EUROPEAN COMMISSION 
Brussels, 11.1.2012 
SEC(2011) 1640 final 
  
COMMISSION STAFF WORKING DOCUMENT 
Bringing e-commerce benefits to consumers 
Accompanying the document 
COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 
A coherent framework to boost confidence in the Digital Single Market of e-commerce 
and other online services 
{COM(2011) 942 final} 
{SEC(2011) 1641 final}  
 
  
This document is a staff working document of the services of the European Commission. It 
does not purport to represent or pre-judge any formal position of the Commission on the 
issues discussed. 
 
EXECUTIVE SUMMARY 
 
1 This report identifies the latest trends in business-to-consumer e-commerce in the EU and 
examines the potential benefits for consumers if current obstacles are overcome and the 
true potential of e-commerce in the Single Market is fulfilled.  It is a follow up to the 
Communication1 and Staff Working Document2 on cross-border e-commerce in the EU.  
Boosting consumers' confidence in e-commer ce and the completion of  the Digital Single 
Market have been identified as two of the tw elve priority areas of action under the Single 
Market Act. The creation of a vibrant Digital Single Market is one of the seven pillars of 
the Digital Agenda for Europe which has set out e-commerce targets for 2015; 50% of 
consumers buying on-line and 20% buying on-lin e cross-border within the EU.  The 
report is based on a consumer market study on the functioning of e-commerce in goods in 
the EU and other recent studies.   
 2 During the recent years, e-commerce sales have been the main growth engine of the retail 
sector.  E-commerce is the dom inant distance sales channe l and accounts for around 4% 
of the total retail sector.  The impact of e- commerce on the whole retail sector is however 
significantly greater since consumers resear ch many more offline purchases on the 
internet, ensuring that businesses that sell onl ine exert competitive pressure on "bricks and 
mortar" shops.  Many businesses have realised  that they have to make e-commerce an 
integral part of their business model. E-co mmerce is therefore an opportunity for business 
as a whole despite the challenges it  poses to current  business models. 
 3 In the last few years, e-co mmerce has grown both domestically and cross-border.  During 
2008-2010, domestic business-to- consumer e-commerce has gr own from 28% to 36% of 
the population making an online domestic purch ase, while cross-border e-shoppers have 
only grown from 6% to 9%.
3  At a time of economic crisis when consumers and 
businesses are under tight financial constraint s, there is a shift towards e-commerce.  
Consumers are seeking the advantages offered by e-commerce, such as cheaper prices and 
wider choice, while businesses see e-comme rce as an opportunity to reach more 
consumers to grow.  According to the mark et study on e-commerce, most online shoppers 
(66%) say they are turning to e-commerce for lower prices, 50% to save time, while 47% for reasons related to choice
4.   
 4 However, despite this growth, the untappe d potential benefits of e-commerce are 
significant.  For example, in a basket of  100 goods with a median price of €112, it is 
estimated that by buying online across the EU consumers could save up to €745.  
                                                
 
1 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Co mmittee of the Regions on cross-border bu siness-to-consumer e-commerce in the 
EU. COM(2009) 557 final. 
2 Commission Staff Working Document, Report on cross-border e-commerce in the EU. SEC(2009) 283 final. 
3 Eurostat: Information society statistics (2011). Data extracted on 11 April 2011. 
4 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  This is based on a 
sample of frequent online shoppers.  Frequent shoppers were defined as respondents who bought products online 
at least once a month. 
 
 2However, there are so many obstacles that most cross-border transactions fail.  In 6 out of 
10 cases consumers are not able to complete  such cross-border purchases.  If these 
transactions were completed, consumers coul d save up to €1745, thes e savings amount to 
16%5.   
 5 Considerable welfare improvements can also be  found domestically both in terms of price 
and choice. There are savings to be made in 13 out of 15 products categories for which 
prices were collected, if pr oducts were bought from online shops  in a country rather than 
from offline shops. In  a typical shopping trip
6, consumers have at least double the 
selection when shopping domestically online ra ther than offline.  If they shop online 
across the EU they have up to 16 tim es more products to choose from. 7 
 6 The current consumer welfare gains from e-commerce in goods
8 alone in terms of lower 
online prices and wider choi ce are estimated to be around €11.7 billion, an amount 
equivalent to 0.12% of EU GDP.   If e-commerce were to grow to 15% of the total retail 
sector and Single Market barriers were eliminated, total consumer welfare gains are 
estimated to be around €204 billion, an amount equivalent with 1.7% of EU GDP9.   
 7 An assessment of the incidence of problem s when purchasing goods online and problems 
when purchasing goods offline, showed that th ere is no significant difference between the 
sales medium used and problems faced. Yet the pot ential benefits will not be realised if 
consumers and businesses refrain from buying and selling online and do not take 
advantage of the opportunities offered by the Single Market.  The Communication on 
cross-border e-commerce has identified the obstacles to cross-bor der e-commerce and a 
set of actions to address thes e.  The Commission has carried out further in-depth work to 
identify more general obstacles to e-commer ce and how these can be tackled to increase 
consumer welfare.  Many obstacles to e- commerce are common to domestic or cross-
border e-commerce. Beyond the actions identif ied in the Communication on cross-border 
e-commerce and the Digital Agenda, this repor t identifies three areas where action should 
be taken to boost e-commerce: information,  redress  and enforcement .  Actions in these 
three areas can increase consumer trust a nd confidence in online purchases.  Solutions 
may be found in providing accurate and transparent information for domestic and cross-
border offers , making available  information to retailers wishing to sell online , 
promoting fast, efficient and cheap online dispute resolution mechanisms , as well as 
better enforcement mechanisms  to ensure application of existing legisla tion concerning 
consumers and businesses in the field of e-commerce.   
 
                                                
 
5 These findings come from the following study: European Commission (2009). ‘Mystery shopping evaluation of 
cross-border e-commerce in  the EU’, YouGovPsychonomics, data collected on behalf of the European 
Commission. 
6 E.g. A shopping trip involving visits to five online and five offline shops and searching for similar goods. 
7 This estimation does not cover the whole retail market.  In  the whole retail market there is more choice offline, 
since there are far more businesses selling offline than onlin e. However, a consumer is not likely to visit or have 
information from all online and offline shops before making a purchase.  A consumer is more likely to make a 
limited number of visits to  online and offline shops. 
8 This excludes services, such buyin g flights, hotel accommodation, etc., which are a considerable part of e-
commerce. 
9 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  This is based on a 
sample of frequent online shoppers.  Frequent shoppers were defined as respondents who bought products online 
at least once a month. 
 
 38 The report shows that the information  provided to consumers on retailers' websites, as 
well as websites of information intermediaries such as price comparison websites, is frequently partial and sometimes misleading and incorrect.  Data gathered from over 260 
price comparison websites revealed that very often it is difficult for consumers to compare 
the price and quality of different  goods on offer.  In addition , most offers are domestic and 
do not reach consumers in other EU countries. 
 9 One of the main factors holding back the de velopment of e-commerce, both domestic and 
cross-border, is consumers' concern about what will happen if things go wrong.  As a 
matter of fact, the majority of online trans actions run smoothly a nd regular online cross-
border shoppers are ra ther confident in e-commerce.  However, online dispute resolution 
mechanisms  should be put in place to overcome the concerns of the majority who are 
afraid to step online cross-border. 
 10 Various recent fact-finding exercises presente d in this report show that many businesses 
are not in compliance with existing rules concerning selling and a dvertising online.  
Improvements to the general enforcement framework surrounding e-commerce will 
increase competition and consumer welf are through stamping out on bad business 
practices and increasing consumers' confidence in online transactions. 
 11 Commission services will continue to monitor and analyse the development of e-
commerce and whether consumers ar e reaping its full benefits.  
 
1) Introduction 
 
12 This report is a follow up to the Commission Communication
10 and Staff Working 
Document11 on business to consumer cross-border e-commerce in the EU.  It accompanies 
the Commission's Communication and Staff Working Document on a coherent framework 
to strengthen confidence in the Digital si ngle market of e-commerce and other online 
services 12 by providing evidence on how e-comm erce works in the EU from the 
perspective of the consumers.   Boosting consumers' confidence in e-commerce and the 
completion of the Digital Single Market have be en identified as two of the twelve priority 
areas of action under the Single Market Ac t.  If consumers and businesses see e-
commerce as a practical and viable alternative to offline retail, this will result in an increase in competition, both online and offline, as business compete to reach the marginal consumers.  In turn, this will resu lt in an increase in consumer welfare and a 
more competitive European economy. The Digita l Agenda for Europe has set out targets 
for 2015; 50% of consumers buying on-line and 20% buying on-line cross-border within 
the EU. 
 13 This report has an expanded scope from prev ious work on e-commerce since it covers in 
more detail issues that are related to dome stic e-commerce and also to the provision of 
information. The evidence presented in the report is largely based on primary data collected on behalf of Commission servi ces through a consumer market study on e-
commerce, consisting of a consumer survey, collection of price data of goods sold online 
                                                
 
10 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Commi ttee of the Regions on Cross-border bus iness to consumer e-commerce in the 
EU. COM(2009) 557 final. 
11 Commission Staff Working Document, Report on cross-border e-commerce in the EU. SEC(2009) 283 final. 
12 COM(2011)942. 
 
 4and offline, and a mystery shopping ex ercise of price comparison websites13.  The report 
is complemented by other studies, Eurostat and industry data.   
 14 The reason to examine price comparison websites in detail is that they have become a key 
source of information for consumers both in th eir online but also in their offline purchase 
decisions.  This trend seems likely to grow further.  As such information intermediaries are becoming more important in the consumer environment it is necessary to monitor and 
evaluate whether they are serving the consum er interest by providing information in a 
clear, transparent and accurate manner.   
 
15 The primary research tries to estimate the full potential of the online goods market in the 
EU and the benefits that would accrue to cons umers if this was achieved.  These benefits 
are calculated on the basis of price savings and an increa sed choice of goods available 
online and across EU borders.  In addition, the report identifies in de tail the current main 
obstacles to domestic and cross-border e- commerce aiming to identify areas where EU 
action would increase online confidence of both consumers and businesses. 
   
2) Online shopping in the EU 
 2.1 Number of online shoppers  
16 Between 2004 and 2010, the percentage of indi viduals who made an online purchase of a 
good or a service for private use in the last year, rose from 20% to 40%
14.  There are 
however considerable variations  at country level, ranging fro m 4% in Romania to 68% in 
Denmark.  In many Member States (Denma rk, Germany, France, Luxembourg, the 
Netherlands, Finland, Sweden and the UK) the figure is higher than 55%, yet in other 
Member States (Bulgaria, Gr eece, Italy, Cyprus, Estonia, Latvia, Lithuania, Hungary, 
Portugal, Romania) the figure is below 20%. 
 
                 
                                                
 
13 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".   
14 Eurostat: Information society statistics (2 011). Data extracted on 21 March 2011. 
 
 5Figure 1 - Percentage of individuals who ord ered goods or services over the Internet for 
private use in the last year (2010) 
 
Source: Eurostat, Information society statistics  (2010). Data extracted on 14 April 2010. 
 
2.2 E-commerce compared to other retail channels15 
 
17 Besides the traditional method of selling goods and services in shops, used by 73% of 
retailers in the EU, a simila r proportion (72%) mentioned using at least one off-premises 
(“distance”) sales channel. E-commerce is  the most common distance sales channel16 with 
53% of retailers selling g oods or services via the Internet to end consumers17. 
 18 Figure 2 shows the use of e-commerce by retailer s across the EU.  As before, there are big 
variations at country level.    This ranges from around 
a fifth (19%) of retailers in Romania 
selling goods or services via the Internet, to a pr oportion that is almost four times higher in the 
UK (78%). In twelve countries, more than half of all retailers use the Internet as a sales 
channel.  
 
                                                 
15 Data in section 2.2 refers to retailers employing more than 10 employees.  It comes from European 
Commission (2011). Flash Eurobarometer 300.  "Retailers' attitudes toward cross-border trade and consumer 
protection". 
16 Distance sales channels include sales conducted over the internet, phone and post. 
17 According to Eurostat Statistics in Focus 37/2010 and the Eurostat External and In tra-EU Trade Yearbook of 
2009, the intra-EU trade volume in goods was four the volume of trade in services in 2008. Unit: Percentage of Individuals
68 67 67 66 
60 59 59 
56 
42 
40 
38 38
36
33
29
27 27
24
18 1817 17
15 15 
12 11 
54
0 10 20 30 40 50 60 70 80 
DK NL UK SE LU DE FI FR AU EU 
 27BE MT IE SK PO CZ SI ES CY HU EE LV IT PT EL LT BG RO
 
 6Figure 2 - Percentage of retailers selling online (2010) 
Unit: Percentage of Retailers
78
65
58 5756 55 55 5553 53 53 5250 50 50 49 4947
43
41
36 35
33
31
282624
19
0102030405060708090
UK  
IE  
AT  
DK  
SI  
EL  
EE  
FR  
DE  
EU27
CZ  
NL  
ES  
MT  
SE  
IT  
HU  
FI  
LU  
SK  
BE  
LT  
CY  
PT  
PL  
BG  
LV  
RO  
 
 
Source: European Commission (2011). Eurobarometer 300, "Retailers’ attitudes towards cross-border trade and 
consumer protection" 
 
  
2.3 Volume/value of e-commerce   
 
19 The EU business to consumer e-commerce market  is estimated to be  around €91 billion in 
2010
18.  This represents around 3.5% of the total EU retail sector.  The variations across 
European countries are very large.    Th e leading countries are the UK (7.9%), Denmark 
(5.4%), Finland and Sweden (4%) and France and Germany (3.9%).  In other laggard 
countries, e-commerce barely regi sters as a share of the total retail sector.  The UK has the 
lion's share of the EU e-commerce market w ith 34.6% of EU total, followed by Germany 
(19.6%) and France (19.1%).  The second group of  countries with lowe r percentage shares 
of the EU e-commerce market is led by the Netherlands (4%), Spain (3.5%), Italy (3.3%) 
and Sweden (2.9%). 
 
2.4 Consumers buying cross-border 
 
20 In total, 40% of EU consumer s made an online purchase of a good or a service last year.  
However, most of these purchases were domes tic as only 9% of EU consumers made a 
cross-border purchase online (figure 3). Concerning cross-borde r purchases, country 
                                                 
18 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". Based on data from 
Euromonitor covering 24 Member states (excluding C yprus, Malta and Luxembourg).  The definition of retail 
used for this calculation excludes specialist retailers of motor vehicles, motorcycles, vehicle parts, fuel, and 
foodservice, rental and hire  and wholesale industries. 
 
 7variations are rather significant, with six countries at  20% or higher (Belgium, Denmark, 
Luxembourg, Malta, Austria and Finland) and ei ght countries below 5% (Bulgaria, Czech 
Republic, Greece, Italy, Lithuania, H ungary, Poland and Romania).    
 
Figure 3 – Individuals who ord ered goods or services over the Internet from sellers from 
other EU countries in the last 12 months 
Unit: Percentage of Individuals
53
35
2928
2120
18
1615
1312
10 109988776
44332221
0102030405060
LU
MT
AT
DK
FI
BE
IE
FR
CY
SE
NL
SI
UK
EU27
SK
DE
EE
ES
LV
PO
EL
IT
LT
HU
BG
CZ
PL
RO
 
Source: Eurostat, Information society statistics  (2010). Data extracted on 14 April 2010. 
 
 21 One in three (32%) online shoppers
19 said that they bought goods  from other countries in 
the EU in 2010.  Online shoppers in Malta (9 4%), Luxembourg (88% ), Cyprus (83%), 
Austria (77%), Ireland (68%) and Belgium ( 54%), are the most likely to make cross-
border purchases of goods in the EU.  In addition to the market size of different countries, 
geographic location and knowledge of the la nguage in which offers are made are 
important factors underpinning cr oss-border flows of trade.  For a full list of e-commerce 
cross-border flows see figure 4 in Annex 1.  The countries  that attract most online 
shoppers from other EU countries are Germa ny (27%), the UK (24%) and France (14%), 
which are also the most mature e-commerce economies in Europe.20  In addition many 
consumers in other EU countries speak Germ an, English or French. Two in three EU 
online cross-border shoppers bought goods fr om websites available in English, 21% 
bought from websites in German and 14% bought  from websites in French.   56% of 
European consumers use another language th an their own for searching or buying goods 
and services online.21 
                                                 
19 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". The sample size for 
online shoppers is 25940 and includes only purchases of goods. 
20 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". The sample size for 
online shoppers is 25940 and includes only purchases of goods. 
21 European Commission (2011).  Flash Eurobarometer 31, "User language preferences online".   
 
 8 
22 It is worth noting that 18% of online shoppers  said that they bought goods from countries 
outside the EU in 2010.  25% of online s hoppers bought a good from a US website, while 
17% said that they bought a good from a Chinese website.  
 
2.5 Businesses selling cross-border22 
 
23 In 2010, nearly three out of four EU (74%) re tailers did not sell cros s-border in other EU 
countries (figure 5 and figure 6 below). This is  slightly higher than  the situation in 2009 
when 71% said they did not se ll cross-border but similar to  the level reco rded in 2005 
(75%).  Only one in five EU (21%) retailer s sell their goods or services in other EU 
countries.  From the ones selli ng cross-border, most sell in more than four countries 
(62%), 29% sell in two-three countries whil e 9% sell only in one  country. Again, large 
differences between countries are observed.   
 
Figure 5 – Number of countries to wh ich retailers sell cross-border (2010) 
Unit: Percentege of Retailers
0%10%20%30%40%50%60%
LU
AT
EL
IS
SK
BE
IT
SI
NL
DKUK
MT
IE
EE
LT
DE
EU27
HU
CY
SE
LV
CZ
FR
ES
NO
PT
BG
FI
PL
RO
1 2 or 3 4+ 
 
Source:  European Commission (2011).  Eurobarometer 300 , "Retailers’ attitudes towards cross-border trade and 
consumer protection".  
                                                 
22 Data in section 2.5  comes from European Commission (2011). Flash Eurobarometer 300.  "Retailers' attitudes 
toward cross-border trade and consumer protection". The sample in this Eurobarometer is made of retailers 
employing more than 10 employees.  
 
 9Figure 6 – Number of other EU countries wh ere retailers actively market/advertise to 
final  
Unit: Percentage of Retailers
677269
55
567
141013
977 5
201020082006
none 1 2 or 3 4+ dk/na
 
 
Source: European Commissi on (2011). Eurobarometer 300 "Retailers’ a ttitudes towards cross-border trade and 
consumer protection" 
 
24 In four countries with relatively small economies, (Greece, Luxembourg, Austria and 
Slovakia), 30% or more retailers sell their products cross-border wh ile in four other 
countries (Bulgaria, Finland, Po land and Romania), less than  15% of retailers sell cross-
border.    It is interesting to note that the countries with the biggest e-commerce markets 
(UK, France and Germany) are around the EU average (21%).  Even in these countries, 
many retailers are not taking advantage of the strong interest that consumers from other 
EU countries have to shop cross-border and the fact that many consumers are willing and 
able to buy in a language othe r than their own such as Engl ish, German and French.  It 
seems that many retailers in the biggest e-commerce markets are content to focus on 
domestic sales.  The benefits for the minority  of businesses who do se ll cross-border seem 
clear however.  56% of retail ers using e-commerce and selli ng cross-border, said that 
more than 10% of their total e-commerce turnover came from sales to consumers in other EU countries. 
  
2.7 Spending and payment methods
23 
 
25 In 2010, EU online consumers spent around €1163 purchasing goods online.    Across the 
EU, there are big variations at national leve l.  Online shoppers in Denmark, Germany and 
                                                 
23 Findings in this section concern purchases of goods over €30, exclude food and groceries as well as services  
Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  
 
 10the UK spend the most buying goods online. EU consumers shopping only domestically 
spend on average €778 while consumers who also shop cross-border spend on average 
€1667 (includes both domestic and cross-border transactions). (see figure 7 and 8 below). 
Online cross-border shoppers spent on av erage 693€ purchasing goods from other 
countries. Consumers in Austria, Bulgaria, Es tonia, Italy, Cyprus , Lithuania, Latvia, 
Luxembourg, Malta, Portugal, Romania and Slov enia spend more in other countries than 
in their own countries. 
 
Figure 7 – Euro spent online purchasing products  from websites in origin country in the 
last 12 months (Remember: this does not include money spent for services such as 
music/film downloads, travel,  entertainment, banking, insurance, and other financial 
services)  
Unit: Euro
020040060080010001200140016001800
CY
DK
DE
ES
UK
NL
EL
IT
FR
EU27
CZ
AT
FI
IE
SE
LT
BE
PL
PT
SK
RO
SI
HU
LV
EE
BG
MT
LU
 
Basis: Domestic Online Shoppers 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
          
 
 11Figure 8 – Euro spent online purchasing pr oducts from websites in another EU27 
country in the last 12 months (Remember: this does not incl ude money spent for services 
such as music/film downloads, travel, en tertainment, banking, insurance, and other 
financial services)  
Unit: Euro
0200400600800100012001400160018002000
CY
LT
IT
ES
DK
LU
EL
NL
IE
EU27
AT
UK
MT
EE
DE
PT
PL
RO
LV
SI
BESE
CZ
BG
FR
FI
SK
HU
 
Basis: Cross-Bord er Online Shoppers 
  
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
26 In their last online purchase concerning a good over €3024, online shoppers spent on 
average around €255.  This va ries between east Europe25 where spending is around €196, 
while in west Europe it is around €268. 
 27 The median amount spent online is highest for cars and other motor vehicles (€330), 
furniture (€304), electrical household appliances (€181), ch ild care arti cles (€176), 
electronic equipment (€165), sports and outdoor  equipment (€145), and clothes shoes and 
jewellery (€100). For a full breakdown of spending on online goods see figure 9 below. 
 
       
                                                
 
24 Excluding food and groceries 
25 Excluding the Czech Republic 
 
 12Figure 9 – Median amount of money spent online by product category 
Unit: Euro
.00 50.00 100.00 150.00 200.00 250.00 300.00 350.00Other (Specify)BooksCDs/DVDsOver the counter medicines (sold without prescription)Computer software (incl. games)Prescribed medicinesChildren’s products/toysCosmeticsClothes, shoes and jewelleryGardening suppliesTools and do-it-yourself suppliesCar parts, motor vehicle partsSports and outdoor equipmentElectronic equipment (incl. computer, phone, camera)Child care articlesElectrical household applianceFurnitureCar, motor vehicle
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
28 Online shoppers use a variety of paymen t methods to carry out their e-commerce 
transactions. Most online transactions (45%) are concluded using credit/charge cards.  
Online payment systems (e.g. PayPal, Smart2 Pay, Webmoney, Giropay, iDeal) are used 
by over one in three online shoppers (36%).  Other widely used payment methods are 
bank/credit transfer (31%), cash on deliver y (20%) and debit cards (18%). Cash on 
delivery is a very popular means of paymen t in Bulgaria, the Czech Republic, Greece, 
Hungary, Poland, Romania, Slovakia and Sloven ia, with over 35% of consumers using 
this.  In some of these countri es this percentage reaches up to  70%.  The use of debit cards 
is high in Bulgaria, Spain and Sweden, 25 %-30%, while in the UK and Ireland it is 35% 
or more.  Less widely used methods are dir ect debit (11%), cheque payments (2%) and 
payments by mobile phone (1%).  (see figure 10 below) 
 
     
 
      
 
 13Figure 10 – Payments methods used for on line purchases over the last 12 months 
Unit: Percentage of Online Shoppers
2.71.21.810.717.719.731.036.245.3
.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0 50.0OtherPayment by mobile phone (for
example PayMo)ChequeDirect DebitDebit CardCash on DeliveryBank/credit TransferOnline payment systems such as
PayPal, Smart2Pay, Webmoney,
Giropay, iDEALCredit/Charge Card
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
3) Untapped potential  
29 Consumers can benefit from e-commerce in te rms of wider choice and lower prices, while 
business can use e-commerce to reach a broader group of consumers, either domestically or cross-border. Despite the st rong growth in e-commerce in the last few years, it is 
evident that the full potential of this sales channel has not been re ached.  There are still 
considerable obstacles holding b ack both consumers and businesses. 
 
3.1 Why consumers buy online 
 
30 Consumers shop online for a variety of reasons  ranging from cheaper products to finding 
better quality products.  For fr equent online shoppers, the do minant factor for shopping 
online seems to be price, followed by perceive d savings in time, the possibility to carry 
out price comparisons easily, the flexibility in ordering any time of the day/week and finding a wider selection online.  
 
 14Figure 11: Consumer survey – What are your three most important REASONS for 
buying products online? 
 
Note: Based on frequent online shopper subsample (N=13872) 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
31 A closer investigation at country  level reveals that there are co nsiderable differences in the 
demand-side drivers of e-commerce across the EU.  In some countries, such as Greece, 
Cyprus, Luxembourg, Hungary, Malta, Poland, Portugal, Romania, Slovenia and Sweden, 
the availability of specific products online is a key factor driving e-commerce.  While the 
EU average is 22%, in these countries 30% or more consumers sa y that finding certain 
products is a key reason for them shopping online.  Also, in some countries (Luxembourg, Malta and Poland) a considerab le group of consumers (25% or more compared to an 
average of 19%) says that one of the main r easons for shopping online is the wider choice 
found there. 
 
3.2 Savings     
 
32 According to consumers' own perceptions, th ere are significant sa vings shopping online.  
Consumers estimated that on th eir last online purchase th ey saved around €136 compared 
to buying the same product in a shop
26.  Based on price data collected for a basket of 30 
goods sold domestically, incl uding delivery costs, there are savings b uying products 
online rather than offline, in 13 out of th e 15 product sub-categories for which price data 
were collected.  Excluding food products, th e online prices of these goods, including 
delivery costs, are cheaper by 2%.  From the basket of these 30 products there is no correlation between the offline price of a product and the poten tial savings that could have 
been made by purchasing the same product onl ine.  The biggest savings were found on 
products with relatively lowe r prices (excluding food products ).  The product categories 
where savings of at least 5% can be f ound online are women's fragrances, in-car 
navigation, LCD TVs, and mobile phones.
 27 
 33 Consumers can also find price savings by sh opping cross-border.  For example, in a 
basket covering 100 go ods, with a median price of €112, it  is estimated that by buying 
online cross-border, consumers could save up to  €745.  This is based on  transactions that 
                                                
 
26 This refers to purchases of goods worth over €30, excludes food and groceries as well as services. 
27 Findings in this paragraph concern purchases of goods over €30, excludes food and groceries as well as 
services.  Civic Consulting (2011). "Consumer ma rket study on the functioning of e-commerce". 
 
 15could have actually been completed.  However,  in the considerably fragmented EU online 
marketplace, most online cross-border tran sactions attempted by consumers cannot be 
completed due to a variety of obstacles.  In 6 out of 10 cases consumers are not able to complete such cross-border purchases.  In  the same example, if it was possible to 
complete these transactions and take advant age of all cross-border offers, a consumer 
could save up to €1746.
28   
 34 The advantages of e-commerce are found not only  in price but also choice.  In a typical 
shopping trip
29, consumers have a wider choice when shopping online, as they can access 
a much wider selection of goods.  Based on the data collected in the market study30 
consumers have much more choice when buying, from a limited number of shops, online 
rather than offline.  At national level, it is estimated that consumers have 2.5 times more 
choice when shopping online.  If one considers, for the same product categories, the choice that is available cross-border on and o ffline, consumers have 16 times more choice 
with the choice offered by online shops acros s Europe. (Figure 12 and 13 in Annex 1).  
Interviews with industry stakeholders reveal ed that more popular product ranges can be 
found both online and offline, yet due to cons traints on shelf space, less popular products 
can be found only online.  
 
3.3 Overall savings 
 
35 The current consumer welfare gains from e-commerce in goods
31 alone in terms of lower 
online prices and wider choi ce are estimated to be around €11.7 billion, an amount 
equivalent to 0.12% of EU GDP.  Under a scenario where e-commerce grows to 15% of 
the total retail sector and barriers to the Digital Single Market are eliminated, total 
consumer welfare gains are estimated to be around €204 billion, an amount 
equivalent to 1.7% of EU GDP .  Yet these benefits will not be realised if consumers and 
businesses refrain from buying and selling on line and do not take advantage of the 
opportunities offered by the Single Market.   
 36 It is important to note that the above findings hold only when  searching for products in a 
limited number of online and offline shops, some thing that reflects a reasonable pattern of 
consumer behaviour.  If one ta kes the entirety of the retail sector, a consumer has a bigger 
choice offline since most retailers sell only offline.  This is supported by data from 
another recent case study on the pric es of electrical and electronic goods. 
 
3.4 Case study on electrical and electronic goods
32 
 
37 An analysis of online and o ffline sales and prices of goods in six product categories 
(digital cameras, flat screen televisions, media players, PC notebooks, refrigerators and 
irons) in six Member States (Germany, Fran ce, Italy, the Netherlands, Poland and the UK) 
showed that the number of models available online is, in all cases, lower than the number 
of individual models availabl e through offline channels. It also showed that the vast 
                                                 
28 YouGov Psychonomics (2009).  "Mystery shopping evaluation of cross-border e-commerce in the EU". 
29 E.g. A shopping trip involving visits to five online and five offline shops and searching for similar goods. 
30 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
31 Findings in this paragraph concern purchases of goods over €30, excludes food and groceries as well as 
services.  Civic Consulting (2011). "Consumer ma rket study on the functioning of e-commerce". 
32 ECORYS (forthcoming). "Study on the Competitiveness of EU electrical and electronics goods markets with a 
focus on pricing and pricing strategies".  
 
 16majority of sales through bot h channels are accounted for by models that are available 
both online and offline. Particularly for online sales, at least 95% comes from models available both online and offlin e. While this suggests that in the case of electronic and 
electrical goods, the main role of online sales is an alternativ e sales channel of models that 
are also available offline rather than a provide r of a greater range of products, the range of 
models available from one individual online sh op may still be much greater than available 
from one individual offline shop (or even from  all shops within a particular region).  
 38 The analysis also found that  online prices in 2008-2009 we re on average lower than 
offline prices and that across countries ther e is more convergence of online than offline 
prices. However, there are also a number of  models for which the online price was higher 
than the offline price. In fact, there seem to be different  degrees of price dispersion (online 
vs offline) across countries for particular  products and different  degrees of price 
dispersion across products for individual coun tries. Moreover, within countries there 
tended to be more convergence between onlin e and offline prices for models that are 
available in different countries  than for 'local' models.  
 39 Not surprisingly, consumers' online purchases tend to be oriented towards those models 
for which savings from online purchases are greater than average savings.   
 
40 When it comes to saving time by buying online,  despite the fact that 50% of online 
shoppers say that one of the most important  reasons for shopping online are time savings, 
a comparison on the estimated time spent s hopping between online and offline shoppers, 
reveals that this is approximately the same. According to their own estimates (including 
time spent researching the purch ase), online shoppers  spent around 70 minutes before they 
completed their last purchase of a good onlin e, while offline shoppers spent around 75 
minutes before purchasing a good in a shop33.  
 41 It is interesting to note that there are some clear differences between countries in east and 
west Europe. Consumers in east Europe s eem to spend more time shopping online (74 
minutes compared to 70 which is the average) but they seem to spend less time shopping offline (73 minutes compared to 75 which is the average).  At the same time, consumers in west Europe seem to spend less time s hopping online than the average (69 minutes 
compared to 70 which is the average) but th ey spend more time shopping offline than the 
average (84 minutes compared to 75 which is the average).   
 
3.5 Prospects for e-commerce 
 
42 The prospects for growth in online sales are bright despite the many obstacles consumers 
and businesses face.  Illustratively, in a recen t study around one in two retailers in the UK 
disagreed that online commerce will never be  more than 10-15% of overall retail sales.
34 
 
3.5.1 Business strategies 
 
43 E-commerce is having a significant transforma tional impact on the retail sector.  It is 
increasingly becoming an integrated part of retailers' business strategies.  Retailers are 
realising that, despite the initial disrupti on and challenges associated with change, e-
commerce offers many opportunities.   Besides the purely online retailers who rely solely 
                                                 
33 This refers to purchases of goods worth more than €30 and excluding food and groceries. 
34 RSR sponsored by Oracle and ATG. "After the storm: Connecting with the new online consumer" (2011). 
 
 17on e-commerce as a sales channel, many busin esses are using e-commerce as part of a 
multi-channel business strategy to reach consumers and sell their products.  In a recent worldwide business survey, ar ound 80% of businesses said that the future of online 
commerce lies more with cross-channel or merged channel capabilities
35.  The same 
survey revealed that for 64% of businesses their main challenge was to keep up with 
evolving consumer shopping patterns such as  social networks, mobile, etc. 76% of 
retailers responded that less th an 10% of their annual sales come from online channels 
while 65% said that less than 2% comes from  mobile.  Yet, the pr ospects for e-commerce 
are positive since when the same businesses ar e asked to look ahea d three years 21% of 
them predict that at least 25% or more of their annual sales will come from e-commerce, 
while 24% believe more than 15% will come from mobile commerce.  
 
3.5.2 Cross-border36 
 
44 One in seven consumers (14%) say that they  intend to spend more in cross-border 
purchases in the coming year, rather than what  they spent during the previous year.  This 
proportion has remained relatively stable since 2006.   
 45 At the same time, we see more and more c onsumers willing to shop cross-border.  Since 
2008, there has been a big increase (13%) in  the percentage of consumers who are 
interested in making a cross- border transaction in the ne xt 12 months.  In 2010, 46% of 
consumers said that they are interested in ma king a cross-border transa ction in the next 12 
months whereas in 2008 and 2006, the co rresponding figure stood at 33%. The large 
majority of consumers who have tried cross- border shopping intend to try it again. 72% of 
those consumers who have made at least one cross-border purchase in the past said that 
they are interested in making a cross- border transaction in the next year. 
 46 On the business side, signs are not as positive since many obstacles surrounding e-
commerce are dissuading many busine sses from selling cross-border.
37 One in three 
retailers with more than 10 employees (EB 300) would be interested in making cross-
border sales in the EU, if the laws regulating transactions wi th consumers were the same 
across the EU.  However, a parallel can be drawn with consumer be haviour; retailers who 
have already sold products in other countries  of the EU are more positively inclined. The 
big majority of retailers that have made a cr oss-border sale (70%) w ould be interested in 
making cross-border sales to more countries if  the laws regulating consumer transactions 
were the same across the EU. The corresponding value for reta ilers who do not sell cross-
border is 23%. Moreover, four in 10 businesses selling cross- border or interested in doing 
so (EB 321), would increase thei r cross-border operations if they could chose one single 
European contract law; 81% of thos e would sell to more EU countries.  
 
                                                 
35 RSR sponsored by Oracle and ATG. "After the storm: Connecting with the new online consumer" (2011). 
36 Data concerning consumers comes from: European Commission (2011). Eurobarometer 299. "Consumer 
attitudes towards cross-border trade and consumer protection".  Data concerning businesses comes from two Eurobarometers:  
- European Commission (2011). Flash Eurobarometer 300.  "Retailers' attitudes toward  cross-border trade and 
consumer protection".  The sample in this Eurobarometer is made of retailers employing more than 10 employees. 
- European Commission (2011). Flash Eurobarometer 321. "European contract law in consumer transactions". 
The sample in this Eurobarometer is made of micro, small, medium and large retailers who are either conducting cross-border business-to-consumer transactions  or are planning to do so in the future. 
37 At the same time, it should be acknowledged that some businesses are not interested in selling cross-border. 
 
 183.5.3 Mobile-commerce, Social-commerce 
 
47 At the moment, both mobile and social commer ce in Europe are at an embryonic stage.  
Just 6% of consumers made an online purch ase of a good using their mobile phone, and 
2% bought a good through a social network website.  
 48 However, the prospects for mobile commerce seem to be bright as more and more 
consumers are buying smart phones and other mob ile devices. According to industry data, 
shipments of smart phones overtook shipments of personal computers in the fourth quarter 
of 2010. Shipments of smart phones were aroun d 101 million during the fourth quarter of 
2010, while shipments of personal computers were around 92 million
38. It is estimated 
that, in 2011, the worldwide smart phone market will grow by nearly 50% and smart phone vendors will ship more than 450 million smart phones, compared to the 303.4 million units shipped in 2010
39. It is expected that by 2015 total smart phone shipments 
will reach 925.7 million units.40  
 49 In 2010, three of the top five acquired mob ile devices in EU5 (Germany, France, Italy, 
Spain, United Kingdom) were smart phones.  In the beginning of 2011, smart phone 
adoption reached 38% of the population over 13 in Spain (10% yearly increase) the 
leading country in smart phone adoption in Eu rope.  Spain was clos ely followed by Italy 
and the United Kingdom.
41 
 50 The spread of smart phones opens many opp ortunities to consum ers and businesses. 
Businesses are already advertising their goods and services on mobile devices and using 
these devices as a tool to attract c onsumers. Smart phones can have a strong 
transformative effect on commerce by enab ling mobile transactions, identifying store 
locations, serving as a platform for compar isons of information on prices, quality and 
product specifications, etc.   
 51 In a recent global business survey, 62% of re tailers of questioned businesses said that 
mobile commerce represents a big untapped pot ential for their company and 45% said the 
same about social networks.
42  
 52 In a recent survey, 7% of respondents said th at, they were likely to  use their mobile phone 
to find information about a product they wanted  to buy in 2011, while 6% said they were 
likely to use their mobile phone to buy a product online in 2011.
43   
 53 Social commerce is the use of social media in  the context of e-commerce.  At the end of 
2010, the monthly penetration of social networks  in Europe reached 84% of al European 
internet users.
44 Many brands and retailers have began using social media in various ways 
such as selling directly on so cial media sites, using them to advertise their products and 
drive traffic to their websites, or receive f eedback from existing or potential customers.  
                                                 
38 http://www.idc.com/getdoc.jsp?containerId=prUS22689111 , 
http://www.idc.com/about/viewpressrel ease.jsp?containerId=prUS22653511  
39 http://www.idc.com/getdoc.jsp?containerId=prUS22762811  
40 http://www.idc.com/getdoc.jsp?containerId=227367  
41 comScore (February, 2011) .  "The comScore 2010 Mo bile Year in Review".  
42 RSR sponsored by Oracle and ATG (2011). "After the storm: Connecting with the new online consumer". 
43 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  
44 The comScore 2010 Europe Digital Year in Review. comScore (February, 2011).  This covers 14 EU countries 
(AT, BE, DK, FI, FR, DE, IE, IT, NED, PL, PT, ES, SE, UK). 
 
 19Despite the relatively small size of the soci al commerce market at present, the high 
penetration of social networks provides pr omises for social commerce for the future. 
 
4) Consumer behaviour: drivers , constraints and problems 
 
4.1 Consumer research and purchase behaviour 
 
54 The internet has changed fundamentally  how consumers shop and how businesses 
advertise and sell their goods and services online.  It ha s created innovative ways of 
organising, accessing, sharing and evaluating information such as prices, technical 
product characteristics, shop openi ng hours, quality reviews, et c.  Search engines, price 
comparison websites, product comparison sites and consumer reviews are tools that are 
now used widely and are becoming embedd ed in consumer behaviour and business 
models.   
 
4.1.1  Research behaviour45 
55 Online shoppers use a variety of research me thods to inform their purchase decisions 
before they buy goods online. In their first th ree steps during their research, 31% visited 
sellers' websites, 30% of used a search e ngine, 27% used a price comparison website and 
24% visited an online market place while 24% read customer reviews.  Other online and offline sources of information were also used  but to a lesser extent . (See figure 14 below).  
 
Figure 14 – Research methods used before purchasing online a product
 
Unit: Percentage of Online Shoppers
31%
30%
27%
24%
24%
22%
18%
16%
14%
14%
8%
5%
5%
4%
4%
4%
4%
10%
0% 5% 10% 15% 20% 25% 30% 35%Visited seller websites
Searched using a general search engine 
Searched using a price comparison website
Read customer reviews online
Visited online market places for new products
Visited manufacturer/brand websites
Visited shops in person
Discussed with friends, colleagues
Read, heard or viewed reports online
Reviewed mail order catalogue in print
Read, heard or viewed online advertisements
Contacted online or phone customer service
Read, heard or viewed reports in print/radio/TV
Read, heard or viewed advertisements in print/radio/TV
Read independent consumer or testing magazine in print
Visited independent advice website
Visited social networking sites
Other
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
                                                 
45 Data on this section are from Civic Consulting (2011). "Consumer market study on the functioning of e-
commerce". 
 
 2056 A closer look at consumer be haviour reveals that  there are differences in research 
behaviour across countries but also betw een frequent and occasional online shoppers46.   
Frequent online shoppers prefer to use genera l search engines while occasional shoppers 
are more likely to search for information on ma nufacturers' and brand websites.  Frequent 
online shoppers also use online marketplaces th at sell new products not just to purchase 
goods but also to get information.  Consumers in east Europe are generally more likely to 
use online consumer reviews for information. Anot her information tool that is used widely 
in the EU is price comparison websites.  F our in five EU online consumers (81%) have 
used a price comparison website in 2010. 
 
57 The research behaviour of online consumers is  not limited to using onl ine tools.  Nearly 
one in two (47%) used at least one offline re search method before making their last online 
purchase. 18% of online shoppers visited a shop in person before making an online 
purchase. At the same time, of fline shoppers are using online t ools for their research.  For 
their last purchase, nearly one in two off line shoppers (49%) used  at least one online 
research method.  Some of the most commonl y used online research methods by offline 
shoppers are: visits to sellers' websites ( 15%), search engines (15%), online consumer 
reviews (14%), price comparison websites (1 3%) and visits to manufacturers'/brand 
websites (13%). This cross-channel research  behaviour acts as an added incentive for 
businesses, both online and offlin e, to compete in order to reach the marginal consumer.   
As competition intensifies and e-commerce becomes a viable alternative it increases consumer welfare for both online and offlin e consumers. Figure 15 below summarises the 
research behaviour of respondents to this  making an offline purchase of a product. 
 
 
                      
                                                
 
46 For the purposes of this survey, "frequent online shoppers" were respondents who bought products online at 
least one a month, while "occasional online shoppers" were respondents who purchased products online less than 
once a month, but did buy online at least once during the last 12 months (December 2009 – December 2010). 
 
 21Figure 15 – Research methods used before purchasing offline a product  
 
Unit: Percentage of Individuals
53%
39%
19%
15%
15%
15%
14%
13%
13%
12%
11%
8%
8%
7%
5%
3%
3%
3%
14%0% 10% 20% 30% 40% 50% 60%
Visited shops in person
I did not take any other action to research this online purchase
Discussed with friends, colleagues
Reviewed mail order catalogue in print
Visited seller websites
Searched using a general search engine
Read customer reviews online
Visited manufacturer/brand websites
Searched using a price co,parison website
Visited online market places for nez products
Read, heard or viewed reports online
Read, heard or viewed online advertisements
Read, heard or viewed adverisements in print/radio/TV
Read, heard or viewed reports in print/radio/TV
Read indipendent consumer or testing ,agawine in print
Visited social networking sites
Contacted online or phone customer service
Visited independent advice website
Other
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  
 
4.2 Price Comparison Websites47 
 
58 As seen, many consumers use intermediaries su ch as search engines, price comparison 
websites and online marketplaces to inform th emselves before making an online or offline 
purchase.  From those consumers using pri ce comparison websites, 56% use them because 
they are the quickest way to compare price, 51% use them to find the cheapest prices, 
22% find out more about the range of offe rs, 16% to find information about specific 
products, and 13% to find customer comments, product reviews and ratings.  Therefore, it 
is important that these intermediaries and the retailers that appear on them provide 
information in a clear, transparent, and accurate form.  The market study included a consumer survey, a mystery shopping study and a price collection exer cise that looked 
into the business practices of price compar ison websites and examined how well they 
serve consumers' interests.  
 59 A comparison of the average of cheapest pr ices found on price comp arison websites and 
the average of the cheapest onl ine prices found through the pric e data collection exercise 
revealed that there important savings can be  found on price comparison websites.  Once 
aggregated across countries, for 10 products  defined at brand/model level, price 
comparison websites often offered savings by  more than 5%.  Since the market study 
                                                
 
47 Data in this section comes from Civic Consulting (2011). "Consumer market study on the functioning of e-
commerce". 
 
 22found that the online prices ar e generally cheaper than offl ine prices, the savings from 
price comparison websites are potentially higher if compared to offline shopping. 
 60 Eight out of ten online consumers use pr ice comparison websites in their shopping 
decisions.  Yet, a recent mystery shopping ex ercise has shown that  despite the high 
numbers of consumers using such information intermediaries, cross-border offers are not 
reaching most consumers since the big major ity of price comparison websites (86%) are 
available only in one language  and the majority (83%) do not provide the option to choose 
offers from other countries.  Only 27% of retailers found on price comparison websites 
were registered in other countries. 
 61 It is disappointing that many price comparis on websites are not performing very well in 
terms of the information they provide to consumers.  Contrary to the provisions of the E-commerce Directive
48, many price comparison websites (5 3%) do not provide their full 
business address.  Other deficiencies in information provision are observed on delivery 
time and product availability.  Only 20% of price comparison websites provided information on delivery time on their results page, while 80% did not do so.  Concerning 
product availability, most pr ice comparison websites (62 %) did not provide any such 
information. 
 62 Many price comparison websites suffer from lack of transparency concerning their 
business model, information on prices and ranki ng of offers.  Just one in two (52%) price 
comparison websites have information on their business model.  Even when they do have 
such information, in 60% of cases they did not indicate clearly if the retailers appearing on 
the specific price comparison website pay to  have their products listed.  18% did not 
provide very clear information on why some retailers are list ed or not, while 66% did not 
provide any such information at all.  
 63 In most cases (73%), there was no clear information on how ofte n price comparison 
websites update their prices.  In 44% of cases it was unclear whether the information provided on price comparison websites includes VAT and any other taxes.  In 51% of 
cases details of the delivery costs were not provided. 
 64 A significant percentage of price comparison websites perform sub-optimally in one of 
their major functions, the presen tation of prices. Two out of tested three price comparison 
websites (68%) did not provide any informati on about the default ranking of the search 
results.  Even when the mystery shoppers tr ied to rank results according to the cheapest 
offer, in one in three cases (33%) they found it difficult or even impossible to do so. 
 65 Using the default view of the price comparis on websites, the first offer was the cheapest 
only in 38% of trials.  Using the lowest pric e view, the cheapest correct offer was not the 
first listed offer in one in two trials (53% ).  The cheapest correct offer was the first 
product displayed in less than ha lf trials (47%).In 15% of trials, the ch eapest correct offer 
was not even listed at all on the first page of results. 
 
 
                                                
 
48 Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects 
of information society services, in particular electronic commerce, in the Internal Market ('Directive on 
electronic commerce') 
 
 
 23Figure 16: Rank of cheapest of fer after adjusting to rank according to lowest price  
 
What is the rank of the cheapest correct offer?
122
68 66
3 2 2 7 3 1 1 0 81 9 1 1 1 4 991 0 7 784512 4
552147%
11%
6%6%3%2%3%1%1% 2%1% 1%1%1% 1%1% 1% 1%0% 0%11%
0%
0100200300400500600
1234567891011121314151617181920>20
Not listedNumber of trial s
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
66 Price comparison websites provided the final pr ice including VAT and other taxes in 36% 
of tests, while they provided information on VAT, other taxes and delivery costs only in 
19% of trials.  Even whey they did provide information on VAT, other taxes and delivery 
costs, the final price was different on retailer s' websites in 36% of cas es.  It is not very 
often that price comparison websites provide information on the availability of specific 
products (only 38% of cases) or de livery time (only 20% of cases).  
 
 24Figure 17: Provision of informatio n on PCW: Price information  
Cheapest Offer: What type of price information is provided on the result page if PCW?
Price(unclear if VAT and other 
taxes are included), 44%
Price(including VAT and other 
taxes), 36%Price(excluding VAT and other 
taxes), 1%Price(including VAT, ther taxes, 
and delivery costs), 19%
 
Note: “Price (unclear if VAT is included)” refe rs to cases when the PCW provided a price 
without further information. It was therefore unclear whether VAT, other taxes or delivery costs are included or not.  
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
67 The majority of consumers using price compar ison websites do not feel  misled (70%), yet 
a significant proportion feel misled (12%) or can not tell whether they were misled or not 
(18%).  Young consumers (18-24 years) an d consumers with postgraduate studies 
reported more often than others that they fe lt misled.  From those that felt misled, 49% 
said they found a cheaper price elsewhere, 32% said that the i ndicated price did not 
correspond to the price on the se ller's website and 16% said that the product information 
was not correct. 
 68 Since consumers have demonstrably the tendency to focus on the initial price of what 
appears to be the cheapest offer, businesses ha ve an incentive to adopt  similar strategies 
and exclude add-on costs from the initial offer.  Therefore, it is likely that consumers find 
it very difficult to choose meaningfully be tween different products since many of the 
initial offers do not reveal the end price that consumers have to pay.   The way offers are 
presented has a marked effect on consumer  behaviour and has been shown to cause 
considerable consumer detriment.  The pr ovision of prices and other key information 
should be offered upfront in a clear and simp le manner so as not to mislead consumers. 
 
69 A study carried out by the Office of Fair Trading in the UK (OFT), found that many 
consumers limited their search to one price comparison website.  If consumers limited their search to one of ten price comparison websites, they had a 50% chance of finding 
one of the lowest prices.  57% of internet shoppers that used only one price comparison 
site or search engine stated that one s earch intermediary produced enough choice.  The 
study found that if consumers expanded their s earch to other price comparison websites 
 
 25and found lower prices they could make significant savings.  The missing potential 
savings were calculated to 150 million to 240 million per annum.49 
 70 Another study by the OFT  on the "Advertisi ng of Prices", inves tigated whether the 
manner prices are presented or 'framed' to consumers has effects on consumer decision-
making and consumer welfare. The result of the study showed that drip pricing (also 
referred to as partitioned pric ing) - where the consumers see only part of the full price up-
front and price increments are dripped through the buying process – accounted for the largest average welfare loss, which went  up to 15% of the stakes involved.
50 
 
71 A comparison of the cheapest retailer prices  found through price comparison websites in 
the mystery shopping exercise and the average online prices  collected in the price 
collection exercise reveals that  that savings can be found usi ng price comparison websites.  
For the 10 selected products, defined at brand/ model level, there are often savings of more 
than 5% if consumers use price comparison we bsites rather than buying these products 
offline or online without carry ing out extensive research. 
 72 Yet, these cheaper prices where consumers can  make savings are not  straightforward to 
find on price comparison websites.  Also, the my stery shopping exercise  revealed that the 
overall performance of price comparison webs ites is problematic in many other aspects 
too.  The fact that such websites are so wide ly used and that the majority of consumers 
place their trust in them to in form their decisions amplifies the overall consumer detriment 
suffered by consumers. 
 
4.3 Purchase behaviour
51 
 
73 When consumers finally purchase goods online, they tend to buy them directly from the 
sellers' websites (42%), while  online marketplaces/platforms  are also popular (27%). A 
close look at the reasons why consumers fina lly choose a specific website for purchases 
reveals that the main reasons is price (60%),  followed by some prev ious experience with 
purchasing from the same website (25%), the availability of clear  and complete product 
information (20%), the availability of a produc t only at that specific website (19%), a well 
designed website (17%), and fast delivery (15% ), followed by other reasons.  For the full 
list of reasons see figure 18 below.  
 
          
                                                
 
49 OFT (2007) Internet Shopping. 
50 OFT(2010) Advertising of prices. 
51 Unless stated otherwise, data in this section comes from Civic Consulting (2011). "Consumer market study on 
the functioning of e-commerce". 
 
 26Figure 18 – Reasons for which consumers finally choose a specific website for making 
the purchase of a good 
Unit: Percentage of Online Shoppers
50%
25%
20%
19%
17%
15%
10%
10%
10%
9%
8%
6%
5%
4%
3%
2%0% 10% 20% 30% 40% 50% 60%
The price was lowest 
I purchased from the site before 
Product information was clear and complete 
It was the only site that offered the product I wanted
The site was clearly designed and easy to use 
Fast delivery was offered 
The site had a good reputation
Information on contractual terms was clear and complete
Several ways for secure payment were offered
It was a seller to whom it is easy to return products and get reimbursed
The site included product reviews from other customers
The site provided a phone number / contact details of the seller
Information on other consumer rights was clear and complete
There was a trust mark on the website
It was from a seller that has a shop I can go to for after-sales service
Other
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
4.3.1 What are online shoppers buying? 
 
74 According to Eurostat data covering both do mestic and cross-border transactions and 
including goods and services, the most popular categories for online consumers are travel 
and holiday accommodation (51%), clothes and sports goods (48%), books, magazine and 
e-learning material (38%), tick ets for events (35%), and household goods (35%).  Figures 
19 and 20 below shows the evolution, from 2006 to 2010, on consumer purchases online. 
 
               
 
 27Figure 19 – Most recent purchase in the origin country by type of products 
Unit: % of individuals
0 5 10 15 20 25Shares/financial services/insuranceMedicineFood/groceriesOthersComputer hardwareElectronic equipmentFilms/MusicHousehold goodsTickets for eventsBooks/magazines/e-learning materialClothes, sports goodsTravel and holiday accomodation
2006
2010
 
 
Source: Eurostat, Information society statistics  (2010). Data extracted on 23 June 2011. 
 
Figure 20 – Most recent purchase in the origin country by type of products 
Unit: % of individuals who ordered goods or services,  over the Internet, for private use, in the last 
year
0 1 02 03 04 05 06 0MedicineShares/financial services/insuranceOthersFood/groceriesComputer hardwareElectronic equipmentFilms/MusicHousehold goodsTickets for eventsBooks/magazines/e-learning materialClothes, sports goodsTravel and holiday accomodation
2006
2010
 
Source: Eurostat, Information society statistics  (2010). Data extracted on 23 June 2011. 
 
 28 
75 The "Consumer market study on the functi oning of e-commerce" shows that in 2010, 
consumers' last purchases dominated the fiel ds of electronic equipment (18%), clothes, 
shoes and jewellery (17%), books (10%) and CD s/DVD's (7%).   For a full breakdown of 
goods bought online see figure 21 below. 
 
Figure 21 – Most recent purchase in the origin  country by type of products (30€ or 
more) 
Unit: Percentage of Online Shoppers
18%
17%
10%
7%6%6%6%5%3%3%2%9%
1%Electronic equipment (incl. computer, phone, camera)
Clothes, shoes and jewellery
Books
CDs/DVDs
Electrical household appliance
Computer software (incl. games)
Cosmetics
Children’s products/toys
Sports and outdoor equipment
Car parts, motor vehicle parts
Over the counter medicines (sold without prescription)
Furniture
Tools and do-it-yourself supplies
Gardening supplies
Child care articles
Prescribed medicines
Car, motor vehicle
Other (Specify) 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
4.4 What holds consumers back 
 
76 There will always be people who prefer to shop offline for a variety of reasons such as 
instant gratification, human c ontact, a preference to see goods beforehand, etc.  According 
to Eurostat data, from those consumers that bought something more than a year ago or never bought anything on the Internet, 62% prefer  to shop in person because they like to 
see product, are loyal to shops or force of habit and 52% say that have no need to make their purchases online.  
 
       
 
 
 29 
77 The potential of e-commerce can be found in  more consumers shopping online and online 
shoppers making more purchases online.  What is important is to make e-commerce a viable option for consumers and businesses that are willing to make transactions online.  If consumers and businesses see e-commerce as a practical and viable alternative to offline retail, this will result in an increa se in competition, both online and offline, as 
business compete to reach the marginal consumers, to the benefit even of consumers with no intention of shopping online.  In turn, this  will result in an increase in consumer 
welfare and a more competitive European economy. 
 
78 Despite the fact that the market tends to find solutions, there is a general consensus that 
much remains to be done to improve the onlin e regulatory environment in order to reach 
the untapped potential of e-commerce.  An improved European legal framework on 
consumer rights, contract la w and redress can help empower  consumers thus facilitating 
cross-border e-commerce.  For example, 44% of consumers were dissuaded from shopping cross-border because they were un certain about their rights cross-border.
52  
 79 Internet penetration and connection speed are important elements facilitating e-commerce.  
It is no coincidence that the countries where most consumers buy online (Denmark, 
Germany, France, Luxembourg, the Netherlands , Finland, Sweden and the UK) have high 
internet penetration, fast and relatively a ffordable connection speeds to the internet.  
These countries, and Belgium, have levels of broadband take up which are higher than the 
United States  (US levels are 26.4 subscr iptions per 100 inhabitants, according to OECD 
May 2010 statistics).  As stated  in the Digital Agenda, ever y European should have access 
to basic broadband by 2013, and fast and ultra fast broadband by 2020. Broadband 
connections in the EU are much faster today th an they were a few years ago.  Yet, there is 
room for action in order to reach the e-comm erce targets set out in the Digital Agenda. 
                     
                                                
 
52 European Commission (2010).  Eurobarometer 299a.  "Attitudes towards cross-border trade and consumer 
protection". . 
 
 30Figure 22 – Broadband penetration rate 
 
 
Source: European Digital Agenda Scoreboard (2010). Data extracted on 9 November 2011.  
 
80 Many consumers that are potentially interest ed in buying online refrain from doing so due 
to a variety of reasons unrelated to internet access and skills.   
 81 These concerns are associated with a general l ack of trust in online businesses.  According 
to Eurostat data, the main inhibiting fact ors about buying goods a nd services online are 
concerns with: the security of payments ( 11%), privacy (10%), receiving or returning 
goods and getting redress (9%), access to paym ent card (4%), delivery (3%), difficulty in 
finding relevant information on the website (3 %) and other reasons (3%). (See figure 23 
below). 
 
 
 31Figure 23 – Reasons for not buying online 
Unit: Percentage of Individuals
20
17
11
10
5
4
3
3
1
40 5 10 15 20 25
They prefer to shop in person, they like to see product, loyalty to shops or
force of habit
They have no need
Payment security concerns
Privacy concerns
They lack the necessary skills
They don't have a payment card
Relevant information about goods and services difficult to find on website
Too long delivery times or because of the problematic to receive the
ordered goods at home
The speed of the Internet connection is too low
Other reasons
 
 
Source: Eurostat, Information society statisti cs (2010). Data extracted on 14 April 2011.  
 
 
82 According to the market study  carried out for this report53, consumers who do not shop 
online  were asked for the three most important reasons for not buying goods online , 
the majority said they prefer  to go to shops and see the goods (40%).  This was followed 
by concerns about: payments and personal details  (29%), difficulty to solve problems 
if something goes wrong  (28%), safety of goods sold online (26% ), a desire to have the 
products immediately (21%), a preference for in-person sales servic e (17%), lack of 
payment card (12%), and a variety of other reasons related to information, choice, and 
delivery concerns.  (See figure 24 below).  
 
            
                                                
 
53 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 32Figure 24 – Most important reasons for no t buying products online (three answers 
possible) 
Unit: Percentage of Offline Shoppers
40%
29%
28%
26%
21%
17%
12%
12%
7%
6%
6%
4%
4%
4%
4%
4%
2%
3%0% 5% 10% 15% 20% 25% 30% 35% 40% 45%
I like going to shops and seeing the products
I have concerns regarding misuse of my personal/payment details
It’s more difficult to solve any problems if something goes wrong
I do not trust the safety of products sold online
I want the products immediately
I prefer in-person sales service
I do not wish to buy products online
I don't have a payment card
I do not know how to buy products online
Products I buy are often cheaper in shops
It’s easier to compare prices in shops
I can only find certain products in shops
There’s more choice in shops
The type of payment card I have is not accepted by online sellers
I save time by buying in shops
Delivery arrangements of online sellers are not convenient for me
Products I buy are often of a better quality in shops
Other
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
83 When occasional online shoppers54 were asked for the three most important reasons 
for buying goods online only occasionally , most say they prefer to go to shops and see 
the goods (38%).  Other reasons were: difficulty to solve prob lems if something goes 
wrong  (32%), a desire to have the products immediately (29%) and misuse of payment or 
personal details (19%).  Some of  their other lesser concerns were related to price, choice, 
customer service, safety, time and delivery.  It is noteworthy, that compared to non-online 
shoppers, occasional shoppers were more lik ely to have concerns (+4%) about the 
difficultly in solving problems if something went wrong and a much weaker concerns about the potential misuse of payment or pers onal details (-10%).  (See figure 25 below).  
 
                                                
 
54 The study defined "occasional shoppers" as shoppers purchasing goods online less frequently than once a 
month, but did buy online at least once in the last 12 months. 
 
 33Figure 25 – Most important reasons for only occasionally buying products online (three 
answers possible) 
Unit: Percentage of Occasional Online Shoppers
38%
32%
29%
19%
15%
14%
14%
11%
10%
8%
7%
6%
6%
5%
4%
9%0% 5% 10% 15% 20% 25% 30% 35% 40% 45%
I like going to shops and seeing the products
It’s more difficult to solve any problems if something goes wrong
I want the products immediately
I have concerns regarding misuse of my personal/payment details
Products I buy are often cheaper in shops
I can only find certain products in shops
I prefer in-person sales service
I do not trust the safety of products sold online
I save time by buying in shops
Delivery arrangements of online sellers are not convenient for me
It’s easier to compare prices in shops
I do not wish to buy more products online
There’s more choice in shops
The type of payment card I have is often not accepted by online sellers
Products I buy are often of a better quality in shops
Other
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 84 According to the views of frequent, occa sional and non-online shoppers examined 
together, the main concerns with buying goods online in their country  have to do with 
issues about getting redress  in case something goes wrong (returning products they don't 
like and replacing or repairing faulty products, 57%), delivery  (delivery of wrong or 
damaged goods, no delivery, or long delivery, 68%) and misuse of personal data (21%) 
and theft of payment card detail s (20%). (See figure 26 below) 
 
 
            
 
 34Figure 26 – Concerns about buying products  online domestically (three answers 
possible) 
Unit: Percentage of Individuals
31%
29%
26%
21%
21%
20%
18%
15%
13%
8%
7%
5%
2%
18%0% 5% 10% 15% 20% 25% 30% 35%
Returning a product I didn't like and getting reimbursed is not easy
Wrong or damaged products will be delivered
Replacement or repair of a faulty product is not easy
Products will not be delivered at all
Personal data may be misused
The payment card details may be stolen
Long delivery times
Delivery costs or final price are higher than displayed on website
Customer service is poor
There is a lower level of consumer protection when buying online
I do not know what my consumer rights are when buying online
Goods sold online are unsafe
Other concerns – specify
I don’t have any concerns
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 85 A comparison of concerns buying online cro ss-border rather than domestically , 
reveals that many more consumers are worried about delivery : long delivery time (35%, 
an increase of 17%), no delivery (27%, an in crease of 6%).  Also, there are slightly 
stronger concerns about remedies for faulty products and getting redress  in case 
something goes wrong: returning a product they don't like and getting reimbursed is not easy (34%, an increase of 3%), replacement or repair of a faulty product is not easy (29%, an increase of 3%).  An additional issue showing str onger concerns is lack of knowledge 
of consumer rights when shopping online  (19%, an increase of 8%).  (See figure 27 
below).  
 
            
 
 35Figure 27 – Concerns about buying products  online in another EU country (three 
answers possible) 
Unit: Percentage of Individuals
35%
34%
29%
27%
23%
21%
19%
19%
16%
12%
6%
6%
2%
12%0% 5% 10% 15% 20% 25% 30% 35% 40%
Long delivery times
Returning a product I didn't like and getting reimbursed is not easy
Replacement or repair of a faulty product is not easy
Products will not be delivered at all
Wrong or damaged products will be delivered
The payment card details may be stolen
Personal data may be misused
I do not know what my consumer rights are when buying from an online
seller based in another EU country
Delivery costs or final price are higher than displayed on website
Customer service is poor
The level of consumer protection in other EU countries is lower than in my
country of residence
Goods sold online are unsafe
Other concerns
I don’t have any concerns
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
86 When consumers who did not shop cr oss-border where asked about the reasons for not 
buying cross border, it was shown that these are rather similar to the reasons for not 
buying online at all.  Most consumers said that there is enough choice  in their country 
(42%).   This drew a strong response in the two biggest e-commerce markets, Germany and the UK, as well as in the Nether lands, Denmark, Poland and France. 35% of 
respondents said it is difficult to solve any problems  if something goes wrong, 26% said 
it is due to extra delivery/custom charges , 24% because of a longer delivery time , 22% 
said they have no need of doing so, while  15% said they did not know what their 
consumer rights are when buying online cross-bor der, and 14% said th ey had too little 
information concerning offers from foreign se llers.  Other reasons were mentioned to a 
lesser extent. (See figure 28 below).  
 
 
         
 
 36Figure 28 – Reasons for not buying products from an online seller based in another 
country (three answers possible) 
Unit: Percentage of non-cross shoppers
42%
35%
26%
24%
22%
15%
14%
13%
12%
12%
11%
5%
4%
4%
1%
1%0% 5% 10% 15% 20% 25% 30% 35% 40% 45%
There is enough choice in my conutry
It’s more difficult to solve any problems if something goes wrong
There are extra delivery/custom charges
There is a longer delivery time
There is no need to buy cross-border
I do not know what my consumer rights are when buying from an online
seller based in another country
I have too little information regarding offers from foreign sellers
I have concerns regarding misuse of my personal/payment details
I do not trust the safety of products sold online in other countries
The products I want are cheaper in my country
I do not speak the language of foreign websites
The products I want are of better quality in my country
The type of payment card I have is not accepted by foreign sellers
The level of consumer protection in other countries is lower than in my
country
I tried but was redirected to a website in my country
Foreign sellers refuse to sell to me because I live in another country
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  
 
4.5.1 Problems encountered when buying goods online 
 
87 The market study55 showed that the majority of onlin e shoppers (76%) do not in practice 
experience these problems while using e-commerce to purchase goods.  However, one in five (24%) online shoppers has experien ced problems. (See fi gure 30 below).  An 
assessment of the incidence of problem s when purchasing goods online (24%) and 
problems when purchasing goods offlin e (20%), shows that there is no significant 
difference between the sales medium used and problems faced .  
 
            
                                                
 
55 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 37Figure 29 – Problems encountered by online shoppers while buying online 
Unit: Percentage of online shoppers who encountered a problem
28%
20%
17%
17%
14%
10%
7%
4%
4%
1%
1%
1%
0%
7%0% 5% 10% 15% 20% 25% 30%
Long delivery time
Damaged product delivered
Non-delivery
Product did not match description on website
Wrong product delivered
Customer service was poor
Delivery costs or final price was higher than displayed on website
I could not return a product I didn't like and get reimbursed
The seller did not replace or repair a faulty product
The product sold was unsafe
My personal data was misused
My payment card details were stolen
A foreign seller charged a higher price to me than to consumers in the
country of the seller
Other problems
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
88 Problems with online transactions can be split between 17% when buying from a business 
in their own country and 7% when buying cr oss-border.  A breakdown of these figures 
shows that cross-border shoppe rs do not seem to encounter  more problems than domestic 
shoppers.  From those online shoppers th at bought domestically 14% experienced a 
problem, while from those online shoppers that bought cross-border 13% experience a 
problem .  The incidence values for most type of  problems are rather similar between 
the two groups. (See figure 30 below).  Most problem s with products bought online from 
domestic sellers were reporte d in Poland (26%), Italy (22%), the UK (21%) and Romania 
(18%).  Most problems with products bought on line from sellers based in other countries 
were reported in Malta (29%), Ireland ( 22%), Cyprus (19%), Luxembourg (18%), 
Lithuania (13%), Austria (12%), Greece (12 %), Latvia (11%), Belgium (11%), Italy 
(11%), Finland (10%), Portugal (10%) and Spain (9%),. 
 
 
   
 
      
 
 38Figure 30 – Problems encountered buying online domestically and cross-borders 
Unit: Percentage of Individuals
0% 5% 10% 15% 20% 25% 30%
long time delivery
damaged product delivered
product did not match description on website
non delivery
wrong product delivered 
customer service poor
delivery costs or final price was higher than displayed on website
the seller did not replace or repair a faulty product
I could not return a product I didn't like and get reimbursed
the product sold was unsafe
my personal data was misused
my payment card details were stolen
a foreign seller charged a higher price to me than to consumers in the
country of the seller
other
Domestic Cross Border
 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 89 The greatest majority of problems buying goods concerned delivery : long delivery times 
(28%), damaged product delivered (20%), non-delivery (17), wrong product delivered 
(14%), delivery costs or fina l price was higher than displa yed on the website (7%).  The 
second group of problems concerned issues related to getting redress : customer service 
was poor (10%), seller did not replace or repair  a faulty product (4%), could not return a 
product within the cooling off period and ge t reimbursed (4%).  Ot her problems were: 
product did not match descriptio n on website (17%), unsafe products (1%), personal data 
was misused (1%) and payment card details were stolen (1%).   
 90 A recent Eurobarometer survey
56 comparing the shopping experience of domestic and 
cross-border distance shoppers confirmed that there are no significant differences in 
encountered problems.   Only 16% of s hoppers experienced a delay with a product 
purchased cross-border in the EU while 18%  of shoppers experien ced a delay with a 
product purchased domestically.  5% of shoppe rs had a problem with goods not delivered 
after purchasing cross-border in the EU wh ile 6% of shoppers had a problem with no 
delivery after purchasing domestically.  (See figure 31 below). 
 
 
 
                                                 
56 European Commission (2011). Eurobarometer 299. "Consumer attitudes towards cross-border trade and 
consumer protection". 
 
 39Figure 31 – Delay in delivery and non-delivery  of goods or services purchased by 
distance 
Unit: Online Shoppers
186
165
196
02468 1 0 1 2 1 4 1 6 1 8 2 0Delay in delivery of something You purchased something and it
was not delivered at all
from a seller or provider in their own country from a seller or provider in another EU country
from a seller or provider in a non-EU country
 
 
Source: European Commission, (2011).  Eurobarometer 299, "Consumer attitudes towards cross-border trade 
and consumer protection". 
 
 91  Consumer perceptions about fraud, deliver y problems and redress are lower among those 
consumers who tried cross-border e-commerce.   From the general consumer population, 
just 3% are equally confident in purchasing online cross-borde r as they are domestically.  
However, the levels of confidence of those who actually carried out online cross-border 
transactions are twice as hi gh. 61% of those who have made  at least once online cross-
border transaction say that they  are equally confident buying from domestic or foreign EU 
online retailers. (See figure 32 below).  
 
 
            
 
 40Figure 32 – Level of confidence in cross-border purchases 
48
3333
614
516
10% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
all respondents
those who had made at least
one cross-border purchase via
the Internet
More confident in sellers from my own country than in another EU country
Equally confident
More confident in sellers from another EU country
DK/NA 
 
Source: European Commission (2011).  Eurobarometer 299 , "Consumer attitudes towards cross-border trade and 
consumer protection". 
 
4.5.2 Comparison of concerns and actual problems 
 
92 A comparison of the reasons holding back consumers from buying online and the actual 
problems online consumers meet, reveals that some of these concerns are not substantiated.  For example, c ontrary to their fears, the ev idence shows that the incidence 
of problems concerning payments and abuse of pe rsonal data, as well as  the percentage of 
unsafe products sold online is very low.  The concerns that seem to be vindicated by actual problems seem to be the ones related to delivery, non-conformity of products 
delivered and redress . 
 
4.6 Problems, complaints and redress 
 
93 A significant problem affecting cross-border transactions an d undermining the consumers' 
confidence in the Digital Single Market is the refusal of online businesses to deliver if the service recipients are not re siding in the same Member State. The Commission has 
received a significant number of complaints wh ich give evidence of refusals to supply or 
of differences in treatment in the online wo rld that are based on the residence of the 
service recipient. 
 
 
 4194 Article 20 (2) of the Services Directive57 obliges Member States to ensure that general 
conditions of access to a service which are ma de available to the public at large by a 
service provider do not cont ain discriminatory provisions based on the nationality or on 
the place of residence of recipients. This doe s not exclude that service providers apply 
different prices and other conditions of acces s to the extent that those differences are 
directly justified by objective criteria. Further to the implementation of Article 20(2) of the Services Directive into the national legal orde rs of Member States, it is for the relevant 
national authorities to ensure the enforcem ent of national provisions implementing the 
non-discrimination principle. The Commission will publish guidelines for the application 
of this provision of the Services Directive by February 2012. 
 95 In the case that consumers are not satisfied with the handling of complaints from online 
businesses they can seek help from a third party body such as a consumer organisation, a 
European Consumer Centre (in the case of cro ss-border complaints), an  alternative dispute 
resolution body or a government authority.   
 
4.6.1 European Consumer Centres 
 
96 The European Consumer Centres Network (ECC-Net)
58 is the only European network 
fully dedicated to inform citizens about their rights  when shopping cross-border and 
support them when they seek for redress with a trader in another EU Member State if 
something goes wrong.  Internet purchases conti nue to be the main source of consumer's 
cross-border complaints with  56% of all complaints addr essed to ECC-Net the in 2010 
(44,232 complaints). 
 97 The last report on e-commerce prepared by the ECCs  was published in 2010: "The 
European Online Marketplace: Consumer comp laints 2008-2009".  As far as the problems 
reported are concerned, the trends observe d in 2008 and 2009 are similar to previous 
years, with delivery  (non delivery of goods, partial deli very or delayed delivery) and 
problems with product/service  (defects with the product, non conformity, products 
causing damage, etc.) again constituting the main areas of consumer complaints, 
representing three quarters of the total amount of complaints . Problems with 
purchasing electronic goods  (TVs, radios, stereos, CD /DVD players, MP3 players, 
cameras, computers, video-games, etc) dominated . 
 98 The ECC-Net received a rela tively high number of consum er complaints related to non 
display or incorrect display of prices or even hidden costs . Security of payments  has 
gained an even more significant importan ce and consumers are not getting sufficient 
information on the possibilities of  getting redress from the intermediaries that facilitate 
cross-border payments.  
 99 While ECCs do not deal with cases where fraud is known or found to exist as it is a 
criminal matter, they report that the number of cases signalled to them on e-commerce 
fraud  has significantly increased. These cases involve fake web traders, fraudulent 
escrow companies, internet auction fraud, etc.  
 
                                                
 
57  Directive 2006/123/EC of the European Parliament and of the Council of 12 December 2006 on 
services in the internal market, OJ L 376/36, 27.12.2006; available at: http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:376:0036:0068:EN:PDF   
58 http://ec.europa.eu/ecc-net 
 
 42100In 2011, the ECC-Net carried out a mystery sho pping exercise in order to check whether 
online retailers selling cross- border offer the right level of protection to consumers59.  The 
ECC-Net mystery shoppers carr ied out actual purchases to  check retailers' compliance 
with EU legislation.  The mystery shopping ex ercise involved 305 cros s-border purchases. 
During the design phase of this exercise , the mystery shoppers found it surprisingly 
difficult to find online retailers that were will ing to sell cross-border despite the fact that 
the original list of retailers wa s compiled with this in mind.  Fr om the original  selection of 
retail websites, 60% did not fulfil the criteria , set by the ECCs, for selling cross-border.  
Another barrier was language since only 61%  provided information in more than one 
language. 
 101Most online retailers do not sell cross-border and often the ones that do are not compliant 
with EU consumer legislati on.  Many traders are dissuaded from selling cross-border by 
the complexity and lack of harmonisation of  the EU legal environment governing cross-
border e-commerce transactions.  For example, only 29% of retailers  know where to look 
for information or advice about consumer legi slation in force in other EU countries, and 
72% of distance sellers did not even know the ex act length of the "cooling-off" period for 
distance sales in their own country
60. Almost 40% of exporting retailers or  retailers 
interested in starting a cro ss-border activity a nd involved in e-commerce transactions 
declared that the need to adapt and comply w ith different consumer protection rules in the 
foreign contract laws has an impact on th eir decision to sell cr oss-border in the EU61.  
 102In 18% of purchases carried out during th e ECC mystery shopping ex ercise, traders did 
not inform shoppers about their right of wit hdrawal, while in 63% of cases the websites 
did not provide information concerning the lega l warranty and associated  consumer rights.  
Mystery shoppers found out that 11% of we bsites did not provide the opportunity to 
review the details of the orde r before placing it and 12% of  websites did not even provide 
an electronic-mail address. 
 103The delivery rate of products  was high reaching 94% (of wh ich 99% were in conformity 
with the order).  Almost 50% of all deliveries took place w ithin 7 days, while 82% took 
place within 14 days. 
 104From the 305 websites used in this exercise , 52 online retailers (17 %) were members of a 
trustmark scheme.  88% of retailers that belonged to a trustmark scheme informed 
consumers about their right of withdrawal in the terms and conditions compared to 80% of 
the total number of retailers.  84% of retailers belonging to a trustmark partly reimbursed 
mystery shoppers when returning products w ithin the cooling-off period, compared to 
90% of retailers in total.  48% of retail ers belonging to a trustmark reimbursed the full 
amount (including delivery costs) compared to 43 % in total.  It is es pecially worrying that 
57% of online retailers did not reimburse deliv ery costs despite having the legal obligation 
to do so.   
 
                                                
 
59 European Consumer Centres Network (2011). "Online cross-border mystery shopping – State of the e-Union".  
60 European Commission (2011). Flash Eurobarometer 300.  "Retailers' attitudes toward cross-border trade and 
consumer protection".   
The "cooling-off" period is the period after the purchase during which a consumer has the legal right to return a 
product purchased on the internet, by phone or post without paying a penalty.  This "cooling-off" period ranges from 7 to 15 calendar days depending on the country where the product is sold. 
61 European Commission (2011). Flash Eurobarometer 321. "European contract law in consumer transactions". 
 
 43105The external evaluation of the ECC-Net published in 201162 suggested that the network 
could take a proactive and preventive  approach towards targeted traders (fraudulent 
or within key sectors) in order to raise awareness of consumer rights, obtain their 
cooperation, and dissuade traders from in fringing laws.  The Commission will use 
existing networks, such as the Enterprise Europe Network, to step-up efforts to inform online retailers about their obligat ions when selling cross-border but also 
about the opportunities offered by sellin g in other EU countries and taking 
advantage of the potential of the Single Market. The ECC-Net can provide assistance 
and information on consumer issues.  
 
106Besides taking their complaints to the Eur opean Consumer Centres, consumers may wish 
to seek legal advice or take the matter to court.  The market study
63 found that the highest 
rates of satisfaction were when consumers sought advice from lawyers (77%), consulted 
consumer organisations (75%) and filed online complaints with online dispute resolution 
bodies (e.g. online mediator, arbitrator, ombudsman).   
 107Consumers were asked to rate different m easures that could increase confidence in e-
commerce from 0-10.  The results  did not reveal big variati on in consumers' preferences 
between measures.  The most popular are secu re online payment systems, having the same 
set of online rights everywhere across the EU, online sellers en suring that personal data is 
not stolen or misused, public authorities ensuri ng that fraudulent traders are closed down 
and provision of accurate contact information on sellers' websites.  For a full list of 
measures see figure 33 in Annex 1. 
 108When consumers were asked whether they woul d be willing to solve a dispute with an 
online seller through an online dispute resolution body, most were positive (52%), a 
sizeable proportion did not know (32%), and only a small minority (16%) were not willing. (See figure 34 below). 
 
                  
                                                
 
62 CPEC (2011).  Evaluation of the European Consumer Centres Network.  Report carried out on behalf of the 
European Commission. 
63 Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  
 
 44 
      Figure 34 – Would you be willing to solve a dispute with an online seller through an 
online dispute resolution body (for exampl e online mediator, arbitrator, ombudsman)? 
That means submitting and settling the dispute online (for example through online 
forms, emails, online chat) 
Unit: Percentage of Individuals
52%
16%32%
Yes
No
DK
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  
 
109Since redress has been identifie d as a problem both in consumers' perceptions but also in 
actual problems, it is clear that more effici ent and effective redress mechanisms would 
improve conditions for consumer in e-commerce. 
  
4.7 E-commerce and enforcement 
 
110The increase in e-commerce brings new challe nges for enforcement authorities.  This is 
especially in the case of cross-border e- commerce where enforcers are constrained by 
jurisdictional boundaries whilst expected to respond with sp eed and effectiveness. In 
addition, resources available limited.  
 
 
 45111In this context, active cooperation between en forcement authorities has proven to be one 
of the most effective tools available to enforcers64. For this reason, the Commission set up 
with Member States in December 2006 th e Consumer Protection Cooperation (CPC) 
Network65. The Network brings togeth er the consumer enforcement authorities of all the 
Member States (as well as from Norway, I celand and Liechtenstein). Authorities work 
closely together to stop breaches to the consumer rules in cert ain situations where 
consumers and traders are estab lished in different countries.  
 112From its first year of activ ity, the Network has carried out, under the coordination of the 
Commission, new forms of pan-European enforcement: the so called EU-sweeps.  In a 
sweep, enforcement authorities simultaneously screen a sample of websites in a given 
sector for compliance with EU consumer le gislation and take appropriate enforcement 
actions. The sweeps are carried out on an annua l basis. The four sweeps completed so far 
by the Network have contributed to improve compliance in the sectors targeted (so far 
websites selling airline tickets, ring-tones fo r mobile phones, electr onic goods and tickets 
for sports and cultural events). Authorities have checked about 1800 websites in the four 
sweeps, and up to 80% of websites which were  initially found in breach of consumer law 
have now been corrected.  
 113From the 305 cross-border purchases carried out during the ECC-Network mystery 
shopping exercise, 173 cases were shared with the CPC Network of en forcers since it was 
judged that these cases concerned consumers' collective interests.  Improved co-operation 
between the ECC-Network and the CPC Netw ork would improve the online environment 
for consumers.  The external evalua tion of the ECC-Net recommended that cooperation 
between the ECC-Net and the Consumer Pr otection Cooperation (CPC) Network 
should be further enhanced . At present a working group composed by ECC and CPC 
members is looking into concrete  recommendations for cooperation. 
 
5)  Conclusion 
 
114The data presented in this reports shows that  e-commerce is continui ng to grow as a sales 
channel.  More and more consumers are choos ing to use the Internet  to carry out their 
background research before making a purchase ei ther online or offline.  In addition, 
increasing numbers of consumers are making actual purchases onlin e.  Businesses are 
showing a similar behaviour by embracing e- commerce and the opport unities it offers, 
despite their initial reluctance.  As businesses engage in e-commerce more intensely trying to reach consumers, there is a positive effect on competition both online and offline.  This results in an increase in cons umer welfare for all consumers.  The report has 
shown that there are considerable gains fo r consumers from e-commerce such as lower 
prices, a wider choice of goods and services  and convenience.  Consumers are already 
enjoying some of the be nefits offered by e-commerce.  Yet, the European online market is 
by no means complete.  There is a considerab le way to go in order to reach the true 
potential lying in e-commerce as a sales channe l.  An achievement of  this potential would 
considerably increase the benefits to consum ers and at the same time make the European 
economy much more competitive and responsive to consumer demand.  In a truly online Single Market where e-commer ce in retail goods makes up 15% of the retail sector, total 
                                                
 
64 COM (2009) 330 final - dated  2.7.2009 
65 Regulation (EC) No 2006/2004 of the European Parliament and of the Council of 27 October 2004 on 
cooperation between national authorities responsible fo r the enforcement of consumer protection laws.  
 
 46consumer welfare gains are estimated to be around €204 billion, an amount 
equivalent with 1.7% of EU GDP.  
 
115However, in order to reach this true potential  it is necessary to tackle the many obstacles 
identified.  Their nature is twofold as they appear both on the demand but also, and most 
importantly, on the supply side.  On the side of  the consumers, the majority is still not 
buying online and despite the fact that many have embraced domestic e-commerce most 
are reluctant to engage in cross-border e-co mmerce despite the poten tial benefits.  The 
reasons behind this lack of confidence are generally the same fo r offline shoppers and 
shoppers who buy online only occasionally.  Th ese can be traced to concerns about 
getting redress in case something goes wr ong, problems with de livery, misuse of 
personal/payment details, uncertainty about consumer rights when shopping cross-border 
and unsafe products.   
 116An examination of the actual  problems faced by consumers reveals there is no significant 
difference in the incidence of problems if  one compares e-commerce to offline 
transactions. Consumer concerns about e-comm erce are substantiated in the case of actual 
problems with delivery, non-compliant products, and getting redress in case something goes wrong.  On the contrary, only a very small minority of consumers seems to face actual problems with misuse of  personal/payment details and unsafe products.  Therefore, 
it seems that consumer concerns about these issues are misplaced.   
 117Measures to improve delivery, redress mechan isms and raise the confidence of consumers 
on their online rights are needed.  The Comm ission has adopted two legislative proposals 
to improve out-of-court dispute resolution fo r all consumer disput es, including those 
related to cross-border onlin e transactions: a proposal for a Directive on Alternative 
Dispute Resolution for consumer disputes
66 and a proposal for a Regulation on Online 
Dispute Resolution for consumer disputes67.  The latter proposal focuses especially on e-
commerce.  The whole procedure will be handled online, consumers will be able to submit their complaint in their own language and this will be free of charge or at low cost.   
Better means of out-of-court di spute resolution will increase consumers' confidence in the 
Digital Single Market and the business opportunities of SMEs. Also, they will reduce costs for consumers, businesses and nationa l courts. The Common European Sales Law 
will also address the problem of consumer un certainty about their rights. When applying 
this law, consumers would benefit from the same set of rights when shopping abroad and 
would be informed of their key rights in a dvance of a transaction through a standardised 
information notice. 
 118A recent workshop held during the Digital Ag enda Assembly on "Building confidence for 
the digital single market"
68 gathered strong consensus for further exploring the role and 
potential of a European trust mark accreditati on scheme to enhance trust and online cross 
border transactions. Trust ma rks can effectively be comb ined with, and leverage upon, 
other tools such online alternative dis pute resolution schemes and information 
intermediaries. Commission services will examine further what can be done at EU level in the area of trustmarks to increase confidence in e-commerce in Europe. 
 
                                                
 
66 COM (2011) 793 final  
67 COM (2011) 794 final 
68 http://ec.europa.eu/information_society/events/cf/daa11/document.cfm?doc_id=18277 
 
 47119The biggest problems holding back the deve lopment of e-commerce seem to be on the 
supply side.  Despite the fact that increas ing numbers of businesses are embracing the 
opportunities offered by e-commerce most still se ll only offline.  From those that do sell 
online, the majority sell only do mestically rather than cross-bor der.  Regulatory barriers to 
cross-border e-commerce that have been al ready identified by the Commission in detail 
remain largely unaddressed.  These can be traced to differences in contract law, VAT, the territorial management of copyright necessary  for the offer of goods which attract a levy, 
the national transposition of the European le gislation on electronic waste disposal etc.  
Many traders do not sell cross-border due to th e complexity and lack of harmonisation of 
the EU legal environment governing cros s-border e-commerce transactions.  The 
Commission has addressed some these issues through legislative proposals such as the 
Directive on Consumer Rights
69 that has been adopted recently and the proposal for a 
Regulation on a Common European Sales Law70. The Commission is also assessing the 
need for adapting other consumer legislation due to the increasing importance of digital 
services.  Others issues are cu rrently being discussed such as the recast of the Directive on 
Waste of Electrical and Electronic Equipment71.  Issues such as copyright and intellectual 
property rights will be addressed by the Commis sion in forthcoming legislative proposals. 
 120The findings of the report show that one  growing area of problems has to do with 
information.  As the use of information inte rmediaries becomes more widespread it is 
necessary that they provide information in a clear, transparent and accurate manner.  Also, 
consumers would benefit if such interm ediaries provided information on goods and 
services from everywhere in the EU and co vered aspects beyond pri ce and pure, technical 
product characteristics.  This could open up the Single Market for goods and services 
resulting in lower prices a nd wider choice.  The existing fragmentation of price and 
product comparison intermediaries  is serving to entrench Si ngle Market obstacles in the 
mind of EU consumers. 
 121To address these issues, Comm ission services will work clos ely with product testing and 
other organisations providing information on product quality comparisons/price/best value 
for money, to see how to make results more  available and comparable across the EU.  
Also, it will engage closely with  information intermediaries in order to: a) ensure that they 
respect EU consumer legislati on, and b) encourage them to include cross-border offers on 
price and quality in a way that unlock s the potential of the Single Market.   
 
122In addition, the Commission will use existing networks to step-up efforts to inform online 
retailers about the opportunities offered by selling in other EU countries and taking 
advantage of the potential of the Single Ma rket.  The Commission will make education of 
SME retailers in legal aspects of selling cross-border online a key them in its future work on EU law and standards through th e Enterprise Europe Network
72 and the ECC Network. 
 123Consumers' confidence in e-commerce can  also be improved through the improved 
enforcement of the rules governing e-comm erce.  The Commission will encourage the 
                                                
 
69 http://www.europarl.europa.eu/en/pressroom/cont ent/20110622BKG22276/html/Consumer-rights-what-the-
new-EU-rules-will-mean 
70 Proposal for a Regulation of the European Parliament and of the Council on a Common European Sales Law 
{SEC (2011) 1165 final} {SEC (2011) 1166 final} / COM (2011) 635 final   
71 Proposal for a Directive of the Eu ropean Parliament and of the Coun cil on waste electrical and electronic 
equipment (WEEE) (Recast) {SEC (2 008) 2933} {SEC  (2008) 2934 }/ COM/2008/0810 final 
72 http://www.enterprise-europe-net work.ec.europa.eu/index_en.htm 
 
 48European Consumer Centres Network to take  a more proactive and preventive approach 
towards problematic traders and sectors in order to improve understanding of consumer 
rights, dissuading them from infringing la ws and reporting non-compliant traders to 
enforcement authorities.    Furthermore, th e Commission will also facilitate further the 
dialogue between the European Consumer Cent res Network and the network of consumer 
enforcement authorities (CPC-network) in order to improve the enforcement of EU 
legislation governing business-t o-consumer onlin e transactions. 
 124Other complementary actions foreseen in the Di gital Agenda, such as the roll-out of fast 
and affordable broadband, will also help towards achieving the true potential of the Single 
Market in e-commerce, with beneficial eff ects for consumers and the European economy 
as a whole. 
 
 49ANNEX 1 
 
FIGURES  
 Figure 4 – Countries from which you  have bought products online  
 
country Austria    Belgium   Bulgaria   Czech 
Republic Cyprus    Denmark   Estonia   Finland   France    Germany   Greece   Hungary   Latvia    Lithuania   
Austria   2% 0% 1% 0% 0% 0% 0% 5% 90% 0% 1% 0% 0% 
Belgium 2%   1% 1% 0% 0% 0% 0% 42% 26% 0% 0% 0% 0% 
Bulgaria 5% 3%   1% 0% 1% 0% 1% 15% 19% 2% 0% 1% 0% 
Cyprus 0% 1% 0% 0%   0% 0% 0% 8% 10% 15% 0% 0% 1% 
Czech Rep 5% 0% 0%   0% 1% 0% 1% 9% 24% 1% 2% 0% 0% 
Denmark 3% 1% 0% 0% 0%   0% 2% 5% 32% 0% 0% 0% 0% 
Estonia 2% 1% 0% 1% 1% 4%   11% 5% 27% 1% 1% 5% 3% 
Finland 4% 2% 1% 1% 0% 5% 7%   5% 38% 0% 1% 1% 0% 
France 1% 15% 1% 1% 1% 2% 0% 1%   41% 1% 0% 0% 0% 
Germany 31% 4% 1% 3% 1% 4% 1% 1% 9%   1% 1% 0% 1% 
Greece 3% 2% 1% 1% 4% 0% 0% 1% 10% 27%   1% 0% 0% 
Hungary 10% 1% 0% 3% 0% 0% 0% 1% 3% 26% 0%   0% 0% 
Ireland 1% 2% 1% 1% 0% 1% 1% 0% 9% 15% 1% 0% 0% 1% 
Italy 4% 4% 1% 1% 1% 2% 1% 2% 26% 36% 3% 1% 1% 1% 
Latvia 2% 1% 0% 0% 0% 1% 5% 3% 4% 23% 0% 0%   5% 
Lithuania 4% 1% 1% 1% 0% 0% 3% 1% 5% 17% 2% 0% 3%   
Luxembourg 4% 19% 0% 0% 0% 1% 0% 0% 43% 78% 0% 0% 0% 0% 
Malta 1% 1% 0% 0% 0% 0% 0% 0% 2% 7% 0% 0% 0% 0% 
Netherlands 3% 15% 1% 1% 1% 2% 0% 0% 11% 43% 1% 1% 0% 1% 
Poland 2% 2% 1% 4% 0% 1% 0% 0% 8% 33% 2% 0% 0% 1% 
Portugal 1% 1% 0% 1% 0% 1% 0% 0% 16% 18% 1% 0% 1% 0% 
Romania 7% 1% 4% 0% 0% 0% 0% 2% 9% 22% 2% 8% 0% 0% 
Slovakia 5% 0% 0% 59% 0% 0% 0% 0% 7% 15% 0% 4% 0% 0% 
Slovenia 16% 1% 0% 1% 0% 0% 0% 0% 4% 45% 0% 0% 0% 0% 
Spain 2% 5% 1% 1% 0% 2% 0% 2% 27% 22% 1% 1% 0% 0% 
Sweden 3% 2% 0% 2% 0% 15% 0% 3% 9% 32% 1% 1% 0% 0% 
 
 50UK 2% 3% 1% 2% 2% 2% 1% 1% 17% 21% 1% 1% 1% 1% 
Total 8% 5% 1% 2% 1% 2% 1% 1% 14% 27% 2% 1% 1% 1% 
 
 
country Luxembourg   Ireland    Italy      Malta     Netherlands   Poland    Portugal   Romania   Slovakia   Slovenia   Spain     Sweden   United 
Kingdom 
Austria 2% 1% 4% 0% 4% 2% 0% 0% 0% 0% 1% 1% 13% 
Belgium 2% 0% 3% 0% 38% 0% 0% 0% 0% 0% 2% 1% 20% 
Bulgaria 1% 1% 6% 1% 2% 1% 1% 1% 0% 0% 1% 1% 41% 
Cyprus 0% 1% 5% 0% 2% 0% 0% 0% 0% 0% 1% 1% 74% 
Czech Republic 0% 1% 1% 0% 2% 18% 0% 0% 19% 0% 1% 0% 17% 
Denmark 0% 2% 2% 0% 8% 1% 1% 0% 0% 0% 2% 22% 48% 
Estonia 1% 1% 2% 0% 3% 3% 1% 0% 0% 0% 1% 6% 35% 
Finland 0% 2% 3% 0% 7% 1% 0% 1% 0% 0% 2% 22% 40% 
France 5% 2% 3% 1% 3% 1% 2% 0% 1% 0% 5% 1% 29% 
Germany 7% 1% 5% 0% 11% 3% 0% 1% 1% 0% 4% 2% 20% 
Greece 1% 2% 9% 0% 2% 0% 1% 0% 0% 0% 3% 1% 49% 
Hungary 1% 2% 1% 0% 1% 1% 0% 1% 16% 1% 2% 1% 27% 
Ireland 0%   3% 1% 4% 4% 1% 1% 1% 0% 4% 2% 74% 
Italy 2% 3%   1% 4% 2% 1% 1% 1% 1% 7% 2% 29% 
Latvia 0% 3% 3% 0% 1% 4% 0% 0% 0% 0% 1% 5% 33% 
Lithuania 0% 4% 1% 1% 1% 8% 1% 0% 0% 0% 2% 1% 39% 
Luxembourg   2% 5% 0% 5% 0% 1% 0% 0% 0% 2% 1% 19% 
Malta 0% 1% 9%   1% 0% 0% 0% 0% 0% 0% 0% 93% 
Netherlands 1% 2% 3% 1%   2% 1% 0% 0% 0% 4% 1% 21% 
Poland 1% 3% 1% 0% 3%   0% 0% 2% 0% 3% 1% 23% 
Portugal 2% 4% 4% 0% 3% 0%   0% 0% 0% 21% 1% 41% 
Romania 0% 1% 13% 0% 2% 2% 2%   0% 0% 5% 0% 19% 
Slovakia 1% 1% 1% 0% 1% 4% 0% 0%   0% 0% 0% 15% 
Slovenia 1% 1% 5% 0% 3% 2% 0% 0% 1%   1% 1% 34% 
Spain 2% 5% 8% 1% 2% 0% 5% 0% 0% 0%   1% 28% 
Sweden 0% 1% 3% 0% 3% 2% 1% 0% 0% 0% 3%   34% 
United Kingdom 2% 9% 6% 2% 6% 3% 1% 0% 1% 0% 8% 2%   
Total 3% 3% 4% 1% 6% 2% 1% 1% 1% 0% 5% 2% 24% 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 51Figure 12: Subcategory overview - average price difference onlin e vs. offline (in %), including  delivery costs 
 
  
Notes: Based on a total number of 4559 observa tions. Data collected in De cember 2010. Negative values mean that online price is  lower than offline price of the product (shaded). Positive values 
mean that the online price is hi gher than the offline price  
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce".  Country  
  
Mobile 
Phones 
Laptops 
Digital 
Cameras 
In-Car 
Navigation 
LCD TVs 
Portable 
MP3 
Players 
Premium 
Women's 
Fragrances 
Video 
Games 
Hardware 
Traditiona
l toys 
Men's 
outerwear 
Women's 
outerwear 
Footwear  
Power 
tools and 
accessories 
Instant 
Standard 
Coffee 
Standard 
Milk 
Formula 
Austria -8.6 -3.7 3.5 -13.5 -9.6 3.4 1.2 -5.2 16.8 2.5 8.7 1.1 -1.3 189.8 62.8 
Belgium 0.7 -3.1 2.6 -5.2 -8.9 1.7 -9.3 -6.3 8.5 7.8 5.3 - -0.5 46.9 40.8 
Czech Republic -3.8 -1.4 -2.6 -13.4 -12.0 3.4 -47.6 -1.6 -5.0 -7.3 -18.3 -19.0 -4.5 106.9 17.3 
Denmark -8.1 -3.5 4.5 3.5 -3.2 4.1 -12.6 -8.7 30.7 -6.7 -23.2 -16.5 -8.8 160.3 80.0 
France -1.1 -2.8 -7.6 -12.1 -6.5 1.3 5.7 -3.3 21.9 -2.0 8.5 -5.2 -6.7 243.4 32.7 
Germany -9.0 -6.5 -1.9 -6.5 -4.3 10.8 -5.1 -1.5 14.9 -1.9 15.2 -8.5 -3.5 116.2 67.9 
Greece -4.8 0.0 5.7 -3.0 -10.5 -2.0 -0.4 4.0 10.6 -9.6 3.9 -25.5 -1.2 105.2 21.7 
Hungary -19.3 -24.4 1.4 -12.0 -8.4 -9.1 -52.1 -17.7 51.1 0.0 0.0 3.7 -11.0 177.7 61.0 
Italy -5.8 -5.6 4.6 -4.4 0.2 5.2 -7.6 -6.9 40.5 -11.3 -9.6 -13.1 11.7 118.2 45.8 
Netherlands -5.6 -1.0 2.6 -7.4 -3.3 -1.5 -8.6 -4.5 5.0 -1.0 16.3 -10.3 0.0 97.7 58.0 
Poland -1.3 -2.8 -6.3 -0.9 -11.8 -2.3 -43 -7.9 -7.6 -7.4 -10.1 -9.1 -0.2 99.5 43.9 
Portugal -2.4 1.6 9.1 -1.0 1.0 8.7 6.0 0.3 25.1 5.6 -11.3 22.4 12.5 111.4 58.8 
Romania -4.4 -1.3 7.1 -3.5 1.3 9.6 -26.5 -1.5 20.4 24.1 -4.2 16.0 -16.7 135.8 70.1 
Slovakia 3.7 -3.0 10.5 -20.0 -6.2 2.8 -29.2 1.9 21.2 0.9 4.1 -1.5 -6.0 107.2 63.3 
Spain 0.6 2.6 -12.5 -1.5 -7.4 6.3 1.4 -1.0 28.7 1.8 2.2 -0.2 -4.6 199.3 50.0 
Sweden -11.8 -0.3 -0.3 -9.5 -7.3 6.9 -38.1 -6.7 1.1 -1.2 7.7 -6.9 0.2 168.7 475.3 
United Kingdom -6.2 3.6 2.0 -1.6 8.6 0.2 -0.4 -3.2 -6.4 -8.4 -1.4 2.5 8.8 155.2 41.3 
Average -5.1 -3.0 1.3 -6.6 -5.2 2.9 -15.7 -4.1 16.3 -0.8 -0.4 -4.8 -1.9 137.6 75.9 
 
 52Figure 13: Overview – average choice  difference online vs. offline (in %) 
 
Notes: Based on a total number of 4559 observa tions. Data collected in De cember 2010. Positive values mean that online choice i s bigger than offline choice of the product (shaded). Negative 
values mean that online choice is sma ller than offline choice of the product  
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerceCountry 
 
  
Mobile 
Phones 
Laptops 
Digital 
Cameras 
In-Car 
Navigation 
LCD TVs 
Portable 
MP3 Players 
Premium 
Women's 
Fragrances 
Video Games 
Hardware 
Traditional 
toys 
Men's 
outerwear 
Women's 
outerwear 
Footwear  
Power tools 
and 
accessories 
Instant 
Standard 
Coffee 
Standard 
Milk 
Formula 
Austria 2317 122 33 3 25 -10 107 -25 -39 73 71 19 11 -29 233 
Belgium 102 208 338 163 184 36 191 246 431 10 67 0 153 85 298 
Czech Republic 130 -2 257 15 -22 120 48 200 24 -37 9 78 -8 -14 38 
Denmark -16 25 6 -3 -8 -42 -18 0 17 -53 -50 -57 2 -32 -83 
France 209 26 61 235 163 70 346 0 1202 138 340 1412 117 33 50 
Germany 43 197 8 199 388 87 63 0 250 -8 89 187 99 404 50 
Greece 71 70 -7 22 -27 22 -50 0 -26 -78 1 -31 -5 -42 30 
Hungary 345 -7 102 62 8 2775 120 0 85 50 0 42 54 25 4 
Italy 289 39 114 83 22 125 -6 -62 -12 220 -23 1657 18 0 27 
Netherlands 323 546 782 490 67 671 113 456 465 394 45 121 163 55 218 
Poland 142 94 97 56 43 -13 47 12 95 126 98 165 32 17 -11 
Portugal 2 -7 474 392 101 -4 103 -54 -47 304 84 55 165 64 15 
Romania 204 35 523 203 129 263 -9 -13 11 68 -25 -2 53 4 -28 
Slovakia -41 103 13 31 -19 -33 -56 99 3 212 37 9 299 -47 534 
Spain 41 75 114 9 20 20 -48 -9 -14 -4 25 -31 -14 -14 -11 
Sweden 63 -8 15 2 15 9 64 0 37 -34 -21 147 -8 -3 -20 
United Kingdom 144 254 39 95 141 45 27 56 108 35 69 36 68 419 123 
Average 257 104 174 121 72 244 61 53 152 83 48 224 71 54 86 
 
 53 
Figure 33 – Measures to increase confidence 
 
 
 Mean Median Mode 
Online sellers having secure online payment systems and 
ensuring that my payment data is not stolen or misused 6.92 8.00 10 
Having the same consumer rights wherever I shop online across 
the EU 6.57 7.00 10 
Online sellers ensuring that my personal data is not stolen or 
misused 6.54 7.00 10 
Public authorities across the EU ensure that fraudulent online 
sellers are closed down 6.52 7.00 10 
Accurate contact information is available on seller websites 6.49 7.00 7 
Public authorities across the EU co-operate to ensure that all 
products sold online are safe 6.24 7.00 8 
Hotlines of online sellers are available for sales and after-sales 
service without additional charges 6.14 6.00 7 
Websites have online trust marks 6.05 6.00 8 
Independent and accurate price comparison websites 5.99 6.00 7 
Online sellers agree to resolve any individual dispute with me 
through an online dispute resolution body 5.92 6.00 5 
Online sellers adhere to industry codes of good conduct 5.83 6.00 5 
Public bodies providing information, advice and support about 
my consumer rights online 5.82 6.00 5 
Independent advice websites providing guidance on best 
products 5.71 6.00 5 
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
             
 
 54ANNEX 2 
 
Consumer Survey and Mystery Shopping Survey of Price Comparison Websites73 
 
1 The consumer survey examined the frequency of use of price comparison websites, the 
reasons for using them and the overall consumer experience.  The survey covered all 27 
Member States. The mystery shopping study identified 262 pric e comparison websites in 
the EU.  The working definition used for a price comparison website is " a website that 
lists and compares prices for new products available directly ( on-click access) from 
numerous, competing online retailers' websites ".  The availability of price comparison 
websites across Member States is rather une ven.  The countries with the highest number 
of price comparison websites are the ones that  have the biggest e-commerce markets (e.g. 
the U.K., France, Germany and the Netherlands). 
 2 The mystery shopping exercise covered 233  price comparison websites, 15 online 
marketplaces and approximately 1200 checks on retailers' websites.  On each price comparison website, mystery shoppers carried  out checks for five specific products. 
 
3 Price comparison websites are the first poi nt of call in the shopping trip of many 
consumers, irrespective of whether consum ers actually end up making the purchase online 
or offline.  These websites are supposed to  deliver accurate and updated information in a 
simple and transparent manner.  This is expected to intensify competition between 
retailers and benefit consumers.  Since these information intermediaries play a pivotal role in the functioning of the e-commerce market, co nsumers should be able  to trust them and 
benefit from their use.  The consumer su rvey and mystery shopping looked into price 
comparison websites and examined how well they serve consumers' interests. 
 
Price comparison websites – Frequency of use 
 
4 Price comparison websites are used widely a ll over the EU, even in countries in which 
they are not well established or widespread.  Four out of five online consumers (81%) 
have used a price comparison website in 2010.  Only one fifth of consumers have never 
used one.  Around half of consumers (48%) use such websites once a month.   
 5 Price comparison websites are most used in  the Czech Republic (92%), Poland (91%) and 
Slovakia (90%) whereas they are least used in Cyprus (42%), Es tonia (41%) and Malta 
(14%).          
                                                
 
73 Consumer Market Study on the functioning of e-commerce. Civic Consulting (2011). 
 
 55Figure 1: Proportion of respondents who use a price comparison website 
Table 1: Proportion of respondents who use a price comparison website
14414251575863687374747475767980818181828385868790919192
0 1 02 03 04 05 06 07 08 09 0 1 0 0MaltaEstoniaCyprusLithuaniaIrelandBelgiumLuxembourgHungaryNetherlandsBulgariaSloveniaRomaniaSpainPoertugalLatviaAustriaEUUnited KingdomFranceFinlandDenmarkGermanySwedenGreeceSlovakiaItalyPolandCzech Republic
 
Note: Based on all respondents (N=29010) 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
Price comparison websites - Lo cal language, national offers 
 
6 The big majority of price comparison websites (86%) are available only  in one language.  
Only 14% offer the choice of more than one  language or are available in a different 
language version.  The languages most likely to be offered in addition to the default 
language are German, Italian and English.  The price comparison websites offering 
multiple languages are concentrat ed in a handful of countries (more than half can be found 
in Denmark, Portugal, Hungary and the UK) .  Many countries do not have any price 
comparison websites in a language other than the local one.   
 
7 The majority of price comparison websites (8 3%) include offers onl y from one country.  
Only 17% of price comparison websites offer th e possibility of viewi ng offers from other 
countries than the one which the website is located.  In the cases where this is possible, these websites offer the possibili ty to view offers from other EU countries while also in 
some cases from the United States, China and other third-countries.   
 8 The mystery shopping exercise also revealed that there ar e a number of businesses which 
operate country specific price comparison webs ites in multiple EU countries, but choose 
not to show offer from one of their sites in another country 
 9 It seems that consumer choice is limited and consumers do not have easy access to offers 
across the Internal Market since price co mparison websites are primarily in local 
languages and do not offer cross-border offers. 
 
 
  
 
 56Price comparison websites – Actual purchases 
 
10 Despite the fact that the overwhelming majority  of online shoppers have  used such sites, 
only a small minority (7%) have actually boug ht a product through a seller they found  
through a price comparison website.    The items bought most frequently through price 
comparison websites are child care articles, medicines (prescribed as well as over-the-
counter), electrical household a ppliances, electronics, sports  and outdoor equipment as 
well as CDs and DVDs.  A socio-demogra phic breakdown of responses shows that 
consumers with more years of education are mo re likely to use price comparison websites. 
 
Price comparison websites – Reasons influencing use 
 
11 The majority of consumers (56%) use price co mparison websites because they think it is 
the quickest way to compare prices.  One in  two consumers (51%) use such websites to 
find the cheapest prices, while a sizeable group (22%) use them to fi nd out more about the 
range of offers available.  16% use price comparison websites to find information about 
specific products and 13% to find comments by other customers, product reviews and ratings. 
Figure 2: Why do you use price comparison websites? 
   
Note: Based on PCW user sub sample (N=23619) 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
Price comparison websites - Provision of information 
 
12 It is important that trusted intermediaries such as price comparis on websites provide clear 
and transparent information since they are one of the first sources of information 
influencing a consumer's purchasing decision. 
 
Business address 
13 According to the e-commerce directive74, price comparison websites should have on their 
websites details that allow them to be contact ed rapidly and communicated with in a direct 
and effective manner.  This includes both a geographic address and an electronic mail 
address.  However, just 47% of price co mparison websites provided their full business 
address.  13% did not provide any business details while in 40% of the cases these were 
partially provided.  
 
 
Ratings, Consumer Reviews 
                                                 
74 Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects 
of information society services, in pa rticular electronic commerce, in the In ternal Market (Directive on electronic 
commerce) 
 
 5714 In one out of two trials (53%) the price comparison websites offered consumers ratings 
about online retailers.   
 15 70% of price comparison websites do not prov ide consumers with pr oduct reviews, with 
only 30% doing so.  Similarly, in 69% of price comparison websites there were no consumer reviews for products.  Product reviews written by consumers were only 
available on 31% of the price comparison websites checked. 
 
Provision of other information 
16 Nearly all price comparison websites (95% of trials) provided the retailer's name on their 
website, while in two out of three trails (67% ) they provided the retailer's logo. Also, in 
89% of cases, price comparison websites included photographs of the products.  
 
17 The delivery time not specified on price comp arison websites very often.  Only 20% of 
price comparison websites provided informa tion on delivery time on their results page, 
while 80% did not do so.   
 18 Concerning product availability, most price comparison websites (62%) do not provide 
any such information. 
 19 An area that price comparison websites seem to be doing well on information provision is 
product information, with 72% of them  providing information about product 
characteristics. 
 
Financing 
20 Just one in two (52%) price comparison we bsites have information on their business 
model.  Even when they do have such info rmation, in 60% of cases they do not indicate 
clearly if the retailers appearing on the specifi c price comparison website pay to have their 
products listed. 
 
Coverage 
21 The coverage of specific price comparison we bsites is often not clear. Just 16% provide 
clear information explaining why some retail ers are listed whereas others not.  18% 
provide this information but not very cl early, while 66% do not provide any such 
information at all. 
 
Default ranking
75  
22 Two out of three price comparison websites (68%) do not provide any information about 
the default ranking of the search results.  17 % provide very clear information while 15% 
provide some information but it is not so clear.  For those websites that provided 
information about the default ranking of results, 20% offers were ranked according to lowest price first while 15% of results were ranked by relevance.  46% of results were 
ranked according to "popularity" or a mix of " popularity and relevance" .  In 18% of cases 
it was not possible to identify how ordering ta kes place, despite the information offered by 
the websites.    
 
Price 
                                                
 
75 Ranking used by Price Comparison Website when the user has not selected any settings 
 
 5823 The mystery shopping exercise results show that price comparison websites as a whole 
have significant deficiencies on the provision of relevant info rmation concerning prices.   
 24 In most cases (73%), there is no clear information on how often price comparison 
websites update their prices.  6% provide some  information on this but it is unclear (e.g. 
"regularly ", "periodically " and " constantly ") while 21% provide clear information on how 
price updates take place. 
 25 In 44% of cases it is unclear whether the informa tion provided on price comparison 
websites includes VAT and any other taxes.  In  51% of cases details of the delivery costs 
are not provided.   
 26 Only 22% of tested price comparison webs ites provided clear information about their 
policies concerning fraudulent or rogue trader s.  12% provide uncle ar information while 
66% did not provide any such information at all.  The overwhelming majority of price 
comparison websites do not participate in a trustmark scheme or an industry code of conduct. 
 
27 Even when mystery shoppers actively tried to  rank results according to the cheapest offer, 
this was not always possible. Mystery shoppers  managed to do this easily only in 67% of 
cases.  In 28% of trials this was not possible and in 5% of cases this was difficult.  The 
ranking of search results according to price in cluding delivery costs was possible only in 
14% of cases. 
 28 In nearly three out of four tr ials (72%) using the lowest price view, the cheapest offer is 
within the first five products.  However, in 15% of such trials, th e cheapest offer was not 
listed at all on the first page of results. 
 29 Mystery shoppers carried out checks trying to find out where the cheapest price appears in 
comparison to the default view.  The cheapest pr ice appears first only in 38% of cases.  In 
66% of cases it appears in the top five offers  while in 76% of cases in appears in the top 
ten.  Yet, in 17% of cases the cheapest price is  not even listed on the first page of results. 
 30 The table below presents a comparison to results from searching using the lowest price 
view. 
Figure 3: Rank of cheapest correct offer dur ing mystery shopping trial (using lowest 
price view, if available) and default view 
Rank of cheapest correct offer Product search using lowest 
price view, if available  
(Percentage of trials)  Default view   
(Percentage of trials)  
First offer listed (Rank 1) 47% 38% 
Listed among the first five offers 
(Rank 1-5) 72% 66% 
Listed among the first ten offers 
(Rank 1-10) 81% 76% 
Not listed on first page 15% 17% 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 
 5931 It is clear that if a consumer uses the "rank by the lowest price" function, then the chances 
of the lowest price appearing higher improve.76  However, the difference between this and 
the default view is not very high and there is  a 15%-17% chance, nearly one in six, that 
the consumer will not be able to find the ch eapest offer anywhere on the first page of 
listings. 
 
Price comparison websites – Consumer experience 
 
32 From the consumers that use price comparis on websites, one in tw o (50%) find them the 
quickest way to compare prices and one in th ree (32%) say they ar e useful to find out 
more about the range of available offers.  23% say they buy the cheapest product they find 
on price comparison websites.  22% find the easy to use and nearly as many (21%) say 
they are useful to find information about sp ecific products.  18% find price comparison 
websites useful to find customer co mments, product reviews and ratings. 
 33 It is interesting to note, that  even in countries where they are not used widely, such as 
Cyprus, Malta and Greece, the ones who use them report positive experiences. 
 
Figure 4: According to YOUR EXPERIENCE using price comparison websites, what 
reflects your opinion? 
 
Note: Based on PCW user sub sample (N=23619) 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 34 However, a sizeable group of consumers are not so positive about their experience with 
using price comparison websites.  17% find th at different price comparison websites show 
different prices, and 14% use at least two or three price comparison we bsites as each site 
presents different offers.   
 35 19% of consumers who buy goods online do not us e price comparison websites.  The most 
important reasons for not using price comparis on website do not reflect specific concerns 
with the services offered by the price compar ison websites themselves.  The main reason 
for non-use is because consumers prefer to shop from a website they already know (26%), while one in four consumers (22%) say that  they do not know of any price comparison 
websites.  Some prefer to use general search  engines (14%), while others compare prices 
                                                
 
76 One should keep in mind that 29% of the pri ce comparison websites checked, did not have a " rank by the 
lowest price " function 
 
 60across several websites that they already know 13%.  14% prefer to speak to a person in a 
shop or on the phone.  To a small extent, consumers say that there are some negative features in the service of price comparison websites that put them off from using them: 10% say they do not trust them, 6% say they do not provide adequate information about product specifications, 5% cannot find the produc ts they are searching for, 4% find such 
websites to be very complicated, 4% find no va riation in prices in the type of products 
they are searching for, 4% say the products compared are not the same and 3% find that 
the listed prices are not up to date. 
Figure 5: Why don’t you use price comparison websites? 
 
Note: Based on non PCW user  sub sample (N=5391) 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
  36 Overall, most consumers using price comparis on websites did not feel misled (70%), yet 
an important section thinks they were misled  12% while 18% report th at they do not know 
if they were misled or not.  From those that  did feel misled, one in  two (49%) said that 
they found a cheaper price elsewhere, one in th ree (32%) said that th e indicated price did 
not correspond to the price on the seller's  website and 16% said that the product 
information was not correct.   Other reasons  for being misled include delivery time, 
delivery charges, and retailers' refusal to sell because of a consumer's place of residence. 
Figure 6: Why have you felt you were misled  when using a price comparison website? 
 
Note: Based on respondents who felt mislead (N=2832) 
 
 61Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 
Price comparison websites – Usefulness as rated by mystery shoppers 
 
37 On the whole (73%), mystery shoppers found price comparison websites to be relatively 
easy to use.  Yet, a significant minority (27%) found them difficult to use.  This suggests 
that there is some room for improvement. 
 38 Disappointingly, a large number of price comparis on websites seem to fail in one of their 
primary tasks, allowing a consumer to make an  informed choice.  In nearly 4 out of ten 
cases (39%), mystery shoppers could not agree that the tested pric e comparison websites 
were useful in allowing them to make an  informed choice.  In 48% of cases they 
"somewhat agreed" and only in 13% of cases they said that they strongly agreed. 
 
Figure 7: Usefulness of PCW for making an informed choice 
Indicate your level of agreement with the following statement: "I found this PCW to be useful in 
allowing me to make an informed choice"
Strongly disagree, 15%
Strongly agree, 13%
Somew hat disagree , 24%Somew hat agree, 48%
 
Sample: N=227 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
39 There are various features on a price comp arison website that affect a consumer's 
perception whether he or she is making an  informed choice using a price comparison 
website.  This can be traced from informa tion about the website's business model to how 
results are ranked. 
 40 Mystery shoppers found that 91 price comparis on websites (out of 233 tested) were not 
useful in providing information about their busin ess model.  This is very important since if 
this information is not provided the cons umer cannot know how products are ranked, 
whether retailers' are paying to have their produ cts listed, or what the market coverage is. 
 
 
 6241 One aspect that mystery shoppers did not find useful was information about the products.  
86 websites were found to be not useful in providing prod uct information.  This ranged 
from confusing product specifications, whether products were sold stand-alone or they 
included accessories, if essential component s to a product (e.g. camera lens) were 
included in the price or not and so on. 
 42 Another important piece of information on price comparison websites that mystery 
shoppers thought was generally lacking was in formation about the retailers.  Mystery 
shoppers found that 81 price comparison websites were not useful in this aspect.  Provision of information about retailers can act as a significant boost to consumers' 
confidence.  If a consumer knows that a specific retailer is not a rogue seller or an 
unreliable one, then he or she is much more likely to buy from them. 
 43 Two of the main reasons that consumers use online shopping are to save money and have 
a wider choice.  Price comparison websites act as intermediaries that are supposed to help 
consumers making such purchase decisions.  Howe ver, the mystery shoppers revealed that 
a large number of price comparison websites fail in this.  They marked 78 price comparison websites as being not useful in  helping them identify the correct offer.
77  This 
is because in some price comparison websites the products were not av ailable at all, in 
others mystery shoppers had to use various se arch terms in order to identify them, some 
generated large numbers of totally unrelated pr oducts, while others di d not generate easily 
the cheapest correct offer.  The price functi on itself was marked as unhelpful in 72 price 
comparison websites out of the 233 checked.  This  was attributed to various reasons such 
as: limited range of correct offers, not bei ng able to rank products  according to price, 
addition of sponsored links on top, incorrect of fers, add-on fees such as delivery missing 
from the price, lack of clarity on VAT and other taxes, and discrepancies between price 
comparison websites and retailer websites. 
 
Consistency of price comparison websites and retailer websites 
 
44 The mystery shoppers carried out around 1200 tr ials checking whether the information 
provided on price comparison websites, concer ning the cheapest offer, were consistent 
with the information provided on the website of  that specific retailer.  Mystery shoppers 
found the cheapest offer on the price comparis on website and then clicked through to the 
retailer's website and carried out a consiste ncy check.  This check included comparing 
information such as VAT, delivery costs, delivery time, product availability, product 
information. 
 45 In nearly the entirety of cases (95%), the links  were functioning and direct to the retailers' 
websites.  In the vast majority of cases, 90%,  the retailer's name indicated on the price 
comparison website was identical to the name provided on the website of the retailer itself. 
 46 In around eight out of ten cases (79%) the retailer's price including VAT matched the 
price indicated on the price co mparison website.  At the same time, in 21% of cases the 
prices quoted on the price comparison website were not accurate.  In the relatively few 
cases (19%) that the price comparison webs ite provided the final price including VAT, 
                                                
 
77 The "correct offer" is identified as the cheapest available product that matches the specifications of the product on the 
mystery shoppers' list  
 
 63other taxes and delivery costs, this was not consistent with the price on the retailer's 
website in one in three cases (36%). 
 47 It is unusual that price comp arison websites display informa tion about the time it takes for 
goods to be delivered.  This happ ens only in out of five cases (20%).  Even when the price 
comparison websites indicate such information, in more than half of cases (57%) the 
delivery time on the retailer's websites doe s not match that indicated by the price 
comparison website.  
 48 Most price comparison websites (62%) do not pr ovide information on the availability of 
specific products.  In the case of the one s that do, this is us ually matched by the 
information provided on the retailer's website, 80 % of cases.  However, in one out of five 
cases the information offered by the retail er on product availability is different. 
 49 The situation concerning information on product specification is much better as this is 
indicated in nearly thr ee out of four (74%) times. When su ch information is indicated on a 
price comparison website, this matched by retail ers almost always (in 90% of cases).   
 
50 The table below summarises results where the offer available on a retailer's website was 
not identical to the offer availa ble on a price comparison website. 
 
Figure 8: Reasons for discrepancies between offers on price comparison websites and 
retailers' websites 
 
Retailer Page: If the offer was not identical, which statements apply?
149
81
76
64
36
3128
17
6 5
020406080100120140160
Price on
retailer higher
than on PCWDelivery costs
higher than on
PCWPrice on
retailer lower
than on PCWProduct is not
availableDelivery not
avavilable to
my countryDelivery costs
lower than on
PCWDelivery time
longer than on
PCWProduct
specifications
less attractiveRetailer does
not have trust
mark
indicated on
PCWProduct is not
new Number of trials
 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 
 
 
 6451 As the table reveals78, most of the discrepancies are rela ted to price differences.  This does 
not always mean that prices are more expensive on a retailer's website.  As a matter of fact, in 107 cases one aspect of  the price was cheaper.  Howe ver, in 230 cases one aspect 
of the price was more expensive on retaile rs' websites.  The underlying reason for such 
differences is not necessarily price manipul ation.  These discrepancies can be partly 
attributed to technical reasons such as ine ffective or delayed up-da ting of price data.  
Despite the underlying motive for the resu lting negative price differentials, the end 
outcome remains the same for consumer.   
 
Add-on costs  
 
52 The mystery shopping exercise and to a lesser extent the consumer survey, reveal that 
often there are various add-ons to prices indicated on price comparison websites.  These 
add-on costs are not clear upfront and they  appear as incremental add-ons, dripping 
through the entire purchas ing process.  These higher costs are due to a variety of reasons: 
VAT and/or other taxes, higher delivery charges, longer delivery time, etc.   
 53 Consumers often focus on the in itial price of the chosen of fer (e.g. what appears as the 
cheapest good) and commit to buy from that busin ess even if the pric e gradually increases 
until they purchase the good.  Since consumers have demonstrably the tendency to focus on the initial price of what looks  to be the cheapest offer, bus inesses have an incentive to 
adopt similar strategies and ex clude add-on costs from the initi al offer.  Therefore, it is 
likely that consumers find it very difficult to choose meaningfully between different 
products or businesses since many of the initia l offers do not reveal the end price that 
consumers have to pay.   The way offers ar e presented has a marked effect on consumer 
behaviour the latest resear ch has shown that this cau ses considerable consumer 
detriment
79.  The provision of prices and other ke y information should be offered upfront 
to consumers in a clear and simple manner. 
 
Retailer websites – Provision of information 
 
54 It is not only important that price comp arison websites provide clear and transparent 
information themselves, but it is as equally essential that the retailers to which consumers are directed at do the same. 
 
Business address 
55 According to the e-commerce directive
80, online retailers should have on their websites 
details that allow them to be contacted ra pidly and communicated wi th in a direct and 
effective manner.  This includes geographic ad dress and electronic mail address.  In 67% 
of cases, retailers provided th eir business address while in 27% of cases it was partially 
provided (e.g. missing postcode, or country).  6% of traders did not provide any 
information concerning their business address.   Concerning electronic mail address, in 
77% of cases retailers provided this on their websites.  However, a significant percentage 
                                                 
78 "Delivery not available to my country".  This item was checked only in trials in Member States with a low 
number (less than 10) of price comparison websites.  
79 Advertising of prices. OFT (2010) 
80 Directive 2000/31/EC of the European Parliament and of the Council of 8 June 2000 on certain legal aspects 
of information society services, in pa rticular electronic commer ce, in the Internal Mark et (Directive on electronic 
commerce) 
 
 65(23%) did not provide this, as they are oblig ed. The absence of geographic and electronic 
mail address appears to be exacerbated in th e case where retailers appear on the websites 
of online market places. 
 
Cooling-off period 
56 In four out of five cases (83%) mystery shoppe rs were able to find information concerning 
their right to return a good without giving a reason at least within seven days after the 
purchase.  However, in 14% of cases retailers  did not provide any in formation on this and 
in 3% the information provided was unclear. 
 
Legal warrantee 
57 The situation concerning provisi on of information about consumer s' right to have a faulty 
good repaired or replaced or even get a re fund, within two year s after purchasing the 
goods seems to be worse.  Such information was provided only in 37% of cases.  In 16% of cases this information was unclear while in nearly one in two cases (47%), such 
information was not provided at all. 
 
Retailer websites – Offers 
 
58 In two thirds (67%) of cases, re tailers were registered in th e same country as the one at 
which the price comparison websites were targete d.  Yet, up to 27% of retailers provided a 
business address outside the targeted country wh ile in 6% of cases the provided 
information was unclear.  In the cases where cross-border targeti ng is observed, this 
usually involves business from countries w ith bigger economies offering their goods on 
price comparison websites targeted at consum ers in countries with  smaller economies.  
For example, most price comparison websites targeted at Belgian consumers are very 
frequently French listed businesses, some price comparison websites targeted at Irish 
consumers are UK listed businesses, and pric e comparison websites targeting Austrian 
consumers are German listed businesses.