GREEN PAPER Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values
Date: 2013-04-24
Institutions: European Commission
Subjects: European audiovisual area, Internet, audiovisual production, economic growth, facilities for people with disabilities, family protection, freedom of expression, innovation, mobile phone, television

EUROPEAN 
COMMISSION 

Brussels, 24.4.2013  
COM(2013) 231 final 

GREEN PAPER 

Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values 

EN 

   EN 

 
 
 
 
  
 
TABLE OF CONTENTS 

1. 

2. 

2.1. 

2.2. 

2.3. 

2.4. 

3. 

3.1. 

3.2. 

3.3. 

3.4. 

3.5. 

4. 

Introduction .................................................................................................................. 3 

Growth and Innovation ................................................................................................ 4 

Market considerations .................................................................................................. 5 

Financing models ......................................................................................................... 8 

Interoperability of connected TV ................................................................................. 9 

Infrastructure and spectrum........................................................................................ 10 

Values......................................................................................................................... 11 

Regulatory framework ............................................................................................... 11 

Media freedom and pluralism .................................................................................... 13 

Commercial communications .................................................................................... 15 

Protection of minors................................................................................................... 16 

Accessibility for persons with disabilities.................................................................. 17 

Next steps ................................................................................................................... 18 

EN 

2 

   EN 

 
GREEN PAPER 

Preparing for a Fully Converged Audiovisual World: Growth, Creation and Values 

1. 

INTRODUCTION

1 

The objective of this Green Paper is to open a broad, public discussion on the implications of 
the  on-going  transformation  of  the  audiovisual  media  landscape,  characterised  by  a  steady 
increase  in  the  convergence  of  media  services  and  the  way  in  which  these  services  are 
consumed and delivered. 

Convergence  can  be  understood  as  the  progressive  merger  of  traditional  broadcast  services 
and  the  internet.  This  results  in  viewing  possibilities  extending  from  TV  sets  with  added 
internet connectivity, through set-top boxes delivering video content ‘over-the-top’ (OTT)2 to 
audiovisual  media  services  provided  via  PCs,  laptops  or  tablets  and  other  mobile  devices. 
Consumers use tablets or smartphones while simultaneously watching TV, for instance to find 
out more about what they are watching or to interact with friends or with the TV programme 
itself. 

Lines  are  blurring  quickly  between  the  familiar  twentieth-century  consumption  patterns  of 
linear  broadcasting  received  by  TV  sets  versus  on-demand  services  delivered  to  computers. 
Moreover,  with  every  smartphone  enabling  converged  production  as  well  as  consumption, 
there might be a future shift from ‘lean-back’ consumption to active participation. 
It  is  expected  that  connectable  TVs  will  move  from  40.4  million  devices  end  of  20123  to  a 
presence in a majority of EU TV households by 20164. 

As  regards  usage  of  the  functions  enabled  through  added  connectivity  to  the  internet,  the 
reported  rate  in  the  UK  in  2012  –  which  is  the  highest  in  the  EU  -  as  11 %  of  the  installed 
base,  in  comparison  with  44 %  in  China,  18 %  in  Korea  and  17 %  in  India5.  In  the  US,  an 
increase  from  currently  22.5 %  of  US  households  using  connected  TVs  including  OTT 
connections and game consoles to up to 43.1 % is foreseen by 20166. 
While  linear  general  viewing  times  are  still  around  4  hours  a  day  across  the  EU7,  the 
converged experience progressively becomes a reality and market players develop and adapt 
business models. Technology already allows the user to create, distribute and access all types 
of  content  irrespective  of  time,  place  or  device.  The  Commission’s  vision  is  to  seize  the 
opportunity of this changing technological environment to ensure the widest possible access 
to  European  diversified  content  for  all  Europeans  and,  the  widest  choice  of  high  quality 
offers.  The  technological  ability  to  deliver  content  to  be  legally  accessible  to  viewers 
throughout the EU could also incentivise market players to create new types of content. 

1 
2 

3 
4 
5 

6 
7 

For a glossary of relevant terms see http://ec.europa.eu/digital-agenda/en/connectedTV. 
Over-the-top  players  provide  audiovisual  content  online  without  themselves  being  electronic 
communications services and network providers. 
IHS Screen Digest. 
IHS Screen Digest. 
http://www.prnewswire.com/news-releases/western-viewers-fall-behind-in-the-web-connected-tv-
revolution-168126616.html. 
Source: e-marketer. 
Yearbook of the European Audiovisual Observatory, Volume II, page 171. 

EN 

3 

   EN 

 
                                                 
The need for private economic actors to further innovate and for policy makers to ensure the 
right framework conditions, and to reflect on possible public policy responses, results in the 
following questions: 

-  How  to  transform  the  process  of  convergence  in  a  larger  European  market  into  economic 
growth and business innovation in Europe (chapter 2)? 

-  What  are  the  implications  of  convergence  for  values  such  as  media  pluralism,  cultural 
diversity,  and  the  protection  of  consumers,  including  specific  groups  such  as  minors 
(chapter 3)? 

As convergence will become gradually more tangible over the next decade, it might have an 
impact in future on a number of legal instruments including the Audiovisual Media Services 
Directive (AVMSD)8 – focus of this paper -, the E-Commerce Directive9 and the electronic 
communications  framework10.  The  consultation  does  not  presuppose  any  specific  outcome. 
Nonetheless, it may pave the way towards possible regulatory and other policy responses in 
the longer term, in particular linking up Commission initiatives such as the Better Internet for 
Kids Coalition11, possible activities to follow up the report of the High Level Group on Media 
Freedom and Pluralism12, as well as work on self-regulatory initiatives. 

GROWTH AND INNOVATION 

2. 
In  2012,  22 %  of  EU  citizens  used  a  mobile  device  to  access  the  internet13.  By  2016,  the 
majority of consumer internet traffic in volume is expected to be video and the majority of IP 
traffic to be channelled mainly through WI-FI and mobile devices14.  

Key figures — audiovisual content consumption moving online 

Consumer  spending  on  digital  video  (movies  and  TV  series  delivered  over  the  Internet) 
reached €
 364.4 million in 2011 (+41,8% vs. 2010) in Europe within a market of physical and 
digital videos amounting €

 9493.8 million (-4.6% vs. 2010)15. 

The  unmet  demand  for  VoD  services  from  pay-TV  operators  from  other  Member  States  is 
estimated to be in the range of €

 1,610 million annually16. 

 760 million to €

Internet  video  users  are  expected  to  increase  globally  to  1.5  billion  by  2016,  up  from 
792 million in 201117. 
306 video-on-demand (VoD) services in the EU in the third quarter of 201218. 

72 hours of video are uploaded to YouTube every minute. 

8 

9 

10 
11 
12 
13 
14 

15 
16 
17 

Directive  2010/13/EU  of  the  European  Parliament  and  of  the  Council  of  10  March  2010  on  the 
coordination  of  certain  provisions  laid  down  by  law,  regulation  or  administrative  action  in  Member 
States concerning the provision of audiovisual media services (AVMSD), OJ L 95, 15.4.2010, p. 1–24. 
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), Official Journal L 178 , 17/07/2000, p 1- 16. 
E.g. Article 31 Universal Services Directive, spectrum policy, Article 6 Access Directive. 
http://ec.europa.eu/digital-agenda/en/creating-better-internet-kids. 
http://ec.europa.eu/information_society/media_taskforce/doc/pluralism/hlg/hlg_final_report.pdf. 
Eurostat 2012 Individuals - Mobile Internet access (isoc_ci_im_i). 
http://www.cisco.com/en/US/solutions/collateral/ns341/ns525/ns537/ns705/ns827/white_paper_c11-
481360_ns827_Networking_Solutions_White_Paper.html. 
International Video Federation Yearbook 2012. 
http://ec.europa.eu/internal_market/media/docs/elecpay/plum_tns_final_en.pdf. 
http://newsroom.cisco.com/press-release-content?type=webcontent&articleId=888280. 

EN 

4 

   EN 

 
                                                 
For  equipment  manufacturers  and  technology  developers,  opportunities  exist  to  serve  a 
growing  market  with  innovative  devices  including  user-friendly  interfaces  and  accessibility 
solutions. Network operators will see increased demand for bandwidth with a positive impact 
on investments in high-speed networks. Content creators can find new ways to maximise their 
audience,  monetise  their  works  and  experiment  with  creative  ways  to  produce  and  offer 
content. Broadcasters can find more platforms19 to distribute their content and enhance their 
interactive offerings. 

The key elements for this potential to materialise are familiar: a big enough market to grow, a 
competitive  environment,  a  willingness  to  change  business  models,  interoperability  and  an 
adequate infrastructure. To shape the future of media driven by the internet, Europe needs to 
put  those  elements  into  place  while  fostering  the  values  underpinning  the  regulation  of 
audiovisual media services. 

2.1.  Market considerations 

The EU is characterised by cultural and linguistic diversity which is a potential competitive 
advantage on the world market, but has also been considered a challenge in an environment 
characterised by network effects.  

Network effects in the media and internet world may lend a significant comparative advantage 
to operators and providers who operate legally in a borderless market enabling them to raise 
sizeable  budgets  and  take  advantage  of  economies  of  scale.  Entrants  who  offer  audiovisual 
content online without territorial access restrictions can turn the over 368 million EU internet 
users20  into  potential  viewers  and  thus  challenge  the  position  of  traditional  players.  This  is 
often the case of US players who address the EU’s fragmented market successfully.  

In  Europe,  the  consumer  experience  with  audiovisual  media  services  delivered  online  still 
remains  often  one  of  limited  choice  and  of  disabling  access  based  on  often  geographical 
delimitations.  Applications  in  smart  TV  sets  are  often  restricted  by  national  settings  and 
manufacturers’  pre-selected  choices  and  access  to  content  from  other  EU  countries  is  often 
blocked.21 

Technology will help to overcome these obstacles. Content producers, subtitle providers and 
researchers have started to create alliances to share the available language resources (e.g. the 
subtitle corpora22 held by producers) and tools23. 

Consumer experience of the future 

18 

19 

20 
21 

22 

23 

European  Audiovisual  Observatory;  all  platforms  considered:  pure  internet,  electronic  sell-through, 
videogame consoles, cable, IPTV, dedicated STB, smartphones, smart TVs, Push VoD (satellite, DTT) 
except apps in iTunes and in the Google Play App Store. Does not include: archives, trailers, TV series, 
adult, training, catch-up catalogues of film channels. 
Platforms  can  be  integrated  in  the  device  by  manufacturers  or  provided  by  other  players  such  as 
electronic communications and cable operators, over-the-top (OTT) players or broadcasters. 
http://www.internetworldstats.com/stats9.htm. 
Study on the economic potential of cross-border pay-to-view audiovisual media services TNS opinion, 
Plum,  the  futures  company  -  Study  prepared  on  behalf  of  the  European  Commission  –  January  2012 
http://ec.europa.eu/internal_market/media/elecpay/index_en.htm#maincontentSec1. 
Subtitling companies or film producers/distributors hold large corpora (databases) of subtitles, often in 
many different languages in parallel. This is very valuable raw material to develop customised machine 
translation systems. 
E.g. SUMAT (www.sumat-project.eu) and SAVAS (www.fp7-savas.eu) and the ICT Work Programme 
2013, page 47 http://cordis.europa.eu/fp7/ict/docs/ict-wp2013-10-7-2013-with-cover-issn.pdf. 

EN 

5 

   EN 

 
 
                                                                                                                                                         
a) A Polish student spending her Erasmus year in London can access all the audiovisual offers 
from  Polish  operators  with  her  Polish  credit  card  —  just  the  same  way  she  used  to  do  in 
Kraków, as Polish services are provided to London.  

b) Her flatmate is from the UK and is writing a thesis on works by Portuguese directors. He 
can  easily  access  material  from  Portuguese  audiovisual  content  providers.  The  flatmates 
frequently watch together sports events from various EU countries. 

The Green Paper on the online distribution of audiovisual works sought to shed more light on 
issues  mainly  related  to  copyright24.  The  Commission  will  publish  the  results  of  that 
consultation  in  2013.  In  December  201225,  the  Commission  re-affirmed  its  commitment  to 
work  for  a  modern  copyright  framework  and  agreed  on  two  parallel  tracks  of  action:  a 
structured stakeholder dialogue in 2013 to address a number of issues (including cross-border 
portability of content and access to audiovisual works) where rapid progress is needed;. and 
the completion of market studies, impact assessments and legal drafting work, with a view to 
a  decision  in  2014  whether  to  table  the  resulting  legislative  reform  proposals26..  Copyright 
matters will therefore not be covered in depth by this paper. 

From the supply point of view, the media world today is one of competition for the attention 
of  consumers.  Market  players  (e.g.  pay-TV  operators,  free  to  air  public  service  and 
commercial broadcasters, VoD distributors and device manufacturers) try to differentiate their 
offers  by  providing  premium  or  attractive  content,  including  on  an  exclusive  basis  or  user-
friendly interfaces. Increased content offer in terms of quantity and diversity is changing the 
entertainment landscape. 
In 200927, EU broadcasters invested around one third of their revenues in content. Out of the 
€34.5  billion  programme  spend  in  the  EU  by  broadcasters  approximately  €15.6  billion  was 
spent  on  acquiring  rights  –  €5.8  billion  on  sp orts  rights  and  €9.8  billion  on  film  and  TV 
acquisitions28.  Premium  content  (major  sport  events  and  successful  recently  released  films, 
so-called blockbusters) generates a high demand and significant revenues in the audiovisual 
sector.  BT's  participation  in  the  Premier  League's  tenders  for  the  television  rights  to  its 
football matches over the three seasons commencing in 2013/14 resulted in a record £ 3 bn, a 
71 %  increase29  over  the  previous  three-season  deal.  In  the  US,  Netflix  spend  an  estimated 
$ 4.8 bn buying streaming content in 2011/12.  

Success  may  depend  on  the  ability  to  consistently  offer  such  content  to  viewers.  While 
exclusive deals between platform operators and content providers have formed the basis for 
content producers to amortise their investments, they may also restrict the possibilities of third 
parties to provide such content to their audiences. These may constitute barriers to entry for 
new players.  

24 

25 
26 

27 

28 

29 

Green Paper on the online distribution of audiovisual works in the European Union: opportunities and 
challenges towards a digital single market, COM(2011) 427 final. 
Communication from the Commission on content in the Digital Single Market, COM(2012) 789 final. 
The  following  elements  will  be  addressed:  territoriality  in  the  Internal  Market;  harmonisation, 
limitations  and  exceptions  to  copyright  in  the  digital  age;  fragmentation  of  the  EU  copyright  market; 
and how to improve the effectiveness and efficiency of enforcement while underpinning its legitimacy 
in the wider context of copyright reform 
Report  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions. First Report on the Application of Articles 13, 16 
and  17  of  Directive  2010/13/EU  for  the  period  2009-2010:  Promotion  of  European  works  in  EU 
scheduled and on-demand audiovisual media services, COM/2012/0522. 
Final  study  on  the  implementation  of  the  provisions  of  the  Audiovisual  Media  Services  Directive 
concerning the promotion of European works in audiovisual media services, 13 December 2011. 
http://www.guardian.co.uk/media/2012/jun/13/premier-league-tv-rights-3-billion-sky-bt. 

EN 

6 

   EN 

 
                                                 
Moreover, when platforms reach a high popularity among users and become a key channel for 
content providers to reach audiences, the concern may arise that these platforms could favour 
certain  companies  or  their  own  services,  in  the  case  of  vertically  integrated  companies.  In 
addition,  these  platforms'  access  to  a  wide  range  of  user  data  may  give  them  an  additional 
competitive  advantage30.  Certain  Member  States  such  as  the  UK  have  assessed  the  need  to 
impose ex ante wholesale release obligations for access to live top-flight sports and first-run 
Hollywood movies, considered essential for competitors to be viable in business. 

EU  competition  rules  are  used  at  national  and  European  level  to  address  possible  abuses  of 
market  power  in  circumstances  where  a  company  holds  a  dominant  position  in  a  relevant 
market. In that context there is a need to ensure that a quick and effective market is possible in 
an increasingly converged world. 

The  Commission  has  intervened  on  several  occasions  to  ensure  competition  in  the  joint 
selling  of  sports  media  rights31.  It  has  accepted  remedies  in  the  context  of  merger  cases  to 
ensure that premium films and sports rights content remain accessible32. In this context, case 
law  of  the  Court  of  Justice  of  the  European  Union  (CJEU)  on  refusals  to  licence  can  be 
noted33. The refusal by a right holder enjoying a dominant position to give access to a product 
or  service  indispensable  for  carrying  on  a  particular  business  may  be  abusive  if  that  refusal 
prevents the emergence of a new product for which there is a potential consumer demand, that 
it is unjustified and such as to exclude any competition on a secondary market. Finally, in the 
Premier League case, the CJEU held that while EU competition law does not preclude a right 
holder from granting to a single licensee exclusive broadcasting rights over a sporting event in 
one  or  more  Member  States,  a  right  holder  cannot  prohibit  the  exclusive  licensee  from 
effecting any cross-border provision of services that relate the broadcasting of such a sporting 
event34. This is because such a prohibition would enable the licensee to be granted absolute 
territorial  exclusivity  in  the  area  covered  by  its  licence,  thereby  eliminating  all  competition 
between broadcasters and partitioning the internal market in accordance with the scope of the 
exclusive broadcasting rights. 

Competition-related  considerations  also  arise  with  regard  to  the  financing  of  public  service 
broadcasters. Public service broadcasters often extend their activities to the online world with 
applications or webpages. While some actors welcome this extension, others perceive this as a 
direct competition with their commercial offers, which do not benefit from public funding. In 
2009,  the  Commission  adopted  a  Communication  on  the  application  of  state  aid  rules  to 
public  service  broadcasters  in  the  light  of  new  technological  developments,  including  the 
multiplication  of  distribution  platforms  and  technologies.  The  Communication  requires  the 
introduction of an ex ante test. This involves a public consultation regarding significant new 
services  launched  by  public  service  broadcasters,  thus  allowing  the  Member  State  to  assess 
the impact of a new service on the market and to balance it against its value for society. 

30 
31 

32 
33 

34 

See also 3.1 on data protection. 
Case COMP/38.173 — Joint selling of the media rights to the FA Premier League Case, COMP//37.214 
— Joint selling of the media rights to the German Bundesliga, and COMP/37.398 — Joint selling of the 
commercial rights of the UEFA Champions League. 
Case COMP/M.2876 Newscorp//Telepiù. 
Case  C-418/01  IMS  Health,  C-418/01,  GmbH  &  Co.  OHG  v  NDC  Health  GmbH  &  Co.  KG  [2004] 
ECR I-5039. 
Joined Cases C-403/08 and C-429/08 Football Association Premier League Ltd & Others v QC Leisure 
&  Others  -  Karen  Murphy  v  Media  Protection  Services  Ltd,  judgment  of  4  October  2011.  See  also 
Commission  Communication  to  the  European  Parliament,  the  Council,  the  Economic  and  Social 
Committee and the Committee of the Regions ‘A coherent framework for building trust in the Digital 
Single Market for e-commerce and online services’ dated 11 January 2012, page 7. 

EN 

7 

   EN 

 
                                                 
QUESTIONS FOR PUBLIC CONSULTATION: 

(1) 

(2) 

What are the factors that enable US companies to establish a successful presence in 
the  fragmented  EU  market  despite  language  and  cultural  barriers,  while  many  EU 
companies struggle? What are the factors hindering EU companies? 

What  are  the  factors  affecting  the  availability  of  premium  content?  Are  there 
currently  practices  relating  to  premium  content  at  wholesale  level  which  affect 
market  access  and  sustainable  business  operations?  If  so,  what  is  the  impact  on 
consumers?  Is  there  a  need  for  regulatory  intervention  beyond  the  application  of 
existing competition rules? 

(3) 

Are there obstacles which require regulatory action on access to platforms? 

Financing models 

2.2. 
Progressive convergence, changing consumer behaviour35 and emerging new business models 
impact the financing of audiovisual production. 
The  formats  of  TV  programmes  and  series36  are  increasingly  traded  within  Europe  — 
sometimes adjusted to local tastes — and exported to other parts of the world37. There seems 
to be a potential for more cooperation on productions where language barriers are lower, e.g. 
programmes  for  children  or  documentaries.  In  addition  to  TV  shows  developed  by 
professional producers, user-generated content can also reach significant audiences, possibly 
integrated by broadcasters in their linear schedule. In addition, OTT players might offer their 
own series and live TV shows and acquire rights to premium content. 

Member States have developed various ways of promoting European works including diverse 
ways  of  facilitating  their  production,  financing  and  distribution  to  a  wider  audience.  The 
AVMSD sets mandatory percentages of European and independent works to be broadcast by 
EU  broadcasters.  For  non-linear  audiovisual  media  services,  the  obligation  to  promote 
European  works  is  formulated  more  flexibly  with  the  possibility  to  require  financial 
contributions  from  broadcasters  and  on-demand  service  providers  in  order  to  support  the 
production  of  European  works.  However,  while  Member  States  are  broadly  fulfilling  the 
current  legal  requirements,  they  are  concentrating  efforts  on  domestic  productions.  Non-
domestic European works only make up 8.1 %38 of broadcasting hours in the EU. 

The  trend  for  VoD  platforms  to  invest  in  original  content  shows  that  these  new  players  are 
potential  new  investors  in  audiovisual  content.  With  the  dynamic  rise  of  VoD  services  and 
given the current contribution of broadcasters to the production of European works, there are 
discussions  in  some  Member  States  regarding  the  contribution  to  financing  of  content  by 
internet-based  new  players  directly  involved  in  its  exploitation.  This  might  raise  specific 
issues regarding contributions from non-European players.  

35 

36 

37 

38 

Declining consumer expenditure on DVDs, -7.7 % from 2010 to 2011, with consumer spending on VoD 
growing by 20.1 % to a total of €
 1.2 bn. The European Video Yearbook, 2012, p. 7. Between 2008 and 
2010, UK  online video viewing  time  more  than doubled  to 31  minutes per day;  in France  it  grew  by 
104% to 24 minutes/day. Source: Cimscore. 
See  footnote  28:  According  to  the  study  on  the  implementation  of  the  AVMSD  on  promotion  of 
European  works,  during  the  period  2006-2008  the  export  of  formats  from  Europe  to  North  America, 
South  America  and  Asia  represented  5 084  broadcast  hours  and  the  intra-European  trade  in  formats 
amounted to 19 995 broadcast hours. The export of formats from Europe to North America amounted to 
2 213 hours compared to 8 363 hours from North America to Europe. 
Examples of formats exported globally and adapted locally include programmes such as ‘Who wants to 
be a Millionaire’ and ‘Deal or no deal’ and series such as ‘The Killing’ and ‘The Bridge’. 
See footnote 28. 

EN 

8 

   EN 

 
                                                 
QUESTIONS FOR PUBLIC CONSULTATION: 

(4) 

(5) 

Do the current AVMSD requirements provide the best way to promote the creation, 
distribution, availability and market appeal of European works? 

How  will  convergence  and  changing  consumer  behaviour  influence  the  current 
system  of  content  financing?  How  are  different  actors  in  the  new  value  chain 
contributing to financing? 

2.3. 

Interoperability of connected TV 

Connected TV devices and services depend on a variety of standards in the broadcasting, IT 
and  telecom  sectors39.  Convergence  reopens  the  question  which  approach  should  be  taken 
towards standardisation, bearing in mind both its advantages (allowing scale economies and 
interoperability) and its drawbacks (risk of freezing innovation). 

HbbTV  is  an  ETSI  standard  applied  by  a  number  of  broadcasters,  content  providers, 
networks  and  consumer  device  manufacturers  in  Europe40  to  link  broadcast  and  broadband 
content. One41 functionality of HbbTV is to trigger broadband content through the broadcast 
signal.  Another  approach  is  a  complete  platform  solution  where  broadcasters  and  network 
operators cooperate, such as in the UK example of YouView42. In Italy, mainly for historical 
reasons, the MHP43 standard is used for connected TV. 

It  appears  that  a  connected  TV  set  bought  in  one  Member  State  frequently  does  not  allow 
modification of its settings to receive services from other Member States44 and cannot respond 
to the trigger in a broadcast signal legitimately transmitted from another Member State. 

Some  manufacturers  may  configure  their  devices  to  limit  the  range  of  services  and 
applications 
that  can  be  accessed.  Some  Member  States  have  developed  national 
specifications  based  on  HbbTV.  In  some  cases,  applications  following  those  national 
specifications  are  not  fully  compatible  with  devices  in  other  countries.  Moreover,  in  some 
cases  specific  technical  mechanisms  (such  as  Digital  Rights  Management)  are  included  in 
devices  to  respond  to  expectations  of  national  players.  For  application  developers,  different 
standards mean that they need to re-author their products to different devices45. 

QUESTIONS FOR PUBLIC CONSULTATION: 

(6) 

Is  there  a  need  for  EU  action  to  overcome  actual  or  potential  fragmentation  and 
ensure  interoperability  across  borders?  Is  there  a  need  to  develop  new  or  updated 
standards in the market? 

39 

40 

41 

42 

43 

44 
45 

These  include  the  DVB  broadcasting  standards  and  the  internet  protocol  for  the  delivery  of  content. 
Others such as MPEG 25 and HTML-5 for content presentation may play an increasing role in future. 
According to the information available at the time of writing, HbbTV is already in regular operation in 
CZ,  DK,  FR,  DE,  NL,  PL,  ES  and  CH.  AT,  FI,  NO,  SE  and  TR  have  either  announced  plans  to 
introduce HbbTV or are carrying out trials. There is also interest outside Europe. 
There  are  also  network  operator  portals  and  manufacturer  portals  based  on  HbbTV  as  well  as 
independent applications. 
YouView was launched in July 2012 with its own eco-system of several companies working together. 
Like other vertical market platforms, it does not have a fully standardised architecture. 
MHP, or the Multimedia Home Platform, can be described as a set of instructions that tell the operating 
system  on  a  digital  TV  receiver  how  to  deal  with  an  interactive  TV  application  it  has  received. 
http://www.dvb.org/technology/fact_sheets/DVB-MHP_Factsheet.pdf. 
Discussed in meetings with stakeholders. 
Several players aim to address this issue e.g.: http://www.smarttv-alliance.org; Open IPTV Forum. 

EN 

9 

   EN 

 
                                                 
2.4. 

Infrastructure and spectrum 

Delivery  of  multiple  audiovisual  content  streams  in  ultra/high-quality  definition,  including 
parallel  usage  and  3D,  is  expected  —  even  with  improved  compression  technology  —  to 
increase  the  bandwidth  required  to  watch  content  over  the  internet  up  to  100  Mbps  and 
beyond.  The  Commission  has  set  out  a  comprehensive  policy  to  foster  the  development  of 
broadband in the Digital Agenda for Europe46 and proposed the Connecting Europe Facility to 
promote  targeted  infrastructure  investment  at  European  level47.  Moreover,  the  Commission 
recently  carried  out  a  public  consultation  on  specific  aspects  of  transparency,  traffic 
management and switching in an Open Internet48 and intends to provide further guidance on 
this matter. 

Dedicated spectrum has provided broadcasters with a valuable public resource to enable their 
own  and  others’  programme-making  activities.  However,  a  significant  net  benefit  was 
identified  in  reallocating  part  of  the  digital  dividend  realised  from  switching  off  analogue 
broadcast signal transmission — the 800 MHz band — to develop wireless broadband access 
in outlying regions. This was confirmed by the Radio Spectrum Policy Programme49, which 
set a target of 1200 MHz of spectrum for wireless broadband, putting even greater pressure on 
available spectrum resources. Spectrum resources can facilitate terrestrial and satellite-based 
delivery of audiovisual content as well as the interactive functionality necessary  for content 
delivery  and  supplementary  services.  Convergence  raises  the  issue  of  the  future  role  of 
terrestrial  broadcasting  in  the  provision  of  such  services.  Industry  actors  are  increasingly 
exploring  hybrid  models  combining  the  advantages  of  broadband  in  delivering  individual 
choice of on-demand content with the efficiency of broadcasting in making content (e.g. live 
sports or entertainment events) simultaneously available to a large audience. 

QUESTIONS FOR PUBLIC CONSULTATION: 

(7) 

(8) 

(9) 

How  relevant  are  differences  between  individual  platforms  delivering  content  (e.g. 
terrestrial  and  satellite  broadcasting,  wired  broadband  including  cable,  mobile 
broadband) in terms of consumer experience and of public interest obligations? 

What  frequency  allocation  and  sharing  models  can  facilitate  development 
opportunities  for  broadcasting,  mobile  broadband  and  other  applications  (such  as 
programme-making equipment) carried in the same frequency bands? 

What  specific  research  needs  with  regard  to  spectrum  have  to  be  addressed  to 
facilitate such development? 

3. 

VALUES 

The values that underpin the regulation of audiovisual media services in Europe have resulted 
in  rules  supporting  freedom  of  expression  and  media  pluralism,  the  promotion  of  cultural 
diversity50  protection  of  personal  data  as  well  as  the  protection  of  consumers,  including 
vulnerable  groups  such  as  minors  and  persons  with  disabilities.  The  challenge  is  to  foster 
respect for those values in a converged environment, via the appropriate policy choices. 

46 
47 
48 

49 
50 

http://ec.europa.eu/digital-agenda. 
https://ec.europa.eu/digital-agenda/en/connecting-europe-facility. 
http://ec.europa.eu/digital-agenda/en/line-public-consultation-specific-aspects-transparency-traffic-
management-and-switching-open 
https://ec.europa.eu/digital-agenda/node/118. 
This is an intrinsic value to be safeguarded in line with Article 167 TFEU. 

EN 

10 

   EN 

 
                                                 
3.1. 

Regulatory framework 

The main rationale for the regulation of audiovisual media services at EU level has been the 
Internal  Market,  with  the  country  of  origin  principle  at  its  core.  This  ‘single  European  TV 
market’  has  entailed  a  minimum  set  of  common  rules  covering  aspects  like  advertising, 
protection of minors and promotion of European audiovisual works. 

The technology-neutral approach of the AVMSD means that the same services are regulated 
in  the  same  manner  irrespective  of  the  device  on  which  they  are  consumed.  However,  the 
AVMSD  makes  a  distinction  between  linear  (television  broadcasts)  and  non-linear  (on-
demand51)  services,  based  on  the  much  higher  degree  of  consumer  control  in  on-demand 
services, justifying less stringent regulation in certain areas. 

The  AVMSD  rules  apply  only  to  media  service  providers.  The  definition  of  this  concept  is 
based on the notion of editorial responsibility52. For as long as a provider has responsibility 
for the choice of the content and determines the manner in which it is organised, its services 
are subject to the AVMSD even if the content is delivered over the internet. 

Linear and non-linear services will increasingly compete on the same screen, sometimes even 
offering over two delivery channels the same content for the attention of the same audience. 
With  new  forms  of  on-demand  content  that  seem  more  like  ‘lean-back’  linear  content,  the 
difference  between  linear  and  non-linear  services  from  the  consumer’s  point  of  view  might 
blur. If, in a converging world, linear and non-linear provision of similar content were to be 
treated  as being  in  competition, then  the current differences  in regimes could clearly  distort 
that  relationship.  On  the  other  hand,  if  the  degree  of  customer  control  remains  a  significant 
feature  for  users,  then  differentiated  regulation  would  retain  a  certain  logic.  This  requires 
policy  makers  to  reflect  on  the  ways  in  which  these  changes  will  affect  both,  consumers’ 
perceptions of the received service and the effectiveness of current tools. 

The  AVMSD  applies  only  to  providers  under  EU  jurisdiction.  When  delivered  via  satellite, 
audiovisual media services fall under the jurisdiction of a Member State if the satellite up-link 
is located in the Member State or the satellite capacity used is ‘appertaining to that Member 
State’53.  Those  rules  do  not  extend  to  content  delivered  over  the  internet  from  countries 
outside the EU, but targeting the EU.  

With media services from outside the EU increasingly accessible via the internet and satellite, 
efforts to establish jurisdiction over those services would imply an assessment of the need to 
address  overlapping  jurisdiction.  Similar  issues  are  under  discussion  in  the  field  of  data 
protection. 

The  provision  of  non-linear  services  is  also  subject  to  the  E-Commerce  Directive.  In  a 
converging  environment  the  relationship  of  this  Directive  with  the  AVMSD  becomes  more 
visible54.  This  is  also  the  case  for  data  protection  legislation,  as  the  processing  of  personal 
data is often the prerequisite for the functioning of new services, even though the individual is 

51 

52 

53 
54 

AVMSD  Article  1.1.g:  "on-demand  audiovisual  media  service"  (i.e.  a  non-linear  audiovisual  media 
service) means an audiovisual media service provided by a media service provider for the viewing of 
programmes at the moment chosen by the user and at his individual request on the basis of a catalogue 
of programmes selected by the media service provider. 
This means the natural or legal person who has editorial responsibility for the choice of the audiovisual 
content  of  an  audiovisual  media  service  and  determines  the  manner  in  which  it  is  organised  (Article 
1(1)(d) AVMSD). This excludes natural or legal persons who merely transmit programmes for which 
editorial responsibility lies with third parties. 
Art. 2(4) AVMSD. 
See in particular the “internal market clause” in Article 3 as well as Article 4 and Articles 6 – 8. 

EN 

11 

   EN 

 
                                                 
often  not  fully  aware  of  the  collection  and  processing  of  personal  data.  The  moment  data 
generated  during  the  consumption  of  audiovisual  media  services  relates  to  an  identified  or 
identifiable natural person, it is personal data, and as a consequence falls under the scope of 
the EU Data Protection Directive (95/46/EC)55. Another relevant regulatory area is consumer 
protection56.  

Given  the  global  and  complex  nature  of  the  internet,  self-regulation  seems  an  appropriate 
complement to the regulatory approach. In 2012, the Commission launched a process57 with 
enterprises  and  other  stakeholders  to  develop  a  code  of  good  practice  for  self-  and  co-
regulation exercises. This has led to the drafting of principles for better self- and co-regulation 
aiming at ensuring a greater effectiveness58. 

They  should  be  considered  as  a  benchmark  for  self-  and  co-regulation  processes  which  are 
already mentioned in the AVMSD59.  

In  a  progressively  converging  world,  media  literacy  becomes  also  important  for  audiences, 
irrespective  of  their  age.  The  Commission  has  developed  several  policy  strands  for  media 
literacy, beyond those included in the AVMSD60. Media literacy is understood as the ability 
to access the media, to understand and to critically evaluate different aspects of the media and 
media contents and to create communications in a variety of contexts61. 

QUESTIONS FOR PUBLIC CONSULTATION: 

(10) 

(11) 

Given convergence between media, is there evidence of market distortion caused by 
the  regulatory  differentiation  between  linear  and  non-linear  services?  If  yes,  what 
would  be  the  best  way  to  tackle  these  distortions  while  protecting  the  values 
underpinning the EU regulatory framework for audiovisual media services? 

Is there a need to adapt the definition of AVMS providers and / or the scope of the 
AVMSD,  in  order  to  make  those  currently  outside  subject  to  part  or  all  of  the 
obligations of the AVMSD or are there other ways to protect values? In which areas 
could emphasis be given to self/co-regulation? 

(12)  What would be the impact of a change of the audiovisual regulatory approach on the 

country of origin principle and therefore on the single market? 

55 

56 

57 

58 

59 
60 
61 

Directive  95/46/EC  of  the  European  Parliament  and  of  the  Council  of  24  October  1995  on  the 
protection of  individuals  with  regard  to  the  processing of  personal  data and on  the free  movement  of 
such data OJ L 281, 23.11.1995, p. 31–50 
E.g.  Directive  2005/29/EC  on  Unfair  Commercial  Practices  protects  consumers  from  misleading  or 
aggressive  marketing,  and  ensures  that  any  claim  made  by  traders  in  the  EU  is  clear,  accurate  and 
substantiated; and the Directive 2011/83/EU on Consumer Rights regulates several areas of consumer 
rights, harmonising some of them. Information on digital products to be downloaded or viewed online, 
for example, will have to carry clear information on interoperability and functionality. 
Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic and Social Committee and the Committee of the Regions, A renewed EU strategy 2011-14 
for 
http://eur-
681 
lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0681:FIN:EN:PDF. 
https://ec.europa.eu/digital-agenda/en/news/principles-better-self-and-co-regulation-and-establishment-
community-practice. 
Article 4.7. 
Article 33. 
Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European 
Economic  and  Social  Committee  and  the  Committee  of  the  Regions  "A  European  approach  to  media 
literacy in the digital environment" COM(2007)833final. 

Responsibility, 

COM(2011) 

Corporate 

Social 

final, 

EN 

12 

   EN 

 
                                                 
(13) 

Does  increased  convergence  in  the  audio-visual  landscape  test  the  relationship 
between the provisions of the AVMSD and the E-Commerce Directive in new ways 
and in which areas? Could you provide practical examples of that? 

(14)  What  initiatives  at  European  level  could  contribute  to  improve  the  level  of  media 

literacy across Europe? 
3.2.  Media freedom and pluralism62 

Media  freedom  and  pluralism  are  enshrined  in  Article  11  of  the  Charter  of  Fundamental 
Rights of the European Union. The AVMSD63 and competition rules, at both EU and national 
level, contribute to sustaining media pluralism. 

Through  the  internet,  citizens  have  access  to  an  unparalleled  amount  of  information  and 
content  beyond  national  offerings  and  can  participate  in  opinion  making.  This  facilitates 
freedom of expression and enhances pluralism of opinions. 

At  the  same  time,  ways  how  people  relate  to  information  change.  Filtering  mechanisms, 
including  personalised  search  results,  make  it  more  likely  for  people  to  receive  the  news  in 
their area of interest, and from a perspective with  which they  agree. On the  one hand, such 
filtering  and  personalisation  mechanisms  have  a  clear  potential  for  empowering  citizens,  by 
allowing them to navigate efficiently through the information overload that characterises the 
digital  environment  and  to  receive  tailor-made  services  corresponding  to  their  individual 
needs.  On  the  other  hand,  this  may  decrease  the  role  of  the  media  as  editors  in  the  public 
sphere and strengthen the role of platform providers, for example online companies. The latter 
may  not  only  determine  what  content  is  accessible  but  can  also  impact  choices,  e.g.  by 
varying the prominence with which certain content is displayed, limiting the citizen’s ability 
to change the menu or restricting certain applications. This could influence the de facto choice 
for  citizens  to  access  media  offerings  representing  a  plurality  of  opinions  and  can  lead  to  a 
situation where citizens potentially find themselves in a vulnerable situation without realising 
it.  The  availability  of  various  platforms  providing  valuable  content  to  users,  as  well  as  the 
openness of those platforms, is an important condition for a thriving media landscape. 

Member States may impose reasonable must-carry obligations on network operators, for the 
transmission of specified broadcast channels to the public, if a significant number of viewers 
use  such  networks  as  their  principal  means  to  access  these  channels64.  In  circumstances, 
where the ability to reach audiences is dependent on scarce transmission resources, this is a 
way  to  ensure  the  provision  of  specified  channels  when  the  availability  of  content  is 
considered by Member States to be necessary for general interest objectives. In the broadband 
environment, transmission capacity is less of a constraint on the choice of content available to 
viewers.  

The accessibility of ‘general interest content’, including in the online environment, might be 
limited in practice by business decisions, such as those of equipment manufacturers and/or by 

62 

63 

64 

Please note also public consultations regarding media freedom and pluralism http://ec.europa.eu/digital-
agenda. 
The  AVMSD  supports  media  pluralism  by  allowing  audiovisual  media  services  to  freely  circulate 
within the single market, based on the country of origin principle and e.g. through article 14. This — 
together with the specific rules on the promotion of European works — supports media pluralism. 
Art  31  of  the  Universal  Service  Directive  2002/22/EC  as  amended  by  the  Citizen's  Rights  Directive 
2009/136/EC. 

EN 

13 

   EN 

 
                                                 
the  operators  of  the  platforms  that  can  be  accessed  via  this  equipment  or  indeed  by  content 
providers themselves65. 

Member  States  may  also  specify  digital  broadcasting  services  to  which  access  must  be 
ensured and National Regulatory Authorities can impose obligations on operators to provide 
access to electronic programme guides (EPGs)66. 

Even if content is accessible, finding ‘general interest content’ in an enhanced multichannel 
environment can be a potential challenge for viewers. Therefore Member States have also the 
possibility  to  impose  obligations  in  relation  to  the  presentational  aspects  of  electronic 
programme guides and similar listing and navigation facilities67. 

QUESTIONS FOR PUBLIC CONSULTATION: 

(15) 

Should the possibility of pre-defining choice through filtering mechanisms, including 
in search facilities, be subject to public intervention at EU level? 

(16)  What should be the scope of existing regulation on access (art. 6 Access Directive) 
and  universal  service  (art.  31  Universal  Service  Directive)  in  view  of  increasing 
convergence of linear and non-linear services on common platforms? In a convergent 
broadcast/broadband environment, are there specific needs to ensure the accessibility 
and the convenience to find and enjoy 'general interest content'? 

3.3. 

Commercial communications 

The  AVMSD  sets  limits  in  transmission  time  for  broadcast  advertising,  such  as  12  minutes 
per  hour,  and  lays  down  criteria  relating  to  the  advertising  of  certain  products  as  well  as 
advertising  in  relation  to  minors.  Qualitative  rules  apply  similarly  to  both  linear  and  non-
linear services, while quantitative rules apply only to linear services. In view of the increasing 
competition between linear and non-linear services and the fact that non-linear services might 
be provided by providers not subject to EU jurisdiction, European broadcasters fear that such 
an asymmetry puts them at a disadvantage. 

In  the  context  of  convergence,  some  innovative  advertising  techniques  put  existing  rules  to 
the test. The Commission was informed about concerns regarding commercial overlays68 over 
broadcasters’  linear  services  and  the  question  whether  this  could  challenge  the  essential 
purpose of advertising regulation, in particular whether such overlays could be shown with or 
without the consent of users and broadcasters. Disguised commercial communications in the 
online environment could also present challenges.  

Personalisation  of  content  offers  can  benefit consumers and advertisers,  but  may  depend  on 
tools  posing  challenges  for  personal  data  protection.  European  data  protection  rules69  can 
increase  consumer  trust  in  innovative  business  models  which  is  the  stated  objective  of  the 
Commission  proposals  for  a  reform  of  the  EU  regulatory  framework  submitted  in  January 

65 

66 
67 
68 
69 

In the case of digital television equipment, Article 24 of the Universal Service Directive could be used 
to  ensure  interoperability.  Annex  VI  currently  ensures  e.g.  that  signals  transmitted  in  the  clear  are 
displayed on devices capable of descrambling scrambled broadcasts. 
Art 5 (1b) of the Access Directive 2002/19/EC as amended by Directive 2009/140/EC. 
Art 6 (4) of the Access Directive 2002/19/EC as amended by Directive 2009/140/EC. 
Visual elements that appear on the screen during a broadcast. 
ePrivacy Directive and the proposed Data Protection Regulation amending the current Data Protection 
Directive. 

EN 

14 

   EN 

 
                                                 
201270.  The  advertising  industry  has  introduced  a  self-regulatory71  system  for  online 
behavioural  advertising,  which  in  the  future  might  be  extended  to  cover  video  adverts  in 
addition to display adverts. Industry standardisation initiatives such as Do Not Track (DNT)72 
should also be taken into account. 

QUESTIONS FOR PUBLIC CONSULTATION: 

(17)  Will the current rules of the AVMSD regarding commercial communications still be 
appropriate when a converged experience progressively becomes reality? Could you 
provide some concrete example? 

(18)  What  regulatory  instruments  would  be  most  appropriate  to  address  the  rapidly 
changing advertising techniques? Is there more scope for self/co-regulation?  

(19)  Who should have the final say whether or not to accept commercial overlays or other 

novel techniques on screen? 

3.4. 

Protection of minors 

The continuum of content across the differently regulated linear and non-linear transmission 
channels weakens the impact of the current regulatory regime for linear on children’s access 
to  content.  Effective  age  verification,  also  for  adolescents'  access  to  content,  remains  a 
challenge. Differences in the regulatory approach to different types of content on screen might 
moreover make it difficult for users to determine which authorities to complain to73.  
In  ‘A  European  Strategy  for  a  Better  Internet  for  Children’  launched  in  May  201274,  the 
Commission  argues  that  more  quality  content  should  be  developed  for  children  and  that 
children should also be protected when they go on the internet. 31 leading companies across 
the value  chain have  signed  up  to  a  Coalition to  develop, through a self-regulatory process, 
appropriate  measures  for  five  key  actions:  i)  simple  and  robust  reporting  tools  for  users;  ii) 
age-appropriate privacy settings; iii) wider use of content classification; iv) wider availability 
and use of parental control; and v) effective removal of child abuse material. Some of these 
actions relate to the AVMSD and could be supported by amending the legislation. Collective 
results  and  engagements  were  made  public,  including  recommendations  for  best  practices. 
Companies  have  produced  individual  statements  regarding  the  implementation  of  those 
recommendations. The Commission will continue to engage with the Coalition as a platform 
for discussing progress through 2013. 

QUESTIONS FOR PUBLIC CONSULTATION: 

(20) 

(21) 

70 

71 

72 

73 
74 

Are  the  current  rules  of  the  AVMSD  appropriate  to  address  the  challenges  of 
protecting minors in a converging media world? 

Although  being  increasingly  available  on  devices  and  platforms  used  to  access 
content, take-up of parental control tools appears limited so far. Which mechanisms 
would be desirable to make parents aware of such tools? 

COM(2012)11  –  Regulation  of  the  European  Parliament  and  of  the  Council  on  the  protection  of 
individuals  with  regard  to  the  processing  of  personal  data  and  on  the  free  movement  of  such  data 
(General Data Protection Regulation). 
A  cross-European  self-regulatory  Framework 
http://www.iabeurope.eu/news/self-regulation-framework.aspx. 
A  global  DNT  standard  would  describe  the  technical  details  of  a  ‘signal’  that  users  can  send  to 
providers via their online equipment, including their web browser. The signal indicates their preferences 
regarding tracking. http://blogs.ec.europa.eu/neelie-kroes/donottrack/. 
An example where this issue is addressed is ParentPort. 
http://europa.eu/rapid/pressReleasesAction.do?reference=IP/12/445. 

for  Online  Behavioural  Advertising 

(OBA): 

EN 

15 

   EN 

 
                                                 
(22)  What  measures  would  be  appropriate  for  the  effective  age  verification  of  users  of 

online audiovisual content? 

(23) 

(24) 

(25) 

Should  the  AVMSD  be  modified  to  address,  in  particular,  content  rating,  content 
classification and parental control across transmission channels? 

Should  users  be  better  informed  and  empowered  as  to  where  and  how  they  can 
comment or complain concerning different types of content? Are current complaints 
handling mechanisms appropriate? 

Are the means by which complaints are handled (funding, regulatory or other means) 
appropriate to provide adequate feedback following reports about harmful or illegal 
content,  in  particular  involving  children?  What  should  be  the  respective  roles/ 
responsibilities  of public  authorities, NGO's and providers of products and services 
in  making  sure  that  adequate  feed-back  is  properly  delivered  to  people  reporting 
harmful or illegal content and complaints? 

3.5. 

Accessibility for persons with disabilities 

Technology  offers  more  possibilities  to  assist  visually,  hearing  and  cognitively  impaired 
persons than ever before. However, these opportunities may be lost if accessible content, i.e. 
subtitles,  sign  language  or  audio-description,  is  not  produced  or  not  made  available  to  end 
users.  

The AVMSD already obliges Member States to encourage media service providers to make 
their  services  gradually  accessible  to  people  with  visual  or  hearing  disabilities.  The 
implementation  of  this  provision  by  Member  States  varies  considerably.  Accessibility 
services can be included in ‘must carry’ obligations imposed by Member States. 
The  Commission  has  presented  a  proposal  for  a  Directive  on  web  accessibility75  and  is 
exploring  how  to  further  improve  the  situation  of  accessible  goods  and  services  in  the  EU 
market  and  establishing  general  accessibility  requirements  in  the  forthcoming  European 
Accessibility  Act.  The  adoption  of  a  European  Standard  covering  also  audiovisual  issues 
related to accessibility is expected by the end of 2013. 

QUESTIONS FOR PUBLIC CONSULTATION: 

(26) 

Do you think that additional standardisation efforts are needed in this field? 

(27)  What incentives could be offered to encourage investment in innovative services for 

people with disabilities? 

4. 

NEXT STEPS 

All interested parties are invited to comment on the ideas raised in this Green Paper, including 
by responding to the specific questions listed, to the following address: 

CNECT-CONVERGENCE-AV@ec.europa.eu 

European Commission 

Directorate- General for Communications Networks, Content and Technology 

Unit G1 

75 

Proposal for a Directive of the European Parliament and of the Council on the accessibility of public 
sector bodies' websites COM(2012) 721 final. 

EN 

16 

   EN 

 
                                                 
Office BU25 05/181 

B- 1049 -Brussels 

In  this  context,  the  Commission  may  organise  or  participate  in  meetings  with  stakeholders, 
including  industry,  consumers,  investors,  Members  of  the  European  Parliament  and  the 
Council. 

Please submit your comments by 31/08/2013. Contributions received will be published on the 
DG  CONNECT  website  unless  a  contributor  requests  otherwise.  It  is  important  to  read  the 
specific privacy statement attached to this consultation for information on how your personal 
data and contribution will be dealt with. 

EN 

17 

   EN