Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on creative content online in the Single Market {SEC(2007) 1710}
Date: 2008-01-03
Institutions: European Commission
Subjects: Internet, access to information, audiovisual production, dissemination of information, intellectual property, provision of services, single market

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 03.01.2008 
COM(2007) 836 final 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

on Creative Content Online in the Single Market 

{SEC(2007) 1710} 

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COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

on Creative Content Online in the Single Market 

1. 

INTRODUCTION 

1.1. 

Creative Content Online 

The  availability  and  take-up  of  broadband,  and  the  increasing  possibility  to  access  creative 
content  and  services  everywhere  and  anytime,  provide  challenging  new  opportunities.  For 
consumers, it means new ways to access, and even to influence, creative content available on 
worldwide  networks  such  as  the  internet,  both  from  home  and  using  mobile  devices.  For 
companies,  it  means  the  possibility  to  offer  new  services  and  content  and  to  develop  new 
markets. 

With  the  emergence  of  new  devices,  networks  and  services,  these  challenges  have  to  be 
addressed  by  content  and  network  operators,  right  holders,  consumers,  governments  and 
independent  regulators.  Successful  responses  will  be  key  to  growth,  jobs  and  innovation  in 
Europe. 

They  can  best  be  addressed  at  European  level  as  most  of  these  new  services  need  the  dual 
advantages of economies of scale and cultural diversity that the EU internal market provides. 
Therefore,  EU  policies  should  aim  at  promoting  fast  and  efficient  implementation  of  new 
services and related business models for the creation and circulation of European content and 
knowledge  online.  In  this  context,  the  Commission  has  identified  as  "creative  content 
distributed  online":  content  and  services  such  as  audiovisual  media  online  (film,  television, 
music  and  radio),  games  online,  online  publishing,  educational  content  as  well  as  user-
generated content. 

According to the study on "Interactive content and convergence"1 (covering EU 25), by 2010, 
revenues  from  online  content,  will  more  than  quadruple  from  €1.8bn  in  2005,  to  €8.3bn  by 
2010, online content will also make up a sizeable part of total revenues in some sectors; about 
20% for music and 33% for video games. 

With the spread of broadband internet access, the roll-out of advanced mobile networks, and 
the mass availability of digital devices it is possible to distribute online content on a market of 
dimensions unknown until now. European consumers increasingly access films, music, news 
or games through different networks and electronic devices. 

1 

Study  on  "Interactive  Content  and  Convergence;  Implications  for  the  Information  Society" 
commissioned  by  Information  Society  and  Media  Directorate-General  of  the  European  Commission, 
published on 25 January 2007 

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1.2. 

Results of the public consultation 

With a view to exploring further ways to support the development of creative content online 
services in Europe, the Commission launched a public consultation on "Content Online in the 
Single Market" in July 2006. This consultation attracted more than 175 written contributions 
from a great variety of stakeholders2. 

A  number  of  contributions  to  the  public  consultation3,  invite  the  Commission  to  show 
restraint and not intervene prematurely with further legislation in a nascent and fast evolving 
market given the risk of adverse effects. However, some call for specific changes in the legal 
framework on issues such as intellectual property rights licensing, private copying levies and 
interoperability. 

Many contributions call on the Commission to encourage cooperation (including charters or 
codes  of  conduct)  between  industry,  right  holders  and  consumers  on  issues  such  as  DRMs, 
Content Online and Film Online. 

Furthermore, there were various calls for financial support and various requests for promoting 
standards concerning the interoperability of DRMs. 

The  public  consultation  was  complemented  by  the  aforementioned  independent  study  on 
"Interactive  Content  and  Convergence".  Based  on  a  wide  stakeholders'  consultation,  it 
provided  an  overview  of  the  challenges  to  be  addressed  to  favour  the  development  of  new 
content services in the EU. 

1.3. 

Objectives of this Communication 

Building on the results of the consultation process, and in order to complement the initiatives 
already  undertaken  in  the  context  of  the  i2010  strategy,  the  Commission  intends  to  launch 
further actions to support the development of innovative business models and the deployment 
of cross-border delivery of diverse online creative content services. 

The  market  for  online  creative  content  is  emerging  and  developments  take  place  at  a  rapid 
pace. This calls for a twofold approach to deal with already identified challenges that need to 
be  addressed  quickly,  and  to  launch  further  discussions  on  some  of  the  existing  and 
forthcoming  challenges.  Therefore,  this  Communication  is  launching  a  focused  public 
consultation in preparation for the adoption of a Recommendation on Creative Content Online 
by  the  Council  and  the  European  Parliament,  and  is  creating  a  stakeholders'  discussion  and 
cooperation  platform,  hereafter  the  "Content  Online  Platform",  to  initiate  the  work  on 
forthcoming challenges. 

This Communication addresses a first set of challenges central to the uptake of online content 
services  in  Europe.  Other  initiatives  of  the  Commission  such  as  the  Internal  Market  review 
and  the  review  of  the  consumer  'acquis',  the  review  of  the  Satellite  and  Cable  Directive 
(93/83/EEC)4,  the  report  on  the  application  of  the  2001  Copyright  Directive  (2001/29/EC)5, 

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5 

http://ec.europa.eu/avpolicy/other_actions/content_online/contributions/index_en.htm 
For a summary of the public consultation, see the Commission staff working paper on Creative Content 
Online. 
OJ L 248, 6.10.1993, p. 15. 
OJ L 167, 22.6.2001, p. 10. 

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the Green Paper currently being prepared by the Commission on Copyright in the Knowledge 
Economy,  the  implementation  report  on  the  Recommendation  on  online  management  of 
music rights (2005/737/EC)6 and the forthcoming Second evaluation report on the Conditional 
Access Directive (98/84/EC)7 provide further opportunities to deal with challenges related to 
creative content online. 

2. 

CHALLENGES & PROPOSALS 

The challenges raised by online distribution of creative content are considerable, ranging from 
legal issues related to licensing to attractive billing systems or broadband and spectrum issues. 
The last point will be dealt with in the framework of the modernisation of the legal framework 
for electronic communications, while others will have to be broached as appropriate. 

The  transfer  of  creative  content  services  to  the  online  environment  is  an  example  of  major 
systemic  change.  For  policy  makers,  making  the  most  of  this  change  means  meeting  three 
related objectives: 

– 

– 

ensuring  that  European  content  achieves  its  full  potential  in  contributing  to 
European  competitiveness  and  in  fostering  the  availability  and  circulation  of 
the  great  diversity  of  European  content  creation  and  of  Europe's  cultural  and 
linguistic heritage; 

updating/clarifying  possible  legal  provisions  that  unnecessarily  hinder  online 
distribution of creative content in the EU, while acknowledging the importance 
of copyright for creation.  

– 

fostering users' active role in content selection, distribution and creation. 

Based on the results of the public consultation and on the study on "Interactive content and 
convergence",  the  Commission  deems  that  there  are  four  main,  horizontal  challenges  which 
merit action at EU-level: availability of creative content; multi-territory licensing for creative 
content; interoperability and transparency of DRMs; and legal offers and piracy8.  

2.1. 

Availability of creative content 

Lack of availability of creative content for online distribution and lack of active licensing of 
rights  on  new  platforms  remain  major  obstacles  for  the  development  of  online  content 
services. Since online content is a nascent market, the value of new forms of distribution is 
sometimes still unknown. This results in major difficulties in settling terms of trade for online 
exploitation  of  creative  content.  Right  holders  fear  loosing  control  as  illegal  copying  in  the 
digital  environment  has  proven  to  be  highly  damaging.  While  legitimate  online  offer  of 
creative content is widely regarded as one of the means of curbing illegal copying, some right 
holders prefer to protect existing revenue streams rather than actively licensing their rights on 
new platforms. Licensing for online exploitation is also hampered by potential conflicts with 
rights already granted for main forms of exploitation. 

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8 

OJ L 276, 21.10.2005, p. 54 – OJ L 284, 27.10.2005, p. 10. 
OJ L 320, 28.11.1998 p. 54. 
For  the  other  issues  raised  in  the  public  consultation,  see  the  Commission  Staff  Working  Paper  on 
Creative Content Online. 

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Most  of  the  difficulties  related  to  availability  of  content  are  considered  as  inherent  to 
emerging  markets,  and  stakeholders  are  expected  to  find  innovative  and  collaborative 
solutions to exploit content online and prevent or remedy bundling, exclusivity or non-use of 
media  rights9.  In  response  to  stakeholders'  demand,  the  Commission  intends  to  enhance  its 
role  of  facilitator  and  to  encourage  "win-win"  deals  and  cross-industry  agreements  in  the 
framework of the new Content Online Platform. 

The  application  of  competition  law  can  in  some  cases  remedy  abuse  relating  to  the 
exploitation or bundling of rights. 

Another issue relates to the often high transaction costs for rights-clearance. One particularly 
acute  problem  is  that  of  orphan  works  –  i.e.  books,  photographs,  film  material  and  other 
works under copyright for which the right holders are difficult or even impossible to identify 
or to locate10. Efforts for identification and location are costly and time consuming. Hence, in 
many cases, orphan works cannot be exploited and yield no financial benefit to the (unknown 
or not locatable) author so they are unproductive both in economic and social terms. 

The problems arising from orphan works are notably tackled within the context of the i2010 
Digital  Libraries  initiative,  which  aims  at  bringing  Europe's  cultural  and  scientific  heritage 
online. In its Recommendation of 24 August 2006 on the digitisation and online accessibility 
of  cultural  material  and  digital  preservation11,  the  Commission  urged  the  Member  States  to 
create  mechanisms  facilitating  notably  the  use  of  orphan  works.  Council  conclusions  of  13 
November  200612  endorsed  the  Commission's  approach  and  stressed  the  need  to  ensure  the 
effectiveness of national solutions for orphan works in a cross-border context. This is also a 
key  recommendation  in  the  report  on  copyright  issues  of  the  High  level  expert  group  on 
digital  libraries13.  The  Commission  will  closely  monitor  the  implementation  of  the 
Recommendation and the need for further action at European level. 

2.2.  Multi-territory licensing for creative content 

Another  major  market  change  resulting  from  convergence  is  the  ability  of  content  service 
providers to reach new audiences by making content available on new platforms at European 
or even global level. As a result of copyright territoriality, a content service provider has to 
obtain the right to make content available in each Member State. The costs incurred, may be 
detrimental  to  the  exploitation  of  a  vast  majority  of  European  cultural  works  outside  their 
national markets. 

The  online  environment  allows  content  services  to  be  made  available  across  the  Internal 
Market.  However,  the  lack  of  multi-territory  copyright  licences  makes  it  difficult  for  online 
services to fully benefit from the Internal Market potential. 

While  it  is  first  for  right  holders  to  appreciate  the  potential  benefits  of  multi-territory 
licensing,  there  is  a  need  to  improve  the  existing  licensing  mechanisms  to  allow  for  the 
development  of  multi-territory  licensing  mechanisms,  for  instance  by  promoting  fair 

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13 

Interactive Content and Convergence; Implications for the Information Society, 2007, p. 13 
Gowers  Review  of  Intellectual  Property,  December  2006,  p.  69:  "The  British  Library  estimates  40 
percent of all print works are orphan works". 
OJ L 236, 31.8.2006, p. 28. 
OJ C297, 7.12.2006, p. 1. 
See: http://ec.europa.eu/information_society/activities/digital_libraries/hleg/index_en.htm 

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competition on the market for rights management. It should be noted that different practices 
apply to different types of content. 

In  the  music  sector,  in  order  to  facilitate  the  introduction  of  a  multi-territorial  system  of 
copyright licensing for online music services, the Commission issued a Recommendation on 
online management of music rights in October 2005. This Recommendation aims to facilitate 
the grant of multi-territory licences for online use of musical works by affirming the right of 
right  holders  to  entrust  the  management  of  any  of  the  online  rights  necessary  to  operate 
legitimate  online  music  services,  on  a  territorial  scope  of  their  choice,  to  a  collective  rights 
manager  of  their  choice,  irrespective  of  the  Member  State  of  residence  or  the  nationality  of 
either the collective rights manager or the right holder. The Commission has recently invited 
all interested stakeholders to submit views and comments on their initial experience with this 
Recommendation  and,  in  general,  on  how  the  online  music  sector  has  developed  since  its 
adoption. 

The  issue  of  multi-territory  licensing  has  become  relevant  in  other  creative  content  sectors 
such  as  the  audiovisual  sector.  In  the  audiovisual  sector,  while  the  new  Directive  on 
audiovisual  media  services  will  facilitate  cross  border  development  of  on-demand  services, 
many  right  holders  still  choose  to  grant  licences  for  only  a  few  national  territories,  thus 
slowing  the  availability  of  audiovisual  works  in  video-on-demand  catalogues  abroad. 
Developing  a  system  where  right  holders  would  be  encouraged  to  grant,  next  to  the  main 
licence, a second multi-territory licence would be one of the issues to be covered in the public 
consultation in respect of the preparation of a proposal for a Recommendation, as well as an 
issue  for  discussion  within  the  Content  Online  Platform.  Furthermore,  the  Commission 
envisages  financing  an  independent  study  investigating  the  economic  consequences  for 
European audiovisual works that could result from such a practice. 

2.3. 

Interoperability  and  transparency  of  Digital  Rights  Management  systems 
(DRMs) 

The  uptake  of  legitimate  services  passes  by  tackling  the  problem  of  digital  piracy  by 
enhancing the cooperation between the various players in the value chain and by developing 
attractive offers and business models for the distribution of digital content. DRM constitute a 
key  enabling  technology  in  this  respect,  allowing  right  holders  to  enforce  their  rights  in  the 
digital environment and to develop business models adapted to consumer demand and needs. 
However,  for  some  time  now,  DRMs  and  associated  Technological  Protection  Measures 
(TPMs)  have  sometimes  been  perceived  in  a  negative  way,  as  technology  merely  used  to 
restrict  copying  and  competition,  failing  to  meet  initial  users'  and  businesses'  expectations. 
This has led to a situation where certain market players opt for online distribution of content 
without  any  copy-restriction  mechanisms.  Notwithstanding,  these  developments  mainly 
concern  one  type  of  content  and  business  model;  i.e.  pay  per  download  of  music. 
Technologies  allowing  management  of  rights  in  the  online  environment  might  be  a  key 
enabler  for  the  content  sector's  digital  shift  and  for  the  development  of  innovative  business 
models - especially with regard to high value content.  

The  move  to  a  DRM  protected  environment  results  in  a  major  paradigm  shift  for  European 
citizens  and  consumers.  Usage  governed  by  licensing  agreements  enforced  by  technical 
measures now complements usage of copyright protected work governed by law. As a result 
consumers  must  increasingly  confront  complex  contractual  terms  when  purchasing  music, 
film  or  other  creative  content  online,  and  are  not  necessarily  fully  aware  of  the  usage 
restrictions  applied  or  the  use  of  their  personal  data.  This  is  perceived  as  severely  affecting 

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user interests, and putting the existing balance between copyright holders and user interests at 
risk. At the same time, while a  great  number of DRM protected content services  have been 
launched  in  the  past  years,  stakeholders  are  increasingly  concerned  that  the  lack  of 
interoperability, standardisation and cross platform friendliness in DRMs leads to gatekeeper 
situations. In order not to jeopardize the future of this technology as an enabling factor, it is 
crucial to address the question of interoperability. 

Better  interoperability  of  DRM  systems  would  improve  the  level  of  competition  and 
consumer acceptance necessary for the take-up of online distribution of creative content. For 
consumers, DRM  interoperability means that they can choose different devices and still use 
them with different 'download-to-own' services. For content producers or content aggregators 
interoperability  means  they  are  not  locked  into  one  distribution  channel  that  forms  a 
gatekeeper  to  the  marketplace.  For  device  and  ICT  developers,  interoperability  means  that 
their products can be used with different content services14. 

As  lengthy  discussions  among  stakeholders  did  not  yet  lead  to  the  deployment  of 
interoperable DRM solutions, there is in any case a need to set a framework for transparency 
of DRMs regarding interoperability, by ensuring proper consumer information with regards to 
usage  restrictions  and  interoperability.  Providing  consumers  with  an  accurate  and  easily 
understood labelling system on interoperability and usage restrictions, allowing them to make 
an  informed  choice  will  improve  citizens'  rights  and  provide  for  a  sound  basis  for  a  wider 
availability of content online. 

2.4. 

Legal offers and piracy 

Recording music and film industries have expressed the view that the Commission should be 
prepared to take legislative steps to make sure that the public interest in ensuring an adequate 
level  of  data  protection  is  properly  reconciled  with  other  important  public  policy  objectives 
such  as  the  need  to  combat  illegal  activities  and  to  protect  the  rights  and  freedoms  of  third 
parties.  

Piracy  and  unauthorised  up-  and  downloading  of  copyrighted  content  remains  a  central 
concern. The  fight against online  piracy involves a number of  complementary elements: (1) 
developing legal offers; (2) educational initiatives; (3) enforcement of legal rights; (4) seeking 
improved  cooperation  from  Internet  Service  Providers  (ISPs)  in  stopping  dissemination  of 
infringing  content.  The  idea  of  education  and  awareness-raising  on  the  importance  of 
copyright  for  the  availability  of  content  is  widely  supported  as  a  tool  in  the  fight  against 
piracy. 

Content  owners  call  for  increased  co-operation  in  the  fight  against  piracy.  Annex  I  to  the 
recently  adopted  legislative  proposal  for  the  reform  of  the  Authorisation  Directive  includes 
references  concerning  compliance  with  national  measures  implementing  the  Copyright 
Directive  (2001/29/EC)  and  the  Enforcement  Directive  (2004/48/EC)15.  Moreover,  Article 
20(6)  of  the  legislative  proposal  to  amend  the  Universal  Service  Directive  provides  for  an 

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15 

To the extent that DRMs are a form of conditional access system, in the second evaluation report of the 
Conditional  Access  Directive  that  is  to  be  undertaken  in  2008,  the  Commission  will  assess  to  what 
degree that Directive has or could facilitate the roll out of DRMs. 
COM(2007) 697 final. 

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obligation for ISPs to clearly inform subscribers in advance of the conclusion of the contract 
and regularly thereafter of their obligations to respect copyright and related rights16.  

In  France,  a  Memorandum  of  Understanding17  between  music  and  film  producers,  Internet 
service  providers  and  the  Government  was  signed  on  23  November  2007.  Under  the 
agreement, France is to set up a new Internet authority with powers to suspend or cut access 
to the web for those who illegally file-share. 

It  would  indeed  seem  appropriate  to  instigate  co-operation  procedures  ("code  of  conduct") 
between access/service providers and right holders and consumers in order to ensure a wide 
online  offer  of  attractive  content,  consumer-friendly  online  services,  adequate  protection  of 
copyrighted  works,  awareness  raising/education  on  the  importance  of  copyright  for  the 
availability of content and close cooperation fight piracy/unauthorised file-sharing. 

3. 

CONCLUSION 

While the review process of Directives affecting distribution of content, such as the Satellite 
and Cable Directive, the 2001 Copyright Directive and the Conditional Access Directive are 
ongoing, this Communication launches a process to address the identified and most pressing 
challenges  related  to  online  distribution  of  creative  content.  The  Commission  wishes  to 
address the challenges raised in this document by two means: 

– 

16 
17 

18 

The  setting-up  of  the  "Content  Online  Platform",  a  framework  for  discussion,  at 
European  level.  This  Platform  devoted  to  content  specific  or  cross-industry 
negotiations  around  the  issues  related  to  the  online  distribution  of  creative  content, 
should  include,  according  to  the  agenda  of  each  meeting,  content  providers,  right 
holders,  companies  and  organisations  from  the  telecoms  and  technology  sectors  as 
well as consumers. The remit of the Content Online Platform will include the issues 
mentioned  in  this  Communication  such  as:  availability  of  content,  improvement  of 
rights clearance mechanisms, development of multi-territory licensing, management 
of copyright online, cooperation mechanisms to improve respect of copyright in the 
online  environment.  The  work  of  the  Platform  should  also  contribute  to  the 
elaboration of a Guide for consumers and users of Information Society services18. 

COM(2007) 698 final 
"Accord pour le développement et la protection des œuvres et programmes culturels sur les nouveaux 
réseaux" – http://www.culture.gouv.fr/culture/actualites/index-olivennes231107.htm 
See  MEP  Z.  Roithova's  (EPP)  "own  initiative"  report  on  Consumer  confidence  in  the  digital 
environment and European Parliament resolution of 21 June 2007 on consumer confidence in the digital 
environment 
http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-
//EP//TEXT+TA+P6-TA-2007-0287+0+DOC+XML+V0//EN&language=EN  

(2006/2048(INI)) 

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– 

the  preparation, 

Reflecting  on 
towards  mid  2008,  of  a  proposal  for  a 
Recommendation  of  the  Parliament  and  the  Council  on  Creative  Content  Online, 
which would cover the following issues: transparency (labelling) and interoperability 
of DRMs; encouragement of innovative licensing regimes in the area of audiovisual 
works; and legal offers and piracy. On the main elements of the future proposal, the 
Commission  wishes  to  further  consult  interested  stakeholders.  Therefore,  all 
stakeholders are invited to take position on the elements listed in the Annex to this 
Communication by 29/02/2008. 

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Creative Content Online – Policy/Regulatory issues for consultation 

ANNEX 

Digital Rights Management 

1) 

2) 

3) 

4) 

5) 

Do  you  agree  that  fostering  the  adoption  of  interoperable  DRM  systems  should 
support the development of online creative content services in the Internal Market? 
What  are  the  main  obstacles  to  fully  interoperable  DRM  systems?  Which 
commendable practices do you identify as regards DRM interoperability? 

Do you agree that consumer information with regard to interoperability and personal 
data  protection  features  of  DRM  systems  should  be  improved?  What  could  be,  in 
your  opinion,  the  most  appropriate  means  and  procedures  to  improve  consumers' 
information in respect of DRM systems? Which commendable practices would you 
identify as regards labelling of digital products and services? 

Do you agree that reducing the complexity and enhancing the legibility of end-user 
licence  agreements  (EULAs)  would  support  the  development  of  online  creative 
content  services  in  the  Internal  Market?  Which  recommendable  practices  do  you 
identify  as  regards  EULAs?  Do  you identify any  particular  issue related to  EULAs 
that needs to be addressed?  

Do  you  agree  that  alternative  dispute  resolution  mechanisms  in  relation  to  the 
application  and  administration  of  DRM  systems  would  enhance  consumers' 
confidence  in  new  products  and  services?  Which  commendable  practices  do  you 
identify in that respect? 

Do  you  agree  that  ensuring  a  non-discriminatory  access  (for  instance  for  SMEs)  to 
DRM solutions is needed to preserve and foster competition on the market for digital 
content distribution? 

Multi-territory rights licensing 

6) 

7) 

8) 

Do you agree that the issue of multi-territory rights licensing must be addressed by 
means of a Recommendation of the European Parliament and the Council?  

What  is  in  your  view  the  most  efficient  way  of  fostering  multi-territory  rights 
licensing  in  the  area  of  audiovisual  works?  Do  you  agree  that  a  model  of  online 
licences based on the distinction between a primary and a secondary multi-territory 
market can facilitate EU-wide or multi-territory licensing for the creative content you 
deal with? 

Do  you  agree  that  business  models  based  on  the  idea  of  selling  less  of  more,  as 
illustrated  by  the  so-called  "Long  tail"  theory,  benefit  from  multi-territory  rights 
licences for back-catalogue works (for instance works more than two years old)? 

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Legal offers and piracy 

9) 

10) 

11) 

How  can  increased,  effective  stakeholder  cooperation  improve  respect  of  copyright 
in the online environment? 

Do you consider the Memorandum of Understanding, recently adopted in France, as 
an example to followed? 

Do  you  consider  that  applying  filtering  measures  would  be  an  effective  way  to 
prevent online copyright infringements? 

Please  submit  your  comments  by  29/02/2008  in  electronic  format.  All  submissions  will  be 
published on the Commission’s website if not requested otherwise. Contribution to be treated 
confidentially should indicate this at the top of the first page. Should you want to add a cover 
letter please do so in a separate document. In case your comments exceed four pages, please 
provide an executive summary. All submissions should be mailed to the functional mailbox 
of  the  Audiovisual  and  Media  Policies  Unit  of  the  Directorate-General  for  Information 
Society and Media: avpolicy@ec.europa.eu. 

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