table below. Although this proportion represents a doubling of the baseline value provided in 2010 (9%), the Regulation target of 75% by 2020 will not be reached, if a similar trend remains. Table 7: Indicators provided in Annex II of the Regulation – cases dealt with by the ECCs which were subsequently referred to ADR Indicators provided in Regulation Indicator: Baseline (2010) provided in Regulation: Target in Regulation

(by 2020): Interim status: % of those cases dealt with by the ECCs and not resolved directly with traders which were subsequently referred to ADR 9% 75% 18% (2016) Activities funded under Objective III in stakeholders' views were considered on average moderately effective under both Programmes (see table below). Table 8: Overview of progress made during evaluation period (stakeholder assessment of activities – Objective III)

Indicator Baseline

(annual average

2011-13) Evaluation period (annual average 2014-17) Progress made Effectiveness of activities funded under Objective III

(on a scale of 1 to 5) Moderately effective

(3.4) a) Moderately effective

(3.4) O Benefits achieved

(on a scale of 1 to 5) Moderately achieved

(3.2) a) Moderately achieved

(3.1) O

++ = significant progress made; + = progress made; O = stable; – = negative trend.

Notes: Averages calculated on basis of the available annual data. a) Baseline value for whole Programme period CP 2007-2013. ODR platform and communication campaigns on ADR/ODR were only funded under the 2014-2020 Programme, so that these activities are not assessed regarding CP 2013-2020. Regarding the effectiveness of these activities in developing and reinforcing consumer rights through smart regulatory action and improving access to simple and low-cost redress, see below: Source: Civic Consulting, stakeholder interviews, question 9. N=31, 76, 76, 53, 71, 85, 78 (in the order of activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment because they did not participate in or use the output of the listed activities. Figure 5: With regard interviewees' views on benefits achieved by activities in their country: Source: Civic Consulting, stakeholder interviews, question 10. N=84, 83, 87, 95, 91, 82, 89 (in the order of activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment because they did not participate in or use the output of the listed activities. It is interesting to note that consumers increasingly - from 39% in 2008 to 52% in 2016 -consider it easier to settle disputes with traders through out-of-court bodies than through the courts , indicating an improvement in the accessibility of ADR during the evaluation period (see below). Figure 6: Percentage of consumers who agree that it is easy to settle disputes with retailers and service providers through an out-of-court body or through the courts (EU average), 2008-2016 Source: Own compilation based on year-over-year differences indicated in the Flash Eurobarometer 397 and the Commission’s 2016 survey of consumers’ attitudes toward cross-border trade and consumer protection. The vertical line represents the beginning of the Consumer Programme 2014-2020. Question text: How strongly do you agree or disagree with each of the following statements. In (our country) … It is easy to settle disputes with retailers and service providers through an out-of-court body (i.e. arbitration, mediation or conciliation body) / It is easy to settle disputes with retailers and service providers through the courts. Shown above are those who ‘Agree’ and ‘Strongly agree’ with these statements. Objective IV As for the three indicators related to information exchange within the CPC network , two (information requests, and enforcement requests) showed a substantial increase from the 2011-2013 baseline period to the year 2017, whereas the third one on alerts remained stable (see below Table 9). Requests for enforcement measures reached in 2017 the highest number since the Network’s inception (198), meeting already the target for 2020. For the additional indicators of the timely handling of information and enforcement requests , the targets set in the Programme could be reached. The final two indicators in the Regulation to measure achievement of Objective IV concern the activity of the ECCs and how well known they are to consumers. The targets in the Regulation in this respect have been surpassed, which may be due to the exponential growth of the Internet and of users’ access to online services, which contributes to an increase in online traffic in general, and also in cross-border B2C transactions (as well as related problems). As shown in the above table, one of the targets for 2020 is 106 500 contacts with consumers, which was surpassed already in 2016. It can be projected that by 2020 the ECC-Net will reach even higher volumes. The other indicator concerns the number of visits to the websites. The projected number of website visits in 2017 at more than 8.5 million is already three times the targeted number for 2020. It can be concluded that the targets set by the Consumer Programme for the ECC-Net have already been more than met. Table 9: Overview of progress made during evaluation period (indicators set in the Regulation – Objective IV) Indicator Baseline

(annual average

2011-13)b) Evaluation period (annual average

2014-17) Targets in Regulation (by 2020) Progress made Number of requests to exchange information between CPC authorities 80 101

(2017: 80) 168 a) O / + (stable if only 2017 is considered) Number of requests for enforcement measures between CPC authorities 139 165

(2017: 198)

185 a) ++

(target already achieved in 2017) Number of alerts within the CPC Network 58 54

(2017: 78)

82 a) +

(target nearly achieved in 2017) % of enforcement requests handled within 12 months within the CPC Network 47% 50%

(2017: 24%) 60% O / –

(Negative trend, if only 2017 considered) % of information requests handled within 3 months within the CPC Network 33% c) 45%

(2017: 23%) 50% + / –

(Negative trend, if only 2017 considered) Number of contacts with consumers handled by the ECCs 74 182 99 756

(2016: 111 563) 106 500 a) ++

(target already achieved in 2016) Number of visits to the websites of the ECCs 2 335 000 d) 5 579 663

(2017: 8 542 936) 2 839 000 a) ++

(target already achieved) ++ = significant progress made; + = progress made; O = stable; – = negative trend.

Notes: Averages calculated on basis of the available annual data. a) In Annex II of the Regulation, this target is provided as a specified percentage increase compared to the baseline value provided therein. For convenience reasons, the table provides the target in absolute values, calculated on the basis of the Regulation baseline and the target set. b) Note that baseline data has been updated. The baseline used in the Regulation is mostly the annualised average 2007-2010 (see Part 2 of this report for the related data). c) Average 2007-2010, no data available for 2011-2013. d) Average for years 2011 and 2013. Stakeholders considered the activities implemented in the first four years of the current Consumer Programme under Objective IV to be largely effective, with a slight positive trend, when comparing them to the assessment of the 2007-2013 Programme.

Table 10: Overview of progress made during evaluation period (stakeholder assessment of activities – Objective IV) Indicator Baseline

(annual average

2011-13) Evaluation period (annual average 2014-17) Progress made Effectiveness of activities funded under Objective IV

(on a scale of 1 to 5) Largely effective

(3.7) a) Largely effective

(3.8) O / +

(slight positive trend) Benefits achieved

(on a scale of 1 to 5) Moderately achieved

(3.4) a) Largely achieved

(3.6) + ++ = significant progress made; + = progress made; O = stable; – = negative trend.

Notes: Averages calculated on basis of the available annual data. The activities that were considered to be the most effective in contributing to Objective IV were Training of consumer protection enforcement officials, European Consumer Centres Network and Networking and events (all with an assessment of 4.0). Other activities were assessed slightly lower, but still as largely effective (with ratings between 3.9 and 3.6), see Figure below: Figure 7: To what extent have these activities been effective in supporting enforcement of consumer rights by strengthening cooperation between national enforcement bodies and by supporting consumers with advice? Source: Civic Consulting, stakeholder interviews, question 12. N=26, 67, 73, 26, 43, 58, 55, 71 (in the order of activities from top to bottom). Not included were interviewees who answered “don’t know” or who did not provide an assessment because they did not participate in or use the output of the listed activities. Regarding the perceived benefits of the specific enforcement-related activities in their own countries, the highest rated were Better advice for consumers in cross-border cases in the EU, Better training of ECC-staff and Other benefits. Table 11: Overview of progress made during evaluation period (indicators for potential wider effects – Objective IV) Indicator Baseline

(annual average

2011-13) Evaluation period (annual average 2014-17) Progress made Percentage of consumers who trust public authorities to protect their rights as a consumer 60% 65% + Percentage of consumers who agree that in general, retailers and service providers in their country respect the rules and regulations of consumer law 62% 73% + Percentage of consumers who encountered at least one problem that they considered legitimate to complain about

(Eurobarometer data) 2012: 25% 21% +

Percentage of retailers who agree that the public authorities actively monitor and ensure compliance with consumer legislation in their sector 75% 66% – ++ = significant progress made; + = progress made; O = stable; – = negative trend.

Notes: Averages calculated on basis of the available annual data. 4.Methodology 4.1.Short description of methodology The evaluation was carried out between October 2017 and April 2018. The evaluation was supported by a study carried out by an external contractor. This evaluation also builds on the mid-term evaluation of the Consumer Programme 2007-2013 and the Impact Assessment for the current Programme, notably as regards the definition of the baseline. For the purpose of this evaluation a broad range of reports, academic literature and other documentation on the actions and activities funded under the Consumer Programme were collected, reviewed and processed. To ensure a coverage of interests as broad as possible, a wide variety of stakeholders were consulted for the evaluation. The consultation process combined targeted consultation of stakeholders through interviews, an open public consultation (in combination with the broader consultation process for the preparation of the post 2020 funding programmes) and discussions with stakeholders at network meetings taking place during the period of the evaluation. 182 interviews were conducted by the contractor with stakeholder organisations in all 28 Member States, Norway and Iceland, and at the EU level. Stakeholder interviews covered ministries in charge of consumer policy or consumer agencies, the national authorities responsible for enforcement of consumer legislation and other national authorities responsible for policy and enforcement of relevant legislation, national representatives of the Consumer Safety Network (CSN) or RAPEX contact points, national consumer organisations and European Consumer Centres. The evaluation team also contacted national business organisations and reached out to relevant EU level business organisations, as well as ANEC and BEUC, for interviews. A public consultation took place from 10 January 2018 until 9 March 2018 as part of a consultation on EU funds in the area of Investment, Research and Innovation, SMEs and Single Market preparing the post 2020 funding programmes. The evaluation team also participated in six meetings with relevant EU networks Annex 2 of this document contains the results and uptake of all consultation activities.

In addition, eight case studies were developed focusing on four specific actions and cross-cutting activities financed by the Consumer Programme. The selection of action-specific case studies was done on the basis of several criteria, including the need to cover all Programme objectives and to look into these key actions that involve considerable financial resources, which are essential for identification of main results and assess their effectiveness and which have not yet been evaluated separately. In addition, the case studies on cross-cutting activities were selected notably to cover specific policy areas, to identify synergies/complementarities with other EU programmes and to provide key insights for addressing specific evaluation questions (for instance as regards the coherence of the Consumer Programme with other EU policies/priorities). Finally, the information collected from the various sources for each action has been consolidated and presented in fact sheets which are structured as follows: •Specific objective and eligible actions; •Description of activities; •Amounts committed during Programme period; •Specific activities funded during Programme period; •Outputs and results of activities; •Excerpts from previous assessments/evaluations; •Stakeholder assessment of the effectiveness of activities under the action; •Key sources. 4.2.Limitations and robustness of findings At the moment of the evaluation, the majority of financed actions were still at the early stage of the implementation providing limited data on results of actions and impacts of the programme. Therefore the mid-term evaluation of the programme mostly relied on stakeholder assessments on the implementation and outputs of actions financed under the Consumer Programmes. Where possible, findings from interviews were triangulated with quantitative analysis of outputs and actions. To the extent possible, the analysis of evaluation questions was informed by a comparison with a baseline situation (end of the previous programming period). 5. Analysis and answers to the evaluation questions 5.1Effectiveness Objective I Product safety Key findings The Consumer Programme 2014-2020 has made substantial progress in achieving Objective I compared to the baseline period. Activities have contributed to improved information exchange and cooperation between Member States, thereby reducing differences in enforcement across the EU. The Rapid Alert System for dangerous non-food products-RAPEX has grown into an effective and important pillar of the EU market surveillance architecture that is internationally recognised and appreciated by its main target groups across the EU. Activities to support EU wide market surveillance and enforcement measures, such as joint actions, training and networking are considered to be effective by the main target group, national authorities. They lead to coordinated approaches to common problems, direct contacts between authorities from different countries and exchange of best practices. They also support Member States' authorities in addressing new challenges (e.g. through the E-Enforcement Academy). The activities implemented under the Programme have therefore been largely effective in consolidating and enhancing product safety through market surveillance in the EU, according to the results of the evaluation and in line with stakeholder assessments. The choice of actions builds upon and continues previous Consumer Programmes, and is appropriate for achieving the Programme's Objective I.

Key factors that influence level of achievements related to the objective are limited staff and financial resources for market surveillance and enforcement in Member States, as reported by interviewees. Stakeholders cited the continued presence of unsafe products on the market as well as emerging risks, e.g. from new, technically complex products or from e-commerce with third countries, as evidence that market surveillance needed to continuously adapt to new challenges. While consumer and retailer perception of the level of product safety and enforcement depend on various factors, results from EU-wide surveys can provide some indication of potential wider effects of the Programme in the absence of more objective measures. Consumer trust in product safety has increased during the Programme period, in parallel to the efforts in enforcing product safety in recent years, both at national and EU levels. Also, roughly three quarters of retailers agree that public authorities actively monitor and ensure compliance with product safety legislation in their sector. Retailers' assessment of enforcement activities by authorities fell somewhat around the time of the start of the Consumer Programme 2014-2020 and has remained stable since then. Overall the perception of stakeholders regarding the effectiveness of actions implemented in the first four years of the current Consumer Programme, compared to their assessment of the 2007-2013 Programme sees a slight positive trend . Equally positive was the perception of the benefits that most of these activities have achieved in the Member States. Outputs and results of each of the activities have been triangulated with the assessments of stakeholders made in the interviews conducted in all Member States, Norway and Iceland, and the results of previous specific evaluations, where available. Progress towards Objective I during the evaluation period (the first four years of the current Consumer Programme, i.e. 2014-2017) have been screened through key indicators compared with the baseline situation before the implementation of the Programme, drawing on the results of the ex-post evaluation of the previous Consumer Programme 2007-2013. Specific actions under Objective I The Rapid Alert System for dangerous non-food products (RAPEX) is a tool for national authorities and EU institutions to facilitate rapid information exchange and to implement market surveillance. It also serves through its website as a source of information on unsafe products for the wider public. For the period under evaluation, more than 60% of interviewed business associations, ECCs and national authorities expressed their appreciation of RAPEX as an effective and important tool for market surveillance. Only about one in ten of the interviewees considered the system to be rather not effective, mostly consumer organisations. Limitations of RAPEX include delays in notification, and language issues (the system is in English only). The effectiveness of RAPEX is also illustrated by the measures taken in response to notifications under the RAPEX system by economic operators or authorities, such as withdrawal of products, sales bans, and corrective actions, removal of dangerous products from the market or import into the EU prevention. More than 2 000 voluntary and compulsory measures were reported in 2016 alone. In the same year, the number of reactions was almost double the number of notifications. This means that national authorities are systematically following-up notifications that are circulated in the system. RAPEX has been instrumental in bilateral and multilateral collaboration of the EU with respect to product safety. Based on RAPEX data, the Commission shares information on dangerous products with the OECD Global Recalls portal. Also, as China is the main country of origin for products that are subject to notification, a specific module (RAPEX China) allows for the swift flagging of notifications concerning unsafe products from China. The Consumer Programme 2014-2020 defines for the first time indicators that relate to particular activities, as well as associated baselines and targets to measure progress for each of its objectives. For Objective I, the targets for the two indicators that relate to RAPEX have been reached . It can be said, therefore, that so far, the results for the first years of the Programme indicate a positive trend Under Action 3 of the Consumer Programme, the maintenance and further development of two databases on cosmetics, Cosmetic Ingredient Database-COSING and Cosmetic Products Notification Portal-CPNP are funded. The former is the European Commission’s database for information on cosmetic substances and ingredients and includes all data since the adoption of the Cosmetics Directive in 1976. The CPNP is a free of charge online notification system created for the implementation of Regulation (EC) No 1223/2009 on cosmetic products for the purposes of market surveillance, market analysis, evaluation and consumer information, and to Poison Centres or similar bodies established by EU countries (for the purposes of medical treatment). The positive assessment of COSING's effectiveness by stakeholders (average score of 3.8) is in line with data on the use of COSING, which confirm that the database is frequently accessed (almost 1 200 000 views per month, making it the by far most visited database of DG GROW). For CPNP, as of December 2017 more than 1 600 000 products have been notified in the CPNP by 42 208 organisations, underlining the practical importance of the database. The Joint cooperation and enforcement actions aim to promote and coordinate administrative cooperation for the application of Directive 2001/95/EC. These actions cover from assessment of risks posed by non-food consumer products and product testing to market surveillance operations and co-operation with customs authorities, and others. Specialised laboratories are selected to test products and assess risks. Such actions often lead to submission of notifications in RAPEX. In the period 2014-2016, five joint actions have been undertaken each year. For instance, in the 2014 joint action on acoustic toys, around 2 190 different models of acoustic toys were inspected, so they directly contributed to consolidating and enhancing product safety through market surveillance across EU borders, and such effectiveness is enhanced through the availability of RAPEX as a notification system, so that also non-participating countries benefit from the actions. All stakeholder groups considered joint actions to be effective (average score of 3.9), with ministries and national authorities providing the highest score (4.2). Interviewed ministries and national authorities appreciated the coordinated approach to common problems, the opportunity to join forces and to establish direct contacts with surveillance authorities from different countries, as well as the exchange of knowledge. Limited staff/financial resources for market surveillance and enforcement were most commonly indicated as a factor influencing a low level of achievement of product safety-related benefits. Networking activities and events related to product safety took place to exchange experiences between Member States and support the implementation of the other activities, i.e. the Consumer Safety Network, the CSN permanent subgroup of RAPEX contact, the 2016 edition of the International Product Safety Week hosted by DG Justice and Consumers in Brussels. The interviewed stakeholders considered networking and events to be effective, with ministries and national authorities being the most positive and emphasised the usefulness of networking and events for the exchange of best practices as well as improving coordination with their counterparts in other Member States. The Exchange of safety enforcement officials include visits, coordination of enforcement or investigations, and small workshops. Despite scarce resources as a limiting factor, the number of exchanges almost tripled from 19 in 2014 to 56 in 2017, which can be considered an encouraging number showing a positive trend. This is a development that supports the positive assessment by national authorities. In total, officials from 21 EU and EEA states took part in exchanges. The top three Member States of beneficiaries have been Poland (36 officials), Bulgaria (26 officials), and Croatia (10 officials). The top three hosting Member States have been Poland (23 officials), Malta (18 officials), and France (14 officials). The E-Enforcement Academy is a new activity under both Objective I (Action 2) and Objective IV aimed at boosting both the Consumer Protection Cooperation (CPC) and the consumer product safety networks (CSN) abilities to conduct online investigations by means of high-quality trainings and learning materials. 23 product safety officials from different countries participated in webinars, and 12 officials attended master classes .

In spite of this limited number of participants so far, interviewees (mostly ministries and authorities) gave the E-Enforcement Academy the highest ranking in terms of effectiveness in this Programme area, (average score of 4.2). In order to maximise its potential, together with consolidation for the initial phase, it could be assessed whether more training activities conducted more frequently and in-person could attract further participants to the E-enforcement Academy. Two non-food scientific committees, the Scientific Committee on Consumer Safety (SCCS) and the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) provide advice feeding into the work of EU standardisation bodies and into the knowledge base to further improve consumer product safety in the EU, in particular on cosmetic products. From April 2013 to March 2016, the SCCS and SCHEER adopted 87 documents during a total of 306 meetings. An evaluation of the functioning of the Scientific Committees concluded that the “opinions of the Scientific Committees have generally been fully responsive to the information needs of the relevant Commission Services, although with some variations between SC [Scientific Committees] also depending on the nature of the questions addressed." Objective II - Consumer information and education, developing the evidence base and support to consumer organisations Key findings The Consumer Programme has been largely effective in developing the evidence base for consumer policy, as consumer scoreboards and market studies have led to policy uptake at EU level, and are useful for benchmarking purposes at the national level. Also, support to the EU-level consumer organisation Bureau Européen des Unions des Consommateurs-BEUC is considered to be effective, and the organisation made an important and consistent contribution to representing consumer interests at the EU level. The Consumer Champion training courses for consumer professionals are considered to be valuable and highly appreciated, while the online learning courses and interactive platform are under-used. Capacity of consumer organisations at the national level often remained insufficient in spite of these training measures, mostly due to a lack of resources rather than to drawbacks of the activities per se. Consumer awareness campaigns funded under the Programme have achieved mixed results, with the campaigns' targets in terms of hits or impression achieved, but little long term impacts being discernible. The targets set for this objective in the Regulation are already met, they relate to only one activity funded under this objective, the European Consumer Complaints Registration System. However, in spite of positive indicator values, interviewees emphasised the efforts needed for providing complaints data and suggested that the system needed improvement/changes. Key factors that influence the level of achievements related to the Programme objective are often external in nature: in the area of consumer information and education they include limited staff and financial resources available for this purpose in Member States, but also the limited integration of consumer education into national curricula; in the area of capacity building of consumer organisations they include resource constraints of the target organisations, which cannot appropriately be addressed by the provision of training alone. Specific actions The consumer rights information activities under Actions 5 and 6 of the Consumer Programme 2014-20 have included information campaigns on consumer credit, on energy efficiency (communication campaign targeting energy poor households), and in 2014 consumer rights awareness activities in Croatia (consumer advice services in support of an EU information campaign). The specific evaluation of the 2014 campaigns concluded that, while their messages were considered easy and informative, the increase in awareness after the campaign was relatively small overall (2% to 5%). The evaluation of the second wave reported that "stakeholders perceived that the budget was quite limited and that it would, therefore, have been challenging to make a lasting impact on large numbers of the target group". . Although the stakeholders' assessment was slightly better than "moderately effective" (3.4) in contributing to Objective II, some national consumer organisations argued that such a contribution could be improved if they were given a larger role in these campaigns (campaigns have been principally carried out by specialised media agencies). The benefit assessment concerning Better information for consumers was equally moderate (3.3). This was mainly due to limited staff/financial resources for consumer information, and insufficient capacity of consumer organisations at national level. Capacity building and support to consumer organisations (Action 5) consists of financial support to EU-level consumer organisations, and capacity building measures for national organisations. The financial support to BEUC was last independently evaluated in 2013 for the 200713 contributions. The findings of the evaluation confirmed the organisation’s significant contribution to EU policy-making and representing consumer interests, found it to be reasonably efficient and well-functioning, and recommended improvements in its performance monitoring system (key performance indicators are now in place). Interviewees, in particular consumer organisations, considered the support to BEUC as the most effective activity under Objective in terms of information, education and networking hub for national consumer organisations. This activity received the highest average score for effectiveness of all activities under this objective from interviewed stakeholders (4.2), while its Representation of consumer interests at EU level was equally rated with the highest level of achievement amongst benefits listed (3.6). Not surprisingly, consumer organisations gave the highest average assessment rating (4.5). BEUC also manages as leader of a consortium the Consumer Champion capacity-building programme, which builds on the work of the previous TRACE programme, and consists of courses at the local level in the Member States as well as e-learning courses and an online networking platform. Despite statistics growth in user numbers between 2014 and 2017, BEUC itself noted overall that the online platform did not have the success expected, because of difficulty of navigating it, language obstacles, overall culture in the consumer movement (preference for face to face networking) and competition with other platforms (BEUC’s own internal member platform). On the other hand, local courses were appreciated within the Consumer Champion programme, as they provide space for networking with other consumer stakeholders in the country, they are in the national language and focus on country’s specificities. . However, the impact of the Consumer Champion on the Improved capacity of national consumer organisations ranked the lowest in terms of level of achievement, particularly among consumer organisations. The likely most significant factor limiting the level of achievement is the lack of resources of consumer organisations. In Consumer education areas, the Consumer Classroom website had 277 241 unique users, 25 048 registered users (out of which 6 721 were teachers), 223 ready-to-use teaching resources collected from across the EU, 544 lessons created by users, and had built 78 partnerships across Europe with consumer organisations, school associations and other interested NGOs, and also organised an annual school competition bringing student from different Member States together to compete on topical consumer issues. Local courses were the most appreciated by participants (mostly from consumer organisations), as they provided space for networking with other consumer stakeholders in the country, are in the national language and focus on country’s specificities. The effectiveness of the Consumer Classroom also depends on the national situation that determines its uptake in the education system. Improving evidence base for policy-making (Action 4), including for designing smart and targeted regulations and for detecting any market malfunctioning or changes in consumers’ needs. It accounts for the largest share of the Programme resources spent under this objective (about 40%) also through the funding of consumer scoreboards and market studies. Based on the results of the scoreboards , the Commission identifies markets that do not function well and which may require further in-depth research. Ten studies were carried out within the period 2014-2020, including on measuring consumer detriment in the EU, on pre-contractual information and billing in the energy market, on sharing economy and on residential prosumers in the European Energy Union.

Scoreboards and market studies' effectiveness is evidenced through policy uptake of their results at the EU and national levels : ·Findings of the Consumer Markets Scoreboard can help national policymakers to benchmark their national situation against other countries. ·Scoreboards have informed the European Semester exercise evaluations and impact assessments, and indicators in the strategic planning of DG Justice and Consumers; ·The findings of market studies fed into policy and other Commission initiatives. The 2017 Study on measuring consumer detriment in the EU fed into the REFIT (Regulatory Fitness and Performance Programme, These activities have, therefore, been effective in informing the consumer policy process. Alike the majority of interviewees considered both scoreboards and market studies to be effective in developing the evidence base for consumer policy and useful also at the national level. Several consumer organisations complained that policymakers at the EU and national level did not sufficiently take the evidence base into account when making consumer policy decisions. There were also reported shortcomings in some instances with regard to the planning and timeliness of the evidence produced. The European Consumer Complaints Registration System (ECCRS) - based on a harmonised methodology for classifying and reporting consumer complaints and enquiries - aims to provide a broad evidence basis on consumer issues and enable comparisons across the Member States. ECCRS data has fed into the preparatory work for some initiatives and studies, often for triangulation purposes, including for e.g. the Study on measuring consumer detriment in the EU, the Evaluation of the Consumer Rights Directive and the Consumer Scoreboards (since 2012). The number of complaint bodies and countries submitting complaints data to the ECCRS also increased from 37 complaint bodies representing 13 countries in 2014 to 73 complaint bodies representing 20 countries in 2015, thereby meeting the targets set in the Regulation for 2020. This contrasts, however, with the views of stakeholders, who gave the ECCRS on average the lowest assessment for any of the activities funded under this objective. This divergence can be explained by the fact that the targets are quantitative, and focus on inputs, while stakeholder assessments instead refer to motivation, contents and usability of results, which have been indicated to be limited so far. Also, the ECCRS was assessed lowest in terms of affordability of the costs borne by each organisation relative to the benefits it received. It can therefore be concluded that in spite of the achievement of the related targets, the ECCRS needs further review. Objective III Consumer rights and redress Key findings The funded activities such as the ODR platform, awareness campaigns on ADR/ODR and related networking and events complement each other and have been an appropriate choice to reach the objective. Also, behavioural and other policy studies have contributed to creating a fundament for evidence-based consumer policy and legislation. The ODR platform has been relatively successful in attracting consumers to register their complaints. The target for 2020 in terms of complaint numbers is likely to be achieved. However, the platform has been less effective in reaching its aim to improve access to ADR, with so far 2% of the registered complaints reaching an ADR body. Possible reasons include the early stage of implementation of the ODR platform, a limited awareness of consumers and traders of the platform, and the reluctance of traders to settle their disputes via ADR. The main benefit of the ODR platform appears to be that traders contacted through the platform often informally solve the problem directly with the affected consumers without any involvement of an ADR scheme. Positive trends with respect to accessibility of and consumer satisfaction with ADR can be observed based on EU survey data. They possibly reflect ongoing efforts in Member States to improve ADR systems and a broader recognition of ADR as an efficient means of redress. Behavioural studies are an essential tool to support evidence based policymaking that considers how real consumers interact in real markets with real companies, complementing evidence from legal and economic studies. However, as for Objective II, stakeholders think that policymakers do not make sufficient use of these studies, or that the studies could be better promoted. Several studies have however fed directly into the development of EU consumer policy initiatives, with the practical value of the studies being confirmed by stakeholders. Specific actions The actions funded under this objective are targeted to address the problems - as summarised in the baseline and in the 2011 impact assessment of the Consumer Programme 2014-2020 - concerning Sub-optimal protection of consumer rights, Regulatory fragmentation of consumer legislation, Problems faced by consumers when trying to secure redress, and need to further improve the integration of consumer interests in EU policies: . Facilitating access to alternative dispute resolution mechanisms for consumers through an European Online Dispute Resolution-ODR platform, as well as related awareness campaigns and networking activities under Action 9 account for roughly half of the Programme resources spent under this objective. From 15 February 2016 to 15 February 2017, 1.9 million people visited the ODR platform . On average the website received over 160 000 visitors per month and the number of complaints registered on the ODR platform is already slightly more than halfway to its 2020 target after the first 22 months of the ODR platform’s existence. The Commission’s 2017 report on the functioning of the ODR platform indicates that in 85% of the cases, complaints were automatically closed within 30 calendar days after submission, meaning that the consumer and the trader failed to agree on a competent ADR body. Only less than 1% of the complaints that were lodged through the ODR platform reached a final outcome through an ADR procedure. However, the survey report shows that around 44% cases (including automatically closed cases) are settled directly by the parties following the contact via ODR platform .

It can be stated, therefore, that the ODR platform has been successful in attracting consumers to register their complaints; however, its impact on improving access to ADR is difficult to assess and quantify. Further close monitoring and a more in-depth assessment in some years will be needed to improve access to ADR. Traders’ willingness to engage in it may depend on a number of factors, such as a very slow judicial system or high litigation costs that act as an incentive for traders to not to engage in ADR, since they do not have much to fear as consumers will not normally go to court. Another factor is the costs of ADR proceedings . Awareness of the ODR platform, and of ADR, is a prerequisite of their use. Therefore, communication activities on ADR/ODR have included awareness-raising campaigns on social media, high-level events with traders, and enforcement activities (web-scraping) to determine the level of traders’ compliance with the ODR Regulation. In addition, in 2017 the Commission contracted a web-scraping study of EU Traders’ website to examine the current state of compliance of online traders in the EU with the ODR Regulation. More than 20 000 web shops across the EU were examined and findings showed that traders’ compliance with their obligation to include the ODR link depends on the size, country and sector of a trader.’ The increasing confidence in cross-border ecommerce and satisfaction with ADR, therefore, is a beneficial environment for the activities funded under the Consumer Programme, especially the ODR platform, in which increasing consumer demand for such a tool can be expected Within the framework of the Consumer Programme 2014-2020, the Commission financed six behavioural studies between 2014 and 2017 : stakeholders in general appreciated the approach of basing consumer policy and legislation on evidence, and considered behavioural studies as effective and potentially helpful for policymaking. However, remarks were raised on the actual limited use of these studies by policy-makers. A case study on the evidence base identified however a number of examples where it is expected that the results of the studies contribute to a better understanding of consumers' behaviour in the market, support the enforcement of consumer protection rules in the online environment, and inform policy options to enhance consumer protection in the online environment or contribute to activities by different Commission services (e.g. DG ENV, GROW, ENER, JRC). Among the other studies, three have informed the development of EU consumer policy initiatives, namely the study which contributed to the recast of the CPC Regulation , the consumer market study on guarantees, which fed into the proposals on digital contracts and informed the REFIT of the Consumer Sales and Guarantees Directive 1999/44/EC and the study on transparency of online platform into the New Deal for consumers . Other studies are ongoing, in order to support smart regulatory action, such as ex-ante and ex-post evaluations, impact assessments, public consultations, and the evaluation and simplification of existing legislation. Among other activities, the Citizens’ Energy Forum was considered to be largely effective (average rating 3.8) as a “space for concertation and exchange of policy views” . The recommendations that came out of the Forum were widely used by the Commission when proposing the ‘Clean Energy Package for all Europeans’. Also two working groups on consumer policy have been convened within the framework of the Citizens’ Energy Forum, including the Vulnerable Consumer Working Group. Stakeholders considered that the Citizens’ Energy Forum made a notable contribution to consumer policy and legislation at the EU level, in particular noting that the recommendations that came out of the Forum were widely used by the Commission when proposing the ‘Clean Energy Package for all Europeans’. Other networking activities and events include meetings of the Financial Services User Group (FSUG) providing advice to the Commission in the preparation and implementation of legislation or policy initiatives affecting the users of financial services. . The Multi-Stakeholder Groups (MSGs) on Environmental Claims and on Comparison Tools set up as the result of the Consumer Summit brought together industry representatives, NGOs and national authorities with the aim to improve compliance with the Unfair Commercial Practices Directive 2005/29/EC (UCPD) in these two areas. The MSG on Comparison Tools' Key Principles for Comparison Tools have fed into the UCPD Guidance and have also been referenced in the Communication on Online Platforms and the Digital Single Market published on 25 May 2016. Interviewees unanimously found these networking activities and events very useful, and attributed a multiplier effect to them in that information gained through these activities is passed on to the relevant services at the national level. The results of the evaluation also confirm that considerable outputs and results were produced, which fed into the policy process. Objective IV: Enforcement Key findings The Consumer Programme 2014-2020 is on track to achieve Objective IV, as is evidenced by significant progress made in reaching most of the targets set in the Programme. The activities funded complement each other well and have been largely effective in supporting enforcement of consumer rights by strengthening cooperation between national enforcement bodies and by supporting consumers with advice. Activities related to the Consumer Protection Cooperation Network-CPC have grown in importance and seen improvement in terms of effectiveness. A new knowledge exchange platform (IT tool) has also been added to support collaborative work and to share results with the wider CPC Network. However, there are still differences between Member States in making use of the CPC System and to engage in enforcement requests, with a significant drawback in achieving Objective IV being the often long response times in the network. Exchanges of enforcement officials are an appreciated activity that has seen increased participation, but that is unevenly used by Member States. Also, the EEnforcement Academy has received a high assessment of effectiveness, although participation in its first year in operation has remained lower than planned, especially in web-based modules. The European Consumer Centres-ECCs have established themselves further during the current Programme as an important institutional component of EU consumer law enforcement policy. The output of the ECC-Net is significant, and the quality and timeliness of the ECCs’ services is also assessed positively in the recent specific evaluation, despite disparities in this respect between ECCs in different Member States. The main challenge for the ECCs is still their visibility. EU survey data shows that in parallel to the implementation of activities under the Consumer Programme, trust of consumers that public authorities protect their rights, and that retailers generally respect consumer rights has increased. This correlates with a slight reduction of problems experienced by consumers. Two thirds of retailers consider public authorities to actively monitor and ensure compliance with consumer legislation in their sector. However, this percentage has decreased over the last years. With some resemblance to the situation discussed regarding product safety, limited staff and financial resources of consumer protection authorities in the Member States are considered key factors influencing the level of achievements related to the Programme objective; other key factors include the rapid innovation of products and services, as well as new distribution channels that make effective consumer protection more difficult. While this development offers many advantages for consumers as well as for businesses, there are also increased risks for widespread infringements of consumer rights and difficulties with enforcement of consumer rights. The Digital Single Market Strategy therefore highlighted the "need for more rapid, agile and consistent enforcement of consumer rules for online and digital purchases to make them fully effective". More recently, effective enforcement of consumer rights was made a central part of the New Deal for Consumers launched by the European Commission. The 2011 mid-term evaluation of the 2007-2013 Programme and the impact assessment for the current Programme from the same year had concluded that problems continued to exist in the area of enforcement of consumer rights, particularly in a cross-border context and suggested to further increasing the coordination within the CPC Network and enforcement authorities. The role of effective and efficient enforcement of EU consumer law has become particularly prominent with the advance of digitalisation and the Internet and the rapid growth of online business-to-consumer trade.

Specific actions While the responsibility for enforcement of EU consumer law and policy lies primarily with the EU Member States, the 2004 CPC Regulation established the Consumer Protection Cooperation Network (CPC) of public enforcement authorities responsible for consumer law enforcement in the Member States (so called national competent authorities, or NCAs) in cases of cross-border consumer law infringements. Under the CPC system (CPCS), the main platform through which exchanges of information and enforcement requests between competent authorities are taking place, the database initially suffered from a technical problems as well as a lack of experience and understanding on the part of authorised users. Then, it has improved, and a recently introduced CPC knowledge exchange platform complementing the database was considered to be an effective innovation. Several interviewees in the current Programme evaluation emphasised the role of the CPC Network for developing a common understanding of the CPC Regulation and a more harmonised approach to implementation. Overall, the CPC Networks is therefore considered by stakeholders to be largely effective. The CPC Regulation also includes a provision on coordinated market surveillance and enforcement activities in cases of intra-Community infringements that harm the interests of consumers in more than two Member States (Article 9). EU-wide screenings of websites, commonly known as sweeps are carried out. So far, four sweeps were funded under the Consumer Programme 2014-2020. The effects of sweeps assessed through a follow-up screening showed that the level of compliance among traders with EU consumer law has increased considerably, indicating the effectiveness of the sweeps. Sweeps enable authorities to obtain information on the processes and problems in other Member States and to take actions ex officio. The so-called Joint Actions require the concerned traders to cease unfair commercial practices in areas of common interest across the EU. The CPC Network has so far concluded three coordinated enforcement actions under the current Consumer Programme. Joint actions have been assessed as effective and were considered to represent a “further step in enforcement cooperation” in earlier, specific evaluations. The added value of common enforcement actions has been evidenced and underlined also in the studies that prepared the review of the CPC Regulation. This joint approach enhances legal certainty and the chances of achieving compliance and offers a more cost-effective solution and received positive assessment by stakeholders. Both limitations in the legal framework provided by the CPC Regulation as well as practical difficulties, have however influenced the achievement of the Programme objectives. Problems of coordination of joint actions were reported for the leading Member States in ensuring the participation of other Member States together with costs of accounting and reporting The functioning of the CPC-Network is supported through training activities, which include the exchange of CPC enforcement officials and the E-Enforcement Academy. The exchanges of officials have taken off slowly, but are gradually expanding. Compared to the first years after the entry into force of the CPC Regulation, the total number of exchanges has seen a threefold increase - from 62 CPC exchanges for the years 2009-2013 to 196 CPC exchanges for the years of 2014-2017 – though it remains still limited with an uneven Member States’ engagement . Such exchanges are considered important and useful for enhancing knowledge and understanding about the system of consumer protection and enforcement practices in other Member States. Among the factors reducing the interest in exchanges and their usefulness, language barriers, lack of time and resources on the part of both sending and receiving authorities are included. The EEnforcement Academy (see also references under objective I) seeking to build capacity and improve enforcement with particular focus on online infringements caters to the needs of both the CPC Network and the Consumer Product Safety Network. Total participation in on-site and virtual events (webinars) in 2017- starting year - amounted to 155 persons, below the actual capacity of the training activities. .Although the EEnforcement Academy has not yet fully attracted the interest of enforcement officials. The second main action funded under the Consumer Programme is the network of European Consumer Centres (ECCs) set in each of the 28 EU Member States, as well as in Norway and Iceland. The ECCs support consumers in exercising their rights in relation to cross-border issues by giving free advice and practical assistance. Each ECC is co-funded by the Commission and the Member State where the centre is based. Despite these common requirements, the ECCs differ considerably in size, capacity and institutional characteristics. These differences are at least partly related to the different institutional organization of consumer protection in the respective countries. The 2017 specific evaluation of the ECC-Net systematises information on average times for answering information requests and for handling complaints by individual ECCs across the Member States. The performance of ECCs is further analysed through consumer satisfaction surveys and mystery shopping tests. The overall evaluation in the Draft Status Report is positive, in line with the view of the stakeholders interviewed for this Programme evaluation. The Status Report provides detailed assessments of the ECC performance regarding: ·Information provision, in 2016 the ECCs handled 44 000 information requests, which took them on average approximately five days each. ·For the handling of complaints, the ECCs managed to improve the time it takes to deal with complaints, despite a substantial increase in the number of complaints handled (the volume almost doubled since 2007). In terms of the outcome of complaints, in 2015, 51% of the shared cases (cases handled with the involvement of traders) were resolved amicably. For around one third of the disputes in 2015 and 2016, no solution could be found. Around 16% of these cases were transferred to ADR bodies. ·Enhancing ECCS' visibility is on the whole positively assessed. However, in spite of meeting and surpassing the targets set in the Consumer Programme and despite the promotional efforts on the part of the ECCs, their overall visibility is still considered rather low. The Status Report emphasises the existence of significant differences in the level of services provided by ECCs across Member States. These differences are visible in all aspects of the activities of the Centres. The three types of exchanges known as information requests, alerts and enforcement requests, respectively as well as time limits for handling of information and enforcement requests have been used in the Regulation on the Consumer Programme as indicators for measuring the level of information flow within the CPC Network. In a summarised way, it can be said that two of the indicators measuring the level of information flow within the CPC Network (i.e. related to information requests, enforcement requests) show a substantial increase from the 2011-2013 baseline period to the year 2017, whereas the third one (alerts) remains stable.

As for the timely handling of information and enforcement requests, the targets set in the Programme for information requests is on track to be reached. The targets set by the Consumer Programme for the ECC-Net have already been more than met To what extent do the activities and outputs of the actions match the objectives of the programmes? The intervention logic of the Consumer Programme 2014-2020 and the answers to the effectiveness questions have indicated that the activities and outputs related to the activities under the Consumer Programme on the whole match the stated objectives for each Programme area. No activities or outputs have been identified that would not match one of the four specific objectives and the set of specific actions set out in Annex I of the implementing Regulation (EU) No 254/2014 related to these objectives. 5.2 Efficiency 5.2.1. Which were the costs and the benefits of the actions? Of the EUR 188.8 million earmarked for the seven-year period from 2014 to 2020, a total of EUR 95.4 million (50,53%) had been committed as of the end of 2017. The types of costs involved in the actions undertaken under the programme consist mainly of: - Operational costs of actions under the four objectives; - costs of actions that cover multiple objectives, such as travel and subsistence for monitoring execution of actions, events, meetings, support staff for IT system maintenance, etc. The quantification of Programme costs in the external evaluation focuses on direct Programme costs and co-financing contributions of beneficiaries, for which unambiguous data is available. Other costs are not considered. Regarding benefits of the programme, the external programme evaluation has provided limited quantified data and mostly refers to a more rich qualitative assessment of the benefits of the programme by stakeholders. Benefits can be categorized as follows: - Benefits for direct beneficiaries (national authorities, consumer associations) - Direct and indirect benefits for EU consumers - Direct and indirect benefits for businesses operating in the single market - Direct and indirect benefits for national authorities - General social and economic benefits

5.2.2. Justification of cost distribution and prioritisation The distribution of funding 2014 - 2017 between objectives was: Objective I: EUR 13.1 million Objective II: EUR 35.1 million Objective III: EUR13.0 million Objective IV EUR 30.2 million Approximately 4% of the budget was used to fund cross-cutting activities, such as travel costs for events, meetings, support staff for IT system maintenance, etc. 5.2.3. Proportionality of cost vs benefits The external evaluation did not provide sufficient information to calculate the proportionality of costs vs benefits. 5.2.4. Factors influencing efficiency The external evaluation found that stakeholders and beneficiaries consider that the actions/activities are clearly defined, that the annual work programmes are transparent and the Programme is well structured. The evaluators did not identify any major gaps, inconsistencies or overlaps between the activities funded. Potential for efficiency gains identified in the mid-term evaluation of the Consumer Programme 2007-2013 in the Programme implementation were addressed through simplification of procedures for the financing of the exchange of officials and ECC net. For the Consumer Programme, EUR 188.8 million were earmarked for its implementation over the seven-year period from 2014 to 2020, of which a total of EUR 95.4 million (50, 53%) had been committed as of the end of 2017. The following figure presents the breakdown of funds committed under the Consumer Programme between 2014 and 2017 per objective. 5.2.5 Efficiency per objective Figure 5: Proportion of funds committed under the Consumer Programme 2014-2020 by objective, 2014-2017 Source: Civic Consulting, based on 2014-2017 budget data provided by DG Justice and Consumers.

As shown in the figure, the two objectives that received the highest share of funding between 2014 and 2017 were Objective II: Consumer information, education and support for consumer organisations (EUR 35.1 million) and Objective IV: Enforcement (EUR 30.2 million). Activities funded under Objective I: Safety and Objective III: Rights and redress consumed EUR 13.1 million and EUR 13.0 million, respectively. Approximately 4% of the budget belongs to the ‘Administrative’ budget line, which is used to fund cross-cutting activities, such as travel costs for events, meetings, support staff for IT system maintenance, etc. EUR 13.1 million, or 14% of the funds committed under the Consumer Programme between 2014 and 2017, were spent on activities related to Objective I. The following figure shows a detailed breakdown of the funds committed under this objective between 2014-2017 by main activity. Figure 6: Breakdown of funds committed under Objective I by type of activity, 2014-2017 In the four years under consideration, the amount committed for RAPEX totalled EUR 2.9 million, or 3.0% of total Programme costs. Given that the number of notifications in the RAPEX system was 8 658 in this period, the average Programme cost per notification was EUR 335 (equivalent to EUR 10.8 per notification and participating country), which appears very proportionate. According to stakeholders, the Consumer Programme achieved the benefit of better information on unsafe non-food products for enforcement authorities with a high average rating of 4.0 (on a scale of 1 to 5). This was the highest assessed benefit discussed with stakeholders regarding product safety. During the evaluation period, the amount committed for joint cooperation and enforcement actions in the area of non-food consumer product safety was EUR 6.2 million, equalling 6.5% of total Programme costs. This amount covers 70% of the budget for such actions as co-financing requirements apply. Five joint actions on product safety have been undertaken each year that led to enforcement actions on many of the products tested. Stakeholders noted that joint actions provided participants with good knowledge of new products and new market surveillance methods and enabled them to share experiences on best practices and apply similar approaches in the Member States as well as save resources and test products which they would otherwise not have been able to test. Although the external evaluation did not provide sufficient quantitative assessment, it has to be reported that the implementation of such joint actions was considered as rather burdensome by national authorities participating, requiring for the coordination, management and reporting on the action significant resources from participating national authorities/the coordinating authority, which raised questions of efficiency over the last years. In response, under the Consumer Work Programme 2017, the financing modus of these joint actions was changed from action grants to procurement. This is expected to also address the need to support more flexible and more strategic activities and a better communication of joint action results as well as the need to have as many national market surveillance authorities on board as possible. EUR 35.1 million (37%) of the funds committed under the Consumer Programme between 2014 and 2017 were spent on activities related to Objective II, which aims to improve consumers’ education, information and awareness of their rights, to develop the evidence base for consumer policy and to provide support to consumer organisations, including taking into account the specific needs of vulnerable consumers. The following figure shows a detailed breakdown of the funds committed under Objective II of the Consumer Programme between 2014-2017 by main activity. Figure 7: Breakdown of funds committed under Objective II by type of activity, 2014-2017 In the four years under consideration, support to the EU-level consumer organisation BEUC totalled EUR 5.9 million (slightly below EUR 1.5 million per year), equalling 6.2% of total Programme costs committed. According to stakeholders, outputs and results appear to be proportionate to spending levels. The Consumer Programme achieved the benefit of an improved representation of consumer interests at EU level (average score of 3.6 on a scale of 1 to 5). A consistent funding of BEUC has led to successful functioning of the organisation, which has grown and found other sources of funding (with the Commission's core grant under the Consumer Programme constituting just over a third of the organisation’s total funding). No inefficiencies were identified. During the evaluation period, the amount committed for consumer rights and information campaigns was EUR 9 million, or 9.5% of total Programme costs. As media campaigns require a large amount of resources, the costs allocated appear in principle to be proportionate to the activities undertaken or planned, although the data on outputs and results is too fragmented to draw detailed conclusions for the campaigns funded. Two separate evaluations for the two waves of the consumer credit campaign were conducted, which both found mixed results in terms of efficiency, mainly questioning the extent to which the right people (the target group) had been reached. Important financial resources were allocated to the consumer organisations capacity building project “Consumer Champion” and the consumer education project “Consumer Classrooms”. The Consumer Champion project has ended at the beginning of 2018. A new project supporting capacity building of consumer organisations will be implemented in 2019-2020, it will keep some elements of the Consumer Champion which were most successful, especially the local courses. The Consumer Classroom project as well ended in December 2018. The Commission is considering further activities in consumer education to be carried out. The efficiency of this project targeting primarily teachers is less easy to evaluate as it is complex to assess the change in the knowledge of pupils and the value of the participation of the pupils and teachers in a European project supplementing a variety of national efforts.

Of the funds committed under the Consumer Programme between 2014 and 2017, EUR 13.0 million, or 14%, were spent on activities related to Objective III. The following figure shows a breakdown of the funds committed under Objective III of the Consumer Programme between 2014-2017 by main activity. Figure 8: Breakdown of funds committed under Objective III by type of activity, 2014-2017 During the evaluation period, the amount committed for six behavioural studies on consumer decision-making was EUR 2.4 million, equalling 2.5% of total Programme costs. Due to the large amount of resources required for behavioural research and the complexities of the testing involved, the costs can be considered to be proportionate to the activities conducted or planned. EUR 30.2 million, or 31% of the funds committed under the Consumer Programme between 2014 and 2017, were spent on activities related to Objective IV. The following figure shows a detailed breakdown of the funds committed under Objective IV of the Consumer Programme between 2014-2017 by main activity. Figure 9: Breakdown of funds committed under Objective IV by type of activity, 2014-2017 In the evaluation period, the amount committed for the ECC-Net was EUR 24.8 million, equalling 26.0% of total Programme costs. The level of co-financing for ECCs is 50% in most Member States and goes up to 65% in some cases. The 2017 status review of the ECC-Net found that it had in many ways contributed to a higher level of consumer protection in the internal market, and confirmed through stakeholder interviews that the costs for running the ECC appear to be adequate as well as “the added-value of ECCs in relation to their costs”. However, the status review noted that the level of achievement varied greatly between ECCs. Overall, consumer education and information (including the evidence base) and enforcement together account for two thirds of the total amount committed under the Consumer Programme between 2014 and 2017, in line with their key importance for a welfare-enhancing consumer market. Stakeholders assessed that the distribution of funds among the four Programme areas (product safety, consumer education/information, consumer rights and redress, and enforcement) has been largely justified given the benefits achieved (average score of 3.7 on a scale of 1 to 5). It is notable that the assessment diverged considerably by stakeholder group, with higher average assessments given by ECCs and ministries/national authorities, who are also major direct beneficiaries of Programme activities. Beyond considering the allocation by Programme area/objective, it is also of interest to analyse the allocation of funding to main activities. During the evaluation period, the activities that received the largest amount of funding (EUR 2 million or more) were: ·European Consumer Centres Network (ECC-Net) – EUR 24.8 million; ·EU consumer information/awareness raising campaigns – EUR 9.0 million; ·Consumer scoreboards and surveys – EUR 8.9 million; ·Joint cooperation and enforcement actions in the area of non-food consumer product safety – EUR 6.2 million; ·Support to EU-level consumer organisations (BEUC) – EUR 6.0 million; ·Consumer market studies – EUR 5.1 million; ·EU consumer education resources (Consumer Classroom) – EUR 3.1 million; ·Communication campaigns and actions on ADR/ODR – EUR 3.1 million; ·Online Dispute Resolution (ODR) Platform maintenance – EUR 3.0 million;

·Rapid Alert System for dangerous non-food products (RAPEX) – EUR 2.9 million; ·Behavioural studies – EUR 2.4 million; ·Consumer Protection Cooperation (CPC) Network (IT tool and support to enforcement coordination) – EUR 2.0 million. It can, therefore, be concluded that the total amount allocated to the ECC-Net is much higher than the support to public enforcement in the areas of consumer rights and product safety. The Commission finances 50% of the ECCs networks' activities, which is decisive for the activity and the very existence of the ECC-Net, at least according to the current model of co-funding. The 2017 Status Report concluded that the costs for running the ECC-Net are proportionate to the added value of its services to consumers. At the same time, the ECCs are facing the challenge of ensuring a comparable service content and quality across the network. Regarding enforcement, the EU provides a framework for enforcement cooperation as well as the IT tool used b