COMMISSION STAFF WORKING DOCUMENT Bringing e-commerce benefits to consumers
Date: 2012-01-11
Institutions: European Commission
Subjects: Internet, commercial arbitration, consumer protection, digital technology, electronic commerce, electronic money, single market, technical barriers to trade, trade promotion, trade regulations

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-commerce and the completion of the Digital Single 
Market have been identified as two of the twelve 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-line  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 dominant distance sales channel 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  research  many  more  offline  purchases  on  the 
internet, ensuring that businesses that sell online 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-commerce 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-commerce has grown both domestically and cross-border.  During 
2008-2010, domestic business-to-consumer e-commerce has grown from 28% to 36% of 
the  population  making  an  online  domestic  purchase, 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  constraints,  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-commerce  as  an  opportunity  to  reach  more 
consumers to grow.  According to the market 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 choice4.   

4  However,  despite  this  growth,  the  untapped  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 Committee of the Regions on cross-border business-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. 

 
 
 
 
 
 
 
 
                                                 
However, 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 could 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 products were bought from online shops in a country rather than 
from  offline  shops.  In  a  typical  shopping  trip6,  consumers  have  at  least  double  the 
selection  when  shopping  domestically  online  rather  than  offline.    If  they  shop  online 
across the EU they have up to 16 times more products to choose from. 7 

6  The current consumer welfare gains from e-commerce in goods8 alone in terms of lower 
online  prices  and  wider  choice  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 GDP 9.   

7  An assessment of the incidence of problems when purchasing goods online and problems 
when purchasing goods offline, showed that there is no significant difference between the 
sales medium used and problems faced. Yet the potential 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-border  e-commerce  and  a 
set of actions to address these.  The Commission has carried out further in-depth work to 
identify more general obstacles to e-commerce 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 identified in the Communication on cross-border 
e-commerce and the Digital Agenda, this report 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  and  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 legislation 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 online. 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 buying 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. 

2

 
 
 
 
 
 
                                                 
8  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 development 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 transactions run smoothly and regular online cross-
border shoppers are rather 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 presented in this report show that many businesses 
are  not  in  compliance  with  existing  rules  concerning  selling  and  advertising  online.  
Improvements  to  the  general  enforcement  framework  surrounding  e-commerce  will 
increase  competition  and  consumer  welfare  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 are reaping its full benefits.  

1) Introduction 

12  This  report  is  a  follow  up  to  the  Commission  Communication10  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  single  market  of  e-commerce  and  other  online 
services  12  by  providing  evidence  on  how  e-commerce  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 been identified as two of the twelve priority 
areas  of  action  under  the  Single  Market  Act.    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  result  in  an  increase  in  consumer  welfare  and  a 
more competitive European economy. The Digital 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 previous work on e-commerce since it covers in 
more  detail  issues  that  are  related  to  domestic  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  services  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 Committee of the Regions on Cross-border business 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. 

3

 
 
 
 
 
 
 
 
                                                 
and offline, and a mystery shopping exercise 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 their 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  consumer  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 consumers if this was achieved.  These benefits 
are  calculated  on  the  basis  of  price  savings  and  an  increased  choice  of  goods  available 
online and across EU borders.  In addition, the report identifies in detail 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 individuals 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 from 4% in Romania to 68% in 
Denmark.    In  many  Member  States  (Denmark,  Germany,  France,  Luxembourg,  the 
Netherlands,  Finland,  Sweden  and  the  UK)  the  figure  is  higher  than  55%,  yet  in  other 
Member  States  (Bulgaria,  Greece,  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 (2011). Data extracted on 21 March 2011. 

4

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure 1 - Percentage of individuals who ordered goods or services over the Internet for 
private use in the last year (2010) 

Unit: Percentage of Individuals

80 

70 

68  67  67  66 

60 

50 

40 

30 

20 

10 

0 

60  59 59 

56 

42 

40 

38 38

36

33

29

27 27

24

18 18 17 17

15  15 

12  11 

5

4

DK  NL  UK  SE  LU  DE FI  FR  AU  EU 
 27

BE MT IE SK PO CZ SI ES CY HU EE LV IT  PT  EL  LT  BG RO

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 similar 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 goods or services via the Internet to end consumers17. 

18  Figure 2 shows the use of e-commerce by retailers 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 proportion 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 Intra-EU Trade Yearbook of 
2009, the intra-EU trade volume in goods was four the volume of trade in services in 2008. 

5

 
 
 
 
 
 
 
                                                 
Figure 2 - Percentage of retailers selling online (2010) 

Unit: Percentage of Retailers

90

80

78

70

60

50

40

30

20

10

0

65

58

57

56

55

55

55

53

53

53

52

50

50

50

49

49

47

43

41

36

35

33

31

28

26

24

19

K
U

E

I

T
A

K
D

I

S

L
E

E
E

R
F

E
D

7
2
U
E

Z
C

L
N

S
E

T
M

E
S

T

I

U
H

I

F

U
L

K
S

E
B

T
L

Y
C

T
P

L
P

G
B

V
L

O
R

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 
201018.  This represents around 3.5% of the total EU retail sector.  The variations across 
European countries are very large.    The 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 registers as a share of the total retail sector.  The UK has the 
lion's share of the EU e-commerce market with 34.6% of EU total, followed by Germany 
(19.6%) and France (19.1%).  The second group of countries with lower 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 consumers made an online purchase of a good or a service last year.  
However,  most  of  these  purchases  were  domestic  as  only  9%  of  EU  consumers  made  a 
cross-border  purchase  online  (figure  3).  Concerning  cross-border  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 Cyprus, 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. 

6

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
variations are rather significant, with six countries at 20% or higher (Belgium, Denmark, 
Luxembourg, Malta, Austria and Finland) and eight countries below 5% (Bulgaria, Czech 
Republic, Greece, Italy, Lithuania, Hungary, Poland and Romania).    

Figure 3 – Individuals who ordered goods or services over the Internet from sellers from 
other EU countries in the last 12 months 

Unit: Percentage of Individuals

53

60

50

40

30

20

10

0

35

29

28

21

20

18

16

15

13

12

10

10

9

9

8

8

7

7

6

4

4

3

3

2

2

2

U
L

T
M

T
A

I

K F
D

E
B

E

I

R
F

Y
C

E
S

L
N

I

S

K
U

7
2
U
E

K
S

E
D

E
E

S
E

V
L

O
P

L
E

T

I

T
L

U
H

G
B

Z
C

L
P

Source: Eurostat, Information society statistics (2010). Data extracted on 14 April 2010. 

1

O
R

21  One in three (32%) online shoppers19 said that they bought goods from other countries in 
the  EU  in  2010.    Online  shoppers  in  Malta  (94%),  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  language  in  which  offers  are  made  are 
important factors underpinning cross-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 Germany (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  German,  English  or  French.  Two  in  three  EU 
online  cross-border  shoppers  bought  goods  from  websites  available  in  English,  21% 
bought  from  websites  in  German  and  14%  bought  from  websites  in  French.      56%  of 
European consumers use another language than 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".   

7

 
 
 
 
 
 
                                                 
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 shoppers 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%) retailers did not sell cross-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  sell  cross-border  but  similar  to  the  level  recorded  in  2005 
(75%).    Only  one  in  five  EU  (21%)  retailers  sell  their  goods  or  services  in  other  EU 
countries.    From  the  ones  selling  cross-border,  most  sell  in  more  than  four  countries 
(62%),  29%  sell  in  two-three  countries  while  9%  sell  only  in  one  country.  Again,  large 
differences between countries are observed.   

Figure 5 – Number of countries to which retailers sell cross-border (2010) 

Unit: Percentege of Retailers

60%

50%

40%

30%

20%

10%

0%

U
L

T
A

L
E

S

I

K
S

E
B

T S

I

I

L
N

K
D

K
U

T
M

E

I

E
E

T
L

E
D

7
2
U
E

U
H

Y
C

E
S

V
L

Z
C

R
F

S
E

O
N

T
P

I

G F
B

L
P

O
R

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.  

8

 
 
 
 
 
 
 
 
 
                                                 
Figure  6  –  Number  of  other  EU  countries  where  retailers  actively  market/advertise  to 
final 

Unit: Percentage of Retailers

2006

2008

2010

69

5

7

13

7

72

5

6

10

7

67

5

5

14

9

none

1

2 or 3

4+

dk/na

Source: European Commission (2011). Eurobarometer 300 "Retailers’ attitudes 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  while  in  four  other 
countries (Bulgaria, Finland, Poland 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 other than their own such as English, 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 sell cross-border seem 
clear  however.    56%  of  retailers  using  e-commerce  and  selling  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 methods23 

25  In 2010, EU online consumers spent around €1163 purchasing goods online.    Across the 

EU, there are big variations at national level.  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".  

9

 
 
 
 
 
 
 
 
                                                 
the 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  average  693€  purchasing  goods  from  other 
countries.  Consumers  in  Austria,  Bulgaria,  Estonia,  Italy,  Cyprus,  Lithuania,  Latvia, 
Luxembourg, Malta, Portugal, Romania and Slovenia 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

1800

1600

1400

1200

1000

800

600

400

200

0

Y
C

K
D

E
D

S
E

K
U

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N

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F

7
2
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A

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T
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K
S

I

O S
R

U
H

V
L

E
E

G
B

T
M

U
L

Basis: Domestic Online Shoppers 

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

10

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure  8  –  Euro  spent  online  purchasing  products  from  websites  in  another  EU27 
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

2000

1800

1600

1400

1200

1000

800

600

400

200

0

Y
C

T
L

T

I

S
E

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D

U
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A

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Basis: Cross-Border 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  €30 24,  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  articles  (€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 

11

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure 9 – Median amount of money spent online by product category 

Unit: Euro

Car, motor vehicle

Furniture

Electrical household appliance

Child care articles

Electronic equipment (incl. computer, phone, camera)

Sports and outdoor equipment

Car parts, motor vehicle parts

Tools and do-it-yourself supplies

Gardening supplies

Clothes, shoes and jewellery

Cosmetics

Children’s products/toys

Prescribed medicines

Computer software (incl. games)

Over the counter medicines (sold without prescription)

CDs/DVDs

Books

Other (Specify)

.00

50.00

100.00

150.00

200.00

250.00

300.00

350.00

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

28  Online  shoppers  use  a  variety  of  payment  methods  to  carry  out  their  e-commerce 
transactions.  Most  online  transactions  (45%)  are  concluded  using  credit/charge  cards.  
Online  payment  systems  (e.g.  PayPal,  Smart2Pay,  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  delivery  (20%)  and  debit  cards  (18%).  Cash  on 
delivery  is  a  very  popular  means  of  payment  in  Bulgaria,  the  Czech  Republic,  Greece, 
Hungary,  Poland,  Romania,  Slovakia  and  Slovenia,  with  over  35%  of  consumers  using 
this.  In some of these countries 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  direct  debit  (11%),  cheque  payments  (2%)  and 
payments by mobile phone (1%).  (see figure 10 below) 

12

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 10 – Payments methods used for online purchases over the last 12 months 

Unit: Percentage of Online Shoppers

Credit/Charge Card

Online payment systems such as
PayPal, Smart2Pay, Webmoney,
Giropay, iDEAL

45.3

36.2

Bank/credit Transfer

31.0

Cash on Delivery

Debit Card

19.7

17.7

Direct Debit

10.7

Cheque

1.8

Payment by mobile phone (for
example PayMo)

1.2

Other

2.7

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

45.0

50.0

3) Untapped potential 

29  Consumers can benefit from e-commerce in terms 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  strong  growth  in  e-commerce  in  the  last  few  years,  it  is 
evident that the full potential of this sales channel has not been reached.  There are still 
considerable obstacles holding back 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  frequent  online  shoppers,  the  dominant  factor  for  shopping 
online seems  to be price, followed by perceived 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.  

13

 
 
 
 
 
 
 
Figure 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 considerable 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  say  that  finding  certain 
products is a key reason for them shopping online.  Also, in some countries (Luxembourg, 
Malta  and  Poland)  a  considerable  group  of  consumers  (25%  or  more  compared  to  an 
average of 19%) says that one of the main reasons for shopping online is the wider choice 
found there. 

3.2 

Savings    

32  According to consumers' own perceptions, there are significant savings shopping online.  
Consumers estimated that on their last online purchase they saved around €136 compared 
to buying the same product in a shop26.  Based on price data collected for a basket of 30 
goods  sold  domestically,  including  delivery  costs,  there  are  savings  buying  products 
online rather than offline, in 13 out of the 15 product sub-categories for which price data 
were  collected.    Excluding  food  products,  the  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 potential savings that could have 
been  made  by  purchasing  the  same  product  online.    The  biggest  savings  were  found  on 
products with relatively lower prices (excluding food products).  The product categories 
where  savings  of  at  least  5%  can  be  found  online  are  women's  fragrances,  in-car 
navigation, LCD TVs, and mobile phones. 27 

33  Consumers  can  also  find  price  savings  by  shopping  cross-border.    For  example,  in  a 
basket  covering  100  goods,  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 market study on the functioning of e-commerce". 

14

 
 
 
 
 
 
                                                 
could have actually been completed.  However, in the considerably fragmented EU online 
marketplace,  most  online  cross-border  transactions  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  advantage  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 trip29, 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 offline, consumers have 16 times more choice 
with  the  choice  offered  by  online  shops  across  Europe.  (Figure  12  and  13  in  Annex  1).  
Interviews  with  industry  stakeholders  revealed  that  more  popular  product  ranges  can  be 
found both online and offline, yet due to constraints 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 goods31 alone in terms of lower 
online  prices  and  wider  choice  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  online  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, something that reflects a reasonable pattern of 
consumer behaviour.  If one takes 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 prices of electrical and electronic goods. 

3.4 

Case study on electrical and electronic goods32 

37  An  analysis  of  online  and  offline  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, France, 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  available  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 market 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".  

15

 
 
 
 
 
 
 
 
                                                 
majority  of  sales  through  both  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  offline.  While  this  suggests  that  in  the  case  of  electronic  and 
electrical goods, the main role of online sales is an alternative sales channel of models that 
are also available offline rather than a provider of a greater range of products, the range of 
models available from one individual online shop 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  were  on  average  lower  than 
offline  prices  and  that  across  countries  there  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  countries.  Moreover,  within  countries  there 
tended  to  be  more  convergence  between  online  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 shopping between online and offline shoppers, 
reveals that this is approximately the same. According to their own estimates (including 
time spent researching the purchase), online shoppers spent around 70 minutes before they 
completed  their  last  purchase  of  a  good  online,  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  seem  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  shopping  online  than  the  average  (69  minutes 
compared to 70 which is the average) but they 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 recent 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  transformational  impact  on  the  retail  sector.    It  is 
increasingly  becoming  an  integrated  part  of  retailers'  business  strategies.    Retailers  are 
realising  that,  despite  the  initial  disruption  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). 

16

 
 
 
 
 
 
 
 
 
 
                                                 
on  e-commerce  as  a  sales  channel,  many  businesses  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,  around  80%  of  businesses  said  that  the  future  of  online 
commerce  lies  more  with  cross-channel  or  merged  channel  capabilities35.    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  than  10%  of  their  annual  sales  come  from  online  channels 
while 65% said that less than 2% comes from mobile.  Yet, the prospects for e-commerce 
are positive since when the same businesses are asked to look ahead 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 consumers 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 next 12 months.  In 2010, 46% of 
consumers said that they are interested in making a cross-border transaction in the next 12 
months  whereas  in  2008  and  2006,  the  corresponding  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  businesses  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 with consumers were the same 
across the EU.  However, a parallel can be drawn with consumer behaviour; 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 cross-border sale (70%) would 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 retailers 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 their cross-border operations if they could chose one single 
European contract law; 81% of those 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. 

17

 
 
 
 
 
 
 
                                                 
3.5.3  Mobile-commerce, Social-commerce 

47  At the moment, both  mobile  and  social commerce in Europe are at an embryonic stage.  
Just 6% of consumers made an online purchase 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 mobile 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 around 101 million during the fourth quarter of 
2010,  while  shipments  of  personal  computers  were  around  92  million38.  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 201039. 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  mobile  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 Europe.  Spain was closely followed by Italy 
and the United Kingdom.41 

50  The  spread  of  smart  phones  opens  many  opportunities  to  consumers  and  businesses. 
Businesses are already advertising their goods and services on mobile devices and using 
these  devices  as  a  tool  to  attract  consumers.  Smart  phones  can  have  a  strong 
transformative  effect  on  commerce  by  enabling  mobile  transactions,  identifying  store 
locations,  serving  as  a  platform  for  comparisons  of  information  on  prices,  quality  and 
product specifications, etc.   

51  In  a  recent  global  business  survey,  62%  of  retailers  of  questioned  businesses  said  that 
mobile commerce represents a big untapped potential for their company and 45% said the 
same about social networks.42  

52  In a recent survey, 7% of respondents said that, 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 social media sites, using them to advertise their products and 
drive  traffic  to  their  websites,  or  receive  feedback  from  existing  or  potential  customers.  

38 http://www.idc.com/getdoc.jsp?containerId=prUS22689111, 
http://www.idc.com/about/viewpressrelease.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 Mobile 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). 

18

 
 
 
 
 
 
 
 
 
                                                 
Despite  the  relatively  small  size  of  the  social  commerce  market  at  present,  the  high 
penetration of social networks provides promises 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  has  created  innovative  ways  of 
organising,  accessing,  sharing  and  evaluating  information  such  as  prices,  technical 
product  characteristics,  shop  opening  hours,  quality  reviews,  etc.    Search  engines,  price 
comparison  websites,  product  comparison  sites  and  consumer  reviews  are  tools  that  are 
now  used  widely  and  are  becoming  embedded  in  consumer  behaviour  and  business 
models.   

4.1.1  Research behaviour45 
55  Online  shoppers  use  a  variety  of  research  methods  to  inform  their  purchase  decisions 
before they buy goods online. In their first three steps during their research, 31% visited 
sellers' websites, 30% of used a search engine, 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

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

31%

30%

27%

24%

24%

22%

18%

16%

14%

14%

Read, heard or viewed online advertisements

8%

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

5%

5%

4%

4%

4%

4%

Other

10%

0%

5%

10%

15%

20%

25%

30%

35%

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". 

19

 
 
 
 
 
 
 
 
 
                                                 
56  A  closer  look  at  consumer  behaviour  reveals  that  there  are  differences  in  research 
behaviour  across  countries  but  also  between  frequent  and  occasional  online  shoppers46.   
Frequent online shoppers prefer to use general search engines while occasional shoppers 
are more likely to search for information on manufacturers' and brand websites.  Frequent 
online shoppers also use online marketplaces that 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. Another information tool that is used widely 
in the EU is price comparison websites.   Four 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 online tools.  Nearly 
one in two (47%) used at least one offline research 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, offline shoppers are using online tools for their research.  For 
their  last  purchase,  nearly  one  in  two  offline  shoppers  (49%)  used  at  least  one  online 
research method.  Some of the most commonly used online research methods by offline 
shoppers  are:  visits  to  sellers'  websites  (15%),  search  engines  (15%),  online  consumer 
reviews  (14%),  price  comparison  websites  (13%)  and  visits  to  manufacturers'/brand 
websites  (13%).  This  cross-channel  research  behaviour  acts  as  an  added  incentive  for 
businesses, both online and offline, 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 offline 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). 

20

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure 15 – Research methods used before purchasing offline a product 

Unit: Percentage of Individuals

0%

10%

20%

30%

40%

50%

60%

Visited shops in person

53%

I did not take any other action to research this online purchase

39%

Discussed with friends, colleagues

19%

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

15%

15%

15%

14%

13%

13%

12%

11%

8%

8%

7%

Read indipendent consumer or testing ,agawine in print

5%

Visited social networking sites

Contacted online or phone customer service

Visited independent advice website

3%

3%

3%

Other

14%

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  such  as  search  engines,  price  comparison 
websites and online marketplaces to inform themselves before making an online or offline 
purchase.  From those consumers using price 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  offers,  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  exercise  that  looked 
into  the  business  practices  of  price  comparison  websites  and  examined  how  well  they 
serve consumers' interests.  

59  A comparison of the average of cheapest prices found on price comparison websites and 
the average of the cheapest online prices found through the price 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". 

21

 
 
 
 
 
 
 
 
                                                 
found  that  the  online  prices  are  generally  cheaper  than  offline  prices,  the  savings  from 
price comparison websites are potentially higher if compared to offline shopping. 

60  Eight  out  of  ten  online  consumers  use  price  comparison  websites  in  their  shopping 
decisions.    Yet,  a  recent  mystery  shopping  exercise  has  shown  that  despite  the  high 
numbers of consumers using such information intermediaries, cross-border offers are not 
reaching most consumers since the big majority 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 comparison websites are not performing very well in 
terms of the information they provide to consumers.  Contrary to the provisions of the E-
commerce  Directive48,  many  price  comparison  websites  (53%)  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  price  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 ranking 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 listed or not, while 66% did not 
provide any such information at all.  

63  In  most  cases  (73%),  there  was  no  clear  information  on  how  often  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 presentation of prices. Two out of tested three price comparison 
websites  (68%)  did  not  provide  any  information  about  the  default  ranking  of  the  search 
results.  Even when the mystery shoppers tried 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 comparison websites, the first offer was the cheapest 
only in 38% of trials.  Using the lowest price 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 half trials (47%).In 15% of trials, the cheapest 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') 

22

 
 
 
 
 
 
 
 
 
 
                                                 
 
Figure 16: Rank of cheapest offer after adjusting to rank according to lowest price  

What is the rank of the cheapest correct offer?

s
l
a
i
r
t

f
o
r
e
b
m
u
N

600

500

400

300

200

100

0

47%

521

11%

122

6% 6% 3% 2% 3% 1%

68

66

1% 2% 1% 1%

1% 1% 1% 1% 1% 1% 0% 0%

124

11%

0%

5

32

27

31

10

8

19

11

14

9

9

10

7

7

8

4

5

1 2 3 4 5 6 7 8 91011121314151617181920

Not listed
>20

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

66  Price comparison websites provided the final price 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  retailers'  websites  in  36%  of  cases.    It  is  not  very 
often  that  price  comparison  websites  provide  information  on  the  availability  of  specific 
products (only 38% of cases) or delivery time (only 20% of cases).  

23

 
 
 
 
 
 
 
Figure 17: Provision of information on PCW: Price information  

Cheapest Offer: What type of price information is provided on the result page if PCW?

Price(including VAT, ther taxes, 
and delivery costs), 19%

Price(excluding VAT and other 
taxes), 1%

Price(including VAT and other 
taxes), 36%

Price(unclear if VAT and other 
taxes are included), 44%

Note: “Price (unclear if VAT is included)” refers 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 comparison websites do not feel misled (70%), yet 
a significant proportion feel misled (12%) or cannot tell whether they were misled or not 
(18%).    Young  consumers  (18-24  years)  and  consumers  with  postgraduate  studies 
reported  more  often  than  others  that  they  felt  misled.    From  those  that  felt  misled,  49% 
said  they  found  a  cheaper  price  elsewhere,  32%  said  that  the  indicated  price  did  not 
correspond to the price on the seller'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 have 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  between  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  provision  of  prices  and  other  key  information 
should be offered upfront in a clear and simple 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  search  intermediary  produced  enough  choice.    The 
study  found  that  if  consumers  expanded  their  search  to  other  price comparison  websites 

24

 
 
 
 
 
 
and  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  "Advertising  of  Prices",  investigated  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 pricing) - 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 using 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  websites  rather  than  buying  these  products 
offline or online without carrying out extensive research. 

72  Yet,  these  cheaper  prices  where  consumers  can  make  savings  are  not  straightforward  to 
find on price comparison websites.  Also, the mystery shopping exercise revealed that the 
overall  performance  of  price  comparison  websites  is  problematic  in  many  other  aspects 
too.  The fact that such websites are so widely used and that the majority of consumers 
place their trust in them to inform their decisions amplifies the overall consumer detriment 
suffered by consumers. 

4.3 

Purchase behaviour51 

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 finally choose a specific website for purchases 
reveals that the main reasons is price (60%), followed by some previous experience with 
purchasing from the same website (25%), the availability of clear and complete product 
information (20%), the availability of a product 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". 

25

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure  18  –  Reasons  for  which  consumers  finally  choose  a  specific  website  for  making 
the purchase of a good 

Unit: Percentage of Online Shoppers

0%

10%

20%

30%

40%

50%

60%

The price was lowest 

50%

I purchased from the site before 

25%

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

20%

19%

17%

15%

10%

10%

10%

9%

8%

The site provided a phone number / contact details of the seller

6%

Information on other consumer rights was clear and complete

There was a trust mark on the website

5%

4%

It was from a seller that has a shop I can go to for after-sales service

3%

Other

2%

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  domestic  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%), tickets for events (35%), and household goods (35%).  Figures 
19 and 20 below shows the evolution, from 2006 to 2010, on consumer purchases online. 

26

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 19 – Most recent purchase in the origin country by type of products 

Unit: % of individuals

Travel and holiday accomodation

Clothes, sports goods

Books/magazines/e-learning material

Tickets for events

Household goods

Films/Music

Electronic equipment

Computer hardware

Others

Food/groceries

Medicine

Shares/financial services/insurance

0

5

10

15

20

25

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

Travel and holiday accomodation

Clothes, sports goods

Books/magazines/e-learning material

Tickets for events

Household goods

Films/Music

Electronic equipment

Computer hardware

Food/groceries

Others

Shares/financial services/insurance

Medicine

0

10

20

30

40

50

60

Source: Eurostat, Information society statistics (2010). Data extracted on 23 June 2011. 

27

2006
2010

2006
2010

 
 
 
 
 
 
75  The  "Consumer  market  study  on  the  functioning  of  e-commerce"  shows  that  in  2010, 
consumers'  last  purchases  dominated  the  fields  of  electronic  equipment  (18%),  clothes, 
shoes and jewellery (17%), books (10%) and CDs/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

Electronic equipment (incl. computer, phone, camera)

Clothes, shoes and jewellery

9%

1%

18%

2%

3%

3%

5%

6%

6%

10%

6%

7%

Books

CDs/DVDs

Electrical household appliance

Computer software (incl. games)

Cosmetics

Children’s products/toys

Sports and outdoor equipment

17%

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 contact, 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.  

28

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  increase  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 online regulatory environment in order to reach 
the  untapped  potential  of  e-commerce.    An  improved  European  legal  framework  on 
consumer rights, contract  law 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 uncertain 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  affordable  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 subscriptions per 100 inhabitants, according to OECD 
May 2010 statistics).  As stated in the Digital Agenda, every 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 than they were a few years ago.  Yet, there is 
room for action in order to reach the e-commerce targets set out in the Digital Agenda. 

52 European Commission (2010).  Eurobarometer 299a.  "Attitudes towards cross-border trade and consumer 
protection". . 

29

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure 22 – Broadband penetration rate 

Source: European Digital Agenda Scoreboard (2010). Data extracted on 9 November 2011.  

80  Many consumers that are potentially interested 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 lack of trust in online businesses.  According 
to  Eurostat  data,  the  main  inhibiting  factors  about  buying  goods  and  services  online  are 
concerns  with:  the  security  of  payments  (11%),  privacy  (10%),  receiving  or  returning 
goods and getting redress (9%), access to payment card (4%), delivery (3%), difficulty in 
finding relevant information on the website (3%) and other reasons (3%). (See figure 23 
below). 

30

 
 
 
 
 
 
 
Figure 23 – Reasons for not buying online 

Unit: Percentage of Individuals

0

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

11

10

They lack the necessary skills

5

They don't have a payment card

4

20

17

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

3

3

The speed of the Internet connection is too low

1

Other reasons

4

Source: Eurostat, Information society statistics (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  service  (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". 

31

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure  24  –  Most  important  reasons  for  not  buying  products  online  (three  answers 
possible) 

Unit: Percentage of Offline Shoppers

I like going to shops and seeing the products

40%

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

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

29%

28%

26%

21%

I prefer in-person sales service

17%

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

12%

12%

7%

6%

6%

4%

4%

4%

4%

Delivery arrangements of online sellers are not convenient for me

4%

Products I buy are often of a better quality in shops

2%

Other

3%

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  problems  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  likely  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 personal 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. 

32

 
 
 
 
 
 
                                                 
Figure 25 – Most important reasons for only occasionally buying products online (three 
answers possible) 

Unit: Percentage of Occasional Online Shoppers

I like going to shops and seeing the products

38%

0%

5%

10% 15% 20% 25% 30% 35% 40% 45%

It’s more difficult to solve any problems if something goes wrong

I want the products immediately

32%

29%

I have concerns regarding misuse of my personal/payment details

19%

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

15%

14%

14%

11%

10%

Delivery arrangements of online sellers are not convenient for me

8%

It’s easier to compare prices in shops

I do not wish to buy more products online

There’s more choice in shops

7%

6%

6%

The type of payment card I have is often not accepted by online sellers

5%

Products I buy are often of a better quality in shops

4%

Other

9%

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

84  According  to  the  views  of  frequent,  occasional  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 details (20%). (See figure 26 below) 

33

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure  26  –  Concerns  about  buying  products  online  domestically  (three  answers 
possible) 

Unit: Percentage of Individuals

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

31%

29%

26%

21%

21%

20%

Long delivery times

18%

Delivery costs or final price are higher than displayed on website

Customer service is poor

15%

13%

There is a lower level of consumer protection when buying online

I do not know what my consumer rights are when buying online

8%

7%

Goods sold online are unsafe

5%

Other concerns – specify

2%

I don’t have any concerns

18%

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

85  A  comparison  of  concerns  buying  online  cross-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  increase  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 stronger concerns is lack of knowledge 
of  consumer  rights  when  shopping  online  (19%,  an  increase  of  8%).    (See  figure  27 
below).  

34

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure  27  –  Concerns  about  buying  products  online  in  another  EU  country  (three 
answers possible) 

Unit: Percentage of Individuals

0%

5%

10%

15%

20%

25%

30%

35%

40%

Returning a product I didn't like and getting reimbursed is not easy

Long delivery times

Replacement or repair of a faulty product is not easy

Products will not be delivered at all

35%

34%

29%

27%

Wrong or damaged products will be delivered

23%

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

21%

19%

19%

Delivery costs or final price are higher than displayed on website

16%

Customer service is poor

12%

The level of consumer protection in other EU countries is lower than in my
country of residence

Goods sold online are unsafe

Other concerns

2%

6%

6%

I don’t have any concerns

12%

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

86  When consumers who did not shop cross-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  Netherlands,  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-border,  and  14%  said  they  had  too  little 
information  concerning  offers  from  foreign  sellers.    Other  reasons  were  mentioned  to  a 
lesser extent. (See figure 28 below).  

35

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure  28  –  Reasons  for  not  buying  products  from  an  online  seller  based  in  another 
country (three answers possible) 

Unit: Percentage of non-cross shoppers

There is enough choice in my conutry

It’s more difficult to solve any problems if something goes wrong

42%

35%

0%

5%

10% 15% 20% 25% 30% 35% 40% 45%

There are extra delivery/custom charges

There is a longer delivery time

There is no need to buy cross-border

26%

24%

22%

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

15%

14%

13%

12%

12%

11%

The products I want are of better quality in my country

5%

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

4%

4%

1%

1%

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 online shoppers (76%) do not in practice 
experience these problems while using e-commerce to purchase goods.  However, one in 
five  (24%)  online  shoppers  has  experienced  problems.  (See  figure  30  below).    An 
assessment  of  the  incidence  of  problems  when  purchasing  goods  online  (24%)  and 
problems  when  purchasing  goods  offline  (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". 

36

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure 29 – Problems encountered by online shoppers while buying online 

Unit: Percentage of online shoppers who encountered a problem

0%

5%

10%

15%

20%

25%

30%

Long delivery time

Damaged product delivered

Non-delivery

Product did not match description on website

28%

20%

17%

17%

Wrong product delivered

14%

Customer service was poor

10%

Delivery costs or final price was higher than displayed on website

7%

I could not return a product I didn't like and get reimbursed

The seller did not replace or repair a faulty product

4%

4%

The product sold was unsafe

1%

My personal data was misused

1%

My payment card details were stolen

1%

A foreign seller charged a higher price to me than to consumers in the
country of the seller

0%

Other problems

7%

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  cross-border.    A  breakdown  of  these  figures 
shows that cross-border shoppers do not seem to encounter more problems than domestic 
shoppers.    From  those  online  shoppers  that  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 problems with products bought online from 
domestic sellers were reported in Poland (26%), Italy (22%), the UK (21%) and Romania 
(18%).  Most problems with products bought online 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%),. 

37

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 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

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

Domestic Cross Border

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 final price was higher than displayed 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  get  reimbursed  (4%).    Other  problems  were: 
product did not match description on website (17%), unsafe products (1%), personal data 
was misused (1%) and payment card details were stolen (1%).   

90  A  recent  Eurobarometer  survey56  comparing  the  shopping  experience  of  domestic  and 
cross-border  distance  shoppers  confirmed  that  there  are  no  significant  differences  in 
encountered  problems.      Only  16%  of  shoppers  experienced  a  delay  with  a  product 
purchased  cross-border  in  the  EU  while  18%  of  shoppers  experienced  a  delay  with  a 
product purchased domestically.  5% of shoppers had a problem with goods not delivered 
after  purchasing  cross-border  in  the  EU  while  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". 

38

 
 
 
 
 
 
 
 
 
 
                                                 
Figure  31  –  Delay  in  delivery  and  non-delivery  of  goods  or  services  purchased  by 
distance 

Unit: Online Shoppers

5

6

6

You purchased something and it
was not delivered at all

Delay in delivery of something 

19

16

18

0

2

4

6

8

10

12

14

16

18

20

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, delivery 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-border as they are domestically.  
However, the levels  of  confidence  of  those who actually  carried out online  cross-border 
transactions  are  twice  as  high.  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).  

39

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 32 – Level of confidence in cross-border purchases 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

all respondents

48

33

4

16

those who had made at least
one cross-border purchase via
the Internet

33

61

5

1

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, contrary to their fears, the evidence shows that the incidence 
of problems concerning payments and abuse of personal 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 and undermining the consumers' 
confidence in the Digital Single Market is the refusal of online businesses to deliver if the 
service  recipients  are  not  residing  in  the  same  Member  State.  The  Commission  has 
received a significant number of complaints which give evidence of refusals to supply or 
of  differences  in  treatment  in  the  online  world  that  are  based  on  the  residence  of  the 
service recipient. 

40

 
 
 
 
 
 
 
 
 
94  Article  20  (2)  of  the  Services  Directive57  obliges  Member  States  to  ensure  that  general 
conditions  of  access  to  a  service  which  are  made  available  to  the  public  at  large  by  a 
service  provider  do  not  contain  discriminatory  provisions  based  on  the  nationality  or  on 
the  place  of  residence  of  recipients.  This  does  not  exclude  that  service  providers  apply 
different  prices  and  other  conditions  of  access  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 orders of Member States, it is for the relevant 
national  authorities  to  ensure  the  enforcement  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 cross-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 continue to be the main source of consumer's 
cross-border  complaints  with  56%  of  all  complaints  addressed  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 complaints 2008-2009".  As far as the problems 
reported  are  concerned,  the  trends  observed  in  2008  and  2009  are  similar  to  previous 
years,  with  delivery  (non  delivery  of  goods,  partial  delivery  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  relatively  high  number  of  consumer  complaints  related  to  non 
display or incorrect display of prices or even hidden costs. Security of payments has 
gained  an  even  more  significant  importance  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.  

Directive 2006/123/EC of the European Parliament and of the Council of 12 December 2006 on 

57  
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 

41

 
 
 
 
 
 
 
 
 
                                                 
100In 2011, the ECC-Net carried out a mystery shopping exercise in order to check whether 
online retailers selling cross-border offer the right level of protection to consumers59.  The 
ECC-Net  mystery  shoppers  carried  out  actual  purchases  to  check  retailers'  compliance 
with EU legislation.  The mystery shopping exercise involved 305 cross-border purchases. 
During  the  design  phase  of  this  exercise,  the  mystery  shoppers  found  it  surprisingly 
difficult to find online retailers that were willing to sell cross-border despite the fact that 
the original list of retailers was compiled with this in mind.  From 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 legislation.  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 legislation in force in other EU countries, and 
72% of distance sellers did not even know the exact length of the "cooling-off" period for 
distance  sales  in  their  own  country60.  Almost  40%  of  exporting  retailers  or  retailers 
interested  in  starting  a  cross-border  activity  and  involved  in  e-commerce  transactions 
declared that the need to adapt and comply with different consumer protection rules in the 
foreign contract laws has an impact on their decision to sell cross-border in the EU61.  

102In  18%  of  purchases  carried  out  during  the  ECC  mystery  shopping  exercise,  traders  did 
not inform shoppers about their right of withdrawal, while in 63% of cases the websites 
did not provide information concerning the legal warranty and associated consumer rights.  
Mystery  shoppers  found  out  that  11%  of  websites  did  not  provide  the  opportunity  to 
review the details of the order 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 which 99% were in conformity 
with the order).  Almost 50% of all deliveries took place within 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  within  the  cooling-off  period,  compared  to 
90%  of  retailers  in  total.    48%  of  retailers  belonging  to  a  trustmark  reimbursed  the  full 
amount (including delivery costs) compared to 43% in total.  It is especially worrying that 
57% of online retailers did not reimburse delivery 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". 

42

 
 
 
 
 
 
 
                                                 
105The 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  infringing  laws.    The  Commission  will  use 
existing  networks,  such  as  the  Enterprise  Europe  Network,  to  step-up  efforts  to 
inform  online  retailers  about  their  obligations  when  selling  cross-border  but  also 
about  the  opportunities  offered  by  selling  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 European Consumer Centres, consumers may wish 
to seek legal advice or take the matter to court.  The market study63 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  measures  that  could  increase  confidence  in  e-
commerce from 0-10.  The results did not reveal big variation in consumers' preferences 
between measures.  The most popular are secure online payment systems, having the same 
set of online rights everywhere across the EU, online sellers ensuring that personal data is 
not stolen or misused, public authorities ensuring 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  would  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".  

43

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Figure  34  –  Would  you  be  willing  to  solve  a  dispute  with  an  online  seller  through  an 
online dispute resolution body (for example online mediator, arbitrator, ombudsman)? 
That  means  submitting  and  settling  the  dispute  online  (for  example  through  online 
forms, emails, online chat) 

Unit: Percentage of Individuals

32%

16%

52%

Yes

No

DK

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

109Since redress has been identified as a problem both in consumers' perceptions but also in 
actual  problems,  it  is  clear  that  more  efficient  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  challenges  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  speed  and  effectiveness.  In 
addition, resources available limited.  

44

 
 
 
 
 
 
 
 
 
 
 
 
 
 
111In this context, active cooperation between enforcement 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  the  Consumer  Protection  Cooperation  (CPC) 
Network65. The Network brings together the consumer enforcement authorities of all the 
Member  States  (as  well  as  from  Norway,  Iceland  and  Liechtenstein).  Authorities  work 
closely  together  to  stop  breaches  to  the  consumer  rules  in  certain  situations  where 
consumers and traders are established in different countries.  

112From its first year of activity, 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  legislation  and  take  appropriate  enforcement 
actions. The sweeps are carried out on an annual 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 for mobile phones, electronic 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 enforcers since it was 
judged that these cases concerned consumers' collective interests.  Improved co-operation 
between the ECC-Network and the CPC Network would improve the online environment 
for consumers.  The external evaluation of the ECC-Net recommended that cooperation 
between  the  ECC-Net  and  the  Consumer  Protection  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 continuing to grow as a sales 
channel.    More  and  more  consumers  are  choosing  to  use  the  Internet  to  carry  out  their 
background  research  before  making  a  purchase  either  online  or  offline.    In  addition, 
increasing  numbers  of  consumers  are  making  actual  purchases  online.    Businesses  are 
showing  a  similar  behaviour  by  embracing  e-commerce  and  the  opportunities  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 consumer welfare for all consumers.  The report has 
shown  that  there  are  considerable  gains  for  consumers  from  e-commerce  such  as  lower 
prices,  a  wider  choice  of  goods  and  services  and  convenience.    Consumers  are  already 
enjoying some of the benefits offered by e-commerce.  Yet, the European online market is 
by  no  means  complete.    There  is  a  considerable  way  to  go  in  order  to  reach  the  true 
potential lying in e-commerce as a sales channel.  An achievement of this potential would 
considerably increase the benefits to consumers 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-commerce 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 for the enforcement of consumer protection laws.  

45

 
 
 
 
 
 
                                                 
consumer  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-commerce  despite  the  potential  benefits.    The 
reasons  behind  this  lack  of  confidence  are  generally  the  same  for  offline  shoppers  and 
shoppers  who  buy  online  only  occasionally.    These  can  be  traced  to  concerns  about 
getting  redress  in  case  something  goes  wrong,  problems  with  delivery,  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-commerce 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 mechanisms and raise the confidence of consumers 
on their online rights are needed.  The Commission has adopted two legislative proposals 
to  improve  out-of-court  dispute  resolution  for  all  consumer  disputes,  including  those 
related  to  cross-border  online  transactions:  a  proposal  for  a  Directive  on  Alternative 
Dispute  Resolution  for  consumer  disputes66  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 dispute 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  national  courts.  The  Common  European  Sales  Law 
will also address the problem of consumer uncertainty 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 advance of a transaction through a standardised 
information notice. 

118A recent workshop held during the Digital Agenda 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 accreditation scheme to enhance trust and online cross 
border  transactions.  Trust  marks  can  effectively  be  combined  with,  and  leverage  upon, 
other 
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. 

tools  such  online  alternative  dispute  resolution  schemes  and 

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 

46

 
 
 
 
 
 
 
                                                 
119The  biggest  problems  holding  back  the  development  of  e-commerce  seem  to  be  on  the 
supply  side.    Despite  the  fact  that  increasing  numbers  of  businesses  are  embracing  the 
opportunities offered by e-commerce most still sell only offline.  From those that do sell 
online, the majority sell only domestically rather than cross-border.  Regulatory barriers to 
cross-border  e-commerce  that  have  been  already  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  legislation  on  electronic  waste  disposal  etc.  
Many traders do not sell cross-border due to the complexity and lack of harmonisation of 
the  EU  legal  environment  governing  cross-border  e-commerce  transactions.    The 
Commission  has  addressed  some  these  issues  through  legislative  proposals  such  as  the 
Directive  on  Consumer  Rights69  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 currently 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 Commission 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  intermediaries  becomes  more  widespread  it  is 
necessary that they provide information in a clear, transparent and accurate manner.  Also, 
consumers  would  benefit  if  such  intermediaries  provided  information  on  goods  and 
services from everywhere in the EU and covered aspects beyond price and pure, technical 
product  characteristics.    This  could  open  up  the  Single  Market  for  goods  and  services 
resulting  in  lower  prices  and  wider  choice.    The  existing  fragmentation  of  price  and 
product  comparison  intermediaries  is  serving  to  entrench  Single  Market  obstacles  in  the 
mind of EU consumers. 

121To address these issues, Commission services will work closely 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 legislation, and b) encourage them to include cross-border offers on 
price and quality in a way that unlocks 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 Market.  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 the Enterprise Europe Network72 and the ECC Network. 

123Consumers'  confidence  in  e-commerce  can  also  be  improved  through  the  improved 
enforcement  of  the  rules  governing  e-commerce.    The  Commission  will  encourage  the 

http://www.europarl.europa.eu/en/pressroom/content/20110622BKG22276/html/Consumer-rights-what-the-

69 
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  European  Parliament  and  of  the  Council  on  waste  electrical  and  electronic 
equipment (WEEE) (Recast) {SEC (2008) 2933} {SEC (2008) 2934}/ COM/2008/0810 final 
72 http://www.enterprise-europe-network.ec.europa.eu/index_en.htm 

47

 
 
 
 
 
 
                                                 
European 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  laws  and  reporting  non-compliant  traders  to 
enforcement  authorities.        Furthermore,  the  Commission  will  also  facilitate  further  the 
dialogue between the European Consumer Centres Network and the network of consumer 
enforcement  authorities  (CPC-network)  in  order  to  improve  the  enforcement  of  EU 
legislation governing business-to-consumer online transactions. 

124Other complementary actions foreseen in the Digital 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 effects for consumers and the European economy 
as a whole. 

48

 
 
 
ANNEX 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 
Belgium 
Bulgaria 
Cyprus 
Czech Rep 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 

2% 
5% 
0% 
5% 
3% 
2% 
4% 
1% 
31% 
3% 
10% 
1% 
4% 
2% 
4% 
4% 
1% 
3% 
2% 
1% 
7% 
5% 
16% 
2% 
3% 

2% 

3% 
1% 
0% 
1% 
1% 
2% 
15% 
4% 
2% 
1% 
2% 
4% 
1% 
1% 
19% 
1% 
15% 
2% 
1% 
1% 
0% 
1% 
5% 
2% 

0% 
1% 

0% 
0% 
0% 
0% 
1% 
1% 
1% 
1% 
0% 
1% 
1% 
0% 
1% 
0% 
0% 
1% 
1% 
0% 
4% 
0% 
0% 
1% 
0% 

1% 
1% 
1% 
0% 

0% 
1% 
1% 
1% 
3% 
1% 
3% 
1% 
1% 
0% 
1% 
0% 
0% 
1% 
4% 
1% 
0% 
59% 
1% 
1% 
2% 

0% 
0% 
0% 

0% 
0% 
1% 
0% 
1% 
1% 
4% 
0% 
0% 
1% 
0% 
0% 
0% 
0% 
1% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

0% 
0% 
1% 
0% 
1% 
2% 
11% 

1% 
1% 
1% 
1% 
0% 
2% 
3% 
1% 
0% 
0% 
0% 
0% 
0% 
2% 
0% 
0% 
2% 
3% 

5% 
42% 
15% 
8% 
9% 
5% 
5% 
5% 

9% 
10% 
3% 
9% 
26% 
4% 
5% 
43% 
2% 
11% 
8% 
16% 
9% 
7% 
4% 
27% 
9% 

90% 
26% 
19% 
10% 
24% 
32% 
27% 
38% 
41% 

27% 
26% 
15% 
36% 
23% 
17% 
78% 
7% 
43% 
33% 
18% 
22% 
15% 
45% 
22% 
32% 

0% 
0% 
2% 
15% 
1% 
0% 
1% 
0% 
1% 
1% 

0% 
1% 
3% 
0% 
2% 
0% 
0% 
1% 
2% 
1% 
2% 
0% 
0% 
1% 
1% 

1% 
0% 
0% 
0% 
2% 
0% 
1% 
1% 
0% 
1% 
1% 

0% 
1% 
0% 
0% 
0% 
0% 
1% 
0% 
0% 
8% 
4% 
0% 
1% 
1% 

0% 
0% 
1% 
0% 
0% 
0% 
5% 
1% 
0% 
0% 
0% 
0% 
0% 
1% 

3% 
0% 
0% 
0% 
0% 
1% 
0% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 
1% 
0% 
0% 
3% 
0% 
0% 
1% 
0% 
0% 
1% 
1% 
5% 

0% 
0% 
1% 
1% 
0% 
0% 
0% 
0% 
0% 
0% 

0% 
0% 
1% 
0% 
1% 

4% 
5% 
2% 
4% 
0% 
0% 
1% 
2% 
1% 
0% 
1% 
0% 
2% 
1% 
1% 
0% 
0% 
0% 
2% 
15% 

0% 
0% 
0% 
0% 
0% 
0% 

7% 
0% 
1% 
0% 
0% 
1% 
1% 
5% 
3% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

49

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
UK 

Total 

2% 

8% 

3% 

5% 

1% 

1% 

2% 

2% 

2% 

1% 

2% 

2% 

1% 

1% 

1% 

1% 

17% 

14% 

21% 

27% 

1% 

2% 

1% 

1% 

1% 

1% 

1% 

1% 

country 

Luxembourg   

Ireland    

Italy       Malta      Netherlands    Poland     Portugal    Romania    Slovakia    Slovenia    Spain      Sweden   

Austria 
Belgium 
Bulgaria 
Cyprus 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
United Kingdom 

Total 

2% 
2% 
1% 
0% 
0% 
0% 
1% 
0% 
5% 
7% 
1% 
1% 
0% 
2% 
0% 
0% 

0% 
1% 
1% 
2% 
0% 
1% 
1% 
2% 
0% 
2% 

3% 

1% 
0% 
1% 
1% 
1% 
2% 
1% 
2% 
2% 
1% 
2% 
2% 

3% 
3% 
4% 
2% 
1% 
2% 
3% 
4% 
1% 
1% 
1% 
5% 
1% 
9% 

3% 

4% 
3% 
6% 
5% 
1% 
2% 
2% 
3% 
3% 
5% 
9% 
1% 
3% 

3% 
1% 
5% 
9% 
3% 
1% 
4% 
13% 
1% 
5% 
8% 
3% 
6% 

4% 

0% 
0% 
1% 
0% 
0% 
0% 
0% 
0% 
1% 
0% 
0% 
0% 
1% 
1% 
0% 
1% 
0% 

1% 
0% 
0% 
0% 
0% 
0% 
1% 
0% 
2% 

1% 

4% 
38% 
2% 
2% 
2% 
8% 
3% 
7% 
3% 
11% 
2% 
1% 
4% 
4% 
1% 
1% 
5% 
1% 

3% 
3% 
2% 
1% 
3% 
2% 
3% 
6% 

6% 

2% 
0% 
1% 
0% 
18% 
1% 
3% 
1% 
1% 
3% 
0% 
1% 
4% 
2% 
4% 
8% 
0% 
0% 
2% 

0% 
2% 
4% 
2% 
0% 
2% 
3% 

2% 

0% 
0% 
1% 
0% 
0% 
1% 
1% 
0% 
2% 
0% 
1% 
0% 
1% 
1% 
0% 
1% 
1% 
0% 
1% 
0% 

2% 
0% 
0% 
5% 
1% 
1% 

1% 

0% 
0% 
1% 
0% 
0% 
0% 
0% 
1% 
0% 
1% 
0% 
1% 
1% 
1% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 
0% 
0% 

1% 

0% 
0% 
0% 
0% 
19% 
0% 
0% 
0% 
1% 
1% 
0% 
16% 
1% 
1% 
0% 
0% 
0% 
0% 
0% 
2% 
0% 
0% 

1% 
0% 
0% 
1% 

1% 

0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
1% 
0% 
1% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 
0% 

0% 
0% 
0% 

0% 

1% 
2% 
1% 
1% 
1% 
2% 
1% 
2% 
5% 
4% 
3% 
2% 
4% 
7% 
1% 
2% 
2% 
0% 
4% 
3% 
21% 
5% 
0% 
1% 

3% 
8% 

5% 

1% 
1% 
1% 
1% 
0% 
22% 
6% 
22% 
1% 
2% 
1% 
1% 
2% 
2% 
5% 
1% 
1% 
0% 
1% 
1% 
1% 
0% 
0% 
1% 
1% 

2% 

2% 

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

United 
Kingdom 

13% 
20% 
41% 
74% 
17% 
48% 
35% 
40% 
29% 
20% 
49% 
27% 
74% 
29% 
33% 
39% 
19% 
93% 
21% 
23% 
41% 
19% 
15% 
34% 
28% 
34% 

24% 

50

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
s
e
i
r
o
s
s
e
c
c
a

d
n
a
s
l
o
o
t

r
e
w
o
P

d
r
a
d
n
a
t
S

t
n
a
t
s
n
I

e
e
f
f
o
C

d
r
a
d
n
a
t
S

a
l
u
m
r
o
F

k

l
i

M

Figure 12: Subcategory overview - average price difference online vs. offline (in %), including delivery costs 

Country 

Austria 

Belgium 

Czech Republic 

Denmark 

France 

Germany 

Greece 

Hungary 

Italy 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Spain 

Sweden 

United Kingdom 

Average 

e
l
i

b
o
M

s
e
n
o
h
P

-8.6 

0.7 

-3.8 

-8.1 

-1.1 

-9.0 

-4.8 

s
p
o
t
p
a
L

-3.7 

-3.1 

-1.4 

-3.5 

-2.8 

-6.5 

0.0 

-19.3 

-24.4 

-5.8 

-5.6 

-1.3 

-2.4 

-4.4 

3.7 

0.6 

-11.8 

-6.2 

-5.1 

-5.6 

-1.0 

-2.8 

1.6 

-1.3 

-3.0 

2.6 

-0.3 

3.6 

-3.0 

s
a
r
e
m
a
C

l
a
t
i
g
i
D

3.5 

2.6 

-2.6 

4.5 

-7.6 

-1.9 

5.7 

1.4 

4.6 

2.6 

-6.3 

9.1 

7.1 

10.5 

-12.5 

-0.3 

2.0 

1.3 

n
o
i
t
a
g
i
v
a
N

r
a
C
-
n
I

-13.5 

-5.2 

s
V
T
D
C
L

-9.6 

-8.9 

-13.4 

-12.0 

3.5 

-12.1 

-6.5 

-3.0 

-12.0 

-4.4 

-7.4 

-0.9 

-1.0 

-3.5 

-20.0 

-1.5 

-9.5 

-1.6 

-6.6 

-3.2 

-6.5 

-4.3 

-10.5 

-8.4 

0.2 

-3.3 

-11.8 

1.0 

1.3 

-6.2 

-7.4 

-7.3 

8.6 

-5.2 

e
l
b
a
t
r
o
P

s
r
e
y
a
l
P

3
P
M

s
e
c
n
a
r
g
a
r
F

i

m
u
m
e
r
P

s
'

n
e
m
o
W

e
r
a
w
d
r
a
H

s
e
m
a
G

o
e
d
V

i

3.4 

1.7 

3.4 

4.1 

1.3 

10.8 

-2.0 

-9.1 

5.2 

-1.5 

-2.3 

8.7 

9.6 

2.8 

6.3 

6.9 

0.2 

2.9 

1.2 

-9.3 

-47.6 

-12.6 

5.7 

-5.1 

-0.4 

-5.2 

-6.3 

-1.6 

-8.7 

-3.3 

-1.5 

4.0 

-52.1 

-17.7 

-7.6 

-8.6 

-43 

6.0 

-26.5 

-29.2 

1.4 

-38.1 

-0.4 

-15.7 

-6.9 

-4.5 

-7.9 

0.3 

-1.5 

1.9 

-1.0 

-6.7 

-3.2 

-4.1 

a
n
o
i
t
i
d
a
r
T

s
y
o
t

l

16.8 

8.5 

-5.0 

30.7 

21.9 

14.9 

10.6 

51.1 

40.5 

5.0 

-7.6 

25.1 

20.4 

21.2 

28.7 

1.1 

-6.4 

16.3 

r
a
e
w
r
e
t
u
o

s
'
n
e
M

2.5 

7.8 

-7.3 

-6.7 

-2.0 

-1.9 

-9.6 

0.0 

-11.3 

-1.0 

-7.4 

5.6 

24.1 

0.9 

1.8 

-1.2 

-8.4 

-0.8 

s
'

n
e
m
o
W

r
a
e
w
r
e
t
u
o

8.7 

5.3 

-18.3 

-23.2 

8.5 

15.2 

3.9 

0.0 

-9.6 

16.3 

-10.1 

-11.3 

-4.2 

4.1 

2.2 

7.7 

-1.4 

-0.4 

r
a
e
w
t
o
o
F

1.1 

- 

-19.0 

-16.5 

-5.2 

-8.5 

-25.5 

-1.3 

-0.5 

-4.5 

-8.8 

-6.7 

-3.5 

-1.2 

3.7 

-11.0 

-13.1 

-10.3 

-9.1 

22.4 

16.0 

-1.5 

-0.2 

-6.9 

2.5 

-4.8 

11.7 

0.0 

-0.2 

12.5 

-16.7 

-6.0 

-4.6 

0.2 

8.8 

-1.9 

189.8 

46.9 

106.9 

160.3 

243.4 

116.2 

105.2 

177.7 

118.2 

97.7 

99.5 

111.4 

135.8 

107.2 

199.3 

168.7 

155.2 

137.6 

62.8 

40.8 

17.3 

80.0 

32.7 

67.9 

21.7 

61.0 

45.8 

58.0 

43.9 

58.8 

70.1 

63.3 

50.0 

475.3 

41.3 

75.9 

Notes: Based on a total number of 4559 observations. Data collected in December 2010. Negative values mean that online price is lower than offline price of the product (shaded). Positive values 
mean that the online price is higher than the offline price  

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

51

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 13: Overview – average choice difference online vs. offline (in %) 

Country 

Austria 

Belgium 

Czech Republic 

Denmark 

France 

Germany 

Greece 

Hungary 

Italy 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Spain 

Sweden 

United Kingdom 

Average 

e
l
i

b
o
M

s
e
n
o
h
P

2317 

102 

130 

-16 

209 

43 

71 

345 

289 

323 

142 

2 

204 

-41 

41 

63 

144 

257 

s
p
o
t
p
a
L

122 

208 

-2 

25 

26 

197 

70 

-7 

39 

546 

94 

-7 

35 

103 

75 

-8 

254 

104 

s
a
r
e
m
a
C

l
a
t
i
g
i
D

33 

338 

257 

6 

61 

8 

-7 

102 

114 

782 

97 

474 

523 

13 

114 

15 

39 

174 

n
o
i
t
a
g
i
v
a
N

r
a
C
-
n
I

3 

163 

15 

-3 

235 

199 

22 

62 

83 

490 

56 

392 

203 

31 

9 

2 

95 

121 

s
r
e
y
a
l
P
3
P
M

e
l
b
a
t
r
o
P

-10 

36 

120 

-42 

70 

87 

22 

2775 

125 

671 

-13 

-4 

263 

-33 

20 

9 

45 

244 

s
e
c
n
a
r
g
a
r
F

i

m
u
m
e
r
P

s
'

n
e
m
o
W

107 

191 

48 

-18 

346 

63 

-50 

120 

-6 

113 

47 

103 

-9 

-56 

-48 

64 

27 

61 

s
e
m
a
G
o
e
d
V

i

e
r
a
w
d
r
a
H

-25 

246 

200 

0 

0 

0 

0 

0 

-62 

456 

12 

-54 

-13 

99 

-9 

0 

56 

53 

s
V
T
D
C
L

25 

184 

-22 

-8 

163 

388 

-27 

8 

22 

67 

43 

101 

129 

-19 

20 

15 

141 

72 

l
a
n
o
i
t
i
d
a
r
T

s
y
o
t

-39 

431 

24 

17 

1202 

250 

-26 

85 

-12 

465 

95 

-47 

11 

3 

-14 

37 

108 

152 

r
a
e
w
r
e
t
u
o

s
'
n
e
M

73 

10 

-37 

-53 

138 

-8 

-78 

50 

220 

394 

126 

304 

68 

212 

-4 

-34 

35 

83 

s
'

n
e
m
o
W

r
a
e
w
r
e
t
u
o

71 

67 

9 

-50 

340 

89 

1 

0 

r
a
e
w
t
o
o
F

19 

0 

78 

-57 

1412 

187 

-31 

42 

-23 

1657 

45 

98 

84 

-25 

37 

25 

-21 

69 

48 

121 

165 

55 

-2 

9 

-31 

147 

36 

224 

s
l
o
o
t

r
e
w
o
P

s
e
i
r
o
s
s
e
c
c
a

d
n
a

d
r
a
d
n
a
t
S

t
n
a
t
s
n
I

e
e
f
f
o
C

d
r
a
d
n
a
t
S

a
l
u
m
r
o
F

k

l
i

M

11 

153 

-8 

2 

117 

99 

-5 

54 

18 

163 

32 

165 

53 

299 

-14 

-8 

68 

71 

-29 

85 

-14 

-32 

33 

404 

-42 

25 

0 

55 

17 

64 

4 

-47 

-14 

-3 

419 

54 

233 

298 

38 

-83 

50 

50 

30 

4 

27 

218 

-11 

15 

-28 

534 

-11 

-20 

123 

86 

Notes: Based on a total number of 4559 observations. Data collected in December 2010. Positive values mean that online choice is bigger than offline choice of the product (shaded). Negative 
values mean that online choice is smaller than offline choice of the product  
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce

52

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

Having the same consumer rights wherever I shop online across 
the EU 

6.57 

7.00 

Online sellers ensuring that my personal data is not stolen or 
misused 

6.54 

7.00 

Public authorities across the EU ensure that fraudulent online 
sellers are closed down 

6.52 

7.00 

Accurate contact information is available on seller websites 

6.49 

7.00 

Public authorities across the EU co-operate to ensure that all 
products sold online are safe 

6.24 

7.00 

Hotlines of online sellers are available for sales and after-sales 
service without additional charges 

6.14 

6.00 

Websites have online trust marks 

6.05 

6.00 

Independent and accurate price comparison websites 

5.99 

6.00 

Online sellers agree to resolve any individual dispute with me 
through an online dispute resolution body 

5.92 

6.00 

Online sellers adhere to industry codes of good conduct 

5.83 

6.00 

Public bodies providing information, advice and support about 
my consumer rights online 

5.82 

6.00 

Independent advice websites providing guidance on best 
products 

5.71 

6.00 

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

10 

10 

10 

10 

7 

8 

7 

8 

7 

5 

5 

5 

5 

53

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 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 price 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 uneven.  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  point  of  call  in  the  shopping  trip  of  many 
consumers, irrespective of whether consumers 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, consumers should be able to trust them and 
benefit  from  their  use.    The  consumer  survey  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  all  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%),  Estonia  (41%)  and  Malta 
(14%).          

73 Consumer Market Study on the functioning of e-commerce. Civic Consulting (2011). 

54

 
 
 
 
 
 
 
 
 
                                                 
Figure 1: Proportion of respondents who use a price comparison website 

Table 1: Proportion of respondents who use a price comparison website

Czech Republic
Poland
Italy
Slovakia
Greece
Sweden
Germany
Denmark
Finland
France
United Kingdom
EU
Austria
Latvia
Poertugal
Spain
Romania
Slovenia
Bulgaria
Netherlands
Hungary
Luxembourg
Belgium
Ireland
Lithuania
Cyprus
Estonia
Malta

92

91
91

90

87

86

85

83

82

81
81
81

80

79

76

75

74
74
74

73

68

63

58

57

51

14

42

41

0

10

20

30

40

50

60

70

80

90

100

Note: Based on all respondents (N=29010) 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

Price comparison websites - Local 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 concentrated 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 (83%) include offers only from one country.  
Only 17% of price comparison websites offer the possibility of viewing offers from other 
countries than the one which the website is located.  In the cases where this is possible, 
these websites offer the possibility 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 are a number of businesses which 
operate country specific price comparison websites 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  comparison  websites  are  primarily  in  local 
languages and do not offer cross-border offers. 

55

 
 
 
 
 
 
 
 
 
 
 
 
Price 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  bought  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  appliances,  electronics,  sports  and  outdoor  equipment  as 
well  as  CDs  and  DVDs.    A  socio-demographic  breakdown  of  responses  shows  that 
consumers with more years of education are more likely to use price comparison websites. 

Price comparison websites – Reasons influencing use 

11  The majority of consumers (56%) use price comparison 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 find 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 comparison 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 contacted 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  comparison  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 particular electronic commerce, in the Internal Market (Directive on electronic 
commerce) 

56

 
 
 
 
 
   
 
 
 
 
 
                                                 
14  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 provide consumers with product 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  comparison  websites  very  often.    Only  20%  of 
price  comparison  websites  provided  information  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 
information  about  product 

information,  with  72%  of 

them  providing 

product 
characteristics. 

Financing 

20  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 do not indicate 
clearly if the retailers appearing on the specific price comparison website pay to have their 
products listed. 

Coverage 

21  The coverage of specific price comparison websites is often not clear. Just 16% provide 
clear  information  explaining  why  some  retailers  are  listed  whereas  others  not.    18% 
provide  this  information  but  not  very  clearly,  while  66%  do  not  provide  any  such 
information at all. 

Default ranking75  

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 takes place, despite the information offered by 
the websites.    

Price 

75 Ranking used by Price Comparison Website when the user has not selected any settings 

57

 
 
 
 
 
 
 
 
 
 
 
                                                 
23  The  mystery  shopping  exercise  results  show  that  price  comparison  websites  as  a  whole 
have significant deficiencies on the provision of relevant information 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  information  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  websites  provided  clear  information  about  their 
policies concerning fraudulent or rogue traders.  12% provide unclear 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 including delivery costs was possible only in 
14% of cases. 

28  In nearly three out of four trials (72%) using the lowest price view, the cheapest offer is 
within the first five products.  However, in 15% of such trials, the 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 price 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 during 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) 
Listed among the first five offers 
(Rank 1-5) 

Listed among the first ten offers 
(Rank 1-10) 

47% 

72% 

81% 

38% 

66% 

76% 

Not listed on first page 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

15% 

17% 

58

 
 
 
 
 
 
 
 
 
 
31  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  cheapest  offer  anywhere  on  the  first  page  of 
listings. 

Price comparison websites – Consumer experience 

32  From the consumers that use price comparison websites, one in two (50%) find them the 
quickest  way  to  compare  prices  and  one  in  three  (32%)  say  they  are  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  specific  products.    18%  find  price  comparison 
websites useful to find customer comments, 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 that different price comparison websites show 
different prices, and 14% use at least two or three price comparison websites as each site 
presents different offers.   

35  19% of consumers who buy goods online do not use price comparison websites.  The most 
important reasons for not using price comparison website do not reflect specific concerns 
with the services offered by the price comparison 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 price comparison websites checked, did not have a "rank by the 
lowest price" function 

59

 
 
 
 
 
 
 
 
 
                                                 
across 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 products they are searching for, 4% find such 
websites  to  be  very  complicated,  4%  find  no  variation  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 comparison websites did not feel misled (70%), yet 
an important section thinks they were misled 12% while 18% report that 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 three (32%) said that the 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) 

60

 
 
 
 
 
 
 
Source: 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 comparison 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 price 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%

Somew hat agree, 48%

Strongly agree, 13%

Somew hat disagree , 24%

Sample: N=227 
Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

39  There  are  various  features  on  a  price  comparison  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 information about the website's business model to how 
results are ranked. 

40  Mystery  shoppers  found  that  91  price  comparison  websites  (out  of  233  tested)  were  not 
useful in providing information about their business model.  This is very important since if 
this  information  is  not  provided  the  consumer  cannot  know  how  products  are  ranked, 
whether retailers' are paying to have their products listed, or what the market coverage is. 

61

 
 
 
 
 
 
 
 
 
 
 
41  One aspect that mystery shoppers did not find useful was information about the products.  
86  websites  were  found  to  be  not  useful  in  providing  product  information.    This  ranged 
from  confusing  product  specifications,  whether  products  were  sold  stand-alone  or  they 
included  accessories,  if  essential  components  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  information  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.  However, 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  available  at  all,  in 
others mystery shoppers had to use various search terms in order to identify them, some 
generated large numbers of totally unrelated products, while others did not generate easily 
the cheapest correct offer.  The price function 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  being  able  to  rank  products  according  to  price, 
addition of sponsored links on top, incorrect offers, 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  trials  checking  whether  the  information 
provided  on  price  comparison  websites,  concerning  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 comparison website and then clicked through to the 
retailer's  website  and  carried  out  a  consistency  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 comparison 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  website  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 

62

 
 
 
 
 
 
 
 
                                                 
other  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 comparison websites display information about the time it takes for 
goods to be delivered.  This happens 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  does  not  match  that  indicated  by  the  price 
comparison website.  

48  Most price comparison websites (62%) do not provide information on the availability of 
specific  products.    In  the  case  of  the  ones  that  do,  this  is  usually  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 retailer on product availability is different. 

49  The  situation  concerning  information  on  product  specification  is  much  better  as  this  is 
indicated in nearly three out of four (74%) times. When such information is indicated on a 
price comparison website, this matched by retailers 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 available 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

s
l
a
i
r
t

f
o
r
e
b
m
u
N

160

140

120

100

80

60

40

20

0

81

76

64

36

31

28

17

6

5

Price on
retailer higher
than on PCW

Delivery costs
higher than on
PCW

Price on
retailer lower
than on PCW

Product is not
available

Delivery not
avavilable to
my country

Delivery costs
lower than on
PCW

Delivery time
longer than on
PCW

Product
specifications
less attractive

Product is not
new 

Retailer does
not have trust
mark
indicated on
PCW

Source: Civic Consulting (2011). "Consumer market study on the functioning of e-commerce". 

63

 
 
 
 
 
 
 
 
 
 
 
 
51  As the table reveals78, most of the discrepancies are related 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.  However, in 230 cases one aspect 
of  the  price  was  more  expensive  on  retailers'  websites.    The  underlying  reason  for  such 
differences  is  not  necessarily  price  manipulation.    These  discrepancies  can  be  partly 
attributed  to  technical  reasons  such  as  ineffective  or  delayed  up-dating  of  price  data.  
Despite  the  underlying  motive  for  the  resulting  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 purchasing 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  initial  price  of  the  chosen  offer  (e.g.  what  appears  as  the 
cheapest good) and commit to buy from that business even if the price 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, businesses have 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  between  different 
products  or  businesses  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  the  latest  research  has  shown  that  this  causes  considerable  consumer 
detriment79.  The provision of prices and other key 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  comparison  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  directive80,  online  retailers  should  have  on  their  websites 
details  that  allow  them  to  be  contacted  rapidly  and  communicated  with  in  a  direct  and 
effective manner.  This includes geographic address and electronic mail address.  In 67% 
of cases, retailers provided their 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 particular electronic commerce, in the Internal Market (Directive on electronic 
commerce) 

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(23%) did not provide this, as they are obliged. The absence of geographic and electronic 
mail address appears to be exacerbated in the case where retailers appear on the websites 
of online market places. 

Cooling-off period 

56  In four out of five cases (83%) mystery shoppers 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 information on this and 
in 3% the information provided was unclear. 

Legal warrantee 

57  The situation concerning provision of information about consumers' right to have a faulty 
good  repaired  or  replaced  or  even  get  a  refund,  within  two  years  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, retailers were registered in the same country as the one at 
which the price comparison websites were targeted.  Yet, up to 27% of retailers provided a 
business  address  outside  the  targeted  country  while  in  6%  of  cases  the  provided 
information  was  unclear.    In  the  cases  where  cross-border  targeting  is  observed,  this 
usually  involves  business  from  countries  with  bigger  economies  offering  their  goods  on 
price  comparison  websites  targeted  at  consumers  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  price  comparison  websites  targeting  Austrian 
consumers are German listed businesses. 

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